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Furthermore, to the extent they have not been produced, Plaintiff shall provide to Defendant copies of paystubs showing a reduction in earnings, if any.

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Defendant has a substantial need for the documents and cannot obtain their substantial equivalent by other means.

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To protect the Town and its residents from potential disruption of Town services during the coronavirus pandemic due to the diversion of scarce Town resources and personnel from necessary operations.

Days later, she sought emergency care.

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