If you are searching for terms like criminal costs lawyer NSW, police to pay legal costs, section 214 costs, costs certificate or even practical searches such as AVO lawyer near me and revoke AVO, you are probably worried about two things at once.
First, the outcome of your case.
Second, how much you will spend to get there and whether you can recover any of it.
This long form guide explains how costs work in New South Wales criminal proceedings, when the court can order the prosecution to pay your professional legal costs, when you can seek a costs certificate under the Costs in Criminal Cases Act, what evidence persuades a magistrate or judge, and what our firm does in practice to position you for a successful costs outcome.
Written by our team of experienced and award-winning criminal defence lawyers in Sydney, National Criminal Lawyers®, we integrate direct passages from real costs applications and written submissions to show you the language that has actually moved decision-makers.
Everything that follows is designed to be both educational and linked to related topics you might be searching for like property damage defence lawyer, domestic violence defence strategy, AVO variations, and evidence challenges in the Local Court and District Court.
Why Costs Matter And What “Costs” Actually Means
In criminal proceedings, costs are not a punishment or a windfall. They are a way for the court to repair some of the financial damage caused when a person is drawn into a prosecution that should not have been brought or continued, or when a person is acquitted at trial and the objective facts show that it would not have been reasonable to prosecute had the Crown possessed all relevant facts.
Costs are not automatic. Winning your case is not enough by itself. The court must be satisfied that a statutory ground is met and that it is just and reasonable to order the payment of professional costs. The two principal mechanisms are an order against the informant or prosecutor under section 214 of the Criminal Procedure Act 1986 (NSW) and a certificate under section 2 of the Costs in Criminal Cases Act 1967 (NSW).
From a client’s point of view this translates to clear questions. If the police withdrew your property damage charge, can you ask the Local Court to order them to pay your professional fees. If you were acquitted after a District Court jury trial, can you apply for a certificate that enables you to be reimbursed from the Consolidated Revenue Fund.
If your AVO was dismissed while the charge was withdrawn, where does that leave you on costs? Understanding the two pathways will help you decide if you should press a costs application at the conclusion of your matter.
Pathway One:
Costs Orders Under Section 214 Of The Criminal Procedure Act
Section 214 governs costs orders in summary proceedings. Courts will consider ordering the prosecution to pay the accused’s professional costs when summary proceedings are dismissed or withdrawn. But they only do so where one of the statutory grounds is made out. In written submissions filed in a Local Court costs application, we put the basic structure this way.
“The Accused relies on sections 213 and 214 (a), (b), (c) and (d) of the CPA or in the alternative on section 2 of the CCC Act.”
The focus under section 214 is whether the investigation was unreasonable or improper, whether the proceedings were instituted without reasonable cause or in bad faith or conducted improperly, whether the prosecutor unreasonably failed to investigate matters suggesting innocence, or whether other exceptional circumstances exist so that it is just and reasonable to award costs.
The case law consistently warns against importing a higher test than the statute requires. As one set of our submissions accurately records, “it is not necessary, in order to satisfy a Court, when making an application for costs, that the investigation ‘fell grossly below optimum standards’. No expression similar to the term ‘fell grossly below optimum standards’ appears in s214(1)(a) CPA.” Our analysis then cites JD v DPP and ORS [2000] NSWSC 1092 as authority for rejecting that unwarranted gloss.
Our submissions continued by explaining how a court assesses whether the investigation or institution of proceedings was unreasonable. They adopted a well known passage from the industrial law context that has been cited many times in criminal costs applications.
“One way of testing whether a proceeding is instituted ‘without reasonable cause’ is to ask whether, upon the facts apparent to the applicant at the time of instituting the proceedings, there was no substantial prospect of success. If success depends upon the resolution in the applicant’s favour of one or more arguable points of law, it is inappropriate to stigmatise the proceeding as being ‘without reasonable cause’. But where, on the applicant’s own version of the facts, it is clear that the proceeding must fail, it may properly be said that the proceeding lacks reasonable cause.”
Courts do not stop with a checklist. They evaluate what police had, and what they should have had, before charging. The same submissions summarise the point as follows.
“The question whether the proceedings were initiated without reasonable cause is to be answered by ‘reference to the quality of the evidence which the police had gathered, with an eye not only to the enquiries which had been made but also to those which should have been made’.”
The quotation is taken from JD v DPP [2000] NSWSC 1092 at [28], a decision frequently used in section 214 arguments.
There is also authority recognising that it is not enough to show a prima facie case existed on paper. The Crown’s duty is to evaluate contradictory material and obvious weaknesses. To quote directly from one of our Local Court costs briefs that synthesised several appellate authorities, “The fact that a prosecution may be launched where there is evidence to establish a Prima Facie case does not mean that is reasonable to launch a prosecution because ‘There may be cases where there is contradictory evidence and where it is reasonable to expect a Prosecutor to make some evaluation of that evidence’.”
The same theme is repeated in a decision of the Court of Criminal Appeal.
“The legitimate interest which the community has in serious crimes being prosecuted by the Director of Public Prosecutions is not disputed. That cannot, in our judgement, make it reasonable as between the Crown and the accused or applicant to prosecute in the face of significant weaknesses in the Crown case which the Crown acting reasonably, ought to have been aware.”
That statement from R v Pavy has been quoted in multiple costs applications and appears in written submissions we have reviewed.
Section 214 also contemplates failures to investigate reasonable lines of inquiry. For example, there are cases where a costs applicant could show that police failed to speak to obvious witnesses, failed to obtain CCTV in circumstances where it was available, or failed to gather records that would either confirm or contradict a complainant’s version. Another of our costs applications put it plainly.
“Investigation into surrounding CCTV was sought but failed. Investigation to access the Accused phone records had also failed on the basis that the duty office did not approve the request. This approval was rejected on the basis that ‘the complainant was unable to provide please with any reasonable time frame for the phone calls taking place’.”
Where the prosecution relies on a circumstantial case, the failure to exclude rational alternatives consistent with innocence can also support an unreasonable investigation finding. As explained in a costs paper that cited Eslarn Holdings Pty Ltd v Tumut Shire Council, “There were other rational inferences consistent with the facts and which were also consistent with the appellant’s innocence which the prosecution had not negatived, so that the guilt of the appellant was not the only rational inference to be drawn therefrom.” The judge in that case observed that the failure to investigate other reasonable hypotheses was sufficient to satisfy the unreasonable investigation test.
Another appellate decision used in section 214 arguments is Cliftleigh Haulage Pty Ltd v Byron Shire Council, where Hodgson JA criticised a failure to interview a relevant independent witness once the defence identified an alternative explanation. The passages relied upon in real submissions are worth reproducing.
“Whether or not it was reasonable to rely on a circumstantial case before the appellant company’s assertion, it was arguably no longer reasonable after the assertion was made and there was a witness, not connected with the company, who may have been able to give direct evidence on the point.”
The court continued, “If a prosecutor knows there are five eye witnesses to an event, and interviews and calls only one of them, and the prosecution then fails, I think s.70(1)(a) may apply even if the person seeking costs does not prove what the other four witnesses would have said.”
The practical lesson for a person defending a Local Court matter that was dismissed or withdrawn is simple. To recover professional costs under section 214, point to concrete investigative failures or to the absence of reasonable cause at the time of charge. Do not rely on the fact you won.
As one set of submissions rightly warned, “The provisions referred to in 214(1)(b) contains no provisions that ‘exceptional circumstances’ are required to [the] making of an order for costs.”
What matters is the objective quality of the evidence the police had and should have had, measured at the time proceedings were instituted.
Pathway Two:
Costs Certificates Under Section 2 Of The Costs In Criminal Cases Act
The second pathway is a certificate under section 2 of the Costs in Criminal Cases Act. Unlike section 214, this route is not about punishing a police failure. It asks a different question. If the prosecution had been in possession of evidence of all the relevant facts at the time of institution of proceedings, would it have been reasonable to prosecute.
One of our written submissions filed in the District Court captures the statutory text and the structure of the analysis.
“The Court or Judge or Magistrate in any proceedings relating to any offence, whether punishable summarily or upon indictment, may where, after the commencement of a trial in the proceedings, a defendant is acquitted or discharged in relation to the offence concerned, or a direction is given by the Director of Public Prosecutions that no further proceedings be taken grant to that defendant a certificate under this Act, specifying the matters referred to in section 3 and relating to those proceedings.”
Section 3 then defines what the certificate must specify. The same submissions set out the words that have guided judges for decades. A certificate “shall specify that, in the opinion of the Court or Judge or Magistrate granting the certificate: if the prosecution had, before the proceedings were instituted, been in possession of evidence of all the relevant facts, it would not have been reasonable to institute the proceedings, and that any act or omission of the defendant that contributed, or might have contributed, to the institution or continuation of the proceedings was reasonable in the circumstances.”
The point is to ask a hypothetical question with the benefit of everything we now know from the trial record and any further facts admitted under section 3A.
These submissions also record two often overlooked clarifications. A grant of legal aid does not bar a person from applying for a certificate, due to section 42 of the Legal Aid Commission Act. The fact that a jury considered the case is not an answer in itself either. The court must still ask the Allerton question.
“Applying the Allerton test, it is submitted that your Honour, having considered all of the relevant facts, would conclude that, if the prosecution had evidence of all the relevant facts immediately before the proceedings were instituted, it would not have been reasonable to institute the proceedings.”
In the same document our lawyers collect useful principles. One of them is sometimes controversial in public commentary but not in the law.
“Another very important principle which should be noted and which has been well established by the authorities is that the prosecution cannot resist a certificate under s.2 of the CCC Act on the basis of some ill defined community interest in bringing a particular accused, or kind of matter, before the courts.”
The submissions refer to R v Moore and to a well known statement repeated in Pavy and in Manley that generalised public confidence arguments do not answer the objective reasonableness test.
For readers who want the framework in a single passage, this submission also quotes the summary of principles given by McColl JA in Mordaunt v DPP. It explains that the Act has a beneficial purpose, that the institution of proceedings is measured at the time of arrest or charge, that the onus is on the applicant to show it would not have been reasonable to prosecute, and that the court asks the hypothetical question using all relevant facts proved at trial or admitted later under section 3A. The submissions describe that approach as the starting point for judges considering section 2 certificates.
The same collection sets out detailed reminders that will help potential applicants and their lawyers. The reasonableness of prosecution is not judged by the usual DPP discretionary test about reasonable prospects of conviction nor by a committal test. It is its own objective analysis under section 3. It is not defeated by the notion that many cases are word against word. As one judge put it in an unreported decision cited in our aforementioned submissions, things are different “where the word upon which the Crown case depended had been demonstrated to be one which was very substantially lacking in credit.”
What Counts As Persuasive Evidence In Costs Applications
Every costs application is fact heavy. The law is stable but the outcome depends on what you can show. We approach the evidence in three steps.
First, we reconstruct the state of the police case at the moment of institution of proceedings. Did the police have only a bare complaint and no corroboration? Did they overlook obvious lines of inquiry? Were there custody management notes, third party witnesses, CCTV, phone data, medical records, or workplace records that would have materially affected the decision to charge.
In one of our costs applications, the failure to pursue phone records after being told the complainant could not provide a timeframe, and the failure to obtain nearby CCTV, were highlighted.
“Investigation into surrounding CCTV was sought but failed. Investigation to access the Accused phone records had also failed on the basis that the duty office did not approve the request.”
That text was then paired with case law about the duty to test competing rational inferences.
Second, we gather independent material that shows the prosecution theory was incomplete or objectively weak at the time. For example, the presence of injuries on an accused recorded in custody reports where there is no medical evidence of injury to the complainant was highlighted in one Local Court costs brief: “the custody management reports indicates that the person who was injured was in fact the Accused. In no police statement was there an indication of injury on the complainant.” That mismatch triggered the principle that an investigation is unreasonable where basic corroborative steps are not taken despite obvious red flags.
Third, we link the facts to the statutory test using direct appellate language. Here the aim is to give the court permission to say what the cases say. The passage from a costs application for our client K about “no substantial prospect of success” is often put in front of the magistrate because it fits well with a facts sheet that, even if accepted at its highest, could not meet the elements of the offence. The submissions we quoted above include the full Kanan test for exactly that reason.
How Often Does The Court Order Police To Pay Costs
Rare but not vanishingly rare. Magistrates and judges are cautious because costs orders divert public resources and should not chill legitimate prosecutions. But when the investigation is unreasonable or the institution of proceedings is without reasonable cause, costs follow. The best way to think about frequency is to look at the reasons that persuade courts. Appellate judges have said it is not sufficient to rest on a prima facie case if there are significant weaknesses that a reasonable prosecutor should have appreciated.
They have also rejected the idea that a general need to be seen to prosecute serious crimes can make an unreasonable case reasonable. Submissions for our client A capture this in a compact way.
“It would be unacceptable to impose some qualification upon the section designed to encourage prosecutions in order to satisfy some ill defined community interest in bringing a particular accused, or kind of matter, before the Courts.”
The practical signal for clients is that there is no taboo against costs orders. The question is always evidence and timing. If your property damage charge was withdrawn at hearing because the only witness was unreliable and objective records did not support the allegation, or if your AVO was dismissed and the facts indicate the police knew or should have known the case could not meet the elements, then a section 214 application is not only appropriate but important to hold the state to a proper standard.
Timing, Procedure And What You Can Claim
Under section 214, a costs application is made immediately after the proceedings are dismissed, withdrawn, or result in a stay, or at the conclusion of a hearing. The defence outlines the statutory ground and tenders material showing what the police had and what they did not do. The court may hear from the prosecutor, then rules on whether a ground is made out and whether it is just and reasonable to award costs. The order relates to professional costs of legal representation. It does not compensate you for stress or time off work. The court then assesses quantum by reference to a just and reasonable amount based on the work actually done.
Under section 2 of the Costs in Criminal Cases Act, a certificate application is made in the court where the acquittal or discharge occurred. If the certificate is granted, the administrative recovery then takes place through the Attorney General’s Department. Our submissions for A reminds applicants that legal aid is not a bar.
“The fact that the applicant’s trial was funded by a grant of legal aid does not preclude him from making the application: s.42 of the Legal Aid Commission Act 1979.”
Quantifying what you can recover differs between the two regimes. A section 214 order is a court order against the prosecution to pay professional costs in a just and reasonable amount. A section 2 certificate entitles you to apply for payment from Consolidated Revenue. Both relate to professional costs rather than general damages. In practice we provide an itemised schedule of attendances, analysis time, drafting, conference time, and hearing time to support the figure sought, and we square it with the proportionality of the work to the issues that were actually in dispute.
Case Study Themes Taken From More Real Submissions
While we cannot publish private names, we can extract the recurring investigative themes and the exact phrases that have been used in successful submissions. The following examples come from written submissions filed in Local Court and District Court matters.
First, failure to interview obvious witnesses. One Local Court costs application highlighted that police were told about material eyewitnesses early and simply did not take statements. The submission put it plainly.
“There is no indication in any of the statements which forms part of the brief of evidence against the Accused that suggests that some enquiry was made with any of the witnesses who were first hand witnesses or material witnesses to the offences alleged against the Accused.”
Second, objective contradictions that should have changed the charging decision. The same brief pointed to custody management entries showing the accused had visible injury while there was no mention of injury to the complainant, then tied that to the duty to evaluate contradictory material rather than proceed on a bare allegation. That approach was anchored by the passage from Pavy that we have already quoted, warning prosecutors that public interest in serious crime does not make an objectively weak case reasonable.
Third, circumstantial cases and rational alternatives. One set of submissions quoted Eslarn to illustrate that prosecution cannot ignore other rational inferences consistent with innocence, and used Cliftleigh to show that ignoring independent eyewitnesses will ground a costs order even if the defence cannot prove what those witnesses would have said. The quotes reproduced earlier are the very sentences that align with section 214 arguments.
Fourth, the proof in the procedural pudding. Sometimes the most telling fact is that a weak case collapses at the door of the court after the prosecution has had months to rethink the evidence. One submission captured this candidly.
“It is submitted that the withdrawal of the charges on the day of the hearing is the proof in the pudding that ‘on the applicant’s own version of the facts’ the proceedings would fail and that the proceedings lacked reasonable cause.”
Fifth, the structure of section 2 arguments after an acquittal. Our submissions for our client A submissions are useful because they walk carefully through the statutory text and then apply the Mordaunt principles. They emphasise, among other points, that the institution of proceedings is measured at arrest or charge, that the onus lies on the applicant, and that the court considers all relevant facts including those proved during the trial and those admitted afterwards under section 3A. The submissions bring together those points in one place so that the court can grant a certificate with confidence that the statutory test has been properly respected.
How We Build A Costs Application From The Ground Up
Our firm’s approach to costs is systematic. From the first conference we separate the merits strategy from the costs strategy. If you are calling because you typed criminal costs lawyer NSW or AVO lawyer near me or property damage defence lawyer into Google after a first appearance, we will map a path for both the substantive defence and a potential costs application if the case resolves in your favour.
We create a record of requests to the prosecution for disclosure and for basic investigative steps, such as CCTV capture, forensic downloads, and third party records. Where appropriate we write to the officer in charge asking them to speak to particular witnesses, and we note any refusal or delay. If the case is later withdrawn or dismissed, these preserved requests become evidence that the prosecutor unreasonably failed to investigate a matter they should have been aware of. The language we use is consistent with the appellate authorities. We identify lines of inquiry and flag contradictions, then we link those steps to section 214’s text.
When a case proceeds to trial and ends in an acquittal, we pivot to the section 2 framework. We prepare a short chronology of what the police knew at arrest or charge and what the prosecution should be taken to have known had they possessed evidence of all relevant facts. We draw on the Mordaunt principles to show that the test is not the DPP policy on prospects but the objective test set by the statute. Where there is an argument about the effect of word against word evidence, we show how credibility issues progressed during trial and whether the principal Crown witness was, in the language used in authorities collected in our submissions for A, “very substantially lacking in credit.”
If your case included an AVO that was dismissed or varied, and a related charge that was withdrawn, we will address costs on each component. If the result flowed from police failing to investigate exculpatory witnesses or from a charge that could not meet the elements even at its highest, then section 214 is engaged. If the result was an acquittal after a hearing on the merits in the Local Court or a trial in the District Court, then section 2 becomes an additional or alternative path.
Common Misunderstandings About Costs In Criminal Cases
There are several myths that can cost you money if you rely on them. The first is the idea that an acquittal guarantees a costs order against the police. That is incorrect. Costs are not punitive and are not automatic. You must bring your case within the statutory grounds in section 214 or the certificate test in section 2.
The second is the misconception that it was reasonable to prosecute simply because a prima facie case existed. The authorities cited in the submissions above make it clear that a bare prima facie case is not the test, especially where contradictory material is obvious and unexplored. The passages from JD v DPP and Pavy reproduced earlier are often used by courts to answer this point.
The third is the thought that public policy concerns about serious categories of crime make an otherwise unreasonable prosecution reasonable. The A submissions condense the answer to that point into one sentence that courts accept. “It would be unacceptable to impose some qualification upon the section designed to encourage prosecutions in order to satisfy some ill defined community interest in bringing a particular accused, or kind of matter, before the Courts.”
The fourth is the view that legal aid funding prevents a costs certificate. It does not. The A document is explicit. “The fact that the applicant’s trial was funded by a grant of legal aid does not preclude him from making the application: s.42 of the Legal Aid Commission Act 1979.”
What This Means For People Reading This Guide
If you have had a charge withdrawn or dismissed in the Local Court and are wondering whether you can recover your professional legal costs, the answer is that you may be able to do so, but only if we can show one of section 214’s grounds and that it is just and reasonable. That will require a careful review of what police knew and did. If you were acquitted after a hearing or a trial and you are thinking about a costs certificate, the question becomes whether, on all relevant facts, it would not have been reasonable to prosecute at the outset. The Submissions for A and Mordaunt principles tell us how to ask and answer that question for the court.
If your matter also involved an AVO that you wish to vary or revoke, the costs issues will run alongside the AVO strategy. We can guide you through the evidence needed to revoke AVO orders or to resist final orders while also preserving a record that supports a later costs application, whether the AVO is dismissed or another outcome is reached. This is why people search for revoke AVO and AVO lawyer near me at the same time they search for criminal costs lawyer NSW. The issues overlap. A property damage defence lawyer may be the first person to spot the contradictions that later carry a section 214 application.
The quotes we have incorporated above show the tone and specificity that persuades courts. To recap the most instructive lines. “The starting point… is to first acknowledge that it is not necessary… that the investigation ‘fell grossly below optimum standards’.” That is how we correct misguided arguments about the threshold. “There may be cases where there is contradictory evidence and where it is reasonable to expect a Prosecutor to make some evaluation of that evidence.” That is how we press the duty to engage with weaknesses. “There were other rational inferences consistent with the facts and which were also consistent with the appellant’s innocence which the prosecution had not negatived.” That is how we frame circumstantial cases where rational alternatives were left unexplored. “If a prosecutor knows there are five eye witnesses to an event, and interviews and calls only one of them, and the prosecution then fails… s.70(1)(a) may apply.” That is how we show unreasonable or improper investigation even without proving what the other witnesses would have said. And on section 2 certificates, A reminds the court of the question it must answer, including that legal aid is not a bar and that public policy glosses do not trump the statute.
Frequently Asked Questions
How long does a costs application take?
The application itself is typically made immediately after your matter is dismissed, withdrawn, or an acquittal is entered. The court will either hear it there and then or allocate a short timetable for submissions. A section 2 certificate requires an application in the court of acquittal and then administrative processing with the Attorney General’s Department.
Do I need to be present?
In Local Court section 214 applications the accused is usually already present for the hearing or mention. For section 2 certificates after a District Court trial, your legal team can generally appear without you while you get on with your life.
What information should I collect now?
Anything that shows investigative steps requested by the defence and not performed. Emails requesting CCTV preservation. Letters asking police to interview a named witness. Notices of alibi. Confirmations that the complainant declined to provide medical records where injury was central. Custody management notes showing the accused’s visible injuries. All of these can later be linked to section 214 or section 2 arguments.
What can I realistically recover from?
Professional costs for your defence work, assessed on a just and reasonable basis in section 214 orders or under the certificate process for section 2. Fees for conferences, preparation, drafting, mentions, and hearings can be claimed. We provide an itemised schedule so the court can assess fairly.
How does this relate to appeals or convictions?
Costs orders after acquittals or withdrawals are one thing. Other costs regimes apply in the event of successful appeals. You should speak with an appellate criminal lawyer if you are considering setting aside a conviction. Our firm handles those matters and we can advise on costs prospects in that context.
The National Criminal Lawyers Approach And Why It Works
The reason clients choose us for costs applications is that we build the record early. We document investigative gaps, we request specific steps, and we write letters of representations that explain why the case should not proceed. Those representations often lead to withdrawals. When they do, we do not stop there. If the record supports it, we apply for costs. Where a case goes to a hearing or a trial and ends in acquittal, we prepare a careful section 2 application based on Mordaunt and Allerton.
Our submissions match the tone courts expect. We do not rely on rhetoric or generalised fairness. We quote the authorities that matter and we give the magistrate or judge a principled path to the order. The passages you have seen throughout this article are not slogans. They are the lines that have carried real costs applications. For example, the decisive Kanan passage on proceedings instituted without reasonable cause appears verbatim in successful Local Court submissions, and the extracts from our costs submissions for A lay out the path to a certificate with the precision District Court judges require.
If your case intersects with an AVO, domestic violence allegations, or property damage, we knit the merits defence with the costs strategy. A client who searched property damage defence lawyer might at first be focused on avoiding a conviction and protecting their employment. We keep that focus while also preserving the material that can win a costs order once the charge is withdrawn or dismissed. A client who searched revoke AVO or AVO lawyer near me may be seeking urgent protection of their family and work life. We will align the AVO strategy with a potential section 214 or section 2 application, so that if the AVO is dismissed alongside a withdrawn charge you are positioned to recover your professional costs where the statute allows.
Your Next Step: Contact us
If your charge was withdrawn or dismissed, or if you were acquitted after a hearing or a trial, you should obtain advice immediately about a costs application. The window for a section 214 application is at the end of proceedings in the Local Court. The pathway for a section 2 certificate requires a targeted application that integrates all relevant facts and the authorities set out in A and Mordaunt. We will review your brief, identify the best ground, and prepare the application.
Call National Criminal Lawyers® now. Ask to speak with a criminal costs lawyer NSW about a section 214 application or a section 2 certificate. If you found us by searching AVO lawyer near me, revoke AVO, property damage defence lawyer, or police to pay legal costs, you are in the right place. We will protect your rights, your time, and your pocket. We have persuaded prosecutors to withdraw weak matters and we have used the precise language quoted above to secure costs outcomes when appropriate.
Contact us for a free initial discussion and a clear plan. We will tell you where your case sits on the section 214 grounds or the section 2 certificate test, what evidence we will collect, and what you can expect. When results matter and costs matter, you want a defence team that treats both with equal seriousness. Reach out today and let us start the work.
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