Amended Answer; Amended Answer to First Amended Complaint; Answer

     [||c2f5afb8-2aba-4927-9205-45839509efe6||] IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

RICHARD GORDON HATCHER, et al., 

Plaintiffs, 

Vv. CiV H 77-154 

METHODIST HOSPITAL OF GARY, 

INC. , et Aal1l., 

Defendants. 

  

AMENDED ANSWER 
  

Defendant Joseph Califano, Secretary of Health, Education 

and Welfare (hereinafter sometimes referred to as the federal 

defendant) by his undersigned attorneys hereby responds to 

the Complaint as follows: 

First Defense 
  

The complaint fails to state a claim upon which relief 

can be granted. 

Second Defense 
  

Defendant Califano asserts that the Court should not exer- 

cise its jurisdiction at the present time under the Doctrine of 

Primary Jurisdiction. 

Third Defense   

In answer to the numbered paragraphs of the Complaint, 

the federal defendant admits, denies and alleges as follows: 

l. This paragraph contains plaintiffs' characterization 

of its action to which no answer is required, but insofar as 

an answer may be deemed required, deny. 

2. This paragraph contains conclusions of law and not 

, averments of fact to which an answer is required, but insofar 

as an answer may be deemed required, admit, and defendant 

Califano specifically avers that this Court should not exercise 

its jurisdiction under the Doctrine of Primary Jurisdiction.  



RA » 
3. The first four sentences of this paragraph contain 

  

plaintiffs' characterization of this action to which no answer 

is required, but insofar as an answer may be deemed required, 

deny. The remainder of the paragraph contains conclusions of 

law and not allegations of fact to which an answer is required, 

but insofar as an answer may be deemed required, deny. 

4. Admit the first and third sentences. The federal defen- 

dant is without knowledge or information sufficient to form a 

belief as to the truth or falsity of the allegations contained 

in the second and fourth sentences. The federal defendant 

denies the allegation contained in the fifth sentence, and is 

without sufficient knowledge or information to form a belief as 

to the truth or falsity of the fifth sentence as to the other 

defendants. The sixth sentence is a conclusion of law and not 

an allegation of fact to which an answer is required, but insofar 

as an answer may be deemed required, the federal defendant is 

without sufficient knowledge or information to form a belief as 

to the truth or falsity of the sixth sentence. 

5. The federal defendant admits the first sentence and 

the second sentence to the extent that Plaintiff Page has 

required and does require hospital treatment. The federal 

defendant is without sufficient knowledge or information 

to form a belief as to the truth or falsity of the remainder of 

the second sentence and the entire third sentence. The fourth 

sentence is a conclusion of law and not an allegation of fact 

to which an answer is required, but insofar as an answer may 

be deemed required, the federal defendant is without knowledge or 

information sufficient to form a belief as to the truth or falsity 

of the allegations contained in the fourth sentence. 

6. Deny the last sentence. The federal defendant is with- 

out knowledge or information sufficient to form a belief as to 

the truth or falsity of the remaining allegations.  



4 » 
7. Deny first sentence except to admit that Methodist 

  

Hospital of Gary, Inc. is not a not-for profit corporation orga- 

nized under the laws of the State of Indiana which currently 

operates a 165-bed facility in Merriville, and affirmatively 

alleges that HEW figures from November 1976 show that the 

hospital operates a 385-bed facility in the City of Gary. Deny 

the second sentence except to admit that Methodist Hospital of 

Gary, Inc. is a recipient of federal funds under the Hill-Burton 

Act and the Medicare and Medicaid programs. Admit the third 

and fourth setences. Deny the fifth sentence. Deny the sixth 

sentence. 

8. Admit, 

9. Admit, except to affirmatively state that the Health 

Facilities, Services and Review Development Division is called 

the Health Facilities, Services and Resource Development Bureau 

and the other division of the State Agency is the Health Resources 

Development Division. 

10. Admit, except to affirmatively state that the Health 

Facilities, Services and Review Development Division, is called 

the Health Facilities Services. 

11. Admit. 

12. Admit. 

13. Admit the first sentence. The federal defendant is 

without information or knowledge sufficient to form a belief 

as to the truth or falsity of the allegation in the second 

sentence, 

14. Deny the first sentence except to admit that Broadway 

Methodist Hospital is located in Merriville, Lake County, 

Indiana, approximately fifteen miles south of Gary Methodist 

Hospital. Admit the second sentence. The federal defendant 

is without knowledge or information sufficient to form a belief 

as to the truth or falsity of the remaining allegations.  



© » 
15. Admit the first sentence. The federal defendant is 

  

without sufficient knowledge or information to form a belief as 

to the truth or falsity of the allegations in the second sen- 

tence. 

16. The federal defendant admits that the Broadway facility 

located in Merriville, Indiana, has a small minority population 

and that the linear acceleration is located only at Broadway. 

The federal defendant is without knowledge and information suffi- 

cient to form a belief as to the truth or falsity as to the 

remaining allegations in paragraph 16 (a) through (4d), inclusive. 

17. Deny and affirmatively allege that Methodist Hospital 

of Gary, Inc. received a grant of $1,152,527, a guarantee on a 

loan of $14,336,193.12 and an interest subsidy of $6,032,555.54. 

18. Deny. The federal defendant affirmatively BE that 

it performed no civil rights review of Project 189 prior to 

avarding the Hill-Burton grant of $1,152,527. There was no national 

requirement by HEW that a pre-grant civil rights review be made 

and no national guidelines were established for discretionary 

reviews. The September 5, 1973, endorsement on the loan 

guarantee and interest subsidy for Project 189 was given after 

Methodist Hospital of Gary, Inc. agreed to sign the Civil Rights 

Assurances of July 27, 1973. 

19. Admit first sentence. Deny second sentence and 

affirmatively allege that the 1976 application requested 

$3,281,370 for a health services building at Gary, $3,599,800 

for a health services building at Merriville, and $1,262,200 

for a laundry at Merriville which will serve both facilities. 

20. Admit. 

21. Admit. 

22. Admit the first sentence. Deny the second sentence 

except to admit that a letter from Mr. Clarence Wood raised the 

issue of inferior health care to the poor and minority persons  



© *» 
of Gary. Deny the last two sentences and respectfully refer 

  

the Court to the letter from Alfred Sanchez dated October 21, 

1976, with attachments labelled Hill-Burton Applications of 

the Methodist Hospital, Inc. for a full statement of its 

terms and qualifications. 

23. Admit the first sentence. The federal defendant is 

without sufficient knowledge or information to form a belief 

as to the truth or falsity of the second sentence. 

24. Deny and affirmatively allege that HEW is presently 

conducting a civil rights compliance review and that under the 

Doctrine of Primary Jurisdiction, HEW should be allowed to 

complete that review prior to a judicial determination by this 

Court. 

25. The federal defendant is without sufficient knowledge 

or information to form a belief as to the truth or falsity 

as to the allegations contained in this paragraph. 

26. The federal defendant denies this paragraph and affir- 

matively alleges, with respect to subparts (a), (b), (cc), (4), 

(e), and (i), that the federal defendant is presently conducting 

a civil rights compliance review pursuant to its authority 

under Title VI of the Civil Rights Act. 

27. The federal defendant is without kneulsdne or informa- 

tion sufficient to form a belief as to the truth or falsity 

of the allegations contained in this paragraph. 

28. The federal defendant is without knowledge or informa- 

tion sufficient to form a belief as to the truth or falsity of 

the allegations contained in this paragraph. 

29. This paragraph contains plaintiffs' prayer for relief 

to which no answer is required. 

The federal defendant hereby specifically denies all of 

the allegations of the complaint not hereinbefore otherwise 

answered.  



  

OF COUNSEL: 

MARVIN G. GAVIN 

Regional Attorney 

EDWARD L. KOVEN 

Assistant Regional Attorney 
Department of Health, 
Education and Welfare 

300 South Wacker Drive 
18th Floor 

Chicago, Illinois 

JEFFREY CHAMPAGNE 

U.S. Department of Health, 
Education and Welfare 

® 
Respectfully submitted,. 

a Mth (Bn bo Seton samp 

BARBARA ALLEN BABCOCK 

Assistant Attorney General 

  

  

FRED W. GRADY 

Assistant United States Attorney 

td [5 C& MHptleT 
BARBARA B. O'MALLEY 
  

Ortluesea 2 (toss 
REBECCA IL. ROSS 

Lon O Collar, 
ANN F. COHEN 

  

  

  

S Sunaa foe 
CATHY $. SURACE b vo 

Attorneys for Defendant 
Attorneys, Department of Justice 
Washington, D.C. 20530 
Telephone: (202) 739-4267 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., 

Plaintiffs, 

Vv. CIV 'H 76-3173 

METHODIST HOSPITAL OF GARY, 
INC., et al., 

Defendants. 

  

AMENDED ANSWER TO FIRST AMENDED COMPLAINT 
  

Defendant Joseph Califano, Secretary of Health, Education 

and Welfare (hereinafter sometimes referred to as the federal 

defendant) by his undersigned attorneys hereby responds to the 

Complaint as follows: 

First Defense 
  

The complaint fails to state a claim upon which relief 

can be granted. 

Second Defense 
  

Defendant Califano asserts that the Court should not exer- 

cise its jurisdiction at the present time under the Doctrine of 

Primary Jurisdiction. 

Third Defense 
  

In answer to the numbered paragraphs of the Complaint, 

the federal defendant admits, denies and alleges as follows: 

l. This paragraph contains plaintiffs’ shavacterization 

of its action to which no answer is required, but insofar as 

an answer may be deemed required, deny. 

2. This paragraph contains conclusions of law and not 

averments of fact to which an answer is required, but insofar as 

an answer may be deemed required, admit, and defendant Califano 

specifically avers that this Court should not exercise its juris- 

diction under the Doctrine of Primary Jurisdiction.  



  

3. The federal defendant admits the first sentence and 

the second sentence to the extent that plaintiff Terry has 

required use of hospital facilities, including emergency room 

treatment. The federal defendant is without information or 

knowledge sufficient to form a belief as to the truth or fal- 

sity of the remaining allegations in the second sentence. The 

third sentence is a conclusion of law and not an allegation + 

of fact to which an answer 1s required, but insofar as an 

answer may be deemed required, the federal defendant is without 

information or knowledge sufficient to form a belief as to the 

truth or falsity of the allegations of the third sentence. 

4., The first two sentences of this paragraph contain 

plaintiffs' characterization of this action to which no answer 

is required, but insofar as an answer may be deemed required, 

deny. The remainder of the paragraph contains conclusions of 

law and not allegations of fact to which an answer is required, 

but insofar as an answer may be deemed required, deny. 

5. Deny first sentence except to admit that Methodist 

Hospital of Gary, Inc. is a not-for-profit corporation orga- 

nized under the laws of the State of Indiana which currently 

operates a 1l65-bed facility in Merriville and affirmatively 

allege that HEW figures from November 1976 show that the hos- 

pital operates a 385-bed facility in the city of Gary. Deny 

the second sentence except to admit that Methodist Hospital 

of Gary, Inc. is a recipient of federal funds under the Hill- 

Burton Act and the Medicare and Medicaid programs. The third 

and fourth sentences are admitted. 

6. Admit 

7. Admit 

8. Admit first sentence. Deny second sentence except to 

admit that Gary is the largest city in Lake County. Deny second 

sentence and affirmatively allege that although Gary had a 

 



population of 175,415 according to the 1970 census, it has a 

  

population of 167,546 according to the 1975 census, and further 

affirmatively state that in 1970 the population of the City 

of Gary was 52.8% Black and 9.4% Hispanic. 

9. The federal defendant is without knowledge or informa- 

tion sufficient to form a belief as to the truth or falsity of 

the allegation contained in the first sentence. Admit the 

second sentence. Admit the third sentence. The federal defen- 

dant lacks knowledge or information sufficient to form a belief 

as to the truth or falsity of the allegations contained in the 

fourth sentence. Admit the last sentence. 

10. The federal defendant admits that the Broadway facility 

is located in Merrillville, Indiana, which has a small minority 

population, that the linear accelerator is located only at 

Broadway, and that the Merrillville facility consists of 165 

beds. The federal defendant is without knowledge or information 

sufficient to form a belief as to the truth or falsity of the 

remaining allegations in the first three sentences. The federal 

defendant admits the fourth sentence. 

11. The federal defendant admits the first sentence. The 

federal defendant is without information or knowledge sufficient 

to form a belief as to the truth or falsity of the allegations 

contained in the second sentence. 

12. The federal defendant is without information or know- 

ledge sufficient to form a belief as to the truth or falsity of 

the allegations contained in this paragraph. 

13. Deny and affirmatively allege that Methodist Hospital 

of Gary, Inc. received a grant of $1,152,527, a guarantee on a 

loan of $14,336,193.12, and an interest subsidy of $6,032,555.54. 

l4. Deny. The federal defendant affirmatively alleges that it 

performed no civil rights review of Project 189 prior to award- 

ing the Hill-Burton grant of $1,152,527. There was no national  



requirement by HEW that a pre-grant civil rights review be made 

  

and no national guidelines were established for discretionary 

reviews. The September 5, 1973, endorsement on the loan 

guarantee and interest subsidy for Project 189 was given after 

Methodist Hospital of Gary, Inc. agreed to sign the Civil Rights 

Assurances of July 27, 1973. 

15. Admit first sentence. Deny second sentence and affir- 

matively allege that the 1976 application requested $3,281,370 

for a health services building at Gary, $3,599,800 for a health 

services building at Merriville, and $1,262,200 for a laundry 

at Merriville which will serve both facilities. 

16. Admit the first sentence. Deny the second sentence 

except to admit that a letter from Mr. Clarence Wood raised 

the issue of inferior health care to the poor and minority 

persons of Gary. Sony the last two sentences and respectfully 

refer the Court to the letter from Alfred Sanchez dated 

October 21, 1976, with attachment labeled Hill-Burton Applica- 

tions of the Methodist Hospital, Inc. for a full statement of 

its terms and qualifications. 

17. Admit the first sentence. The federal defendant is 

without knowledge or information sufficient 40 form a belief 

as to the truth or falsity of the allegations contained in the 

second sentence. 

18. Deny. The federal defendant affirmatively avers that 

HEW 1s presently conducting a civil rights compliance review. 

and that under the Doctrine of Primary Jurisdiction HEW should 

be allowed to complete that review prior to a judicial deter- 

mination by this Court. 

19. The federal defendant is without knowledge or informa- 

tion sufficient to form a belief as to the truth or falsity 

of the allegations contained in this paragraph.  



  

20. The federal defendant denies this paragraph and 

affirmatively alleges that the federal defendant is presently 

conducting a civil rights compliance review pursuant to its 

authority under Title VI of the Civil Rights Act. 

21. This paragraph contains plaintiffs’ prayer for relief 

to which no answer is required. 

The federal defendant hereby specifically denies all of 

the allegations of the Complaint not hereinbefore otherwise 

answered. 

OF COUNSEL: 

MARVIN G. GAVIN 

Regional Attorney 

EDWARD L. KOVEN 

Assistant Regional Attorney 
Department of Health, 

" Education and Welfare 
300 South Wacker Drive 
18th Floor 

Chicago, Illinois 

JEFFREY CHAMPAGNE 

U.S. Department of Health, 
Education and Welfare 

Respectfully submitted, 

SARBARA ALLEN BABCOCK 
Assistant Attorney General 

  

  

FRED W. GRADY 

Assistant United States Attorney 

gi 

Bets RB. GC’ pele 
BARBARA B. O'MALLEY 
  

Oo WeL0 2113 }0sS 
REBECCA L. ROSS 

Lorn lle... 
ANN F. COHEN 

  

  

>. 
CATHY SURACE 

Attorneys for Defendant 
Attorneys, Department of Justice 
Washington, D.C. 20530 
Telephone: (202) 739-4267  



  

CERTIFICATE OF SERVICE 
  

I hereby certify the copies of the foregoing Amended 

Answer in CIV H 77-154 and the Amended Answer to the First 

Amended Complaint in CIV H 76-373 were served upon the 

following counsel of record: 

by one-day express mail to: 

Ms. Beth Lief 

10 Columbus Circle 

New York, New York 10019 

Mr. Julian Allen 
2009 Broadway 

Gary, Indiana 46407 

Mr. Bruce Sayers 
Hodges, Davis, Greenberg, 

Compton & Sayers 
5525 Broadway 

Gary, Indiana 46401 

Mr. Michael Schaefer 

Assistant Attorney General of 
Indiana 

219 State House 

Indianapolis, Indiana 46204 

Mr. Edward L. Koven 

Assistant Regional Attorney 
Department of H.E.W. 
300 South Wacker Drive 
18th Floor 

Chicago, Illinois 

by first class mail to: 

Ms. Marilyn G. Rose 
1757 NM Street, N.W. 

Washington, D.C. 20036 

Jeff Champagne 
Department of H.E.W. 
Office of Civil Rights 
General Counsel 
330 Independence Ave., S.W. 
Washington, D.C. 20201 

Jim Hinchman 
Department of H.E.W. 

Office of General Counsel 
200 Independence Ave., S.W. 
Washington, D.C. 20201 

Lorn A_Ceon 
  

ANN F. COHEN 

 



  

IN "THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  

RICHARD GORDON HATCHER, et al., 

  

Plaintiffs, 

v. Civil'No. HB 77-154 | 

METHODIST HOSPITAL OF GARY, INC., 

et al., 

Defendants. 

/ 

ANSWER : 

Defendant Joseph Califano, Secretary of Health, Education 

and Welfare (hereinafter sometimes referred to as the federal 

defendant) by his undersigned attorneys hereby responds to the 

Complaint as follows: 

First Defense   

Plaintiffs have failed to exhaust their administrative 

remedies. 

Second Defense   

The Court lacks jurisdiction over the subject matter of 

the action. 

Third Defense   

The complaint fails to state a claim upon which relief 

can be granted. 

Fourth Defense   

In answer to the numbered paragraphs of the Complaint, 

the federal defendant admits, denies and alleges as follows: 

1. This paragraphs contains plaintiffs' characterization 

Of its action to which no answer is required, but insofar as 

an answer may be deemed required, deny. 

2. This paragraph contains conclusions of law and not 

averments of fact to which an answer is required, but insofar 

as an answer may be deemed required, deny. 

h 
3 

 



  

3. The first four sentences of this paragraph contain 

plaintiffs' characterization of this action to which no answer 

is required, but insofar as an answer may be deemed required, 

deny. The remainder of the paragraph contains conclusions of 

law and not allegations of fact to which an answer is required, 

but insofar as an answer may be deemed required, deny. 

4. Admit the first and third sentences. The federal 

defendant is without knowledge or information sufficient to 

form a belief as to alte truth or falsity of the allegations 

contained in the ‘second and fourth sentences. Deny the fifth 

and sixth sentences. 

5. The federal defendant is without knowledge or infor- 

mation sufficient to form a belief as to the truth or falsity 

of the allegations contained in the first, second and third 

sentences. Deny the fourth sentence. 

6. Bony the last sentence. The federal defendant is 

without knowledge or information sufficient to form a belief 

as to the truth or falsity of the remaining allegations. 

7. Deny first sentence except to admit that Methodist 

Hospital of Gary, Inc. is a not-for profit corporation orga- 

nized under the laws of the State of Indiana which currently 

operates a 1l65-bed facility in Merriville, and affirmatively 

allege that HEW figures from November 1976 show that the hos- 

pital operates a 385-bed facility in the city of Gary. Deny 

the second sentence except to admit that Methodist Hospital 

of Gary, Inc. is a recipient of federal funds under the Hill- 

Burton Act and the Medicare and Medicaid programs. Admit the 

third and fourth sentence. Deny the fifth sentence. Admit the 

sixth sentence. 

8. Admit. 

9. Admit, except to affirmatively state that the Health 

Facilities, Services and Review Development Division is called 

 



  

the Health Facilities, Services and Resource Development Bureau 

and the other division of the State Agency is the Health Resources 

Development Division. 

10. Admit, except to affirmatively state that the 

Health Facilities, Services and Review Development Division 

is called the Health Facilities Services. 

11. The federal defendant is without knowledge or infor- 

mation sufficient to form a belief as to the truth or falsity 

of this allegation. 

12. Admit. 

13. Admit the first sentence. The federal defendant 

is without information or knowledge sufficient to form a belief 

as to the truth or falsity of the allegation in the second 

sentence. 

14. Deny the first sentence except to admit that Broadway 

Methodist Hospital is located in Merrillville, Lake County, 

Indiana, approximately fifteen miles south of Gary Methodist 

Hospital. Admit the second sentence. The federal defendant 

is without knowledge or information sufficient to form a belief 

as to the truth or falsity of the remaining allegations. 

15. Admit the first sentence. Deny the second sentence. 

16. Deny except to admit that the Broadway facility 

located in Merriville, Indiana has a small minority population 

and that the linear acceleration is located only at Broadway. 

The federal defendant is without knowledge and information 

sufficient to form a belief as to the truth or falsity of the 

allegations concerning the location of handicapped persons in 

South Lake County. 

17. Deny and affirmatively allege that Methodist Hospital 

of Gary, Inc. received a grant of $1,152,527, a guarantee on a 

loan of $14,336,193.12 and an interest subsidy of 56,032,555.54. 

18. Deny. 

i 
a 

 



  

12. Admit first sentence. Deny second sentence and 

affirmatively allege that the 1976 application requested 

$3,281,370 for a health services building at Gary, $3,599,800 

for a health services building at Merriville, and $1,262,200 

for a laundry at Merriville which will serve both facilities. 

20. . Admit. 

21. Admit. 

22. Admit the first sentence. Deny the second sentence 

except to admit that-a letter from Mr. Clarence Wood raised 

the issue of inferior health care to the poor and minority 

persons of Gary. Deny the last two sentences and respectfully 

refer the Court to the letter from Alfred Sanchez dated 

October 21, 1976 with attachments labelled Hill-Burton 

Applications of the Methodist Hospital, Inc. for a full 

statement of its terms and qualifications. 

23. Admit the first sentence. Deny the second sentence. 

24. Deny and affirmatively allege that none of the named 

plaintiffs wrote objections to HEW. 

25. Deny. 

26. Deny. 

27. Deny. 

28. Deny. 

29. This paragraph contains plaintiffs' prayer for re- 

lief to which no answer is required. 

The federal defendant hereby specifically denies all of 

the allegations of the complaint not hereinbefore otherwise 

answered. 

Respectfully submitted, 

A A 
re a A 7) rn ol es 
  

BARBARA ALLEN BABCOCK 7 
Assistant Attorney General 

  

RICHARD 1... KIESER - 
rT gd 3 wha a = - i a a hr 

United stares AttorneV 

 



  

OF COUNSEL: 

JEFFREY CHAMPAGNE, 

U.S. Department of Health, 
Education and Welfare 

MARVIN G. GARVIN 

Regional Attorney 

EDWARD IL. KOVEN 

Assistant Regional Attorney 
Department of Health, 

Education and Welfare 

300 South Wacker Drive 

18th Floor 

Chicago, Illinois 

  

FRED W. GRADY 

Assistant United States Attorney 

C28 £ Fail 
~"DENNIS G. LIND 

AL en: wa gr i 
REBECCA L. ROSS 

Attorneys for Defendant 
Attorneys, Department of Justice 
Washington, D.C. 20530 

Telephone: 739-4267 

  

  

 



  

CERTIFICATE OF SERVICE 
  

I certify that a copy of Defendants Answer has 

— A 
been served this 4 L day of July. 1977 by mailing 

  

postage prepaid to: 

Ms. Beth Lief 

Mr. Jack Greenberg 
Mr. Melvyn Leventhal 
10 Columbus. Circle 
New York, New York 10019 

Mr. Julian Allen 
2009 Broadway 
Gary, Indiana 46407 

Ms. Marilyn G.. Rose 
Ms. Christine B. Hickman 

1787 X Street, N.W. 
Washington, D.C, 20036 

Mr. Bruce E. Sayers 
Hodges, Davis, Greenberg, Compton 

& Sayers 
5525 Broadway 
Gary, Indiana 46401 

Kipton Kaplan 

Executive Director, Northern Indiana 
Comprehensive Health Services Agency, 
Inc. 

900 East Colfax Avenue 
South Bend, Indiana 46617 

Michael Schaefer 
Assistant Attorney General 

of Indiana 

219 State House 

Indianapolis, Indiana 46204 

Ce i te 
  

EBECCA™L.. ROSE [||c2f5afb8-2aba-4927-9205-45839509efe6||]