The forced eviction at Loc Hung vegetable garden in Saigon on January 4 and 8, 2019 joined the long list of land disputes between the people and the State of Vietnam. We are putting together a timeline of events that have happened to date and will continue to update as this story develops.
December 20, 2018
News about a possible forced eviction came about on December 20, 2018, on social media. Blogger and human rights activist, Pham Doan Trang, reported on her Facebook that according to the residents at Loc Hung, 50 local police officers from different forces in Ward 6 of District Tan Binh showed up at the garden area, demanding the residents to allow them to perform an administrative check. By 1:30 p.m., the police withdrew.
December 29, 2018
The People’s Committee of Ward 6 issued an announcement, stating that they would begin a forced removal of all illegal constructions that were built after January 1, 2018, which also notified the residents that the time for such removal would take place within 90 days from January 2, 2019. It is unclear if all residents received the announcement.
January 3, 2019
During the night of January 1, 2019, the residents announced on social media that the local authorities have brought in barbed wires, frequency disrupting machine, forklifts, and bulldozers to the garden’s area.
January 4, 2019
At daybreak, a group of some 400 people from different police and security forces showed up at Loc Hung and began to block street access to the garden, starting from the Bay Hien intersection to Thanh Thai and To Hien Thanh streets. The removal of some 40 houses lasted from 7:30 A.M. until 6:00 P.M., during which time 20 people were arrested and taken to the Ward 6’s police station for opposing it.
The residents insisted that they had never received any order for such removal.
January 7, 2019
During the night, hundreds of police officers and civil security personnel were ordered to go to Loc Hung where the public speakers – on high volume – were announcing the government would only remove illegally built constructions. Cao Ha Chanh, one of the persons serving on the board of representatives for the families living at Loc Hung, recalled that the removing force still did not provide the people with any legal documents regarding the order to remove before they started to take down the homes.
January 8, 2019
Starting at 5:30 a.m., approximately 1.000 officers from different police forces and others entered Loc Hung garden. Similar to what happened on January 4, 2019, the authorities blocked off the streets leading to the area by putting up the barbed wires. To gain entry, people must show the police their identification. As soon as they arrived, they began arresting those residents identified as “leaders” in the community, including Cao Ha Truc.
Electricity and internet were cut off in the area. By 7:30 A.M., the forklifts and excavators were put to work as the authorities began to tear down the residents’ homes. By the end of the day, all of the houses at Loc Hung garden were demolished. The residents estimated there were about 200 homes.
Among the now homeless people were some 20 disabled veterans who served in the former South of Vietnam’s military who do not have a family and they were being taken care of by the residents and the priests from the Redemptorists Church.
On the same day, Amnesty International – Southeast Asia office – publicly denounced the Vietnamese government’s decision to remove the houses forcefully belong to Loc Hung’s residents.
January 9, 2019
In the early hours of the day, the police released Cao Ha Truc and other residents who got arrested the day before.
The Ho Chi Minh City Police Department’s newspaper was among the first state-owned media reported on the removal of Loc Hung Garden’s houses, which the government estimated to be around 120 in total. Accordingly, the People’s Committee of Ward 6 stated that the removal of the illegal constructions was carried out under proper legal procedures.
January 10, 2019
Tuoi Tre and a few others also reported the story, mostly to allow the District Tan Binh’s authorities to make their argument public, that they have only “enforced the removal of illegal constructions on a public area and not a forced eviction in a land recovery matter.”
Further, the People’s Committee of Tan Binh District confirmed with the media that they had followed the proper legal procedures when organizing the enforcement team to take down a total of 112 construction projects without a permit at Loc Hung between January 4-9, 2019.
January 11, 2019
Chris Hayes, a Labor Party’s member of the Australian Parliament, and a Vietnamese-Australian bishop, Vincent Nguyen Van Long, both called on the Vietnamese government to cease from enforcing the removal of Loc Hung resident’s houses, stating that it is a violation of the people’s freedom of religion and belief.
On the same day, the Secretary of the Vietnamese Communist Party’s Ho Chi Minh City division, Nguyen Thien Nhan spoke about Loc Hung for the first time.
VnExpress quoted him saying: “there are many things which should be normal, but those who are plotting against the government would still abuse them to incite (others). As seen in a few cases in 2018, the city had learned from our experience so that we would not confront the people, but we will use propaganda activities to let them understand.”
January 12, 2019
The local authorities put up a large panel in the area, announcing a public construction was going to be developed after the removal team had flattened out the entire Loc Hung vegetable garden. On the same day, some of the residents met with a group of lawyers who have expressed interest in providing legal assistance.
January 13, 2019
The Committee for assistance in the development project regarding the public school at Ward 6, District Tan Binh, HCM City (the project to be developed at Loc Hung) announced the assistance policy that the District was going to be provided for those who were farming on the land. Accordingly, on January 10, 2019, the People’s Committee of HCM City approved the assistance proposal for those who have been using the land at Loc Hung garden for agriculture purpose at the rate of 7,055,000 VND/m2.
Attorney Trinh Vinh Phuc published a few photographs of the documents provided by the residents of Loc Hung in support of their claim for legal possession of the land.
January 14, 2019
At 9:00 A.M. a group of religious leaders of the Interfaith Council together with some of the priests from the Redemptorists Church in Saigon went to visit the residents of Loc Hung. In the afternoon, Bishop Paolo Nguyen Thai Hop also came to visit at around 3:00 P.M. During both the morning and afternoon visits of these religious leaders, the local government used loud public speakers to interfere with their prayers and speeches to the residents.
|Summary of Factual Disputes Regarding Loc Hung:
The disputed land consists of 4.8 hectares in Ward 6, District Tan Binh, which includes parcels 126-5, 128-5, 129-5, and 131-101-5 according to the No. 12 Map (of the old recordings). The location of the land is as follows: the North West touches Alley 9/24 Cach Mang Thang Tam Street, the South West touches Hung Hoa Street, The South East touches Chan Hung Street, and the North East touches the current existing residence.
The People’s Committee of Tan Binh District claims this land is public because, before April 30, 1975, it was under the management and control of the former Republic of South Vietnam’s Department of Telecommunication and was used as a telecommunication tower. After April 30, 1975, the new government took control of the land according to Decision 111/CP dated April 14, 1977, issued by the Government Council, and continued to use the telecommunication tower.
On the contrary, Loc Hung’s residents claim that the original owner before April 30, 1975, was the Catholics Church of Vietnam who had granted them the right to farm on such land. After April 30, 1975, the residents continued to live and farm on the land undisrupted and without dispute with other people. After the Law on Land 1993 took effect in Vietnam, the residents have been petitioning the government in almost 20 years for the right to possess and usage of the land. However, the government did not respond to their petitions.
(To Be Continued)
Loc Hung Vegetable Garden Continues To Be Harrassed (RFA-Vietnamese)
Loc Hung Vegetable Garden “Devasted after Forced Removal” (BBC-Vietnamese)
Loc Hung Vegetable Garden Under Siege (BBC-Vietnamese)
Forced Removal of 110 Households Was Done According to Law (HCM City Police Department Newspaper)
Tensions Mount in Aftermath of Attack on Dong Tam Village
Leader Le Dinh Kinh killed, wife tortured, and 22 others charged, as civil society demands answers from government
As details and testimonies slowly emerge from Dong Tam after a surprise government raid early the morning of January 9, tensions between officials and civil society activists continue to mount as the two groups fight to clarify events that led to the deaths of 84-year-old village leader Le Dinh Kinh and three police officers, as well as the arrest of more than 30 villagers.
Compounding tensions is the fact that Vietnam is a one-party authoritarian state in which all official news, press, and media outlets are controlled by a single communist party. Citizen-journalists make ample use of social media to counter the systemic bias, as the general population struggles to establish the facts.
State media announced yesterday that 22 individuals have been charged: 20 for murder, including two of Kinh’s sons, Le Dinh Chuc and Le Dinh Cong, as well as 2 others for obstruction of officials. Murder is among the most serious charges of the Vietnamese penal code, with punishment ranging up to and including the death penalty.
The clash in Dong Tam was the culmination of a land dispute that had been simmering for years over private farmland earmarked for a military airport (Mieu Mon). Experts state that land disputes in Vietnam have become increasingly common, at Loc Hung garden in Ho Chi Minh City most recently, due to the ambiguous laws that the ostensibly “communist” country has enacted regarding land ownership.
According to villager testimonies, around 3 AM the morning of January 9, 2020, approximately 3,000 officers from the police, riot, and armed forces carrying clubs, sticks, guns, shields, and tear gas grenades poured into Dong Tam village (My Duc suburban district, Hanoi), targeting village leader Le Dinh Kinh’s house.
Collecting eyewitness accounts, citizen-journalist and activist Pham Doan Trang explained: “as violent skirmishes broke out, police used an explosive charge to blow a hole into village leader Kinh’s house, all while firing bullets and tear gas. Other officers tightly sealed off all the paths and alleyways in the village and used German shepherds to hunt down ‘culprits’. The villagers responded with rocks and Molotov cocktails. Police completely collapsed the roof of Le Dinh Kinh’s house and more than 30 members of his extended family were taken away.”
Trang reports that the Dong Tam area is currently under complete lockdown and no independent journalists have been allowed in, noting state media outlets simultaneously began reporting the same story January 9, citing a single source: Vietnam’s Ministry of Public Security. The brief statement from the ministry stated that a number of officers ‘sacrificed themselves’ in the line of duty, while one ‘hostile culprit’ died.
It was not until January 10 that state media identified the “hostile culprit” as village leader Le Dinh Kinh himself, who was accused of leading a mob of villagers to “obstruct officials” who were working on constructing a wall delineating Mieu Mon Airport. Officials did not explain why this work was being done at four in the morning, nor why 3000 officers were present in the village rather than closer to the Mieu Mon work site, a few kilometers away. Officials handed over Kinh’s body to villagers the same day (January 10).
Luong Tam Quang, deputy head of the Ministry of Public Security, explained at a press conference January 14 that Kinh was shot because he was “holding a grenade” and posed a threat to security forces. Quang, however, confirmed that the Ministry of Public Security did not have an arrest warrant for anyone when police stormed Kinh’s private residence.
Kinh’s wife, Du Thi Thanh, told land rights activist Trinh Ba Tu that Kinh was shot right in front of her, twice in the head, once in the heart, and once in the left foot. A viral video of Kinh’s body on social media showed a single bullet hole near his heart, and an unexplained long surgical scar down his abdomen.
Kinh’s funeral was held January 13, but the area of Dong Tam remained under high security, with the internet cut. Little to no footage of the funeral is available, and supporters were largely prevented from attending.
Public outpouring of support for Kinh has been swift on social media, with many seeing him as a exemplary moral leader who consistently fought for the weak. In his lifetime, Kinh was a peasant farmer, a revolutionary soldier who had fought against the Americans, a Communist Party member at 20, head of police in his village, and both party secretary and chairman of the village’s Party committee in the 1980s.
That the Vietnamese government has killed a model Party member has intellectuals commenting on the inherent symbolism, stating Kinh’s murder represented the communist regime “digging its own grave”.
Kinh’s wife, Du Thi Thanh, herself suffered harsh mistreatment from the authorities, and in a surreptitiously recorded video that has spread on social media, she details how police slapped and kicked her repeatedly to force her to falsely confess to using grenades and petrol bombs.
Her son Le Dinh Cong, adopted daughter Bui Thi Noi, and her grandchildren Le Dinh Doanh and Le Dinh Quang are also likely victims of forced confessions, as their battered images appeared on state television January 13, stoically confessing to making petrol bombs and other weapons to attack police. They admitted they had broken the law, even implicating prominent activist Nguyen Anh Tuan and blogger Le Dung Vova in encouraging “anti-state” activities.
All four subjects were covered in scrapes, black eyes, bruises, and swellings, and looked down as they spoke during the entire recording, appearing to be reading from statements off-camera.
Forced scripted confessions, particularly those aired on state television, are common in authoritarian regimes, like Vietnam, China, and North Korea.
State media also reported that Le Dinh Chuc, Le Dinh Kinh’s second son, is laying in a hospital; his condition is unknown.
The January 14 press conference further identified the three police officers killed in the raid as: Colonel Nguyen Huy Thinh, Captain Pham Cong Huy, and Lieutenant Duong Duc Hoang Quan.
After days of state media reporting that the villagers attacked and killed the officers by grenades, knives and petrol bombs, deputy head Quang admitted that the three individuals had fallen down a four-meter skylight in Kinh’s residence while pursuing suspects. He alleges that Dong Tam residents, upon seeing the officers in the well, poured gasoline and lit them on fire.
All three officers have been given posthumous awards and the honorary title of “martyr” by President and Party General Secretary Nguyen Phu Trong for their service.
Vietnam has cracked down on those challenging the official narrative, and according to citizen-journalist Pham Doan Trang, the government has arrested people in Can Tho, Quang Ngai, and Dak Nong for posting online about the event. She also notes that land rights activists (and brothers) Trinh Ba Tu and Trinh Ba Phuong, who are in direct contact with the Dong Tam villagers and have worked to smuggle information out, are currently at high risk of arrest.
Facebook itself is now complicit in the oppression, activists say , as the government—using a cybersecurity law it passed in 2018—has succeeded in pressuring the company to remove videos and posts regarding the Dong Tam attack; Vietnam’s own online army has succeeded in bringing down some activists’ profiles through coordinated campaigns.
Vietnamese civil society organizations have responded accordingly, organizing several campaigns to bring awareness to the event, as well as pressure the Vietnamese government to address inconsistencies and unknowns in the government’s “evolving” narrative.
Luat Khoa Magazine, an independent journal that covers legal and political issues in Vietnam, has mailed a letter to To Lam, head of Vietnam’s Ministry of Public Security with a list of fundamental legal questions for Mr. Lam to answer (English translation here), while a nationwide, weeklong “Pray for Dong Tam” color campaign launched Sunday, Jan 12, calling for calm, mourning, and an objective investigation into what transpired January 9 (English translation here).
Perhaps most significantly, the “Dong Tam Task Force”, an ad hoc organization established by leading Vietnamese activists, launched January 13 to organize, coordinate, and facilitate fact-finding in the Dong Tam attack (English translation here). It also aims to protect the remaining village witnesses from further government harassment and arrest.
Long-simmering Land Dispute in Hanoi Suburb Explodes in Violence, Killing 4
In scenes resembling a war zone, Dong Tam villagers vow to fight to the death to resist “corrupt” land reclamation
Amid sounds of explosions, screams, and gunfire, the villagers of Dong Tam, a rural commune 35 km southwest of Hanoi, clashed with Vietnamese police in the early morning hours of January 9, killing three police and one civilian, state-controlled media reported this afternoon.
According to the BBC, at 4 AM, police cordoned off Dong Tam in coordination with local ground forces and attacked villagers over a disputed piece of land. The villagers, who were never officially notified but had only heard through unofficial channels, declared in video recorded an hour before the attack that they would “fight to the death”.
The land had been earmarked since 1980 to form a part of the Mieu Mon military airfield, but in 2015, the plan was expanded to take up more nearby farming land and generalized to become an airport.
Citizen-blogger social media reports say police burst into the village with tear gas and grenades filled with plastic ball bearings, and descended upon village leader Le Dinh Kinh’s house, shooting and killing one individual, who remains unidentified as of this report.
Le Dinh Kinh and his son Le Dinh Cong have served as village representatives during repeated land disputes with the government. Media outlets have been unable to reach Le Dinh Cong for comment, but villagers say Cong’s family is in police custody and his father Kinh had gone into hiding a few days prior to the showdown. Prominent activist Anh Chi says those in custody include at least Cong’s daughter-in-law and two other family members.
Another witness describes “thousands of police officers rushing into the village” using flash grenades, firing tear gas, shooting rubber bullets, blocking off all pathways and alleys, and beating villagers indiscriminately, including women and old people. The witness stated that electricity to the village has not been cut, but the internet has.
According to state media, which quotes an official statement from the Ministry of Public Security, it was villagers who attacked police with “grenades, petrol bombs, and knives” as officials tried to erect a wall delineating Mieu Mon airport. The statement accuses villagers of obstructing official duties and “disturbing public order”, a catch-all often used to describe anti-government actions in Vietnam.
Dong Tam previously made international headlines in April 2017 when it held hostage 38 government officials and police officers in another land dispute with Viettel, a military-owned telecommunications company.
According to VNExpress, 46 hectares were granted to Viettel in March of 2015, only for villagers to complain to the government in June of 2016 that the land was being taken away from farming. Villagers were able to successfully fight off land reclamation from late 2016 until February 2017.
The land dispute came to a head in April 2017 when villagers captured more than three dozen officials and police and held them hostage as leverage for government dialogue. All hostages were released by April 22, after the mayor of Hanoi, major-general Nguyen Duc Chung, came to negotiate with villagers personally.
Vietnamese activists and experts believe the central conundrum causing Vietnam’s land disputes lays in the country’s political regime: “how [does one] allocate land in a Communist country that allows quasi-private ownership rights but still considers all land to be state property”?
According to the NYTimes, “[i]n 2013, Vietnam tweaked its land law in ways meant to introduce more transparency into eminent domain [i.e. government land reclamation] cases. […] But experts say land disputes continue, in part, because the 2013 revisions do not allow private ownership or set clear definitions of what qualifies as the public interest in eminent domain cases.”
Mike Ives of the NYTimes reports further: “[l]and disputes are common on the fringes of Vietnamese urban areas, where land values are often high; villagers are typically compensated at prices well below market rates for agricultural land that is later rezoned for other uses. John Gillespie, a professor at Monash University in Australia who is an expert on land reform in Vietnam, said in an interview that the disputes tended to be more violent when villagers perceived that business interests outweighed public ones.”
Dong Tam, with a population of around 9,000, continues to be under siege, according to social media reports. All parties involved remain on edge, with activist Anh Chi stating that “Tuan Ngo, one of lawyers helping the villagers, came to Dong Tam but was stopped outside. He was threatened to be arrested by a man in plainclothes with aggressive words.”
Images of one of the police officers killed in the clash have also begun circulating on social media, with those on both sides of the land dispute expressing sympathy. Nhu Quynh, whose 27-year old husband appears to have been involved at Dong Tam, inadvertently revealed in her caption that 3000 police officers were deployed. The image (screencaptured below) has since been taken down.
Le Dung Vova, a well-known activist and writer has stated of land disputes in Vietnam: “Things will not stop at Dong Tam. […] Similar incidents will keep happening everywhere [as in Loc Hung Garden], with different levels of intensity, especially as land resources become more scarce.”
Update: BBC News has reported that Dong Tam’s leader Le Dinh Kinh has passed away January 10, after clashing with government forces in the early morning hours of January 9.
Land Dispute in Hanoi Prompted Police Officers To Protest, Is That Illegal?
On the morning of November 12, 2019, a protest over a land dispute broke out in the Vietnamese capital of Hanoi. However, unlike in other recent protests, the protesters were not beaten up and arrested by the local authorities. This is probably because the people protesting were police officers of Dong Anh District and so their protest was not deemed illegal by the Hanoi government. This scenario was rare and not the typical case for most of those who protest in Vietnam because in most cases protesters have been assaulted and arrested by local authorities.
During the last few years, whenever I have had an opportunity to speak with foreigners, I have defended the right of the Vietnamese people to engage in peaceful assembly, which is protected by Vietnam’s Constitution. The problem is that the government of Vietnam has always classified the right to demonstrate and gather for peaceful assembly as a “disruption of public order,” and so the authorities have arrested hundreds and thousands of its citizens over the years because they joined protests.
As it turns out, many foreigners have the false belief that demonstrating is illegal in Vietnam and that people are not allowed to protest. The largest protest in Vietnam after our civil war ended in 1975 happened last year, in June 2018. And at that same time, The Vietnamese also clarified that the right to protest was not only legal, but it was a people’s constitutional right. Yet government officials continued to condemn the people’s right to demonstrate and have vowed that they will not allow any crowd to gather publicly. One of the most strident officials supporting the banning of all protests is To Lam, the minister of public security – the head of the national police force of Vietnam.
On November 12, 2019, social media and non-governmental media of Vietnam began to report that these police officers had gathered to protest a land dispute involving houses being constructed in Dong Anh district in Hanoi. The cause of the demonstration was very similar to the case of many farmers who had lost their land because of rapid plans for real estate developmental projects in recent years. Those protesting police officers had paid substantial amounts of money to purchase their homes some 17 years ago, but they had not yet received them. The police officers suspected corruption and went to protest against it. In Vietnam’s state-owned media, these protesters were classified as retired police officers who are not currently on active duty. It is likely that the government wants to soften up the fact that it was a case of actual, currently on duty went on protest for their land right to call these protesters as “retired.” However, the land dispute was confirmed to be true as was the fact that these officers did not receive their houses which they had already paid for.
Whether these officers are retired or not, this is one of the very few incidents in which people who belong to a police unit have found themselves in the same position as other victims who have lost their land. In this case, it was the land rights of former police officers that had been violated and they could not find a proper way to resolve the problem. Protesting against alleged corruption was the only option for them to raise their voices and to address this issue.
Police forces in Vietnam have always played a close role in carrying out the government’s actions and will. They have been cast as active members of the Vietnamese Communist Party (VCP) who were assigned to fight opposition movements and the people who do not agree with the way the VCP leads. During the November 12, 2019 incident, the protest by these police officers was not abruptly stopped by the authorities. None of the retired officers got arrested and none were classified as “reactionary forces” in Vietnam’s state-owned media, as has been the case with others who have protested.
This is an indication of the big difference in how the government treats its own police officers versus how it treats Vietnamese citizens during protests. Nevertheless, the protest by police in Dong Anh district earlier this month has underpinned that land disputes are becoming a wild beast in Vietnam. This social problem will not exclude government workers and police who will soon join the masses of people in the country who have suffered the injustice of seeing their land taken from them.
Earlier this year inJanuary, in the Loc Hung Garden Incident, local authorities wrongfully evicted and destroyed over 100 households in Tan Binh district in Ho Chi Minh City. The residents of Loc Hung have filed their petitions and they are continuing their legal struggle with the authorities right up until now. In a major city such as Ho Chi Minh City, the Loc Hung residents have only faced losing their homes and their land but in other remote areas, the victims have faced physical harm and some have even lost their lives. That is the story of death-row inmate Dang Van Hien.
Dang Van Hien and his neighbors from Village 1535, Quang Truc ward, Tuy Duc district, who come from different areas of the country, have become adjusted to living in poverty since the time they were born. They gradually saved up enough money and bought a small piece of land, but all they could afford was property in areas off the beaten track or remotely placed in the jungle. They have been living as the modern “les miserables” in a remote area in Dak Nong province in the Central Highland of Vietnam.
These farmers were there to farm and live peacefully until a private company – Long Son Investment & Commercial – came and disputed their land ownership. Tragedy struck when the government granted Long Son 1,079 hectares of forest land without first doing a proper land survey, which resulted in the company’s claims overlapping the parcels of land owned by these poor farmers. Over the last 10 years, these farmers have tried everything they could to petition the government to correct the improper land assessment. At the same time, Long Son used force to destroy their crops and tried to kick them off their lands and out of their homes.
On October 23, 2016, a deadly altercation happened involving Hien, his friends and the workers of Long Son. Hien fired a self-made gun killing three workers and injuring some others when workers invaded his farm with bulldozers and weapons. He was sentenced to death in 2018 and the highest court upheld his sentence this year. His life may be spared if President Nguyen Phu Trong grants him a reprieve. However, there is no indication that this will happen.
The Vietnam Land Law has faced a lot of controversies and criticisms in public because its ambiguity has resulted in the many land disputes that people have been facing. Yet, because the state wants to securely own all of the land in the country, individuals and private entities cannot own land and can only receive land use rights from the state. As a socialist country, the Communist Party does not allow private property ownership, and yet the law defines nicely that land ownership in Vietnam “belongs to the entire people” “with the State acting as the owner’s representative and uniformly managing land.” The State also gives itself the power to “hand over land use rights to land users in accordance with this Law.” (Article 4, Land Law 2013). This clause that the state shall “hand over land use rights” has created land disputes in Vietnam over the past decades and continues to do so because of corruption.
With the recent story of police officers protesting for their land rights this month in Hanoi, we can see that disputes involving land will continue to be a problematic social issue growing inside the country and that no one will be spared, including government workers and police officers. And if the president of Vietnam does not save the life of Dang Van Hien, Hien will be the first person to be executed due to a land dispute and his case may put more pressure on land administration in Vietnam.
To protect their land rights everyone has to fight, from a poor farmer living in the Central Highlands to the police officers in Vietnam’s capital. The consequences each of them may face for protesting for their rights may be very different. But they all have no other choice but to oppose those who violate their rights. The people have waited patiently and petitioned for 10 or 20 years to protect their rights, but they still have not gotten any response from the judicial system. Corruption and secret deals between some local authorities and real estate developers coupled with an ambiguous law on land administration have worked together to prevent victims of land disputes from having their day in court and receiving justice.
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