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Campaign Finance Audit Report — Aaron Peskin for Mayor 2024 (ID # 1468468)

English

February 27, 2026

I. Introduction

This Audit Report summarizes the audit results for the committee Aaron Peskin for Mayor 2024, FPPC ID # 1468468 (the “Committee”), for the period January 1, 2024, through December 31, 2024. The audit was conducted by Ethics Commission audit staff to determine whether the Committee materially complied with applicable state and local campaign finance laws during the November 2024 election.

II. Audit Authority

San Francisco Charter Section C3.699-11 authorizes the Ethics Commission (the “Commission”) to “audit campaign statements and other relevant documents” of campaign committees that file with the Commission. San Francisco Campaign and Governmental Conduct Code (“C&GCC”) Section 1.150(a) requires the Commission to audit all committees of candidates who have received public financing and authorizes the Commission to initiate targeted audits of other committees at its discretion.

III. Objective and Scope

The objective of the audit was to reasonably determine whether the Committee materially complied with requirements of the San Francisco Campaign Finance Reform Ordinance (C&GCC Section 1.100, et seq., and supporting regulations) and the California Political Reform Act (California Government Code Section 81000, et seq., and supporting regulations).

The audit was conducted based on an analysis of the Committee’s filings and support documentation obtained from the Committee. A complete summary of the audit’s objectives and the methods used to address those objectives appears in Appendix A.

IV. Committee Information

The Committee qualified as a committee on April 5, 2024, as a candidate-controlled committee supporting the election of Aaron Peskin (the “Candidate”) to the office of Mayor in the November 5, 2024, election. The Committee was terminated on June 10, 2025.

Stacy Owens, President of S.E. Owens & Company, served as the Committee’s treasurer (the “Treasurer”) for the full period covered by the audit. Marissa Quaranta, an employee of S.E. Owens & Company, was the primary audit contact on behalf of the Committee during the audit.

For the period covered by the audit, the Committee reported receiving $2,179,134—including $970,531 in monetary contributions, $8,603 in nonmonetary contributions, and $1,200,000 in public financing—and making or incurring $2,148,763 in expenditures.

V. Material Audit Findings

Material findings represent instances of noncompliance that Auditors determined to be significant based on the frequency of occurrence within a representative sample, or based on the significance of the dollar amount, the percentage of total activity, or the importance of the item to the purposes of state or local law.

Auditors identified no material findings during the audit.

VI. Other Identified Findings

Auditors identified the following non-material findings during the audit. These findings represent instances of noncompliance discovered through review of the Committee’s filings and support documentation and through testing of sampled transactions that were determined not to be material in terms of frequency or dollar amount. This information is reported for the awareness of committees and treasurers and to facilitate the tracking of trends across audit reports.

Finding VI-1. The Committee did not maintain documentation to support reported contributor information for contributions made by check

Applicable Law

For each received contribution of $100 or more, committees must report the contributor’s full name, street address, occupation, and employer or if self-employed, name of business. Gov’t Code § 84211(f).

Additionally, for each received contribution of $100 or more, committees must maintain original source documentation including, among other required information, the contributor’s street address, occupation, and employer, as well as all communications sent by the committee to secure that information. 2 CCR §§ 18401(a)(2)(A), 18401(a)(3)(A)-(B).

A committee must return any contribution of $100 or more within 60 days if the committee does not have on file in its records the name, address, occupation, and employer of the contributor. Gov’t Code § 85700(a). Fair Political Practices Commission (FPPC) Advice Letter A-04-110 notes that the information required to be obtained by Section 85700 does not need to be obtained firsthand from a contributor, and no particular method for obtaining the information is required. However, “recordkeeping is a separate obligation of candidates and treasurers” and “the sufficiency of any record keeping in a particular instance will be assessed against the requirements of regulation 18401.”

Analysis

Auditors reviewed a sample of 155 contributions for compliance with reporting and recordkeeping requirements, including 21 contributions made by check. From that sample, Auditors identified six contributions made by check (3.9% of the sample and 28.6% of sampled check contributions) for which the Committee did not retain contributor cards, or any communications or other records, to support the reported occupation and employer information. Auditors were unable to verify the reported information, and it is unclear how the Committee determined this information to be accurate.

The table below summarizes the contributions discussed in this finding:

ContributorDateAmountReported Occupation/Employer
John McGoldrick6/11/2024$100Retired
Robert Kaiser7/14/2024$300Retired
James Keith10/18/2024$500Homemaker
Astrid Meghrigian10/20/2024$500Retired
Hina Dave10/27/2024$500Manager at San Francisco Public Utilities Commission
Jennie Parrilla11/3/2024$25Retired

Finding VI-2. The Committee did not maintain support records for several expenditures

Applicable Law

For each expenditure made of $25 or more, or a series of payments for a single product or service totaling $25 or more, committees must maintain records containing the date and amount of the expenditure, the full name and street address of the payee, and a description of the goods or services received, as well as source documentation including cancelled checks, wire transfers, credit card charge slips, bills, receipts, invoices, statements, or vouchers. 2 CCR § 18401(a)(4)(A)-(B).

Committees must maintain detailed accounts, records, bills, receipts, and other original source documentation as necessary to prepare financial statements for a period of four years. C&GCC § 1.109(a), 2 CCR § 18401(b).

Analysis

Auditors reviewed a sample of 124 expenditures and identified seven transactions (5.6% of the sample) for which the Committee did not maintain any support records. Auditors were therefore unable to substantiate the reported expenditure information for these transactions. Regulation 18401 and C&GCC Section 1.109(a) require committees to maintain original source documentation for all expenditures of at least $25 for a period of four years.

The table below summarizes the expenditures discussed in this finding:

PayeeDateAmount
FedEx9/22/2024$31
Staples9/24/2024$849
Happy Donuts10/5/2024$51
ZipRecruiter10/25/2024$90
Costco Wholesale10/26/2024$110
Whole Foods Market11/5/2024$129
DocuSign11/30/2024$45

Finding VI-3. The Committee did not forfeit several prohibited contributions from business entities

Applicable Law

City law prohibits corporations, limited liability companies, or limited liability partnerships from making contributions to a candidate committee. C&GCC § 1.114(b).

A committee that receives a contribution which does not comply with the requirements of Section 1.114 must pay promptly the amount received or deposited in excess of the permitted amount to the City and County of San Francisco by delivering the payment to the Ethics Commission for deposit in the General Fund. Id. § 1.114(f).

Analysis

The Committee reported a total of 4,200 contributions from 2,660 individual contributors on Schedule A (Monetary Contributions Received) of the Form 460 during the audit period. Auditors reviewed filing data for all reported contributions and identified several contributors that appeared to be business entities based on the reported name.

During the audit period, the Committee made seven payments by check to the Ethics Commission totaling $7,240 for forfeited contributions. The Committee provided an itemized list of the individual contributions forfeited, which made up the aggregated totals in the seven forfeiture checks paid to the Ethics Commission.

Auditors compared the itemized forfeitures list to the list of identified contributors that appeared to be business entities and identified three contributions totaling $950 that had not been forfeited. Auditors confirmed that the Committee received each of the three contributions. In each instance, the contribution was made by check, and the payor name printed on the check was a business name, as opposed to an individual. Accordingly, the Committee should have forfeited an additional $950 pursuant to Section 1.114(f) for the three contributions prohibited by Section 1.114(b).

The table below summarizes the contributions discussed in this finding:

ContributorDateAmount
Molinari Associates, LLC (James Molinari)6/14/2024$500
R&I Glassworks7/25/2024$150
JT Evergreens9/13/2024$300

Finding VI-4. The Committee received a nonmonetary contribution over the limit from another candidate committee

Applicable Law

City law prohibits local candidate committees from accepting contributions cumulatively exceeding $500 in an election from any individual. C&GCC § 1.114(a). A committee that receives a contribution which exceeds the limits imposed by Section 1.114 must pay promptly the amount received or deposited in excess of the permitted amount to the City and County of San Francisco by delivering the payment to the Ethics Commission for deposit in the General Fund. Id. § 1.114(f).

A nonmonetary contribution is “made” by a contributor, and “received” by a candidate or committee on the date that the candidate or committee obtained possession or control of the goods or services or otherwise received the benefit of the expenditure. 2 CCR § 18421.1(f).

Analysis

The Committee reported a $500 nonmonetary contribution from the committee Boudin for District Attorney 2023 (the “Boudin committee”) dated August 27, 2024, for the purchase of donor emails. Support records for this contribution consisted of an invoice from the Boudin committee, which indicated a total cost of $720 for 1,600 emails. The invoice noted that $500 was subtracted as a nonmonetary contribution and indicated a balance due of $220. Auditors were unable to identify any record of a $220 payment. The Treasurer confirmed that the Committee had inadvertently not paid the remaining invoice amount. The Committee therefore received $220 in nonmonetary contributions over the limit from the Boudin committee and should have forfeited this amount to the Ethics Commission.

The table below summarizes the nonmonetary contribution discussed in this finding:

ContributorDateReported AmountAmount Per Invoice
Boudin for District Attorney 20237/27/2024$500$720

Finding VI-5. The Committee likely made a prohibited in-kind contribution to another candidate by paying for an event permit

Applicable Law

Funds in a candidate committee’s campaign account can only be used for the candidate’s own campaign or related office expenses, provided they are reasonably for a legislative, governmental, or political purpose. C&GCC § 1.122(b)(1). Contributions received by a candidate cannot be expended for the candidacy of any other candidate, for or against any measure or state ballot proposition, or for donations to charitable organizations. Id.

Analysis

The Committee reported a $791 expenditure to San Francisco Recreation & Parks dated October 23, 2024, with the description, “10/23/24: Permit for joint rally with Dean Preston. Candidate in attendance.” Support records consisted of a receipt dated October 23, 2024, from the San Francisco Recreation & Parks Permits Office in the amount of $791. The customer listed on the receipt was an individual named De’Marea Brandy, who was associated with the committee Dean Preston for Supervisor 2024 (the “Preston committee”). Auditors confirmed from the Preston committee’s campaign filings that Brandy was a paid employee of that committee. However, the indicated prepaid expense card number on the receipt matches that of the Committee’s PEX card, and Auditors confirmed in the Committee’s PEX Account Statement for October 2024 that the Committee had made the $791 expenditure to Recreation & Parks on October 23, 2024.

Auditors identified no record of a reimbursement from the Preston committee, and the Treasurer confirmed to Auditors that no reimbursement had been received to their knowledge. Auditors also verified that the Preston committee did not report any such payment to the Committee in its campaign filings. Because the Preston committee did not reimburse the Committee for its shared use of the permit for the joint event—presumed to be $396, or half the total cost of the permit—the Committee made a $396 nonmonetary contribution to the Preston committee. Section 1.122(b)(1) prohibits local candidate committees from using campaign funds to make contributions to other candidates.

The table below summarizes the expenditure discussed in this finding:

PayeeDateAmount
San Francisco Recreation and Parks10/23/2024$791

Finding VI-6. The Committee reimbursed campaign employees more than 45 days after the original expenditure dates

Applicable Law

A committee may reimburse a volunteer or paid employee for expenditures made on behalf of the committee if the committee’s treasurer is provided dated receipts and written descriptions for each expenditure, and the reimbursement is paid within 45 calendar days of the expenditure being made. 2 CCR § 18526(a). If reimbursement is not paid within 45 days, the expenditure must be reported on the campaign statement as a nonmonetary contribution received on the 45th day after the date of the expenditure by the person to be reimbursed. Id. § 18526(d).

Analysis

Auditors reviewed a sample of 124 expenditures and identified six expenditures to campaign employees that comprised reimbursements for various payments to subvendors. Based on a review of receipts provided by the employees to the Committee in connection with these reimbursements, Auditors identified 66 payments totaling $7,093 for which the employee was reimbursed more than 45 days after making the expenditure.

The table below summarizes the expenditures comprising the late reimbursed payments discussed in this finding:

PayeeDateAmount
Michael Redmond7/2/2024$983
John Shelley8/27/2024$1,087
Vivian Redmond9/12/2024$198
Anthony Leung11/1/2024$596
Michael Redmond11/18/2024$874
Jamie Hughes11/27/2024$560
Committee Response to Finding

The Treasurer provided the following comment: “During busy campaign periods it’s not unusual that these type of items are paid late.”

Finding VI-7. The Committee did not include proper spoken or text message disclaimers on several advertisements

Applicable Law

An “advertisement” is any general or public communication that is authorized and paid for by a committee for the purpose of supporting or opposing a candidate for elective office. Gov’t Code § 84501(a)(1).

In addition to complying with advertisement disclaimer requirements set forth in Government Code sections 84100 et seq., advertisements by candidate committees that support or oppose any candidate for City elective office must include the disclaimer statements, “Paid for by [insert the name of the candidate committee],” and “Financial disclosures are available at sfethics.org.” C&GCC § 1.161(a)(4). Local law also requires the format and size of disclaimer statements for a candidate committee to comply with the Political Reform Act’s disclaimer requirements for independent expenditures for or against a candidate. Id.

For audio and video advertisements, the disclaimers required by Section 1.161 must be spoken at the beginning of such advertisements. Id. § 1.161(a)(5).

For an advertisement that is a text message that supports or opposes a candidate, a candidate controlled committee must include a disclaimer, which, for local candidates, must comply with the requirements of Section 1.161(a)(4). Id., Gov’t Code § 84504.7(a)(1)-(b)(2).

Analysis

Auditors reviewed a sample of 124 expenditures, including 26 related to the production or dissemination of various forms of advertisements. Auditors inspected copies of the advertisements associated with these expenditures and identified six video advertisements, a radio advertisement, and a text message advertisement that did not comply with all applicable disclaimer requirements.

The identified video and radio advertisements did not fully comply with the spoken disclaimer requirement of Section 1.161(a)(5). Two videos titled “Alcatraz” and “Only Aaron” associated with payments to Beacon Media, and a video titled “Remember to Vote” associated with a payment to Jacopo Scano did not contain any spoken disclaimer. An additional two Beacon Media videos, titled “Recovery” and “Decades,” had the disclaimer spoken at the end of the video, instead of the beginning. The script for a Chinese language radio advertisement related to a payment to Sing Tao Radio also indicates that the disclaimer was spoken at the end.

Text message advertisements associated with a payment to Rough House Productions appear not to comply with Regulation 84504.7. Auditors reviewed a document containing a series of text message scripts targeting various categories of voters. No disclaimer was included with any individual message or elsewhere in the document, indicating that the text messages were likely sent without disclaimers.

The table below summarizes the expenditures related to the advertisements discussed in this finding:

VendorDateAmountType of Advertisement
Beacon Media, LLC.        7/3/2024$57,049Videos        
8/22/2024$50,000
9/5/2024$52,800
9/20/2024$35,500
10/11/2024$18,575
Sing Tao Radio10/2/2024$12,138Radio
Rough House Productions10/7/2024$3,961Text Messages
Jacopo Scano12/4/2024$600Video

Finding VI-8. The Committee received contributions that were likely prohibited under the City’s contractor contribution prohibition

Applicable Law

Under local law, no City contractor or affiliate of a City contractor may make any contribution to a candidate for an office for which the individual holding that office, or the board on which such an individual serves, must approve the contractor’s contract, for a period of 12 months after the date of contract approval. C&GCC § 1.126(b)-(c).

An individual holding City elective office, or the clerk of the board on which such an individual serves, must notify the Ethics Commission by filing Form SFEC-126 within five business days of the approval of each contract by the relevant officer or board. Id. § 1.126(f)(4), C&GCC Reg. § 1.126-4(a)-(b).

Pursuant to the contribution ban in Section 1.126, a committee will meet due diligence requirements if the contributor certifies under penalty of perjury, in writing, including in an electronic format, that the contributor does not meet the aforementioned criteria in Section 1.126. C&GCC Reg. § 1.126-7.

Analysis

Utilizing Form SFEC-126 filing data made publicly available on the Ethics Commission’s website, Auditors compared the affiliates and subcontractors reported by the Mayor’s Office to the contributors disclosed by the Committee. Auditors identified 18 contributors who appeared to be listed as either affiliates or subcontractors to contracts that were approved by the Mayor’s Office. Because the Candidate was a candidate for the office of Mayor, these contributions appear to have been prohibited by the City’s contractor contribution prohibition.

Notwithstanding, Auditors verified that the Committee included the language specified in Regulation 1.126-7 on contributor cards and its online contribution landing platform, and the Committee thereby likely met the due diligence requirement of Regulation 1.126-7.

The table below summarizes the contributions discussed in this finding:

Contributor/Affiliate NameContractor NameContract Approval DateContribution Date(s)Contribution Amount(s)
Alida FisherSan Francisco Unified School District11/11/20234/15/2024$150
Bruce FisherGood Samaritan Family Resource Center of San Francisco5/14/20246/21/2024$500
David MauroffSan Francisco Pretrial Diversion Project2/12/202410/30/2024$50
Francis SoElevated Tastes SFO Inc.4/16/20246/25/2024$500
James FaglerTransbay 2 Senior, L.P.2/26/20247/26/2024$250
James LoyceMission Neighborhood Centers, Inc.9/21/20237/13/2024$250
Jim IlligCurry Senior Center10/18/20236/27/2024$100
John SedlanderHomebridge, Inc.5/22/20247/12/2024 8/9/2024$100 $50
Peter WongPGH Wong and Partners JV4/17/20247/26/2024$300
Ringo WongElevated Tastes SFO Inc.4/16/20246/26/2024$250
Sam DennisonHarm Reduction Therapy Center7/31/202410/25/2024$500
Shanti SinghSFCLT TNFF Holdings LLC5/30/20234/9/2024$100
Timothy DurningLa Raza Community Resource Center, Inc.6/11/20247/2/2024 8/8/2024 8/23/2024 9/6/2024 10/3/2024$25 $25 $25 $25 $25 
Whitney JonesChinatown Community Development Center, Inc.11/6/20237/26/2024$500
Mariann CostelloSF Tourism Improvement District Mgmt Corp11/11/20236/27/2024$150
Matthew AlexanderSan Francisco Unified School District11/11/20236/21/2024$250
Camellia PeabodyPositive Resource Center8/30/202410/28/2024$500
Dawn KamalanathanSFUSD & NICJR1/31/20245/6/2024 6/28/2024 10/3/2024$100 $250 $50 
Committee Response to Finding

The Treasurer provided the following comment: “As stated, the committee met the due diligence requirement of Regulation 1.126-7.”

VII. Conclusion

Except as noted in the audit findings sections above, and based on the evidence obtained, Auditors conclude that the Committee substantially complied with the requirements of the California Political Reform Act and the San Francisco Campaign and Governmental Conduct Code. The Committee was provided a copy of this report and an opportunity to respond. The Committee’s comments are included in this report alongside the relevant finding.

This report and the support documentation on which it is based will be forwarded to the Commission’s Enforcement Division for further investigation and/or enforcement action as warranted. The scope of the audit is not exhaustive of all conduct of the Committee during the audit period, and any subsequent enforcement action may include conduct not covered in this report.

This Audit Report is intended to provide information about the Committee’s activities and its compliance with campaign finance requirements to the Commission, the Committee and its Treasurer, and San Francisco voters. This report, and all Audit Reports prepared by the Commission, will be posted to the Commission’s website at sfethics.org.

Appendix A

Objectives and Methodology

Audit Objective 1

Determine whether disclosed campaign finance activity materially agrees with activity in the Committee’s bank account.

Methodology:

  • Calculated total reported contributions and expenditures in the Committee’s filings and total reported credits and debits in the Committee’s bank statements.
  • Applied adjustments as needed to account for variations in transaction reporting between sources.
Audit Objective 2

Determine whether the Committee accepted contributions from allowable sources and in accordance with limits, appropriately disclosed those contributions, and maintained required contribution records.

Methodology:

  • Reviewed contributions submitted for public funds matching for compliance with limits and accuracy of contributor information.
  • Selected a statistically significant sample at a 95% confidence level and a 3.5%margin of error based on the total number of reported contribution transactions. Selected samples for testing from a range of periods, sources, and payment methods.
  • Reviewed each sampled transaction for compliance with state and local requirements regarding contribution restrictions, disclosure, and recordkeeping.
  • Performed additional targeted testing of contributions identified through analysis of filing data and support records.
  • Utilized automated procedures to analyze data extracted from the Committee’s filings. Identified contributions from prohibited sources and late-reported transactions. Verified identified noncompliance against support records.
Audit Objective 3

Determine whether the Committee made expenditures for allowable purposes, appropriately disclosed those expenditures, and maintained required expenditure records.

Methodology:

  • Selected a statistically significant sample at a 95% confidence level and a 3.5%margin of error based on the total number of reported expenditure transactions. Selected samples for testing from a range of periods, sources, amounts, vendors, and agents.
  • Reviewed each sampled transaction for compliance with state and local requirements regarding expenditure restrictions, disclosure, and recordkeeping, including any expenditures made to subvendors by agents or contractors of the committee.
  • Performed additional targeted testing of expenditures identified through analysis of filing data and support records.
  • Utilized automated procedures to analyze data extracted from the Committee’s filings. Identified late-reported transactions and verified identified noncompliance against support records.
Audit Objective 4

Identify any other evidence of potential noncompliance for inclusion in the audit report or referral for further investigation.

Methodology:

  • Analyzed data extracted from the Committee’s filings.
  • Analyzed support records obtained from the Committee.

Appendix B

Supplemental Table to Finding VI-5

Table B-1. Expenditures reimbursed by the Committee to campaign employees more than 45 days after the original payments.

EmployeePayment DateSubvendorReceipt AmountReceipt Date45th Day
Michael Redmond7/2/2024Ike’s$3684/1/20245/16/2024
Bread & Butter$394/1/20245/16/2024
Noah’s$334/1/20245/16/2024
LAZ Parking$284/1/20245/16/2024
LAZ Parking$244/1/20245/16/2024
Walgreens$844/6/20245/21/2024
IMCO Parking$204/6/20245/21/2024
IMCO Parking$204/6/20245/21/2024
OfficeMax$914/12/20245/27/2024
Civic Parking$124/21/20246/5/2024
Safeway$644/26/20246/10/2024
Ace Hardware$234/28/20246/12/2024
Ace Hardware$574/29/20246/13/2024
Costco$2034/30/20246/14/2024
Best Buy$1194/30/20246/14/2024
Ace Hardware$325/1/20246/15/2024
DoE$135/1/20246/15/2024
Unspecified$95/2/20246/16/2024
Ace Hardware$275/3/20246/17/2024
Staples$2975/4/20246/18/2024
OfficeMax$535/4/20246/18/2024
Ace Hardware$495/15/20246/29/2024
John Shelley8/27/2024Staples$1674/26/20246/10/2024
Noah’s$605/5/20246/19/2024
Costco$3395/11/20246/25/2024
OfficeMax$415/13/20246/27/2024
CVS$315/13/20246/27/2024
Best Buy$1575/18/20247/2/2024
Safeway$685/20/20247/4/2024
OfficeMax$3905/25/20247/9/2024
Twisted Donuts$616/9/20247/24/2024
Safeway$3406/27/20248/11/2024
Vivian Redmond9/12/2024Safeway$457/11/20248/25/2024
Cole’s Hardware$807/18/20249/1/2024
Lyft$227/18/20249/1/2024
Anthony Leung11/1/2024Sing Tao Daily$7008/6/20249/20/2024
Taobao$7159/11/202410/26/2024
Michael Redmond11/18/2024Safeway$229/13/202410/28/2024
House of Bagels$1029/14/202410/29/2024
Martha & Bros$769/14/202410/29/2024
Martha & Bros$779/15/202410/30/2024
Best Buy$1909/17/202411/1/2024
Martha & Bros$769/21/202411/5/2024
Ace Hardware$159/21/202411/5/2024
Martha & Bros$819/22/202411/6/2024
Bob’s Donuts$689/22/202411/6/2024
Trader Joe’s$259/25/202411/9/2024
Golden Eagle$179/27/202411/11/2024
Martha & Bros$769/28/202411/12/2024
Martha & Bros$769/28/202411/12/2024
The Jelly Donut$399/28/202411/12/2024
Happy Donut$439/29/202411/13/2024
Best Buy$6510/1/202411/15/2024
Best Buy$29710/3/202411/17/2024
Ace Hardware$4110/3/202411/17/2024
Jamie Hughes11/27/2024Lowe’s$215/1/20246/15/2024
Best Buy$1637/25/20249/8/2024
OfficeMax$858/3/20249/17/2024
Cole’s Hardware$168/21/202410/5/2024
Ace Hardware$108/26/202410/10/2024
OfficeMax$1038/27/202410/11/2024
Costco$2389/1/202410/16/2024
Ace Hardware$189/4/202410/19/2024
Grocery Outlet$1089/14/202410/29/2024
FedEx$559/17/202411/1/2024
Safeway$910/5/202411/19/2024

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