Phone: (215) 996-1785. at 7. v. Workers' Comp. Shannon P. Mickle, Haverford, for respondent N. Paone Construction, Inc. BEFORE: LEADBETTER, Judge, and BROBSON, Judge, and FRIEDMAN, Senior Judge. Partner Carrier Copyright 2023 All Rights Reserved. Crouse v. Cyclops Indus., 560 Pa. 394, 745 A.2d 606 (2000). You will love the mud room area off the garage. She concluded that the review petition was barred by res judicata because Claimant was aware of the left shoulder injury and agreed not to include it in the C & R agreement, citing Weney v. Workers' Compensation Appeal Board (Mac Sprinkler Systems, Inc.), 960 A.2d 949 (Pa.Cmwlth.2008). Plymouth Valley Estates by Sal Paone Builder. Fantastic open floor plan with a chef inspired kitchen, open dining area, main level study and amazing great room with gas a fireplace. Police set up a perimeter around the residence, and the tactical team was notified. WebInformation Related To N Paone Construction in Hatfield, PA 19440. 1120 North Bethlehem Pike, PO Box 280, Spring House, PA 19477 Appeal Bd. In 2012, Appellant was the owner, president, You can reach us on AND NOW, this 30th day of January, 2013, the order of the Workers' Compensation Appeal Board in the above-captioned matter is AFFIRMED. The Combined Opinion from On March 3, 2008, Claimant and Employer entered into a C & R agreement to settle Claimant's indemnity benefits for a lump sum amount of $175,000 as a full and final satisfaction of all future wage loss benefits. Exhibit D1; Reproduced Record (R.R.) In conclusion, Claimant's review petition was barred by the final and binding C & R agreement. The parties waived their appeal rights. WebN PAONE CONSTRUCTION INC is a DOT registered motor carrier located in LANSDALE, PA. View phone number, email, key contacts, trucks, drivers, inspections, insurance, check for fraud, cargo hauled, authority status and more. The property is the location of the corporate offices of N. Paone Construction Inc, and it is owned by NRP Properties, LLC, of 590 Kohlman Circle, Hatfield. Nothing in the record suggests that Employer promised to continue to pay medical bills for the left shoulder injury and that Claimant relied on such promise to enter into the C & R agreement. at 11, 14 and 15; S.R. Paone Builders, Inc Jan 1992- Present31 years 2 months Builder/Developer: Residential: builder, home improvements, additions, hardscaping Commercial: builder of multi-unit The North Penn Tactical Response Team is comprised of trained officers from Towamencin, Upper Gwynedd, Upper Merion, Lower Salford and Franconia townships and Telford Borough. We proudly offer a fully furnished sample open Tuesday to Sunday 1-5. WebN. We invite you to come take a look we are sure you will like what you see. Company Owner/Manager: If you see any incorrect information on this page, pleasecontact the DOT directly to make changesto correct your record. The Board affirmed WCJ Callahan's decision, concluding that the evidence did not indicate that the C & R agreement was entered into by a unilateral or mutual mistake. She indicated that if Claimant was alleging the medical bills only for the left shoulder injury, the penalty petition would be denied. Employer's voluntary payment of medical expenses was not an admission of its liability for the left shoulder injury and cannot be construed as a promise to continue to make such payment. the Court. Appeal Bd. our Backup, Combined Opinion from Levin & Co., 800 A.2d 374 (Pa.Cmwlth.2002)(holding that the right to recover alleged in the complaint was conclusively settled between the parties upon approval of the stipulation and its incorporation in the judgment). Claimant sustained a work-related closed head injury on February 26, 1996 and received disability benefits pursuant to a notice of compensation payable issued by Employer. WebGet coupons, hours, photos, videos, directions for N Paone Construction at 3220 Bergey Rd Hatfield PA. Search other General Contractor in or near Hatfield PA. WebCheck your spelling. (Schuh), 16 A.3d 1221 (Pa.Cmwlth.2011); Findlay Twp. Plymouth Valley Estates by Sal Paone Builder. Compare McKenna v. Workers' Comp. He disputes that res judicata applies to this matter, noting that unlike in Weney, there was no prior litigation involving a request to amend the description of his work injuries. The company received ; Thatcher's Drug Store of W. Goshen, Inc. v. Consol. Judges: WebFind 2 listings related to N Paone Construction in Hatfield on YP.com. Paragraph 24 of the proposed addendum stated: The accepted injury includes a closed head injury, seizure disorder, left shoulder fracture, chronic pain, loss of short-term memory and Bipolar Disorder. Hanrahan said a male in the residence made threats to a friend via text message that he intended to harm himself. A party invoking the doctrines of promissory and equitable estoppel has the burden of establishing all the elements of the doctrines. 1925(a) Opinion, is as follows. Q. Employer did not accept its liability for the left shoulder injury in the notice of compensation payable or in any agreement, and specifically refused to include it as part of the C & R. Nor was there any prior decision finding Employer liable for that injury. at 8. Dubow, J. All of our models are designed with today?s lifestyle in mind. "The subject followed directions and cooperated with police," Hanrahan said. The subject was not injured, Hanrahan said, adding that the subject was alone in the residence. Paone Construction, Inc. And I read it more than once. March 3, 2008 Hearing, Notes of Testimony (N.T.) . [D]o you understand that if I approve this agreement, once it's approved, you can't go back to the Employer, the insurer, a Judge, anyone and ask for additional payments of wage-loss benefits? The record instead demonstrates that he negotiated the extent of his work injuries with Employer and ultimately agreed to omit the left shoulder injury in the agreement. (Korach), 584 Pa. 411, 883 A.2d 579 (2005). Providence Reserve is a community of 52 homes with 16 Singles, 10 Twins, and 26 Town homes. WebN Paone Construction, Inc Business Data 113 Veronica Ln, Lansdale, Pennsylvania, 19446-1498 (215) 996-1785 AllBiz Business Profile Background Search FAQ's about Nick Q. Employer states that Claimant flagrantly misrepresents that the left shoulder injury was erroneously omitted in the final draft of the C & R agreement. Claimant sought to impose a penalty upon Employer in the amount of 50% of the $1200 medical bills. Court:Commonwealth Court of Pennsylvania. (EthanAllen Eldridge Div. 2 of N Paone Construction Inc's trucks include auxiliary power units. By enacting Section 449, the General Assembly intended for C&R Agreements to be "on equal footing with civil, Once a C&R Agreement is approved by a WCJ, it is final, conclusive and binding on the parties, and may not be, Full title:Michael DePUE, Petitioner, v. WORKERS' COMPENSATION APPEAL BOARD (N. Paone. He claims that the left shoulder injury was erroneously omitted in the final draft of the agreement. at 5. This Contractor is listed on All contractors & builders with a speciality in B2B Contractors . An approved C & R agreement can be set aside only upon a clear showing of fraud, deception, duress, mutual mistake, or unilateral mistake caused by an opposing party's fault. It is your responsibility to independently verify the information on the site. WebN Paone Construction is a practicing in Hatfield, Pennsylvania. Q. From Free Law Project, a 501(c)(3) non-profit. In order to maintain an action in promissory estoppel, the aggrieved party must show that (1) the promisor made a promise that he or she should have reasonably expected to induce action or forbearance on the part of the promisee; (2) the promisee actually took action or refrained from taking action in reliance on the promise; and (3) injustice can be avoided only by enforcing the promise. Section 449(a) and (b) of the Workers' Compensation Act (Act), Act of June 2, 1915, P.L. N Paone Construction Inc Contact Information Phone Number: (215) 852-4925 Edit Address: 113 Veronica lane, Lansdale, PA 19446 Edit Do you work for this USA, Inc. v. Workers' Comp. on CaseMine. Spring House, PA Home Builder - Sitemap Id. Sign up for free Patch newsletters and alerts. We seek to ensure that all of the data presented on the site regarding new homes and new home communities is current and accurate. at 5b. Q. Servs. Claimant cannot rely on Employer's voluntary payment of the medical bills for the left shoulder injury to support his estoppel claims. N PAONE CONSTRUCTION INC information is sourced from the DOT and is public information available through the FOIA. WebN. The [WCJ] shall consider the petition and the proposed agreement in open hearing and shall render a decision. Law Project, a federally-recognized 501(c)(3) non-profit. We also find Claimant's reliance on the doctrines of promissory and equitable estoppel to be inapposite. The record simply does not support Claimant's assertion that the left shoulder injury was erroneously omitted in the final draft of the C & R agreement. v. Workmen's Comp. Breast Ultrasound Screening Coming Direct to You! WebFree and open company data on Pennsylvania (US) company N. PAONE CONSTRUCTION INC. (company number 2225718), 3220 Bergey Road, Hatfield, PA, 19440 N PAONE CONSTRUCTION INC information is Brought to you by Free Law Project, a non-profit dedicated to creating high quality open legal information. Paone was sentenced to time served, plus a $5,000 fine and five years of supervised released, which ends in 2014. Id. [Emphasis added.] "Numerous attempts made by the friend and radio to communicate with him were unsuccessful," Hanrahan said. Id. WebHomes by N. Paone Construction, Inc. CLOSED OUT. Employer submitted WCJ Kelley's March 3, 2008 decision approving the C & R agreement (Exhibit D1); the transcript of the March 3, 2008 hearing held on the petition to approve the C & R agreement (Exhibit D2); and a packet consisting of a proposed addendum to the C & R agreement prepared by Claimant's counsel with changes and a handwritten notation made by Employer's counsel thereon, and the February 27, 2008 letter of Employer's counsel sent to Claimant's counsel (Exhibit D3). Try adding more details such as location. The Board stated that Claimant [was] attempting to raise a matter through his Review Petition that should have been litigated during the earlier proceedings on the C & R Agreement, pursuant to Weney. Board's Opinion at 6. CourtListener is sponsored by the non-profit Free Law Project. A. The agreement must be explicit with regard to the payment, if any, of reasonable, necessary and related medical expenses. WebN PAONE CONSTRUCTION INC is a motor carrier operating under USDOT Number 1869681 in Pennsylvania. WCJ Kelley found that Claimant understood the full legal significance of the agreement as regards [his] work related injury and right to workers' compensation benefits. WCJ Kelley's Finding of Fact No. Steven H. Kitty, Doylestown, for petitioner. Our community is located in beautiful Upper Gwynedd Webhis petition for assessment of a penalty against N. Paone Construction, Inc. (Employer) for failure to pay medical bills for the left shoulder injury. Site: npaonehomes.com. WebGet coupons, hours, photos, videos, directions for N Paone Construction at 3220 Bergey Rd Hatfield PA. Search other General Contractor in or near Hatfield PA. You can reach us on phone number (215) 996-1785, fax number or email address . Because Claimant did not expressly reserve his right to add a new injury to the description of his work injuries, he was precluded from doing so more than two years after the approval of the C & R agreement. WebN Paone Construction Inc's commercial over-the-road transportation services may include specialized, flatbed, or heavy haul driving. Sign up to receive the Free Law Project newsletter with tips and announcements. Appeal Bd. Copyright 2001-2023 Builders Digital Experience, LLC. When you walk through the community you will notice attention to detail and homes to fit different tastes and budgets. The injuries subject to the C & R agreement were described as any and all injuries suffered at North Paone Construction Company, including but not limited to the accepted injuries of a severe closed head injury with seizure disorder and short term memory loss. The Train fare to N Paone Construction costs about $3.75 - $9.25. The essential elements of equitable estoppel are the party's inducement of the other party to believe certain facts to exist and the other party's reliance on that belief to act. Claimant argues that the C & R agreement should be corrected to add the left shoulder injury to the description of his work injuries accepted by Employer. Once a C & R agreement is approved, any issue which was not expressly reserved in the agreement may not be raised later. Police attempted to make contact to the subject via cell phone and via the friend. at 6. Michael DePue (Claimant) appeals from the order of the Workers' Compensation Appeal Board (Board) that affirmed the decision of the Workers' Compensation Judge (WCJ) denying (1) his petition for review seeking to add a left shoulder injuryto the description of his work injuries more than two years after approval of the Compromise and Release Agreement (C & R agreement) and (2) his petition for assessment of a penalty against N. Paone Construction, Inc. (Employer) for failure to pay medical bills for the left shoulder injury. The North Penn Tactical Response Team and an armored Bearcat were called in because there was a threat of firearms, according to Hatfield Township Detective Pat Hanrahan. For driving directions, please contact the builder. All rights reserved. She determined that the parties entered into a valid and binding agreement. WCJ Kelley's Conclusion of Law No. Phone : 215-996-1785 Are you entering into this agreement of your own free will? In support, he relies on the contract construction rule that the intention of the parties must be ascertained from the document itself if its terms are clear and unambiguous. Appeal Bd. Three days after the WCJ approved the stipulation and granted the review petition, the claimant filed another review petition to amend the notice of compensation payable to add neck or cervical spine injuries. WebHomes by N. Paone Construction, Inc. CLOSED OUT Learn More About this Market Communities In Philadelphia Area Homes in Philadelphia Area Community Info Providence Reserve/Carriages Providence Reserve is a community of 52 homes with 16 Singles, 10 Twins, and 26 Town homes. How much is the Train fare to N Paone Construction? Bellefonte Area Sch. 5; R.R. Now, they have agreed to continue paying medical expenses, which are reasonable and necessary and causally related to your injury. This Contractor is listed on All contractors & builders with a speciality in B2B Contractors . Description: Our company has over 25 years in the remodeling Communities In Philadelphia Area ; Homes in Philadelphia Area . (Morgan), 156 Pa.Cmwlth. Appeal Bd. "For the safety of everyone, the police SWAT was called in," Hanrahan said. Vince Pennoni signed the agreement on Securitas Sec. Employer agreed to continue to pay all reasonable and related medical bills. Id. Westinghouse Elec. 4; R.R. He was not asked and did not testify as to the left shoulder injury. See N Paone Construction, PA, on the map. NewHomeSource.com is a trademark of Builders Digital Experience, LLC and all other marks are either trademarks or registered trademarks of their respective owners. N. Paone Builders, Inc Address: 113 VERONICA LANE Lansdale, PA 19446 Use our bidding system to request a quote N. Paone Builders Mason Their BuildZoom Our community is located in beautiful Upper Gwynedd Township. 304, 627 A.2d 250, 254 (1993), aff'd,545 Pa. 70, 680 A.2d 823 (1994). In Weney, the claimant's first review petition was resolved by a stipulation, in which the parties agreed to amend the notice of compensation payable to include a shoulder injury. (Rockwell Int'l), 869 A.2d 1075 (Pa.Cmwlth.2005); Barszczewski v. Workers' Comp. VMSC medics are also part of the civilian response of the tactical team. v. Workers' Comp. ), 932 A.2d 309 (Pa.Cmwlth.2007). at 12 and 14. After negotiations with Employer, Claimant agreed to omit the left shoulder injury from the description of his injuries accepted by Employer in the C & R agreement. Appeal Bd. Click here to see more Our new community, Plymouth Valley Estates, will include 79 single-family-detached, luxury homes on .25 - .50 acre lots. ; R.R. WebThe Bus fare to N Paone Construction costs about $2.00. Police were dispatched to the home at 1:45 p.m. for a report of a suicidal subject. And do you also understand that's true even if your condition were to worsen or change in any way? Q. WebFounder and president, Nick Paone, started N. Paone Construction in 1992. WebMontgomery County PA Home Builder | Sal Paone Builders Build your dream home or choose from any of our single family, carriage homes, or adult community homes today. The Kohlman Circle address is owned by Nicola Paone. He asserts that Employer routinely paid medical bills for the left shoulder injury and that it knew that the bills were causally related to [his] injuries. Id. Claimant sustained a work-related The relevant facts are undisputed. Learn More About this Market. This browser is no longer supported. Copyright 2015 Sal Paone Builder. Dep't of Labor & Indus., Bureau of Workers' Comp. Have you had enough time to review the agreement? We Company Owner/Manager: If you see any incorrect information on this page, please. ; Supplemental Reproduced Record (S.R.) However, we do not assume any liability for inaccuracies. Subscribe M. DePue v. WCAB (N. Paone v. N. Paone Constr. On direct examination, he testified as follows as to his understanding of the C & R agreement: Q. Michael, you understand that the gross settlement is $175,000? Promissory estoppel may be invoked to enforce a promise made by a party to an opposing party when there is no enforceable agreement between the parties. Exhibit D1; R.R. Because Claimant was not permitted to add a new work injury after approval of the C & R agreement, we affirm. North Penn Teacher Wins VFW 'Teacher Of The Year', Safety Concern Shuts Down Playground At Fischer's Park In Towamencin, $1.5 Million Roundabout Project Begins On Old Skippack Road, Discover Your Future - STEM for Girls in 5-8th grades, Open House - Check Out The NEW Total Fitness & Golf Gym, College Financial Aid and Funding Workshop at Southern Lehigh Public Library. On September 7, 2010, Claimant filed another petition seeking to review his benefits, alleging that the description of his work injuries was incorrect. Q. The last MCS-150 form date is listed as 9/5/2013. Please switch to a supported browser or download one of our Mobile Apps. See also Lance v. Mann, 360 Pa. 26, 28, 60 A.2d 35, 36 (1948)(applying the merger doctrine to hold that judgment settles everything involved in the right to recover, not only all matters that were raised, but those which might have been raised); Smith v. I.W. rely on donations for our financial security. Montgomery County public land records shows the property is a commercial parcel with one living unit and a mixed residential/commercial structure. 1688 EDA 2020. (Dillard), 850 A.2d 795 (Pa.Cmwlth.2004). The relevant facts are undisputed. And you and I have been discussing this settlement offer for at least a couple of months? WebAbout N Paone Construction: N Paone Construction in Hatfield Twp Area, PA is a business listed in the categories Builders & Contractors, General Contractors & Building It is well established that a valid C & R agreement, once approved, is final, conclusive and binding on the parties. (Plouse), 768 A.2d 1193, 1196 (Pa.Cmwlth.2001). This home has a pending offer. WebFind your new home in Providence Reserve/Carriages at NewHomeSource.com by N. Paone Construction, Inc. with the most up to date and accurate pricing, floor plans, prices, photos and community details. Appeal Bd. OPINION BY Judge LEADBETTER. In a subsequently issued interlocutory order, WCJ Callahan precluded Claimant from proceeding on the review petition and scheduled a hearing on the penalty petition to determine whether Claimant was alleging unpaid medical bills for the left shoulder injury only or for other injuries accepted by Employer. Appeal Bd. 1831 N. Gravers Rd is currently under construction and will be the Doylestown Floor plan with 4 bedrooms, 2.1 Baths. Community Info. Dep't of Labor & Indus., Bureau of Workers' Comp. Appeal Bd. Appeal Bd. Get directions now. Were the terms of this agreement explained to you to your satisfaction? Claimant further argues that the description of the injury in the C & R agreement as any and all injuries sustained at Employer's workplace indicates the parties' intention to include the left shoulder injury in his injuries accepted by Employer. WebN. In enacting Section 449 of the Act, the legislature intended a C & R agreement to be on equal footing with civil settlements in order to promote a public policy of encouraging the parties to settle disputes and bring them to finality. Employer argues that Claimant was entitled to receive medical benefits only for the injuries described in the C & R agreement as accepted by Employer and that the review petition was barred by res judicata and collateral estoppel. WebHomes by N. Paone Construction, Inc. CLOSED OUT Learn More About this Market Communities In Philadelphia Area Homes in Philadelphia Area Community Info After a hearing held on March 3, 2008, WCJ Susan Kelley approved the C & R agreement and adopted and incorporated its terms as her own findings of fact. The Most Popular Urban Mobility App in Philadelphia. Make your practice more effective and efficient with Casetexts legal research suite. Hanrahan said a hostage negotiator communicated with the subject via a bullhorn and public address system from the armored vehicle sent to the scene. The listed MCS-150 Mileage and year for N Paone Construction Inc is 12,000 (2008). ; R.R. v. Workers' Comp. Stroehmann Bakeries, Inc. v. Workers' Comp. 1831 N. Gravers Rd is currently under construction and will be the Doylestown Floor plan with 4 bedrooms, 2.1 Baths. See Sun Co. (R & M) v. Pa. Turnpike Comm'n, 708 A.2d 875 (Pa.Cmwlth.1998). None known, Docket Number: All rights reserved. And those are your initials. The company began framing houses in some of the most sought out communities in both Montgomery A construction company and its sole owner were jointly and severally liable for the amount plaintiff paid to another contractor to complete a building project. at 21 b, 24b and 25b. All of our homes at Providence Reserve live up to the N. Paone reputation of quality workmanship. The injuries subject to the C & R agreement were described as any and all injuries suffered at North Paone Construction Company, including but not limited to the accepted injuries of a severe closed head injury with seizure disorder and short term memory loss. Id. On September 13, 2010, WCJ Bonnie Callahan held a hearing on the petitions. Appeal Bd. You understand that? Farner v. Workers' Comp. Appeal Bd. Were you promised anything that's not in this agreement to settle your Workers' Compensation Case? Michael DePUE, Petitioner, v. WORKERS' COMPENSATION APPEAL BOARD (N. Paone Construction, Inc.), Respondent. (Phillis), 996 A.2d 1111 (Pa.Cmwlth.2010). Paone Construction, Inc. A company that builds not only homes but communities. at 9. Search the web for: n paone construction hatfield This case has not yet been cited in our system. Claimant's appeal to this Court followed. Fine & Decorative Arts Auction | Jewelry | Artwork | Furniture | Silver, Delaware Valley University Hosts Raising Livestock on a Small Farm Community Course This Spring, Snow, Ice, Possible Flooding With PA Storm: See Latest, 4 Reasons Why Sleep is Important for Chronic Pain Patients, Montgomeryville-Lansdale Area Adoptable Pets: Cats & More, PA 24th Senatorial District Race Still Remains Close, $5.85 Million Verdict For Montco Family In Eminent Domain Case, Historic Designation For Lansdale Train Station, PA House Passes Bill To Rename Road For Famous Montco Resident, Bill Establishing PA Chief Nursing Officer Approved by State Senate. Home styles range from 4 bedroom single family to Town homes with two or three bedroom with or without lofts. WebWCAB (N. Paone Construction, Inc.) Receive free daily summaries of new opinions from the Supreme Court of Pennsylvania. Welfare, 26 A.3d 1251 (Pa.Cmwlth.2011)(holding that the Court may affirm the lower tribunal's order if the lower tribunal reached a correct result, although the basis for the decision is not entirely correct). Montgomery County, PA Home Builder - Find your new home today | Montgomery County Single Family Homes, If you're ready to move we have a variety of move-in ready options. As the Court has consistently held, an employer's voluntary medical payment does not constitute an admission of liability for an injury. If you are eager to make a move, and have your heart set on a quality new home built by Sal Paone Builders,an Express Delivery Home can be a perfect choice. Colmar Fire Police had closed off Bergey Road from Richmond Road to Bethlehem Pike. Registration: 1988. The C & R agreement was final and binding on the parties and may not be amended after its unappealed approval. 736, as amended, added by Section 22 of the Act of June 24, 1996, P.L. Because Claimant was not permitted to add a new work injury after approval of the C & R agreement, we affirm. Firedex of Butler, Inc. v. Workers' Comp. WebThe relevant factual and procedural history, as gleaned from the trial court's Decision and Pa.R.A.P. January 3rd, 2022, Precedential Status: Q. WebFind 2 listings related to N Paone Construction in Hatfield on YP.com. Claimant's Brief at 14. Employer's exhibits showed that before the execution of the C & R agreement, Claimant's counsel sent a proposed addendum to the agreement (paragraphs 19 through 25) to Employer's counsel. The following opinions cover similar topics: CourtListener is a project of Free It has a total of 2 trucks and 3 drivers. Utilizing the 2003 Life Tables, she determined that Claimant had the life expectancy of 30 years or 1560 weeks and was entitled to receive a prorated value amount of $401.04 a month. at 7 (emphasis added). WebOpinion for Store Road, LLC v. N. Paone Const. 3220 Bergey Rd, Frnt 1 Hatfield, PA 19440 Montgomery County. The subject was transported via Volunteer Medical Service Corps of Lansdale to for evaluation. WebDoing business as: N Paone Construction. See reviews, photos, directions, phone numbers and more for N Paone Construction locations in Hatfield, PA. To support his petitions, Claimant submitted a pre-trial memorandum (Exhibit C1), in which he alleged that Employer informed him in January 2010 that it would no longer pay for treatment of his left shoulder injury. A 33-year-old suicidal man barricaded in a home at 3220 Bergey Road in Hatfield Township was taken into custody around 5 p.m. after a three-hour standoff with Hatfield Township Police and the North Penn Tactical Response Team. In its answer, Employer denied Claimant's allegations and sought dismissal of the review petition invoking res judicata and collateral estoppel. Supermarkets, Inc., 535 Pa. 469, 636 A.2d 156 (1994). (U.S. Food Serv. On July 19, 2010, Claimant filed a penalty petition alleging that Employer failed, neglected or refused to pay medical bills.
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