COMMONWEALTH OF MASSACHUSETTS
Plymouth, ss.
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
CIVIL ACTION DOCKET NO. 11-1260
______________________________________________________________________
Phillip Ofume (self and on behalf his family) Plaintiff (Pro se & Forma Pauperis)
v.
Massachusetts Department of Transitional Assistance (DTA)
Defendant
________________________________________________________________________
PLAINTIFF (SELF AND ON BEHALF HIS FAMILY), PHILLIP OFUME'S VERIFIED MOTION AND MEMORANDUM FOR SUMMARY JUDGMENT
________________________________________________________________________
A. STATEMENT OF MOTION/BRIEF ANALYSIS
Now comes the Plaintif, Phillip Ofume (self and on behalf his family) and respectfully moves for Summary Judgment because of Defendant's claim that it can not grant Plaintiff Application for Food Stamp and TAFDC because of lack of personal trust of who they are and the official documents they have even if they are US citizens, qualified noncitizen, refugees, asylee, etc families with children without assets or income. Defendant, Department of Transitional Assistance (DTA) is an agency of the Commonwealth of Massachusetts and provider of FOOD STAMP/SNAP and Transitional Aid to Families with Dependent Children (TAFDC) particularly, it provides cash assistance and food stamp to US citizens, qualified noncitizen, refugees, asylee, etc families with children without assets or income. Plaintiff and his family are US citizens, qualified noncitizen, refugees, asylee, etc families with children without assets or income and their daily/monthly income is $0.00.
In further support of this Verified Motion, Plaintiff relies on his Verified Memorandum of Law, Evidence, and fact, etc.
B. MEMORANDUM
Per Decision ( EXHIBIT "A") of the Hearing Officer, Mr. John F. Welan dated February 1, 2012 herewith attached as EXHIBIT A of the administrative hearing on January 11, 2012, the Defendant or its representatives (hereinafter, "White male hearing officer and female DTA caseworker") suspected be carrying longstanding animosities against Plaintiff and his family allege, surfing facebook, twitter and other internet sources is better than physical evidence of document signed and issued by the approved officials of the United States of America, Commonwealth of Massachusetts, United Nations High Commission for Refugees (UNHCR), etc shamefully denied Plaintiff and his family's application for food stamp and TAFDC by trump up profile claim based on personality preference without reference to the authentic official evidence or documents mentioned above because of the following reasons:
(a) that they cannot provide food stamp and TAFDC to a female Black child who is a Citizen of the United States of American born at Salem, MA Hospital on November 25, 2006 with parents and siblings suffering under $0.00 because they don't trust her Original Birth Certificate, Social Security Card, School Records, etc. Action of the Defendant has created further irreparable damage such as Court Eviction Notice under politically issued tracking record as XTrack with swift Summary Proceedings and urgently returnable for February 29, 2012 at 8.30 a.m. (SOUTH EAST HOUSING COURT, BROCKTON SESSION). EXHIBITS
;
(b) that they cannot provide food stamp and TAFDC to the two Black parents of the Black Child mentioned in (a) above who are foreign convention refugees/asylees because they don't trust their Refugees Certificates issued by the United Nations High Commission for Refugees (UNHCR), Receipts for Application for Permanent Residence and Adjust Status, Social Security Cards, two months (July and August 2011) pay stubs, and they continue to demand for more and more pay stubs etc;
(c) that they cannot provide food stamp and TAFDC to three Black children born in Canada who are riders on parents refugees and asylee status because they don't trust parents' Refugees Certificates issued by the United Nations High Commission for Refugees (UNHCR), their Receipts for Application for Permanent Residence and Adjust Status, Social Security Cards, two months (July and August 2011) pay stubs and they continue to demand for more and more pay stubs, etc.
(d) that they can not provide food stamp and TAFDC to two Black children born in Nigeria who are riders on parents refugees and asylee status because they don't trust parents' Refugees Certificates issued by the United Nations High Commission for Refugees (UNHCR), their own Receipts for Application for Permanent Residence and Adjust Status, two months (July and August 2011) pay stubs, etc.
Summary Judgment should be granted against agency's allegations and breach of statute because the Defendant's own testimony shows that Defendant received all the citizen, noncitizen, refugees, asylees and other eligibility or qualified applicants for FOOD STAMP/SNAP and TAFDC but because of the color, race, nationality, etc of the Plaintiff and his family agency or defendant was short of trust and denied their application because the agency's hearing officer is lay and lacks immigration law training to understand 212(a)(7)(A)(i)(I) to use the valid unexpired immigrant entry document required by the Immigration and Nationality Act, and a valid unexpired passport, or other suitable travel document which Plaintiff's political opponents paid US Immigration and Custom Enforcement (ICE) to impound and seize Plaintiff and his family's to bring fake charge under 212(a)(7)(A)(i)(I).
On September 29, 2005 in accordance with INA Plaintiff and his children and wife landed in the United States with valid unexpired immigrant entry document required by the Immigration and Nationality Act, and a valid unexpired passport, or other suitable travel document but politically ICE impounded and seized these valid and unexpired documents (EXHIBITS ). On January 25, 2006 the disclosure Order of The Presiding Honourable Justice Eliza Klein exposed US ICE as corrupt agency and when the documents were disclosed shame overwhelmed ICE and it was discovered that Plaintiff and his family landed in the United States with valid unexpired immigrant entry document required by the Immigration and Nationality Act, and the United Nations Convention of July 28, 1951. EXHIBITS
Since October 2011 the monthly income of this large family is $0.00 because they are waiting for the Commissioner of the USCIS Nebraska Service Center to hear their Application for the renewal of their Employment Authorization Documents (EAD) since January 2011 and Appeal on Unemployment Benefit which one child who worked for over one year filed with the Massachusetts Department of Unemployment Assistance (DUA), Boston MA.
1. The Plaintiffs, Phillip Ofume and his family, respectfully moves for summary judgment. The
Defendant alleges that they denied Food Stamp and TAFDC because they have no trust on and believe that the Plaintiff and his family are US citizens, qualified noncitizen, refugees, asylee, etc families with children without assets or income ($0.00) and that they must be provided the assistance which they have provided for others.
2. That Defendant disbelieve all Plaintiff's and family's official documents issued to them by the governments of the United States (I-94, Social Security Cards, Proof of failure of the immigration charge and parole falsified by ICE and brought under INA 212(a)(7)(A)(i)(I), Receipt and Refugee waiver on Plaintiff and family's application for Permanent Resident and Adjust Status, Biometric Test Receipts and Waiver, etc) and Commonwealth of Massachusetts/Agencies/Other Service Providers (Mass ID, Proof of Residence of Mass, School Records, Birth Certificate, etc); United Nations High Commission for Refugees (UNHCR - Certificates of Refugees to two parents and all the children were added as riders and certificates of Prisoner of Conscience issued with cash award by the Amnesty International, Intl. Secretariat, London, UK); government of Canada (United Nations Refugees Travel Document, Birth Certificates, Visa); etc.
3. The Defendants used all the official documents listed on paragraph 2 above to provide Food Stamps and TAFDC to other people or applicants and Plaintiff requires four-year full disclosure of the documents used by the defendants to grant whites and non-whites food stamps and TAFDC and recipients must be issued subpoena to appear before this Court in person.
4. Defendant, caseworker agreed that Plaintiff provided to her two months (July and August 2011) pay check stubs and Defendant's Hearing Officer said, " We need only four weeks" but Plaintiff and his family provided more than required. Defendant's decision contradicts the transcript of the hearing (EXHIBIT A) which Plaintiff has ordered by personal submission to the Office of the Hearing Officer.
5. Summary judgment should be granted on allegations of breach of equity in delivery of these services to the people of America; failure to use official documents which were signed, sealed and personally delivered by the officials of the government of America, United Nations High Commission for Refugees, government of Canada, government of the Commonwealth of Massachusetts, etc.; mistrust of all the documents submitted by the Plaintiff and his family on ground of race and color; hidden agenda such as refusal to take physical official documents issued by the approved officials, agencies and authorities mentioned above and fall back to NOTHING such as surfing facebook, twitter and other internet or unreliable computer generated information to grant Blacks services whereas defendant used fewer of the physical documents which Plaintiff and his family submitted to grant whites Food stamps and TAFDC.
C. UNDISPUTED FACT
For the purposes of this motion, the following facts areundisputed:
6. At present daily/monthly income of the Plaintiff and his family is $0.00. Because of the fact that under daily/monthly $0.00 income of a family of nine (9) persons (seven children and two parents) there is eminent danger of starvation, death and related harm if this family is not provided with Food Stamps and TAFDC which defendant provides including minimum humanitarian assistance pending issuance of USCIS's EMPLOYMENT AUTHORIZATION DOCUMENT (EAD) and employment.
7. That under the Constitution and Bill of Rights of the Commonwealth of Massachusetts and United States of America thus, to save the lives of this family, social services (food stamp and TAFDC) which Defendant provides US citizens, qualified noncitizen, refugees, asylee, etc families with children without assets or income must be provided to the Plaintiff and his family because they are based on the official documents issued to them by the governments of the United States (I-94, Social Security Cards, Proof of failure of the immigration charge and parole falsified by ICE and brought under INA 212(a)(7)(A)(i)(I), Receipt and Refugee waiver on Plaintiff and family's application for Permanent Resident and Adjust Status, Biometric Test Receipts and Waiver, etc) and Commonwealth of Massachusetts/Agencies/Other Service Providers (Mass ID, Proof of Residence of Mass, School Records, Birth Certificate, etc); United Nations High Commission for Refugees (UNHCR - Certificates of Refugees to two parents and all the children were added as riders and certificates of Prisoner of Conscience issued with cash award by the Amnesty International, Intl. Secretariat, London, UK); government of Canada (United Nations Refugees Travel Document, Birth Certificates, Visa); etc.
8. There is serious case of racial discrimination and preferential treatment because recently majority of the major US and international media aired OCCUPY WALL STREET ET AL PROTESTS and Americans and world heard American Whites confessions against the highhanded racial discrimination of the Defendant (DTA and related social services providers across the United States). In these confessions majority said, "I applied for food stamps and TAFDC with only my state ID Card and I was approved and given heavy food stamps and alot of cash benefits which I don't need because I am working and I have no dependant family members that will help me use the food stamps...what I did was to give cash to charities and buy foods and give them to the soup table and food bank..."
9. Defendant, Department of Transitional Assistance (DTA) is an agency of the Commonwealth of Massachusetts and provider of FOOD STAMP/SNAP and Transitional Aid to Families with Dependent Children (TAFDC) particularly, it provides cash assistance and food stamp to US citizens, qualified noncitizen, refugees, asylee, etc families with children without assets or income.
10. Reliant on paragraphs 1- 4 above, Plaintiff and his family filed COMPLAINT SEEKING EMERGENCY TEMPORARY INJUNCTIVE RELIEF FOR CONTINUATION OF TAFDC/FOOD STAMP BENEFITS AND PAYMENT OF UNPAID BENEFITS TO NEEDY FAMILIES WITH CHILDREN PURSUANT TO M.G.L. c. 18 sec. 2 (A)(D); 1st , 4th , 5th and 14th Amendments to the Constitution and Bill of Rights of the United States; Humanitarian Ground with direct reference to Snyder v. Phelps and Public Interest; particularly the present conditions ($0.00) of the Plaintiff and his family. Two Appeals made in March 2011 and May 2011, DTA’s Hearing Office refused to hear the appeals and also refused to grant benefits including emergency benefits. Because of this Complaint and to delay and punish this family, lately January 11, 2012 the Defendant conducted deceitful hearing and during the hearing each time Plaintiff wants to made important argument and statement of facts, the Hearing Officer will turn off the take and pretended to be recalling documents and requesting for something through the defendant's case worker which are not relevant to Plaintiff submissions.
11. In this defendant's office in Brockton on October 20 & 21, 2005 the first transitional assistance application made in the United States was made in this office and denied with all the documents which Plaintiff submitted to them then the casework was Mr. John. After similar administrative hearing also under $0.00 income, in April 2006 Plaintiff appealed administrative decision to the Superior Court, Lawrence, MA and Plaintiff's petition was presided over by woman Honourable Justice. Before the first Motion Day in May 2006, Defendant (DTA) rushed to grant food stamp and cash benefit and unpaid November/December 2005, January, February, March and April 2006 was paid to Plaintiff. During the closing of the appeal, The Presiding Hon. Justice warn Defendant in Declaratory Statement, "Right to Benefits depends on Immigration Status" (DTA ( SUPERIOR COURT, LAWRENCE, MA - Ofumes v. DTA Civil Docket No. ESCV2006-00381)
12. Defendant and its caseworker received copies of the receipts and refugee waiver on Plaintiff and family's application for Permanent Resident and Adjust Status, Biometric Test Receipts and Waiver, etc); documents and materials issued by the Commonwealth of Massachusetts/ Agencies/Other Service Providers such as Mass ID, Proof of Residence of Mass, School Records, Birth Certificate, lease, etc); documents and material issued by the United Nations High Commission for Refugees such as UNHCR - Certificates of Refugees to two parents and all the children were added as riders and certificates of Prisoner of Conscience issued with cash award by the Amnesty International, Intl. Secretariat, London, UK; documents and material issued by the government of Canada such as United Nations Refugees Travel Document, Birth Certificates, Visa; documents issued etc. Under oath, the defendant and its casework
13. Action of the Defendant has created further irreparable damage such as Court Eviction Notice under politically issued tracking record as XTrack with swift Summary Proceedings and urgently returnable for February 29, 2012 at 8.30 a.m. (SOUTH EAST HOUSING COURT, BROCKTON SESSION). EXHIBITS
C. ARGUMENT
Plaintiff's Complaint mentioned in paragraph 10 above was served on the Defendant since November 2011 but it failed to oppose the Complaint which maybe seen as no contest position in this case. This delay has created further irreparable damage such as Court Eviction Notice under politically issued tracking record as XTrack with swift Summary Proceedings and urgently returnable for February 29, 2012 at 8.30 a.m. (SOUTH EAST HOUSING COURT, BROCKTON SESSION).
THEREFORE, summary judgment should be granted where there are no material facts in dispute and the moving party is entitled to judgment as a matter of law. Cassesso v. Commissioner of Correction, 390 Mass. 419, 422 (1983); Community National Bank v.Dawes, 369 Mass. 550, 553 (1976); Mass. R. Civ. P. 56c. The moving party bears the burden of affirmatively demonstrating the absence of a triable issue, and that the moving party is entitled to judgment as a matter of law. Pederson v. Time, Inc., 404 Mass. 14, 16-17 (1989).
Where the party moving for summary judgment does not have the burden of proof at trial, this burden may be met by either submitting affirmative evidence that opposes an essential element of the opponent’s case, or by “demonstrating that proof that such element is unlikely to be forthcoming at trial.” Flesner v. Technical Communications Corp., 410 Mass. 805,809 (1991); Kourouvacilis v. General Motors Corp., 410 Mass. 706, 716 (1991). Once the moving party establishes the absence of a triable issue, the party opposing the motion must respond and allege specific facts establishing the existence of a material fact in order to defeat the motion.
I. SUMMARY JUDGMENT SHOULD BE GRANTED IN PARAGRAPHS 1, 2, 3,4, ,5 , 6 AND 7 OF THE PLAINTIFF'S COMPLAINT BECAUSE THE DEFENDANT HAS NO KNOWLEDGE OF THE PROOF OF VERIFICATION REQUIRED UNDER COMMONWEALTH OF MASSACHUSETTS REGULATIONS (C.M.R.)
Under 106 C.M.R.§§ 361.550, 361.600, 930 Defendant see Plaintiff and his family as Blacks and because of this profiled problem, all verification requirements were met and orderly but defendant disbelieved and expanded bias judgment and denied them food stamp and TAFDC against the weight of CMR to the extent that pay check stubs which it claimed that two months or eight(8) weeks pay stubs are not sufficient, CMR requested for only four (4) weeks and nothing for applicants who just started work,
"Proof of earned income – such as copies of wage stubs (usually the last four weeks, unless you just started working), direct deposit bank statements, or a statement from your employer about your earnings. 106
C.M.R. §§ 361.610(A), 363.210(G)(1)"
Refugee and Asylee statues were adequately established and further established with UNHCR Refugee Certificate of Adoption issued to two parents of the Ofume family. Order of Hon. Justice Eliza Klein which compel the Government of America to disclose Plaintiff's and his family's valid and unexpired Refugees Travel Documents and Passports issued to them under United Nations Convention of July 28, 1951 which are the valid immigration documents required by Foreign Convention Refugees to flee persecution oversea and land into the United States of America. Defendant's Caseworker and Hearing Officer have wasted public fund to allow this case to drag on and on to this Court because of lack of the knowledge of the CMR, INA and United Nations Convention of July 28, 1951 which define process of determination of the status and rights of Refugees.
Statement of Motion and paragraphs 1 to 11 above, between Plaintiff and Defendant's Caseworker, the following Pre-hearing and hearing Questions and Answer took place:
Q. Do you know the Plaintiff's wife, Mrs. Maureen Ofume and how?
A. Yes, she came to my office fill out application forms for food stamp and TAFDC.
Q. Did Mrs. Ofume give you pay stubs and how many?
A. Yes, she gave pay stubs for July 2011 and August 2011
Q. That's for how many weeks and how months pay stubs are required under CMR?
A. Don't know. I received pay stubs for eight(8) weeks
Hearing Officer & Plaintiff
Q. How weeks pay stub would applicant requires to submit to the DTA in support of application for food stamp and TAFDC?
A. Last four(4) weeks
Caseworker/Plaintiff
Q. According to the Hearing Officer, last four (4) weeks, why is that you did not grant Plaintiff application for food stamps and TAFDC?
A. Last four(4) weeks. I denied Maureen's Application because I was not able to verify her documents on internet.
Q. Did Mrs. Ofume give you her own and family's original and copies of their US immigration and residence documents such as Refugee Certificates for Dr. Phillip C. Ofume and Mrs. Maureen Ofume, 1-94 for all the family members, Birth Certificates, Social Security Cards, Massachusetts Identification Cards, Lease, Utility Bills, etc.
A. Yes.
Q. Did you take copies of these documents?
A. Yes.
Q. What reason do you have after receiving these documents and denied Mrs. Ofume and his family's application for food stamp and TAFDC?
A. I told you that I could not verify these documents on Internet because I searched for them through google, yahoo and DHS and I could not find them.
Q. Do you use internet to verify other applications?
A. I cannot talk about other people's application because of privacy rules.
Q. Do you know that Virginia (Richmond) and DTA Salem, MA granted the Ofume family food Stamp and TAFDC with the same US immigration and residence documents such as Refugee Certificates for Dr. Phillip C. Ofume and Mrs. Maureen Ofume, 1-94 for all the family members, Birth Certificates, Social Security Cards, Massachusetts Identification Cards, Lease, Utility Bills, etc. ?
A. Yes
Q. What reason do you have to deny her application if your sub-regional office in Massachusetts and other US state used the same documents to grant their application?
A. I denied Maureen application and if other states and Massachusetts sub-office approved them that's their business...my business is different.
M.G.L. c. 18 sec. 2 (A)(D) did not dictate these ugly actions of the Defendant because without this intolerance the law empowering the services of Defendant is well made but political interest has distorted this good law and it speaks for itself as follows:
“Section 2. (A) The department shall provide and administer throughout the commonwealth a comprehensive transitional assistance financial assistance program, including the following services: the provision of financial assistance to those in economic needs and the determination of eligibility for the categorical public assistance provided under the Federal-State programs;
… and other forms of financial assistance to families and individuals as needed.
In order that said services be adapted, organized and coordinated to meet the needs of certain population groups, each community service center shall provide financial assistance programs for:
(a) families, children and unmarried parents, which program shall, among other objectives, serve to assist, strengthen and encourage family life for the protection and care of children, assist and encourage the use by any family of all available resources to this end;…
(d) provide the range of transitional assistance financial assistance services on a fair, just and equitable basis to all people in need of such services;
(D) Subject to appropriation, the department shall administer a program of emergency assistance to needy families with children and pregnant woman with no other children, subject to and in accordance with the provisions of the Social Security Act of 1935, as defined in 42 USC 606(e), to provide benefits to avoid destitution or to provide living arrangements in a home. The commonwealth shall accept matching funds from the appropriate federal authorities for said program.
Said program of emergency assistance shall assist eligible families to prevent destitution or to provide living arrangements in the home.
The department shall promulgate rules and regulations to establish the levels of benefits available under the program and to ensure simplicity of administration in the best interest of needy recipients. Such benefits shall include, but not be limited to, the following:—
(a) for the prevention of the loss of housing, the actual liability up to three times the monthly rental or mortgage liability;
(b) for the prevention of utility shutoffs or for the resumption of utility services, up to three months of the actual service liabilities;
(c) for the provision of home heating assistance, up to three months of the actual fuel liabilities.
The department shall promulgate regulations which would authorize the department to make payments for a fourth month of rent, utility or fuel arrearages if the commissioner certifies in writing that the family would otherwise become homeless, or be without utilities or fuel.
(d) for the prevention of homelessness, temporary shelter as necessary to alleviate homelessness when such family has no feasible alternative housing available, up to the maximum period subject to federal reimbursement; storage of furniture for up to thirty days; moving expenses of up to one hundred and fifty dollars; advance rent payments of one month’s rent; and security deposit not to exceed one month’s rent.
The department shall establish procedures, consistent with federal law, to require applicants for the program to also submit an application for federal energy assistance where appropriate. No benefits for a particular emergency shall be provided to an applicant family under the emergency assistance program when benefits are available within seven days of application under the federal assistance program to meet such particular emergency.
A needy family shall be eligible for assistance under the emergency assistance program if its income is within the income limits for the program of aid to families with dependent children established pursuant to chapter one hundred and eighteen.
Emergency assistance shall not be granted to a family who, at any time within one year immediately prior to the filing of an application for emergency assistance, has made an assignment or transfer of real or personal property for the purpose of becoming eligible for such assistance.”
D. CONCLUSION
Summary judgment should be granted because the Defendant's caseworker and hearing officers are lay and know nothing about CMR, INA and United Nations Convention of July 28, 1951 which define process of determination of the status and rights of Refugees and they blindfolded by the cloud of race and color. Further Order of this Court is required to send Defendant to under a parole in terms race relation sensitivity training. Defendant to grant food stamp and TAFDC and interest and arrears starting from April 2011 through present and receipt of Employment Authorization Document (EAD) and Employment.
E. RELIEF
WHEREFORE, Plaintiff and his family respectfully requests that the court grant
this Motion for Summary Judgment.
VERIFICATION OF MOTION/MEMORANDUM IN SUPPORT OF PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
I, Phillip Ofume, Plaintiff, one of the parents and representative of the Ofume family hereby respectfully verify, sign and submit the foregoing Motion for Summary Judgment and/or that the foregoing facts and evidence are true and correct under the pains and penalties of perjury.
_______________________
Dr. Phillip C. Ofume & Co. 506 Warren Avenue #2 Brockton, MA 02301 Tel. 781-479-9027 E-mail: limptintinc@gmail.com
P.O. Box 2416 Lynn, MA 01903
Tel. (781) 479-9027,
E-mail: limptintinc@gamail.com
To:
Clerk/Magistrate of the Court (Civil Sessions)
Plymouth County Superior Court
72 Belmont St.
Brockton, MA 02301
Contact information and other particulars of the Defendant:
Massachusetts Department of Transitional Assistance (DTA)
c/o The Honourable Secretary of Justice and Attorney-General of
the commonwealth of Massachusetts
Department of Justice (Litigation)
One Ashburton Place
Boston, MA 02108 -1518
Phone: (617) 727-2200
Further copies to:
President Barack H. Obama
President of the United States of America
1600 Pennsylvania Avenue, NW
Washington, DC 20500
Vice- President Joseph Biden,
Washington Office:
Eisenhower Executive Office Bldg.
Washington, DC 20501
Honourable Eric H. Holder, Jr.
US Secretary of Justice and Attorney General,
9
OFUME V. DTA
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Office of the Assistant Attorney General, Main
Washington, D.C. 20530
The Chief of Immigration Judge
The Assistant Chief of Immigration Judge
OFFICE OF THE CHIEF IMMIGRATION JUDGE
5107 Leesburg Pike, Suite 2500
FALLS CHURCH,
Virginia, USA 22041
Ms. Mary Patrice Brown, Acting Counsel
Office of Professional Responsibility
950 Pennsylvania Avenue, N.W., Suite 3266
Washington, D.C. 20530
His Excellency, High Commissioner
United Nations High Commission for Refugees (UNHCR)
Headquarters,
Geneva, Switzerland
His Excellency, High Commissioner
United Nations High Commission for Human Rights (UNHCHR)
Headquarters,
Geneva, Switzerland
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