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UKPC / SCS LAW Court Claim Form
Namiku
post Sat, 18 Aug 2018 - 22:07
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Good evening,

I hope you're all well. Been a while since I was last on here.

So some time ago around 1 AM the driver drove the keeper to hospital. Didn't think much about it at the time and just parked as close to the hospital on the main road.

There were some complications so the keeper had to be admitted to hospital. The driver went home around midday the next day and noticed there was a penalty on the windscreen.

After a few hours sleep the driver went back to the hospital and parked on the main road having forgotten about the penalty before. The driver came out late the same evening and saw another penalty on the windscreen. They were PPCs so we decided to ignore them.

During the time the keeper stayed in hospital we got about 6 in total. They sent chaser letters every few months and we just ignored them as per previous advice.

We've received a Claim Form (in keepers name) by the court from UKPC and SCS LAW and obviously cannot ignore this. No evidence has been given and it seems it will follow in 14 days as stated on the form.

All of the PPC and the claim forms are in keepers name. The keeper was obviously not driving as they were in hospital. Are we right in thinking that with the evidence of the keeper being in hospital and obviously not driving, and therefore not entered any contract with regards to parking, this is a pretty straightforward win for us?

We have been searching for cases where the defendant was not the driver however we cannot seem to get anything recent up.

Any help or pointing in the right direction is appreciated.

Thanks

** EDITED TO OBSCURE DETAILS **

This post has been edited by Namiku: Thu, 23 Aug 2018 - 13:26
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Namiku
post Fri, 24 Aug 2018 - 20:10
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QUOTE (ostell @ Fri, 24 Aug 2018 - 20:58) *
Was there a ticket on the windscreen? If not it would appear that the have not issued the PCNS within 14 days that are required to hold the keeper liable


Well we remember at least two tickets on the windscreen on the first night on separate occassions. From their pictures of my car on the NtKs it would appear that only one of the five has evidence that there was a ticket on the windscreen.

Also will they provide any evidence and at what stage so we can build the defence? They should surely be providing contracts, signs, evidence of contravention, all pictures etc. no?

On the particulars of claim there is nothing!

@Albert Ross what is up with the attachments?

Thanks

This post has been edited by Namiku: Fri, 24 Aug 2018 - 21:10
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Sheffield Dave
post Fri, 24 Aug 2018 - 20:48
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Did the number of PCNs exactly match the number of parking events - or did you sometimes get multiple tickets for a single period of parking? And if so, what do the signs say - e.g. do they mention 'per 24H period'? For that matter, were the signs forbidding, e.g. "permit holder only"?

The doubling to £120 is probably them adding on a fictional £60 debt collection fee, which they certainly can't do if they're claiming against the keeper rather than the driver.

If they were putting Notices to Driver on the windscreen, did the later postal Notices to Keeper each arrive within 29-56 days of the parkng event?

Don't expect or rely on getting any good quality documents from them before your defence is due to be submitted.
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Namiku
post Fri, 24 Aug 2018 - 21:25
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I believe the number of PPC matched the parking events. If anything we didn't get a ticket for some as there were probably no patrols some nights.

The NtK have been received within the 29-56 days.

We will check the signs this weekend and post them up.

[ One thing about the signs, they have been there since 2012 I believe with no change, or at least there was no change from 2012 - 2017 will check if still the same this weekend. ]

Without providing any sort of evidence and if the facts of the case aren't how is the defendant supposed to submit a defence? They can't jsut withhold evidence if they plan to have a hearing? The judge surely wouldn't allow it!

This post has been edited by Namiku: Fri, 24 Aug 2018 - 21:30
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Redivi
post Sat, 25 Aug 2018 - 00:38
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You make the first point of the defence that the claim fails to disclose any cause of action and invite the court to strike it out or order Further and Better Particulars of Claim

You can still use the points :

Legal capacity to bring the claim
Failure to follow POFA
Failure to follow Govt instructions on hospital parking
Inadequate signs
Costs not incurred
Even if incurred are none of your concern
Beavis doesn't apply
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nosferatu1001
post Mon, 27 Aug 2018 - 00:07
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They're supposed to engage I; the PAP and send documents, but there hasn't yet been a claim where a failure to do so has cost the ppc.
If you read up on the process instead of pontificating you would see that evidence will be submitted by them a lot further down the line
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Namiku
post Tue, 11 Sep 2018 - 15:26
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Hello everyone,

An issue came up and was fully invested so couldn't deal with this. Apologies for the delay.

Here is the current signage:









And the below is old signage from the time of the original charges which is similar to the fourth sign just above:



According to google streetview the signs have been changed some time between May 2017 and Present

Thanks for your time everyone.

This post has been edited by Namiku: Tue, 11 Sep 2018 - 15:29
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nosferatu1001
post Tue, 11 Sep 2018 - 22:35
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Show us your defence ASAP. You're running a clock that isn't stopping.

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Namiku
post Mon, 17 Sep 2018 - 22:43
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I HAVE COME UP WITH THE BELOW AND MADE IT AS RELEVANT AS POSSIBLE TO ME BY RESEARCHING DIFFERENT FORUMS DEFENCES ETC. DONT CRUCIFY ME I HAVE NO IDEA WHAT I'M DOING : BangHead.gif

IN THE COUNTY COURT
CLAIM No: CXXXXXX
BETWEEN:
UK Parking Control LTD (Claimant)
-and-
namiku (Defendant)
________________________________________
DEFENCE STATEMENT
________________________________________
STATEMENT OF DEFENCE
1. I am the defendant in this matter.

2. It is admitted that the Defendant is the registered keeper of the vehicle in question. However, the Defendant was not the driver and for the reasons stated below and denies that she is liable to the Claimant either as alleged in the Particulars of Claim or at all. Each and every allegation in the Particulars of Claim is denied.

3. The Claimant has no cause of action against the Defendant on the following grounds:
Non-disclosure of reasonable grounds or particulars for bringing a claim

5. The Claimant has not complied with the pre-court protocol and has not disclosed reasonable grounds for bringing a claim.

6. There was no compliant “Letter Before Court Claim”, under the Practice Direction, meaning the Defendant could not compile a Formal Response.

7. The Particulars of Claim fail to fulfil CPR Part 16.4 because it does not include a statement of the facts on which the claimant relies, only referring to a Parking Charge Notices with no further description; it fails to establish a cause of action which would enable the Defendant to prepare a specific defence and it does not include any evidence of the claimants legal capacity to bring the claim or evidence of the listed contraventions:
‘-- DATE – DESCRIPTION -- AMOUNT --DUE DATE
XX/XX/XX /PCN £120 XX/XX/XX
AND THE CLAIMANT CLAIMS
The Claimant claims the sum of £600.00 for Parking charges and costs if applicable. Total debt £600.

8. The Particulars of Claim provide no evidence to support the contraventions. They do not mention what the original charge was, what the alleged contract was, what legal capacity the claimant has to bring a claim and evidence of this, nor anything which could be considered a fair exchange of information. The Defendant has therefore had to cover all possible defences, causing significant distress and denying a fair chance to defend the claim. The Claimant's solicitor is known to be a serial issuer of particulars of claim which arise from an automated template, with no due diligence. The Defendant argues that the Claimant's conduct in pursing consumers through the small claims track, using an automated system is against the public interest and not something the courts should be seen to support.

9. The Defendant invites the court to strike out or dismiss the claim under Rule 3.4(2)(a) of PRACTICE DIRECTION 3A as having not set out a concise statement of the nature of the claim or disclosed reasonable grounds or particulars for bringing a claim (Part 16.4(1)(a) and PRACTICE DIRECTION 16 paragraphs 3.1-3.8). In C3GF84Y (Mason, Plymouth County Court), the judge struck out the claim brought by KBT Cornwall Ltd as Solicitors of a private parking company had not submitted proper Particulars of Claim, and similar reasons were cited by District Judge Cross of St Albans County Court on 20/09/16 where a claim was struck out without a hearing, due to solicitors of parking charge companies template particulars being incoherent, failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''. The Practice Direction also sets out the following example which is analogous to this claim: ‘those which set out no facts indicating what the claim is about, for example ‘Money owed £5000’.’

Failure to comply with the procedural requirements of POFA 2012

10. No evidence has been supplied by the Claimant as to who parked the vehicle. The Defendant was admitted in hospital prior to these charges arising as will be evidenced from medical records and could not possibly have been driving, parking, or in any way shape or form agree to any terms of such parking.

11. Keeper liability has not passed in accordance with Protection of Freedoms Act 2012 Schedule 4 (also referred to as PoFA). For the Claimant to recover the parking charge from the Defendant, the Claimant must have followed the strict requirements in the PoFA 2012 Schedule 4, which provides that liability can be transferred from driver to keeper. The Claimant has failed to meet the conditions of the Act and has never acquired any right to pursue the Defendant in this capacity if it cannot identify the driver. This distinguishes the case from Elliott v Loake [1982] in which there was irrefutable evidence of the driver’s identity. PoFA 2012 Schedule 4 has not been complied with and the claimant may not quote reasonable assumption. In the case of Excel v Mr L. (17/11/2016, Skipton), the judge dismissed the claim, summing up that: ether the claimant could prove the defendant was the driver, which they could not; or the claimant could comply with PoFA to pursue the defendant as the keeper, which it was proved they did not. In POPLA’s ‘Annual Report of the Lead Adjudicator 2015’, on ‘Understanding Keeper Liability’, the expert opinion of PATAS and POPLA Lead Adjudicator and barrister, Henry Michael Greenslade, was that:
‘However keeper information is obtained, there is no ‘reasonable presumption’ in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Further, a failure by the recipient of a notice issued under Schedule 4 to name the driver, does not of itself mean that the recipient has accepted that they were the driver at the material time. Unlike, for example, a Notice of Intended Prosecution where details of the driver of a vehicle must be supplied when requested by the police, pursuant to Section 172 of the Road Traffic Act 1988, a keeper sent a Schedule 4 notice has no legal obligation to name the driver. Any evidence in this regard may therefore be highly relevant.’

12. Schedule 4 of PoFA also states that the maximum sum that may be recovered from the keeper under keeper liability is the amount specified on the notice to keeper. None of the sums whether separately or jointly as a total correspond with the amounts on the notices to keeper therefore the claimant has failed to comply with the provisions. Therefore, the Defendant has no liability in law and the court is invited to strike out this claim with immediate effect.

13. Schedule 4 paragraphs 8 and 9 of the PoFA stipulate the mandatory information that must be included in the Notice to Keeper. If all this information is not present, then the Notice to Keeper is invalid.

14. A notice to keeper does not specify the period for which the car was parked despite this being one of the strict requirements. The car park allows for 30 minutes of FREE parking therefore as no period was specified it cannot be established whether any contravention in fact occurred. The Claimants failure to comply with the procedural requirements of POFA 2012 means that the registered keeper cannot be held to account for the alleged debt of the driver. Schedule 4 paragraphs 8(5) or 9(5) specify the time limits for serving a Notice to Keeper:
(Where a notice to driver (parking ticket) has been served) Not earlier than 28 days after, nor more than 56 days after, the service of that notice to driver; or where a notice to driver has not been served the notice to keeper must be served within 14 days.
The date of the alleged Parking Charge Notices are between 03/01/2016 and 06/01/2016; to comply the latest date of which the Notices to Keeper should have been sent would be between 28/02/2016 and 02/03/2016 if a notice to driver was issued and between 17/01/2016 and 20/01/2016. As no evidence whatsoever has been submitted by the claimant the defendant who has provided evidence that they were not the driver, cannot determine whether a notice to driver was issued at any point. If none was issued then the Notices to Keeper which are dated from 05/02/2016 and 11/02/2016 would be invalid. The defendant invites the court to thoroughly inspect any photographic evidence submitted by the claimant to determine whether a notice to driver was in fact issued as they have admitted that to their employees doctoring photos to legitimise charges and claims. If no notice to drivers was in fact issued then the Defendant has no liability in law and the court is invited to strike out this claim with immediate effect.

No contract on any terms

16. A contract was never formed. There was never a contractual relationship, whether categorised as a licence or some form of contractual permission, because the signage is not adequate especially since the area is the location of the maternity and A&E hospital grounds where most people would be expected to visiting in shock and distress. There are no illuminated signs entering the area on the main hospital road where the car was allegedly parked and there is a pay and display car park separated by arm barriers opposite. Failure to provide clear signage relating to charges and terms of parking invalidates any alleged contract between the claimant and the driver let alone the keeper.

Failure to comply with government guidelines for hospital parking

17. The Secretary of State for Health, the land owner, lays out the following principles on parking:
‘Additional charges should only be imposed where reasonable and should be waived when overstaying is beyond the driver’s control (eg when treatment takes longer than planned, or when staff are required to work beyond their scheduled shift).‘ The NHS trust, who is the land operator, was informed that the reason why the keeper was admitted to hospital was due to complications caused by an error on their staff’s part. They are still investigating and have not replied before the deadline on defence submission.

18. The Secretary of State for Health, also states:
‘Reasonable implementation of additional charges practice might include additional charges for people who do not have legitimate reasons for parking (eg commuters), or who persistently flout parking regulations (eg blocking entrances). A period of grace should normally be applied before a parking charge notice is issued.’ No period of grace or observation of the vehicle is mentioned in any notices to keeper or particulars of claim.

Locus standi

19. The Claimant has no standing to bring this claim, or in the alternative the doctrine of privity applies and the Claimant is not privy to a contract that is between the landowner and the driver. The proper Claimant is the landowner which is the Secretary of State for Health. The Claimant does not have a contract with the Secretary of State for Health and it is assumed but not evidenced that they would have one with the NHS trust who operates the land. By acting as agents of the land operator rather than the land owner their contract for parking services is therefore null and void. The Defendant has reasonable belief that a statutory assignment has not taken place, therefore per Viscount Haldane’s judgement in Dunlop Pneumatic Tyre Co Ltd v Selfridge & Co Ltd [1915] AC 847, the Claimant may only sue on the contract as an agent if consideration has been given by the landowner personally or through the Claimant acting as agent; no such consideration flows as the Claimant does not receive payment from the landowner to manage the site in the landowner’s commercial interest, does not receive any proceeds from the sale of tickets, and does not offer parking as consideration for the Defendant’s payment for a licence to park. The Claimant’s business model is solely driven by the recovery of penalty fees. Strict proof is required that there is an assignment of contractual rights leading from the landowner to UK Parking Control LTD. The Defendant has reasonable belief that the Claimant does not have the authority to issue charges on this land in their own name and that they have no locus standi to bring this case, per Tweddle v Atkinson [1861] 1B &S 393, as confirmed by the House of Lords in Dunlop Pneumatic Tyre Co Ltd v Selfridge & Co Ltd. The Defendant also has reasonable belief that the tests of enforceability for the Contracts (Rights of Third Parties) Act 1999 have not been met. The Claimant has failed to establish an express conferral pursuant to section 1(1)(a) and section 1(3), which requires precise terms which identify the Claimant, and which expressly state that the Claimant has the ‘right to enforce the contract’ or the ‘right to sue’, or even to demonstrate an implied conferral per section(1)(1)(b) and section 1(3), which requires a term to expressly confer a benefit on the Claimant and for the Claimant to be specifically named, noting that it is not a benefit if the Claimant’s position is merely improved if the contract is performed (A Burrows, ‘The Contracts (Right of Third Parties) Act 1999 and its implications for commercial contracts’ [2000] LMCLQ 540, 542-546). Furthermore as per Trendtex Trading Corporation v Credit Suisse [1982] AC 679, a mere right to sue for damages is not assignable unless the assignee has a genuine commercial interest in taking the assignment; and Lords Neuberger and Sumption’s judgement (at [28]), in Parking Eye Ltd v Beavis [2015] UKSC 67, shows that the Claimant does not have a wider legitimate interest extending beyond the prospect of damages, as their interest is only limited to the recovery of compensation for the alleged breach of contract, and no commercial interest has engaged as to the control of parking as the Defendant had paid for a licence to park.

Trespass

20. The Particulars of Claim are deficient in establishing whether the claim is brought in trespass. In the event that a trespass claim is brought by the Claimant , the Defendant has reasonable belief that the Claimant does not have a contractual or proprietary right to occupy or possess the site per Hill v Tupper [1863] 2 H & C 121; the landowner has not assigned rights to enable the Claimant to pursue a case under the tort of trespass. In any event, the Defendant’s sole liability would be damages in favour of the landowner. Per the Supreme Court in the case of Cavendish Square Holding BV v Talal El Makdessi and ParkingEye Ltd v Beavis [2015] UKSC 67 (the Beavis case), trespass is limited to the landowner themselves claiming for a nominal sum.

Applicability of ParkingEye Ltd v Beavis [2015] UKSC 67
21. The Claimant might argue that the Supreme Court’s landmark decision in the Beavis case is applicable.

22. This case is not supported by any similarity in the circumstances or signage. Mr Beavis refused to pay a charge of £85 for overstaying a permitted period of free parking in a car park at a retail park. The signs displaying this information were accepted to be large, prominent and legible. The notice stated ‘2 hour max stay… Failure to comply … will result in a Parking Charge of £85.’ Mr Beavis exceeded the time limit by one hour but declined to pay the charge and maintained the term which sought to impose the charge was an unfair term. The Beavis case does not assist the claimant and in fact, supports my defence.

The agreed damages clause is a penalty

23. The signage provides for a parking charge of £60 if the terms and conditions of parking are breached. The Claimant seeks £120 which is an extravagant and unconscionable penalty, and therefore an unrecoverable bare attempt at 'double recovery' which is a gross abuse of process.

24. In ParkingEye Ltd v Beavis the Supreme Court recast the test to be applied when seeking to distinguish a liquidated damages clause from a penalty clause. To engage a penalty the question was whether the relevant provision was “unconscionable” or “extravagant” (Lord Hodge at [221]). The full test was expounded by Lord Hodge (at [255]).

25. The Supreme Court was only prepared to accept a charge (£85) that was sufficient to act as a disincentive and that was worth collecting. The Supreme Court had previously stated that £135 would be unacceptable (ParkingEye v Somerfield). The charge to the Defendant of £120 is evidently extravagant and unconscionable in that it is disproportionate to the Claimant’s interest, and disproportionate to the highest level of damages that could possibly arise from the Defendant’s alleged breach of contract.

26. The Defendant therefore disputes the amount claimed, as it comprises excessive and non-contractual elements, and costs must be proved. With reference to paragraph 31, the Claimant claims a sum of £120 as a ‘parking charge’ (for which liability is denied), which includes £60 that the claimant has untruthfully presented as contractual charges, which amounts to double charging.
27. The Protection of Freedoms Act does not permit the Claimant to recover a sum greater than the parking charge before a Notice to Keeper is issued. In any event the Protection of Freedoms Act is clear that a vehicle keeper would only be liable for the amount of the penalty charge notice, and no further costs.

28. The Claimant has claimed legal representative’s cost on the claim form, despite being well aware that CPR 27.14 does not permit such charges to be recovered in the Small Claims Court. The Defendant also has the reasonable belief that the charges have not been invoiced and/or paid. The Defendant also has a good faith belief that due to the sparse particulars the cost claimed for filing the claim has not been incurred. This appears to be an attempt at double recovery as a way to inflate the value of the claim. The solicitor has been incompetent and is not due any monies. In the alternative, the Claimant is put to strict proof to show how this cost has been incurred.

29. The Defendant invites the court to strike out the claim for the above grounds or at the very least order better particulars and evidence from the claimant in order for the defence to be properly based on the facts of the case. The defendant invites the court to dismiss any evidence which the claimant wishes to rely on during the hearing if this is not disclosed to the defendant prior.

Statement of Truth

30. The defendant believes that the facts stated in this defence are true.

MUST BE SUBMITTED BY WEDNESDAY I BELIEVE BangHead.gif

This post has been edited by Namiku: Tue, 18 Sep 2018 - 08:16
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nosferatu1001
post Tue, 18 Sep 2018 - 07:40
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OK so what dont you understand?
Dont say "all of it" because for sure there will be some parts you do understand

Remember this is YOUR defence, YOU must be happy with it and *understand* it.
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Namiku
post Tue, 18 Sep 2018 - 08:21
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Well I have no experience so have just researched similar defences and copied what I thought was relevant to me. I need someone to look at at and give me some feedback, advice, any additions etc.

I wouldn't be here if I knew what I was doing.

I also want to add something about the costs and the claimant having to prove them but couldn't find the right thing.

Further on that I want to say something about the offer to pay with a discount that is 1. not available to the keeper and 2. this would constitute cost for the agent since they are willing to accept this payment initially so there is no justification to add another £30 on top just because the payment is not made within a select timeframe as that would be considered a fine?
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nosferatu1001
post Tue, 18 Sep 2018 - 10:25
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we know yo uhave no experience
What that doesnt mean is that you have no *understanding*. same as you dont expect to be able to understand how to drive a car without doing some work, you cannot understnad a defence without doing the work yourself.

Your last argument has no bearing/. Theyre not required to poffer a discount to the keeper, but under POFA they can only recover the amount on the origial parking notice, not any additional amounts.

So, I ask again

What parts of this defence DO you understand? There will be SOME elements. Dont expect us to exhaustively proof road a huge long defence when we dont even know what ytou dont understand.

This is a serious legal processs. Yo ucannot half arse it. you cannot wing it.
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Namiku
post Tue, 18 Sep 2018 - 15:05
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Since they have quite clearly failed to comply with PoFA can I just put that as an argument and win the case? Or is it that they can change the sum at a later stage to comply with PoFA?

This post has been edited by Namiku: Tue, 18 Sep 2018 - 15:06
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nosferatu1001
post Wed, 19 Sep 2018 - 07:51
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Failing to comply with POFA means the Keeper has no liability.
Trying to add unrecoverable sums means any reward should be reduced, IF they win.

You cannot just "put an argument and win the case". You put EVERY argument that applies.

You are assuming that courts run on black and white. They do NOT.

This post has been edited by nosferatu1001: Wed, 19 Sep 2018 - 07:52
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Namiku
post Wed, 19 Sep 2018 - 14:34
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Thanks defence submitted.
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