NV [24] The policy must have a value of at least $500 claimed were claimed or may be claimed by adverse claimants; which is less than the amount in controversy of $3,000 in Judicial Code 48(1) then required for general diversity jurisdiction and two or more of the beneficiaries must live in different states. 929 was enacted by the 64th United States Congress approved February 22, 1917 to overcome the problem with an interpleader when the claimants live in different states raised in New York Life v. Dunlevy. Comm'n v. Ewing, 418 P.2d 296 (Colo. 1966). Admitted. On June 17, 2014, Transamerica answered the complaint by commencing a third-party interpleader action pursuant to 28 USC 1335 against Plaintiffs, Nachman as the Trusts trustee, Malka as the Trusts successor trustee, and Nancys Estate. , 418 P.2d 296 (Colo. 1966). Tribunals, Courts and Enforcement Act 2007, "An Historical and Critical Analysis of Interpleader", Prudential Insurance Company of America v. Tull, An Act to enable Courts of Law to give Relief against adverse Claims made upon Persons having no Interest in the Subject of such Claims, "Tribunals, Courts and Enforcement Act 2007", "The Tribunals, Courts and Enforcement Act 2007 (Commencement No. 1993). In Section 2 of your Answer, include all affirmative defenses that you may have. - Same decision defense (employer would still have fired employee for lawful reasons even if the actual firing was for a mix of lawful and unlawful reasons) (. (in an ADA Defense Answer . . 14. 602-ARIZONA (602-274-9662) If bill was not sent to patient prior to interpleader, then provider may not receive any monies. ;";(JCnMPu#(BHnY4&"(JQIA4yN ze^^3s>kyNt5-c*a9=EyhY;@-C$W2qHAUQbegk87l7e5+LJ3'sU "n[.r+mrk'V'f(d0lOGIc#yGrmv&A;V~cM+J,QYiE&BC" /JIwv1^H{4j$MB. Note that, unlike affirmative defenses where the defendant bears the burden of proving the defense, some of the following are more properly styled "additional defenses" where the plaintiff bears the burden of proving that the defense does not apply (e.g. Defendant affirmatively alleges that Plaintiff has failed to state a legal basis to discharge Plaintiffs insured from liability for [his/her] negligence or to restrain Defendants from initiating claims against Plaintiffs insured, and that any such relief should be denied. 6. he must be perfectly indifferent between them. A negative defense is the specific denial of the material fact or facts alleged in the pleading . This is a complex issue and the above wording needs to be adjusted for each case and set of facts. This action is barred in whole or in part by the doctrines of res judicata and/or collateral estoppel. Disclaimer: The information and forms on this site are for illustrative purposes only. Matters outside of these jurisdictions are handled by Fennemore Craig, P.C., lawyers licensed in the relevant jurisdiction or by or with the assistance of attorneys at other associated, co-counsel law firms who are licensed in the relevant jurisdiction. The relief sought by Plaintiffs under Count II of the Complaint for Interpleader must be governed in accordance with the fiduciary duties and obligations imposed by the Court Defendant [], through undersigned counsel, Answers the Complaint in Interpleader (Complaint), as follows: WHEREFORE, Defendant [] requests the following relief: DATED this ____ day of _____________, _____. On April 22, 2014, Nachman sent Transamerica a letter in which Nachman claimed that he was the rightful Policy beneficiary, that he never transferred ownership of the Policy, and that he commenced legal proceedings to establish his ownership. {LAW FIRM NAME} The title of the action. An interpleader action, therefore, enables the stakeholder to turn the dispute over to a court. v. Acuff-Rose Music, Inc., 510 U.S. 569, 590 (1994). 1994). If you are interested in speaking to a Jimerson Birr lawyer or want general information about the firm, our practice areas, lawyers, publications, or events, please contact us via email or telephone for assistance at (904) 389-0050. 80203, 702-625-7777 Persons with claims that may expose a plaintiff to double or multiple liability may be joined as defendants and required to interplead. 2005) Have representative in-house counsel or retained attorney attend all hearings. Subsequently, FLS purchased the Policy through an auction for $1,194,522. l"dngf The file number. - ignorance of the law. A party served with a pleading stating a cross-claim . Both serve the same function of joining two or more adverse claimants to a single proceeding in order to promote efficiency and protect the stakeholder from multiple lawsuits. 11) Order 2014", "The Civil Procedure (Amendment) Rules 2014: Section 36", Practice Direction 83 - Writs and Warrants - General Provisions, Practice Direction 84 - Enforcement by taking control of goods, "The Taking Control of Goods Regulations 2013", "Federal Interpleader and Some Recent Cases", Commercial Union Insurance Co. v. U.S. 999 F.2d 581 (1993 DC Cir. An interpleader proceeding has two stages. do not claim any interest in the subject of the subject matter of the suit, but the right to them is claimed or supposed to belong to a third party who has sued or expect to sue for the subject matter of the suit; has not colluded in any matter with such third party. Ostling v. See also 4 J. Moore et al., Moores Federal Practice 22.04[1] (3d ed. The court in the South Dakota Action ultimately found that Plaintiffs were entitled to the Policy proceeds. Healthy City School Dist. One specific situation commonly seen in the reported cases is where the policyholder was allegedly murdered by a beneficiary (which would disqualify that beneficiary from receiving any proceeds).[2]. As a ninth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiff herein, and each and every cause of action contained in the unverified Complaint, is barred by reason of acts, omissions, representations, and courses of conduct by Plaintiff, by which these answering Defendants were led to rely on to its detriment, thereby barring each and every cause of action under the Doctrine of Equitable Estoppel. 5. Rule 11 requires that you have a good faith basis for believing an affirmative defense actually applies before pleading it, and in discovery you will likely need to respond to an interrogatory identifying all factual bases for every affirmative defense you plead. That Plaintiffs insured not be discharged from further liability. The reason said the Court: a stakeholder is allowed to bring an interpleader action, rather than choosing between adverse claimants. Thus, even though Transamerica declined to choose between the adverse claimants (rather than bringing [the] interpleader action), that decision could not itself be a breach of a legal duty. Citations omitted. As a thirteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiff did not reasonably rely upon any alleged misrepresentations or nondisclosures of material facts made by these answering Defendants; therefore, Plaintiff is barred from seeking any affirmative relief against these answering Defendants. COMES NOW, Defendants___________________. 1335(b). If provider does not attend all hearings, they may not receive any monies, Ensure bill has been sent to patients of motor vehicle accidents and work-related accidents. An example of an interpleader involving health care providers. As a first, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiffs unverified Complaint, in its entirety, nor any purported cause of action set forth therein, allege facts sufficient to constitute a cause of action against these answering Defendants. (Code Civ. 1991). - All Rights Reserved, Community Advocacy & Social Responsibility. , 408 P.2d 970 (Colo. 1965). Admitted. Answer - 4 Section 1: Admissions and Denials A Guide to Resources in the Law Library SCOPE: Bibliographic resources relating to admissions and denials in an answer to a complaint. Get free summaries of new opinions delivered to your inbox! 2000). *IMPORTANT - READ CAREFULLY: Past results do not guarantee, warrant, or predict future case outcomes. SK6F7ETKn ~vC;,pr_\,Wy~m/\%)*5bIx [3], It originally applied to bailees subject to multiple actions of detinue,[4] and privity was required either between the parties or in detinue, in order for the defendant to be able to sue for garnishment.[5]. 1332(a) or (c), and the value of the property in controversy must be at least $500. The stakeholder must also establish the possibility of multiple lawsuits. 8. 1335, and Rule Interpleader established by Federal Rules of Civil Procedure 22. When a claimant alleges that the stakeholder is liable for an independent wrong, such party is not a mere stakeholder, notwithstanding its assertion that it has no interest in the disputed funds. To achieve that, the party holding the asset files . An interpleader action is an equitable proceeding brought by a third party to have a court determine the ownership rights of multiple claimants to the same asset or property that is held by that third party. The Leading Law Firm In The Nation For ADA Legal Defense, On Behalf of The Karlin Law Firm LLP | Jun 29, 2012 | Real Estate Disputes |. The insurance company is the stakeholder, the claimants are the persons who might be beneficiaries under the policy, and the cash value of the policy benefit is the res. [any] matter constituting an avoidance or affirmative defense." See Penn Mutual's Answer, Affirmative Defenses and Interpleader, Exhibit J (identifying the discussion date as August 4, 2009). Kentucky requires that a party affirmatively state the following affirmative defenses, if applicable, in its answer: Accord and satisfaction. Anderson's Ohio Civil Rules Practice with Forms is a desk reference that provides practicing attorneys and judges in Ohio with a manual to find quick and accurate answers to procedural questions under the Civil Rules. The second stage is like an action at law to determine which of the claimants is entitled to the res. Prompted by this discussion, Petitioner filed this action against Jeremy Toler, Jennifer Toler and Penn Mutual. - Same decision defense (employer would still have fired employee for lawful reasons even if the actual firing was for a mix of lawful and unlawful reasons) (Mt. 12-2022. In an interpleader action, a party who knows two or more other parties are making a claim on some asset controlled by the party can ask the court to decide who has what rights to the asset, deposit the asset into the custody of the court or a third party and remove itself from the litigation. [18] In addition, s. 65 of the 2007 Act declared: (1)This Chapter replaces the common law rules about the exercise of the powers which under it become powers to use the procedure in Schedule 12. 4 pages) 8 Tex. 8, 2008) (internal quotation marks and citation omitted); Inovlotska v. Greenpoint Bank, 8 A.D.3d 623 (2d Dept. Bank 260 U.S. 235 sustained that a defensive interpeader in an action at law in federal court could be taken under Judicial Code section 274b added by 38Stat. 4 0 obj AZ This is not to be used in all matters or cases, and each matter or case is different. 15. P. 8.03). Section 13-21-111.6), - violation of the Soldier's and Sailor's Civil Relief Act (protections for active duty military against service of process while deployed), - claim barred by death (does not survive to be asserted by estate), - claim barred by probate code/testament/closing of estate, - no alter ego / barred by limited liability status of entity, - produce use was outside of particular purpose, - failure to provide opportunity to inspect/repair, - product supplied in accordance with specification, - failure to exhaust administrative remedies, - learned intermediary or sophisticated user doctrine, - no deficiency judgment permitted by law, - no evidence that modified warning would have been followed or would have prevented injury, - manufacturing/labeling/marketing in conformity with the state of the art at the time, - product provides net benefits for a class of patients, - damages were the result of unrelated, pre-existing, or subsequent conditions unrelated to defendant's conduct, - act of god (or peril of the sea in admiralty cases), - force majeure (enjoying a renaissance due to COVID-19), - failure to act in a commercially reasonable manner, - no benefit conferred (unjust enrichment), - refusal to surrender (unlawful detainder), - doctrine of primary or exclusive jurisdiction, - failure to preserve confidentiality (in a privacy action), - prior commercial use (trademark and patent), - functionality defense (design patent infringement), - expiration of patent for nonpayment of fees (patent validity), - estoppel due to prior judgment of invalidity (patent validity), - lack of novelty re prior art (Section 102) (patent), - inadequately disclosed or claimed (patent), - grace period as to disclosures from inventor (patent), - business competition privilege (intentional interference), - no intent to permanently deprive (civil theft), - suicide (in accident or some benefits actions), - adverse possession (in trespass action), - mutual acquiescence in boundary (in trespass action), - statutory immunity (under applicable state or federal law), - unconstitutional (relating to statute allegedly violated), - insanity (normally in criminal context, but may have some application in civil suits linked to criminal acts), - self-defense (in assault, battery, trespass actions), - defense of real property (assault/battery), - defense of personal property (assault/battery), - recapture of personal property (assault/battery), -permission/invitation/consent (in assault, battery, trespass actions), - Section 2-607 UCC acceptance of goods, notification of defect in time or quality within reasonable time, - breach of implied covenant of good faith and fair dealing, - no damages (where required element of pleading), - category of damages sought barred by contract, - damages sought in excess of limitation and barred by contract, - implied repeal of statute (see In re: Stock Exchanges Options Trading Antitrust Litigation, 317 F.3d 134 (2d. In pleading to a preceding pleading, a party shall set forth affirmatively accord and satisfaction, arbitration and award, assumption of risk, contributory negligence, discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, injury by fellow servant, laches, license, payment, release, res judicata, statute of Mr. Smiths attorney enters an interpleader action to determine how the remainder of the funds will be divvied up, as there is not enough to cover all of the outstanding bills. stream 89501. Can your hotels employees cause an ADA lawsuit? - Noerr-Pennington defense (antitrust) (a Sherman Act defendant can raise the affirmative defense of right to petition for redress, even if they use that right to try to gain an anti-competitive advantage). SECOND AFFIRMATIVE DEFENSE (As to Count II - Interpleader) 30. An interpleader action is one of those remedies. However, it is error for a trial court to permit a defense over an objection when first presented at trial. Admitted. To establish this claim, the plaintiff must prove all of the following: . (LiMandri v. % The defendant in a declaratory suit can seek affirmative relief and sue on the basis of any cause of action that may be appropriate in a the provisions of Rule 85.5 impose no time limit by which the application under that Rule must be made by the creditor or other party claiming an interest. . A designation of the pleading being submitted. What is an Interpleader Action? The applicant or interpleading party may join as a defendant in such action any other party against whom claims are made by one or more of the claimants or such other party may interplead by cross-complaint; provided, however, that such claims arise out of the same transaction or occurrence. You may have to pay the opposing party's attorney fees and costs in the event of a loss. Co. v. Viscuso, 569 F. Supp. The rest of the grounds under the old provisions of the Motion to Dismiss are now grounds for affirmative defenses (Section 5(b), Rule 6). Acknowledged that Plaintiffs so allege. {Telephone:} (in an ADA Defense Answer . {Address} c. 231, 85A imposes upon the defendant-registered owner of an automobile involved in a collision the responsibility for setting up as an affirmative defense in his answer a denial that the automobile was being operated by a person for whose conduct the defendant was legally responsible. The complaint fails to state a claim upon which relief can be granted. Therefore, under New York law, the interpleader remedy is available only to a stakeholder. American Intern. 4. See Noerr-Pennington Doctrine (2009), ABA Section of Antitrust Law, at p.107. Conversely, a negating defense involves attacking one or more elements of the prosecutor's or plaintiff's case. Apr. $ vrM1iz,UEFx952D Texas SB1552 2023-2024 Relating to affirmative defenses for a Texas Commission on Environmental Quality enforcement action for unauthorized emission or opacity events. Remember that real estate agents and brokers are regulated by the Florida Department of Business and Professional Regulation so they must follow some specific procedures in the event of a binder dispute. The stakeholder may invoke Rule 22 as a plaintiff, or by counter-claiming in an action already started against him by one, or more claimants. The Defendants incorporate herein by reference the responses to paragraphs (1) . Denver, New facts need to be sufficiently pleaded to establish each element of a claimed affirmative defense. B. Interpleader Action Under 28 U.S.C. The insurance company believes that the deceased committed suicide, but the claimants believe the death was by accident. As the vast majority of these affirmative defenses will not apply to any given case, ensure you don't just plead this entire laundry list - this list is intended as a. The agent will be permitted to recover costs and attorneys fees incurred in initiating an interpleader action. This blog will focus on the use of Interpleader Actions for escrow binder disputes in Florida. Because that protection allows the escrow agent to recover attorneys fees and costs from the funds it holds, the protection is to the detriment of any the buyer and seller arguing over the entitlement to the amount being held. A: Here is a sample answer that can help you out. the Defendants in the Funds that are subject of this action. Product description. 28 U.S.C. The court concluded that there had been no action or inaction on the part of the plaintiff that could be interpreted to be a recognition of the fact that the defendants intended to claim attorneys' fees or a waiver of objection to their failure to plead such a claim. Understanding Usury: Is It an Investment, or Is It a Loan? AS AND FOR A FIRST AFFIRMATIVE DEFENSE: 21. . a person is under a liability in respect of a debt or in respect of any money, goods or chattels and he is, or expects to be, sued for or in respect of that debt or money or those goods or chattels by two or more persons making adverse claims thereto; a sheriff or a person expected to be sued by two or more persons as claims made to any money, goods, or chattels taken or intended to be taken by a sheriff in execution under any process, or to the proceeds or value of any such goods or chattels, by a person other than the person against whom the process is issued, a person is making a claim to or in respect of goods seized in execution of the County Court or the proceeds or value thereof. This is part of Vail Law's. As a fifth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants are informed and believe, and on such information and belief, allege that by reason of Plaintiffs conduct which constitutes a breach of contract, tortious conduct, waiver, unclean hands, and laches, Plaintiff is estopped to assert any right of relief. Such an action may be entertained although the titles or claims of the conflicting claimants do not have a common origin, or are not identical, but are adverse to and independent of one another. 3. a. Interpleader Defendant No. Two people come forward claiming to be the beneficiary named in the policy. Rule 22(b). 2003), - failure to take advantage of effective system to report/stop harassment (in Title VII actions, called the Faragher-Ellerth defense) (see Jones v. D.C. Dept. As stated in Chapter 2 "The Legal System in the United States", a criminal defendant will be acquitted if the prosecution cannot prove every element of the offense beyond a reasonable doubt. 1700 Lincoln Street #2400 (1) The closing agent shall, by interpleader action or other legal proceeding, seek adjudication of the rights of the parties with respect to disputed reserved proceeds by the county court or circuit court, whichever may have jurisdiction of controversies in the amount of the disputed reserved proceeds, in a county where all or a portion of the (Code Civ. In many cases, an interpleader action arises due to an individual receiving settlement funds meant for the payment of multiple bills. Protecting the Rights of Healthcare Providers in Interpleader Actions. Interpleader 1369 - Multiparty, Multiform Jurisdiction (mass accident statute) . The most complete list of affirmative defenses available in one place: currently 230 separate affirmative defenses. Jur. P. 10 . Joinder for interpleader is proper even though: (b) Relation to Other Rules and Statutes. Defendant is informed and believes and, based thereon, alleges that Plaintiff has engaged in conduct and actions to constitute a novation concerning the obligations, conduct, or acts at issue in the Complaint, barring recovery from Defendant. In cases where a person was subject to multiple claims, the applicant had to show that he: As a result of the coming into force of Part 3 and Schedule 12 of the Tribunals, Courts and Enforcement Act 2007[15] on 6 April 2014,[16] Order 17 and Order 33 were replaced by the new Parts 83-86 of the Civil Procedure Rules. Through litigation, Mr. Smith receives a settlement payment, from the other drivers insurance, that is meant to cover pain and suffering, attorney fees, and medical bills. 4. | wu %PDF-1.4 In 1922 the United States Supreme Court in Liberty Oil Co. v. Condon Nat. They are a potent procedural weapon to defeat or diminish the plaintiff's claim or claims. In order for this court to have jurisdiction over this action, at least two defendants must be citizens of different States as defined in 28 U.S.C. Alexander v. Riga, 208 F.3d 419, 432 (3d Cir. 931 approved June 25, 1948, it was reconstituted as 28U.S.C. This page was last edited on 6 May 2022, at 15:28. Rule 8(c) requires that both defenses to liability and defenses that potentially mitigate damages must be set forth in the pleadings. 2d 355, 362 (S.D.N.Y. The 2014 amendments have proved to be problematic, in that they now fail to cover a situation where: In February 2018, several High Court enforcement officers asked the Queen's Bench Division for directions as to how to proceed in such circumstances, and the Master ruled that the repeal of Rule 17 had the effect of reviving the equitable form of interpleader proceedings, as the 2007 Act did not expressly abolish the interpleader action itself, and "interpleader statutes are not at all to limit or affect the equitable jurisdiction of the court to entertain an interpleader suit or action."[21][22]. 3. Section 475.25(1)(d)1., Florida Statutes, sets for the statutory procedure that real estate professionals should follow in the event of conflicting binder claims. As an eighth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiff herein, and each and every cause of action contained in the unverified Complaint, is barred because Plaintiff has engaged in acts and courses of conduct which render him in pari delicto. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 The Karlin Law Firm LLP All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, Sample General Denial Answer with Affirmative Defenses filed in California Superior Court or Federal ADA, Business or Real Estate Lawsuit with Affirmative Defenses. An admission or denial. Life Assur. Snap Spectacles: Smile Because You May Indeed Be On Camera, Dont Let Your Child Be The Invisible Kid This Halloween. 3. Instead, Plaintiffs merely alleged a claim to the stake itself. Citing Clearlake Shipping PTE Ltd. v. O.W. Inovlotska, 8 A.D.3d at 624-25; Birnbaum v. Marine Midland Bank, 96 A.D.2d 776 (1st Dept. Red Rock ignored the statute governing the distribution of the proceeds of the HOA sale in 2014 & also refused requests to distribute in 2014 & 2016 and in civil actions in 2017, 2019 . 7. As the vast majority of these affirmative defenses will not apply to any given case, ensure you don't just plead this entire laundry list - this list is intended as a brainstorming tool. An interpleader action originates when the plaintiff holds property on behalf of another, but does not know to whom the property should be transferred. Interpleader is a civil procedure device that allows a plaintiff or a defendant to initiate a lawsuit in order to compel two or more other parties to litigate a dispute. Id. IL Co., 523 P.2d 979 (Colo. 1974). 8(c) requires a party to "set forth affirmatively . AFFIRMATIVE DEFENSES. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or the information linked to on the state site. Managing Partner Many affirmative defenses are listed in Rule 94 of the . Upon learning this information, FLS attempted to exercise its remedies under the Sale Agreement (e.g., rescind the agreement or proceed with the purchase at a reduced price). 85016 28. Cir. The may claim language added in 1948 codification to Title 28 of the United States Code in the definitions of claim allow interpleader for unliquidated claims, such as multiple claimant to a liability insurance policy injured in an accident before they are reduced to judgment or settled, however the injunction may only restrain the claimants from suits making claims against the res not suits to liquidate the claim or against third parties. Freiberger Haber LLP is a national law firm located in Melville Long Island & New York City. % Interpleader had its origins as a civil procedure at common law, which was later adopted and expanded by the Court of Chancery in its equitable jurisprudence. Statutory Interpleader governed by 28U.S.C. DEFENDANT IVETTE MONROIG'S ANSWER TO INTERPLEADER COMPLAINT Defendant Ivette Monroig, by and through her undersigned attorneys, hereby files the following Answer and Affirmative Defenses/Claims in response to Plaintiff's Interpleader Complaint: 1. RULE 22. - Noerr-Pennington defense (antitrust) (a Sherman Act defendant can raise the affirmative defense of right to petition for redress, even if they use that right to try to gain an anti-competitive advantage). First Affirmative Defense You could buy guide Defendant Answer To Complaint Affirmative Defenses And or See id. requires a party to "set forth affirmatively . Sign up for our free summaries and get the latest delivered directly to you. {City}, {State} {ZIP} A bad alternative does not affect a good one. SECOND AFFIRMATIVE DEFENSE (As to Count II - Interpleader) 37. These procedure are outlined generally by Florida Realtors and include seeking an Escrow Disbursement Order, Arbitration, Mediation or Interpleader. When one person holds property that they do not own and multiple claimants to the property exist, an interpleader action is employed to determine the rightful owner of said property. 1. When one person holds property that they do not own and multiple claimants to the property exist, an interpleader action is employed to determine the rightful owner of said property. Dist. The person holding the funds (escrow agent) to which two or more persons make claims (such as a buyer and seller) files suit asking the court to decide which party has a legal right to the binder. California may have more current or accurate information. SPV-LS LLC v. Citron, 2018 N.Y. Slip Op. This is always one of the first defenses you look for in every case. 8(B).) The key is that the claim[ ] for relief . If a defense is not raised by the pleadings, it may still be tried by the express or implied consent of the parties. Impleader is a United States civil court procedural device before trial in which a defendant joins a third party into a lawsuit because that third party is liable to an original defendant.Using the vocabulary of the Federal Rules of Civil Procedure, the defendant seeks to become a third-party plaintiff by filing a third party complaint against a third party not presently party to the lawsuit . That the Court award $[] of the interpleaded funds to Defendant []. An interpleader action is a lawsuit that is filed in county or circuit court in the jurisdiction where the escrowed funds are located. 1335 . Factors in Determining Privilege
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