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Help to set aside a CCJ for a parking ticket
Whispersun
Posts: 8 Forumite
Hi all,
I’m seeking some advice about a CCJ for parking ticket - I have read many posts and gone through the procedure recommended by many, and now I am a little stuck as to what to do next. I do apologise in advance if I have missed posts which cover my scenario.
Background
- Moved house last year.
- Updated driving licence and V5.
- Redirected post.
- Updated addresses.
- Went to pick up post from old address to find out I have a CCJ filed against me for a parking ticket over a year ago.
- Contacted county court to find out details - they provided me with n244 to appeal.
- Double checked my credit rating as did not even believe this was real, but it is.
- Emailed for SAR from Parking Company DPO.
- Contacted solicitors to inform contact with their client for SAR.
- Solicitors have informed if I can supply evidence of address change they can contact their client to see what they can do - I can’t imagine they can remove the CCJ now, or can they?
I have now received details of the ticket from the DPO;
- Vehicle was parked temporarily in Permit Holders Only Bay, which is in the same block as some Pay & Display Bays, also next to a sign on the road which says Pay & Display - very sneaky indeed.
- Photos show the vehicle in the bay for max 3 mins, though they state it was in there for longer.
- It was not me driving.
While waiting for a response from DPO I drafted a 6 point Draft Order and a Witness Statement, though I’m unsure how to finalise it, or if I need to remove anything.
In particular, I'm unsure as to what information should I add in section 1.4 on the WS, if anything about the detail I have received?
Also, should I request SAR from Solicitors or is it just the Parking Company?
I’d be very grateful for any advice. Please let me know if you require more details or specific timings.
——————————————
DRAFT ORDER
IN THE XXXXXXXXXX COUNTY COURT
Claim No. XXXXXXXXXX
BETWEEN:
XXXXXXXXX Claimant
-- and --
Miss XXXXXXXXXXX Defendant
It is ordered that:
1. The Judgment dated XX/XX/2019 be set aside.
2. The Defendant shall file and serve its Defence by 4pm following 14 days after the date on which the Judgment is set aside.
3. The Claimant do pay the Defendant's costs of this application to the sum of £255.
4. The Claimant has permission to file and serve a reply if so required.
5. All enforcement be put on hold pending the outcome of the application.
——————————————
WITNESS STATEMENT
I am XXXXXXXXXX and I am the Defendant in this matter.
This is my supporting Statement in support of my application dated XX/XX/XXX to:
A. Set aside the Default Judgment dated XX/XX/XXXX as it was not served to my current address.
B. Order for the Claimant to pay the Defendant £255 as reimbursement for the set aside fee.
C. Order for the original claim to be dismissed.
1. Default Judgment
1.1. I understand that the Claimant obtained a Default Judgment against me as the Defendant on XXXX2019. However, this claim form has not been served at my current address, therefore I was not aware of the Default Judgment until XX/XX/2019 when old mail was collected from a previous address XXXXXX. I understand that this Claim was served at XXXXXX. However, I moved to a new address XXXXXX on XXXX2018. In support of this I can provide confirmation from XXX Council showing my updated details for the purposes of paying Council tax, completion statement from solicitors, mortgage statement, V5C log book which shows the details of the registered keeper.
1.2. I have also never received any previous documentation from the Claimant in this matter and therefore I was never able to properly challenge the Claimant’s claim.
1.3. On the XXXX2019 I contacted Northampton County Court to find out details of the Default Judgment and if it had been filed against me. They emailed some particulars of the claim and informed it had been filed against me.
1.4 On XXXX2019 I emailed the data protection officer at Parking Firm XXX with a subject access request, requesting all details they have regarding any alleged incidents. What details should I include here, if any?
1.5. I believe the Claimant has behaved unreasonably in pursuing a claim against me without ensuring they held the Defendant’s current and correct contact details, especially considering they had good reason to believe they did not hold my current contact details having received no response from me to their correspondence to the address XXXXXXXXX. According to publicly available information my circumstances are far from being unique. The Claimant’s persistent failure to use correct and current addresses results is an unnecessary burden for individuals and the justice system across the country.
1.6. On the basis provided above I would suggest that the Claimant did not fulfil their duty to use the Defendant’s current address when bringing the claim.
1.7. Considering the above I was unable to defend this claim properly. I believe that the Default Judgment against me was issued incorrectly and should be set aside.
2. Order dismissing the Claim
2.1. I further believe that the original Claim by the Claimant has no merit and should therefore be dismissed. I understand that the Claimant is a Parking Company which seeks to claim for “Parking Charge Notices” which the Claimant believes are due as a result of an alleged breach of contract for parking by a driver.
2.2. If the Claimant has obtained details of the vehicle for which the Defendant is the Registered Keeper, and used those details to make a claim for a “Parking Charge Notice’’, I therefore dispute the claim in its entirety as I do not know the wording of the contract nor do I know the means by which the contract was alleged to come into force.
2.3. If the Claimant can evidence that the alleged incident relates to a vehicle for which the Defendant is the Registered Keeper, any Notice to Keeper served by the Claimant would have needed to comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012. Otherwise, the Claimant is required to prove the driver of the vehicle they claim was involved in the alleged incident. I submit that the Claimant cannot provide such evidence and further submit that the Claimant does not include ‘Protection of Freedoms Act 2012’ wording on the Parking Charge Notices they issue and therefore cannot hold the Defendant automatically liable for the alleged incident merely for being the Registered Keeper of a vehicle.
2.4. A requirement of the Protection of Freedoms Act 2012 is that this any Notice to Keeper served by the Claimant must be served within 14 days of the date of the alleged incident. Since I have not received any documentation from the Claimant prior to finding out about the Default Judgment, I submit the Claimant will not have complied with the requirements of the Act and therefore cannot claim this charge against me as the Registered Keeper in any case.
2.5. I further submit that the Claimant’s claim is without merit due to substantial issues in law. This is for the following main reasons:
2.5.1. Lack of Standing by Claimant: The Claimant is unlikely to be the landowner of the car park in question, and will have no proprietary interest in it. This means that the Claimant, as a matter of law, will have no locus standi to litigate in their own name. Any consideration will have been provided by the landholder, and only they would have been able sue for any damages or trespass.
2.5.2. No Loss Suffered by Claimant: Their claim is presumably based on damages for alleged breach of contract. It is a fundamental principle of English Law that a party who suffers damages through breach of contract can only seek through court action to be put back in the same position as they would have been if the breach had not occurred. In order to do so, they must demonstrate their actual, or genuine, pre-estimate of loss. I submit that no loss has been suffered by the Claimant as a result of any alleged breaches of contract on the part of any motorist of the vehicle of which I am the Registered Keeper. I further submit that any loss to the landholder (which would be the only party able to claim such losses) would be at most a few pounds.
2.5.3. Claimed charge is an Unenforceable Penalty: I further submit that the Parking Charge that the Claimant claimed, given it is not based on any loss suffered due to the alleged breach, is nothing but an unenforceable penalty.
2.5.4. No contract with the claimant: Any contract must have offer, acceptance and consideration both ways. There would not have been consideration from the Claimant to the motorist; the fee for parking benefits the landowners, not the Claimant. Therefore, there is no consideration from the motorist to the Claimant.
2.6. On this basis I believe that the Claimant has not provided any reasonable cause of action and therefore the claim should be dismissed in its entirety.
2.7. In order to make informed decisions and statements in my defence as keeper of the a vehicle, I will require copies of all paperwork and pictures of all signs from the Claimant.
Statement of Truth:
I believe that the facts stated in this Witness Statement are true.
Full name: xxxxxxxxxxxxxx
Dated: XXXXXXXXXX
Signed: ________________________________
I do hope someone can take a look and advice, thanks in advance.
I’m seeking some advice about a CCJ for parking ticket - I have read many posts and gone through the procedure recommended by many, and now I am a little stuck as to what to do next. I do apologise in advance if I have missed posts which cover my scenario.
Background
- Moved house last year.
- Updated driving licence and V5.
- Redirected post.
- Updated addresses.
- Went to pick up post from old address to find out I have a CCJ filed against me for a parking ticket over a year ago.
- Contacted county court to find out details - they provided me with n244 to appeal.
- Double checked my credit rating as did not even believe this was real, but it is.
- Emailed for SAR from Parking Company DPO.
- Contacted solicitors to inform contact with their client for SAR.
- Solicitors have informed if I can supply evidence of address change they can contact their client to see what they can do - I can’t imagine they can remove the CCJ now, or can they?
I have now received details of the ticket from the DPO;
- Vehicle was parked temporarily in Permit Holders Only Bay, which is in the same block as some Pay & Display Bays, also next to a sign on the road which says Pay & Display - very sneaky indeed.
- Photos show the vehicle in the bay for max 3 mins, though they state it was in there for longer.
- It was not me driving.
While waiting for a response from DPO I drafted a 6 point Draft Order and a Witness Statement, though I’m unsure how to finalise it, or if I need to remove anything.
In particular, I'm unsure as to what information should I add in section 1.4 on the WS, if anything about the detail I have received?
Also, should I request SAR from Solicitors or is it just the Parking Company?
I’d be very grateful for any advice. Please let me know if you require more details or specific timings.
——————————————
DRAFT ORDER
IN THE XXXXXXXXXX COUNTY COURT
Claim No. XXXXXXXXXX
BETWEEN:
XXXXXXXXX Claimant
-- and --
Miss XXXXXXXXXXX Defendant
It is ordered that:
1. The Judgment dated XX/XX/2019 be set aside.
2. The Defendant shall file and serve its Defence by 4pm following 14 days after the date on which the Judgment is set aside.
3. The Claimant do pay the Defendant's costs of this application to the sum of £255.
4. The Claimant has permission to file and serve a reply if so required.
5. All enforcement be put on hold pending the outcome of the application.
——————————————
WITNESS STATEMENT
I am XXXXXXXXXX and I am the Defendant in this matter.
This is my supporting Statement in support of my application dated XX/XX/XXX to:
A. Set aside the Default Judgment dated XX/XX/XXXX as it was not served to my current address.
B. Order for the Claimant to pay the Defendant £255 as reimbursement for the set aside fee.
C. Order for the original claim to be dismissed.
1. Default Judgment
1.1. I understand that the Claimant obtained a Default Judgment against me as the Defendant on XXXX2019. However, this claim form has not been served at my current address, therefore I was not aware of the Default Judgment until XX/XX/2019 when old mail was collected from a previous address XXXXXX. I understand that this Claim was served at XXXXXX. However, I moved to a new address XXXXXX on XXXX2018. In support of this I can provide confirmation from XXX Council showing my updated details for the purposes of paying Council tax, completion statement from solicitors, mortgage statement, V5C log book which shows the details of the registered keeper.
1.2. I have also never received any previous documentation from the Claimant in this matter and therefore I was never able to properly challenge the Claimant’s claim.
1.3. On the XXXX2019 I contacted Northampton County Court to find out details of the Default Judgment and if it had been filed against me. They emailed some particulars of the claim and informed it had been filed against me.
1.4 On XXXX2019 I emailed the data protection officer at Parking Firm XXX with a subject access request, requesting all details they have regarding any alleged incidents. What details should I include here, if any?
1.5. I believe the Claimant has behaved unreasonably in pursuing a claim against me without ensuring they held the Defendant’s current and correct contact details, especially considering they had good reason to believe they did not hold my current contact details having received no response from me to their correspondence to the address XXXXXXXXX. According to publicly available information my circumstances are far from being unique. The Claimant’s persistent failure to use correct and current addresses results is an unnecessary burden for individuals and the justice system across the country.
1.6. On the basis provided above I would suggest that the Claimant did not fulfil their duty to use the Defendant’s current address when bringing the claim.
1.7. Considering the above I was unable to defend this claim properly. I believe that the Default Judgment against me was issued incorrectly and should be set aside.
2. Order dismissing the Claim
2.1. I further believe that the original Claim by the Claimant has no merit and should therefore be dismissed. I understand that the Claimant is a Parking Company which seeks to claim for “Parking Charge Notices” which the Claimant believes are due as a result of an alleged breach of contract for parking by a driver.
2.2. If the Claimant has obtained details of the vehicle for which the Defendant is the Registered Keeper, and used those details to make a claim for a “Parking Charge Notice’’, I therefore dispute the claim in its entirety as I do not know the wording of the contract nor do I know the means by which the contract was alleged to come into force.
2.3. If the Claimant can evidence that the alleged incident relates to a vehicle for which the Defendant is the Registered Keeper, any Notice to Keeper served by the Claimant would have needed to comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012. Otherwise, the Claimant is required to prove the driver of the vehicle they claim was involved in the alleged incident. I submit that the Claimant cannot provide such evidence and further submit that the Claimant does not include ‘Protection of Freedoms Act 2012’ wording on the Parking Charge Notices they issue and therefore cannot hold the Defendant automatically liable for the alleged incident merely for being the Registered Keeper of a vehicle.
2.4. A requirement of the Protection of Freedoms Act 2012 is that this any Notice to Keeper served by the Claimant must be served within 14 days of the date of the alleged incident. Since I have not received any documentation from the Claimant prior to finding out about the Default Judgment, I submit the Claimant will not have complied with the requirements of the Act and therefore cannot claim this charge against me as the Registered Keeper in any case.
2.5. I further submit that the Claimant’s claim is without merit due to substantial issues in law. This is for the following main reasons:
2.5.1. Lack of Standing by Claimant: The Claimant is unlikely to be the landowner of the car park in question, and will have no proprietary interest in it. This means that the Claimant, as a matter of law, will have no locus standi to litigate in their own name. Any consideration will have been provided by the landholder, and only they would have been able sue for any damages or trespass.
2.5.2. No Loss Suffered by Claimant: Their claim is presumably based on damages for alleged breach of contract. It is a fundamental principle of English Law that a party who suffers damages through breach of contract can only seek through court action to be put back in the same position as they would have been if the breach had not occurred. In order to do so, they must demonstrate their actual, or genuine, pre-estimate of loss. I submit that no loss has been suffered by the Claimant as a result of any alleged breaches of contract on the part of any motorist of the vehicle of which I am the Registered Keeper. I further submit that any loss to the landholder (which would be the only party able to claim such losses) would be at most a few pounds.
2.5.3. Claimed charge is an Unenforceable Penalty: I further submit that the Parking Charge that the Claimant claimed, given it is not based on any loss suffered due to the alleged breach, is nothing but an unenforceable penalty.
2.5.4. No contract with the claimant: Any contract must have offer, acceptance and consideration both ways. There would not have been consideration from the Claimant to the motorist; the fee for parking benefits the landowners, not the Claimant. Therefore, there is no consideration from the motorist to the Claimant.
2.6. On this basis I believe that the Claimant has not provided any reasonable cause of action and therefore the claim should be dismissed in its entirety.
2.7. In order to make informed decisions and statements in my defence as keeper of the a vehicle, I will require copies of all paperwork and pictures of all signs from the Claimant.
Statement of Truth:
I believe that the facts stated in this Witness Statement are true.
Full name: xxxxxxxxxxxxxx
Dated: XXXXXXXXXX
Signed: ________________________________
I do hope someone can take a look and advice, thanks in advance.
0
Comments
-
Your six point draft order only has five points.I drafted a 6 point Draft Order...
This post includes the six points you need:
https://forums.moneysavingexpert.com/showpost.php?p=75364394&postcount=170 -
Thanks for spotting Keith, I’ll adjust accordingly
0 -
This is the adjust 6 Point Draft I shall use...
It is ordered that:!
1. The default Judgment dated XX/XX/2019 be set aside.
2. Costs to be reserved.
3. Unless the Claimant serves a copy of the claim form on the Defendant by 4pm on XX/XX/19 paragraph 2 shall cease to have effect and the Claimant shall pay the Defendant's costs summarily assessed at £255 and the claim shall be struck out.
4. If the Claimant serves the claim form as directed in paragraph 3 the Defendant shall file and serve a defence by 4pm on XX/XX/2019.
5. Should the Claimant discontinue the Claim after the CCJ is set aside, paragraph 2 shall cease to have effect and the Claimant shall pay the Defendant's costs summarily assessed at £255 plus the Defendant's costs for attending the hearing.
6. All enforcement be put on hold pending the outcome of the application.0 -
Any advice please? Is this fine as it is or do I need to add anything extra? Thanks0
-
This bit of the WS is not OK and needs deleting!2.5.2. No Loss Suffered by Claimant: Their claim is presumably based on damages for alleged breach of contract. It is a fundamental principle of English Law that a party who suffers damages through breach of contract can only seek through court action to be put back in the same position as they would have been if the breach had not occurred. In order to do so, they must demonstrate their actual, or genuine, pre-estimate of loss. I submit that no loss has been suffered by the Claimant as a result of any alleged breaches of contract on the part of any motorist of the vehicle of which I am the Registered Keeper. I further submit that any loss to the landholder (which would be the only party able to claim such losses) would be at most a few pounds.
https://forums.moneysavingexpert.com/discussion/comment/75916480#Comment_75916480PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top or bottom of any page where it says:
Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
Thanks for taking a look Coupon-mad, I’ll remove accordingly.
The parking firm have agreed to set the judgment aside with a consent order, provided I make a payment - judgment amount of £300+ and a £100 court fee.
If I make the payment they will draft the consent order for me to sign and send it back for them to countersign, and then file it with the court.
I’m hesitant to go down this route as I do not trust them, I’m concerned they will not carry the consent order through if I pay them. If they are true to their word I have another concern - what if the judge does not agree to set it aside. I believe I only get one chance and I’m wondering if I am better off just trying got set it aside myself.
All I want is for the CCJ to be removed and would be happy to pay the costs if I knew it would be set aside and didn’t have to go to court.
Any advice on what I should do in this situation?0 -
£400 is not a bargain. I would not do this, not least on principle. Bad example for your family for you to be seen to bend over for a scam. Not something I would do, especially as we are confident you will get this set aside without too much sweat.The parking firm have agreed to set the judgment aside with a consent order, provided I make a payment - judgment amount of £300+ and a £100 court fee.
We see all CCJs set aside here and have done for over a year. I can only recall ONE Judge not agreeing to a set aside (in 2017 I think) as the person failed to show that they didn't receive the claim form - that's all the Judge wants to know, really (plus that you have an arguable defence with some merit to it, and everyone does against these scams).All I want is for the CCJ to be removed and would be happy to pay the costs if I knew it would be set aside
The above will cost you £255 only.
You will need to attend for the set aside hearing, and can ask for the Judge to order the £255 against the Claimant, which they may or may not agree but if you convince the Judge then this will all cost you nowt to remove the CCJ.and didn’t have to go to court.
Which PPC?PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top or bottom of any page where it says:
Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
Thanks again for the support Coupon-mad, I really appreciate it. I’m nervous about having to attend court, but understand I should stand up to these fraudsters.
The PPC is One Parking Solution.0 -
0
-
Thanks KeithP.
Below is the final draft I plan to submit with the n244. Anyone for one last check please, I'm wondering if I need to add anything about the details I received from the DPO.
DRAFT ORDER
IN THE XXXXXXXXXX COUNTY COURT
Claim No. XXXXXXXXXX
BETWEEN:
XXXXXXXXX Claimant
-- and --
Mrs XXXXXXXXXXX Defendant
It is ordered that:
1. The default Judgment dated XX/XX/2019 be set aside.
2. Costs to be reserved.
3. Unless the Claimant serves a copy of the claim form on the Defendant by 4pm on XX/XX/19 paragraph 2 shall cease to have effect and the Claimant shall pay the Defendant's costs summarily assessed at £255 and the claim shall be struck out.
4. If the Claimant serves the claim form as directed in paragraph 3 the Defendant shall file and serve a defence by 4pm on XX/XX/2019.
5. Should the Claimant discontinue the Claim after the CCJ is set aside, paragraph 2 shall cease to have effect and the Claimant shall pay the Defendant's costs summarily assessed at £255 plus the Defendant's costs for attending the hearing.
6. All enforcement be put on hold pending the outcome of the application.
WITNESS STATEMENT
I am XXXXXXXXXX and I am the Defendant in this matter.
This is my supporting Statement in support of my application dated XX/XX/XXX to:
A. Set aside the Default Judgment dated XX/XX/XXXX as it was not served to my current address.
B. Order for the Claimant to pay the Defendant £255 as reimbursement for the set aside fee.
C. Order for the original claim to be dismissed.
1. Default Judgment
1.1. I understand that the Claimant obtained a Default Judgment against me as the Defendant on XXXX2019. However, this claim form has not been served at my current address, therefore I was not aware of the Default Judgment until XX/XX/2019 when old mail was collected from a previous address XXXXXX. I understand that this Claim was served at XXXXXX. However, I moved to a new address XXXXXX on XXXX2018. In support of this I can provide confirmation from XXX Council showing my updated details for the purposes of paying Council tax, completion statement from solicitors, mortgage statement, V5C log book which shows the details of the registered keeper.
1.2. I have also never received any previous documentation from the Claimant in this matter and therefore I was never able to properly challenge the Claimant’s claim.
1.3. I believe the Claimant has behaved unreasonably in pursuing a claim against me without ensuring they held the Defendant’s current and correct contact details, especially considering they had good reason to believe they did not hold my current contact details having received no response from me to their correspondence to the address XXXXXXXXX. According to publicly available information my circumstances are far from being unique. The Claimant’s persistent failure to use correct and current addresses results is an unnecessary burden for individuals and the justice system across the country.
1.4. On the basis provided above I would suggest that the Claimant did not fulfil their duty to use the Defendant’s current address when bringing the claim.
1.5. Considering the above I was unable to defend this claim properly. I believe that the Default Judgment against me was issued incorrectly and should be set aside.
2. Order dismissing the Claim
2.1. I further believe that the original Claim by the Claimant has no merit and should therefore be dismissed. I understand that the Claimant is a Parking Company which seeks to claim for “Parking Charge Notices” which the Claimant believes are due as a result of an alleged breach of contract for parking by a motorist.
2.2. If the Claimant has obtained details of the vehicle for which the Defendant is the Registered Keeper, and used those details to make a claim for a “Parking Charge Notice’’, I therefore dispute the claim in its entirety as I do not know the wording of the contract nor do I know the means by which the contract was alleged to come into force.
2.3. If the Claimant can evidence that the alleged incident relates to a vehicle for which the Defendant is the Registered Keeper, any Notice to Keeper served by the Claimant would have needed to comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012. Otherwise, the Claimant is required to prove the driver of the vehicle they claim was involved in the alleged incident. I submit that the Claimant cannot provide such evidence and further submit that the Claimant does not include ‘Protection of Freedoms Act 2012’ wording on the Parking Charge Notices they issue and therefore cannot hold the Defendant automatically liable for the alleged incident merely for being the Registered Keeper of a vehicle.
2.4. A requirement of the Protection of Freedoms Act 2012 is that this any Notice to Keeper served by the Claimant must be served within 14 days of the date of the alleged incident. Since I have not received any documentation from the Claimant prior to finding out about the Default Judgment, I submit the Claimant will not have complied with the requirements of the Act and therefore cannot claim this charge against me as the Registered Keeper in any case.
2.5. I further submit that the Claimant’s claim is without merit due to substantial issues in law. This is for the following main reasons:
2.5.1. Lack of Standing by Claimant: The Claimant is unlikely to be the landowner of the car park in question, and will have no proprietary interest in it. This means that the Claimant, as a matter of law, will have no locus standi to litigate in their own name. Any consideration will have been provided by the landholder, and only they would have been able sue for any damages or trespass.
2.5.2. Claimed charge is an Unenforceable Penalty: I further submit that the Parking Charge that the Claimant claimed, given it is not based on any loss suffered due to the alleged breach, is nothing but an unenforceable penalty.
2.5.3. No contract with the claimant: Any contract must have offer, acceptance and consideration both ways. There would not have been consideration from the Claimant to the motorist; the fee for parking benefits the landowners, not the Claimant. Therefore, there is no consideration from the motorist to the Claimant.
2.6. On this basis I believe that the Claimant has not provided any reasonable cause of action and therefore the claim should be dismissed in its entirety.
2.7. In order to make informed decisions and statements in my defence as keeper of the a vehicle, I will require copies of all paperwork and pictures of all signs from the Claimant.
Statement of Truth:
I believe that the facts stated in this Witness Statement are true.
Full name: xxxxxxxxxxxxxx
Dated: XXXXXXXXXX
Signed: ________________________________0
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