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'New' submenu in context menu for any package node is placed in lower part of the context menu. Why? I'd suppose that user will invoke New File wizard more on package node to create something there, because he'd suppose that it would automatically create the object in selected package. So it should be placed in the beginning of the list as it's in context menu for 'Source Packages' node or even project node itself.
See the spec.
Milan is asking why. So the reply is, because the spec was not implemented.
Verified in dev-200406230100.