Snowball v Singh (No 2)
[2024] FedCFamC2G 415
•9 May 2024
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 2)
Snowball v Singh (No 2) [2024] FedCFamC2G 415
File number: MLG 1844 of 2023 Judgment of: JUDGE FORBES Date of judgment: 9 May 2024 Catchwords: BANKRUPTCY - application for review of Registrar’s decision to make sequestration order – hearing de novo - where respondent debtors have not filed material in support of application – where debtors sought adjournment to challenge underlying debt – adjournment refused – whether petitioning creditor proved outstanding debt – application for review dismissed and Registrar’s orders affirmed Legislation: Bankruptcy Act 1966 (Cth) s 40, 43, 47, 52
Federal Circuit and Family Court of Australia Act 2021 (Cth) s 256
Federal Circuit and Family Court of Australia (Division 2) (Bankruptcy) Rules 2021 (Cth) r 4.05, 4.06
Oaths and Affirmations Act 2018 (Vic) s 27
Cases cited: Bechara v Bates (2021) [2021] FCAFC 34
Guss v Larkfield Industrial Estates Pty Ltd [2023] FedCFamC2G 235
Snowball v Singh [2024] FedCFamC2G 414
Division: Division 2 General Federal Law Number of paragraphs: 55 Date of hearing: 24 April 2024 Place: Melbourne Counsel for the Applicant: Mr Boadle Solicitor for the Applicant: Sanicki Lawyers Solicitor for the Respondents: Hone Legal & Conveyancing ORDERS
MLG 1844 of 2023 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 2)
IN THE MATTER OF ASHIL ROHIT SINGH AND LOUISE NATALIE SINGH, BANKRUPTS
BETWEEN: THOMAS ERICK SNOWBALL
Applicant
AND: ASHIL ROHIT SINGH
First Respondent
LOUISE NATALIE SINGH
Second Respondent
ORDER MADE BY:
JUDGE FORBES
DATE OF ORDER:
9 MAY 2024
THE COURT ORDERS THAT:
1.The application by the Respondent debtors filed on 1 March 2024 for review of Judicial Registrar Ellis’ orders made on 29 February 2024 is dismissed.
2.The orders made by Judicial Registrar Ellis on 29 February 2024 are affirmed, including that the estates of the Respondents be sequestrated under the Bankruptcy Act 1966 (Cth) and that the Applicant creditor’s costs be paid from the estates of the Respondent debtors.
3.Any application by the Applicant creditor for costs in relation to the review application shall be in the form of a written submission, not exceeding 3 pages, setting out the basis on which such costs are to be calculated and ordered. Any such submission must be filed no later than 14 days after the date of these orders.
4.The Respondent debtors may file a written submission in reply on the question of costs, not exceeding 3 pages, no later than 21 days after the date of these orders.
5.The question of costs will be determined on the papers.
Note: The form of the order is subject to the entry in the Court’s records.
Note: The Court may vary or set aside a judgment or order to remedy minor typographical or grammatical errors (r 17.05(2)(g) Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 17.05 Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth).
REASONS FOR JUDGMENT
JUDGE FORBES
INTRODUCTION
By an application dated 1 March 2024 pursuant to section 256(1) of the Federal Circuit and Family Court of Australia Act 2021 (Cth) (the FCFCOA Act) the respondent debtors seek a review of orders made by a Judicial Registrar of this Court on 29 February 2024 to sequestrate their estates under the Bankruptcy Act 1966 (Cth) (the Bankruptcy Act).
On 7 October 2022 the County Court of Victoria entered judgment in default (default judgment) in favour of the applicant creditor against the respondents in a sum of $204,646.56 (judgment debt). The judgment debt has not been met and bankruptcy notices were issued against each of the respondents. Following the failure of the respondents to comply with the bankruptcy notices within the requisite period, the applicant petitioned to sequestrate their estates.
Upon the creditor’s petition, Judicial Registrar Ellis found that the first respondent committed an act of bankruptcy on 16 October 2023 and the second respondent committed an act of bankruptcy on 10 October 2023. In each case, the respondents failed to pay debts prescribed in bankruptcy notices served upon them. As well as sequestrating their estates, the Judicial Registrar ordered that the applicant’s costs be paid from the estates of the respondent debtors in a sum of $6,390.50.
APPLICATION FOR REVIEW
The application for review filed by the respondent debtors seeks a review of all the orders made by the Judicial Registrar. The application does not advance the grounds on which the review is sought. However, the respondents seek that the proceeding based on the creditor’s petition be dismissed.
On 13 March 2024, the Court made case management orders including that:
(a)by no later than 4pm on 28 March 2024, the respondents file and serve any affidavit(s) in which they intend to rely and an outline of submissions setting out grounds and argument about why the Judicial Registrar’s decision should be set aside; and
(b)by no later than 4pm on 16 April 2024, the applicant file and serve any affidavit(s) on which he intends to rely and an outline of submissions setting out why the judicial registrar’s decision should be affirmed.
The respondents, who are the applicants in this proceeding, did not comply with the Court’s directions. By the day prior to the hearing of the application, only the applicant (as the respondent in this proceeding) had filed any materials. The applicant creditor had filed a number of documents upon which he intended to rely, including:
(a)an affidavit of the applicant sworn 15 April 2024 deposing to the truth of the matters stated in the creditor’s petition and confirming that the judgment debt was still owing;
(b)an outline of submissions as to why the sequestration orders should be made;
(c)an affidavit of search from the applicant’s solicitors affirmed on 23 April 2024;
(d)an affidavit of the applicant sworn in the United Kingdom but electronically witnessed by his solicitor in Australia on 23 April 2024 deposing to the judgment debt remaining outstanding; and
(e)a court book comprising all relevant background documents including the judgment order and bankruptcy notices, creditor’s petition and supporting documents, affidavits of service, documents filed for the hearing before Judicial Registrar Ellis and documents filed prior to the review hearing before me.
HEARING
Just hours before the hearing of the review application, the first respondent filed an affidavit deposing to his belief and that of his current solicitor that there may be an arguable defence to the claims upon which the default judgment had been entered. In essence, the first respondent contended that the applicant’s underlying claim was based on a sham arrangement and that the default judgment was liable to be set aside. The first respondent sought that the hearing of the review application be adjourned to enable his current solicitor to obtain a file from the solicitors who acted at the date the default judgment was entered so that he could independently advise on the issue and make an application to set aside the judgment.
When the hearing convened, Mr Hone, the respondents’ current solicitor, relied on the affidavit and pressed the application for an adjournment. Mr Boadle of counsel oppose the adjournment on behalf of the applicant. For reasons given ex tempore and separately published I refused the adjournment request[1].
[1] Snowball v Singh [2024] FedCFamC2G 414
Approach to a review application
A hearing under s 256(1) of the FCFCOA Act seeking a review of a Registrar’s decision is a hearing de novo and the creditor’s petition is considered afresh. The review does not hinge, or focus, upon error in the decision of the Registrar[2].
[2] Guss v Larkfield Industrial Estates Pty Ltd [2023] FedCFamC2G 235 at [33]
In a hearing de novo the petitioning creditor is the true applicant and carries the onus of proving the application by bringing forward the evidence required by s 52(1) of the Bankruptcy Act. The debtor/bankrupt does not need to show error in the Registrar’s decision. The only onus of the debtor/bankrupt who actively opposes the creditor’s petition is to prove either solvency or any other sufficient cause under section 52(2)[3].
[3] Bechara v Bates (2021) [2021] FCAFC 34 at [27], [37], [59]-[66], [74], [88], [92]
Accordingly, the petitioning creditor must prove, and the Court must be satisfied, that the requirements for the making of a sequestration order have been established. The applicant submits, and I accept, that the Court’s attention should be solely focused on the creditor’s petition and whether the matters set out in section 52(1) are made out.
If the Court concludes that the making of a sequestration order is appropriate, the Court will dismiss the review application, leaving the Registrar’s extant order in place. For good order, the Court should confirm or affirm the Registrar’s extant order.
Applicable law
Turning then to the relevant considerations which underpin whether a Court should make a sequestration order in any given circumstances.
Section 43 of the Bankruptcy Act sets out the Court’s jurisdiction permitting it to make sequestration orders. The exercise of that jurisdiction depends on the petitioning creditor establishing the commission of an act of bankruptcy by the debtor concerned. There are also a number of other conditions that must be satisfied, which include residence in Australia by the debtor(s) at the time of the commission of the act of bankruptcy.
Section 40(1) of the Bankruptcy Act provides a list of the matters which constitute acts of bankruptcy which can serve the basis for the issue of a creditor’s petition. One of those is that the creditor has obtained a final judgment or orders against the debtor which has not been stayed, which has been served on the debtor within the requisite time, and in relation to which the debtor does not have a counterclaim, set off or cross-claim which is equal to or greater than the amount of the debt. The onus falls on a debtor to provide satisfactory proof if a counterclaim, set off or cross-demand is alleged.
The official receiver may issue a bankruptcy notice on the application of a creditor who has obtained a final judgment, subject to that amount being at least $10,000. An act of bankruptcy occurs where, as here, a bankruptcy notice has been issued, served and remains unsatisfied.
Section 52(1) of the Bankruptcy Act prescribes the matters required to be proved by the petitioning creditor before the Court may make a sequestration order against the estate of a debtor. At the hearing of a creditor’s petition, the Court requires proof of:
(a)the matters stated in the petition (for which purpose the Court may accept an affidavit verifying the petition as sufficient);
(b)service of the petition; and
(c)the fact that the debt or debts on which the petitioning creditor relies is or are still owing.
Part 4 of the Federal Circuit and Family Court of Australia (Division 2) (Bankruptcy) Rules 2021 (Cth) also applies in relation to a creditor’s petition seeking a sequestration order against the estate of a debtor. Those rules prescribe, among other things, the form of the creditor’s petition, the form and content of the verifying affidavit required by subsection 47(1) of the Bankruptcy Act, the content of the affidavits proving the debt and rules relating to service.
Relevantly, before the hearing of the creditor’s petition, an applicant creditor must:
(a)file an affidavit deposing to the service of documents required to be served under rule 4.05[4];
(b)no earlier than the day before the hearing date for the petition, search or cause a search to be made in the National Personal Insolvency Index and file an affidavit setting out the results of that search, attaching a copy of the relevant extract of the Index[5]; and
(c)as soon as practicable before the hearing date, file an affidavit of a person who knows the relevant facts which states that each debt on which the applicant creditor relies is still owing[6].
[4] Federal Circuit and Family Court of Australia (Division 2) (Bankruptcy) Rules 2021 (Bankruptcy Rules) r 4.06(2)
[5] Bankruptcy Rules r 4.06(3)
[6] Bankruptcy Rules r 4.06(4)
Evidence
Before turning to the matters about which the Court must be satisfied, it is appropriate to make some comment about the evidence which is currently before the Court.
In advancing the case for the making of sequestration orders, counsel for the applicant creditor relied upon his outline of submissions and the materials contained within the court book, which included a number of affidavits which had been filed subsequent to the proceedings before the Registrar.
Mr Boadle for the applicant submitted that the respondents had failed to comply with the Court’s case management orders and had failed to file any evidence or submissions in support of the review application. He submitted that there was no evidence nor any submission before the Court that the respondents can pay their debts or that for other sufficient cause a sequestration order ought not be made. Counsel submitted that the Court can only deal with the evidence before it, all of which supports the applicant’s petition.
In his oral submissions, counsel for the applicant informed the Court that open correspondence from the applicant’s solicitors reminding the respondents of their obligation to file submissions and evidence had gone unanswered. Correspondence with the respondents’ solicitor attaching a draft index to the court book and inviting comment had also gone unanswered.
Until the filing of an affidavit seeking an adjournment of the proceeding just hours before the hearing was to begin, there had been no engagement in the review application by those who had filed it. As separately explained in my ex tempore reasons rejecting the adjournment application[7], the respondents’ last minute contention that there may be a basis for making an application to set aside the default judgment really rose no higher than mere assertion.
[7] Snowball v Singh [2024] FedCFamC2G 414
The applicant creditor submits that where a debtor/bankrupt fails to comply with orders or is dilatory or uncooperative, the review application should be heard and disposed of promptly at a final hearing. It is submitted that this approach is consistent with the character of the power being exercised by the Court on applications for de novo review of a delegated power. The applicant’s submission is that the Court in the present case is left with no substantive opposition to the making of the sequestration orders, subject to the Court being satisfied that the elements required to be proved by the applicant.
Proof of matters stated in the creditor’s petition (s 52(1)(a))
The creditor’s petition dated 18 October 2023[8] states that:
[8] Court Book (CB) 9 - 11
(1)The respondent debtors owe the applicant creditor the amount of $224,692.20 comprising of:
(a)$204,646.56 being a judgment entered against the respondents on 7 October 2022 by the County Court of Victoria in proceedings CI-22-02376, comprising the claim amount, interest and costs up until 7 October 2022; and
(b)$20,045.64 being penalty interest on the claim amount of $194,592 at the applicable statutory rate of 10% from 8 October 2022 to 18 October 2023.
(2)The applicant creditor does not hold security over the property of the respondent debtors.
(3)At the time when the act of bankruptcy was committed, the respondent debtors:
(a)were personally present in Australia; and
(b)were ordinarily resident in Australia.
(4)The following act of bankruptcy was committed by the respondent debtors within 6 months before the presentation of the petition:
(a)The First Respondent debtor failed to comply on or before 14 October 2023 (or 16 October 2023, being the next business day) with the requirements of a bankruptcy notice served on him on 23 September 2023 or to satisfy the Court that he had a counter-claim, set off or cross demand equal to or more than the sum claimed in the bankruptcy notice, being a counter-claim, set off or cross demand that he could not have set up in the action in which the judgment referred to in the bankruptcy notice was obtained.
(b)The Second Respondent debtor failed to comply on or before 11 October 2023 with the requirements of a bankruptcy notice served on her on 19 September 2023 order to satisfy the Court that she had a counter-claim, set off or cross demand equal to or more than the sum claimed in the bankruptcy notice, being a counter-claim, set off or cross demand that she could not have set up in the action in which the judgment referred to in the bankruptcy notice was obtained.
By an affidavit sworn on 18 October 2023[9], the applicant creditor deposed that the statements contained in the creditor’s petition are true. Specifically, he deposed that the first and second respondents had failed to pay the outstanding debt or make an arrangement for payment of the debt within 21 days after the service of the bankruptcy notices.
[9] CB 12
Also on 18 October 2023, the applicant’s solicitor filed an affidavit in compliance with r 4.06(3) which deposed to her search of the respondents on the National Personal Insolvency Index and confirmed that there were no details of a debt agreement in relation to the debt on which the applicant relied.
The applicant also seeks to rely upon an affidavit sworn on 15 April 2024 where he deposes to the truth of the matters contained in the creditor’s petition and again seeks to rely upon the affidavits he swore on 18 October 2023. In the 15 April affidavit the applicant also deposes to service of the creditor’s petition on each of the debtors as referred to in his earlier affidavits and he confirmed once again that the judgment debt remains outstanding.
In light of the above evidence, I am satisfied that the matters stated in the creditor’s petition have been established and that the affidavits relied upon by the applicant are sufficient proof of those matters.
I note for the sake of completeness, that the respondents’ solicitor made no submission that the creditor’s petition was defective.
Service of the petition (s 52(1)(b))
The respondent debtors have not raised any issue regarding the service of the creditor’s petition. However, it still falls to the applicant to satisfy the Court that service has been properly affected.
The applicant relies upon an affidavit of Kenneth James Ramshaw dated 8 November 2023[10] which deposes to service of the creditor’s petition on the first respondent. I am satisfied that the affidavit complies with the requirements of r 4.06(2) of the Federal Circuit and Family Court of Australia (Division 2) (Bankruptcy) Rules 2021 (Bankruptcy Rules) and that it is satisfactory evidence of service of the documents required to be served in such a proceeding.
[10] CB 50
Similarly, in relation to the second respondent, the applicant relies upon an affidavit of Mr Ramshaw dated 8 November 2023[11]. Again, I am satisfied that the affidavit meets the requirements of r 4.06(2) of the Bankruptcy Rules and that it should be accepted as satisfactory evidence of service of the documents required to be served in support of a sequestration application.
[11] CB 99
Whether the debt is still owing (s 52(1)(c))
Section 52(1)(c) requires the Court to be satisfied that the debt or debts on which the petitioning creditor relies is or are still owing. The respondents correctly submit that the onus falls on the applicant creditor, in a de novo proceeding, to bring forward proof to establish this requirement.
Mr Boadle on behalf of the applicant submitted that a number of affidavits filed in support of the application for sequestration orders establish that the judgment debt has not yet been satisfied. He referred to the affidavit of debt sworn by the applicant on 18 October 2023[12], the applicant’s affidavit of debt sworn on 28 February 2024 and a further affidavit filed on 23 April 2024, the day before the review hearing.
[12] CB 13
The applicant’s counsel submits that the most recent of the affidavits is the most relevant because it is the most proximate to the hearing and confirms that the debt on which the sequestration is sought remains unpaid. For reasons which will be explained below, the applicant creditor contends that even if that most recent affidavit is not admitted, the Court can be comfortably satisfied based on previous affidavits and other evidence that the judgment debt has not been paid.
The issue of the outstanding debt was the one matter on which the respondents’ solicitor made a substantive submission. Although Mr Hone did not positively assert that the debt had been paid, he reiterated that it was for the applicant creditor to prove that it had not.
In that respect, Mr Hone submitted that the only evidence the applicant creditor could rely upon was his most recent affidavit of debt, purportedly sworn on 23 April 2024. However, Mr Hone submitted that the affidavit was defective because it had not been properly sworn and, as such, could not be received as evidence by the Court. He noted that the affidavit of debt of Mr Snowball had been electronically signed and sworn at Surbiton in the United Kingdom and had been electronically witnessed by the applicant’s solicitor in Australia. While noting that the affidavit had been endorsed with a statement to the effect that it had been sworn and witnessed by audiovisual link in accordance with the requirements of section 27(1A) of the Oaths and Affirmations Act 2018 (Vic), Mr Hone queried whether an affidavit sworn by a deponent in a foreign country could be witnessed by an Australian solicitor.
The respondents’ solicitor went on to submit that if the 23 April 2024 affidavit of debt is excluded from evidence, the creditor’s application for a sequestration order must fail because he had not produced evidence of the outstanding debt on the day prior to the hearing as required by the rules.
In his reply, Mr Boadle contended that it the respondents’ submission was based on false premises. First, rule 4.06 does not require proof of the outstanding debt to be established by the filing of an affidavit on the day prior to hearing. Rule 4.06(3) certainly requires that an affidavit deposing to the search of the National Personal Insolvency Index must be filed no later than the day before the hearing date for the petition. However, pursuant to r 4.06(4) an affidavit deposing to the outstanding debt is to be “sworn as soon practicable before the hearing date for the petition”[13] – there is no strict requirement for that to be the day before the hearing.
[13] Bankruptcy Rules r 4.06(4)(a)
Secondly, counsel for the applicant submitted that the attack on the admissibility of the most recent affidavit was not supported by any substantive argument and advanced on the entirely speculative basis that it might not be a proper affidavit because it might not have been properly sworn. Mr Boadle submitted that it was not a proper challenge to the evidence to simply cast doubt over the affidavit and not advance any argument to support that doubt. In essence, he submitted that it is not satisfactory for the respondents to cast a shadow and then leave it for the Court to work out.
Thirdly, Mr Boadle submitted that the substantive matter about which the Court requires proof under s 52(1)(c) is the fact that the debt or debts are still owing. He submitted that while the rules require the filing of an affidavit, that should not be taken to be the only source of evidence upon which the Court can rely to be satisfied of the objective fact. Mr Boadle submitted that for the purposes of establishing the factual condition to the exercise of a power, the Court should not allow form to override substance. Indeed, it is always open to the Court to excuse a party from compliance with the rules.
Further, it was submitted that even if there was a technical reason for the most recent affidavit of debt to be excluded (which is denied), there is no evidence to contest earlier affidavits of debt including the one filed on 28 February 2024 and no evidence before the Court that the debt has in fact been paid.
Notwithstanding the issues raised by Mr Hone and the ensuing debate between counsel, I am comfortably satisfied that the debt on which the petitioning creditor relies is still owing.
My reasons for being so satisfied include the following:
(a)there is no evidence that there has been any payment made by the debtors toward the judgment debt. Neither the debtors nor their legal representative have asserted that the debt is not owing either by way of affidavit or oral submission. In a review application one would have expected a debtor to file evidence or at the very least make a positive assertion that the debt is not outstanding. That has not occurred here and the Court is entitled to draw an inference in favour of the applicant’s case;
(b)as mentioned earlier, at the commencement of proceedings the respondent debtors sought an adjournment to enable them to consider making an application to set aside the County Court default judgment. The premise of that application (notwithstanding I refused the adjournment) was that the default judgment had not been disturbed, the debt had not been paid and the debtors want judgment set aside;
(c)the applicant creditor has filed a number of affidavits of debt. Prior to the 23 April 2024 affidavit, the most recent was filed only a few weeks earlier at the end of February 2024. I consider that to be a relatively recent and still probative piece of evidence, which is not in any way contested; and
(d)as a condition to the exercise of its power to make a sequestration order, the Court is required to consider whether there is proof of a substantive fact. Even if there was a requirement in the court rules for an affidavit of debt to be filed on the day before the hearing (which in my view there is not) and even if the 23 April 2024 affidavit of debt was inadmissible because of a technical defect in the way in which it was taken (a matter I do not consider necessary to decide having regard to other overwhelming evidence), it remains open to the Court to derive satisfaction from the totality of the evidence before it, including inferences properly drawn from that evidence.
True it is that the onus rests with the petitioning creditor to establish the matters in s 52(1) of the Bankruptcy Act. But ultimately it is for the Court to be satisfied of the objective fact. There is a strong body of evidence weighing in favour of a finding that the debt remains outstanding and no denial or other evidence from those against whom the fact is asserted. The respondents have not raised by evidence or other means any reason for the Court to consider that there is not, in truth and reality, an outstanding debt owed to the petitioning creditor. If anything, the conduct and submissions of the respondents support the creditor’s assertion.
I am satisfied that the requirement of s 52(1)(c) is made out. The weight of evidence in support of my finding is so overwhelming that I do not consider it necessary to formally determine the correctness or otherwise of the debtor’s submission about the admissibility of Mr Snowball’s 24 April 2023 affidavit. The matter was not the subject of any detailed legal submission from either party and my finding in relation to s 52(1)(c) does not turn on that affidavit alone.
Exercise of discretion
The Court may exercise a discretion to dismiss a creditor’s petition if it is satisfied by the debtor that he or she is able to pay his or her debts or that there is some other sufficient cause for a sequestration order not to be made[14].
[14] Bankruptcy Act 1966 (Cth) s 52(2)
As I mentioned earlier, in support of their application for an adjournment of the review proceedings, the debtors posited that they may have grounds upon which to make an application to set aside the default judgment. For reasons given ex parte in rejecting the adjournment application, I found the debtor’s belief to be no more than assertion unsupported by any evidence.
In the substantive hearing of the review application, the respondent debtors did not advance any other ground which would persuade the Court not to make the sequestration order. The debtors did not identify any ground in their application, have not filed any evidence other than the last minute affidavit of the first respondent and have not advanced any other reasons in an outline of submissions. Nor have the debtors sought to prove their solvency.
Insofar as I should consider the submission that the respondents may have a basis to challenge the underlying claim and the judgment debt, I am not satisfied that it is a sufficient cause not to make the sequestration order. As mentioned in my ex tempore reasons, the basis for the respondents’ submission does not rise above mere assertion[15].
[15] Owen v Sandhu [2024] FCA 198
DISPOSITION
I have decided that it is appropriate to make a sequestration order against the estate of the debtors. Accordingly, the orders made by Judicial Registrar Ellis on 28 February 2024 should be affirmed and the application for review filed on 1 March 2024 will be dismissed.
Unless persuaded otherwise, the respondents, who are the applicants on review, should pay the petitioning creditor’s costs of this application. The applicant should file a short submission, of no more than 3 pages, outlining the costs he seeks in relation to this application and the basis upon which those costs are to be calculated and ordered. That submission should be filed not later than 14 days after the making of these orders. The respondent debtors may file a short reply submission (again no more than 3 pages) no later than 7 days after that.
The Court will determine the question of costs on the papers.
I certify that the preceding fifty-five (55) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Forbes. Associate:
Dated: 9 May 2024
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