Alzubi v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs
[2021] FCCA 1629
•13 July 2021
FEDERAL CIRCUIT COURT OF AUSTRALIA
Alzubi v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 1629
File number(s): MLG 2353 of 2016 Judgment of: JUDGE LUCEV Date of judgment: 13 July 2021 Catchwords: MIGRATION – Judicial review – decision of Administrative Appeals Tribunal - Subclass 572 Vocational Education and Training Sector visa
PRACTICE AND PROCEDURE – Extension of time – factors – whether substantial delay – whether explanation for delay satisfactory – whether prejudice – whether proposed grounds of review have merit
Legislation: Migration Act 1958 (Cth) ss 116, 476, 477
Migration Regulations 1994 (Cth) sch 8, cl 8202
Cases cited: ADN15 v Minister for Immigration and Border Protection [2016] FCA 810
AFP21 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 1322
Brisbane South Regional Health Authority v Taylor (1996) 186 CLR 541; (1996) 70 ALJR 866; (1996) 139 ALR 1
Duwai v Minister for Immigration and Border Protection [2014] FCA 1141
GEQ18 v Minister for Home Affairs [2019] FCCA 3338
Hunter Valley Developments Pty Ltd v Cohen (1984) 3 FCR 344; (1984) 58 ALR 305; (1984) 7 ALD 315
Jess v Scott (1986) 12 FCR 187; (1986) 70 ALR 185
Minister for Immigration & Multicultural Affairs v Yusuf [2001] HCA 30; (2001) 206 CLR 323; (2001) 75 ALJR 1105; (2001) 180 ALR 1; (2001) 62 ALD 225
Minister for Immigration and Citizenship v SZMDS [2010] HCA 16; (2010) 240 CLR 611
Minister for Immigration and Ethnic Affairs v Wu Shan Liang [1996] HCA 6; (1996) 185 CLR 259
Minister for Immigration and Multicultural Affairs v Eshetu [1999] HCA 21; (1999) 197 CLR 611
MZABP v Minister for Immigration and Border Protection [2015] FCA 1391; (2015) 242 FCR 585
MZABP v Minister for Immigration and Border Protection [2016] FCAFC 110; (2016) 152 ALD 478
MZZIV v Minister for Immigration & Border Protection [2013] FCA 1203
Re Commonwealth; Ex parte Marks [2000] HCA 67; (2000) 75 ALJR 470; (2000) 177 ALR 491
SZLIH v Minister for Immigration and Citizenship [2009] FCA 108
SZSDA v Minister for Immigration and Citizenship [2012] FCA 1319
SZTES v Minister for Immigration & Border Protection [2015] FCA 719
SZTES v Minister for Immigration & Border Protection [2015] FCAFC 158
Tran v Minister for Immigration and Border Protection [2014] FCA 533
WZAWB v Minister for Immigration & Anor [2016] FCCA 1345; (2016) 309 FLR 398
Number of paragraphs: 50 Date of last submission/s: 13 July 2021 Date of hearing: 13 July 2021 Place: Perth (with Microsoft Teams link to Melbourne) The Applicant: No appearance by or for the Applicant Counsel for the First Respondent: Mr Simpson Solicitor for the First Respondent: Clayton Utz The Second Respondent: Submitting appearances, save as to costs ORDERS
MLG 2353 of 2016 BETWEEN: HAMZA NASER AYED ALZUBI
Applicant
AND: MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTICULTURAL AFFAIRS
First Respondent
ADMINISTRATIVE APPEALS TRIBUNAL
Second Respondent
ORDER MADE BY:
JUDGE LUCEV
DATE OF ORDER:
13 JULY 2021
THE COURT ORDERS THAT:
1.The Extension of Time Application filed 28 October 2016 be dismissed.
2.The name of the First Respondent be amended to read “Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs”.
3.The Applicant pay the First Respondent’s costs in the sum of $3,737 by 13 August 2021.
REASONS FOR JUDGMENT
(Delivered ex tempore and revised from transcript)JUDGE LUCEV
On 28 October 2016 the applicant, Mr Hamza Naser Ayed Alzubi, (“Mr Alzubi”), lodged, in the Melbourne Registry of this Court, an extension of time application(“Extension of Time Application”) pursuant to s 477 of the Migration Act 1958 (Cth) (“Migration Act”), seeking an extension of time in which to file an application for judicial review (“Proposed Judicial Review Application”). The Proposed Judicial Review Application seeks review pursuant to s 476 of the Migration Act of a 2 September 2016 decision of the Administrative Appeals Tribunal (“Tribunal Decision” and “Tribunal” respectively), to affirm a decision of a delegate (“Delegate’s Decision” and “Delegate” respectively) of the first respondent, the Minister for Immigration and Border Protection, now the Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs (“Minister”), to cancel Mr Alzubi’s Subclass 572 Vocational, Education and Training Sector visa under s 116(1)(b) of the Migration Act (“VETS Visa”).
It is necessary to say a little about the delay in this matter coming to hearing. As noted in [1], the matter was filed in the Melbourne Registry on 28 October 2016. As the Chief Judge of this Court observed in AFP21 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 1322 at [25] per Chief Judge Alstergren it is “common knowledge that the Melbourne Registry of this Court has a large backlog”. The position was seemingly much the same in November 2019 when it was said, on an application to transfer a matter from the Sydney Registry of the Court to the Melbourne Registry of the Court, that “Delays in the Melbourne Registry of this Court … would mean that it would be likely that the application would not be heard for some two to three years if transferred”: GEQ18 v Minister for Home Affairs [2019] FCCA 3338 at [7] per Judge Dowdy.
Exactly six months after the Extension of Time Application was filed the matter came on for a First Court Date on 28 April 2017, and a Registrar of this Court made the usual first orders in a migration proceeding by consent (“Registrar’s Orders”), including an order that the hearing of the matter be listed before Judge Kelly on 26 March 2019, that is almost twenty-three months later.
On 15 February 2019, and less than six weeks before the listed hearing, the parties were advised that the matter “must be vacated to a date to be advised” because of the “recent appointment of a judicial officer [not Judge Kelly before whom the matter was then listed] to another Court and the consequent need to reallocate other cases that have also been fixed for hearing”.
More than two years later, on 16 June 2021, a notice of listing was emailed to the parties from the Chambers of the Court’s National Migration Law Judge, Judge Kendall, relisting the matter for final hearing on 13 July 2021 (“Notice of Relisting”) before the Court as presently constituted sitting in Perth with a Microsoft Teams link to Melbourne.
When the matter was called in Melbourne today, there was no appearance by Mr Alzubi. The matter was then called outside the room in which the matter was listed in Melbourne, and again there was no appearance by Mr Alzubi. The Court took steps to endeavour to contact Mr Alzubi by way of telephoning the number listed on the Proposed Judicial Review Application for Mr Alzubi and, despite three endeavours to do so, no contact has been able to be made with him.
The Court is satisfied that the Notice of Relisting was sent to the notice of address for service listed on the Proposed Judicial Review Application, that being the only address for service notified to the Court by Mr Alzubi.
The grounds for Mr Alzubi’s Extension of Time Application are set out at paras [3] – [4] of Mr Alzubi’s Affidavit sworn 28 October 2016 (“Alzubi Affidavit”), and are as follows:
3.On 6 September 2016 I received an email from, Mr Nazim Al Bardo at Bardo Lawyers with a letter saying I had been refused from the AAT. He did not provide me with a copy of my decision, just the letter.
4. I went to see him after he sent me this email. He told me that to do the application to the court would be $3000. This was just to fill out the forms. He also told me that he needed another $15000 - $20000 for the court to run the case. I could not afford this. I went to another migration agent after this. However, this agent could not help because she said that I needed a lawyer. She referred me to another lawyer who I met for the first time on 12 Oct 2016. It was at this appointment that I was first advised that I had 35 days to appeal the decision and that this deadline had past. I was never informed prior to this that I need to lodge a application within 35 days.
The Proposed Judicial Review Application is presently incompetent by virtue of s 477(1) of the Migration Act, and remains so unless the Court grants an extension of time pursuant to s 477(2) of the Migration Act, which provides as follows:
(2) The Federal Circuit Court may, by order, extend that 35 day period as the Federal Circuit Court considers appropriate if:
(a) an application for that order has been made in writing to the Federal Circuit Court specifying why the applicant considers that it is necessary in the interests of the administration of justice to make the order; and
(b) the Federal Circuit Court is satisfied that it is necessary in the interests of the administration of justice to make the order.
In considering the law with respect to delay in making an application for judicial review under the Migration Act, regard must be had to the judgments of the High Court in Re Commonwealth; Ex parte Marks [2000] HCA 67; (2000) 75 ALJR 470; (2000) 177 ALR 491 (“Marks”) and Brisbane South Regional Health Authority v Taylor (1996) 186 CLR 541; (1996) 70 ALJR 866; (1996) 139 ALR 1 (“Brisbane South Regional Health Authority”), which, in summary, provide as follows:
(a)a limitation period is the general rule and an extension provision is the exception to it: Brisbane South Regional Health Authority CLR at 553 per McHugh J;
(b)the limitation period represents Parliament’s judgment as to how the welfare of society is best served by causes of action being litigated within a limitation period: Brisbane South Regional Health Authority CLR at 553 per McHugh J;
(c)where a significant period of time has elapsed, and in all but very exceptional cases, the limitation period should be “rigidly applied”: Marks at [16] per McHugh J; and
(d)the effect of the limitation period is such that it “may often result in a good cause of action being defeated.”: Brisbane South Regional Health Authority CLR at 553 per McHugh J.
With the above statements of principle in mind, the factors the Court generally takes into account when determining whether to grant an extension of time, pursuant to s 477(2) of the Migration Act are well-established, but not closed, and can be summarised as follows:
(a)the extent of the delay;
(b)the explanation for the delay;
(c)any prejudice that may be suffered; and
(d)the merits of the Proposed Judicial Review Application,
see Hunter Valley Developments Pty Ltd v Cohen (1984) 3 FCR 344; (1984) 58 ALR 305; (1984) 7 ALD 315.
In relation to delay, generally, “the longer the delay the more persuasive the explanation needs to be”: Tran v Minister for Immigration and Border Protection [2014] FCA 533 at [38] per Wigney J; see also Jess v Scott (1986) 12 FCR 187; (1986) 70 ALR 185; FCR at 195 per Lockhart, Sheppard and Burchett JJ.
In this case the delay of 18 days is not long and probably not of itself long enough to weigh to any significant degree against the grant of an extension of time.
To the extent that it can be gleaned from the Alzubi Affidavit, Mr Alzubi’s explanation for the delay relevantly appears to rely on his not having been advised by any of his then advisors of the 35-day time limit until two days after that time limit had expired. That, however, does not explain the subsequent 16-day delay before the Extension of Time Application was ultimately filed. There is no explanation for that delay in the Alzubi Affidavit.
It is well-established that an applicant, here Mr Alzubi, has the onus of making proper inquiries and taking reasonable action to ascertain whether he could challenge the Tribunal Decision as to any applicable time limit: SZLIH v Minister for Immigration and Citizenship [2009] FCA 108 at [33] per Cowdroy J; SZSDA v Minister for Immigration and Citizenship [2012] FCA 1319 at [38] per Foster J; Duwai v Minister for Immigration and Border Protection [2014] FCA 1141 at [7] per Edmonds J.
The Court notes that Mr Alzubi is a native Arabic speaker and has been in Australia since at least 2014 and, seemingly, living in the community in New South Wales and Victoria during that time: CB 117. In the present circumstances, with Mr Alzubi not having appeared for this hearing, there is nothing in those matters which suggests to the Court that, in this case, those matters would have materially contributed to the relevant delay: see ADN15 v Minister for Immigration and Border Protection [2016] FCA 810 at [29] per Charlesworth J.
The Court finds that Mr Alzubi’s explanation for the delay is not satisfactory and weighs against an extension of time being granted.
The Minister submitted that no prejudice would be suffered by him if Mr Alzubi is granted an extension of time. The Court notes this submission, but also notes that, based on usual principles in relation to extension of time applications, there may have been some prejudice to the Minister because the Minister had lost a vested right to retain the benefit of the Tribunal Decision on the expiry of the time limitation under s 477(1) of the Migration Act: Marks at [17] per McHugh J. As the Court observed in WZAWB v Minister for Immigration & Anor [2016] FCCA 1345; (2016) 309 FLR 398 at [109] per Judge Lucev:
There must be some prejudice arising from the fact that this is a case in respect of which the Minister might rightfully have thought that the litigation was at an end by reason of the extraordinary length of the delay in making the application. In traditional terms, the Minister is prejudiced by reason of the fact that he was entitled to consider that the fruits of the litigation were his. In those circumstances, there is additional prejudice by reason of the costs incurred as a consequence of this application.
The Court notes that this is not a case of extraordinary delay, but nevertheless, the Minister would have been entitled to consider that the fruits of the litigation were his.
In the present case prejudice is a factor which weighs, in the Court’s view, albeit slightly, against a grant of an extension of time, notwithstanding that the Minister asserts that there is no prejudice.
In determining whether the merits of the Proposed Judicial Review Application are arguable or have reasonable prospects of success, it is not necessary for Mr Alzubi to positively establish that the Proposed Judicial Review Application will succeed at final hearing: SZTES v Minister for Immigration & Border Protection [2015] FCA 719 at [48] and [102] per Wigney J (“SZTES”) (from which an appeal was dismissed: SZTES v Minister for Immigration & Border Protection [2015] FCAFC 158), but it will rarely be in the interests of the administration of justice, or the interests of justice, to extend time to file an application which has little or no prospect of success: MZZIV v Minister for Immigration & Border Protection [2013] FCA 1203 at [6] per Mortimer J.
In determining whether the grounds of review are arguable, reasonably arguable, or have reasonable prospects of success the Court is only required to deal with the grounds of review, and to examine them, in a reasonably impressionistic manner, and without the full consideration of all of the arguments which would be necessary upon a consideration of the merit of each of the grounds of review, the issue being not whether Mr Alzubi would be successful in the ultimate outcome, but whether an extension of time ought to be granted because an impressionistic, and necessarily preliminary examination of the grounds of review, reveals that the grounds of review, or any of them, might be arguable, reasonably arguable, or have a reasonable prospect of success, if fully examined as to their or its merit: SZTES at [48] per Wigney J; MZABP v Minister for Immigration and Border Protection [2015] FCA 1391; (2015) 242 FCR 585 at [62] per Mortimer J (in a passage expressly approved by the Full Court of the Federal Court in MZABP v Minister for Immigration and Border Protection [2016] FCAFC 110; (2016) 152 ALD 478 at [38] per Tracey, Perry and Charlesworth JJ).
The Tribunal Decision may be set aside on judicial review on the basis of jurisdictional error in relation to a decision exceeding jurisdiction, or a failure to exercise authority or powers given to the Tribunal under the Migration Act: Minister for Immigration & Multicultural Affairs v Yusuf [2001] HCA 30; (2001) 206 CLR 323; (2001) 75 ALJR 1105; (2001) 180 ALR 1; (2001) 62 ALD 225 (“Yusuf”) at [82] per McHugh, Gummow and Hayne JJ. In certain circumstances, a denial of procedural fairness may constitute jurisdictional error: SZBEL at [32] and [33] per Gleeson CJ and Kirby, Hayne, Callinan and Heydon JJ.
The Proposed Judicial Review Application contains the following grounds of review:
1.The Tribunal made a jurisdictional error.
2.The Tribunal error of law.
It can be assumed that ground 2 is intended to read, “The Tribunal made an error of law”.
The third paragraph under the grounds of application indicated that “Further particulars [are] to be provided”, but no such particulars have been provided.
Mr Alzubi, as a consequence of his non-appearance, made no submissions at hearing and the Court also notes that he failed to file written submissions in accordance with the Registrar’s Orders.
The Minister opposes the Extension of Time Application primarily on the basis that the two unparticularised putative grounds of review lack any merit whatsoever.
Neither ground of review is particularised. The Court, therefore, turns to the Tribunal Decision itself to determine if the Tribunal Decision is affected by the error alleged in the unparticularised grounds.
In the Tribunal Decision, the Tribunal notes that Mr Alzubi appeared before the Tribunal to give evidence and present arguments and was represented in relation to the review by his registered migration agent: at [3] of the Tribunal Decision, CB 116. On that basis, it appears, at least prima facie, that there can have been no denial of procedural fairness, in a hearing sense at least.
The Tribunal went on at [5] to correctly identify the issue as being whether Mr Alzubi, as the holder of a class of student visa, had breached cl 8202 (“Condition 8202”) of sch 8 to the Migration Regulations 1994 (Cth) (“Migration Regulations”) and whether, if Mr Alzubi had breached Condition 8202, the discretion to cancel the VETS Visa had been enlivened under s 116(1) of the Migration Act: CB 116.
The Court also dealt with and identified the requirements in Condition 8202 at [6] of the Tribunal Decision, most relevantly, as to whether Mr Alzubi had been enrolled in a registered course of study or training and went on, at [7], to observe that the VETS Visa had been cancelled on the basis that Mr Alzubi was not enrolled in a registered course: CB 116.
The Tribunal Decision at [8] acknowledges that the Mr Alzubi’s agent had indicated to the Tribunal that Mr Alzubi acknowledged that there was a ground to cancel the VETS Visa seemingly on the basis of non-enrolment: CB 116. The Tribunal then sets out the circumstances pertinent to Mr Alzubi’s non-enrolment and the facts that led to the non-enrolment breach of Condition 8202: CB 116.
The Tribunal then turned to the question of the discretion to cancel the VETS Visa and noted Mr Alzubi had not re-enrolled following a dispute over a sum of $500 in relation to enrolment fees with his original course provider: Tribunal Decision at [9], CB 117.
The Tribunal at [10] set out Mr Alzubi’s original enrolment in a course in Sydney, in an ELICOS course, his return to Jordan early in 2015 and then his return to Sydney in February 2015 after his trip to Jordan. The Tribunal noted that Mr Alzubi had stated that he went to many different education providers in relation to commencing a new course because he felt that he had been “ripped off” by being required to pay the additional $500 in relation to his enrolment at the first college that he attended in Sydney. The Tribunal further noted that it provided additional time for Mr Alzubi to provide evidence of his seeking other enrolments but that he ultimately only provided one such example: Tribunal Decision at [10], CB 117.
The Tribunal at [12] noted that Mr Alzubi asked for further time to provide post-hearing submissions and documents and that the Tribunal provided that time but Mr Alzubi only provided one additional document relating to enrolment in a course, and that no international documents were provided by Mr Alzubi, the provision of international documents having been the original context in which the additional time had been asked for: CB 117.
The Tribunal noted that Mr Alzubi acknowledged that he was not enrolled in a registered course and that he had not been enrolled in a registered course since 1 March 2015, and that he had not enrolled in a further course up until the time that his VETS Visa was cancelled on 6 October 2015, and that he had not studied in Australia since January 2015 when he left to see his mother in Jordan; his mother apparently being unwell: Tribunal Decision at [12], CB 117.
The Tribunal then went on to consider in more detail the question of the discretion to cancel the VETS Visa. It noted that it had regard to the matters raised by Mr Alzubi as to why the VETS Visa should not be cancelled and also to the government policy guidelines contained in the Department’s Procedure Advice Manual (“PAM3”).
The Tribunal noted that Mr Alzubi had had a dispute with his original education provider over what it described as a relatively small sum of $500 to be paid: Tribunal Decision at [17], CB 118. The Tribunal went on to note that that was unusual and questioned why Mr Alzubi would jeopardise his education in Australia over such an amount of money and noted, again, that Mr Alzubi felt that he had been “ripped off”: Tribunal Decision at [17], CB 118.
The Tribunal at [18] noted that Mr Alzubi claimed to have sought other opportunities to enrol with other providers but that he had not been permitted to do so because he did not have a release letter from his original education provider, and that that provider would not provide him with a release letter because he had not paid the disputed $500. The Tribunal then noted that, in any event, Mr Alzubi had only provided one example of an attempt to find a new education provider, and that example was in 2015 before he moved to Melbourne in August 2015: Tribunal Decision at [18], CB 118.
The Tribunal at [19] concluded that it did not accept Mr Alzubi’s explanation for his failure to enrol and study for the extended period of time, noting that he did not pay the $500 for the release letter from his original education provider despite being aware that that would entitle him to gain an enrolment elsewhere. The Tribunal further noted that that was a choice that Mr Alzubi made of his own volition and that Mr Alzubi had not been studying elsewhere since early 2015: Tribunal Decision at [19], CB 118. The Tribunal observed that although Mr Alzubi claimed to have come to Australia with the sole intention of studying, his actions were the opposite. The Tribunal found that had Mr Alzubi intended to study, he would not have spent only three months at a college, entered into a dispute over the amount of money for his fees, and then chosen not to study again. The Tribunal concluded, in that regard, that Mr Alzubi was not a genuine student in Australia: Tribunal Decision at [19], CB 118.
The Tribunal noted Mr Alzubi’s personal circumstances, including the fact that his mother was unwell and that he had to return to Jordan, but noted that his mother had actually been unwell, according to medical reports provided, prior to the time that Mr Alzubi had left to study in Australia. The Tribunal, therefore, did not accept that his concern for his mother’s health would lead Mr Alzubi not to be able to enrol in a course of study for such an extended period of time whilst remaining in Australia: Tribunal Decision at [20]-[22], CB 119.
The Tribunal also referred to an argument that if Mr Alzubi were to return home to Jordan without completing a qualification, that he would be disowned by his family and that his parents wanted him to complete his studies in Australia. The Tribunal, in that regard, noted that Mr Alzubi’s parents had continued to support him financially whilst in Australia, even when he was not studying, and the Tribunal concluded that, although the family might be disappointed, the family knew of the migration issues and continued to support him financially. The Tribunal did not accept that that was the action of a family ashamed or willing to disown him because he had not completed his qualifications in Australia and considered that Mr Alzubi’s family would continue to support him on return to Jordan, including in studies at a Jordanian university: Tribunal Decision at [23]-[24], CB 119.
The Tribunal noted that there were no international obligations relevant to Mr Alzubi’s circumstances: Tribunal Decision at [24], CB 119.
The Tribunal at [27] affirmed the Delegate’s Decision to cancel Mr Alzubi’s VETS visa: CB 120.
Thus, in considering whether to exercise its discretion to cancel the VETS visa, the Tribunal dealt with each substantial argument made by Mr Alzubi as to why the discretion should be exercised in his favour. Further, it correctly interpreted and applied the relevant provisions of the Migration Act and Migration Regulations and made findings which were open to it (for the reasons it gave) and which were reasonable and rational in the circumstances: Minister for Immigration and Ethnic Affairs v Wu Shan Liang [1996] HCA 6; (1996) 185 CLR 259; Minister for Immigration and Multicultural Affairs v Eshetu [1999] HCA 21; (1999) 197 CLR 611; Minister for Immigration and Citizenship v SZMDS [2010] HCA 16; (2010) 240 CLR 611.
There is nothing in the Tribunal Decision, or the other material before the Court, that suggests that the Tribunal made an error of law or a jurisdictional error in considering Mr Alzubi’s arguments in making the Tribunal Decision. As set out above, the Tribunal considered and rejected Mr Alzubi’s arguments as to why the discretion not to cancel the VETS Visa should be exercised in his favour.
Accordingly, there is nothing to suggest that the Tribunal made a jurisdictional error, and the Tribunal Decision is a privative clause decision. It follows that, on a broad overview and consideration of the Tribunal Decision, Mr Alzubi has insufficient prospects of success to warrant an extension of time being granted to bring the Proposed Judicial Review Proceedings.
For those reasons, the Court has concluded that the grounds of the Proposed Judicial Review Application do not have sufficiently arguable merit to warrant the grant of the extension of time application.
Therefore, the Court has concluded that, on balance, even where the length of the delay does not weigh against the grant of the Extension of Time Application, the effect of the consideration of the other factors to be considered in relation to the Extension of Time Application, including the want of a proper explanation for the delay, and the failure of Mr Alzubi to make out, at the requisite level, that the grounds of the Proposed Judicial Review Application, might give rise to any obviously discernible jurisdictional error and, therefore, are unlikely to have any reasonable prospect of success, means that the Court should not extend time for the making of the Proposed Judicial Review Application.
I certify that the preceding fifty (50) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Lucev. Associate:
Dated: 16 July 2021
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