Dealing with Non-Party Defenses

IN OUR JUDGMENT
By Terri Todd & Ted Smith

In our judgment, plaintiffs’ counsel should take an offensive posture with regard to nonparty defenses that are asserted by defendants and aggressively seek to force defense counsel to properly identify nonparties in a timely manner and move to strike inappropriate nonparty defenses.

Indiana’s Comparative Fault Act⁽¹⁾ provides that in an action based upon fault, the trial court shall instruct the jury that in reaching its verdict it shall first determine the percentage of fault of the claimant, of the defendant(s), and of any person or entity who is a nonparty. The total of those percentages of fault must equal 100%.⁽²⁾ If the claimant’s percentage of fault is not greater than 50% of the total fault, the jury shall next determine the total amount of the claimant’s damages without regard to fault.⁽³⁾ The jury shall next multiply the percentage of fault of each defendant by the total amount of the claimant’s damages and enter a verdict against each defendant in an amount that equals the product of that multiplication.⁽⁴⁾

The nonparty defense is a powerful tool because the claimant loses the percentage of his/her damages that equals any percentage of fault that is attributed to a nonparty. Therefore, defendants search for individuals and entities to name as nonparties to reduce their liability to a plaintiff. Defense counsel frequently name nonparties whose legal liability to the plaintiff is marginal (or nonexistent) and whose percentage of fault is small at best. Once a defendant pleads a nonparty defense, the plaintiff is then put in the position of making a tactical decision as to whether to add the nonparty as a defendant in the case.

I.C. 34-4-33-10(b) provides that the burden of proving a nonparty defense rests with the defendant, who must affirmatively plead the defense. If the plaintiff adds the nonparty as a defendant in the case, the plaintiff then bears the burden of proof with regard to that party’s fault. Therefore, if a nonparty’s fault is slight and/or the nonparty’s liability is marginal, plaintiff’s counsel may decide that the better strategy is not to sue the nonparty. The purpose of this article is to suggest steps that should be taken to identify nonparty defenses, determine whether asserted nonparty defenses are valid, and to eliminate invalid nonparty defenses from a case.

Plaintiffs counsel must take the offensive with regard to identifying nonparty defenses and determining whether they are valid. I.C. 34-4-33-10(c) provides that:

A nonparty defense that is known by the defendant when he files his first answer shall be pleaded as a part of the first answer. A defendant who gains actual knowledge of a nonparty defense after the filing of an answer may plead the defense with reasonable promptness. However, if the defendant was served with a complaint and summons more than one hundred fifty (150) days before the expiration of the limitation of action applicable to the claimant’s claim against the nonparty, the defendant shall plead any nonparty defense not later than forty-five (45) days before the expiration of that limitation of action. The trial court may alter these time limitations or make other suitable time limitations in any manner that is consistent with:

(1) giving the defendant a reasonable opportunity to discover the existence of a nonparty defense; and

(2) giving the claimant a reasonable opportunity to add the nonparty as an additional defendant to the action before the expiration of the period of limitation applicable to the claim. [Emphasis added.]

In view of I.C. 34-4-33-10(c), plaintiffs counsel should generally file suit at least 150 days prior to the expiration of the applicable statute of limitations. However, that is not always possible — as in the situation where the plaintiff does not hire counsel until shortly before the expiration of the statute of limitiations. In addition, there are situations in which defendants name nonparties who plaintiff’s counsel decides to sue, who then name other nonparties less than 150 days prior to the expiration of the statute of limitations. In such situations, pursuant to I.C. 34-4-33-10(c), plaintiff’s counsel should ask the court to alter the time limitations for pleading nonparty defenses.

* * * * * *

A motion and order that can be used to shorten the period of time in which a Defendant must name nonparties are as follows:

IN THE MARION COUNTY SUPERIOR COURT NO. 3
CIVIL DIVISION
STATE OF INDIANA

SUSAN CLARK, Plaintiff
vs.
PATSY GREEN, Defendant.

CAUSE NO. 49D03-9608-CT-0592

PETITION TO ALTER TIME LIMITATIONS FOR PLEADING NONPARTY DEFENSES

Comes now the Plaintiff, Susan Clark, by counsel, and pursuant to I.C. 34-4-33-10(c), moves the Court for an Order, altering the time limitations set out in I.C. 34-4-33-10(c) relative to the naming by the Defendant of any nonparties, to a time prior to the expiration of the statute of limitations relative to the Plaintiff’s claim. In support of this Motion, the Plaintiff shows the Court the following:

1. The incident out of which this lawsuit arises was a motor vehicle crash in which the Plaintiff and Defendant were involved on October 24, 1994. The Plaintiff is making a claim for personal injuries which she sustained in that crash.

2. Pursuant to I.C. 34-1-2-2, the applicable statute of limitations relative to the Plaintiff’s claim is two (2) years after the date of the crash. Therefore, the statute of limitations expires on October 24, 1996.

3. The Plaintiff initiated this case by filing her Complaint for Damages against the Defendant on July 31, 1996.

4. Defense counsel entered an Appearance on behalf of the Defendant and filed a Motion for Extension of Time to answer the Plaintiff’s Complaint and the Interrogatories which were filed simultaneously with the Plaintiff’s Complaint, requesting that the Defendant be given until October 7, 1996 to file an Answer to the Plaintiff’s Complaint and to answer the Interrogatories propounded by the Plaintiff.

5. I.C. 34-4-33-10(c) requires that a Defendant plead any nonparty defense of which she is aware when she files her Answer to the Plaintiff’s Complaint. I.C. 34-4-33-10(c) bars the pleading of any nonparty defense after 75 days prior to the expiration of the applicable statute of limitiations if the Plaintiff’s Complaint is served within 150 days before the expiration of the statute of limitations. In addition, this statute provides that the trial court may alter the time limitations for pleading nonparty defenses consistent with:

(1) giving the defendant a reasonable opportunity to discover the existence of a nonparty defense; and

(2) giving the claimant a reasonable opportunity to add the nonparty as an additional defendant to the action before the expiration of the period of limitation applicable to the claim.

6. The Plaintiff believes that this crash has been fully investigated by representatives of the Defendant. Thus, the facts of the crash are known to all parties.

7. If requested by defense counsel, the Plaintiff will make herself available for deposition prior to October 7, 1996, the date on which the Defendant’s Answer to the Plaintiff’s Complaint is due.

8. The Plaintiff requests that the Court alter the time limitations contained in I.C. 34-4-33-10(c) and issue an Order, requiring the Defendant to plead any nonparty defenses within the enlargement of time that has been granted to her to answer the Plaintiff’s Complaint (i.e., October 7, 1996), in order to permit the Plaintiff to add any named nonparties as additional Defendants in this action prior to the expiration of the statute of limitiations.

WHEREFORE, the Plaintiff prays that the Court order the Defendant to plead any nonparty defenses within the enlarement of time granted to her to answer the Plaintiff’s Complaint (i.e., October 7, 1996), and for all other just and proper relief in the premises.

SMITH TODD & FARRELL

______________________________
Ted Smith #394-48

* * * * * *

IN THE MARION COUNTY SUPERIOR COURT NO. 6

SUSAN CLARK, Plaintiff,
vs.
PATSY GREEN, Defendant.

CAUSE NO. 49D06-9608-CT-0592

ORDER ALTERING TIME LIMITIATIONS FOR PLEADING NONPARTY DEFENSES

Comes now the Plaintiff, Susan Clark, by counsel, and having filed her Petiton To Alter Time Limitations For Pleading Nonparty Defenses, and the Court being duly advised in the premises, now finds that said Petition should be, and hereby is, GRANTED.

IT IS THEREFORE ORDERED, ADJUDGED AND DECREED that the time limitations set out in I.C. 34-4-33-10(c) are altered in order to allow the Plaintiff to add any nonparties named by the Defendant as additional Defendants in this action prior to the expiration of the statute of limitations. The Defedant is therefore ordered to plead any nonparty defenses within the enlargement of time granted to her to answer the Plaintiff’s Complaint for Damages (i.e., October 7, 1996). The plainitff shall be entitled to join any nonparties named by the Defendant by amending her Complaint.

SO ORDERED this ________ day of September, 1996.

________________________________________
The Honorable John F. Hanley, Judge
Marion County Superior Court No. 3

* * * * * *

Another tactic employed by defense counsel is to allege in an Answer to a Plaintiff’s Complaint that “Plaintiff’s alleged damages, if any, were caused in full or in part by a nonparty” or that or that “the Defendant reserves the right to name nonparties who caused or contributed to cause the Plaintiff’s alleged injuries and damages when such nonparties are identified.” Plaintiffs counsel should take affirmative action to combat such tactics — by forcing defense counsel to disclose the name of any nonparties or forfeit the nonparty defense.

Indiana’s Comparative Fault Statute clearly requires that nonparties be specifically identified by proper name. A generic identification is not sufficient.

I.C. 34-4-33-6 provides that:

Sec. 6. The court shall furnish to the jury forms of verdicts that require only the disclosure of:

(1) the percentage of fault charged against each party and nonparty; and

(2) the amount of the verdict against each defendant.

If the evidence in the action is sufficient to support the charging of fault to a nonparty, the form of the verdict also shall require a disclosure of the name of the nonparty and the percentage of fault charged to the nonparty. [Emphasis added.]

In Cornell v. Harbison Excavating, Inc.⁽⁵⁾, the Indiana Supreme Court held that a Defendant pleading a nonparty defense under Indiana’s Comparative Fault Act must specifically name the nonparty. In addition, the Court held that a motion to strike is the appropriate mechanism for challenging a nonparty defense that fails to specifically name an alleged nonparty.

In Cornell, the Plaintiffs sued an excavating company, alleging that it had been negligent in the storage of drainage and sewer pipe which the Plaintiffs’ vehicle struck when it swerved into a ditch to avoid hitting a dog that had run into the roadway. In its Answer to the Plaintiffs’ Complaint, the excavating company named “the unknown owner of the dog” as a nonparty. The Plaintiffs filed a motion to strike that nonparty defense, asserting that in order to constitute a valid nonparty defense, the nonparty must be specifically named. The trial court granted the Plaintiffs’ motion to strike and the Defendant appealed. Both the Indiana Court of Appeals and Supreme Court affirmed the trial court’s ruling.

In its opinion, the Supreme Court stated:

Legislative intent is foremost in construing any statute. Eilbacher, Comparative Fault and the Nonparty Tortfeasor, 17 Ind.L.Rev. 903, 924. These statutes as presently written, coupled with their legislative history, clearly evidence the legislature’s intent to place the burden of pleading and proving the specific name of the nonparty on the defendant. Thus, by clear implication, the legislature intended that a claimant’s recovery is not to be diminished by the percentage of fault of unidentified nonparties.

The thrust of the amendment [the present Ind.Code Sec. 34-4-33-5(a)(1)] is that in order for a culpable nonparty to be assigned fault by the trier of fact, such person must be subject to liability by civil action. Id. This amendment illustrates the legislature’s intention that a culpable nonparty cannot be assigned fault unless the nonparty is subject to civil liability in some forum. Id. An unidentified nonparty is not subject to liability.

In Eilbacher, supra, the writer commented on our Act, opining, “[i]f defendant seeks to diminish his own contribution to damages by proof of fault of the nonparty, the defendant should offer the name of the nonparty tortfeasor. The Act sacrificed a true apportionment of damages among all tortfeasors in favor of maximizing recovery by the injured plaintiff where the nonparty cannot be identified.” Id. 530 N.E.2d at 773.

We concur with this view. Moreover, the plain meaning and clear language of section 6 unmistakenly require the disclosure of “the name of the nonparty”, not merely a generic identification. To hold otherwise would render meaningless the express statutory language.

We likewise concur with the determination of the Court of Appeals that a motion to strike pursuant to Ind.Trial Rule 12(F) was an appropriate mechanism to question a nonparty defense that failed to specifically name the alleged nonparty.⁽⁶⁾

* * * * * *

When Plaintiff’s counsel recieves an Answer which attempts to assert a nonparty defense, but fails to specifically name the nonparty, it is suggested that a letter such as the following be sent to the defense attorney:

September 9, 1996

Donald Black
600 Peoples Bank Building
136 East Market Street
Indianapolis, Indiana 46204

Re: Toni Vickery v. Max Carr
Marion County Superior Court No. 5
Cause No. 49D05-9605-CT-0478

Dear Don:

I have recieved the Answer which you have filed in the above-captioned matter. I note that as your sixth defense, you state:

“Plaintiff’s alleged damages, if any, were caused in full or in part by a nonparty.”

Don, I have a problem with this defense in that it does not specifically identify a nonparty by name. As you know, under Indiana’s Comparative Fault Act, a defendant is required to disclose the name of any alleged nonparty, rather than merely giving a generic identification. I enclose a copy of the Indiana Supreme Court’s decision in Cornell Harbison Excavating, Inc. v. May (1989), Ind., 546 N,E.2d 1186, for your reference in this regard.

As you are aware, the Court signed an Order on August 5, 1996, requiring the Defendant to name any nonparties on or before September 17, 1996. The purpose of that Order is to permit the Plaintiff to add (should it be appropriate) any nonparties as Defendants before the statute of limitations expires on October 7, 1996. However, the nonparty defense that you have asserted does not permit us to do that.

Please inform us immediately as to whether there are any actual nonparties in this matter. If there are no actual nonparties, please withdraw your nonparty defense before the expiration of the statute of limitations.

Sincerely,

SMITH TODD & FARRELL

_______________________
Teresa L. Todd

* * * * * *

When necessary, a Motion To Strike Nonparty Defense, supporting Memorandum, and Order, such as the following can be used:

IN THE MARION COUNTY SUPERIOR COURT NO.5
CIVIL DIVISION
STATE OF INDIANA

TONI VICKERY, Plaintiff
vs.
MAX CARR, Defendant.

CAUSE NO. 49D05-CT-0478

MOTION TO STRIKE NONPARTY DEFENSE

Comes now the Plaintiff, Toni Vickery, by counsel, and pursuant to Trial Rule 12(F) of the Indiana Rules of Trial Procedure, moves the Court for an Order, striking the following Affirmative Defense which appears in the Defendant’s Answer to the Plaintiff’s Complaint:

“6. The Plaintiff’s alleged damages, if any, were caused in full or in part by a nonparty.”

The basis for this Motion is that the Defendant has failed to disclose the proper name of the nonparty as required by I.C. 34-4-33-6 and the Indiana Supreme Court’s holding in Cornell Harbison Excavating, Inc. v. May (1989), Ind., 546 N.E.2d 1186.

______________________________
Ted Smith #394-48
Attorney for Plaintiff

* * * * * *

IN THE MARION COUNTY SUPERIOR COURT NO. 7

CIVIL DIVISION

STATE OF INDIANA

TONI VICKERY, Plaintiff,
vs.
MAX CARR, Defendant.

CAUSE NO. 49D07-9605-CT-0478

MEMORANDUM IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE NONPARTY DEFENSE

The law in Indiana is well-settled that a Defendant asserting a nonparty defense must specifically identify the alleged nonparty by name. A generic identification is not sufficient. I.C. 34-4-33-6 provides that:

Sec.6. The court shall furnish to the jury forms of verdicts that require only the disclosure of:

(1) the percentage of fault charged against each party and nonparty; and

(2) the amount of the verdict against each defendant.

In Cornell v. Harbison Excavating, Inc.⁽⁷⁾, the Indiana Supreme Court held that a Defendant pleading a nonparty defense under Indiana’s Comparative Fault Act must specifically name the nonparty. In addition, the Court held that a motion to strike is the appropriate mechanism for challenging a nonparty defense that fails to specifically name an alleged nonparty.

In its opinion, the Supreme Court stated:

In Kveton v. Siade (1990), Ind.App., 562 N.E.2d 461, Allan Kveton made a claim for personal injuries which he sustained in an automobile collision with the Defendant. At the time of the crash, the Defendant was attempting to turn north onto Main Street in Elkhart, Indiana, from a private driveway. To do so, she had to make a left turn and cross two lanes of southbound traffic. According to the Defendant, a man driving a green pick-up truck approached in the right southbound lane and stopped to allow her room to cross the southbound lanes in front of him. He then looked to his left to check for traffic approaching behind him, turned back, smiled, and motioned for the Defendant to proceed. When the Defendant pulled out onto Main Street, she collided with the Plaintiff’s car in the left southbound lane.

In her Answer to the Plaintiff’s Complaint, the Defendant asserted that the driver of the green pick-up truck was at least partly responsible for the Plaintiff’s injuries. However, the Defendant did not specify the name of the driver of the green pick-up. At trial, the court gave an instruction which advised the jury in part that it could ” … take into consideration the actions or omissions of any operator of a motor vehicle whose conduct, in your judgment, was the proximate cause of the aforesaid accident, whether that operator is a party to this action or not”. The Plaintiff appealed from the jury’s verdict in his favor, alleging that the trial court erred in giving that instruction in that it incorrectly stated the law in allowing the jury to consider the conduct of unnamed nonparties whose conduct may have been a proximate cause of the crash. The Court of Appeals agreed, and in its opinion stated:

By directing the jury’s attention to the unnamed nonparty’s actions and telling them that they might consider whether such actions were the proximate cause of the collision, the court was necessarily inviting them to determine the fault of an unnamed nonparty. That is precisely what the statute, as interpreted by Cornell Harbison, forbids. 562 N.E.2d 461, 464.

In the present case, the attempted naming of a nonparty by a generic identification only is improper and the nonparty defense asserted in the Defendant’s Answer to the Plaintiff’s Complaint should be striken.

__________________________________
Teresa L. Todd #1612-49
Attorney for Plaintiff

* * * * * *

IN THE MARION COUNTY SUPERIOR COURT NO. 7
CIVIL DIVISION
STATE OF INDIANA

TONI VICKERY, Plaintiff
vs.
MAX CARR, Defendant.

CAUSE NO. 49D07-9605-CT-0478

ORDER STRIKING NONPARTY DEFENSE

Comes now the Plaintiff, by counsel, and having filed her Motion To Strike Nonparty Defense, and the Court being duly advised in the premises, now finds that said Motion should be and hereby is GRANTED.

IT IS THEREFORE ORDERED, ADJUDGED AND DECREED that the nonparty defense asserted in rhetorical paragraph 6 of the Defendant’s Answer, to wit: “Plaintiff’s alledged damages, if any, were caused in full or in part by a nonparty”, is hereby striken, and the jury will not be permitted to consider the fault of any nonparties in this case.

___________________________________
The Honorable Gerald S. Zore, Judge
Marion County Superior Court No. 7

In cases governed by the Comparative Fault Act, Plaintiff’s counsel can obtain information relative to potential nonparty defenses and with regard to nonparty defenses that have been properly plead by a defendant who has specifically identified nonparties by name by tendering Interrogatories to the Defendant such as the following:

* * * * * *

IN THE MARION COUNTY SUPERIOR COURT NO. 1
CIVIL DIVISION
STATE OF INDIANA

STEVEN BARNES, Plaintiff,
vs.
RICHARD RHOADES, Defendant.

CAUSE NO. 49D01-9602-CT-2431

PLAINTIFF’S INTERROGATORIES TO THE DEFENDANT, RICHARD RHOADES

Comes now the Plaintiff, Steven Barnes, by counsel, and pursuant to Trial Rule 33 of the Indiana Rules of Trial Procedure, tenders the following Interrogatories to the Defendant, Richard Rhoades, to be answered under oath, fully and without evasion, within thirty (30) days.

INTERROGATORY NO. 1: Do you contend that the collision in which the Plaintiff and Defendant were involved was caused, in whole or in part, by any individuals or entities other than the Plaintiff or Defendant? If so, state:

a. The identity [that is, the name, home address, business address, home telephone number, business telephone number, employer and job title or position] of all such individuals or entities;

b. A detailed description of the conduct (all of the actions and/or inactions) of each individual or entity that you contend constitutes negligence or fault;

c. The sources of your knowledge with regard to that conduct;

d. An explanation of the way in which you contend that conduct caused or contributed to cause the collision in which the Plaintiff and Defendant were involved;

e. The percentages of fault that you contend should be attrributed to each individual or entity.

INTERROGATORY NO. 2: Do you contend that the actions or inactions of any individual or entity, whether a party to this lawsuit or not, caused or contributed to cause and/or aggravated or enhanced the injuries and damages for which the Plaintiff is seeking recovery in this case? If so, state:

a. The identity of all such individuals and/or entities;

b. A detailed description of all of the actions or inactions on the part of each such individual or entity that you allege caused, contributed to cause, aggravated or enhanced the Plaintiff’s injuries and/or damages;

c. A detailed description of the extent to which you contend each such individual or entity caused, contributed to cause, aggravated or enhanced the Plaintiff’s injuries and/or damages and a description of the way or manner in which each such action or inaction allegedly caused, contributed to cause, aggravated or enhanced the Plaintiff’s injuries and/or damages;

d. The name or title of any records or documents on which you rely for your contention or which you allege supports your contention or which reflects or relates to that contention in any way and a detailed description of the contents of all such records or docuements;

e. The identity of all individuals upon whose statements or opinions you rely for that contention or which you allege suports that contention or whom you expect to testify regarding that contention.

INTERROGATORY NO. 3: In the Fifth Affirmative Defense contained in your Answer to the Plaintiff’s Complaint, you allege that:

“The Plaintiff’s damages allegedly sustained were caused in whole or in part or were contributed to by reason of the negligence of a “nonparty”, to-wit: Trailmobile Corporation”.

With regard to this Affirmative Defense, please state:

a. The business address and telephone number for Trailmobile Corporation and the name of its highest ranking officer;

b. The name and address of Trailmobile’s resident agent in Indiana;

c. The nature of Trailmobile’s business;

d. A detailed description of all of the actions and/or inactions of Trailmobile Corporation that you contend constitutes fault which proximately caused or contributed to cause the collision in which the Plaintiff and Defendant were involved;

e. A detailed description of all of the actions and/or inactions of Trailmobile Corporation that you contend constitutes fault which proximately caused or contributed to cause the injuries and damages for which the Plaintiff is seeking recovery in this case or which you allege enhanced or aggravated those injuries and damages; and, a detailed explanation of the manner in which and the degree or extent to which you contend the actions and/or inactions of Trailmobile Corportaion caused or contributed to cause the injuries and damages which the Plaintiff is claiming in this case and/or enhanced or aggravated those injuries and damages;

f. Identify each and every person who you contend can or will testify or who has any knowledge or information which supports your allegation that the Plaintiff’s injuries and damages were caused in whole or in part or contributed to, enhanced or aggravated by reason of the negligence or fault of Trailmobile Corporation; and describe in detail all information or knowledge which each person possesses;

g. Identify and describe each and every document and item of tangible evidence that you contend supports this Affirmative Defense; describe the information contained in each document or illustrated by each item of tangible evidence; and, identify the individual or entitiy who currently has possession, custody or control of each document or item of tangible evidence.

___________________________
Teresa L. Todd #1612-49
Attorney for Plaintiff

* * * * * *

As originally enacted, Indiana’s Comparative Fault statute defined a “nonparty” as “a person who is, or may be, liable to the claimant in part or in whole for the damages claimed but who has not been joined in the action as a defendant by the claimant. A nonparty shall not include the employer of the claimant.”⁽⁸⁾ In 1995, the Indiana legislature amended the Comparative Fault Act to define a nonparty as meaning “a person who caused or contributed to cause the alleged injury, death, or damage to property but who has not been joined in the action as a defendant”.⁽⁹⁾

After the Indiana Court of Appeals’ decision in Chestnut v. Roof⁽¹⁰⁾, it is now clear that all of the amendments to the Comparative Fault Act effected by House Bill 1741 (including the change in the definition of “nonparty”) apply only to causes of action that accrue on or after July 1, 1995. Therefore, many of the cases that are currently being litigated continue to be governed by the original definition of “nonparty”. However,

I.C. 34-4-33-6 was not amended and there is nothing to suggest that the amendment of the definition of “nonparty” changes the Supreme Court’s holding in Cornell Harbison Excavating, Inc. v. May⁽¹¹⁾, requiring that any nonparty be specifically identified by name.

Footnotes

I.C. 34-4-33-1 through I.C. 34-4-33-14.

2. I.C. 34-4-33-5(a)(1) and I.C. 34-4-33-5(b)(1).

3. I.C. 34-4-33-5(a)(3) and I.C. 34-4-33-(b)(3).

4. I.C. 34-4-33-5(a)(4) and I.C. 34-4-33-5(b)(4).

5. (1989), Ind., 546 N.E.2d 1186.

6. 546 N.E.2d 1186, 1187.

7. (1989), Ind., 546 N.E.2nd 1186.

8. I.C. 34-4-33-2(a).

9. I.C. 34-4-33-2(a)(2).

10. (1996), Ind.App., 665 N.E.2d 7.

11. Supra.

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