Exl19 v Minister for Immigration
[2020] FCCA 1255
•8 October 2020
FEDERAL CIRCUIT COURT OF AUSTRALIA
| EXL19 v MINISTER FOR IMMIGRATION & ANOR | [2020] FCCA 1255 |
| Catchwords: MIGRATION – Immigration Assessment Authority – application for a SHEV visa – application for an adjournment – whether the applicant was an unauthorised maritime arrival – whether a port is a proclaimed port, in respect of an area of waters within the Territory of Ashmore and Cartier islands – whether the Authority failed to follow procedures required by law – whether the Authority failed to consider real risk of harm – whether the Authority found the applicant not to be a ‘genuine’ Christian – whether the Authority misapplied s 5J(6) of the Migration Act 1958 (Cth) – whether there is jurisdictional error – no jurisdictional error made out – the application is dismissed – costs to be determined. |
| Legislation: Judiciary Act 1903 (Cth), ss.79 Federal Circuit Court Rules 2001 (Cth), r.7.01 Migration Act 1958 (Cth), ss.5, 5 AA, 5J, 66, 476, 484, Part 7 AA |
| Cases cited: Aon Risk Services v Australian National University (2009) 239 CLR 175 DBE17 v Commonwealth of Australia [2020] FCA 958 DGJ17 v Minister for Immigration and Anor [2020] FCCA 1606 FFZ18 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCCA 1 GGD18 v Minister for Home Affairs (No 3) [2019] FCCA 444 McHugh v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCA 416 Riva NSW Pty Ltd v Official Trustee in Bankruptcy [2017] FCA 188 |
| Applicant: | EXL19 |
| First Respondent: | MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTICULTRAL AFFAIRS |
| Second Respondent: | IMMIGRATION ASSESSMENT AUTHORITY |
| File Number: | SYG 3251 of 2019 |
| Judgment of: | Judge Humphreys |
| Hearing date: | 28 September 2020 |
| Date of Last Submission: | 28 September 2020 |
| Delivered at: | Parramatta |
| Delivered on: | 8 October 2020 |
REPRESENTATION
| Counsel for the Applicant: | Mr Williams |
| Counsel for the Respondents: | Mr Kaplan |
| Solicitors for the Respondents: | Mills Oakley |
ORDERS
The Application for an adjournment for leave to amend the Initiating Application is refused.
The Application for leave to amend the Grounds for Judicial Review is refused.
The matter will be administratively listed for a further hearing on the grounds contained within the original Initiating Application filed in the matter, at a time and date to be set and advised to parties.
Costs order is reserved.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT PARRAMATTA |
SYG 3251 of 2019
| EXL19 |
Applicant
And
| MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTILCULTURAL AFFAIRS |
First Respondent
| IMMIGRATION ASSESSMENT AUTHORITY |
Second Respondent
REASONS FOR JUDGMENT
Introduction
This judgement concerns an application by the applicant, for an adjournment of the proceedings, as well as leave to amend the Initiating Application in relation to the grounds relied upon for judicial review of the decision of the Immigration Assessment Authority (“the Authority”) dated 6 November 2019. That decision, affirmed the decision of the delegate of the Minister for Immigration (“the delegate”), not to grant the applicant a protection visa.
The applicant is a citizen of Iran. In in early 2013, the applicant started dating a divorced woman. The applicant claims he was the victim of blackmail, as a result of films and photographs being taken of him in a compromising situation with the woman. The applicant fears having been reported to authorities for immoral conduct.
The applicant left Iran and travelled to Malaysia and then on to Indonesia. The applicant paid a people smuggler for a place on a boat that was headed to Australia. That boat, known as SIEV751 began to take on water, it is alleged whilst in Indonesian territorial waters, approximately 67 nautical miles from Christmas Island. The applicant, along with a large number of other persons were rescued by Australian Naval warships on 16 July 2013. Regrettably, two passengers on the boat perished when it capsized. The applicant was taken to Christmas Island and arrived there on 17 July 2013 and was taken ashore.
It is common ground that the applicant was placed in immigration detention, as an unauthorised maritime arrival. The applicant remained in immigration detention initially at Christmas Island, until he was moved to Darwin. The applicant was released from immigration detention into the community on 4 September 2013.
On 13 June 2017, the applicant lodged an application for a Safe Haven Enterprise (Class XE) (subclass 790) (protection) visa. On 11 September 2019, the delegate refused to grant the applicant a protection visa. The applicant was referred to the Authority who affirmed the decision, to refuse the applicant a protection visa on 6 November 2019.
The applicant then sought judicial review of the Authority’s decision in this Court. In the applicant’s initiating application, the following orders were sought:
a. The first respondent (Minister) be ordered to produce the “Suspected Irregular Entry Vessel information report”, relating to the applicant’s entry in Australia, and then on a final basis;
b. Relief in the form of a Declaration, that the purported appointment of a port as a proclaimed port, in respect of an area waters within the Territory of Ashmore and Cartier islands, by notice published in the Commonwealth of Australia Gazette No. GN 3 on 23 January 2002, is invalid;
c. Relief in the form of a Declaration, that the purported appointment of a port as a proclaimed port, in respect of an area of waters within the Territory of Christmas Island, by notice published in the Commonwealth of Australia Gazette on 22 January 1981, is invalid;
d. Relief in the form of a Declaration, that the applicant was not “unauthorised maritime arrival” as defined in s 5AA of the Migration Act 1958 (Cth) (“the Act”) and therefore, was not an “fast track review” applicant as defined in s 5 of the Act;
e. Relief in the form of a Declaration, that the applicant was not notified of the decision by the delegate to the Minister made on 11 September 2019, pursuant to s 66 of the Act;
f. Relief in the form of a Writ of Certiorari, bringing the decision by the second respondent (the Authority) dated 6 November 2019 into this Court to be quashed;
g. Relief in the form of a Writ of Mandamus , directing the Administrative Appeals Tribunal, to re-determine the decision made by the Authority on 6 November 2019, according to law;
h. Relief in the form of a Writ of Prohibition, restraining the first respondent (Minister), or the Minister’s employees, officers, delegates or agents of the first respondent, from acting upon or giving effect to the decision made by the Authority, made on 6 November 2019;
i. Costs.
Grounds of Judicial Review
The grounds of judicial review are as follows:
a. The decision of the Authority was vitiated by jurisdictional error, as the applicant was not an “unauthorised maritime arrival”. The applicant claims he was first detained on board a vessel belonging to the Commonwealth, which is registered to Canberra in the Australian Capital Territory (“the Act”). The Act nor the vessel, were excised offshore places, as defined by s 5 of the Act. The applicant was firstly taken to Ashmore Reef and then to Christmas Island, neither of which were proclaimed ports. As a result, the applicant was not an unauthorised maritime arrival;
b. The Authority failed to consider the risk of harm faced by the applicant, as an apostate under Iran law and therefore constructively failed to review the applicant’s claims under the refugee and complimentary protection legislation;
c. There was insufficient logical or evidentiary basis for the Authority to find that the applicant was not a “genuine” Christian, after finding the applicant was baptised, attended bible classes and church services;
d. There is an insufficient logical or evidentiary basis for the Authority to conclude that the applicant was ignorant of the elements of an adherent to the religion might reasonably know regarding the refugee criterion;
e. The Authority misapplied s 5J(6) of the Act by finding the applicant’s political and social media activities in Australia, was for the purpose of strengthening his claims under the refugee criterion or alternatively, failed to consider the claims under the complimentary protection criterion;
f. The Authority misapplied s 5J(3)(i) of the Act, by finding the applicant should modify his behaviour, so as to avoid a real chance of persecution;
g. The Authority erred by failing to distinguish the applicants claims as a non-practising Muslim and apostate, under refugee criterion from the complimentary criterion pursuant to s 5J(6) of the Act.
On 22 January 2020, Registrar Cridland made orders for the preparation of the matter for hearing. At that stage, it was not anticipated that the matter would be listed till March 2021. Due to pandemic restrictions, in relation to personal appearances before the Court, on 17 April 2020, this Court made orders listing the matter for final hearing on 21 May 2020. This was on the basis that both parties were legally represented and the matter could proceed by way of a telephone hearing.
On 7 May 2020, the applicant filed a Notice of a Constitutional Matter and an Application in a Case, seeking production of the following by the first respondent:
The Suspected Irregular Entry Vessel Information report and any and all documents relevant to the applicant’s entry into Australia in 2013 and the decisions to detain the applicant in closed and open detention.
The Notice of a Constitutional Matter, repeated broadly the issues claimed in the applicant’s original Initiating Application.
In an affidavit dated 12 May 2020, Fardin Nikjoo, the then solicitor for the applicant, sought an adjournment of the final hearing of the matter to allow production by the first respondent of the SIEV report, as it was contended that it was relevant to the proposed two new grounds for review by the Court which included a Statement of Claim, for false imprisonment including damages and a claim for a Writ of Habeas Corpus, in that the decision of the Minister to detain the applicant in open and closed detention, was beyond power and invalid. Not surprisingly, the first respondent objected to leave being granted to amend the application to the Court to include the two new proposed grounds.
The Application in a Case was listed before the Court on 20 May 2020. Orders were made for the filing and serving of any Amended Application and any further evidence by the applicant and the first respondent, as well as the filing of written submissions by the applicant on or before 6 July 2020. The matter was listed to determine whether leave should be granted to add the proposed two new grounds of judicial review on 28 September 2020.
On 11 August 2020, the first respondent filed an Amended Response to the draft Amended Application filed on 3 June 2020. That response contended inter alia that:
a. The claim for damages for unlawful imprisonment was beyond the Court’s jurisdiction and therefore incompetent. The Court’s jurisdiction in relation to migration matters, is the same as that of the High Court under s 75(v) of the Constitution, pursuant to
s 476(1) of the Act. That grant of jurisdiction does not extend to the award of damages for unlawful imprisonment, but is limited to direct judicial review challenges of the validity of migration decisions;b. Further, the claim for damages for false imprisonment is out of time and statute-barred, under the limitations act of Western Australia and the Northern Territory or under s 79 of the Judiciary Act 1903 (Cth);
c. Further, the claim that the applicant had been unlawfully imprisoned in ‘community detention’ pursuant to s 197AB of the Act from 4 September 2013, cannot be maintained, as the applicant had produced no evidence to demonstrate he has been the subject of a determination under that provision. Instead, the applicant has held visas and has been a lawful non-citizen pursuant to those visas;
d. The application for judicial review of the decision to detain the applicant on 17 July 2013 has been made outside the time permitted by s 477(1) of the Act and no extension of time has been sought in writing (and any extension of time to do so will be opposed).
The applicant failed to comply with the order to serve any written submissions of no more than 15 pages on or before 6 July 2020. The first respondent filed written submissions on 11 August 2020, notwithstanding that the applicant had failed to file any written submissions.
The Court received a document entitled “The Applicants Outline of Oral Submissions” on the morning of Monday 28 September. The Court was informed that a copy had been provided to the first respondent’s Counsel on the Friday prior to the hearing. Notwithstanding the late provision of that document, Counsel for the first respondent indicated that they were ready and willing to proceed with the matter.
The Adjournment Application
Firstly, Counsel for the applicant indicated that he was seeking an adjournment of the hearing of the interlocutory application, for the amendment of grounds of the application. A lengthy affidavit was provided to the Court, sworn by the applicant on 21 September 2020. No objection was taken to that affidavit being read. The affidavit outlined the correspondence that had taken place between the solicitor for the applicant and first respondent. It also sought to lay blame on the solicitor for the applicant, for failing to apply for an urgent Directions Hearing, as requested by Counsel for the applicant.
It was further noted that on 17 July 2020, the solicitor for the applicant filed a Notice of Intention to Withdraw as the solicitor for the applicant, apparently without advising Counsel for the applicant. On 11 August 2020, the solicitor for the applicant withdrew from the matter. It is alleged that there were difficulties in either the applicant or Counsel for the applicant, who had now been engaged on a direct access basis, accessing the Commonwealth Courts Portal. In the written submissions, it was submitted that the applicant had been seriously jeopardised by the actions of his former solicitor and the first respondent to meet the timetable set by the Court.
Secondly, the applicant sought an adjournment so he could obtain advice and give instructions regarding an “opt out notice” he received from the firm of Maurice Blackburn Solicitors, the instructing firm for the plaintiff in DBE17 v Commonwealth of Australia [2020] FCA 958 (“DBE17”), that the applicant received on 25 September 2020. It is submitted that whether or not the applicant opts in or opts out of the proceedings in DBE17, will have implications for ground one and two of the further amended application and whether the applicant proceeds with grounds one to three of the amended statement of claim.
Third, assuming the applicant provides instructions to proceed with ground two of the further amended application and grounds one to three of the amended statement of claim, the applicant relies on the reasons of Mortimer J in DBE17, dismissing the Minister’s application to strike out the proceedings which argues the similar, if not the same grounds as ground two of the further amended application and grounds one to three of the amended statement of claim.
Fourth, the applicant seeks leave to file and serve a further subpoena on the first respondent, to produce the following documents:
a. any and all documents regarding the exercise of power by officers of the Commonwealth to “turn back” SIEV794 on or around 16 July 2016;
b. any and all documents regarding the exercise of power by officers of the Commonwealth regarding the “interdiction” of SIEV794 on or around 16 July 2013.
Fifth, the applicant seeks leave to file and serve a further amended application and an amended statement of claim. These amendments include an amendment to ground one to include a new sub-ground that the exercise of power by officers of the Commonwealth to “turn back” or “interdiction” SIEV794 on or around 16 July 2013, was contrary to law. Various arguments are put forward suggesting that the “turn back” or “interdiction” policy of the Australian government is contrary to Australian and international law.
It is further submitted that the applicant has been in “detention”, which has been arbitrary and indefinite since the 16 July 2013. This consisted of closed detention, commencing when the applicant was taken on board an Australian naval vessel following the sinking of SIEV794, until his release from closed detention into “open” detention, on 4 September 2013.
The applicant seeks orders for leave to further amend the application, together with an amended statement of claim and seeks leave to be granted to serve a subpoena producing the documents in relation to the powers of the Commonwealth to “turn back” and or “interdict” SIEV794.
In terms of the adjournment application, Counsel for the first respondent submitted that no explanation, let alone a satisfactory explanation, had been put to the Court as to why the application for an adjournment was being made so late. In terms of the material that was filed by the first respondent, it was submitted that it was either uncontentious or alternatively it sought to clarify from the first respondent’s point of view, for the benefit of the Court, what matters were taken issue with. It was submitted that the ‘opt out’ notice in relation to DBE17 was not a matter that was relevant to the proceedings currently before the Court, being a review of the Authority’s decision to refuse the applicant a protection visa.
It was submitted that the jurisdiction of this Court is conferred through s 476 of the Act and the Court has no jurisdiction to deal with damages for false imprisonment, or to issue a Writ of Habeas Corpus. This amounted to a collateral attack on the Authority’s decision, which the Court should not entertain. It was submitted that whether there was a ‘turn back” or “interdiction” of SIEV794, was of no utility to the issue before the Court, as the applicant became an unauthorised maritime arrival, as soon as he set foot on Christmas Island. The reasons for the basis of him being on Christmas Island was irrelevant.
Further, the applicant seeks an adjournment to plead malfeasance or mal-administration or negligence or false imprisonment of the applicant, which the Court has no jurisdiction to hear. If the applicant wishes to raise these issues, he should do so in another place, noting however, that the first respondent’s contention that the applicant is statute-barred from raising this issue.
Consideration of the Adjournment Application
This matter first came before the Court for hearing on 20 May 2020. The Court acknowledges that the hearing date was brought forward from that which had been previously set in 2021. The Court made detailed orders setting out the procedure to be followed, to prepare the matter for hearing in relation to the issue of whether or not leave should be granted to amend the application before the Court.
Notwithstanding these orders, a further application for an adjournment was made on the morning of the hearing, where leave to amend the initiating application was to be considered. The Court has set out above the material contained within the affidavit of the applicant, sworn on 21 September. The fact that there has been a falling out between the applicant, his solicitor and his counsel, is not a relevant matter in the Courts view that can be taken into account, in relation to the adjournment application. The fact of the matter is, the timetable set by the Court for the filing of documentation, was not complied with by the applicant.
The Court rejects the assertion made by the applicant, that the incapacity to comply with the timetable has been caused, in part, by the actions of the first respondent. All the first respondent has done, was file an amended response on 10 August 2020 and in the Courts view, an uncontentious affidavit which annexes a Notice of Detention directed to the applicant dated 2 August 2013 and a screenshot of a client search of the Department’s computer system, confirming that the applicant set foot at Christmas Island.
In seeking the adjournment, the applicant appears to seek to considerably widen the attack on his initial detention, by alleging false imprisonment and/or breaches of international and domestic law in the Commonwealth’s current policies, in relation to actions by authorities, in relation to attempts to enter the Australian migration zone, via sea.
There has been a period of some four months between the initial hearing in May 2020 and when this matter was listed for hearing in September. In the Courts view, this was more than sufficient time to enable the applicant to prepare his case and if necessary, make any Application in a Case for further Court orders. The fact that the application was only made on the morning of the hearing, with very late notification to the Court that the application would be made, is most unsatisfactory.
The High Court made it clear in Aon Risk Services v Australian National University (2009) 239 CLR 175, that Courts are entitled to apply case management principles when considering adjournment applications, particularly when made late. In this case, not only does the applicant seek to adjourn the matter, but seeks to considerably widen the attack to be made on the actions of the first respondent, to include entirely new grounds including matters where the first respondent contends the Court has no jurisdiction. The applicant also seeks leave to issue a subpoena on a wide range of government documentation, which would no doubt be the subject of considerable objection and require consideration by this Court as to whether or not any subpoena seeking information should be upheld. The subpoena purports to seek matters of high government policy and one might suspect involve issues of Cabinet-in -Confidence.
The Court is reasonably satisfied that there has been ample opportunity for the applicant to consider his position and refine his grounds of application. The fact that there has been a falling out between the applicant, his previous instructing solicitor and his Counsel, whilst unfortunate, is not a matter that, in the Courts view, is sufficient of itself to justify an adjournment been granted. The applicant has been represented by the same Counsel since very early in the matter.
There have been other failures, including the failure of the applicant’s Counsel to provide written submissions by the date due. No proper explanation has been given for this failure. Indeed, there is a reasonable inference that this matter has yet again been the subject of very late preparation, evidenced by the provision of a document entitled “The Applicant’s Outline of Oral Submissions”. In the Courts view, this document is in fact the applicant’s written submissions, which should have been filed in July 2020. This document seeks to raise further new matters over and above the issues that were set down for hearing.
Balancing the need for the finality in the matters that are going to be argued before the Court, together with the need for the matter to progress in a reasonably expeditious fashion, the Court determined to refuse the adjournment application. This left the Court to deal with the application for leave to amend the initiating application.
Should leave be granted to amend the Initiating Application
Firstly, the Court notes that the Commonwealth has provided
tothe applicant the documents that relate to a “Suspected Irregular Entry Vessel Information Report”, relevant to the applicant’s entry into Australia in 2013. It was on the basis that these documents have been provided, that it was submitted to the Court that the vessel upon which the applicant embarked on his voyage to Australia, started taking on water 67 nautical miles from Christmas Island and it was at that place that he was taken on board Australian naval vessel.Counsel for the applicant submitted that r 7.01 of the Federal Circuit Court Rules 2001 (Cth) empowers the Court to direct a party to amend a document in the way and on the conditions the Court thinks fit. Thus the Court has broad powers to permit a party to amend an application for review and even permit a party to conduct its case, without filing an amended document. It is submitted that the power to reject an amendment should not be exercised lightly and should be allowed where there are questions of fact to be resolved. The power to reject an amendment should only be exercised where the applicants claims are categorised as “fanciful, trifling, implausible, improbable, tenuous or contradicted by all the available documents or evidence” (see Riva NSW Pty Ltd v Official Trustee in Bankruptcy [2017] FCA 188 at [50]).
In relation to ground one, the applicant seeks to amend it to claim a new sub- ground that the exercise of power by officers of the Commonwealth to “turn back” or ‘interdict’ SIEV794 on or around 16 July 2013, was contrary to law. It is submitted that the turn back policy does not comply with international law or Australian domestic law. Reliance is placed on the number of submissions to a Senate Standing Committee on Foreign Affairs, Defence and Trade, which conducted a review of “Australian Breaches of Indonesian Territorial Waters” released on 27 March 2014.
The second matter that the applicant seeks leave to amend, is to allege that he has been in open custody for a period of seven years, due to restrictions contained within various visas, which related to his education, health and work rights. It is submitted that these restrictions amount to the applicant being in open custody, as compared to closed custody and is thus entitled to seek relief in the form of habeas corpus and/or false imprisonment, as at no point of time was he an unauthorised maritime arrival and he has been the subject of arbitrary and indefinite detention. It is further submitted that the applicant has a claim for negligence, malfeasance and damages as a result of these actions.
Counsel for the first respondent submits that leave to rely upon grounds one and two in the draft amended application, should be refused. It is submitted that it is well-established, through previous decisions of this Court, that Christmas Island is a proclaimed “excised offshore place” pursuant to s 5(1) of the Act. That being the case, as the applicant
isset foot on Christmas Island on 17 July 2013, by so doing, he entered Australia by sea, at an excised offshore place. As a result, pursuant to s 5AA of the Act, the applicant meets the definition of an ‘unauthorised maritime arrival’. It follows that the applicant is therefore a “fast track” applicant and the Authority had jurisdiction to review the decision under Part 7AA of the Act.It is further submitted that insofar as the applicant asserts he was rescued at sea and as a result, the Authority does not have jurisdiction to review the delegate’s decision, as he was not an unauthorised maritime arrival, this has no relevance, given that the applicant set foot at an excised offshore place at Christmas Island and entered the migration zone. It is noted that the definition of the migration zone in s 5(1) of the Act, makes no reference to the place of registration of a ship, on which a non-citizen is a passenger.
In relation to ground two, being the applicant’s claim a Writ of Habeas Corpus and/or damages for false imprisonment, it is either statute-barred or is not within the jurisdiction of the Court to grant, for the reasons set out above.
In relation to the applicant’s claim that he is not an unauthorised maritime arrival, the Court rejects the assertion. The mechanism upon which the applicant entered the exercised migration zone of Christmas Island, is irrelevant. It is well settled through a number of decisions of this Court, including GGD18 v Minister for Home Affairs (No 3) [2019] FCCA 444 at [38] per Street J and FFZ18 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCCA 1 per Driver J, at [29] –[ 34]. In DGJ17 v Minister for Immigration and Anor [2020] FCCA 1606, I adopted the reasoning in the two previously cases cited, to find that Flying Fish Cove at Christmas Island, had been validly exercised from the migration zone and that a person setting foot upon Christmas Island, validly became an unauthorised maritime Arrival and thus subject to the provisions of Part 7AA of the Act. These decisions have not been the subject of successful appeal and remain good law.
The Court accepts the first respondent’s submission that the jurisdiction of this Court to review migration decisions, arises solely through s 476 and s 484 of the Act. Any claim for a Writ of Habeas Corpus, a claim for damages for false imprisonment, malfeasance or negligence on the part of any Commonwealth officials, is not, in the Court’s view, a claim in relation to a migration decision, properly understood but is a collateral attack on the migration decision which is not properly vested in this Court (see McHugh v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCA 416 at [68] and [85] per Anderson J).
The Court also does not accept the assertion of the applicant that he has been in “open detention” since his release in September 2013. The Court is satisfied that the applicant has been at liberty, on various visas, as a lawful non-citizen. The Court does not accept that conditions that may be placed on the visa, to allow the applicant to remain at liberty within the community, amounts to “open detention” and thus subject to a Writ of Habeas Corpus. The Court is not satisfied that the proposed new grounds of appeal, contained within the Application in the Case, meet the threshold for leave to be granted to amend.
Conclusion
Accordingly, the application is rejected.
The orders of the Court are as follows:
a)The Application for an adjournment for leave to amend the Initiating Application is refused.
b)The Application for leave to amend the Grounds for Judicial Review is refused.
The Court will hear arguments in relation to costs.
The matter will be administratively listed for a further hearing on the grounds contained within the original Initiating Application filed in the matter, at a time and date to be set and advised to parties.
I certify that the preceding forty-nine (49) paragraphs are a true copy of the reasons for judgment of Judge Humphreys
Associate:
Date: 8 October 2020
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