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Rosen v. Montgomery County, Md., 121 F.3d 154 (4th Cir. 1997), “has been questioned by the Fourth Circuit.” Williams, 121 F. Supp. 3d at 366; see also id. at 367 (noting that the Fourth Circuit in . Seremeth. concluded that “the ADA applies to the investigations of criminal conduct” whether or not an arrest results). The court in ... ................
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