FULL TESTIMONY: Lindsay’s Mother-in-Law Gives Emotional Testimony on Postpartum Struggles

FULL TESTIMONY: Lindsay’s Mother-in-Law Gives Emotional Testimony on Postpartum Struggles

Good morning. ” Good morning. ” I’m just going to ask you to speak into that microphone. Keep your voice up if you could. All right, council. ” Good morning. ” Good morning. ” And just tell us your name and spell it, please. ” Susan Clancy. Susan N. C L A N C Y. And what time you live? ” Situate. ” And you’re married to Chris.

” Yes. ” And both you and Chris are mother and father. ” Correct. ” Yes. ” Tell us what your relationship was with Lindsay. How you know her? very good relationship. ” And did you have occasion to go to their home in ” Weouth? I did. ” And then in Daxberry as well. ” Correct. ” And obviously you and your husband were the grandparents of the three little kids.

” Yes. ” And um how was your relationship with with the babies? ” Yes. And um tell us how how frequently to your memory you were able to visit with your son Lindsay and of course your grandchildren. ” At least a couple times a month we see them. ” Um at some point by the way what do you do for work? ” Um iron.

” I’m sorry. An iron. ” An iron. ” And what type of uh any focus? ” I worked in the labor and delivery room for about 38 years. ” 38 years in labor and delivery. correct ” helping women that were having babies and obviously you kept up with the studies and continuing education and things. ” Yes, I did. ” To that extent um in your capacity as a an IN 38 well back then it would have been 35 years of experience I think.

” Yes. ” Um fair to say that you as I said you would keep up with all of recent developments in postpartum psychosis postpartum depression all of that. somewhat but I only just was in the delivery room. ” So were you aware of the various positions that were in the forefront if you will of postpartum studies as it relates to medicine? ” Yes.

” And [cough] would one of the people that you were interested in be a person by the name of Dr. Meg Spanelli? ” Yes. And can you tell us who Meanelli is? ” I don’t really know who Meg Spinelli well. We’ve spoken a couple of times. I believe she specializes in postpartum mental health. ” And have you met with her before? ” Not in person.

” Okay. Did you at some point ask Dr. Spanelli to help out at your hospital? And I guess they call it a rounds lecture. I asked her to um bring on her experience in education in that area and share it with my colleagues. ” Did she do that? ” She did. And as time went by, um dealing with uh your job, your family, your son, daughter-in-law, grandchildren, um did you notice in 2022 after Ken was born any change in the personality, if you will, of Lindsay? ” Uh several months after that, I did.

” Would that be sometime in the fall? ” Yes. And can you tell the jurors at being as close as you were with the family? Well, let me back up. As a mother-in-law, did you have any observation to observe Lindsay with her kids? ” Yes. ” Can you tell the jurors about how you saw her acting with her children as a mother? ” She was very nurturing, [cough] very loving. She was a wonderful mother.

” Did you ever see her treat her middle son Dawson bad because you didn’t like him? because she loved us in European. ” She loved her children, all of them, very very much. ” And during that period of time in let’s say October, November of 2022, what did you observe about Lindsay? ” She reached out to me in November and told me that she felt unwell.

” Did she describe any symptoms for her? ” She did. ” Tell the jurors what she said. She felt um mostly she had insomnia. She was losing her appetite. She was um very anxious and sad. ” Did she tell you that she was um seeing doctors? ” Yes. ” And at some point did you recommend um did she come to you and ask you for help regarding seeing a doctor? ” Yes, she asked for my support.

” And did you you obviously gave it to her? Yes. ” And what did you do to make any recommendations for them? ” I [snorts] reached out to my colleagues um who were running a clinic for women that was struggling postpartum. ” That’d be [clears throat] the Southshore. ” Yes. Correct. ” And at some point as a result of your intervention was a um a nurse practitioner Julie Hall uh agreeing to step in and help out.

” Yes. ” Did Lindsay see Julie? I believe she did. ” And you really pretty much were out of the mix at that point. You basically made the connection, knew that she gone there, right? ” Correct. ” Did you find that that Lindsay was interested at all times trying to get better and and see doctor? ” Very much so.

” Did you find at all? Do you have an opinion with your observations of Lindsay as to whether or not she was offered help and would just spurn it and not see doctors and not have treatment? ” She was begging for help. And during that period of time um you were there for her by text and by telephone and in person.

” Correct. ” Now during that time that you were let’s say November and into December the holiday season. Do you recall the holidays for 2022? ” Yes. ” Tell us was that a fun time for the Clancies? ” Lindsay was struggling. We were all very concerned. Um, you knew in January uh, New Year’s actually that she ended up going to hospital.

” Yes. ” You know that she eventually get out of the ML hospital? ” Yes. ” Um, fair to say that you and Lindsay, as I said, communicated a lot by text messaging, right? ” Yes. Correct. ” So, I’m going to approach you with extraction report. This is a report that is done by the DA’s office of the state police on what’s called celebrate where they can go into they examine your phone.

” No. ” The exam Lindsay’s phone and obtaining texts. Have you seen the texts? ” I think so. ” Okay. I’m going to approach you with the extraction report. Okay. And just take a look and see. if your telephone number is on there just for foundation purposes or if you it is okay. And just quickly flip through and see if you recognize those texts.

You won’t have to look at all of them. That’s for sure. They appear to be text between you and Lindsay. ” Mhm. ” Okay. ” Um, your honor, I’m not going to go through each and every text. What I’m going to suggest is I would offer this and then the jurors would be able to look at what they wish. ” Any objection just makes the same objection previously.

All right. Over the communction that may be admitted. ” Thank you very much. ” Come. [clears throat] Good morning. ” Good morning. ” So, you um indicated that you’ve um were a labor and delivery nurse for 38 years. ” Mhm. ” And um what hospital was that? ” South Hospital. ” And early on in in um the defendant’s career, you uh did you work with her ” briefly? And um she then went to Mass General. Correct.

” Yeah, she was a student at the time. ” Okay. Um, and you stated that you are aware of a doctor named Meg Spinelli, correct? ” Yes. ” Did you reach out to her in this case? ” I don’t remember exactly how she and I connected. I I don’t recall. ” Well, you indicated that um you connected with her in a professional capacity to have her come to your hospital, right? ” Yes.

 But as far as um her role in this case with the defendant, did you reach out to her for that? ” I don’t think I did. I don’t recall. ” Um now [clears throat] you said that you began to notice um some issues in um well C defense council said October, November, but fair to say you weren’t aware of what was going on until she texted you on November 16th when she was at the emergency room.

” Yes. ” And that was at Sasha Hospital. Yes. ” And you actually met her there at the emergency room? ” Yes. ” Was she by herself or with Patrick? ” She was by herself. ” Um, did you know how she got there? ” She drove ” She drove herself to the hospital. ” Correct. ” And um, she was in the emergency room for a while. Correct.

” I don’t know how long. Probably an hour, maybe two hours. ” Well, you went down when you knew she was there. Sat with her for a little bit. Went back upstairs to your Because you were working that day, right? ” Correct. I wasn’t able to go down immediately. I had to wait about an hour and a half and then I went down.

” Okay. And then you sat with her for a little bit. You went back up to work, ” right? ” Yes. ” And then you came back down at some point before she was discharged. ” Yes. ” Council, can I see just very briefly? So, Mrs. Clancy, um you you came down to

the emergency room and you sat with her for a while, correct? ” Yes. ” And did she tell you um why she was there? ” Yes. ” And fair to say, she indicated to you that she was um having trouble sleeping and she had some heart palpitations. ” Correct. And that’s what brought her to the emergency room to get checked out? ” Yes.

” Did she tell you that she had um consumed a weed gummy before going to the ER that day? ” She did not. ” Okay. And um in your experience as a nurse, is um that sometimes a reaction to um THC or CBD or some sort of weed um that somebody might have a faster heartbeat? ” I don’t know. Um, now when she was in the emergency room, uh, she was seen by a doctor and provided some medication.

 Were you there when the doctor was there? ” Yes. ” And you’re aware that the doctor, the ER doctor gave her some Trazadone to help her sleep. ” Yes. ” Because that’s what she was really concerned about, right? The sleep. ” Yes. ” And um, when she left the emergency room, did you call her an Uber or have Pat come and get her or call your husband to come get her? ” No.

” She left in her own car, right? ” Correct. Um, and so fair to say after that ER visit, you you remained in pretty constant contact with her at least via text message, right? ” And that um you would check in with her pretty much daily and that’s all in in these texts. ” Yes. ” Um now you um were familiar with the beh the perinatal behavioral health clinic because of your work at Social Hospital.

Correct. ” Correct. And so the person actually that you connected with first was not Julie Paul, was it? ” No, it was one of the midwives that I was working with ” and her name is Nanette, ” I think. So ” And so did she provide you with Julie Paul’s contact information? ” She suggested Julie. ” Okay.

 And as a result of these the suggestion, you reached out to Julie with Lindsay’s permission, right? ” Yes. And um you said that at that point you made the contact, knew she had spoken to Julie and you kind of um stepped back from the clinic. ” Mhm. ” Yes. You’re aware Julie Paul is one of the only um prescribers that the defendant um encountered that’s not personally named in a civil lawsuit that’s pending, don’t you? ” I’m not sure.

” Now, um so the ER visits on the 16th. uh contact is made with uh Julie Paul on November 20th, right? ” That sounds right. ” Okay. Um and that would have been your phone call to her first. ” I don’t remember exactly. ” Um in the time period, well, you knew she was going and getting uh going to see providers and meeting with Julie and going to the clinic.

 Um did you offer to help out more with the kids? ” Yes. ” Um you were still working full-time at that time, weren’t you? Yes. ” So, fair to say it was kind of limited based on your schedule. ” Correct. ” Did you have a normal schedule that you worked at that time period? ” I don’t know what you mean. ” Well, um, as a nurse, did you did you work day shifts? Did you work? ” I worked the day shift.

” Um, so did you offer to watch the kids at nighttime? ” I don’t remember exactly. ” Did the kids come to stay at your house overnight so that she could get some sleep? ” No, they didn’t. Fair to say you offered and she didn’t want the kids to come to your house, right? ” No, that’s not right. ” Well, were they um Did they ever sleep over your house? ” No, they didn’t.

” And Cora was five, right? ” Yes. Correct. ” She turned five that December. ” So, at any point they they never stayed over. We decided together it was best for them to be in their own beds at their own house with all their belongings and Lindsay’s parents were very actively involved in staying over and helping out.

 So it was the best decision that they stay home in their own beds. So, prior to the um November of 2022, did you and your husband ever come and stay over the night so that um Patrick and Lindsay could go off? ” We never did stay at their house. ” And as far as kind of watching the kids or taking the kids outside of the house during the daytime, did you often take Kora on kind of day trips out to lunch? ” Yeah, we used to go to lunch together.

” How about Dawson? Did you take him one-on-one out to ” Not as much. He was younger. ” And how about Ken? Did you ever take him out of the house without Lindsay? ” No. ” And are you aware that um Lindsay told one of the therapists that she wasn’t close with you as in-laws and that she ” I didn’t know that. No.

” That she said she doesn’t generally allow the in-laws to watch her children. ” I did watch the kids. ” Okay. But are you aware that she told the therapist that? ” No. Are you aware she told the therapist that she didn’t have any particular reason why and that they don’t bug me about it either? ” I don’t I didn’t know any of that.

” Now, um Lindsay, uh the defendant, she communicated with you via text about her issues with sleep and the medication she was taking, right? ” Yes. And as far as the um ER visit where the trazadone was prescribed, do you recall having a back and forth conversation with her about that it’s okay to increase it um if you weren’t getting any relief? ” The doctor told her that, so I repeated that.

” Okay. Um and so you’re aware that she was in fact increasing the dose? ” I did not know that. Now, So, um, once the defendant once she was seeing Julie Paul, did you continue to have conversations with her about how she was feeling? ” Yes. ” And, um, you knew that she was taking some new medications after she saw Julie, right? ” Yes.

” [clears throat] ” And [cough] [clears throat] sorry, these pages are different than mine. [snorts] At some point um after being prescribed some medication um you recall that um Lindsay told you that she thought she developed a benzo dependency. Correct. ” I vaguely remember that. That would be on November 29th where she says, “I just deep down inside of me feel that I’ve developed a benzo dependence after just two weeks of using it and I feel like no

one is hearing that and addressing it and we keep throwing different meds in the mix that aren’t really addressing the real issue.” Do you recall that message? ” Sounds familiar. And she asks you are are you you respond so hard I don’t know what to do so should you not use it and she responds I guess not but then I don’t sleep right do you recall that ” I I can’t say for certain it sounds right okay ” I don’t remember a lot of specifics and November 30th.

November 30th, she says. And I’m just He says, “I’m not okay and I’m terrified of taking meds tonight.” Do you see that in the green? ” Yes. And then your response is, “Why are you scared? Why happens if you don’t take them? What are you afraid of? What about ambient?” Right? You’re actively trying to help her kind of figure out the medication.

” Yes, there were a lot of medications. ” Okay. Um you’re aware she wasn’t prescribed all the medications at one time, but just a lot of different combinations were kind of thrown around as options, right? ” It seemed confusing. um that she also she’s very clear and she tells you which medications she’s taking, right? Adavan and Remaron ” probably.

” Okay. And then um she also tells you on November 30th when you’re talking about it, she says, “I know they take time to reach a therapeutic level to have the desired effect.” Right. Do you remember that? ” Yes. ” And then you respond, “Exactly.” And she tells you that she’s just um depressed and she thinks it was brought on by the medication, right? ” I don’t remember that.

” Okay. Well, on November 30th at 7:52, I was never ever this depressed. It was brought on by the medication. Did you say that or did she say that? ” She probably said that. ” Now, you were asked about um the holidays and Thanksgiving. You remember Thanksgiving. Where did you guys go for Thanksgiving? ” To my daughter’s house.

” And um do you remember telling the grand jury that during Thanksgiving things were better? I don’t recall. Well, do you remember her saying that she she said things were better? ” Do you remember that? ” Vaguely. ” Okay. Um, you were asked, “What was Lindsay like during the big Thanksgiving gathering? What observations did you make?” Answer: She smiled.

 The girls all had Thanksgiving t-shirts on that sort of matched. We took a picture. She mo mostly focused on the kids and interacting with the cousins and the aunts and uncles. At one point, she went off a little into the distance. And I approached and asked her how she was doing. And she said, “I’m trying hard to get better. I’m still working at it.

” I asked about her sleep. I thought that was important. And also the fact that she lost some weight, she didn’t have an appetite. And she said things were getting better. Okay. Now during the holidays, you in fact took some time off of work so that you were around a little bit more. Correct. ” Correct. ” And so when you were around a little bit more, did you spend all day every day at their house? ” No.

” Um, fair to say you would come sometimes play with the kids, right? ” Yes. ” Do shopping for her? ” Correct. ” Um, and then you actually went on vacation. ” Yes. ” You and your husband went to Aruba. ” Yes. ” How long were you in Aruba? [snorts] ” Five or six days, I think. And um now moving towards Christmas, you had um dinner with them at their house on the 23rd, right? ” I don’t remember.

” Okay. Um do you remember breakfast on Christmas Day? ” Yes. ” Was that at their house or someplace else? ” Their house. ” Okay. And then what did you guys do after breakfast? ” We went to church. ” And um fair to say you’ve previously testified that breakfast was great. ” Yes. ” And that church was beautiful.

” Yes. And in fact, um, the defendant, she told you that it was great and that she was glad she went to church that day on Christmas Day. ” Yes, she did. ” And then after, um, that you’re aware, uh, they went down to Connecticut to see her family, ” right? ” Um, now are you a active member in the Catholic Church? ” Yes.

” So, you’re um aware that murder is considered a mortal sin? ” Yeah. Can I see you over All right. And what that means is you

are not to consider it for any reason or any purpose. Okay. All right. Council. ” So you were aware, Mrs. Clancy, about the um stay at MLAN Hospital from January 1st to January 5th. Correct. ” Yes. ” And um did you come to the house to help with the kids during that time period? ” Yes. Um, and fair to say when um she came home on the 5th, there was a party for Kora on the 7th.

” Yes. ” Did you go to the birthday party? ” No. ” Um, were you at the house much between January 7th and January 24th? ” I don’t remember. ” Do you recall previously um reporting that you hadn’t been at the house? I don’t remember. [snorts] And during that time period, you never took the kids um on a day trip or for a visit? ” I don’t recall.

” And were you aware that between January 7th and um January 24th that Pat and Lindsay went to the Cape Cod with the kids? ” I’m aware of that. and that they went to the Museum of Science with the kids. ” Yes. ” And that Pat left um Dawson and Ken home or excuse me, left um yeah, Dawson and Ken home to go take skiing.

 Were you aware of that? ” It sounds accurate to me. ” On the ski trip, did they ask you to come over and stay with Lindsay while she was with the other kids? ” I don’t remember. ” [snorts] ” And um you asked on direct examination about um Lindsay going to see providers and you said I think she was begging for help, right? ” She was.

” Um do you did you attend any of those u meetings with her therapists or doctors? No. ” So you don’t know what she told the providers, right? ” I don’t know. M ” and you don’t know what kind of help she asked for other than medication, do you? ” No. ” And do you know whether there was any opt other options offered to her other than MLAN like a partial hospitalization program or intensive outpatient? Were you aware of those options? ” Yeah.

” And do you know if she went? ” She went to Women and Infants. ” So that’s the one day where Pat dropped her off and went skiing and then came back, right? ” I believe so. But ” nothing further. All right, Miss Ry redirect. ” So you she asked you about options that were available to Lindsay. Correct. ” Yes.

” You mentioned one of them was that she could go to the uh women and infants program in Rhode Island that specializes in perinatal and postpartum. ” Right. ” Yes. ” You know that she went there, right? ” Correct. ” You know she was turned away because she was over medicated. Right. ” Yes. ” You also know that they gave her numbers to call suicide hotlines, right? ” Yes.

” She called twice, not once, but twice and again was turned away. Isn’t that right? ” Yes. ” Thank you, ma’am. ” Come on. On that. ” So, you’re aware she was turned away because she told you she was turned away, right? I don’t remember the details of that visit or that day. ” You didn’t review the records, did you? ” No.

” So, you’re not aware that they actually um deferred to Pat and Lindsay reporting over medication? ” I remember something being said that she wasn’t a candidate for that program. That’s what I recall being told by Patrick and Lindsay. ” Okay. And that’s because she everything she described was reported connected to medication and occurred well after um what’s considered the postpartum period.

Right. ” I don’t know. ” Well, you’re a labor and delivery nurse. You know, the postpartum period could be up to a year, right? ” I’ve heard it could be longer. ” Um but generally, it’s within the first 12 weeks that you start to see some symptoms. ” I don’t know. You’re aware that um she was sent from women and infants with actually several options where it included inpatient treatment for medication management, a partial hospitalization program focused on general mental health or continued outpatient management. That’s that’s

what she was sent away with. ” Okay. ” Nothing. ” May I one more? ” Go ahead. One. So outpatient management that would include somebody like Gelatada, right? ” Yes. ” You know that women and infants called Gelatada and she never called them back. ” I didn’t know that. Anything on that? ” No. ” All right. Thank you, man.

 Let me step down. Thank you. All right. All right. Well, members of the jury, this is one of those stops that I told you about. We’re going to have uh kind of throughout today. So, I’m going to ask you to go back to the jury [cough] uh hopefully just for a short amount of time. Then, we’ll bring you right back in and we’ll continue uh with the evidence. Okay.

” All right. of excellent this session. Please be seated. ” All right, council. I know that the uh the next uh witness uh is scheduled to be Dr. La Pasada. ” Yes. Um and uh she will be testifying uh by Zoom. ” That’s correct.

” Um and I think at some point after we talk a little bit, we’re going to have to take a short break just to make sure that uh logistically everything’s all set up uh with the doctor and the system here. And I appreciate everybody’s help technic tech technically in setting that up.

 Um and I know that um the defendant has provided I don’t know maybe five or six um exhibits that uh council wanted to introduce uh through Dr. La Pasada and um so I guess Carmel have you had an opportunity to uh take a look at these? ” Yes. And um we are objecting to these ” items. ” All right. And so why don’t we discuss those here in open court uh and uh and go through it.

 Um and so I I’ve had the opportunity I saw these this morning as well. Um and so Commonwealth, why don’t I hear the objections and then I’ll hear from um the def the defendant. The main objection is that the drawing is inaccurate. The uh window well is in the wrong place and where they have her falling and landing in slide four would be where the window well is actually placed in the photograph.

 I can pass up the photograph to the court. This is in evidence I believe um maybe a couple times. But talks are discretionary, but what they should not do is mislead a jury and present information that’s not accurate. And so the drawing itself is inaccurate. And so we’re objecting to these slides. ” Is that the Commonwealth’s objection is that the the window well is in the wrong place on the on the um drawing.

 I putting aside the late disclosure and the fact that I don’t know if anyone who created this is going to come in and testify that they created it and whether it’s to scale or not, but the the main objection is the uh that it’s inaccurate. ” All right, Mr. Ranken. ” Thank you, your honor. Obviously, um the window well ” [snorts] ” um you’ve got this thing is ridiculous.

the diagram we’re talking about the um window well I’m just going to you already have a copy ” I do yeah ” the window well is depicted on the photo on the diagram I suggest accurately and in fact measurements were taken by u the gentleman who did the computer animation in conjunction with information by way of medical provided by Dr.

 Lapisada and it shows clearly that as Rona can see that we’re talking about the X-rays that are included. There are exhibits that she attaches that shows the way that she falls, how she hits her head. The Kreml has been suggesting that I guess that they’re confused as to how she would have ended up the way she did. This shows the way that she landed on her head, gets to Jefferson fracture, falls back, legs are facing out from the house, she’s laying in the snow.

 They’re all depicted there. If there’s an issue with the window well that’s off, according to the government, they could raise that uncross. They could say, “Well, the window well was really 6 in to the left instead of to the right.” That never struck her anyway. It’s totally irrelevant. Um, I think that they are useful for a jury to be able to review.

 I did have copies made for the jurors and the court as well as the DAs. Um, and Dr. Lapisatada has it and then I could go through, you know, I could go through, but you can see that we we’ve taken the the diagram, the window where the body lands and then to the right of it would be the actual X-ray. Dr. The lapis can compare the injuries, talk about the her the Jefferson fracture.

There’s a photograph that shows the blood and the snow, shows the area, and the photograph actually shows the shows the window well. And I suggest the window well on page six is exactly the way we have it depicted. So, I don’t know what the objection is. I would ask that the court would allow this to be in. ” All right.

Well, I I guess it appears to me slides four, five, and six certainly um go towards the the um doctor’s opinion as we said the mechanism of the injury that shows the um the head striking of the ground. And then on the other part of the slide has the um x-rays and there’s also a uh slide regarding the Jefferson fracture diagram.

 Um and then five is a diagram showing how the thoracic spine injury could could have occurred. Uh and there’s a diagram regarding the uh thoracic spine specifically T6. Um and then uh slide six um shows the and I think there has been testimony as that’s that is where uh the defendant was found. And also then there’s a thoracic spine.

 I think it’s it’s either an X-ray um or some type of scan as well as some of the additional medical devices that were found in that area. Um I I I’m not quite sure about one, two, and three. Um ” that’s that’s fine. I I I can remove one. I can remove two and we’ll just uh focus if you want on on three three things.

 I think that that goes more towards the doctor’s um kind of background and kind of what had been offered in regards to the uh her opinion. ” Your honor, I think you said you were unsure of one, two, and three. ” Yeah. ” And defense said he could go with three, four, and six. Three, four, five, and six.

 So it three was an issue, was it not? ” What’s wrong with three? Well, I I I think again I think four four kind of would cover what’s deal with that. All right. So, uh so I would allow in slide four, slide five, and slide six. ” Okay. Thank you. ” Okay. ” Not our ” And so what we’ll do is Yeah. Objection noted.

 Um and then what we’ll do is take a short break at this point. set [snorts] up the um the Zoom call. Also, I know we’re going to have to probably make certain changes to the to the jury book that was going to be uh presented. So, uh the only slides that will be in that book will be like I said, just so we know. ” Yeah.

 Just so we know which ones you’re talking about. ” Okay. ” There’s a book. ” Well, no, it’s just it’s not a book. It’s just borrow borrow staple together the all of the exhibits. ” All right. So, just so we know what we’re talking about, right? Four and five is the thoracic spine. ” Yes. And like I say, I I I’ve got enough for the jurors plus you and and the DAS.

” Okay. And then six, I just kind of want to make sure that we’re all Yep. ” talked in the same. Thank you. ” All right. So, why don’t we do that? take a short break so that uh those changes can be made and we can uh set up uh for uh the zoom and then we’ll come back out and we’ll proceed with Dr. Lapas. Thank you.

” Okay. All right. Thank you. ” All right.

Disclaimer: This story is fictional and created for entertainment purposes only. Any names, characters, places, or events are fictitious or used fictitiously. No real person or organization is intended to be portrayed.

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