Tag Archives: Tenant eviction

Retaliatory Eviction – Unlicensed HMO Latest Articles, UK Property Forum for Buy to Let Landlords

In a similar situation to the excellent discussion on Retaliatory Eviction, I can report that I have encountered similar practices in an unlicensed HMO. The situation is in some ways worsened by the fact that the four tenants involved were teenagers (2nd year university students) at the time that the 1 year AST was entered into, and as such, inexperienced in property rental. To say that they were exploited by the letting agent would be an understatement (in my opinion). Retaliatory Eviction - Unlicensed HMO

The property in question (in an E3 postcode area) is a double maisonette, two houses built one atop the other, the upper one having a separate entrance from a concrete walk way. It was originally built on two floors with the lower floor comprising a separate kitchen at the front with an L-shaped living/dining room at the rear. It has been “converted” so that the original kitchen is now a fourth bedroom and the original dining area of the lounge/diner is a very small kitchen. Dining is now at one end of the lounge area. Plumbing from the repositioned kitchen is still connected to the original service points by running the water and waste pipes through the new 4th bedroom around three walls in boxes. As you can imagine, the waste outlet is very slow due the the poor rate of fall in the pipe. The gas boiler has also been repositioned as a wall mounted unit in the lounge area again with water and gas supply pipes running around the walls through the living area and hallway back to the original connection points in the “new” 4th bedroom.

Since we have here 4 unrelated people living in a 2-floor house with shared bathroom and kitchen, we clearly have an unlicensed HMO. As the tenants have come to realise their homes status as an HMO, they have asked the letting agent to confirm the situation with the landlord and asked what could be done to ensure that the property could be rectified to meet the HMO standards. At first the letting agent denied that the property was an HMO, however, the tenants persisted. After a month or so, the letting agent then said that the property was not a licensed HMO. After another month or so of pressure, the letting agent said he had contacted the Housing Department of the Local Authority, who had confirmed to him that the property was not an HMO. On being asked for the name and department of the person he had spoken to, no name and a non existent department was forthcoming.

Subsequently, the tenant contacted the Local Authority who confirmed by e-mail that the property was an HMO. When this was reported to the letting agent, their response was, the local authority had contacted the landlord and if the matter was pursued by the tenants, the landlord would evict using a section 21 notice. Subsequently, the letting agent has said that he will get the landlord to fix any minor problems with the property being an HMO, but “if you ask for anything expensive he will evict, what is it that you want?”

The tenants have again contacted the Local Authority to ask for an inspection of the property to try to gain an official list of rectifications required, but have been met with a “we can’t inspect every property because our workloads are too high”.

It seems that a two tier HMO is not working too well as the threat to evict will stop any reporting of the situation by the tenant, especially where the Local Authority does not intervene . Since the HMO designation is statutory, I would have thought that it would be mandatory to at least investigate claims of this nature, otherwise why have the unlicensed HMO status when there appears to be no effective means of gaining enforcement of the statute without the risk of eviction?

Since all the guidance I have read says that the the requirements for HMO’s applies equally whether or not it is licensed or unlicensed, is there not a case to simply have all HMO’s licensed? As the statistics show, tenants are 14 times more likely to die in an HMO than in a regular tenant in a non-HMO, or is it just a fact of life that we cannot afford to protect all HMO tenants equally because of the current financial crisis, and that’s not mentioning what I believe to be the poor practice of the letting agent who is, at best, taking advantage of the naivety the tenant by knowingly letting an unfit HMO.

Eric Crossley

Is the section 21 notice now a risk? Latest Articles, UK Property Forum for Buy to Let Landlords

Under Section 21 of the Housing Act 1988, once an Assured Shorthold Tenancy (AST) agreement has come to an end, a landlord has the legal right to recover possession of their property should they wish. Is the section 21 notice now a risk?

A landlord wishing to re-gain possession of a property is required to serve a Section 21 Notice to tenants. They do not have to give any reason for ending the tenancy.

There are strict rules for landlords to follow when evicting tenants. Under an AST, they must ensure that the tenancy has run for at least six months and that the initial contract term has finished. Landlords have a duty to protect deposits in a suitable holding scheme and to serve the correct notices using Section 21. There are two types of Section 21 Notice and it is important the right one is issued. If the tenancy is still within the contracted fixed term, the S.21 (1)(b) Notice should be served. Where the fixed term has ended and the tenancy has become a periodic agreement, the S.21 (4)(a) Notice is used. Landlords must give at least two months notice before evicting tenants. If the tenant does not vacate within the timescale, a court possession order can be obtained. Following this, if occupants still won’t leave, the landlord can apply again to the court for bailiffs to assist in tenant eviction.

Before going to court it is imperative that protocols have been followed properly. The appropriate notices need to have been served correctly and in a timely manner. According to the Chairman of the London Association of District Judges, a high percentage of eviction notices are being dismissed out of court due to mistakes made in their issue.

Previously, properly served Section 21 Notices have usually proved effective. Wishing to avoid the issue of going to court, tenants nearly always left within the requisite two months. However, it has recently become popular for councils to refuse a Section 21 notice as evidence of tenant eviction. They prefer to wait until the case has been brought to court and a possession order granted before re-homing individuals. As this process can take several weeks or months, it gives councils additional time to relocate tenants. However, it can be financially devastating for landlords, especially if the tenant is not paying rent.

The new Universal Credit system is also causing concern for both landlords and tenants. Previously, benefits were paid to claimants in separate instalments and rent paid directly to landlords, but tenants will now receive one payment, including housing benefit, from which they will need to pay their rent. Only a small percentage of tenants fail to pass rent on to their landlords. However, the new system could potentially see more individuals struggling to manage their finances effectively and the risk of rent arrears will increase. In addition, there is apprehension over proposals to recover arrears by reducing payments to the claimant and paying a percentage directly to the landlord. This could place tenants in an even more vulnerable position and the landlords will only recoup lost rent over very long periods of time and risk further arrears in the future.

It seems inevitable that the long-term result will be more landlords withdrawing from the social-housing sector, with the gap between supply and demand only increasing.

Ex-girlfriend refusing to move out Latest Articles, UK Property Forum for Buy to Let Landlords

I am the tenant of a one-bedroom flat. I moved in almost two years ago. I have a one-year fixed term tenancy which was renewed about ten months ago.Ex-girlfriend refusing to move out

My girlfriend who I have now broken up with moved in with me. She didn’t pay towards the rent and bills for almost a year due to not having an income. She then paid half the rent and bills for a year, before refusing to pay anything more when we broke up recently.

I would like to move out at the end of my tenancy but my girlfriend is refusing to move out. She has been to the council who have advised her that she cannot be evicted at short notice and that she should stay put until forced to move. She applied to take over the tenancy but her application was rejected as her stated income did not cover the rent.

The lettings agent who acts for my landlord tells me that I am liable for all costs if she refuses to leave the property at the end of the tenancy and that it may take six months for the agency to go to court and get her out.

I asked her to leave verbally two months before the end of the tenancy and the agency have emailed her a written request with about six weeks notice, saying that they require vacant possession at the end of the tenancy, and asking her to confirm she will leave the property by then. In their email to her they said she has no right of possesion as she is not the legal tenant. They have also said that they will take pre-emptive legal action if she does not confirm that she will leave the property.

My questions:

1. Is she correct in thinking I can’t ask her to leave without a court order? She is not on the tenancy agreement, but is not obviously an excluded occupier either as I am not the landlord.

2. Is the lettings agent correct in saying that I would be liable for all the rent and court costs until she can be evicted?

3. The lettings agent says they would give permission for me to change the locks at the end of the tenancy if she refuses to move. Would that be an illegal eviction or is it an option open to me?

Changing the locks doesn’t appeal to me but nor does paying someone else’s rent for six months or a further six months of cohabitation, with the eviction notice being in my name.

Retaliatory eviction – possibility of civil litigation? Latest Articles, UK Property Forum for Buy to Let Landlords

We’re a professional couple with a limited company which provides a technology solution to the NHS. It suits our circumstances to rent at this moment in time. Retaliatory eviction

We had a 4-year rental of a lovely apartment until last Summer, when the owner decided to downsize and move back into the property. It was a good relationship, we had treated the property as if it had been our own investment and we parted as friends – with our deposit paid back in full.

After much searching we found a 3-bed town house which appeared to offer us everything we needed. The letting agent was a member of NAEA/ARLA and appeared to be respectable. There were some agreed remedial works to be dealt with and we were given assurances that these would be attended to in due course. We moved into the property in late August 2012.

Sadly, by the beginning of November, it was apparent that the property had some significant problems. There was extensive water penetration upstairs and a rising damp problem to the ground floor. The letting agent was informed immediately, with photographic evidence and a request for urgent assistance. We moved our furniture from the 3rd bedroom.

A ‘trades-person’ appeared in due course, with a notepad and pencil but with no damp meter. A report was promised, but was not forthcoming. The letting agent promised to send another contractor. This one only worked weekends and couldn’t agree a time to call; that visit never took place.

I called the landlords contractor to arrange the remedial work to be completed – missing doors, exposed wires, etc. He visited early November, measured up, made notes, promised to return – but failed.

We spent the most horrendous Christmas and New Year in the house. There was serious damp penetration, black mould which was constantly being removed. Slugs were climbing the walls. The house was very cold and the more that we heated it – the worse the damp became. We telephoned, wrote, sent photographs, yet the letting agent did nothing; there were plenty of replies – unbelievably stating that they were attempting to do everything as quickly as possible. We initially resigned ourselves to getting out of the house at the end of our AST.

In early-February, I wrote the strongest letter to letting agent with photos. A survey was made by Peter Cox, a pretty damning report which agreed with our complaint – serious damp and rain penetration. I wrote again, asking for compensation and a reduction in rent. This was refused. The letting agent had said that the landlord was absent; it transpired this wasn’t the case.

We tracked the landlord down and demanded a meeting. The landlord appeared, agreed with us in full and said that it was the first he knew of the problem. He agreed that we should be compensated and that this was the letting agents responsibility. Our landlord sat in our home, apologising and promised us both that this would be resolved. He remarked how clean we kept the property. The next day he had changed his mind and said that our grievance was with the letting agent. The following day – the EHO (Environmental Health Officer) inspected. That week, the missing doors and exposed electrics were attended to. We sent 2 requests to the letting agent, for the landlords address – these were refused.

A week later we received a section 21 notice to quit. The landlords address was given as c/o a family member in the South – presumably to thwart a legal action by us.

It turned out that the landlord had known of the problems. He’d applied for a grant for roof insulation, in my name – without my knowledge – and prior to our first meeting. It transpired that the letting agents were not members of ARLA or NAEA and we contacted both organisations and Rightmove to get these false affiliations removed. The letting agent claimed an oversight.

We spoke with our MP who has written to the CEO of the local authority, in order to push the EHO. The EHO wrote to the letting agent and the landlord but there was no response. We then began to receive threats from the letting agent to enter the property to inspect and allow viewings; we made a formal complaint to the Police and this is logged with a fast-track number in the event that they continue. We threatened to change the locks and the letting agent replied that this was not necessary.

We defended the section 21 notice on the grounds of incorrect dates and continued to pay the rent. We were not going to be forced out and subjected to costs or inconvenience due to their incompetence. The weather had improved and the house was drying out for the summer and we would tough it out now – having gone through the worst. We have since redecorated all damp affected walls as it is unnecessary to be reminded every day.

Our MP has pushed for resolution; this has mustered a stronger letter from the EHO. There has been no response other than a second section 21 notice. The dates are once again incorrect. The letting agent has put our deposit into a DPS but did not provide the Deposit Protection Certificate or prescribed information until we requested it after five months of tenancy. The prescribed information appears to be incomplete. I doubt that any s21 is valid until deposit is returned and the landlord might be liable for 3x under the Localism Act? Our claim should also be for a reduction in rent back-dated to 11/2012 and should provide compensation for immense stress and upset – particularly to my wife – for the repeated inconvenience, small damage, etc.

We’ve spoken with experts in Landlord/Tenant issues, they’ve seen our file which is very complete and have passed it onto Barristers to evaluate. We have a strong case apparently, but would incur costs of circa £7k to seek compensation/enforcement of duty to repair; we’ve been told that there is little likelihood of being awarded costs – if successful. That’s an expensive ‘point of principle’ for us.

It seems a dreadful situation. We actually like the house and the worst of the problems could be so easily resolved. We must now consider vacating the property before the bad weather sets in again – to remain longer would weaken any case against the landlord and the letting agent. The landlord is inexperienced and his conduct and concern for our welfare has been quite despicable. The promises that he made to my wife and I were instantly forgotten and we would like to do whatever might be done, so that he is taught the lesson.

Please accept our apologies for the long post, is there anything that we could do, other than what the landlord and letting agent expects – that being to vacate and walk away? I feel that someone needs to make a stand here, to create some solid case law if necessary – to protect others faced with similar problems in the future.

Thanks in advance

Roy and Tania

Alternatives to Landlord Licencing Schemes Latest Articles, UK Property Forum for Buy to Let Landlords

The alternatives to Landlord Licensing Schemes require joined up thinking, changes to data sharing protocols within local authorities and revised high level directives and strategies which must begin at Government level. 

Perhaps the first question to ask is what is Landlord Licensing all about? Is it really about raising standards or is it more to do with raising funds?Alternatives to Landlord Licencing Schemes


If society as a whole desires that people should not be subjected to sub standard housing conditions then society as a whole must pay to enforce this (howsoever that might be done) whether the money is raised at a local level or centrally.

It is both unacceptable and wholly undemocratic that landlords should be singled out by Government, Councils and Local Authorities to pay stealth taxes badged as licensing fees on the pretence that the money will be used to fund enforcement related initiatives.

Costs associated with licensing schemes imposed on landlords are funded through increased rents. Neither landlords nor tenants want this, particularly as there is clear evidence (demonstrated in this article) that landlord licensing schemes have proven not to be an effective solution to problems in the Private Rented Sector.

Recycling of Court awarded penalties

The high costs associated with prosecuting criminal landlords is borne by Local Authorities, however, fines and penalties go to the treasury. If these funds were to be redirected to the prosecuting authorities this would assist funding of additional prosecutions and create incentives to bring more criminal landlords to task. Continue reading Alternatives to Landlord Licencing Schemes

Story of an Eviction Latest Articles, UK Property Forum for Buy to Let Landlords

I thought it might be helpful to other readers to post a blog on an eviction process. Story of an Eviction

In one of my HMO’s, I have just had a Section 21 expire and my tenant still present… Joy.

He is 29, able-bodied, and plays for a local cricket team, but has never done a stroke of work in his life.

Until last November his rent of £400 pcm was paid by the council, but then it dropped to the capped amount leaving him circa £80 pcm to top up with. Of course he has not paid a penny, though always has money for booze, fags and electric guitar equipment, with which he disturbs the other tenants in the HMO.

Having said all that, he is quite a personable chap, and I for one cannot fathom why he cannot or will not get himself a job.

He has had three months to find somewhere else and I don’t think has really bothered to even try.

I informed him back in March, informally, that if he could not meet the rent he would have to find somewhere else. Nothing changed, the noise nuisance worsened, and we served him with a Section 21, which effectively gave him ten weeks’ notice. I bought the HMO July 2011, and inherited him with the house, he is NOT a protected tenant, only having been there from 2009. No deposits were passed on from the previous landlord.

So, what would your advice be at this point?

I am thinking of removing his bedroom door, as it is my property…!!?

Has this been tried before?

Seriously though, I am not sure yet what processes and expenses will be generated by this process…

Will the council continue to pay their part of his rent through the eviction process or will this just stop?

Is it my bounden duty to give him free electricity,water, heating etc while the process goes on?

Perhaps he would also like some free clothes and a chauffeur service too?

How long will all this take?

Is this “enforced charity” just part and parcel of being a landlord?

Is there any way of claiming compensation from him/his family/the council..?

All comments and suggestions welcome, and I will try and update this thread as often as possible.

Ian Simpson

Meet The Landlords TV programme – fair representation? Landlord News, Latest Articles, Property Investment News, UK Property Forum for Buy to Let Landlords

Last night I finally got around to watching a TV programme I recorded on BBC a few weeks ago called “Meet The Landlords“.

I was asked to appear on the programme when it was first considered but when I told the reporter what managing my portfolio entailed he wasn’t really that interested. Who could blame him? My tenants stay with me for years, I outsource most things and for that reason I doubt I spend more than a couple of hours every week looking after my property portfolio. It makes me enough to live on, my tenants are all very happy and neither me nor my tenants are ever very likely to make good viewing on the Jeremy Kyle show.

The appearances from landlords and tenants featured on “Meet the Landlords” though was a proper rogues gallery. It wouldn’t surprise me at all if the programming team had stood out the Jeremy Kyle recording studio’s a picked the worst of the worst people. Perhaps they offered them a free Maccie D’s in return for them and their landlords to make another appearence on the telly? LOL

The programme featured:-

  • Two amateur landlords whose tenants had not been paying rent for months,
  • a landlord calling himself the HMO Daddy who runs what I can only describe as “doss houses” for the dreggs of society,
  • and a woman from a North Eastern letting agency who let a property for a private landlord to rent to a drunken ASBO tenant who couldn’t even be bothered to turn up sober and then broke down into tears when presented with a property which he clearly realised he didn’t deserved to live in

If the BBC wanted to make a documentary revealing broken Britian this was a success. If they wanted to portray the Private Rented Sector then sorry, in my opinion it was a massive #FAIL

If the two amateur landlords had employed a decent letting agent or spent some time reading forums such as this one they wouldn’t have found themselves thousands of pounds down in rent arrears. One of the landlords was quite clearly on the verge of a mental breakdown but the hypocrisy of her story was that whilst her tenants were not paying the rent due to her, she was falling into arrears with her own landlord and prioritising subsidising her own mortgage! No wonder Paul Shamplina for Landlord Action has such a thriving Tenant Eviction business. He was one of the few people on the programme who came across as being decent.

I’ve heard about the HMO Daddy selling coaching and mentoring and I had always wondered why a landlord who claimed to be successful would do that. In my mind, you mentor people either to grow your own business (i.e. employees) or you do it when you’ve made enough money to become truly altruistic and because you thrive on helping other to achieve or solve problems which you’ve previously encountered. Having watched this programme I think I may have worked it out. Perhaps “landlord Jim” needs to sell a blueprint of his “secret recipe”, or a positive spin on what he would really like it to be like, in order to subsidise the appalling behaviour of his appalling tenants living in his appalling properties, all of which were exposed on National TV?

I’ve read some very positive views elsewhere on the web about the lady who worked for the letting agency and dealt with the ASBO tenant. Yes she was grounded, caring and very patient. What I can’t get my head around is how it can possible be in the interests of any landlord to put a drunken lout like that tenant into what seemed to be a relatively decent property. Fair enough, it was explained that the rent was guaranteed to be paid directly by the Council due to this chaps “issues” shall we say but come on! Anybody with half a brain can see this chap was on the road to nowhere but prison. If that house isn’t completely trashed within a year then I will eat my words but I’d happily lay a bet that the damage he causes to the property and the distress he causes to the poor people living in close proximity to him will not come close to the rental income. What man in his right mind would think his wife and children would feel safe living to a sexist drunk like him? The guy believed he was God’s gift to women and obviously has no respect for society or the law either. The chap needed to be institutionalised in my opinion, for his own safety and for others, but I suppose that’s the result of what was badged “Care in the Community”.

The real shocker for me was the prostitute tenant who gave up possession of her property without going to Court in return for a tenner. Yes she signed some papers but it was pretty obvious to me that she did that under duress and whilst under the influence of drugs, alcohol or both.

Maybe I’m lucky, perhaps I will be labelled as a snob for writing this review, but the “Meet the Landlords” TV programme was nothing like the Britain I know and love and certainly not representative of what I have witnessed as a result of being a landlord for the last 24 years!

What were your thoughts?Meet The Landlords

Council Eviction – What Tenancy do I have? Latest Articles, UK Property Forum for Buy to Let Landlords

My Question is for a friend of mine…

He is in Council rented accomodation, he has been there for 16 years, but the tenancy was originally made in his wife’s name only, he moved in, expecting his wife and son to follow shortly, but she never did when the fell out and eventually got divorced.

He has never had any tenancy paperwork in his name but has always paid the rent, does he have an assured tenancy as a matter of default since he has been there for so long and he has always paid, and the council have always accepted the rent from him.
I thought if someone was living in a property from years ago, even without a written tenancy aggr. they automatically had an assured tenacy, similar to the automatic AST one would automatically get nowadays.

I ask, because there are moves to evict him, but only him, from the block of flats.

He is very quiet, keeps himself to himself, so is no trouble to anyone, but has had trouble/harrassment from this same councillor before, who is trying to get him out this time.

His flat was assessed for a new kitchen and bathroom about 6 years ago, and both got condemned, but nothing ever got done about it. Recently he was advised to take it up with ‘decent homes’ in the council, but this enquiry seems to have triggered off this action from this councillor for his area. (this councillor is the housing officer I believe)

He is in a two bed flat, and it’s felt they are doing this to try to get it off him for a single child/young children family.

My friend has had mental health issues in the past and is still not fully recovered and is very stessed by the whole situation.

Thanks Council Eviction - What Tenancy do I have?

Family property dispute – legal help required Latest Articles, UK Property Forum for Buy to Let Landlords

12 years ago my father was looking to sell a field. I asked him if I could have it and he said yes. At the time he said we could sort the money out later, the agreed price was £40,000. I have the deeds but he is still the legal owner. If it makes any difference I’ve paid no rent as none was ever agreed. So far as we were all concerned everything would eventually be sorted out. It was a family deal, no need for contracts etc. we all thought.

Over the years I have made huge improvements to the value of the land, gaining planning consent to the point it’s now worth a few hundred thousand. I have also converted an old barn on the property and my plan was to let it as a holiday let. I’ve only just spent another £17,00 on it.

A few weeks ago my father announced he wanted the property back, it was a complete shock to me. I had always intended just to pay him for the land but now he wants everything and is threatening me with eviction!

In the following days I received texts saying my property will be taken and sold and any attempt to remove my improvements will be classed as criminal damage or theft !

I’m using a solicitor who is good but my father and family seem to ignore him. I was at the property the other day and he turned up with another bloke like a scene from the A-team saying he was taking it back no matter what. He damaged work I had done walked everywhere intimidating me.

I called the police and my father told them I threatened him! They just said its nothing to do with them and that it’s civil matter. I said does someone have to get hurt before they act, what happens if they break the locks, let my animals onto the road and they kill someone (I really beleive this is what they might do) but the police said I am over reacting.

I explained to the Police that I am disabled have a 12 month old child with me whilst my family are shouting at us having blocked them in with my car whilst waiting for the police to come. The Police said they have committed no crime!!!

I offered to move and give up any rights I had if they reimburse me for my improvements at a very reasonable figure as I have had enough of it all. They first offered a low figure then changed there mind going back to saying one way or another I am being evicted.

I’m now being told that I have 28 days to move. That’s 12+ years of my life wasted and all this hastle worrying all the time all because of a mans greed.  He now says he just let me use the land and never had any intention of letting me buy it.

I have bills going back to day one but it seems he can do what he pleases and the Police do nothing.

Can my animals be removed and sold?

How can I protect them?

Given that it’s my word against his, am I entitled to buy the property for the price we agreed 12 years ago or is there some sort of financial formula a judge will use to calculate who should pay who?

Do I have any rights at all?


Phil BollenhorseFamily property dispute - legal help required

Section 21 issued prior to contract signing Latest Articles, UK Property Forum for Buy to Let Landlords

We have private tenancy managed by a letting agent. It is a one year contract, rent has been paid on time and all other terms have been complied with, i.e. we are clean, quiet, diligent tenants.

10 months into our contract our letting agent says our landlord wants them to re-market the property.

We have tried to secure alternate property but the deal fell through. We contacted our letting agents and informed them we will not be vacating for the time being as we have been unable to find a suitable alternative property but are continuing to look.

The response from our letting agent was “too bad you have to be out”. I replied that since they had not served section 21 that we would not be leaving but they insist they did serve notice. I questioned when it was sent … they stated “a long time ago and its your word against ours”.

Upon reviewing contract documents given in person prior to signing and on the day of signing I have found a section 21 notice dated/issued 21 days prior to the contract signing. This was slipped in with other misc papers, we were not alerted to it or notified of it. We were, in fact, not aware of what a section 21 was until recently.

We are maintaining the section 21 is invalid …it was generated 3 weeks prior to the residential contract being signed.

Even if it was given on the day with the contract packet the deposit could not possibly have been secured in the scheme prior to the contact signing. Our letting agents gave us documents as package, the contract did not supply the deposit scheme confirmation and reference ID, although that did arrive later.

Are we right in maintaining the section 21 notice is invalid?

The expiry date is valid, it is just the issue date was three weeks before the contract was signed. There was also no exchange of funds at that point and no contract in effect.

It is very stressful they are harassing and threatening eviction.

Any input much appreciated.

RobSection 21 issued prior to contract signing

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