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Agenda 12/16/2008 Item #16F 2 Agenda Item No. 16F2 December 16, 2008 Page 1 of 14 EXECUTIVE SUMMARY Recommendation to approve a Certificate of Public Convenience and Necessity for the Collier County Emergency Medical Services Department. OBJECTIVE: That the Board of County Commissioners approve the renewal of the Certificate of Public Convenience and Necessity ("Certificate") for the Collier County Emergency Medical Services Department and authorize the Chairman to execute the pennit and certificate. CONSIDERATIONS: Collier County Emergency Medical Services is currently operating under a Certificate. Collier County Ordinance No. 04-12, as amended requires that Collier County Emergency Medical Services renew its original Certificate each year. In addition, renewals are based on the same standards as the granting of the original Certificate. Therefore, the requirements for Board of County Commissioners approval in granting certificates, as set forth in the Collier County Ordinance No. 04-12, as amended, Section 5, are provided and are specifically addressed in the attached memorandum from the EMS Chief. Furthermore, Collier County Ordinance No. 04-12, as amended, Section 10 does not require a hearing for the Board of County Commissioners to consider the renewal Ccrtifieate allowing it to be approved routinely by the Board of County Commissioners upon advice of the Administrator. - In accordance with Collier County Ordinance No. 04-12, as anlended, Section 10, the Director of the Bureau of Emergency Services Division recommends approval based on his finding that there is a public necessity for EMS to provide the service based on the factors set forth therein. FISCAL IMPACT: There is no fiscal impact associated with this action. GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this action. LEGAL CONSIDERA nONS: The Permit and renewal Certificate have been signed for legally sufficiency. Although this itcm is quasi-judicial, ex parte disclosure is only required should there be a hearing on the item (i.e. the item is moved to the Board's regular agenda for consideration). This item requires a m~ority vote only. - JAB RECOMMENDATION: That the Board of County Commissioners: 1. Accept the Director of the Bureau of Emergency Services Division's finding of public necessity; 2. Approve and authorize tbe Chaimlan to execute the Emergency Services Pemlit #1 and the renewal of the Certificate of Public Convenience and Necessity for the ColIier County Emergency Medical Services Department. Prepared by: Artie Bay, Supervisor - Accounting, Emergency Medical Services '..<._'_~'N'_ Page I of I Agenda Item No. 16F2 December 16. 2008 Page 2 of 14 COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS Item Number: 16F2 Item Summary: This item requires that all participants be sworn in and ex parte disclosure be provided by Commission members Recommendation to approve a Certificate of Public Convenience and Necessity for the Collier County Emergency Medical Services Department Meeting Date: 12/16120089:0000 AM Prepared By Artie Bay Senior Administrative Assistant Date Bureau of Emergency Services EMS 121212008 4:28:43 PM Approved By Jeff Page Bureau of Emergency Services EMS Chief Date EMS 1213/20088:50 AM Approved By Jennifer A. Belpedio County Attorney Assistant County Attorney County Attorney Office Date 121312008 1 :21 PM ApprO\!ed By Dan E. Summers BUf€.au of Emergency Services Director Date County Manager's Office Bureau of Emergency Services 12/4120083:10 PM Approved By OMS Coordinator Applications Ana!yst Information Technology Date Administrative Services 1214/20084:29 PM Approved 8y Sherry Pryor County Manager's Office Management & Budget Analyst Office of Management & Budget Date 12151200810:43 AM A pproved By James V. Mudd County Manager Date Board of County Commissioners County Manager's Office 1216/200812:13 PM tile://C:\AgendaTest\Export\ 1 I 8-December%20 16,%202008\ I 6,%20CONSENT%20AGL. 121! 0/2008 Agenda Item No. 16;::2 December 16, 2008 Page 3 of 14 Memorandum To: James V. Mudd County Manager From: Jeff Page, Chief Emergency Medical Services Department Date: November 19, 2008 Subject: Certificate of Convenience and Necessity for Collier County Emergency Medical Services Department Per Collier County Ordinance Number 04-1 L please acccpt the following infomlation for renewal of this required certificate: 1. Collier County Emergency Medical Services Department is operated by the County's Board of County Commissioners located at: 3301 East Tamiami Trail. Building F Naples, Florida. 34112 2. Collier County Emergency Medical Services Department provides service to the 2,032 square miles encompassing Collier County. 3. Collier County Emergency Medical Services Department has a total of fifty-nine (59) State licensed vehicles. Thirty-five (35) of these are licensed ground transport vehicles and one (I) medivac helicopter. There are also twenty-three (23) licensed ALS Engines (non-transport). Of the above. Twenty-four (24) licensed ground transports. thirteen (13) licensed ALS Engines and the medivac helicopter operate 24 hours and day, seven days a week. One (I) additional ground transpOli licensed vehicle may operate 12 hours a day. seven days a week (as needed) during the seasonal months and is taken out of the reserve units. The remaining, ten (10) licensed ALS ground transpOli vehicles are held in resen'c, \-vhile the ten (10) licensed j\LS Engines arc placed in service as staffing allows. (Attachment A). 4. Collier County Emergency ~v1cdical Services Department has one 111all1 office and p.;,.1..,,'-...."'''' (1 Q) C'"h....t.-,i-;on" 1"""-'1"".-1 th"''''''''''fh('''.+ t'oll;,~_I"'"..~t.. ~"l'l"_'p r-,",v-U'j'nG l"-Ji~q<-,','V--"-' ......bu~..........u \JU ..:>UVJlUll J.:'> H.'....Ul.....U lllluubll IUl '--_'--1111..-1 '---_.UUl1lJ..... ..... ILL ,,' b '-"'...... .... Emergency Services Division Headquarters Station I Station 2 Station 10 Station 21 Station 22 Station 23 Station 24 Station 30 Station 32 Station 40 Station 42 Station 43 Station 44 Station 46 Medic Res 50 Station 61 Station 70 Station 71 Station 75 Medic Res 90 ALS Eng 20 ALS Eng 44 ALS Eng 45 Med-Flightl 2705 S. Horseshoe Drive 835 8th Avenue South 977 26m Avenue 14756 Immokalee Road 11121 E. Tamiami Trail 4375 Bayshore Drive 7227 Isle of Capri Road 2795 Airport Road North 112 South 1 ,t 4819 Ave Maria Blvd. 1411 Pine Ridge Rd. 7010 Immokalee Road 16325 Vanderbilt Drive 766 Vanderbilt Beach Road 3010 Pine Ridge Road 1280 San Marco Road. 201 Buckner Avenue 4741 Golden Gate Parkway 95 13m Street SW 4590 Santa Barbara Blvd. 175 Isle of Capri Road 4798 Davis Boulevard 8970 Hammock Oak Drive 1885 Veterans Park Drive 2375 Tower Drive Agenda Item No. 16F2 December 16, 2008 Page 4 of 14 Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Immokalee, Florida Ave Maria, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Everglades, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida Naples, Florida 5. Collier County Emergency Medical Services Department has been licensed and certified to provide Advanced Life Support ambulance scrvice in Collier County since Aplil 6, 1981. 6. Three (3) Collier County residents to act as references: Dr. Douglas Lee 2614 Tamiami Trail, #255 Nancy Laschied 4500 Gulfshore Blvd. N. - #903 Dr. James Hampton 823 Bentwood Drive Naples, Florida 34110 Naples, Florida 34103 Naples, Florida 34108 7. Collier County Emergency Medical Services Department schedules of service fees (Attachment B). 8. November 19, 2008 Memorandum from Dan Summers, Director of Bureau of Emergency Services to County Manager Mudd stating no further information required. 9. Collier County Emergency Medical Services Department financial statement is available in Collier County's Finance Department Attachments Emergency Services Division ..--'"-.- /\genda Item r~o. 16F2 December 16. 2008 Page 5 of 14 COLLIER COUNTY FLORIDA EMERGENCY SERVICES PERMIT #1 This Pennit Expires December 31, 2009 Name of Service: Collier County Emereency Medical Services Name of Owner or Manager: Collier County Board of County Commissioners Principal Address of Service: 2705 South Horseshoe Drive. Naples. Florida 34104 Business Telephone: (239) 252-8459 Emergency Telephone: 9-1-1 Description of Services Area: The 2.032 square miles enconmassing Collier County Number of Ambulances on 24 hour duty: 24 ground units (ambulances) Number of Ambulances on 12 hour duty: I ground unit (as needed during season taken from reserve fleet). Number of reserve Ambulances: 10 Number of non-transport AL5 engines 23 Number of Medivac helicopter: ..1 See attachment "A" for description of vehicles. This pennit, as provided in Ordinance 04-12 shall allow the above named Ambulance Service to operate Emergency Medical Services for a fee or charge for the followmg area(s): Collier County until the expiration date hereon, except that this permit may be revoked by the Board of County Commissioners of Collier County at any time the service named herein shall fail to comply with any local, state or federal laws or regulation applicable to the provision of Emergency Medical Services. Issued and approved this __'_ day of .2008. A ITEST: DWIGHT E. BROCK, CLERK BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY, FLORIDA By:. TOM HENNING, CHAIRMAN Approval as to form and legal SuffiCIency: "''''7 ~~ -~O ilt ~ ~ ~ -< 00 00 '"~ NN gggggg w;u).nlri-n.,; NNNNNN Oc")NC7l I~ ~~~~ ._..... 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'" I~ N ~ N N N N N .., .., 0> N .., .., .., .., .., M .., "' '" :; N N N N ~ ~ N <D <D '" "' '" '" '" '" !i' '" .. ... ... ... ... ... ... ~ ~ ~ ... ~ ~ ~ ... ... ~ ~ ... I , c '" .. ll. ~- i c .. ~~ c o ~ '" -' ... I- " .., >- -' < '" .. ~ ::; .. .. ll. ;- .., '0 "' ;0 .. " ~ ~o 1ii ;; '" ;:; '" 0 'j t:! .. "' m :a .\! ~ 0; . > E '0 i= ~ ~'" 05 o "' .. U LI1 1: 0 .. a: Agenda Item No. 16F2 AITJ(NW'M,1,6,2D,Q8 ~H"PatJ'e' 8 ~61'14 RESOLUTION NO. 08 - -E- A RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY, FLORIDA, PROVIDING FOR UP-DATED EMS USER FEES FOR COLLIER COUNTY AMBVLANCt: SERVICES, UP-DATED BILLING AND COLLECTION PROCEDURE, HOSPITAL TRANSPORT BILLING AND FEES, ADJUSTMENTS OF EMS USER FEES PURSUANT TO COLLIER COUNTY ORDINANCE NO. 96-36, W AlVER OF EMS USER FEES FOR SPECIAL EVENTS, AND AN UPDATED PROCEDURE FOR APPROVING HARDSHIP CASES AND PAYMENT PLANS; SUPERSEDING RESOLUTION NO. 07,191; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, Collier County Emergeney Medi"'" Services (hercinof\er refeJTed 10 as "EMS") provides ambulance services to the residents and visilors of Collier County; and WHEREAS, the Collier County EMS operaling budget is funded exelu.ively through ad valorem taxes and user fees; and WHEREAS, the Board of County Commissioner. reecnUy enler1:d into an Agreement with Advanced Data Processing, Ine. (hereinafter referred to as to "Billing ConSUIIanI") to provide collection services for ambulance 9ervicea and associated fees; and WHEREAS, this Resolution i. intended to appiy irrespective of whether EMS bming s1aft', Ad vaneed Data Processing, Inc., or any other billing consultant is responsible for the collection of fees for ambulance service~ and WHEREAS, Collier County Ordinanee No. 96-36 ~ 5 provides that the user fees for ambulance services may be established by ResoJution of the Board of County Commissioners (bereinafter referred to as to "the Board"). NOW THEREFORE, BE IT RESOLVED BY THE COMMISSIONERS OF COLLIER COUNTY, FLORIDA, lb.t: SECTION ONE: EMS USER FEES BASE RATES: SERVICE LEVELS BASE CHARGES A. EMS - BLS NON-EMERGENCY B. EMS-BLSEMERGENCY C. EMS-ALS I NON-EMERGENCY D. EMS - ALS I EMERGENCY E. EMS - ALS 2 EMERGENCY F. EMS - SPECIALTY CARE G. EMS - TREATMENT WIO TRANSPORT H. EMS - HELICOPTER MILEAGE RATES: SERVICE LEVELS A. EMS - GROUND UNIT (Minimum Charge of J mile and no cap) B. EMS -AIR UNIT A0436 SPECIAL EVENTS AND MISCELLANEOUS RATES: BOARD OF COUNTY ~ A0428 A0429 A0426 A0427 A0433 $ 700.00 $ 700.00 S 700.00 $ 700.00 $ 750.00 $ 800.00 $ 175.00 $ 5,900.00 A0434 A0098 A043 I CODES A0425 MILEAGE CHARGE S 12.25 $ 110.00 SERViCE LEVELS A TWO (2) MEDICS/ONE ALS VEHICLE (pER HOUR) ~ $ 150.00 .~---"1~ ,A,genda Item No. 16F2 December 16. 2008 Page 9 of 14 B. ONE (1) MEDIClNO VEHICLE (PER HOUR) $ 50.00 COPIES': Subject 10 statutory exemptions, "public reconls" arc required by Chapter 119, F.S. to be open to illBpcction and copying. Consistent with Chapter 119, Resolution No. 07-327 establishes copying fees as foUows: COPIES OF DOCUMENTS A. One-sided copy which is 14 inches hy 8 Y, inches or less B. Two-sided oopy which is 14 inches by 8 y, inches or less COpy SERVICES The actual cost of duplication for all olher copies will be charged. The first hour of cost of duplication will not be charged. "Actual cost of duplication" is defined in 9 119.07(1), F.s. lIS "the cost of the material and supplies used to duplicate the record/' but does not include the labor cost and overhead cost associated with such duplication. "'Copying fees are subject to change only to the extent lhat either Chapter 119, FS. or Resolution No. 07-327, or both, arc amended, replaced, or superseded. PAST DUE ACCOUNTS INTEREST ON PAST DUE ACCOUNTS SECTION TWO: BILLING COLLECTION PROCEDURE The following sball be the minimum guidelines for billing and collection procedures for ambulance service fees and charges: A. Initial fecs and charges for ambulance service(s) shall be assessed either prior to or following the provision of service, as senrice dyn8Illics reasonably allow. Unpaid fee! and charges. subsequent to time of service shall be retlectr:d in an accounts receivable subsidiary ledger system to be maintained by the EMS Department. EMS Billing Staff will transmit all data nCC"-ssary to Billing Consultant to process the claim. I. Billing Consultant "ill send an initial bill to the service recipient's or responsible party's insurance carrier as soon os insurance infonnation has been received, vuJidatcd, and entered by the Billing Consultant on the accounL When a valid patient address is present, the Billing Consultant will follow the patient statement cycle outfined below. \, An initial statement for ambulance services. including the HlPAA notice or privacy practices shall be sent fourtecD (14) or more day, after the data is entered by the Billing Consultant. but no later than 30 days after service has RAm S .15 $ .20 $ I % monthly B. 2. been provided. ii. (f a non-Medicaid account remains unpaid, statements will be sent 10 the patient no later than every 60 days from the last filed dale. Ifa claim is denied, II blll win be sent to the service recipient or responsibie party. iii. For Medicaid accounts, if the claim is denied because of no coverage at the time of !Jervice, or because it WM detennincd to be not medically necessary to be transported by IlIIlbulance,. a bill will be sent to the service recipient or responsibly pllrty. Agenda Item No. 16F2 December 16. 2008 Page 10 of 14 iv. In the event the service recipient Or responsible party does not have Dr doe. not provide proof of insurance covCI1Ige, statements will be sent to the patient no later than every 60 days from the last stalemeot date. C. The Billing Consultant will provide a file with patients to be sent to collections to the Count)" oS contracted collection agency when all attempts to coUect on the account have been exhausted by the Billing Consultant. The COlDlly may direct the Billing Consultant 10 not send a patient to collections at any time. Billing Consultant may send a patient to collections prior to exhaustion of all collection efforts when: I. The patient acCOWlt has on inV1liid address. 2. Billing Consultant is directed by COWlly to send a patient to conections. D. Interest will be assessed at ] % per month on all accounts that are sent to ~c County's contracted collection agency. E. A reasonable and customary payment plan will be made available for an service recipients or responsible parties. Should the service recipient or responsible party at the time fail to meet the terms and conditions oflhe payment plan for a period of(60) sixty days, the unpaid baJance shaJll'CC!nter the collectWns process set fonh in Section C. above at the point in the collections process at which it Was taken out for a payment plan to be admlnistered. F. When ambulance service bill(s), at the any stage in this biJIing and collection procedure, "'" returned because the Postal Service cannot effectuale delivery, the EMS Billing Section shall make reasonable effort to ascertain the COlTCCt mailing address. If reasonable etfurls to ascertain a correct address fail, the account(s) may be considered. for other coUection alternatives. G. Nothing contained in this Section shall preclude reasonable telephone or other appropriate contaA;t for billing and collection purpo.es, in accordance with all applicable laws. H. Throughout tbe fiscal year, the EMS Billing Section shall review all past due accounts and report to the Board of County Commissioners on an annual basis, of all past due accounts which are believed to be uncollectible. 1. The Board may, after reviewing these past due account. and after finding that diligent efforts at collcc::tion have proven unsuccessful, remove these past due accounts from active accounts receivable in accordance with generally accepted accounting procedures and pursuant to Jaw by Resolution. J. Probate Estate Cases' Should 8 decedent have an unpaid balance for ambulance services, the following shall occur: t. The decedent's Penonal Repr....,tative will notify EMS Billing Staff that a probate e.tate has beon filed with the Probate Court. 2. EMS Billing Staff shall ensure that a Notice of. Claim is timely filed with the Probate Court. 3. EMS Billing Staff shall ensure that the Office of the COWlty Auomey is timely notified of such claim and provided with: I) a copy of ambulance bill{s), 2) all correspondence between EMS Billing StafflBilling Consultant) and Personal Representative, 3) Notice of Claim filed with the Probate Estate. and any olher information necessary to pursue the cJaim. """--'T' P,genda Item r"o. 16F2 December 16 2008 Page 11 of 14 4. The Office of the County Attorney sholl take all reasooabIe actiOllS that ""' necessary to pursue such claim. including but not limited. to faling a lawsuit in the COWlty Court to pursue such claim. 5, If the es1ate has ....ts and $10,000 or less is owed for ambulance servie..., the EMS Director lUld the County Attorney (or hi, designee) are authorized to lake reasonable actions to reach a settlement with the Personal Representative or his aIlomey. Should a settlement be reached, the EMS Director and the County Attorney (or his designee) are authorized to execute a satisfaction and/or release on behalf of the County. lflhe esWe OIlS....ts and in excess of$lO.OOO is owed for ambulance services. any negotiated settlement/compromise of the ambulance billing claim shall be approved by the Board of County Conunissioners. If the estate has nominal 8:iSets or no asscta, the County Manager may waive the rates, fees, and charges ss set forth in Ordinance No. 96-36, as it may be amended, replaced. or superseded. K. All accounts with a balance of S 1 0 or less win be written ofT. SECTION THREE: HOSPITAL TRANSPORT BILLING AND FEES A. The fees set forth in Section One of this Resolution shal1l1Jl!1ly to ambulance transports that occur between a hospital's facilities. B. Should a hospital within the boundaries of Collier County have the need for a tranSport of a patient between hospital facilities located within the boWldaries of ColUer County, ambullUlee transport will be provided. C. Should a hospital within the boundaries of Collier County have the need for a transport ofa patient to hospital facilities iocated o"/Side the boundaries of Collier County, the County, wiU subject to equipment and manpower availability, at its sole discretion, utilize its resources to provide palient transport. D. Hospitals requesting ambulance trlUlSporls &ball be iovoiced directly for ambulance tnIIlSport service on a monthly basis. SECTION FOUR: ADJUSTMENT OF EMS USER FEES The following shall be minimum guidelines for adju.<tments to ambulance service fee.. The Board of County Commissioners, in accordance with criteria established by the enabling Ordinance. may authorize other adjustments. A. Medic,,", and Medicaid AdiUSlments. Contractual adjustments under Medicare and/or Medicaid assignment wLll be made in accordance with applicable Medicare and/or Medicaid rules and regulations. B. Victim's Comnensat:ion Contractual Adjustments. ConlIBctua1 adjustments will be made in ""cordonce with appliOllble sIote, Ji:deral and local rules and regulations, C. Worker'~ Comnensalion Conttactual Adlustments. Contractual adjustments will be made in accordance with applicable state, federal and local rules and fc:gulations. D, County Emnlovee Adiwtments. Board of County Commi!:Sioners and Constitutional Officers' employee!! that have Primary coverage under Collier County's insurance policy will be responsible for any deductibles, co.payments or unpaid balances. An employee !\genda Item No. 16F2 December 16, 2008 Page 12 of 14 may di.pute hiolher ambulance charge in accordance with procedun:o .et forth in OnIinance No. 96.36. E. ChzlDlDusfTricare Adiustments. Conlractual adjustments will be made: in accordance with applicable ChampllSlTricarc rules and regulatioos. F. Railroad Rctircmeat AdiUSllnel'lts. Contractual acljusonents will be made in accordance willi applicable state, federal and local rule. and lCgulmions pertaining to Railroad Retirement Adjustments. G. Social Service. Adiustments. Contractual adjustments will be made in accordance with rules establi.hed by the County Manager and memorialized by a memo"",dum of UDd....tanding cxecuted by the Social Service. Director and the EMS Director. SECTION FIVE: WAIVER OF EMS USER FEE FOR SPECIAL EVENTS. Pur,uant to Ordinance No, 96-36, and from the cffective date of thi, Resolution, user fees for EMS ambulance stand-by ,ervices may be waived if the Board find. that a valid public purpo,e has been established in recognition of their charitable contribulions to the Community. SECTION SIX: HARDSHIP CASES AND PAYMENT PLANS. The Board recognizes that certain service recipients may need to be identified and processed as hardship cases. Payment plans will be established pursuant to the minimum guidelines SC't forth in this Resolution. A. Hardship case, will be established in accordance with the Federal Poverty guidelines. as used by the Social Scrvices Dcpanmcnt DfCollier County. B. Payment plans for hardship cases will be set up on a monthly basis. with a minimum payment ofSIO.OO per month. Hardship cases, placed on a payment plan will not accrue interest or be placed into collection. Notwithstanding the foregoing, if a service recipient has a payment plan and does not make the agreed scheduled payments for a period longer than two (2) months, thc account will be turned over to the County's contracted collection lIBency and interest will begin to aCCNe, SECTION SEVEN: SUPERCISION OF RESOLUTION 07-192 Thi, Resolution shall supersede Resolulion No. 07-192 SECTION EIGHT, EFFECTIVE DATE This Resolution shali become effective on January 29, 2008 PASSED AND DULY ADOPTED by the Board of County CommissionelS of Collier Counly, Florida, this :2/11'1 clay of '}'"/"I, t'\ 'j ,2008, A TIES:r:' . " DWIGHT E. BROCK;::<,::LERK ~~~J legal sufficiency: BOARD OF COUNTY COMMISSIONERS COLLIER COUNTY, FLORIDA By: L Ai IM"~ TOMHENNlN~~ ~Cl A 9 ~,Lt.o leon; A. Belpcdi Assistant County Attorney .i\aellda Item t'Jo. 16F2 ~ December 16, 2008 Page 13of14 ATTACHMENT "C" MEMORANDUM TO: James V. Mudd, County Manager FROM: Dan Summers, Director Bureau of Emergency Services Division DATE: November 19, lOOS REF: Certificate of Convenience and Necessity for Collier County Emergency Medical Services Department After review of the application to renew this certificate for Collier County Emergency Medical Services Department, no further information is required at this time. II ~ I ,g " 0 0 15. - '0; :s " .0 ~ e " .0 ;., 0 "" E ~ ,S .'" "'" !! j "'" ~ 0 ~ 'S '" ~ .!! 0 :s " ~ 0 " '" i! 0 Q. 1ii '" !! ~ " " " ~ ~ " ~ " '"" . Q. " o:l " " '" > '"" "" 0 ~ ,g '€ '3 ,g ~ i': co - 0 :;;, ~ '" " B " .~ 'll Cl. 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