Lidl/Athena ANPR Appeal: POPLA stage

Hi guys,

I was wondering if someone here could please help me finalise my POPLA appeal and make sure it looks ok before I send it.

I got a NTK from Athena ANPR for overstaying in a Lidl car park (by 12 minutes, damnit).

I read around the forum and I used the template appeal that is found on the newbie sticky and emailed that to them.

Predictably they came back and rejected my appeal. The letter was dated 23 May 2014, and the POPLA code was generated on 24 May 2014. However, due to the bank holiday I didn't receive the letter until 28 May 2014, so not sure if there's any issue here?

Anyway, they failed to provide the breakdown of the costs, or any proof that they were authorised by Lidl to be doing this on their behalf, they just vaguely said that they were contracted. I can post a picture of this if necessary.

So I've drafted a POPLA appeal based on what I've read here. The NTK didn't mention the specific name of a creditor, just Athena ANPR, so I've included that. Further to this, the sign in Lidl car park, and my rejection letter talks about the contractual terms of the car park and how failure to comply will make me liable to pay a charge and that I agreed to the contractual terms on the signage. Again, I have a picture of the sign if necessary. So I think the draft I found that talks about it being a disguised breach seems to suit.

I'd really appreciate someone having a look over this so I can send it off confidently :) Please see drafted POPLA below:

POPLA Code:
Vehicle Reg:
PPC: Athena ANPR
PCN Ref:
Alleged Contravention Date & Time:
Date of PCN:

On xx May 2014 I was sent an invoice from Athena ANPR requiring payment of a charge of £90 for an alleged parking contravention.
I would like to appeal this notice on the following grounds:

- Charge not a genuine pre-estimate of loss
- No Creditor identified on the Notice to Appellant
- No authority to levy charges
- Lack of contract
- ANPR Accuracy

Charge not a genuine pre-estimate of loss

1) This charge is not a contractually agreed sum. It is a disguised breach and is not a genuine pre estimate of loss.

Athena ANPR Ltd have not made clear the basis of their charge. Having visited the site, it appears they may be claiming the charge is a contractually agreed sum which I dispute. In my original appeal to Athena ANPR Ltd I requested that they clarify the basis of the charge. If alleging 'contractual fee' I requested they send me a VAT invoice by return and explain the daily rate of parking, however, in their rejection letter Athena ANPR Ltd failed to address this point and failed to provide the information or VAT invoice requested. Nor have they provided a calculation to show this is a genuine pre estimate of loss if alleging breach of contract.

a) This charge is not a contractually agreed sum – it is a disguised breach

If this charge was a contractually agreed fee the sign would been worded to offer various durations of parking at various costs. In addition a payment mechanism would have been provided on-site and a VAT invoice supplied. This is not the case here.

This is a free (for 90 minutes) car park and there is no mechanism to pay for additional parking. The signage indicates that parking for over 90 minutes attracts a £90 charge and, as no limits are specified, this could equally apply for an additional 10 minutes, 10 weeks or indeed 10 years!

The same sum is also sought for returning to the car park within 2 hours, something clearly disallowed by the wording “No return within 2 hours … “, which is immediately followed by “or charge of £90 will apply” - in other words “don’t do this or else” which shows the charges are actually for failing to comply, which equals a deterrent for breach.

In addition no VAT invoice has been provided and I have no evidence that this business operation on this car park has been registered for business rates.

Despite what the sign attempts to say, it is not an offer to park for a fee and it is clear that the true and predominant purpose of the alleged 'parking operation' at (insert location) is to deter breach and, in the absence of evidence that this charge is a genuine pre estimate of loss, it is an unrecoverable penalty.

In a recent ruling at Luton Crown Court 2014 (Civil Enforcement Ltd v McCafferty) the judge ruled that sum quoted on the sign was not a genuine offer to park at that price, but its main purpose was to deter. It was, therefore, a penalty dressed up as a contractual term, and not recoverable.

In the case of Dunlop Pneumatic Tyre Company Limited v New Garage and Motor Company [1915] AC 79, there is the classic statement, in the speech of Lord Dunedin, that a stipulation: “… will be held to be a penalty if the sum stipulated for is extravagant and unconscionable in amount in comparison with the greatest loss which could conceivably be proved to have followed from the breach”.

It would normally be for the owner to claim for loss which is nothing as there are no fees for using this car park and there was no damage or obstruction caused (nor is any being alleged). It is unfair to attempt to make a party pay excessively for an event that would normally be 'breach of contract'.

I require Athena ANPR Ltd to provide a VAT invoice, details of the daily rates of parking and proof that this chargeable regime at this location is registered for business rates.

b) Charge not a genuine pre-estimate of loss

If the sum is sought as damages for breach of contract then under established contract law it must be shown to be a genuine pre estimate of loss arising from the breach.

The car park is free and there was no damage or obstruction caused (nor is any being alleged). I submit that on a free car park there can be no loss arising from any alleged overstay.

The demand for £90 is punitive, unreasonable, exceeds an appropriate amount
has no relationship to the loss that would have been suffered by the Landowner, and is therefore an unenforceable penalty. Furthermore, it exceeds the BPA’s own Code of Practice.
The BPA Code of Practice states:
19.5 If the parking charge that the driver is being asked to pay is for a breach of contract or act of trespass, this charge must be based on the genuine pre-estimate of loss that you suffer.
19.6 If your parking charge is based upon a contractually agreed sum, that charge cannot be punitive or unreasonable.
The appellant requires Athena ANPR to provide a detailed breakdown of how the amount of the charge was calculated. I am aware from Court rulings and previous POPLA adjudications that the cost of running the business may not be included in these pre-estimates of loss.

POPLA Assessor Matthew Shaw has stated that the entirety of the parking charge must be a genuine pre-estimate of loss in order to be enforceable. For example, were no breach to have occurred, then the cost of parking enforcement, such as erecting signage, would still have been the same. The estimate must be based upon loss flowing from a breach of the parking terms, and in this instance there was no such loss.
I therefore respectfully request that my appeal is upheld and the
charge dismissed.

No Creditor identified on the Notice to Appellant

Failing to include specific identification as to who ‘the Creditor’ may be is misleading and not compliant in regard to paragraph 9(2)(h) of Schedule 4 of the Protection of Freedoms Act 2012. Whilst the Notice has indicated that the operator requires a payment to Athena ANPR, there is no specific identification of the Creditor who may, in law, be Athena ANPR or some other party. The Protection of Freedoms Act requires a Notice to Appellant to have words to the effect that ‘The Creditor is…’ and the Notice does not.
I therefore respectfully request that my appeal is upheld and the charge dismissed.

No authority to levy charges

A parking management company will need to have the proper legal authorisation to contract with the consumer on the landowner’s behalf and enforce for breach of contract. The operator must produce evidence to demonstrate that it is the landowner, or a contract or other evidence that it has the authority of the landowner to issue charge notices at this location. The appellant believes there is no contract with the landowner/occupier that entitles Athena ANPR to levy these charges and to pursue these charges in their own name in the Courts and therefore has no authority to issue charge notices. When requested on appeal Athena ANPR failed to provide a copy of the contract. The appellant puts the operator to strict proof to POPLA that they have the necessary legal authorisation at this location and demands that the operator produce to POPLA the contemporaneous and unredacted contract between the landowner and the operator.
I therefore respectfully request that my appeal is upheld and the charge dismissed.

No contract

There was no contract between the driver and Athena ANPR. The driver did not see any contractual information on any signs when entering the car park and therefore at that time had no idea that any contract or restrictions applied. As a consequence the requirements for forming a contract such as a meeting of minds, agreement, and certainty of terms were not satisfied. And even if there was a contract, which has yet to be proven, then it is unfair as defined in the Unfair Terms in Consumer Contracts Regulations 1999.
I therefore respectfully request that my appeal is upheld and the charge dismissed.

ANPR Accuracy

Athena ANPR are obliged to ensure their ANPR equipment is maintained as described in paragraph 21.3 of the British Parking Association's Approved Operator Scheme Code of Practice. I require Athena ANPR to present records as to the dates and times of when the cameras at this car park were checked, adjusted, calibrated, synchronised with the timer which stamps the photos and generally maintained to ensure the accuracy of the dates and times of any ANPR images. This is important because the entirety of the charge is founded on two images purporting to show my vehicle entering and exiting at specific times. It is vital that Athena ANPR produce evidence in response to these points and explain to POPLA how their system differs (if at all) from the flawed ANPR system which was wholly responsible for the court loss by the operator in ParkingEye v Fox-Jones on 8 Nov 2013. That case was dismissed when the judge said the evidence form the Operator was 'fundamentally flawed' as the synchronisation of the camera pictures with the timer had been called into question and the operator could not rebut the point.

So, in addition to showing their maintenance records, I require Athena ANPR to show evidence to rebut this point: I suggest that in the case of my car being in this Lidl car park, a local camera took the image but a remote server added the time stamp. As the two are disconnected by the internet and do not have a common "time synchronisation system", there is no proof that the time stamp added is actually the exact time of the image. The operator appears to use WIFI which introduces a delay through buffering, so "live" is not really "live". Hence without a synchronised time stamp there is no evidence that the image is ever time stamped with an accurate time. Therefore I contend that this ANPR "evidence" from Athena ANPR in this Lidl car park is just as unreliable as the ParkingEye system and I put Athena ANPR to strict proof to the contrary.



Yours Sincerely,
XXXXXXXX



I look forward to your reply,

Thanks!
«1

Replies

  • da_ruleda_rule Forumite
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    Looks good. The only thing I would say is that you have underlined the heading for part b of the first point and not part a. Maybe get rid of this underlining as it makes distinguishing between your main points of appeal and sub-headings a bit difficult.
  • RedxRedx Forumite
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    also make sure the short bullet points are nunbered and ensure the expanded bullet points match the title headers including numbering too - for clarity

    I dont think the generation of the code and subsequent bank holiday are relevant , what is relevant is ensuring its correct and sent in to popla in good time , preferably online and in the post too (tick 3 boxes of 4 , but not the stolen box obviously)
    Newbies !!
    Private Parking ticket? check the 2 sticky threads by coupon-mad and crabman in the Parking Tickets, Fines & Parking Board forum for the latest advice or maybe try pepipoo or C.A.G. or legal beagles forums if you need legal advice as well because this parking forum is not about debt collectors or legal matters per se
  • edited 31 May 2014 at 12:10PM
    ColliesCarerColliesCarer Forumite
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    edited 31 May 2014 at 12:10PM
    Appeals against Athena at Lidl car parks tend to win mostly on No authority as the no GPEOL point cannot always be relied on given they try to claim it's a contractually agreed sum although it does also win sometimes.

    So I would suggest you strengthen your no authority point to cover the fact that Athena tend to send in a witness statement instead of the contract. See the appeal in this thread by Ignatius1 for an example of what you can add to the no authority point to cover the invalid witness statements.

    http://forums.moneysavingexpert.com/showthread.php?t=4974041&highlight=athena

    Also take a look at the later pages/posts of these two threads (both of which recently won POPLA - Flossy on no authority and Shepss on not a GPEOL) for examples of the kind of evidence Athena will send in rebuttal of your appeal so you can be forewarned of what to expect and make sure you've covered the points they are likely to raise.

    http://forums.moneysavingexpert.com/showthread.php?t=4936219&highlight=athena

    http://forums.moneysavingexpert.com/showthread.php?t=4935878&highlight=athena
  • ColliesCarerColliesCarer Forumite
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    Also make sure you edit this paragraph in your not a GPEOL point before sending to either include the specific location or just say "the location in question"

    "Despite what the sign attempts to say, it is not an offer to park for a fee and it is clear that the true and predominant purpose of the alleged 'parking operation' at (insert location) is to deter breach and, in the absence of evidence that this charge is a genuine pre estimate of loss, it is an unrecoverable penalty."
  • Wood182Wood182 Forumite
    4 Posts
    Thanks for your prompt replies :)

    I've looked at those posts and I've made a couple of amendments; I tidied up the formatting, expanding the no authority point and also included an extra part around the ANPR accuracy and the breach of contract that I found on Flossy's post.


    On xx May 2014 I was sent an invoice from Athena ANPR requiring payment of a charge of £90 for an alleged parking contravention.
    I would like to appeal this notice on the following grounds:

    1. Charge not a genuine pre-estimate of loss
    2. No Creditor identified on the Notice to Appellant
    3. Lack of proprietary interest in the land and no authority to levy charges
    4. Lack of contract
    5. ANPR Accuracy

    1. Charge not a genuine pre-estimate of loss

    This charge is not a contractually agreed sum. It is a disguised breach and is not a genuine pre estimate of loss.

    Athena ANPR Ltd have not made clear the basis of their charge. Having visited the site, it appears they may be claiming the charge is a contractually agreed sum which I dispute. In my original appeal to Athena ANPR Ltd I requested that they clarify the basis of the charge. If alleging 'contractual fee' I requested they send me a VAT invoice by return and explain the daily rate of parking, however, in their rejection letter Athena ANPR Ltd failed to address this point and failed to provide the information or VAT invoice requested. Nor have they provided a calculation to show this is a genuine pre estimate of loss if alleging breach of contract.

    a) This charge is not a contractually agreed sum – it is a disguised breach

    If this charge was a contractually agreed fee the sign would been worded to offer various durations of parking at various costs. In addition a payment mechanism would have been provided on-site and a VAT invoice supplied. This is not the case here.

    This is a free (for 90 minutes) car park and there is no mechanism to pay for additional parking. The signage indicates that parking for over 90 minutes attracts a £90 charge and, as no limits are specified, this could equally apply for an additional 10 minutes, 10 weeks or indeed 10 years!

    The same sum is also sought for returning to the car park within 2 hours, something clearly disallowed by the wording “No return within 2 hours … “, which is immediately followed by “or charge of £90 will apply” - in other words “don’t do this or else” which shows the charges are actually for failing to comply, which equals a deterrent for breach.

    In addition no VAT invoice has been provided and I have no evidence that this business operation on this car park has been registered for business rates.

    Despite what the sign attempts to say, it is not an offer to park for a fee and it is clear that the true and predominant purpose of the alleged 'parking operation' at the location is question is to deter breach and, in the absence of evidence that this charge is a genuine pre estimate of loss, it is an unrecoverable penalty.

    In their letter to me rejecting my appeal they state "There are sufficient number of signs in the car park, which clearly state that if you fail to comply with the terms you will be liable to pay a parking charge". The words "fail to comply" indicate the charge is in fact a sum sought as damages for an alleged breach of contract and therefore the charge must be a genuine pre estimate of loss.
    In a recent ruling at Luton Crown Court 2014 (Civil Enforcement Ltd v McCafferty) the judge ruled that sum quoted on the sign was not a genuine offer to park at that price, but its main purpose was to deter. It was, therefore, a penalty dressed up as a contractual term, and not recoverable.

    In the case of Dunlop Pneumatic Tyre Company Limited v New Garage and Motor Company [1915] AC 79, there is the classic statement, in the speech of Lord Dunedin, that a stipulation: “… will be held to be a penalty if the sum stipulated for is extravagant and unconscionable in amount in comparison with the greatest loss which could conceivably be proved to have followed from the breach”.

    It would normally be for the owner to claim for loss which is nothing as there are no fees for using this car park and there was no damage or obstruction caused (nor is any being alleged). It is unfair to attempt to make a party pay excessively for an event that would normally be 'breach of contract'.

    I require Athena ANPR Ltd to provide a VAT invoice, details of the daily rates of parking and proof that this chargeable regime at this location is registered for business rates.



    b) Charge not a genuine pre-estimate of loss

    If the sum is sought as damages for breach of contract then under established contract law it must be shown to be a genuine pre estimate of loss arising from the breach.

    The car park is free and there was no damage or obstruction caused (nor is any being alleged). I submit that on a free car park there can be no loss arising from any alleged overstay.

    The demand for £90 is punitive, unreasonable, exceeds an appropriate amount
    has no relationship to the loss that would have been suffered by the Landowner, and is therefore an unenforceable penalty. Furthermore, it exceeds the BPA’s own Code of Practice.
    The BPA Code of Practice states:
    19.5 If the parking charge that the driver is being asked to pay is for a breach of contract or act of trespass, this charge must be based on the genuine pre-estimate of loss that you suffer.
    19.6 If your parking charge is based upon a contractually agreed sum, that charge cannot be punitive or unreasonable.
    The appellant requires Athena ANPR to provide a detailed breakdown of how the amount of the charge was calculated. I am aware from Court rulings and previous POPLA adjudications that the cost of running the business may not be included in these pre-estimates of loss.

    POPLA Assessor Matthew Shaw has stated that the entirety of the parking charge must be a genuine pre-estimate of loss in order to be enforceable. For example, were no breach to have occurred, then the cost of parking enforcement, such as erecting signage, would still have been the same. The estimate must be based upon loss flowing from a breach of the parking terms, and in this instance there was no such loss.

    I therefore respectfully request that my appeal is upheld and the
    charge dismissed.

    2. No Creditor identified on the Notice to Appellant

    Failing to include specific identification as to who ‘the Creditor’ may be is misleading and not compliant in regard to paragraph 9(2)(h) of Schedule 4 of the Protection of Freedoms Act 2012. Whilst the Notice has indicated that the operator requires a payment to Athena ANPR, there is no specific identification of the Creditor who may, in law, be Athena ANPR or some other party. The Protection of Freedoms Act requires a Notice to Appellant to have words to the effect that ‘The Creditor is…’ and the Notice does not.

    I therefore respectfully request that my appeal is upheld and the charge dismissed.

    3. Lack of proprietary interest in the land and no authority to levy charges

    A parking management company will need to have the proper legal authorisation to contract with the consumer on the landowner’s behalf and enforce for breach of contract. The operator must produce evidence to demonstrate that it is the landowner, or a contract or other evidence that it has the authority of the landowner to issue charge notices at this location. The appellant believes there is no contract with the landowner/occupier that entitles Athena ANPR to levy these charges and to pursue these charges in their own name in the Courts and therefore has no authority to issue charge notices. When requested on appeal Athena ANPR failed to provide a copy of the contract.

    Athena ANPR Ltd is a member of the British Parking Association, and the BPA Code of Practice states, in Section 7.1, that the operator must have written authority from the landowner to recover parking charges, including pursuing through court action in their own name.

    I therefore put Athena ANPR Ltd to strict proof that they have the necessary authorisation at the location in question i.e. a relevant contemporaneous, non-redacted contract with the landowner (not an individual lessee or managing agent as they are another third party) to pursue these charges in the Courts in their own name as creditor. In the event that witness statements are submitted instead of the landowner contract itself, I require that this should be disregarded as insufficient to prove full BPA compliance.

    Even if a basic contract is produced and mentions Parking Charge Notices, I submit that such a contract is a commercial matter between the Operator and the owner/occupier and the lack of ownership or assignment of title or interest in the land reduces any such contract to one that exists simply on an agency basis between Athena ANPR Ltd and the owner/occupier. Such a contract would contain nothing that Athena ANPR Ltd can lawfully use in their own name as a mere agent, that could impact on a third party customer as it does not create any contractual relationship between Athena ANPR Ltd and motorists who used the land. A parking operator has no standing to bring the claim in their own name.

    I therefore respectfully request that my appeal is upheld and the charge dismissed.

    4. No contract

    There was no contract between the driver and Athena ANPR. The driver did not see any contractual information on any signs when entering the car park and therefore at that time had no idea that any contract or restrictions applied. As a consequence the requirements for forming a contract such as a meeting of minds, agreement, and certainty of terms were not satisfied. And even if there was a contract, which has yet to be proven, then it is unfair as defined in the Unfair Terms in Consumer Contracts Regulations 1999.

    I therefore respectfully request that my appeal is upheld and the charge dismissed.

    5. ANPR Accuracy

    Athena ANPR are obliged to ensure their ANPR equipment is maintained as described in paragraph 21.3 of the British Parking Association's Approved Operator Scheme Code of Practice. I require Athena ANPR to present records as to the dates and times of when the cameras at this car park were checked, adjusted, calibrated, synchronised with the timer which stamps the photos and generally maintained to ensure the accuracy of the dates and times of any ANPR images. This is important because the entirety of the charge is founded on two images purporting to show my vehicle entering and exiting at specific times. It is vital that Athena ANPR produce evidence in response to these points and explain to POPLA how their system differs (if at all) from the flawed ANPR system which was wholly responsible for the court loss by the operator in ParkingEye v Fox-Jones on 8 Nov 2013. That case was dismissed when the judge said the evidence form the Operator was 'fundamentally flawed' as the synchronisation of the camera pictures with the timer had been called into question and the operator could not rebut the point.

    So, in addition to showing their maintenance records, I require Athena ANPR to show evidence to rebut this point: I suggest that in the case of my car being in this Lidl car park, a local camera took the image but a remote server added the time stamp. As the two are disconnected by the internet and do not have a common "time synchronisation system", there is no proof that the time stamp added is actually the exact time of the image. The operator appears to use WIFI which introduces a delay through buffering, so "live" is not really "live". Hence without a synchronised time stamp there is no evidence that the image is ever time stamped with an accurate time. Therefore I contend that this ANPR "evidence" from Athena ANPR in this Lidl car park is just as unreliable as the ParkingEye system and I put Athena ANPR to strict proof to the contrary.

    In addition to this the BPA code of practice states the following:

    "21 Automatic number plate recognition (ANPR)

    21.1 You may use ANPR camera technology to manage, control and enforce parking in private car parks, as long as you do this in a reasonable, consistent and transparent manner. Your signs at the car park must tell drivers that you are using this technology and what you will use the data captured by ANPR cameras for."

    Athena ANPR fail to operate the system in a 'reasonable, consistent and transparent manner'. As Athena ANPR place signs too high to see on arrival, there is no opportunity for drivers in moving traffic at the entrance to be 'informed that this technology is in use and what the Operator will use the data captured by ANPR cameras for'. I contend that as well as being unreliable, this is a non-compliant ANPR system being merely a secret high-up spy camera - far from 'transparent' - unreasonably 'farming' the data from moving vehicles at the entrance & exit and neither 'managing, enforcing nor controlling parking' since the cameras are not concerned with any aspect of the actual parking spaces, nor any parking event at all.

    This concludes my appeal, I respectfully request that my appeal be upheld and the charge be dismissed if Athena ANPR fail to address and provide the necessary evidence as requested in the points highlighted above.



    Yours Sincerely,
    XXXX


    Thank you
  • ColliesCarerColliesCarer Forumite
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    That looks ready to go to me
  • da_ruleda_rule Forumite
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    Looks good and ready to go.
  • Wood182Wood182 Forumite
    4 Posts
    Hi all,

    Just thought you might like to know the outcome of this.

    Interestingly, I heard nothing from Athena ANPR after sending this - they did not send any evidence at all, I don't know if this has happened before or if they've decided just to give up on account of their persistent losses.

    Anyway, since no evidence was provided about what the parking conditions were, the assessor had no option but to allow the appeal.

    So thanks very much for your help, all! It's greatly appreciating. Does this kind of thing happen often, where they don't even bother to send evidence?
  • trisontanatrisontana Forumite
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    It appears that several PPC's no longer bother to submit evidence when a strong POPLA appeal has been made. It's just a numbers game to them as enough people believe their threats and just pay up.
    What part of "A whop bop-a-lu a whop bam boo" don't you understand?
  • edited 14 July 2014 at 11:16AM
    FruitcakeFruitcake Forumite
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    edited 14 July 2014 at 11:16AM
    Wood182 wrote: »
    Hi all,

    Just thought you might like to know the outcome of this.

    Interestingly, I heard nothing from Athena ANPR after sending this - they did not send any evidence at all, I don't know if this has happened before or if they've decided just to give up on account of their persistent losses.

    Anyway, since no evidence was provided about what the parking conditions were, the assessor had no option but to allow the appeal.

    So thanks very much for your help, all! It's greatly appreciating. Does this kind of thing happen often, where they don't even bother to send evidence?

    Not offering evidence is becoming more commonplace when the PPC sees a POPLA appeal like yours and realises they are going to lose.

    Well done on your win, and well done on doing it by reading up about the process first. :T Please will you post a redacted copy of the result on the POPLA Decisions thread so others may benefit by using yours.

    http://forums.moneysavingexpert.com/showthread.php?t=4488337
    I married my cousin. I had to...
    I don't have a sister. :D
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