Agenda Packet TC 10/19/2009 - Supplement
September 30, 2009
Number 24
FIFTH CIRCUIT DISMISSES TEXAS
OPEN MEETINGS ACT CHALLENGE
Previous editions of the TML Legislative Update have reported on the progress of the
Alpine Open Meetings Act lawsuit (Avinash Rangra, Anna Monclova, and All Other
Public Officials in Texas v. Frank D. Brown, 83rd Judicial District Attorney, and the
State of Texas).
The core question presented in the case was whether a local government official’s speech,
made pursuant to official duties, has the same constitutional protections that the First
Amendment grants to other types of speech.
In 2006, a federal district court upheld the law. On appeal earlier this year, a three-judge
panel of the U.S. Court of Appeals for the Fifth Circuit issued an opinion that failed to
directly answer the question. Instead, the panel returned the case to the trial court for
further proceedings based on a tougher legal standard of review. Under that standard, the
state would have had to prove that the criminal provision of the Open Meetings Act (Act)
is not unconstitutional.
Shortly after the opinion was issued, both sides filed for a rehearing by the court en banc.
An en banc rehearing is one that is conducted by all of the court’s seventeen judges. The
State of Texas argued that the panel’s decision should be overturned. The plaintiffs
argued that no additional trial proceedings were necessary, and that the court should have
simply declared the criminal provision of the Act to be unconstitutional.
2
TML, along with the Texas City Attorneys Association, the Illinois Municipal League,
the South Dakota Municipal League, the National League of Cities, and the International
Municipal Lawyers Association, filed an amicus brief in the case in support of the
plaintiff’s position.
The court granted the motions, and was set to hear oral arguments this month. But in a
surprise move, the court dismissed the case on September 10 by a 16-1 decision without
the benefit of hearing oral arguments.
The case was dismissed due to a lack of “standing.” The plaintiff is no longer a city
official (he was term-limited as a councilmember), and the court thus deemed the case
moot. “Standing” is a prerequisite to bringing suit, and the doctrine generally requires a
“live controversy.” However, in the case of a statute like the Act, the law allows a case
to proceed if there is a “credible threat of present or future prosecution” or if the case is
“capable of repetition but evading review.” Because the criminal statute of limitations
under the Act is two years, the plaintiff could still be prosecuted even though no longer in
office. In addition, thousands of elected and appointed officials are still subject to
criminal prosecution under the Act.
The lone dissenting justice wrote a scathing rebuke in which he lambasted the other
members of the court for essentially taking the easy way out. The decisive vote, and
other indications from the court, seems to indicate that further appeals of the original case
may be futile.
Because of that, several city officials may file an entirely new lawsuit based on the same
legal principles as the Alpine case, at the federal district court level. If you are an official
who is subject to the Act, and are interested in being a plaintiff in that case, please
contact Rod Ponton, Alpine’s city attorney, at rod_ponton@yahoo.com.
Contrary to what some media reports and attorney general press releases may imply, it is
important to remember that neither the League nor any other entity is opposed to open
government. Quite the contrary. This case was simply arguing that the threat of jail time
is not the least restrictive means of achieving that goal.
PERRY MAKING USE OF STIMULUS BOOST
by R.G. Ratcliffe
AUSTIN - Gov. Rick Perry rallied opposition to federal stimulus spending, but he now is
the manager of one of the biggest pots of federal gold in Texas: crime grants to local law
enforcement agencies.
And those grants have become an integral part of Perry's political machine.
3
Perry in the past has decided what law enforcement agencies receive about $23 million a
year in Edward Byrne Memorial Justice Assistance grants. Now, because of the
American Recovery and Reinvestment Act, Perry will have an additional $90 million to
hand out.
While Perry's office is the conduit for the federal money, the governor chooses which
agencies receive the money and how it is spent. The political payoff has been great.
About $6 million in Byrne grants helped Perry win the endorsement of border sheriffs in
2006. Perry last year held a news conference to promote $557,000 in grant money he was
giving to the San Antonio Police Department to target transnational gangs.
Every time Perry doles out the federal Byrne grants, he sounds like the money is his.
"Texas is tough on crime and remains dedicated to equipping our law enforcement with
the resources necessary to protect our citizens and ensure the safety of our communities,"
the governor said while handing out $2 million of the federal money to East Texas
communities last year.
Perry created a controversy this year when he rejected $550 million in federal
unemployment compensation funds, saying it had too many "strings attached," but he
later accepted more than $12 billion in stimulus funds to balance the state's budget.
Fodder for primary battle
Republican primary rival U.S. Sen. Kay Bailey Hutchison has been attacking Perry on the
stimulus funding, accusing him of hypocrisy. Hutchison voted against the Recovery Act
but has said that once it passed Texas should get its fair share of the money.
Under requirements attached to the Byrne stimulus money, 40 percent must go to local
governments. The governor's office reports that 425 applications have come in for $40
million of the money, based on recommendations from regional councils of government.
The other 60 percent of the stimulus money - about $54 million - can be spent at the
discretion of Perry's office.
Perry spokeswoman Katherine Cesinger said the governor believes it is important to get
the stimulus-backed Byrne money to law enforcement agencies, as well as the usual
grants.
"This funding will support investments in crime prevention, law enforcement,
prosecution, corrections, treatment and justice information sharing initiatives," Cesinger
said.
4
She said the Byrne money is different from the unemployment funds because it is for
one-time spending, while the unemployment money required a future state-paid
expansion of the system.
Tulia controversy
The Byrne grants are named after a New York City police officer murdered in 1988 by
gang members who were ordered by a jailed drug lord to kill a police officer.
The Byrne grants got a bad name in the early part of this decade in Texas when they were
used to fund regional drug task forces, one of which resulted in the conviction of 39
innocent people in Tulia based on the false testimony of an undercover narcotics agent.
Perry, who was not involved in funding the Tulia task force, pulled the plug on regional
task forces and shifted the emphasis in handing out Byrne money to border and homeland
security.
Perry in 2005 gave $6 million in funds to the counties participating in the Texas Border
Sheriff's Coalition "to deter illegal immigration and prevent border-related crime." Days
before Perry's 2006 re-election victory, the sheriffs made a high-profile trip to
Washington with the governor to discuss border crime, and most endorsed Perry.
"I don't think it was a coincidence that the grants roughly correlated with those
endorsements," said Democratic political consultant Jason Stanford, who managed the
gubernatorial campaign of party nominee Chris Bell.
Scott Henson, former director of the ACLU Police Accountability Project, said some of
the Byrne money in Texas is used for prison diversion programs and drug courts in urban
counties. But Henson, who blogs about criminal justice, said some of the money Perry
gave to the border sheriffs did nothing to deter crime.
"Some of the people he gave the money to turned out to be on the drug lords' payroll,"
Henson said, referring to former Starr County Sheriff Rey Guerra, who recently was
sentenced to 64 months in prison for leaking sensitive law enforcement information to
Mexican drug traffickers.
(Note: This article is reprinted with the permission of the Houston Chronicle. It
publicizes the availability of federal grant revenue that is being distributed by the
governor’s office to law enforcement agencies. It also points out a practice that is
particularly bothersome to many city officials: when state leaders distribute federal
dollars to local governments, they state or imply that the
State of Texas is providing the funds. The truth is that the State of Texas provides very
little financial aid to cities.)
5
ATTORNEY GENERAL ISSUES FAVORABLE
ANNEXATION OPINION
On September 3, the Texas attorney general issued opinion GA-737. The opinion
interpreted, among other things, the “100-tracts exemption” to the municipal annexation
plan requirement in the Municipal Annexation Act (Chapter 43 of the Local Government
Code). It did so in a way that confirms a long-held opinion of city attorneys around the
state: it concludes that 1999 legislative changes that apply a complicated, three-year
process to annexations of populated areas do not apply to the annexation of sparsely-
populated areas.
The issue goes back to the 1999 legislative session, which featured aggressive attacks on
municipal annexation authority. Cities were committed to finding some workable
solution. League staff met with “annexation reformers” throughout that legislative
session because the League was convinced there was a very real risk of losing significant
authority to annex if a compromise could not be reached.
Senate Bill 89, which was the compromise enacted that year, was a massive rewrite of
Texas annexation laws. League staff and city officials testified numerous times, offered
amendments, and worked to eliminate or modify the more onerous provisions. Although
the bill changed annexation laws significantly, it included several key provisions that
mitigated the more onerous requirements.
One of the key components was that the bill did not apply its more complicated
procedures to areas that are not densely populated. Under the bill, every city in Texas
was required to adopt an “annexation plan” by December 1, 1999. The plan must
identify areas with 100 or more homes that will be annexed by the city, and must provide
for a three-year process to complete the annexation. The purpose of the plan is to ensure
that built-out areas do not experience a reduction in services after annexation.
Section 17 of S.B. 89, which is codified as statutory notes that follow various sections of
Chapter 43 of the Local Government Code, provides that most of the changes made by
the bill apply only to “plan” annexations. Certain types of areas are exempt from the plan
requirement. For example, if an area contains “fewer than 100 separate tracts of land on
which one or more residential dwellings are located on each tract,” that area need not be
included in an annexation plan. That language is often referred to as the “100-tracts
exemption.” (Note that many cities will have a one-page plan stating that they do not
intend to annex any area for which an annexation plan is required. GA-737 concluded
that the failure to adopt a plan at all is not fatal to an annexation that is made outside of
the plan requirement.)
In the request for GA-737, a county attorney questioned the application of the 100-tracts
exemption. He argued that, for the exemption to apply, every lot in an area must contain
a dwelling. The attorney general rejected that argument, stating that “while the statute
would benefit from legislative clarification, we conclude that Section 43.052(h)(1) of the
6
Local Government Code does not require that a residence be located on each tract of the
area proposed for annexation.”
The opinion supports the proposition that a city may annex an area so long as there are
fewer than 100 homes in the area. Because of the exemption, it is probably fair to say
that most annexations will still not be required to be in an annexation plan. Of course,
the 100-tracts exemption is generally relevant only to home rule cities that annex
sparsely-populated land unilaterally.
TEXAS CITIES RECLAIM ABANDONED PROPERTY
Texas law provides that businesses, financial institutions, and government entities may
retrieve abandoned and unclaimed property held by the Texas comptroller. Any financial
asset, including but not limited to dividends, payroll or cashier’s checks, stocks and
bonds, and insurance proceeds that have been abandoned by the owner for one or more
years, may be reclaimed by the owner. In order to find unclaimed property, owners may
search for such property on the comptroller’s Web site. In addition to the owner’s search,
the agency, through postings on the agency’s Web site, direct mail notices and annual
newspaper advertising, attempts to find the rightful owners of abandoned and unclaimed
property. The owners reclaiming property must then provide the Texas comptroller’s
office sufficient proof of ownership, subject to the agency’s discretion.
Since May 2009, the comptroller’s office has attempted to return unclaimed property to
395 local governments. The agency is still waiting for 150 of these claims to be returned
and accepted by the cities. Both large and small cities are involved in this reclaiming
process. The properties include claims concerning cashier’s or vendor checks, utility
deposits, accounts receivable credit balances, refunds and rebates, and accounts payable.
The agency’s staff continues to work diligently to allow Texas cities to reclaim their
abandoned property.
The agency provides further information on the unclaimed property search procedure,
reclaiming procedure, and appropriate fees for reclaiming property. Please visit the
comptroller’s Web site at www.window.state.tx.us/up for additional information.
7
MUNICIPAL COST INFLATION
CONTINUES TO DECLINE
The Municipal Cost Index (MCI), developed exclusively by American City and County
magazine, shows the effect of inflation on the cost of providing municipal services. The
MCI is used to study price trends, help control price increases for commodities, make
informed government contract decisions, and facilitate sound budget planning.
According to American City and County magazine, the MCI for September was 205.4, a
decline of 0.4 percent from last month’s MCI, and a decline of 4.3 percent during the
previous 12 months. The September 2008 MCI was 214.7.
E-VERIFY REQUIRED FOR FEDERAL
CONTRACTS BEGINNING SEPTEMBER 8
Starting September 8, 2009, federal contractors, including cities that enter into certain
federal contracts, must use E-Verify for their new hires and all employees assigned to any
work on an eligible federal contract. E-Verify is an Internet-based system operated by the
U.S. Citizenship and Immigration Services (USCIS) that allows employers to verify the
employment eligibility of their employees, regardless of citizenship.
(For more information please see “E-verify Required for Federal Contracts” in the March
12, 2009 [http://www.tml.org/leg_updates/legis_update031209a_everify.asp], edition of
the TML Legislative Update, and the U.S. Citizenship and Immigration Services Web site
at: http://www.uscis.gov.)
DON’T FORGET: CURFEW ORDINANCES
NEED REVIEW
Section 370.002 of the Local Government Code requires that after a city adopts a juvenile
curfew ordinance, the city must review and readopt the ordinance every three years. The
statute requires that a city:
1. review the ordinance’s effects on the community and on problems the ordinance
was intended to remedy;
2. conduct public hearings on the need to continue the ordinance; and
3. abolish, continue, or modify the ordinance.
8
A juvenile curfew ordinance expires if a city does not review and readopt it every
three years.
For more information on this issue, please contact the TML Legal Department at (512)
231-7400 or legal@tml.org.
NEW LAW CHANGES EMERGENCY MANAGEMENT
RE-ENTRY AND EVACUATION AUTHORITY
House Bill 1831, passed in 2009, allows a mayor to enforce mandatory evacuation orders
against individuals who refuse to leave a mandatory evacuation area. It also imposes
civil liability on individuals who cause damage or injuries to others who must rescue
them from a mandatory evacuation area as a result of their refusal to evacuate. The new
law requires the state to make rules regarding uniform reentry procedures and
credentialing after a mandatory evacuation. However, an affected city must be
considered when the state makes the rules, and the city can adjust the rules if needed.
The new law also requires a city to provide a post-disaster evaluation to the state division
of emergency management not later than the 90th day after requested to do so by the
division. For more information on city authority and duties in emergencies and disasters
please see Emergency Authority for Local Officials
[http://www.tml.org/legal_pdf/EmergencyAuthLocalOfficials.pdf].
Please contact the TML Legal Department with any questions at (512) 231-7400 or email
legal@tml.org.
RECOVERY FUND RECIPIENTS
ENCOURAGED TO REGISTER
by Carolyn Coleman
The American Recovery and Reinvestment Act of 2009 (Recovery Act) calls for all
recipients of recovery funds to report on the use of these funds to the Recovery
Accountability and Transparency Board (Recovery Board) by October 10. Registration
for recipients is well under way on FederalReporting.gov, with nearly 22,000 already
registered. However, the Recovery Board strongly encourages those not yet registered to
do so immediately to ensure that, when actual reporting occurs between October 1 and
October 10, recipients will be able to maximize the efficacy of the reporting system.
9
The Recovery Board was created by the Recovery Act to oversee the expenditure of
recovery funds and bring transparency and accountability to the process. The board
consists of a chairman, Earl E. Devaney, and 12 federal inspector generals. The board
runs the recovery.gov Web site, which provides information on the recovery initiatives
and spearheads an accountability effort that involves both federal and state investigators
and enforcement officials.
The Recovery Board recently launched the 2.0 version of the recovery.gov Web site. The
redesigned Web site will be both user-friendly and highly interactive and will provide all
Americans with an historic level of transparency on their government’s spending. The
board decided to launch the redesigned version of recovery.gov earlier than the reporting
deadline to allow time for users to become familiar with the Web site’s many new
features, particularly its enhanced mapping capacity.
The Recovery Act allows recipients and agencies of the federal government to conduct
quality reviews of the submitted data between October 11 and October 29. After
considerable outreach to recipients and other affected stakeholders, the board is
announcing the following schedule and process for displaying recipient data on
recovery.gov:
• All reported data associated with recovery contracts awarded directly by federal
agencies will be displayed by October 15.
• All reported data associated with recovery grants, loans, and other forms of assistance
will be displayed on October 30.
• All data changes made by recipients between October 11 and October 29 will be
carefully tracked, chronicled, and made available on recovery.gov shortly after
November 1.
According to Devaney, “[T]his release schedule mitigates the board’s concern that large
amounts of uncorrected data could actually harm transparency rather than enhance it.”
Recipients of funds received under the Recovery Act may register at
www.federalreporting.gov. For additional information regarding the registrations process,
go to www.recovery.gov.
(Note: This article has been reprinted with the permission of the National League of
Cities.)
10
FEDERAL STIMULUS PACKAGE UPDATES
As a way to keep its membership informed in a timely manner, TML has created a Web
page that details many of the city-related portions of the American Recovery and
Reinvestment Act (Recovery Act). The page can be accessed at www.tml.org, by clicking
on “Legislative” and then clicking on “Federal Stimulus Information.”
When the League receives information of interest to city officials, the page will be
updated immediately. Since publication of the last TML Legislative Update, the
following information on the page has been updated:
Environment, Energy, and Telecommunications –the State Energy Conservation
Office (SECO) has posted the Request for Applications (RFA) for the Alternative Fuels
Project, which is part of the larger State Energy Program. Applications for funding under
this project are due at 2:00 pm (CT) on Monday, October 19, 2009. To access the RFA,
please visit http://www.seco.cpa.state.tx.us/arra/sep/transportation/index.php.
In addition, SECO is in the process of mailing to each Texas city with a population of
less than 35,000 a letter detailing the amount of money each city can choose to receive
under the Energy Efficiency and Conservation Block Grant Program. For more
information on this program, please visit
http://www.seco.cpa.state.tx.us/arra/eecbg/index.php.
ETHICS OPINION COULD AFFECT
ELECTED CITY OFFICIALS
A recent advisory opinion issued by the Texas Ethics Commission, Opinion No. 484,
calls into question whether elected officials, including elected city officials, may have
their transportation, meals, and lodging expenses paid or reimbursed by a corporation or
labor organization in return for addressing an audience or participating in a seminar.
The opinion first concludes that such expenses are often permissible under the Penal
Code’s prohibition against illegal gifts and under state lobbying laws, provided the
speaking opportunity is more than merely perfunctory. This was established law.
What is new about the opinion is that it raises the question of whether such payments of
expenses by a corporation or labor organization might be a violation of state campaign
finance laws. The opinion concludes that such payments are violations of campaign
finance laws if the elected official’s services are “in connection with” his or her duties or
activities as an officeholder.
Here’s a hypothetical example: Acme Corporation invites Mayor Smith to speak at
Acme’s annual convention and offers to pay the mayor’s hotel and mileage expenses. If
11
the purpose of the speech is found to be in connection with the mayor’s duties (which
will often be the case), the payment may be an illegal campaign contribution despite the
fact that it would otherwise be legal under the gifting and lobbying statutes.
City officials that are offered free or reduced transportation, meals, and lodging for any
purpose are strongly advised to consult with local counsel and/or contact the Texas Ethics
Commission directly prior to accepting those offers.
PROPOSED AMERICANS WITH DISABILITIES ACT
(ADA) RULES ISSUED BY EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
The ADA Amendments Act of 2008 (ADAAA) was signed into law on September 25,
2008, and became effective on January 1, 2009. The ADAAA overturned many court
cases that narrowly defined a disability under the act. Under the ADAAA, disability is
defined broadly and mitigating measures (like medication or eyeglasses) generally cannot
be used to challenge the disability of a person using the measures. The ADAAA has the
effect of making many additional employees "disabled" under the act and requires city
employers to provide reasonable accomodations to more employees.
On September 23, 2009, the Equal Employment Opportunity Commission (EEOC)
proposed rules based on the ADAAA. These rules reflect the broad scope of “disability”
under the new Act. The proposed rules go into more detail than previous rules on what is
a disability, how mitigating measures are used, and the definition of major life activities,
major bodily functions, and what “substantially limits” means. The proposed rules
provide examples of these terms that broaden past interpretations of the ADA and
provide helpful examples to employers on disability-related employment situations. The
proposed rules also specifically state that only prescription eyewear can be considered as
a mitigating measure in determining a disability and that employers cannot use eyesight
as a factor in hiring or other job placement situations unless this factor is shown to be
job-related and consistent with business necessity. The proposed rules clarify that a
reasonable accomodation is not required when an individual is merely "regarded as"
having a disability. The EEOC is accepting comments on this rulemaking until
November 23, 2009. For more information on these proposed rules, including
information on how and where to file comments, go to the EEOC's Web site at
http://edocket.access.gpo.gov/2009/E9-22840.htm.
Please contact the TML Legal Department with any questions at (512) 231-7400 or send
an email to legal@tml.org.
EPA TO HOLD BROWNFIELDS CONFERENCE
IN NEW ORLEANS
The annual Brownfields 2009 Conference, co-sponsored by the U.S. Environmental
Protection Agency (EPA) and the International City/County Management Association
(ICMA), will take place in New Orleans on November 16-18. The National Brownfields
Conference is the largest, most comprehensive conference focused on cleaning up and
redeveloping abandoned, underutilized, and potentially contaminated properties in the
nation. Registration is free, and the program offers more than 150 educational and
learning opportunities, plenary sessions, 200 exhibitors, networking events, special
training sessions, film screenings, book signings, and more. The conference attracts more
than 6,000 registrants and hundreds of exhibitors. Information presented will be
appropriate for both newcomers to the world of economic and environmental
redevelopment as well as seasoned professionals looking to make new connections.
Visit www.brownfields2009.org for more information or contact Tonia Biggs,
Brownfields Conference Coordinator at (214) 665-8851 or biggs.tonia@epa.gov.
TML member cities may use the material herein for any purpose.
No other person or entity may reproduce, duplicate, or distribute any part
of this document without the written authorization of the
Texas Municipal League.
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4 3 4 1 8 5 9 6 2
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Ab
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0 0 2 0 1 0 0 0 1
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Ab
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1 0 4 1 2 0 0 1 0
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Eq
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1 7 2 2 7 4 4 8 2
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In
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2 3 5 7 3 4 6 1 3 3
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9
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75
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88
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2 2 0 1 1 3 0 0 0
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1 2 0 0 1 1 6 5 1
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6 6 8 6 1 6 6 7 1 4 1 3
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Pr
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2 3 6 1 8 9 4 4 6
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Tr
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15
24
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120
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8
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2 1 0 2 2 2 0 0 2
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11
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Cr
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28
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57
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Fo
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71
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76
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Na
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5 5 1 6 2 2 1 3 0
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2 0 1 4 0 0 1 3 1
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65
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5 6 7 2 3 8 5 1 2 5
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As
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19
9
16
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6
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120
Ju
v
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5 4 1 3 4 3 1 7 6 2
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Sc
h
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R
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18
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27
87
187
91
1
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6
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52
Ad
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49
52
61
51
71
60
44
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60
492
Id
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0 1 2 4 1 1 2 0 1
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We
l
f
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4 1 3 4 4 7 8 8 2
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Cl
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l
s
61
8
28
9
50
0
25
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64
6
79
5
69
1
47
2
4638
To
t
a
l
N
u
m
b
e
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o
f
C
a
l
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s
1,
8
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7
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5
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5
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5
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8
1,
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4
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8
0
3
1,
5
6
3
15,497