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This paper explores strong and weak consistency of M-estimators for non-identically distributed data, extending prior work. Emphasis is given to scenarios where data is viewed as a triangular array, which encompasses distributional regression models with non-random covariates. Primitive conditions are established for specific applications, such as estimation based on minimizing empirical proper scoring rules or conditional maximum likelihood. A key motivation is addressing challenges in extreme value statistics, where parameter-dependent supports can cause criterion functions to attain the value , hindering the application of existing theorems.

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