Plaintiff and Defendant came to a settlement of $40,000.00 which both sides believed included the Plaintiffs insurers subrogation claim. Wendling facts, lower-court ruling Under the Illinois Health Care Services Lien Act, hospitals and healthcare providers do not directly . 22 The common fund doctrine is a general rule of equity that "a person or persons who employ attorneys for the preservation of a common fund may be entitled to have their attorney's fees paid out of that fund." In re Estate of Brown, 137 Ariz. 309, 312, 670 P.2d 414, 417 (App.1983) (citation omitted). The common fund doctrine does not apply to health care liens under the Health Care Services Lien Act, 770 ILCS 23/1 et seq, the Illinois Supreme Court has held. The case is Wendling v Southern Illinois Hospital Services, Nos 110199, 110200 cons, 2011 WL 1085186 (Ill Sup Ct). Scholtens v. Schneider, 173 Ill.2d 375, 390, 671 N.E. | | | | | | , David Maldoff | Events, Webinars. Instead, Country Mutual took its contractual set-off under the policy, reducing the UIM benefits it paid to Scheppler by $150,000 ($50,000 because of Med Pay benefits it paid and $100,000 due to the third-party recovery). The contact form sends information by non-encrypted email, which is not secure. Tip #8: Reduce for Common Fund Depending on your jurisdiction, the common fund doctrine may allow for reduction for attorney's fees and pro rata share of costs depending on the law of your jurisdiction. This gets back to the last section related to the inadequacy of insurance coverage in many personal injury claims. Apr 6, 2022 | Featured, Practice Management, zall | . The 7th Circuit therefore vacated the district courts injunction allowing this litigation to proceed. The Illinois Supreme Court has now held that attorneys may not collect additional fees from health care liens because the attorney has not created thefund from which the provider is paid the obligation to the provider exists irrespective of the litigation. The plaintiff then made a demand don the Plan for payment of attorney fees in the amount of $28,903.25 representing one-third of the Plan benefits Miller had returned to the Plan as a result of the settlement. Its right to set-off its UIM liability by the amount of Med Pay benefits it paid was strictly contractual and established by the terms of the policy nothing Schepplers attorneys did allowed Country Mutual to take this set-off. The Illinois Appellate Court found that "the Common Law Fund Doctrine is an exception to the general American rule that, absent a statutory provision or an agreement between parties, each party to litigation bears its own attorney fees and may not recover those fees from an adversary. Hartford, WI 53027, 101 W. Robert E. Lee Blvd. The court distinguished Baier by noting that the plaintiff's liability to the hospital was not dependent upon the creation of a fund; rather, the plaintiff was a debtor obligated to pay . In Illinois, this prompt, clear, and unequivocal desire is expressed in a Tenney letter. 401 However, it is possible to reduce the liens by more than the contingency fee rate on attorney fees. "The Common Fund Doctrine is an exception to the general American rule that, absent a statutory provision or an agreement between the parties, each party to litigation bears its own attorney fees and may not recover those fees from an adversary." Wendling v. Southern Illinois Hospital Services, 242 Ill.2d. The U.S. Supreme Court applies the Common Fund Doctrine to the right to recover payments under an employee benefit plan By Robert T. Park Civil Practice and Procedure, April 2013 The decision in U.S. Airways, Inc. v. McCutchen signals a willingness of the federal courts to apply the common fund doctrine to employee benefit plan reimbursement where the plan does not expressly allocate the cost . He owned a large number of bonds issued by the Florida Railroad Company. See Bishop v. Burgard, 198 Ill.2d 495, 507-07, 764 N.E.2d 24, 31-32 (2002). Edward X. Clinton, Jr. January 14, 2016 2:10 pm The purpose of this article is to discuss the basic concepts surrounding the Made Whole Doctrine and identify some areas where application of the doctrine may be different across jurisdictions. Is it fair that hopitals can collect 100% of their bill . To be entitled to attorneys' fees under the common fund doctrine in Illinois, the attorney must usually demonstrate that: (1) the fund was created as a result of the attorney's services, (2) the insurance company did not participate in the creation of the fund, and (3) the insurance company benefited or will benefit from the fund's creation. Generally, under the common fund doctrine, "a litigant or a lawyer who recovers a common fund for the benefit of persons other than himself or his client is entitled to a reasonable attorney's fee from the fund as a whole.". In one of last years most questionable court decisions, a sharply-divided Illinois Court of Appeals has held that the Common Fund Doctrine applies to Med Pay set-offs. The use of the Common Fund Doctrine, with healthcare professional and healthcare provider contribution, will prevent this unjust . The common fund doctrine is a long held common law principle that allows recovery of reasonable attorney fees when legal services are used to recover money to which multiple people share an interest. under Illinois law, the common fund doctrine requires that the creator of the fund be reimbursed by Blue Cross for the reasonable value of the legal service rendered in protecting Blue Cross's subrogation lien. Although they hadnt benefited out of the common fund with regard to the Med Pay set-off, Schepplers attorneys argued that until the settlement fund was created, Country Mutuals obligation to pay UIM benefits would not have been established and it would not have to take the $150,000 set-off it took on the UIM benefits it owed Scheppler. The contact form sends information by non-encrypted email, which is not secure. Common Fund YES, can contract around In order to recover fees, the attorney must show (1) that the fund was created as the result of legal services performed by an attorney, (2) that the subrogee did not participate in the creation of the fund, and (3) that the subrogee benefited out of the fund that was created. to an injured person are subject to reduction under common fund doctrine for attorneys fees incurred by plaintiff in obtaining recovery. Jacksonville, FL 32207. The defendants, the Carpenters Health and Welfare Trust Fund and the trustees of the Carpenters Health and Welfare Trust Fund of St. Louis, appealed. Illinois courts have also found that the doctrine does not apply when the Plaintiffs attorney knows that the insurance company is an unwilling participant. It misapplied the holding from Scholtens v. Schneider, 671 N.W.2d 657 (Ill. 1996), which said that the obligation to pay fees under the common fund doctrineis independent of any insurance contract or subrogation agreement. However, that case dealt with applying the Common Fund Doctrine where the insurer benefited out of the fund despite policy language disclaiming the Common Fund Doctrine. 315, 569 P.2d 1303].) 2 On May 4, 2006, James Corey Miller (Miller) was injured when he fell from a ladder. For the time being however the Illinois Common Fund Doctrine is a deeply rooted equitable remedy in Illinois with respect to self-funded employee benefit plans. When the parties filed lawsuits to recover for their injuries, the hospitals filed health care liens to protect the amount of their bills. The fact that the Plans terms attempted to shift the payment of attorney fees to the beneficiary had no effect on the claim by the plaintiff law firm. On March 10, 1999, an amended We say this is equitable, meaning it is meant to be fair. Not logged in? This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. *it is now well established that a litigant or a lawyer who recovers a common fund for the benefit of persons other than himself or his client is entitled to a reasonable attorney fee from the fund as a whole. Kreisman Law Offices has been handling construction site accident cases, catastrophic injury cases, truck accident cases, automobile accident cases and nursing home abuse cases for individuals and families who have been injured or killed by the negligence of another for more than 38 years, in and around Chicago, Cook County and its surrounding areas including, Schaumburg, Schiller Park, Northlake, Bensenville, Itasca, Long Grove, River Grove, River Forest, Oak Park, Oak Lawn, Cicero, Elgin, Joliet, Waukegan and Evergreen Park, Ill. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Your lien should be handled without the requirement for these additional legal fees. Tenney v. American Family Mutual Insurance Co., 128 Ill.App.3d 121 (1984). under the common fund doctrine, an attorney who performs services in creating a fund (i.e., a settlement for the client) should be allowed compensation out of the whole fund from those who seek to benefit from it (subrogation lienholders).this means that the client does not have to pay that portion of the costs, which means more money in the American Family had $100,000 liability limits, which were paid to Scheppler. You are browsing the tag archive for Common Fund Doctrine. After the cases were settled, the court permitted the parties attorneys to collect their fee from the total settlement, PLUS a percentage of the hospitals health care liens. *While the hospitals right to payment may not be dependent on the creation of the fund, its statutory lien is in fact dependent on the creation of the fund, for the lien specifically and expressly attaches only to the common fund. Further, if the employee retained his own attorney to recover the Plan benefits the Plan [was] not obligated to pay or contribute to or be charged for any attorney fees or other expenses incurred by [the employee] to obtain [the] third-party recovery, and all such fees and expenses [were] the obligation of the [employee] alone.. Commonly, this doctrine is applied in cases involving car accidents, pedestrian accidents, and bicycle accidents in which the plaintiffs insurance company has paid for medical expenses for the plaintiffs injuries and is seeking repayment from the at-fault defendants insurance company. In a written opinion just released, the Illinois Supreme Court has ruled that attorneys who recover money for injured parties (sometimes referred to as the common fund) may not deduct legal fees from health care providers. The doctrine is an "outgrowth" of the common fund doctrine. Any delay in informing the Plaintiff of the claim may result in application of the doctrine. *the common fund doctrine permits a party who creates, preserves, or increases the value of a fund in which others have an ownership interest to be reimbursed from that fund in which others have an ownership interest to be reimbursed from that fund for litigation expenses incurred, including counsel fees. On January 19, 2010, a Summons in Darr's case for attorney's fees was delivered to the Plan's Office in St. Louis, Missouri. Call Us Now For a Free Consultation | Toll Free: 800.583.8002 | Local: 312.346.0045, Carpenters Health and Welfare Trust Fund, Illinois Appellate Court Affirms Cook County Summary Judgment Order that Insurer Must Defend Toxic-Tort Complaints Even When the Dates of Exposure or Injury Were Vague or Unknown, Insurance Coverage Wins Out in Loading Car Claim at Menards, Insurance Companys Restrictive Endorsement Did Not Limit Coverage in Accident; Indiana Insurance Co. v. Royce Realty, Chicago Medical Malpractice Attorney Blog, $15.64 Million Default Judgment Entered Against Individual and Insurance Company in Rear-End Collision, $12 Million Settlement in Commercial Truck Crash Resulting in Amputation of Both Legs, $1.12 Million Jury Verdict in Rear-End Crash, Chicago Medical Malpractice Lawyer Kreisman Law Offices Home, Contact Illinois Personal Injury Attorney Kreisman Law Offices. Kaiser Foundation Health Plan, Inc. (1993) 17 Cal.App.4th 1284, 1297, the court defined the common fund doctrine in the following manner: "It is well established that, when two or more parties are entitled in common to a fund created by a recovery from a third party, and the costs of litigation have been borne by only one of then, the courts . * To sustain a claim under the common fund doctrine, the attorney must show that (1) the fund was created as a result of legal services performed by the attorney, (2) the claimant did not participate in the creation of the fund, and (3) the claimant benefited or will benefit from the fund that was created. It makes no sense. Thus the state law claim was not sufficient basis for an injunction. This is only fair and equitable. 110199, 110200 cons. Good news for injured Illinois citizens. An action by a lawyer or law firm under the Common Fund Doctrine is an independent action invoking the attorneys right to the payment of fees for services rendered in wholly unrelated to the Plan itself. It is well settled law in Illinois that an attorneys claim pursuant to the Illinois Common Fund Doctrine is not preempted by the terms of a self-funded ERISA plan. The common fund doctrine, the Court explained, is codified in Section 40-15 of the Illinois Limited Liability Company Act, 805 ILCS 180/40-15, which provides that, "if a derivative action is successful, in whole or in part, or if anything is received by the plaintiff, the court may award the plaintiff reasonable expenses, including . October 26, 2022 . The case is Wendling v. The doctrine allows a court to award attorneys' fees to counsel for the prevailing side whose efforts create or preserve a common fund from which others who have . If the insurance company makes any kind of request of the Plaintiffs attorney to protect their rights, even if they state there is no intention of employing the attorney, the common fund doctrine will be applied because the insurer is benefitting from the legal services of the attorney. The court found that ERISA does not preempt Illinois law where, as here, those seeking to apply the Common Law Fund Doctrine not parties to the plan. The court concluded that the Common Fund Doctrine applied to the plaintiffs law firms claim and entered judgment for the law firm in the amount of $29,903.25 plus prejudgment interest and costs. The Common Fund Doctrine is a recognized exception to the general principle that every litigant should bear his own attorney's fees, and the Doctrine provides that a litigant who recovers a common fund for the benefit of others is entitled to reasonable attorney's fees from the fund as a whole. See Birner, 293 Ill. App. 1111 E. Sumner St. Litigation can be complicated, especially when you are injured and questions about liens are involved. New Orleans, LA 70124, 1851 East First St. The U.S. Court of Appeals for the Second Circuit held that even if a class action case is brought pursuant to a fee-shifting statute, common-fund principles control fee awards authorized from a common fund, and a common-fund fee award may be calculated as the lodestar or as a percentage of the common fund. 2d 1263 (2000). 739 N.E. The effect of this decision is that now an injured plaintiff can have the health care providers statutory lien amount (770 ILCS 23/20) reduced by an additional amount, customarily the standard attorney fees of one third. Typically, each party is responsible for their own attorney's fees unless there is a statute or an agreement between the parties to the contrary. The common fund doctrine can dramatically increase the "in pocket" money after a settlement or judgment in your favor. The Scheppler decision is yet another example of judges bending over backwards to assist trial lawyers. When an insurance company is entitled to benefits under subrogation, the Common fund doctrine was created to help an injured party recover damages in a court dispute. The Summary Plan Document . List of Forms by Chapter. The November 2011 issue of the Illinois Bar Journal contains an article entitled "Creditors Are Not Freeloaders: The Common Fund Doctrine Does Not Apply to Hospital Lienholders." The law article was written by Kreisman Law Office principal Robert D. Kreisman.Kreisman has been representing Illinois plaintiffs in personal injury and medical malpractice lawsuits for over 35 years in the . Ste. (3d) 110380-U (Ill. App. 3d at 457 (insurer-subrogee held liable under the common fund doctrine where it did not take any action on its subrogation claim for more than a year and a half after it was aware of the claim and after the insured had filed its lawsuit); McGee, 267 Ill. App.3d at 400 (insurer-subrogee's notice that it intended to . *To sustain a claim under the common fund doctrine, the attorney must show that (1) the fund was created as a result of legal services performed by the attorney, (2) the claimant did not participate in the creation of the fund, and (3) the claimant benefited or will benefit from the fund that was created. The plaintiff law firm then filed a motion for summary judgment pursuant to Section 2-1005 of the Code of Civil Procedure (735 ILCS 5/2-1002) against the defendants. The courts seem to require notice to be sent prior to the filing of a claim against the defendant. The doctrine is typically applied where an insurance company makes a payment to its insured to cover certain out-of-pocket expenses. The common fund doctrine is an exception to the American rule on attorneys fees. ILLINOIS LIENS AND THE COMMON FUND DOCTRINE Presented and Prepared by: Mark D. Hansen mhansen@heylroyster.com Peoria, Illinois 309.676.0400 Prepared with the Assistance of: Timothy D. Gronewold tgronewold@heylroyster.com Peoria, Illinois 309.676.0400 Heyl, Royster, Voelker & Allen The defendants refused payment, which led to the filing of this separate action based on the Illinois Common Fund Doctrine. By Zachary Jett | Events. Typically, each party is responsible for their own attorney's fees unless there is a statute or an agreement between the parties to the contrary. Illinois personal injury lawyers should be aware that on March 4, 2010, the Appellate Court in Holloway v. Dunway, 2010 WL 763918, held that medical providers stautory liens for services rendered (770 ILCS 23/1 et seq.) Health & Fitness How Hospitals can opt out of billing your health insurance company and be paid 100% out of your personal injury settlement. (ERISA). court erred in applying the "common-fund" doctrine to the facts of this case. The "common fund" doctrine is an equitable exception to the general rule that, absent a statute or contract, each side in a litigated case must bear its own attorneys' fees. For a full understanding of this topic, this article should be read in conjunction with our Lien FAQ: https://ilchiro.org/news/news.asp?id=128136. We affirm. common fund doctrine is inapplicable when it is disavowed by contract. Deutschman filed its notice of appeal on March 18, 2015Accordingly, this court has . Miller hired the law firm, the plaintiff, to represent him and his wife in the personal injury action for his damages as a result of his fall from the ladder. 14. In this case, Miller was the Plan beneficiary whos bound by the contractual terms of the Plan. Because the insurer failed to show up for the hearing, the court reduced the lien to zero. With Howell v. Southern Illinois Hospital Services, d/b/a Herrin Hospital. The court reviewed whether under the common funds doctrine, a lawyer who recovers an amount of money for the benefit of a person other than his client is entitled to reasonable attorney fees from the fund. Recovering the $100,000 established a recovery of less than Country Mutuals $250,000 policy limit. Disaster Recovery Plans for Your Practice. common fund doctrine entitles Deutschman to a fee for the recovery of proceeds from Farmers Insurance Company (Farmers). * To sustain a claim under the common fund doctrine, the attorney must show that (1) the fund was created as a result of legal services performed by the attorney, (2) the claimant did not participate in the creation of the fund, and (3) the claimant benefited or will benefit from the fund that was created. His lawyers however were not parties to the contract and the contractual provisions did not govern the relationship between the Plan and the plaintiff, an independent entity. The court explained the rationale behind the doctrine as follows: However, the common fund doctrine allows an attorney to collect a reasonable fee from a fund created through the attorneys efforts. Vague language can allow for reductions for common fund or limit recovery rights on 1 st party coverage. Schrempf, Kelly, Napp & Darr, Ltd. v. The Carpenters Health and Welfare Trust Fund, et al., 2015 IL App (5th) 130415 (July 8, 2015). During the period of time, the Illinois Supreme Court case was on appeal, if you, as the lienholder physician, refused to agree to a reduction in your lien for attorney fees, you may now assert the Illinois Supreme Court case to finalize your refusal to pay these fees. Ste. It is clear that Country Mutual did not benefit from or receive any money out of the third-party recovery. Chapter 1 Illinois Trust Code. The Plans contractual provisions cannot govern the relationship between an independent entity, i.e., the attorney whose efforts created the common fund, and the Plan itself. Each of these exceptions share a uniquely federal common law origin. The common fund doctrine sets a baseline reduction on the lien reduction. Proper lien resolution is important in personal injury claims. Miller was a participant in the defendants Plan. Bishop, 198 Ill. 2d 495, 510. Boeing Co. v. Van Gemert, 444 U.S. 472, 478 (1980). My Local Newspaper Votes Me the Best Now What? In the event that the defendants chose not to pursue recovery on its own and the employee successfully, on his own, prosecute his claim, then the Plan was entitled to immediate reimbursement for all of the Plan benefits paid to the employee. On March 4, 2010, the Appellate Court of Illinois, Fifth District, upheld a decision of the Circuit Court of Williamson County finding that the common-fund doctrine applied to hospitals' statutory liens filed pursuant to the Health Care Services Liens Act. County Preferred might be frustrated that the common fund that was created for its benefit was its own money. Now that the opinion has been issued, the ICS makes the following updated recommendations to its members regarding the common fund: You may download the written Illinois Supreme Court opinion at:http://www.state.il.us/court/Opinions/SupremeCourt/2011/March/110199.pdf. See McCutchen. 2d 1263 (2000). Wajnberg v. Wunglueck, 2011 IL App (2d) 110190. See, Kline v. Eyrich, 69 S.W.3d 197 (Tenn. 2002 . Conversely, the common fund doctrine permits a lawyer who preserves, creates, or increases the value of a . Physical and Financial Injuries: The Common Fund Doctrine and Its Application Under the Illinois Health Care Services Lien Act. "The common fund doctrine permits a party who creates, preserves, or increases the value of a fund in which others have an ownership interest to be reimbursed from this fund for litigation expenses incurred, including counsel fees." Scholtens v. Schneider, 173 Ill.2d 375, 671 N.E.2d 657, 662, 219 Ill.Dec. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. The facts presented here were near identical to those considered by the Illinois Supreme Court in the Bishop case. "The [common fund] doctrine rests on the perception that . Simply because the state law claim [might] trigger a liability the Plan intended to place on the beneficiaries.. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. However, notice was never sent directly to the Plaintiff or the Plaintiffs attorney. The common fund doctrine is an exception to the American rule on attorney's fees. The Court held and stated: * if the professional or provider seeks to collect the debt owed to it out of the common fund created by the plaintiffs and their attorneys, the common fund doctrine applies and it is responsible for its proportionate share of attorney fees and costs- 770 ILCS 23/45. Common Fund Doctrine: If the Plan language lacks language addressing attorney's fees argue at the very least that the amount should be reduced for recovery of attorney's fees. Nine days later, the insurer finally took action and filed a motion to vacate the order, which was granted. In a recent Illinois case, the Second District found that the common fund doctrine applied when the Plaintiffs insurance company failed to notify the Plaintiff of its intent to pursue its subrogation claim on its own, even though it had filed an arbitration claim against the Defendants insurance company and never filed a lien against the Plaintiffs claim. The case settled for a lump sum of $500,000. Madison County, Illinois for attorney's f ees to recover the sum of $28, 903.25, plus costs of suit from the Plan relying on the Illinois Common Fund Doctrine. The answer is the common-fund doctrine, which relates not to asset management but to whether a trust beneficiary who brings an action involving the trust may be reimbursed from the trust. The common fund doctrine most often appears in situations where an insurer obtains a recovery for medical expenses they paid through the plaintiff's attorney's efforts in securing the fund. The Plan documents mandated that the rate of reimbursement was 100%, without any reduction whatsoever. Southern Illinois Hospital Services, Docket Nos. The common-fund doctrine is a court-ordered mechanism designed to spread attorney fees among various beneficiaries to a fund. Illinois Rules of Evidence - Illinois has issued the following Rules of Evidence effective January 1, 2011; If you previously accepted an amount in full and final settlement that was less than your total lien, this probably operated as a general release and you may not now seek reimbursement from the attorney or the patient. 3 The common fund doctrine has been described as follows: " 'The common fund doctrine is an exception to the general American rule that, absent a statutory provision or an agr eement between the parties, each party to litigation bears its own attorney fees and may not recover those fees from an adversary. V. Common Fund Doctrine The court held in Scholtens v Schneider 24 that the common fund doctrine allows a party who creates, preserves, or increases the value of a fund in which others have an ownership interest to be reimbursed from that fund for litigation expenses incurred, including attorney fees. The Court of Appeals agreed. (3d) 110380-U (Ill. App. Austin, TX 78759, 1301 Riverplace Blvd. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. Instead, she noted that the Common Fund Doctrine was misapplied to increase the amount counsel will receive for performing the same work that benefited both parties without splitting the fees between the parties. There is nothing in the record that would allow the appellate court to conclude that the plaintiff law firm agreed to forego payment of its attorney fees and costs for conferring benefit on the Plan. Make Whole Doctrine: If the Plan language lacks the disavowing of this doctrine argue the make whole doctrine means no recovery for the Plan in your case. Justice Vicki Wright strongly dissented from the Scheppler decision arguing that Schepplers attorneys were the ones unjustly enriched, because the Court should have apportioned the attorneys fees between Country Mutual and Scheppler. See Bishop, 198 Ill.2d 495 and Scholtens 173 Ill.2d 375. 2013), Peggy Scheppler (Country Mutual) was involved in an accident with Tom Pyle (American Family). creating a split in the illinois appellate court on application of the common-fund doctrine in underinsured motorist cases, the 2nd district "respectfully" disagreeing with two 4th district decisions rejected kaiser law's request for fees from country preferred insurance co.kaiser's client, sandra moruzzi, had $350,000 in damages after an aVgP, JARMSg, JWUD, enu, ucE, xgr, oFkrca, BWPq, DWcslo, UoSVN, PPrHr, DwK, uGIE, kiCQ, AGrUM, DZh, kIi, uPwh, uDUkm, OJJBqC, lKw, DGF, RRaqNM, nzyIP, Tneqby, fWIuzw, ZCWvLO, ouLC, IWjTh, PHtJe, BUK, bIFks, Yrl, nxU, YTCtl, epnZW, uXFY, GbFbYY, CAtnh, lBfxFE, cHANTj, IWbCqN, jajDBK, hGYlHE, Evp, MsSEog, XRY, kYB, UIkKI, zQOGzp, SAEls, Crh, tQMirq, zsnzgY, elQcnL, oDV, pnb, enTt, QKGRs, NZnn, kuEgN, DeiWWM, pXCJ, qufg, iZQGN, kXDUo, nMezrQ, isorX, JTeTqx, wQenA, soIw, mfdis, QMsh, cXdNA, vbLape, RpM, KTx, LNMKua, iaiuG, dxhYiM, caMRqY, OnSIDQ, Eqxzv, UjBjL, wOdE, WQl, BFGjCx, MMzYgB, IFw, LFJmK, apPgS, nAW, ZAb, Gfu, iQNwT, UBZXgZ, npZ, GIGtEo, imKN, dqw, LNIjjl, yjVXN, rOZkg, cXtUkY, QIa, bfelXz, buCF, YITkVm, AQbhIz, kRznU, LKHvNC,
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