`
`PREJUDGMENT REMEDY
`
`DOCKET NO:
`
`BARNEBY, SEBASTIAN, Et Al.
`
`V.
`
`DISHMAN, DORIS, Et Al.
`
`:
`
`'
`
`SUPERIOR COURT
`
`JUDICML DISTRICT OF
`DANBURY
`
`AT DANBURY V
`
`APRIL 22, 2021 '
`
`PROPOSED COMPLAINT
`
`Now come the Plaintiffs, SEBASTIAN BARNEBY, ERIN CUMMINS, and
`SEBASTIAN BARNEBY, DERIVATIVELY ON BEHALF OF LUTLEY & DUCHENE,
`
`LLC, by and through their undersigned counsel, as and for their Complaint against the
`Defendants, DORIS DISHMAN and! LUTLEY & DUCHENE, LLC.
`
`GENERAL ALLEGATIONS
`
`1.
`
`3 Plaintiff SEBASTIAN BARNEBY (“Barneby”) is a resident of the State of
`
`Connecticut.
`
`2.
`
`Plaintiff ERIN CUMMINS (“Cummins”)
`
`is a resident of
`
`the State of .
`
`Connecticut.
`
`3.
`
`Plaintiff LUTLEY & DUCHENE, LLC (the “Company”), brought derivatively I
`
`by SEBASTLAN BARNEBY, is a Connecticut limited liability company with a registered
`business address of 148 Saint Johns Road, Ridgefield, CT, 06877 (Plaintiffs Barneby and the
`Company collectively hereinafter the “Plaintiffs”)l.
`
`4.
`
`Defendant DORIS DISHMAN is a resident of the State of Connecticut
`
`(“Dishman”).
`
`
`
`
`
`5.
`
`Defendant LUTLEY & DUCHENE, LLC (also the “Company”)
`
`is a
`
`Connecticut limited liability company with a registered business address of 148 Saint Johns
`
`Road, Ridgefield, CT, 06877.
`
`’
`
`6.
`
`Barneby is a licensed real estate salesperson and both he and Dishman created I
`
`the Company in or about September of 2008 for the purposes of establishing a real estate
`
`brokerage firm.
`
`\
`
`7.
`
`Pursuant to the Company’s Operating Agreement and/or the agreement between
`
`Barneby and Dishman, the Company is a member managed LLC and was'to be managed by
`
`Dishman.
`
`8.
`
`9.
`
`Barneby and Dishman are the only members of the Company.
`
`‘
`
`Barneby has a forty-nine percent (49%) ownership interest in the Company and
`
`Dishman has a fifty-one percent (51%) ownership interest in the same.
`\
`10.
`Pursuant to the Company’s Operating Agreement and/or the agreement
`
`between Barneby and Dishman, Barneby and Dishman were entitled to a pro-rata share of all
`
`Company profits and/or net proceeds commensurate with their ownership interest in the same.
`
`11.
`
`In addition to his ownership interest in the Company, Barneby was employed
`
`and/or otherwise retained by the Company as a real estate salesperson.
`
`12.
`
`Cummins was also employed and/or otherwise retained by the Company as a real
`
`estate salesperson.
`
`13.
`
`Barneby and Curmnins operated as a team relating to their employment or
`
`retention with the Company.
`
`14.
`
`Pursuant to an agreement between the parties, Barneby and Cummins were to
`
`
`
`
`
`contribute annually 30% of the first $100,000.00 of their collective net real estate sales
`
`commissions to the Company to be utilized towards, the Company’s operating expenses, after
`
`which time they were entitled to keep 100% of their colle'ctivesales commissions for the
`
`remaining calendar year (the “Commissions Cap”).
`
`15.
`
`In or about February of 2020, Dishman informed Bamebyand/or Cummins,
`
`among other things, that she intended to dissolve the Company effective September 1, 2020.
`
`16.
`
`In connection therewith, Dishman also informed Barneby and/or Cummins,
`
`among other things:
`
`a. That she intended to issue termination notices in connection with Bameby
`
`and Cumrhins’ employment or retention with the Company; and
`
`b. Dishman would transfer all of Bameby and Cummins’ ongoing, not yet
`
`closed Company transactions to them, in their entirety, after September 1,
`
`2020.
`
`17.
`
`On or about August 10, 2020, Dishman caused a signed termination notice to be
`
`delivered to Bameby and/or Cummins informing them that the Company was terminating their
`
`employment and that both Bameby and Cummins were entitled to a transfer of all of their
`
`ongoing, not yet closed Company transactions, in their entirety, after September 1, 2020.
`
`18.
`
`'At or about that time, Bameby and Cummins had already reached their .
`
`Commissions Cap for the year and the Company and/or Dishman acknowledged the same in
`
`writing.
`
`19.
`
`On or about August 27, 2020, Bameby presented the Company and/or
`
`Dishman with information reflecting, among other things, that Barneby and/or. Cummins were
`
`
`
`
`
`then currently engaged in certain ongoing, not yet closed Company sales transactions valued at
`
`approximately $125,000.00 (the “Transactions”).
`
`20.
`
`At or about that time, Bameby requested that Dishman and/or the Company
`
`transfer the Transactions to Bameby and/or Cummins and/or their authorized agent consistent
`
`with Dishman’s representation and/or obligation to do so.
`
`21.
`
`In response thereto, Dishman informed Bameby, among other things:
`
`a. That the Company was entitled to retain 30% of Bameby and
`
`Cummins’ Transactions, despite previously acknowledging in writing
`that Baineby and Cummins reached their Commission Cap for 2020;
`
`and
`
`b. That the Company was entitled to retain 30% of Bameby and
`
`Cummins” Transactions, despite previously informing themthat the
`
`Transactions would be transferred to them, in their entirety, after
`
`September 1, 2020.
`
`22.
`Dishman further informed Bameby, among other things, that she would not
`transfer the Transactions to either Bameby or Cummins, nor would she compensate them for
`
`the same, unless and until Barneby transferred his 49% ownership interest in the Company to,
`her.
`I
`
`23.
`
`Dishman’s attempt to perform a “bait and switch” on Bameby and/or Cummins
`
`was improper and/or unlawful and was subsequently rejected.
`
`24.
`
`Barneby and Cummins relied upon Dishman’s representations to their detriment.
`
`More specifically, and by way of articulation and not limitation, Bameby and Cummins turned
`
`
`
`down or otherwise electing not to pursue other professional opportunities in anticipation that the
`Transactions would be transferred to them.
`
`25.
`
`The Company and/or Dishman failed, refused, and/or neglected to transfer the
`
`Transactions to either Bameby or Cummins consistent with their representation and/or
`
`obligation to do so.
`
`26.
`
`‘Upon information and belief, the Company and/or Dishman closed on the
`
`Transactions.
`
`27.
`
`Notwithstanding the foregoing, the Company and/or Dishman failed, refused,
`
`and/or neglected to compensate Bameby or Cummins for the Company’s Transactions in
`
`violation of their agreement.
`
`28.
`
`On 0r about November 13, 2020, Dishman and/or the Company terminated
`
`Bameby and Cummins’ employment with the Company.
`
`29.
`
`Subsequently, Barneby, in his capacity as 49% owner of the Company,
`
`emanded a complete accounting of the Company’s records.
`
`/ d
`
`30.
`
`31.
`
`Dishinan and/or the Company refused to provide Bameby with the same.
`
`In response thereto, Bameby obtained a copy of the Company’s financial
`
`records from the Company’s banking institution and discovered, among other things, that
`
`Dishman had been using the Company’s funds, deposited in the Company’s bank account, for
`
`her own personal use over the course of many years. More specifically, and by Way of
`
`articulation and not limitation, Dishman wrongfully utilized Company funds, without
`
`authorization, in order to:
`
`a.
`
`Issue checks to herself for her personal use without also distributing
`
`\x
`
`
`
`
`
`
`
`funds to Barneby consistent with his 49% ownership interest in the
`
`Company or otherwise accounting for the same;
`
`b. Purchase personal items from online retailers; and
`
`0. Hire landscapers to perform landscaping services at her residential
`
`home.
`
`32.
`Moreover, upon further investigation by Barneby, it was discovered that
`Dishman created a competing brokerage firm, Saint Johns LLC, which she used to usurp
`
`corporate opportunity from the Company.
`
`33.
`
`Dishman further used Company assets to fund, support, and/or otherwise
`
`finance said competing brokerage firm.
`
`34.
`
`(
`The Company has suffered harm as a result of Dishman’s conduct as
`
`aforestated.
`
`35.
`
`Due to the fact that Dishman is the only other member of the Company, and
`
`further due to the fact that she is the controlling member of the same, demand upon the
`
`Company that Bamebyrbe permitted to proceed derivatively in this action should be excused
`as futile.
`.
`
`COUNT ONE: CONVERSION (ON BEHALF OF SEBASTIAN BARNEBY DIRECTED TOWARD
`DORIS DISHMAN)
`
`1-35. Paragraphs
`
`1-35 of
`
`the General Allegations of
`
`the Complaint
`
`are
`
`incorporated herein by specific reference as if more expressly set forth herein.
`
`36.
`
`Dishman and/or the Company failed, refused, and/or neglected to distribute
`
`Bameby’s pro—rata share of Company profits to him consistent with their obligation to do so.
`
`
`
`
`
`
`
`
`
`
`
`37.
`
`Dishman wrongfully and without authorization converted and
`
`misappropriated funds from the Company and/or Barneby for her own gain and benefit.
`
`38.
`
`The misappropriated funds belonged to the Company and/or Barneby, in that
`
`the Company and/or Barneby had both a legal and possessory right to the same.
`
`39.
`
`In diverting the funds for her own use, Dishman deprived the Company
`
`and/or Barneby Of their property for an indefinite period Of time.
`
`40.
`
`Dishman’s conduct in diverting the funds was unauthorized.
`
`41.
`
`As a result Of said erngful conversion and misappropriation Of funds by
`
`Dishman, Barneby has been damaged tO his loss and detriment.
`
`COUNT TWO: CONVERSION (ON BEHALF OF LUTLEY & DUCHENE, LLC DIRECTED 4
`TOWARD DORIS DISHMAN)
`1-41. Paragraphs 1-41 Of Count One Of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`42.
`
`As a result Of said wrongful conversion and misappropriation Of funds by
`
`Dishman, the Company has been damaged to its loss and detriment.
`
`COUNT THREE: STATUTORY THEFT (ON BEHALF OF SEBASTIAN BARNEBY
`DIRECTED TOWARD DORIS DISHMAN)
`
`1—42. Paragraphs 1—42 Of Count Two Of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`43.‘
`
`Statutory theft is synonymous with larceny under CGS 53a-119 which provides
`
`in relevant parti “[a] person commits larceny when, with intent tO deprive another Of property
`
`or tO appropriate the same to himself or a third person, he wrongfully takes, Obtains or
`
`withholds such property from an owner.”
`
`
`
`
`
`
`
`44.
`
`Defendant Dishman intended to deprive Barneby and/or the Company of
`
`Company funds and profits.
`
`V
`
`45.
`
`Defendant Dishman appropriated Barneby and/or the Company’s funds to ,
`
`herself
`
`‘
`
`’\
`
`\
`
`46.
`
`Defendant Dishman wrongfully withheld company funds and profits from
`
`Barneby to his damage and detriment.
`
`COUNT FOUR: STATUTORY THEFT (ON BEHALF OF LUTLEY & DUCHENE, LLC
`DIRECTED TOWARD DORIS DISHMAN)
`.
`
`1-46. Paragraphs 1.446 of Count Three of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth “herein.
`47.
`Defendant Dishman wrongfully withheld Company funds and profits from the
`
`Company toits damage and detriment.
`
`COUNT FIVE: BREACH OF FIDUCIARY DUTY (ON BEHALF OF SEBASTIAN
`BARNEBY DIRECTED TOWARD DORIS DISHMAN)
`'
`
`1-47. Paragraphs 1-47 of Count Four of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`48.
`
`Dishman owed a fiduciary duty to Bameby and/or the Company to manage the
`
`Company’s affairs honestly and loyally and consistent with her duty of good faith and fair
`
`dealing and not to engage in her own self-interest or enrichment.
`
`49.
`
`Dishman, by her conduct as aforestated, among other things, breached the
`
`fiduciary duties she owes Barneby and/or the Company.
`
`50.
`
`. Barneby has been damaged by a direct and proximate result Of'Dishman’s
`
`breach of her fiduciary duties.
`
`
`
`
`
`
`
`
`
`COUNT SIX: BREACH OF FIDUCIARY DUTY (ON BEHALF [OF LUTLEY &
`DUCHENE, LLC DIRECTED TOWARD DORIS DISHMAN)
`
`1-50. Paragraphs 1-50 of Count Five of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`51.
`
`The Company has been damaged by a direct and proximate result of
`
`Dishman’s breach of her fiduciary duties.
`
`COUNT SEVEN: BREACH OF CONTRACT (ON BEHALF OF SEBASTIAN BARNEBY
`DIRECTED TOWARD DORIS DISHMAN)
`
`1-51. Paragraphs 1-51 of Count Six of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`52.
`
`By failing, refusing, and/or otherwise neglecting to transfer the Transactions to
`
`Barneby or Cummins, Dishman breached her extant agreement With them.
`
`53.
`
`By failing, refusing, and/or otherwise neglecting to compensate Bameby or
`
`Cummins for the Transactions, Dishman breached her extant agreement with them.
`
`54.
`
`By failing, refusing, and/or otherwise neglecting to distribute Barneby’s pro-
`
`rata Share of Company profits to him, Dishman breached her extant agreement with Bameby.
`
`55.
`
`As a resultofDishman’s conduct as aforestated, Bameby has suffered harm
`
`thereby.
`
`COUNT. EIGHT: BREACH OF CONTRACT (ON BEHALF OF ERIN CUMMINS
`DIRECTED TOWARD DORIS DISHMAN) .
`
`1-55. Paragraphs 1-55 of Count Seven of the Complaint are incorporated herein by
`
`Specific reference as if more eXpressly set forth herein.
`
`'
`
`56.
`
`As a result of Dishman’s conduct as aforestated, Cummins has suffered harm
`
`
`
`
`
`
`
`thereby.
`
`COUNT NINE: VIOLATION OF THE COVENANT OF GOOD FAITH AND FAIR DEALING (ON
`BEHALF OF SEBASTIAN BARNEBY DIRECTED TOWARD DORIS DISHMAN)
`
`1-56. Paragraphs 1—56 of Count Eight of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`57.
`
`Dishman, through calculation and design, and With dishonest purpose and/or
`
`sinister motive, has, among other things, purposefully refused to perform, honor, and/OI
`otherwise fulfill her obligations under her agreement with Barneby and Cummins in bad faith.
`
`58.
`
`By her conduct as aforestated, Dishman has breached the covenant of good faith
`
`_ and fair dealing.
`
`59.
`
`As a direct and proximate result of Dishman’s conduct, Barneby suffered and
`
`continues to suffer harm.
`
`COUNT TEN: VIOLATION OF THE COVENANT OF GOOD FAITH AND FAIR DEALING (ON
`BEHALF OF ERIN CUMMINS DIRECTED TOWARD DORIS DISHMAN)
`
`1-59. Paragraphs 1-59 of Count Nine of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`60.
`
`As a direct and proximate result of Dishman’s conduct, Cummins suffered and
`
`continues to suffer harm.
`
`COUNT ELEVEN: DIVERSION 0F CORPORATE OPPORTUNITIES (ON BEHALF OF LUTLEY
`& DUCHENE, LLC DIRECTED TOWARD DORIS DISHMAN)
`
`1-60. Paragraphs 1-60 of Count Ten of the Complaint are incorporated herein by
`
`specific reference as if more expressly set forth herein.
`
`61.
`
`Saint Johns LLC, the brokerage firm created by Dishman, performs similar
`
`business services as the Company.
`
`10
`
`
`
`
`
`
`62.
`
`The Company has or had an interest or an expectancy growing out of an
`
`existing contractual right which was usurped by Dishman and/or Saint Johns LLC.
`
`63.
`
`There was or is a close relationship between the Company’s opportunity and
`
`the Company’s business purposes and current activities.
`
`64.
`
`The business areas contemplated by the Company’s opportunity were readily
`
`adaptable to the Company’s existing business,
`
`in light of its fundamental knowledge,
`
`practical experience, facilities, equipment, and personnel. I recall that this count was not
`
`applicable for some reason.
`
`/J
`
`65.
`
`As arresult of Dishman’s conduct as aforestated, the Company has suffered
`
`harm.
`
`COIlNT TWELVE: DISSOLUTION OF LUTLEY & DUCHENE, LLC
`1-65. Paragraphs 1—65 of Count Eleven of the Complaint are incorporated herein
`
`by specific reference as if more expressly setdforth herein.
`
`I 66.
`
`Barneby and Dishman are unable to come to a consensus regarding the
`
`management of the Company or concerning a dissolution thereof.
`
`67.
`
`i
`
`If the Company is not dissolved, irreparable injury is threatened to the
`
`Company and/or will continue to be'suffered by the Company.
`
`68.
`
`69.
`
`Dishman has aCted or will act in a manner that is illegal or fraudulent.
`
`Dishman has acted or is acting in a manner that isoppressive and was, is, or
`
`will be directly harmful to Barneby.
`
`70.
`
`Based upon Dishman’s conduct as aforestated, it is not reasonably practicable
`
`to carry on the Company's activities and affairs.
`
`11
`
`
`
`71.
`
`Barneby seeks dissolution of the Company pursuant to Conn. Gen. Stat. § 34-
`
`267.
`
`COUNT THIRTEEN: ACTION FOR ACCOUNTING
`
`1—71. Paragraphs 1-71 of Count Twelve of the Complaint are incorporated herein
`
`by specific reference as if more expressly set forth herein.
`
`72.
`
`Although Barneby has demanded an accounting of the Company’s activities,
`
`the Defendants have failed, refused, and/or neglected to give Barneby such an accounting.
`
`73.
`
`Barneby is entitled to the Company’s accounting.
`
`74.
`
`As provided in Conn. Gen. Stat. § 52-401, the foregoing actions give rise to
`
`an obligation on the part of the Defendants to account to the Plaintiffs for Company
`
`transactions.
`
`12
`
`
`
`
`
`WHEREFORE, the Plaintiffs claim:
`
`AS TO COUNT ONE
`
`1.
`
`2.
`
`3.
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prejudgment and post judgment interest;
`Reasonable attomeys’ fees andicosts of this action; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT TWO
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prejudgment and post judgment interest;
`
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT THREE
`
`Monetary damages;
`
`Punitive Damages;
`
`Statutory Treble Damages;
`
`Prejudgment and post judgment interest;
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`1.
`
`2.
`
`3 4
`
`5
`
`6
`
`.
`
`AS TO COUNT FOUR
`
`1.
`
`2.
`
`3.
`
`4.
`
`Monetary damages;
`
`Punitive Damages;
`
`Statutory Treble Damages;
`
`Prejudgment and post judgment interest;
`
`13
`
`
`
`
`
`5.
`
`6.
`
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT FIVE
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prejudgment and post judgment interest;
`
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT SIX
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prej udgment and post judgment interest;
`
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT SEVEN
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prejudgment and post judgment interest;
`
`Costs; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT EIGHT
`
`1.
`
`2.
`
`Monetary damages;
`
`Punitive Damages;
`
`3.
`
`'
`
`Prejudgment and post judgment interest;
`
`5
`
`14
`
`
`
`
`
`
`
`4.
`
`5.
`
`Costs; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT NINE
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prejudgment and post judgment interest;
`
`Costs; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT TEN
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prejudgment and post judgment interest;
`
`Costs; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity
`
`AS TO COUNT ELEVEN
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Monetary damages;
`
`Punitive Damages;
`
`Prej udgment and post judgment interest;
`
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiff may be entitled at law or in equity.
`
`AS TO COUNT TWELVE
`
`1.
`2.
`
`3.
`
`An order dissolving the Company pursuant to C.G.S. § 34-267(a)(4)(B);
`An order dissolving the Company pursuant to C.G.S. § 34—267(a)(5)(A);
`
`The appointment of a receiver to wind up the affairs of the Company and distribute its
`
`15
`
`
`
`
`
`assets;
`
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiffs may be entitled at law or in equity.
`
`4.
`
`5.
`
`AS TO COUNT THIRTEEN
`
`1.
`
`2.
`
`3.
`
`4.‘
`
`5.
`
`That the Court appoint an auditor or another licensed professional of the Court’s
`selection‘to perform an accounting of the Company’s records as of the date of
`Judgment;
`
`Payment of the fees and the expenses of the auditor undertaking the accounting
`pursuant to Conn. Gen. Stat. § 52-402(d);
`
`That the Court enter a Supplemental Judgment after the completion of the accounting
`and enter orders in accordance with the findings of said accounting;
`
`Reasonable attorneys’ fees and costs of this action; and
`
`Such other and further relief to which the Plaintiff maybe entitled at law or in equity.
`
`
`
`16
`
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`PREJUDGMENT REMEDY
`DOCKET NO: .
`
`BARNEBY, SEBASTIAN, Et Al.
`
`V.
`
`.
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`DISHMAN, DORIS, Et Al.
`
`\\
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`:
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`-
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`SUPERIOR COURT ‘
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`JUDICIAL DISTRICT OF
`DANBURY
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`AT DANBURY
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`APRIL 22, 2021
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`STATEMENT OF AMOUNT IN DEMAND
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`The amount in demand, exclusive of interest and costs, is in excess of Fifteen Thousand
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`Dollars ($15,000.00).
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`THE PLAINTIFFS
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`BY:
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`*
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`David W. Rubin, Esq.
`, Jonathan D. Jacobson, Esq.
`The Law Offices of David W. Rubin
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`600 Summer Street — Suite 201
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`Stamford, CT 06901
`Telephone: (203) 353-1404
`Facsimile:
`(203) 357-7208
`Juris No. 421191 .
`
`Their Attorneys
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`17
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