throbber
Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 1 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 1 of 14
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
`— against —
`
`PREVEZON HOLDINGS LTD.,
`PREVEZON ALEXANDER, LLC,
`PREVEZON SOHO USA, LLC,
`PREVEZON SEVEN USA, LLC,
`PREVEZON PINE USA, LLC,
`
`PREVEZON 1711 USA, LLC,
`PREVEZON 1810, LLC,
`PREVEZON 2009 USA, LLC,
`PREVEZON 2011 USA, LLC,
`FERENCOI
`INVESTMENTS, LTD.,
`KOLEVINS, LTD.,
`
`Defendants,
`
`:
`
`:
`
`:
`
`STIPULAEION AND ORDER
`
`No. 13 Civ. 6326 (WHP)
`
`ECF Case
`
`ALL RIGHT, TITLE AND INTEREST
`IN THE REAL PROPERTY AND
`
`APPURTENANCES KNOWN AS THE 20
`
`PINE STREET CONDOMINIUM, 20
`
`PINE STREET, NEW YORK, NEW YORK
`10005, UNIT 1816 (“20 PINE
`STREET, UNIT 1816"),
`
`:
`:
`:
`
`ANY AND ALL FUNDS ON DEPOSIT IN
`BANK OF AMERICA ACCOUNT NUMBER
`
`**********8293 HELD IN THE NAME
`
`OF PREVEZON ALEXANDER LLC (THE
`
`“PREVEZON ALEXANDER ACCOUNT”),
`
`ANY AND ALL FUNDS ON DEPOSIT IN
`BANK OF AMERICA ACCOUNT NUMBER
`**********8084 HELD IN THE NAME
`
`OF PREVEZON SOHO USA LLC (THE
`
`“PREVEZON SOHO ACCOUNT”),
`
`ANY AND ALL FUNDS ON DEPOSIT IN
`
`BANK OF AMERICA ACCOUNT NUMBER
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 2 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 2 of 14
`
`oa.
`:
`
`:t
`
`.
`:
`
`**********6021 HELD IN THE NAME
`
`OF PREVEZON SEVEN USA LLC (THE
`
`“PREVEZON SEVEN ACCOUNT”),
`
`ANY AND ALL FUNDS ON DEPOSIT IN
`BANK OF AMERICA ACCOUNT NUMBER
`**********8349 HELD IN THE NAME
`
`OF PREVEZON 1711 USA, LLC {THE
`“PREVEZON 1711 ACCOUNT”),
`
`ANY AND ALL FUNDS ON DEPOSIT IN
`BANK OF AMERICA ACCOUNT NUMBER
`
`**********9102 HELD IN THE NAME
`
`OF PREVEZON 2009 USA, LLC (THE
`“PREVEZON 2009 ACCOUNT”),
`
`ANY AND ALL FUNDS 0N DEPOSIT IN
`BANK OF AMERICA ACCOUNT NUMBER
`
`**********8242 HELD IN THE NAME
`
`OF PREVEZON PINE USA, LLC (THE
`“PREVEZON PINE ACCOUNT”),
`
`ANY AND ALL FUNDS ON DEPOSIT IN
`BANK OF AMERICA ACCOUNT NUMBER
`
`**********5882 HELD IN THE NAME
`
`OF PREVEZON 2011 USA, LLC (THE
`“PREVEZON 2011 ACCOUNT”),
`
`ANY AND ALL FUNDS ON DEPOSIT IN
`
`BANK OF AMERICA ACCOUNT NUMBER
`**********9128 HELD IN THE NAME
`
`OF PREVEZON 1810 USA, LLC (THE
`“PREVEZON 1810 ACCOUNT"),
`
`APPROXIMATELY $1,379,518.90
`HELD BY THE UNITED STATES AS A
`
`SUBSTITUTE RES FOR ALL RIGHT,
`TITLE AND INTEREST IN THE REAL
`PROPERTY AND APPURTENANCES
`
`KNOWN AS THE 20 PINE STREET
`
`CONDOMINIUM, 20 PINE STREET,
`NEW YORK, NEW YORK 10005, UNIT
`2009 (THE “20 PINE STREET, UNIT
`2009 SALE PROCEEDS”),
`
`APPROXIMATELY $4,429,019.44
`HELD BY THE UNITED STATES AS A
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 3 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 3 of 14
`
`SUBSTITUTE RES FOR ALL RIGHT,
`TITLE AND INTEREST IN THE REAL
`
`PROPERTY AND APPURTENANCES
`
`KNOWN AS ALEXANDER CONDOMINIUM,
`250 EAST 49th STREET, NEW YORK,
`NEW YORK 10017, UNIT COMM3
`{THE
`“250 EAST 49th STREET, UNIT
`COMM3 SALE PROCEEDS”),
`
`APPROXIMATELY $1,046,530.04
`HELD BY THE UNITED STATES AS A
`
`SUBSTITUTE RES FOR ALL RIGHT,
`TITLE AND INTEREST IN THE REAL
`
`PROPERTY AND APPURTENANOES
`KNOWN AS THE 20 PINE STREET
`
`CONDOMINIUM, 20 PINE STREET,
`NEW YORK, NEW YORK 10005, UNIT
`2308 (THE “20 PINE STREET, UNIT
`2308 SALE PROCEEDS"),
`
`APPROXIMATELY $894,026.21 HELD
`BY THE UNITED STATES AS A
`
`SUBSTITUTE RES FOR ALL RIGHT,
`TITLE AND INTEREST IN THE REAL
`PROPERTY AND APPURTENANCES
`
`KNOWN AS THE 20 PINE STREET
`
`CONDOMINIUM, 20 PINE STREET,
`NEW YORK, NEW YORK 10005, UNIT
`
`1711 (THE “20 PINE STREET, UNIT
`1711 SALE PROCEEDS”),
`
`A DEBT OF 3,068,946 EUROS OWED
`BY AFI EUROPE N.V. To PREVEZON
`
`HOLDINGS RESTRAINED BY THE
`GOVERNMENT OF THE NETHERLANDS
`
`ON OR ABOUT JANUARY 22, 2014
`(THE “AFI EUROPE DEBT”),
`
`and all property traceable
`thereto,
`
`Defendants in Rem.
`
`WHEREAS, on September 10, 2013,
`
`the United States commenced
`
`this action (the “Action”), upon the filing of a verified complaint
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 4 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 4 of 14
`
`(the
`
`“Complaint”)
`
`seeking
`
`forfeiture of
`
`the
`
`above—captioned
`
`Defendants in Rem,
`
`and other assets,
`
`in personam claims against
`
`the aboveucaptioned Defendants, and other relief, and on September
`
`11, 2013,
`
`this Court entered a protective order restraining any
`
`and all assets of the Defendants;
`
`WHEREAS, on December 3 and 20, 2013, Denis Katsyv (“Katsyv”),
`
`IKR, Martash Holdings
`
`(“Martash”),
`
`Prevezon Holdings, Ltd.
`
`(“Prevezon Holdings”),
`
`Prevezon Alexander,
`
`LLC
`
`(“Prevezon
`
`Alexander”), Prevezon Soho USA, LLC (“Prevezon Soho”), Prevezon
`
`Seven USA,
`
`LLC
`
`(“Prevezon Seven”),
`
`Prevezon Pine USA,
`
`LLC
`
`(“Prevezon Pine”), Prevezon 1711 USA,
`
`LLC
`
`(“Prevezon 1111”),
`
`Prevezon 1810,
`
`LLC
`
`(“Prevezon 1810”), Prevezon 2009 USA,
`
`LLC
`
`(“Prevezon 2009”),
`
`and Prevezon 2011 USA,
`
`LLC (“Prevezon 2011,”
`
`together with Prevezon Holdings, Prevezon .Alexander, Prevezon
`
`Soho, Prevezon Seven, Prevezon Pine, Prevezon 1711, Prevezon 1810,
`
`and Prevezon 2009 the “Prevezon Entities”), Ferencoi Investments,
`
`Ltd.
`
`(“Ferencoi”), and Kolevins, Ltd.
`
`(“Kolevins”) filed claims to
`
`certain property;
`
`WHEREAS on or about January 22, 2014,
`
`the Government of the
`
`Netherlands, pursuant
`
`to a request for legal assistance from the
`
`United States
`
`in connection with this
`
`case,
`
`restrained the
`
`Defendant
`
`in Rem AFI EurOpe Debt
`
`and that property remains
`
`restrained;
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 5 of 14
`Case 1:13-ov-O6326-WHP Document 715-1 Filed 05/12/17 Page 5 of 14
`
`WHEREAS,
`
`on November 5, 2014,
`
`the United States filed an
`
`amended. verified complaint
`
`(the “Amended Complaint”),
`
`and the
`
`Court issued an amended protective order
`
`(the “Amended Protective
`
`Order”);
`
`WHEREAS, on December 19, 2014, Denis Katsyv,
`
`IKR, Martash,
`
`Prevezon Holdings, Prevezon .Alexander, Prevezon. Soho, Prevezon
`
`Seven, Prevezon Pine, Prevezon 1711, Prevezon 1810, Prevezon 2009,
`
`and Prevezon 2011 (the “Claimants") filed certain claims;
`
`WHEREAS, on September 9, 2015, Defendants and Claimants gave
`
`notice pursuant to 28 U.S.C. §§ 26?2, 26?5 and 28 C.F.R. Part 14
`
`of potential administrative claims against the United States, and
`
`they further assert that they may have rights to additional claims
`
`under
`
`the Civil Asset Forfeiture Reform Act of 2000
`
`(P.L. 106-
`
`185);
`
`WHEREAS, on October 23, 2015, the United States filed a second
`
`amended verified complaint
`
`(the “Second Amended Complaint”);
`
`WHEREAS, pursuant
`
`to Supplemental Rule G(4)(a)(iv)(C),
`
`the
`
`Complaint and Amended Complaint were published for at
`
`least 30
`
`consecutive days on an. official. government
`
`internet site,
`
`and
`
`pursuant
`
`to Supplemental Rule G(4)(b)(i), notice was sent
`
`to all
`
`persons who reasonably appeared to be potential claimants on the
`
`facts known to the Government, and no other parties filed claims
`
`to any of
`
`the Defendants
`
`in Rem in the Complaint or Amended
`
`Complaint, and all time to do so has expired; and
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 6 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 6 of 14
`
`WHEREAS,
`
`the parties desire to consensually resolve this
`
`case on the terms set forth herein;
`
`IT IS HEREBY STIPULATED AND AGREED, by and between the United
`
`States,
`
`by
`
`its attorney,
`
`Joon H. Kim, Acting United States
`
`Attorney, of counsel, Assistant United States Attorneys Paul M.
`
`Monteleoni, Cristine I. Phillips, and Tara M. La Morte, of counsel,
`
`and the Defendants and Claimants, by their attorneys, Faith E.
`
`Gay, Esq., Quinn Emanuel Urquhart & Sullivan LLP,
`
`that:
`
`l.
`
`The following terms shall have the definitions set
`
`forth herein:
`
`a.
`
`b.
`
`c.
`
`“Complaints” means the original Verified Complaint,
`the Amended Verified Complaint, and the Second Amended
`Verified Complaint filed in this Action.
`
`“Restrained Properties" means the Defendants in Rem
`named in this Action.
`
`“United States" or “Government” means the Plaintiff
`the United States of America.
`
`2.
`
`The purpose of this Stipulation and Order is to
`
`memorialize a settlement agreement pursuant to which the United
`
`States will release all of its claims or potential claims
`
`against all Defendants relating to this Action and release all
`
`Restrained Properties, and all Defendants and Claimants will
`
`release all their Claims or potential claims against the United
`
`States relating to this Action. Upon the completion of the
`
`conditions set forth herein,
`
`the Amended Protective Order shall
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 7 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 7 of 14
`
`be vacated as to all Defendants and all Restrained Properties,
`
`and the Second Amended Complaint shall be dismissed against all
`
`Defendants with prejudice.
`
`3.
`
`Upon entry of the Stipulation and Order,
`
`the
`
`Government shall inform the Government of the Netherlands that
`
`this matter has been resolved and that the Government withdraws
`
`any request for the Government of the Netherlands to continue to
`
`restrain the AFI Europe Debt, and shall request that the
`
`Government of the Netherlands lift the restraint of the AFI
`
`Europe Debt that had been implemented at the request of the
`
`United States.
`
`The Amended Protective Order shall be deemed
`
`modified to allow the release of the AFT Europe Debt.
`
`4.
`
`For the purpose of settlement only, Defendant Prevezon
`
`Holdings will make a payment to the United States consisting of
`
`$5,896,333.65 in United States currency (the “Payment”).
`
`The
`
`Payment shall be due within 15 business days of the release by
`
`the Government of the Netherlands of the AFI Europe Debt and
`
`shall be made by electronic funds transfer pursuant to written
`
`instructions to be provided by the United States Attorney’s
`
`Office for the Southern District of New York. Upon receipt,
`
`the
`
`Payment shall be deposited into the U.S. Treasury pursuant to
`
`the Miscellaneous Receipts Act, 31 U.S.C. § 3302, which
`
`authorizes deposits of public money into the U.S. Treasury, and
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 8 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 8 of 14
`
`does not constitute a forfeiture pursuant to 18 U.S.C.
`
`§ 981(a) (l) (A) -
`
`5.
`
`Upon the Government's receipt of the Payment,
`
`the
`
`Government shall advise the governments of all countries from
`
`whom the Government has sought assistance in connection with its
`
`investigation via Mutual Legal Assistance requests,
`
`including
`
`Switzerland, Latvia, Lithuania, Estonia, Ukraine, and Russia,
`
`that this case has been settled, and provide them a copy of this
`
`Stipulation and Order.
`
`The Government shall also, if requested
`
`by any Party hereto, provide a copy of this Stipulation and
`
`Order to any other branch, department, or agency of the United
`
`States and to any other foreign government or court.
`
`6.
`
`The Parties agree that this Stipulation and Order is
`
`for the purposes of settlement only and nothing in this
`
`Stipulation and Order, nor any act
`
`(including, but not limited
`
`to,
`
`the execution of this Stipulation and Order and/or
`
`fulfillment of the consideration for this Stipulation and Order)
`
`of any Party hereto, nor any transaction occurring between any
`
`Parties hereto prior to the date hereof,
`
`is or shall be treated,
`
`construed, or deemed in any way as an admission by Defendants,
`
`Claimants, Denis Katsyv, Alexander Litvak, or Timofey Krit,
`
`for
`
`any purpose whatsoever, all such liability, fault,
`
`responsibility, and wrongdoing of any kind being expressly
`
`denied by the Defendants, Claimants, Denis Katsyv, Alexander
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 9 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 9 of 14
`
`Litvak, and Timofey Krit, and they specifically deny that the
`
`events described in the Complaints as to them occurred as
`
`described therein.
`
`7.
`
`The Government and the Defendants, Claimants, Denis
`
`Katsyv, Alexander Litvak, and Timofey Krit have decided to
`
`resolve their claims against each other through this Stipulation
`
`and Order.
`
`The Parties further agree that none of the funds
`
`used for the Payment are being paid by or on behalf of any of
`
`the Defendants other than Defendant Prevezon Holdings,
`
`including
`
`but not limited to Ferencoi or Kolevins.
`
`Pursuant to the laws
`
`of the United States,
`
`this Stipulation and Order constitutes a
`
`compromise of disputed claims and should not be construed as any
`
`evidence as to the merits of any of the claims asserted in the
`
`Complaints or of any defenses to those claims. This Stipulation
`
`and Order is not
`
`intended to have any legal effect on any other
`
`pending proceeding in any jurisdiction.
`
`8.
`
`The Parties agree that the Complaints do not allege
`
`that any of the Defendants, Claimants, or Denis Katsyv,
`
`Alexander Litvak, or Timofey Krit,
`
`is responsible, directly or
`
`indirectly, for the arrest, detention, or death of Sergei
`
`Magnitsky, or that they have acted as an agent of, on behalf of
`
`or in agreement with a person in a matter relating to the
`
`arrest, detention, or death of Sergei Magnitsky.
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 10 of 14
`Case 1:13-ov-O6326-WHP Document 715-1 Filed 05/12/17 Page 10 of 14
`
`9.
`
`This Stipulation and Order is intended to fully and
`
`finally resolve all pending claims made by the United States in
`
`the Action relating to the Defendants. Accordingly,
`
`the United
`
`States hereby releases all Defendants, Claimants (including IKR
`
`and Martash), and their current and former subsidiaries,
`
`affiliates, predecessors, successors, and assigns, and their
`
`current and former shareholders, predecessors, successors,
`
`assigns, related entities,
`
`joint ventures, partners, principals,
`
`investors, directors, officers, employees, agents, heirs,
`
`administrators, representatives, attorneys, and managers,
`
`including but not limited to Denis Katsyv, Alexander Litvak, and
`
`Timofey Krit
`
`(“Released Parties”),
`
`from any and all claims,
`
`suits, causes of action, and related liabilities,
`
`including
`
`without limitation costs, expenses, penalties, and attorneys’
`
`fees, concerning, arising out of, or resulting from the
`
`allegations in the Complaints or the facts and matters pleaded
`
`in this Action, or any actions taken by or on behalf of any of
`
`the Released Parties in connection with the allegations in the
`
`Complaints or the facts and matters pleaded in this Action.
`
`10.
`
`The Defendants, Claimants, Denis Katsyv, Alexander
`
`Litvak, and Timofey Krit hereby release the U.S. Attorney's
`
`Office for the Southern District of New York,
`
`the Department of
`
`Homeland Security, Homeland Security Investigations, and their
`
`current and former officers, employees, agents, administrators,
`
`10
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 11 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 11 of 14
`
`representatives, attorneys, and managers (“Government Released
`
`Parties”) from any and all claims, suits, causes of action, and
`
`related liabilities,
`
`including without limitation costs,
`
`expenses, penalties, and attorneys’ fees, concerning, arising
`
`out of, or resulting from,
`
`the filing of this Action or the
`
`United States’ seizure, restraint, and/or constructive
`
`possession of the properties named in the Complaints,
`
`including,
`
`without limitation, any claim that the United States did not
`
`have probable cause to seize or restrain the Restrained
`
`Properties, that the Defendants, Claimants, Denis Katsyv,
`
`Alexander Litvak, or Timofey Krit are prevailing parties, or
`
`that the Defendants, Claimants, Denis Katsyv, Alexander Litvak,
`
`or Timofey Krit are entitled to attorneys'
`
`fees or any award of
`
`interest; and further agree to hold harmless the Government
`
`Released Parties from any and all thirdeparty claims of
`
`ownership of any of the Defendants in Rem. This release shall
`
`not affect Defendants’ rights or claims against any person other
`
`than the Government Released Parties.
`
`11. Upon the Government's receipt of the Payment,
`
`the
`
`Amended Protective Order shall be vacated as to all Restrained
`
`Properties,
`
`the Court shall order the Restrained Properties
`
`returned to the Claimants, and the Action shall be dismissed
`
`against all Defendants with prejudice.
`
`ll
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 12 of 14
`Case 1:13-cv-O6326—WHP Document 715-1 Filed 05/12/17 Page 12 of 14
`
`12.
`
`Each Party to this Stipulation and Order will bear its
`
`own costs and attorneys’
`
`fees.
`
`13. All Parties agree to waive all rights to appeal or
`
`otherwise challenge or contest the validity of this Stipulation
`
`and Order.
`
`14.
`
`The signatories to this Stipulation and Order each
`
`represent that they are duly authorized to sign this Stipulation
`
`and Order.
`
`15. This Stipulation and Order represents the complete
`
`agreement of the Parties hereto.
`
`16.
`
`The signature page of this Stipulation and Order may
`
`be executed in one or more counterparts, each of which will be
`
`deemed an original but all of which together will constitute one
`
`12
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 13 of 14
`Case 1:13-cv-O6326-WHP Document 715-1 Filed 05/12/17 Page 13 of 14
`
`and the same instrument.
`
`Facsimiles or electronic copies shall
`
`be treated as originals.
`
`JOON H. KIM
`
`Acting United States Attorney for
`the Southern District of New York
`
`Attorney for Plaintiff
`
` UL M.
`
`ONTELEONI
`
`CRISTINE I. PHILLIPS
`TARA M. LA MORTE
`
`Assistant United States Attorneys
`One St. Andrew’s Plaza
`
`New York, New York 10007
`Tel.:
`(212) 637—2219
`
`Fax:
`
`(212) 637—0421
`
`PREVEZON HOLDINGS, LTD., PREVEZON ALEXANDER, LLC, PREVEZON SOHO
`
`USA, LLC, PREVEZON SEVEN USA, LLC, PREVEZON PINE USA, LLC,
`PREVEZON 1711 USA, LLC, PREVEZON 1810, LLC, PREVEZON 2009 USA,
`LLC, PREVEZON 2011 USA, LLC,
`
`By:
`
`DENIS KATSYV,
`
`ER
`
`DATE
`
`DENIS KATSYV
`
`DENIS KATSYV
`
`IKR
`
`By:
`
`DENIS KATSYV,
`
`_/_
`
`NER
`
`2.06? 2.0!?
`[
`DATE
`
`DATE
`
`13
`
`

`

`Case 1:13-cv-06326-WHP Document 715-1 Filed 05/12/17 Page 14 of 14
`Case 1:13-cv-O6326—WHP Document 715-1 Filed 05/12/17 Page 14 of 14
`
`MARTASH HOLDINGS
`
`By:M 11%
`
`DENIS KATSYV, OWNER
`
`DATE
`
`KOLEVINS LTD.
`
`By: M
`
`DENIS KATSYV, L
`
`L REPRESENTATIVE
`
`
`
`122.05. 201%
`
`DATE
`
`11.9520”
`
`DATE
`
`FERENCOI
`
`INVESTMENTS, LTD.
`
`By: M 4
`
`DENIS KATSYV, 0
`
`R
`
`QUINN EMANUEL URQUHART & SULLIVAN LLP
`
`DATE E. GAY, ESQ.
`
`95... 21M 3"
`
`to PREVEZON HOLDINGS, LTD., PREVEZON ALEXANDER, LLC,
`Counsel
`PREVEZON SOHO USA, LLC, PREVEZON SEVEN USA, LLC, PREVEZON PINE
`
`USA, LLC, PREVEZON 1711 USA, LLC, PREVEZON 1810, LLC, PREVEZON
`2009 USA, LLC, PREVEZON 2011 USA, LLC, DENIS KATSYV, MARTASH
`HOLDINGS,
`IKR, FERENCOI, and KOLEVINS
`
`SO ORDERED:
`
`THE HONORABLE WILLIAM H. PAULEY III
`UNITED STATES DISTRICT JUDGE
`
`DATE
`
`l4
`
`

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