Dallas Resources – August 1997
By Ed Housewright and Brooks Egerton
Waxahachie - The bishop who headed the Dallas diocese during most of the years that the Rev. Rudolph "Rudy" Kos sexually abused boys remains active as an assistant pastor in Waxahachie.
During the trial, plaintiffs were told retired Bishop Thomas Tschoepe couldn't testify because he has Alzheimer's disease.
Bishop Tschoepe, 81, says Mass about 10 times a week at St. Joseph's Catholic Church and maintains a full schedule, the pastoral administrator and some parishioners said Thursday after Bishop Tschoepe finished a Mass.
Bishop Tschoepe said in a brief interview that he takes medication for anemia.
"My memory's not good," he said before turning away from a reporter and later driving off. "That's going way back. I don't have anything to say. I stayed out of it the trial. I told them I wasn't going to testify.
"Whatever you heard during the trial, half of it isn't true."
Asked later whether he had Alzheimer's, Bishop Tschoepe laughed and declined to comment.
A doctor's affidavit on file at the courthouse confirms that Bishop Tschoepe has Alzheimer's, Randal Mathis, the diocese's attorney, said Thursday night. He said plaintiffs' attorneys never questioned the finding. Sylvia Demarest, a plaintiffs' attorney, said she subpoenaed the former bishop but was told he was too ill to testify.
"There's absolutely no doubt in my mind about the medical diagnosis based on my own observation and the doctor's evaluation," Mr. Mathis said. "If Bishop Tschoepe had been able to testify, I would have called him as a witness."
He said "without a doubt" Bishop Tschoepe would have helped his case.
"Bishop Tschoepe was bishop of the diocese during virtually all of the years involved in the circumstances surrounding Rudy Kos," Mr. Mathis said.
Roger Rosenberg, director of the Alzheimer's Center at University of Texas Southwestern Medical Center at Dallas, stressed that he is not familiar with Bishop Tschoepe's case and has not examined him, but said that people with Alzheimer's can "on the surface appear to be functionally adequate.
"Things that are rehearsed are retained," and that could include driving a car, reading a newspaper, going shopping and saying Mass.
He also added that the disease affects people differently.
In his brief comments, Bishop Tschoepe said he didn't know of any sexual abuse by Mr. Kos from 1981 to 1990 when he was bishop. Bishop Charles V. Grahmann, who succeeded him and removed Mr. Kos in 1992 after the first youth complained of sexual abuse, has apologized three times in recent weeks for the abuse.
"Things were going all right," Bishop Tschoepe said of his years heading the Catholic Diocese of Dallas, acknowledging that he ordained Mr. Kos as a priest.
A nurse who is a parishioner at St. Joseph's said after Mass on Thursday that Bishop Tschoepe, who became assistant pastor after stepping down as bishop in 1990, appears to be in good health.
"He's very active," Kaylene Mongeau said. "There's nothing wrong with his mind. He's never exhibited any behavior that would indicate he had any neurological disorder at all.
"He says he has anemia, but I don't see any evidence of it. I've had him over to eat at my home. He eats like a horse."
Another parishioner, Helen Autrey, said she has seen Bishop Tschoepe picking up trash on the church grounds during sweltering days.
"He's always available," Ms. Autrey said. "You wouldn't believe what people call on him to do."
Bishop Tschoepe also is active in Dallas. He presided over the confirmation Mass earlier this year at St. Bernard of Clairvaux in the White Rock area of Dallas, St. Bernard parishioner Mike Daniel said.
And he's scheduled to return in late August for the parish's 50th anniversary celebration.
"He's filling in for Bishop Grahmann on a number of occasions," said Mr. Daniel.
Ms. Demarest said she was surprised to learn that Bishop Tschoepe is apparently keeping a full schedule.
"We wanted him to testify," she said. "Randy just said he had Alzheimer's. We subpoenaed him. They brought in a medical statement, saying he was too ill to testify. We had to accept that."
Ms. Demarest said Bishop Tschoepe was leading the diocese when suspicions were first raised about Mr. Kos and that "he didn't act appropriately."
According to testimony during the 11-week trial, Bishop Tschoepe met in 1985 with the first priest to voice concerns about Mr. Kos having boys stay overnight in his rectory room.
The Rev. Daniel Clayton, who was Mr. Kos' supervisor at St. Luke's Catholic
Church in Irv
"You are the only one I have to turn to," Father Clayton wrote in August 1986. "My instincts tell me that to do nothing is not a solution."
That same month, the diocese's personnel board asked Bishop Tschoepe to warn Mr. Kos in a letter that he would be suspended if he continued having boys overnight.
Bishop Tschoepe never wrote that letter, the former No. 2 diocese official, Monsignor Robert Rehkemper, testified. Instead, Monsignor Rehkemper warned Mr. Kos orally, but the sleepovers continued, according to testimony.
The jury wanted to hear Bishop Tschoepe testify, jury forewoman Susan Koons said Thursday.
"If anyone should've testified, it's him," she said.
Jurors weren't told during the trial why Bishop Tschoepe was absent, Ms. Koons said. She assumed he was dead, then heard after the verdict that he had Alzheimer's.
"My father has Alzheimer's," Ms. Koons said. "You don't let them drive. They're watched 24 hours a day."
One of the plaintiffs, Jim Sibert, said he too had heard that Bishop Tschoepe couldn't testify because he has Alzheimer's.
"It upsets me, but I'm not surprised," Mr. Sibert said after being told that Bishop Tschoepe maintains an active schedule. "I have come to believe that the church will hide behind anything they can."
In a 1994 interview with The Dallas Morning News , Bishop Tschoepe denied that church officials ever covered up sexual abuse.
Asked whether any abuse occurred, he said: "A little bit. It's all blown out of proportion."
In a deposition that same year, Bishop Tschoepe said several times that he couldn't remember details relating to Mr. Kos.
He declined to testify about other priests in the diocese molesting children. During the trial, testimony was introduced about former priests Robert Peebles Jr., who has acknowledged sexually abusing up to 20 boys from 1979 to 1986, and William Hughes, who is accused of sexually abusing a 13-year-old girl in 1984.
"Can you tell me what other such problems you're aware of?" Windle Turley, the other plaintiffs' attorney, asked Bishop Tschoepe in the deposition.
"I don't think it would have anything to do with this case," Bishop Tschoepe replied.
Mr. Turley, insisting that the cases were related, said: "Could you tell me about the other incidents, please?"
"No, I don't think so."
"You would refuse to answer that question?"
"Yes. Because you give it to the press, and there it goes. I don't think it has anything to do with - with the case here."
At one point, Mr. Mathis, the diocese's attorney, interrupted questioning to say that "there are clearly some memory difficulties involved in my representing Bishop Tschoepe."
Later, plaintiffs and defense attorneys agreed to postpone further questioning - "to see if the witness does better after he recovers from his cataract surgery," as Ms. Demarest put it then.
If the retired bishop's condition was knowingly misrepresented, the court may consider imposing sanctions, said Linda Eads, a law professor at Southern Methodist University and an expert on legal ethics.
"If I were the judge, I would want to know what's going on," she said.
State District Judge Anne Ashby, who presided over the trial, could not be reached for comment.
If the retired bishop's condition was knowingly misrepresented, the court may consider imposing sanctions, according to Ms. Eads.
Ms. Mongeau, one of St. Joseph's parishioners, said she was saddened by the accounts of Mr. Kos' sexual abuse but doubted that Bishop Tschoepe covered up anything or acted inappropriately.
"He's a very straightforward, plain-talking person who's also compassionate," Ms. Mongeau said. "His head and heart are straight. There's no deceit in him whatsoever, no desire to hurt anyone. I don't think he would have allowed something like that if he knew it."
By Renae Merle, Associated Press
Dallas - The parents of 11 boys sexually abused by a former Dallas Catholic Diocese priest should share the blame for not detecting the abuse, the priest who was second-in-command at the time said Friday.
``If they were not responsible, why is the diocese responsible?'' said Monsignor Robert Rehkemper, who was vicar general of the diocese for most of the 11 years that the Rev. Rudy Kos abused the boys. ``We live in an age when people don't want to be responsible for anything.''
Last month, a Dallas jury found the diocese grossly negligent in preventing the abuse of 11 children, including one who committed suicide, and awarded Kos' victims $119.6 million.
Diocese attorneys say they are planning to appeal. Kos, meanwhile, awaits a criminal trial for sexual contact with one child and indecency with another; both were plaintiffs in the civil lawsuit.
Rehkemper, 73, was a central figure in the highly emotional 11-week trial. During his four often-heated days on the stand, he testified that he would've attempted to have Kos removed had he known about the abuse, but what he heard wasn't much more than suspicion.
Plaintiffs attorneys argued that Rehkemper was in the best position to stop the abuse.
On Friday, Rehkemper said he's saddened for the victims, adding that he prays for them every day.
``This should not have happened to them,'' he said.
But, he added, if the parents didn't realize the abuse was taking place, then the diocese should not have been expected to.
``It irks me that they should sue the diocese over something Kos did,'' Rehkemper said.
Both Rehkemper and diocese attorney Randal Mathis pointed out that the priest is not speaking for the entire diocese.
``The diocese has never taken the position that this is the fault of the parents,'' Mathis said.
The Sunday after the trial ended, Bishop Charles Grahmann apologized to victims and their families during a Mass they were expected to attend. Grahmann became bishop after Kos' tenure.
Gail Pawlik, the mother of two victims, said Rehkemper's attitude angered her.
``If any of the parents had any shred of an idea that our kids were being abused they never would have gone back there,'' said Pawlik, whose youngest son, Steve, was the first victim to step forward.
Pawlik added that she would like to see Rehkemper removed from the church.
``He has destroyed so much,'' said Pawlik, who said she is part of one of the founding families of Dallas' All Saints Catholic Church, where Rehkemper is a priest.
Diocese spokesman Michael McGee said the diocese is not going to second guess the parents on this issue.
``We need to move forward and to be a lot more aware of what is going on in our diocese,'' he said.
McGee added that speaking to the media may be a way for Rehkemper to heal.
``He's human too,'' McGee said.
Rehkemper said the abused children were at the age when they knew right from wrong and should have told their parents of the abuse.
``It is hard for me to believe that all 11 of them were so traumatized that they couldn't tell anyone,'' he said. ``Ideally, it was their responsibility to tell someone about'' the abuse.
He added that for most kids when they know something is wrong they will either stop or tell their parents.
``They were not all infants, they were children growing up,'' Rehkemper said. ``They knew it was wrong.''
Plaintiff's attorney Windle Turley pointed out that the role of the parents was discussed with the jury during the trial and jurors still found the diocese at fault.
Turley said Rehkemper's comments are insensitive as well as hurtful to the victims.
``Rehkemper is straight out of the dark ages,'' Turley said.
Sylvia Demarest, another plaintiff's attorney, also was upset by Rehkemper's comments.
``I would thought, given the jury verdict, the attitude of the diocese would have changed,'' Demarest said. ``But obviously it hasn't.''
But Dr. Gail Alexander, an assistant professor of psychiatry at the University of Texas Southwestern Medical Center at Dallas, said many young victims are not able to tell adults about the abuse.
``They feel guilty, like they are the ones doing something wrong,'' said Alexander, who is not associated with the case.
She said a child will often feel trapped and believe that the adult is right.
``Often it is worse when they are older because they feel more responsible,'' she said.
By Brooks Egerton with contributions by Michael D. Goldhaber
A National Conference of Catholic Bishops leader and several other top clerics knowingly allowed a child-molesting priest to work for at least 20 years in Massachusetts, New Mexico, West Texas and Colorado, their correspondence shows.
Repeated transfers of the now-imprisoned Rev. David Holley provide a case study in how bishops have cooperated to protect pedophiles in the priesthood, say experts who have tracked hundreds of clergy-abuse cases around the country.
Catholic Church officials dispute that assertion, saying they lacked knowledge about pedophiles' incurability until the early 1990s and now are moving to flush out "wolves in sheep's clothing."
Indications that bishops understood the danger much earlier appear in their own writings, which were in personnel files that some of Father Holley's former parishioners obtained in litigation a few years ago. The Dallas Morning News recently reviewed the documents, whose contents were sealed under out-of-court settlements and have never been made public.
"This man has been . . . accused of molesting teenage boys on at least two occasions - most recently in a hospital from which he has been barred - and with carrying around and showing to these boys pornographic magazines and books," wrote Worcester, Mass., Bishop Bernard J. Flanagan in a 1968 therapy referral.
Those allegations and similar ones forced Father Holley out of his home diocese of Worcester and led to a series of transfers in the Southwest, the correspondence shows.
In 1982, Bishop Joseph A. Fiorenza wrote that he knew of Father Holley's "past difficulties" and stated: "With our shortage of priests, I am willing to risk incardinating him" - which means formally making him a priest of the Diocese of San Angelo, Texas.
At the time, Bishop Fiorenza headed that diocese. Today, he governs the Diocese of Galveston-Houston and, as vice president of the national bishops group, is expected to become president next year.
Bishop Fiorenza, 66, declined interview requests, saying through spokesman Ron Regan that he didn't want to revisit old traumas. "The church needs to move beyond this," Mr. Regan said Thursday .
Father Holley isn't the only child molester whom Bishop Fiorenza has allowed to continue working. After going to Houston in 1985, the bishop reassigned a priest caught in the act of abusing a girl and offered her no help, according to published reports that his spokesman doesn't dispute. The woman who discovered the abuse said the diocese pressured her not to tell police.
Mr. Regan said the Houston diocese, like the Catholic Diocese of Dallas and many others, now has a policy of investigating all abuse allegations and putting anyone accused on leave.
Father Holley, 70, didn't respond to interview requests. He was sentenced to prison in 1993 for molesting young boys in Alamogordo, N.M., two decades earlier. He is serving a maximum sentence of 275 years at the Western New Mexico Correctional Facility in Grants, N.M.
During Father Holley's 30-year career as a priest, bishops sent him for inpatient psychiatric treatment at least twice, then institutionalized him again when abuse allegations resurfaced in the early 1990s after he'd retired.
One of the hospitalizations was initiated by Bishop Fiorenza's now-deceased predecessor in San Angelo, Bishop Stephen A. Leven, who wrote in 1977 that Father Holley was "a calculated risk."
Other revelations in the bishops' correspondence:
* Bishop Flanagan, now retired, wrote in 1970 that he would help Father
Holley find "a benevolent bishop who could use his services"
after evidence of molestation emerged in three Massachusetts parishes.
The first record of abuse in his personnel file was made in 1968, though
Father Holley has testified that it was reported to Bishop Flanagan during
his first parish assignment, from 1962 to 1964.
* Wilmington, Del., Bishop Thomas J. Mardaga refused to take on Father
Holley but expressed openness to other priests "who have experienced
difficulties in their own communities. This has been our policy . . ."
Bishop Mardaga died more than a decade ago.
* While under Paraclete care, Father Holley served as an assistant pastor
at an Alamogordo church until the mid-1970s. His personnel file contains
no record of allegations being made against him then, but his immediate
supervisor, the Rev. Wilfrid Diamond, later testified that several victims'
families told him of abuse at the time. Father Diamond - who said he himself
was once put under Paraclete care for having sex with a woman - is now
Denver archdiocesan officials said they granted Father Holley the right to work at a Catholic hospital after the Worcester diocese assured them that he was a priest in good standing. Mr. Delisle, the Worcester spokesman, said he didn't have access to the priest's personnel file and couldn't comment.
In the early 1990s, Father Holley and some who supervised him were sued in New Mexico and Massachusetts. More than a dozen Alamogordo victims later received undisclosed amounts from the Diocese of Worcester, as well as the Diocese of El Paso, of which Alamogordo once was a part; the Servants of the Paraclete; and a clinic to which the order sent Father Holley.
Separately, four Massachusetts men received settlements from the Diocese of Worcester, according to published accounts. One man has said he got $12,500; the other amounts weren't disclosed.
The Alamogordo suit led to criminal charges of sexual assault and sodomy, to which Father Holley pleaded guilty. Before being sentenced, he told the judge that he empathized with the young men who had testified against him.
"When they shared their pain, their embarrassment, their anguish, their suffering, I was able to identify with them," The Associated Press quoted the priest as saying.
One of the victims, Robert Curtis, said Thursday he never felt that Father Holley had taken responsibility for his actions. But the greater crime, he said, was committed by the bishops who "shuffled him around to unsuspecting little towns."
"Those people deserve to be in jail, too, as far as I'm concerned," said Mr. Curtis, who was an 11-year-old paperboy when Father Holley first approached him in the early 1970s. "They were consenting to what he did. They put every one of those kids in harm's way, including me."
To this day, he said, none of those clergymen has apologized personally to him.
The Rev. Thomas Doyle, a church-law expert who formerly worked in the Vatican Embassy in Washington, D.C., said Father Holley worked in an unusually large number of dioceses. But the broad outlines of his story, Father Doyle said, are not unusual.
"In numerous dioceses in this country, priests reported for sexual misconduct with children were transferred not only once but often several times," he wrote in a 1996 report for lawyer Sylvia Demarest. She is one of the plaintiffs' attorneys who recently won a $119.6 million judgment against the Diocese of Dallas and suspended priest Rudolph "Rudy" Kos.
In a confidential 1985 report to all U.S. bishops, Father Doyle warned of the emerging pedophilia scandal and offered advice on combating it. After the document's key recommendations went ignored, he began working as an expert witness for victims suing the church - a role he played in the Dallas trial.
In a recent interview, Father Doyle said he did not believe bishops transferred molester priests out of ignorance of pedophilia's seriousness.
Such an argument "is absolute lunacy," said Father Doyle, now a chaplain at Tinker Air Force Base in Oklahoma City. "Everyone knows it's a felony" to sexually abuse a child. Yet, church officials, he said, long failed to report cases to police.
No record could be found that Father Holley's supervisors ever reported him to secular authorities. Texas and New Mexico required such notification.
In 1992, the National Conference of Catholic Bishops first spoke with one voice about abusive priests; some bishops also met with a group of victims. That same year, Cincinnati Archbishop Daniel E. Pilarczyk, then president of the bishops group, issued this statement:
"In the matter of priests and sexual abuse, undoubtedly mistakes have been made in the past. Until recently, few in society and the church understood the problem well. People tended to treat sexual abuse as they did alcoholism - as a moral fault for which repentance and a change of scene would result in a change of behavior. . . .
"Where lack of understanding and mistakes have added to the pain and hurt of victims and their families, they deserve an apology and we do apologize."
Archbishop Pilarczyk called for "far more aggressive steps . . . to protect the innocent, treat the perpetrator and safeguard our children."
He said new policies were already in place, "notwithstanding the fact that such sexual misconduct has involved relatively few priests measured against 53,000 priests in our country."
Father Doyle said nearly 1,000 pedophile priests have been identified over the last 15 years, most through criminal or civil charges. Knowledge of the problem was already widespread when he worked in the embassy a decade ago and sent the Vatican information about cases as they came to light, he said.
"In numerous dioceses across the United States from the 1970s through the early '90s," his report to Ms. Demarest states, "complaints of child abuse were handled in such a unified fashion as to indicate a meeting of the minds as to how best to prevent public knowledge of the abuse, avoid criminal prosecution and suppress potential claims. . . .
"How was such a commonly practiced plan of action arrived at? The bishops' activities in and through the National Conference of Catholic Bishops/United States Catholic Conference would provide an informal forum."
That line of thinking initially led Ms. Demarest to name the bishops group as a defendant in the Kos case. The group resisted in pretrial motions, and she backed off - fearing, she said, that she couldn't prove it had a duty to her clients, at least as that term has been interpreted by the Texas Supreme Court.
Still, she noted Friday, "the Dallas jury found that there was a conspiracy" to cover up abuse by Mr. Kos. "The question arises: Is the conspiracy limited to the Dallas diocese and the parties from outside the diocese who cooperated with them?"
Ms. Demarest said she still struggles to fathom why the church she was raised in has harbored child molesters.
"They needed the bodies" because of the priest shortage, she said. "They were very confident they would be able to prevent the public from finding out."
Former priest A.W. Richard Sipe, who worked at one of the hospitals where Father Holley was institutionalized and has counseled hundreds of pedophile priests, advanced another explanation in a report for Ms. Demarest: that bishops simply didn't consider molestation a major sin, even though they felt it needed to be concealed "to protect the reputation and finances of the Catholic Church."
"After I was ordained in 1959, I learned that some priests had sex with adults and even minors, and to some degree this was taken for granted by church authorities," he wrote.
"The secret world of sexual activity, including sexual activity with minors, was known by the Catholic hierarchy, and though considered unfortunate and morally wrong, was accepted as an inevitable and easily forgivable failure of some priests."
Sister Mary Ann Walsh, a spokeswoman for the bishops' conference, rejected that assessment, although stressing that she didn't know enough about the Holley case to address its specifics.
"This criminal activity is absolutely appalling and always has been," she said. Asked why clerics long failed to report the crimes, she suggested that both they and the priests' victims didn't want to call public attention to "something that was rightly considered sordid."
The bishops' conference now calls for all dioceses to comply with reporting laws and develop abuse-prevention strategies. Since 1992, it has also continued to elaborate on guidelines for dealing with victims, the accused and the community.
Both of the molestation cases that Bishop Fiorenza is known to have dealt with in Houston surfaced in 1986. And both involved priests caught in the act of molesting children, the Houston Chronicle reported in 1992.
The bishop wouldn't talk to the Houston newspaper, which said its calls to him were returned by Monsignor Daniel Scheel, then the diocese's chancellor.
The monsignor wouldn't discuss details of the cases then and maintained that "things were a lot different" when the crimes occurred. "We didn't know about the tendency of these people to repeat their acts."
One case occurred in Navasota, where social worker Ramona Ybarra reported finding the Rev. Fernando Noe Guzman on the floor, pants down, with a 13-year-old girl. Ms. Ybarra told the Chronicle that she later met with Monsignor Scheel, who urged her not to cooperate with police and who transferred Father Guzman to a Galena Park parish.
In a deposition, Monsignor Scheel said he accepted Father Guzman's characterization of the girl as a "precocious child who came on to him." He said he didn't ask her name or age, so the diocese didn't contact her to offer counseling.
Bishop Fiorenza, in his deposition, said he had left the matter in Monsignor Scheel's hands.
The story was unpublicized for a few years, until Father Guzman impregnated a Galena Park church secretary. After she sued, the priest acknowledged the 1986 abuse and was criminally prosecuted. He served 90 days in jail but was not defrocked, the Chronicle reported.
In the other case, a Houston police officer discovered his own priest performing a sex act on an 11-year-old boy in a van. The Chronicle quoted another officer as saying that the Rev. Donald L. Stavinoha laughed about his arrest and predicted that nothing would happen to him because "I'm a priest."
The boy's family sued the diocese and won payments for counseling. Father Stavinoha, stripped of most priestly powers, later pleaded guilty to sexual assault and was imprisoned for a little more than a year.
The two priests' whereabouts are unknown, said Mr. Regan, the diocese
"When acts of sexual misconduct do occur, the diocese strives to respond with compassion and healing love."
Bishop Fiorenza - the first from a Southern diocese elected to a top post in the bishops conference - is a native Texan who has stressed social justice issues.
He headed the church's national anti-poverty program, the Campaign for Human Development, in the early 1990s. He has called for breaking the cycle of poverty and helping the poor build "a better life for themselves and their children."
In an interview with The Morning News last year, Bishop Fiorenza talked about the rapid growth in many of his parishes and the corresponding shortage of pastors. He said he hoped that his flock would be inspired to bring forth new priests.
"We would like to emphasize strengthening family life, bringing moral teachings into the public arena . . . ," the bishop said. "We believe it's a biblical value to welcome the stranger and care for the poor. And of course a high priority is the reverence for life, particularly the unborn child."
In a 1993 affidavit in the New Mexico lawsuit, Father Holley testified that "my psychosexual disorder first began to manifest itself in approximately 1962." That was the year Bishop Flanagan accepted him in the Diocese of Worcester on a trial basis from the Benedictine order, in which he'd gotten his start as a priest in 1958.
Well before he was officially made a diocesan priest in 1967, he testified, "Bishop Flanagan had received reports that I had sexually molested boys" in three parishes. "On at least two occasions Bishop Flanagan called me in to discuss the allegations, cautioned me against causing a scandal in the church, but he expressed no comments about my victims."
Almost 30 years later, four middle-aged men came forward, trying to get the Worcester Diocese to acknowledge the abuse they suffered as boys. They said the church told them in 1993 to sue if they wanted compensation for therapy, according to The Globe; diocese officials declined to comment on that allegation.
Months earlier, at their general assembly, the nation's bishops had passed a resolution saying that they'd "reflected - once again and more deeply - upon the pain, anguish and sense of alienation felt by victims. . . . "
"We pledge ourselves to one another to return to our dioceses and there to examine carefully and prayerfully our response to sexual abuse; to assure ourselves that our response is appropriate and effective; and to be certain that our people are aware of and confident in that response."
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