Cabot 24 Points

IN THE County Court at Northampton CCBC

CLAIM NO: H0C1234

BETWEEN:

Cabot Financial (UK) Limited

Claimant

-and

[NAME OF DEFENDANT]

Defendant

WITNESS STATEMENT

I, JULIAN KENT, am employed by Cabot Financial (Europe) Limited (“Cabot Financial (Europe)”), 16-22 Grafton Road, Worthing, West Sussex, BN11 1QP, will say as follows:

1. I am employed by Cabot Financial (Europe) as a Senior Operations Manager. Cabot Financial (UK) Limited, the Claimant, in these proceedings and Cabot Financial (Europe) are companies within the Cabot Group of Companies. The Claimant has appointed Cabot Financial (Europe) as the primary managing agent and servicer of the account held by the Defendant and Cabot Financial (Europe) continues to manage and service that account in that capacity.

2. Unless it is indicated to the contrary, all the facts and matters in this statement are true and to the best of my knowledge and belief and have come to my attention as I have had conduct of this case on behalf of the Claimant.

3. In this statement I will refer to various documents, true copies of which are contained in the paginated bundle exhibited to this statement marked “JK1”.

Background of the Claim

4. On or around 16/10/2013 the Defendant entered into a Credit Card Agreement, with New Day Ltd RE Aqua (the “Agreement”). A copy of the Agreement is contained in the paginated bundle at pages 1 to 4.

5. Despite requests by New Day Ltd RE Aqua the Defendant failed to make the required minimum repayments/exceeded the credit card limit, pursuant to the Agreement, and on 16/02/2017 New Day Ltd RE Aqua issued the Defendant with a Default Notice (copy enclosed at pages 5 to 7). The Defendant did not address the default and the Agreement was subsequently terminated. Upon termination of the Agreement the Defendant became liable to pay forthwith the full debt outstanding. The Defendant failed to pay the amount due. Enclosed at pages 8 to 63 are statements of account showing how the debt accrued.

6. On 07/08/2017 New Day Ltd RE Aqua assigned to the Claimant, absolutely, all amounts due from the Defendant to New Day Ltd RE Aqua pursuant to the Agreement. The Defendant was provided with notice of the said assignment on 30/08/2017. A copy of the Notice of Assignment is contained in the paginated bundle at pages 64 to 67.

7. The Claimant wrote to the Defendant to ask her to address the outstanding balance. Enclosed at pages 68 to 72 are copies of a selection of its letters. The Defendant did not make payments to address the balance.

8. As a result of no contact or payment from the Defendant, the Claimant instructed Mortimer Clarke Solicitors (‘MCS’) to commence legal proceedings against the Defendant. The Claimant understands that MCS wrote to the Defendant on 19/04/2021 to give notice of its instructions to issue a Claim. A copy of this letter can be found in the attached bundle at pages 73 to 82. The Defendant did not respond.

9. On 24/05/2021 County Court proceedings were issued against the Defendant(s) at County Court Business Centre. A copy of the claim is enclosed at page 83. The claim form was served by the Court to the Defendant’s current address of 108 Villars Street, Preston, PR1 7PB.

10. The Defendant filed her defence on 11/06/2021.

The Defendant’s defence

11. The Defendant alleges that the first time she heard from the Claimant is when she received the claim form. She states that she believes the debt may be statute barred. She also refers to her personal circumstances.

The Claimant’s position

12. On receipt of the defence, the Claimant considered the comments made by the Defendant and elected to allow these proceedings to become stayed whilst it obtained documentation from New Day Ltd RE Aqua and to enable the parties to conduct settlement negotiations.

13. In a letter dated 21/10/2021, MCS wrote to the Defendant to set out a point-by point response to the defence. For brevity, I will not copy the text of this response into this statement but instead refer to that letter. A copy of the letter is enclosed at pages 84 to 86. MCS asked the Defendant to provide clarification of her defence and evidence of her circumstances, but she did not respond.

14. It is the Claimant’s position that the Defendant has been provided ample documentation to evidence his/her liability for this debt. The Defendant has been provided with the documentation which would have been required to comply with any request for documentation pursuant to the Consumer Credit Act 1974 or Civil Procedure Rule 31.14.

Limitation

15. The Defendant claims the debt is statute barred. Section 5 of the Limitation Act 1980 provides that an action founded on simple contract shall not be brought after the expiration of six years from the date on which the cause of action accrued. However section 29(5) of the Limitation Act 1980 states:

“…Where any right of action has accrued to recover…any debt or other liquidated pecuniary claim…and the person liable or accountable for the claim acknowledges the claim or makes any payment in respect of it the right shall be treated as having accrued on and not before the date of the acknowledgment or payment.”

16.As evidenced in the attached transaction statement from New Day, the Defendant made numerous payments toward the outstanding balance with the last payment being received on 18/11/2016 for the sum of £98.96. A statement of account is contained in the paginated bundle at pages 8 to 63. The Claimant commenced proceedings on 24/05/2021 which is within the 6-year limitation period. As such, the Claimant’s position is that the claim is not statute barred and it is entitled to enforce the debt.

Opportunity to Respond

17. MCS wrote to the Defendant on 21/10/2021 fully responding to her defence and providing documentation from the original creditor in support of the Claimant’s claim. The letter additionally provided the Defendant with an opportunity to enter into settlement negotiations with the Claimant without the need for further court proceedings. The Defendant failed to respond. A copy of this letter is enclosed at pages 84 to 86.

18.On 16/09/2022 MCS wrote to the Defendant to inform her of the Claimant’s intention to make an application for Summary Judgment. A copy of this letter is enclosed at pages 87 to 88. The letter explained the potential costs consequences of such an application and invited the Defendant to discuss alternative settlement arrangements. The Defendant did not respond. 

Personal Circumstances

19. While the Claimant is sympathetic to the Defendant’s personal circumstances outlined in her defence, its position is that this does not impact her liability in this matter. The Claimant offered the Defendant an opportunity to provide evidence of her circumstances, however she did not respond.

20. The Claimant takes its customers ability to repay their debt very seriously. Once Judgment is obtained the Claimant will ensure to work with the Defendant to ensure her account is managed correctly. 

Summary

21. It is clear that the Defendant has no real dispute or defence to this debt. The Defendant does not deny entering into, making use of or defaulting on the outstanding balance, she merely believe it to be Statute Barred which the Claimant has evidenced is not true.

22. The documentation enclosed sufficiently evidences that the Defendant entered into the Agreement with Virgin, failed to make all of the agreed payments, and the outstanding debt has been assigned to the Claimant.

23. The Claimant has acted in good faith throughout these proceeding and has offered the Defendant ample opportunities to engage and address this matter on an amicable basis without Court Action.

Conclusion

24. For the reasons set out above I invite this Court to strike out the Defence and grant the Claimant Judgment in the sum claimed of £3959.94 together with fixed costs and costs to be summarily assessed.

STATEMENT OF TRUTH

I believe that the facts in this Witness Statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed:

Dated: 14/11/2022

Julian Kent

Ref: MC/JD/34505511

IN THE County Court at Northampton CCBC

CLAIM NO: H0C1234

BETWEEN:

Cabot Financial (UK) Limited

Claimant

-and

[NAME OF DEFENDANT]

Defendant

WITNESS STATEMENT

I,[NAME OF DEFENDANT], of [ADDRESS OF DEFENDANT]

, WILL SAY as follows:

1. I am the defendant in this case. The contents of this statement are true to the best of my knowledge, information and belief.

I make this witness statement in response in direct response to the claimants filing of a alleged witness statement of Julian Kent (the ‘Alleged Witness’) dated 14th November 2022 who's statement is based on his employment of a company called Cabot Financial (Europe).

The Alleged Witness bases their entire statement on hearsay evidence from the computer system of the Claimant and the computer system of Newday Ltd (the "Alleged Assignor"). The failure of such systems has been brought to light by the recent case of the sub-postmasters who were acquitted of fraud after false convictions based solely on the data from a computer system that generated erroneous data. This is relevant to the present case as it casts doubt on the reliability of computer systems and the evidence they generate. The case is R (on the application of Adams & Ors) v Post Office Ltd [2021] EWHC 1278 (QB). 

2.  The facts and matters set out in this witness statement are within my own knowledge unless otherwise stated and I believe them to be true.

It is disputed that the Alleged Witness can accurately claim to be a Witness to any of the matters within the Claimant's Alleged Witness Statement and the Defendant respectfully requests that the Court give no weight to the Claimant's Alleged Witness Statement as it is based entirely on hearsay.

It is my understanding that the Claimant must serve notice to any hearsay evidence pursuant to CPR 33.2(1)(B) (notice of intention to rely on hearsay evidence) and Section 2 (1) (A) of the Civil Evidence Act. The Defendant avers that no such notice has been served and respectfully asks the court to dismiss the Claimants claim which is entirely based on hearsay evidence.

3. Within this statement I refer to various documents, these are now produced in bundle marked (‘FMS1’). 

Background of the Claim

4. It is disputed that on or around 16/10/2013 the Defendant entered into a Credit Card Agreement, with New Day Ltd RE Aqua (the “Void Agreement”). It is disputed that the documents exhibited by the Claimant at pages 1 to 4 of the paginated bundle are a copy of the Void Agreement.

The Defendant avers that the document exhibited by the Claimant shows a date of 15/10/2013 and not the 16/10/2013 as claimed by the Alleged Witness. The Defendant has no recollection of entering into the Void Agreement. 

The Defendant has contacted the Alleged Assignor by email and they have stated that they have no record of such and account. See Exhibit ('FSM1') Pages 1-2.

The Defendant avers that the Void Agreement was void from the outset due to the failure of the Alleged Assignor to comply with Section 138D of the Financial Services and Markets Act 2000 ('FSMA 2000') and CONC 5.2A of the Consumer Credit Sourcebook, in respect of irresponsible lending. This argument is supported by the decision in Wilson v First County Trust Ltd (No 2) [2004] UKHL 22, which held that agreements which breach the provisions of FSMA 2000 and the Consumer Credit Act 1974 are unenforceable.

The Defendant avers that she did not enter into the agreement and was not in a position to be able to afford a loan when the Claimant claims that the Void Agreement was entered into. 

The Defendant further avers that the document relied on by the Claimant does not bear any signature and as such the Claimant is reliant on a simple tick in a box which provides no evidence of who entered into the Void Agreement. 

The Defendant avers that the Claimant is reliant on a simple electronic signature which provides no proof that the person clicking the button (it cannot be considered signing) is any particular individual or if they are agreeing to specific terms and conditions.

Additionally, as per the case law established in the "Parker v Taswell [2018] EWHC 2711 (Ch)" it was stated that the mere fact that a person has clicked on a box, or otherwise indicated assent to standard terms and conditions on a website, does not necessarily mean that they have given their informed consent to the specific terms of the contract.

The Defendant requests that the court takes into consideration that the Alleged Assignor failed to provide the Defendant with an opportunity to give her informed consent for the use of electronic signature, rendering the agreement unenforceable.

Carey v HSBC Bank Plc | [2009] EWHC 3417 (QB)

The Defendant further avers that Section 61(1)(a) and 127(3) of the Consumer Credit Act 1974 dictate that a creditor must be able to produce a signed document (not necessarily the credit agreement) that contains the prescribed terms. The document must include the credit limit, the interest rate and details of how and when a debtor is to discharge his payment obligations. 

The Defendant avers that the Claimant has failed to produce such a document and respectfully invited the Court to conclude that the  Void Agreement irredeemably unenforceable.

5. It is disputed that requests by the Alleged Assignor were made. It is disputed that the Defendant failed to make the required minimum repayments/exceeded the credit card limit, pursuant to the Void Agreement, and on 16/02/2017 the Alleged Assignor issued the Defendant with a Default Notice. It is disputed that the document exhibited by the Claimant at pages 5 to 7 of their paginated bundle are a copy of a Default notice sent to the Defendant. 

It is disputed that the Defendant did not address the default and the Void Agreement was subsequently terminated. It is disputed that upon termination of the Void Agreement the Defendant became liable to pay forthwith the full debt outstanding. It is disputed that the Defendant failed to pay the amount due. It is disputed that the documents exhibited by the Claimant at pages 8 to 63 are statements of account showing how the debt accrued.

The Claimant is required to prove that a compliant Default Notice was served in relation to the Alleged Agreement pursuant to Consumer Credit Act 1974 Sections. 87 & 88 (1).

The Defendant requests that the Claimant provide evidence of service of the Alleged Default Notice, such as a record of delivery or a witness statement from the person who served the notice. 

6. It is disputed that on 07/08/2017 the Alleged Assignor assigned to the Claimant, absolutely, all amounts due from the Defendant to the Alleged Assignor pursuant to the Void Agreement due the constraints of:

⦁ Section 44 of the Companies Act 2006 - (a Deed of Assignment requires TWO signatures from the Assignor);

⦁ Section 136 of the Law of Property Act 1925 - (An assignee cannot buy future debts, they must have a valid Deed of Assignment and notice must be 'GIVEN'); and;

⦁ Section 196 of the Law of Property Act 1925 - (Service of documents must be in writing).

The Claimant is required to provide the instrument of assignment ('Deed of Assignment'), upon which they rely. The Defendant invites the Court to conclude that any failure of the Claimant to provide the Deed of Assignment means that the Claimant is reliant solely on a claim of an Equitable Assignment and has no legal standing ('Locus Standi') to issue this claim. 

See: (National Westminster Bank plc v Spectrum Plus Ltd [2005] UKHL 41) - Where the House of Lords held that a claimant must prove their ownership of a chose in action in order to enforce it.

The Defendant avers that she has the right to see the Deed of Assignment as highlighted in this case:

See: (Van Lynn Developments v Pelias Construction Co Ltd [1969] 1 QB 607 Where Lord Denning MR said: 'After receiving the notice, the debtor will be entitled, of course, to require a sight of the assignment so as to be satisfied that it is valid, and that the assignee can give him a good discharge.'

and more recently in:  (Promontoria (Oak) Ltd v Emanuel & Others 2021 EWCA Civ 1682) 52.  'we agree with Lord Denning that he is entitled to satisfy himself that there has been such an assignment';

It is disputed that the Defendant was provided with notice of the said assignment on 30/08/2017. It is disputed that the document exhibited by the Claimant at pages 64 to 67 is a copy of the Notice of Assignment ('Alleged Notice of Assignment').

The Defendant requests that the claimants provide evidence of the service of the Alleged Notice of Assignment, such as a record of delivery or a witness statement from the person who served the notice. 

The Defendant avers that sole reliance on a Notice of Assignment does not give the Claimant the right to bring an action at law without joining the Alleged Assignor as a party to the action:

See: (Mitchell Mcfarlane & Partners Ltd v Foremans Ltd 2002) - 'Even If I had held that notice of assignment had not been given, I do not think that this would have made any difference. As an equitable assignee Foremans could not have brought an action at law without joining the assignor, old Foremans.'

7. It is disputed that the Claimant wrote to the Defendant to ask her to address the outstanding balance. It is disputed that the documents exhibited by the Claimant at pages 68 to 72 are copies of a selection of its letters. It is not disputed that the Defendant did not make payments to address the balance. It is disputed that any balance is owed to the Claimant or Alleged Assignor. 

8. It is disputed that as a result of no contact or payment from the Defendant, the Claimant instructed Mortimer Clarke Solicitors (‘MCS’) to commence legal proceedings against the Defendant. It is disputed that the Claimant understands that MCS wrote to the Defendant on 19/04/2021 to give notice of its instructions to issue a Claim. It is disputed that a copy of this letter can be found attached to the Claimant's bundle at pages 73 to 82. It is disputed that the Defendant did not respond as the Defendant disputes receiving any letters from the Claimant prior to the issue of the Claim Form in breach of Pre-Action Protocol.

The Defendant draws the Courts attention to Page 4 of exhibit ('FMS1') - which is copy of the email sent to the Claimant on 26th May 2021 denying that there was any agreement between the Defendant and Alleged Assignor.

9. It is a matter of record that on 24/05/2021 County Court proceedings were issued against the Defendant(s) at County Court Business Centre. It is not disputed that a copy of the claim is enclosed at page 83 of the Claimant's Alleged Witness bundle. It is not disputed that the claim form was served by the Court to the Defendant’s current address of 108 Villars Street, Preston, PR1 7PB.

10. It is not disputed that the Defendant filed her defence on 11/06/2021.

The Defendant’s defence

11. It is not disputed that the Defendant alleges that the first time she heard from the Claimant is when she received the claim form. It is not disputed that she states that she believes the debt may be statute barred. It is not disputed that she also refers to her personal circumstances.

The Claimant’s position

12. It is not disputed that on receipt of the defence, the Claimant considered the comments made by the Defendant and elected to allow these proceedings to become stayed. It is disputed that the Claimant allowed the proceedings to become stayed  whilst it obtained documentation from the Alleged Assignor and to enable the parties to conduct settlement negotiations. The Defendant avers that the Claimant as a bulk purchaser of lists of delinquent accounts and issues bulk claims without conducting any due diligence into the whether the lists of data purchased are accurate or not and as such gives little regard to costs  incurred by innocent parties or the Court time wasted in frivolous and unwarranted claims.

13. It is not disputed that in a letter dated 21/10/2021, MCS wrote to the Defendant to set out a point-by point response to the defence. For brevity, I will not copy the text of this response into this statement but instead refer to that letter. A copy of the letter is enclosed at pages 84 to 86. MCS asked the Defendant to provide clarification of her defence and evidence of her circumstances, but she did not respond.

The Defendant draws the Courts attention to Page 5 of Exhibit ('FMS1') which is an email sent to Mortimer Clarke on 21/10/2021 in response to their email of the same date. The Defendant advised the Claimant that she could not open the password protection communication and asked for the communication to be put into writing.

14. It is disputed that the Defendant has been provided ample documentation to evidence his/her liability for this debt. It is disputed that the Defendant has been provided with the documentation which would have been required to comply with any request for documentation pursuant to the Consumer Credit Act 1974 or Civil Procedure Rule 31.14. The Defendant avers that the Claimant has failed to provide any instrument of assignment, upon which they rely or any proof that a debt is owed to either the Alleged Assignor or the Claimant. 

Limitation

15. It is not disputed that the Defendant claims the debt is statute barred. It is agreed that Section 5 of the Limitation Act 1980 provides that an action founded on simple contract shall not be brought after the expiration of six years from the date on which the cause of action accrued. However section 29(5) of the Limitation Act 1980 states:

“…Where any right of action has accrued to recover…any debt or other liquidated pecuniary claim…and the person liable or accountable for the claim acknowledges the claim or makes any payment in respect of it the right shall be treated as having accrued on and not before the date of the acknowledgment or payment.”

The Defendant does not recall either entering into the Void Agreement or making any payments and as such the matter is subject to the Limitations Act 1980 and is Statute Barred. 

16. It is disputed that it is evidenced in the attached transaction statement from the Alleged Assignor that the Defendant made any payments. It is disputed that the Defendant made numerous payments toward the outstanding balance with the last payment being received on 18/11/2016 for the sum of £98.96. 

It is disputed that the documents exhibited by the Claimant at pages 8 to 63 of their paginated bundle are statement of account. It is not disputed that the Claimant commenced proceedings on 24/05/2021. It is disputed that this is within the 6-year limitation period. It is disputed that the claim is not statute barred. It is disputed that the Claimant is entitled to enforce the debt. It is disputed that any debt exists from the Defendant to the Claimant or Alleged Assignor. 

The Defendant avers that if any debt existed to the Alleged Assignor, the Claimant has failed to show any instrument of assignment an as such has not Locus Standi to issue their claim:

See: Dunlop Pneumatic Tyre Co Ltd v Selfridge Ltd [1915] AC 847 - The Lords agree fundamentally with the decision of the Court of Appeal; there was no contract between Dunlop and Selfridge and therefore Dunlop cannot sue.

Also: See: (National Westminster Bank plc v Spectrum Plus Ltd [2005] UKHL 41) - Where the House of Lords held that a claimant must prove their ownership of a chose in action in order to enforce it.

Opportunity to Respond

17. Is it disputed that MCS wrote to the Defendant on 21/10/2021 fully responding to her defence and providing documentation from the original creditor in support of the Claimant’s claim. It is disputed that the letter additionally provided the Defendant with an opportunity to enter into settlement negotiations with the Claimant without the need for further court proceedings. It is disputed that any letter was received and therefore it is disputed that the Defendant failed to respond. It is disputed that the document exhibited by the Claimant at pages 84 to 86 of their paginated bundle is a copy of the letter the Claimant claims was sent on 21/10/2021. The Defendant requests that the claimants provide evidence of service of this letter, such as a record of delivery or a witness statement from the person who served the letter

18. It is disputed that on 16/09/2022 MCS wrote to the Defendant to inform her of the Claimant’s intention to make an application for Summary Judgment. It is disputed that a copy of this letter is enclosed at pages 87 to 88. It is disputed that the letter explained the potential costs consequences of such an application and invited the Defendant to discuss alternative settlement arrangements. It is disputed that the Defendant did not respond.  

The Defendant draws the Courts attention to Page 6 of ('FMS1') which is an email to MCS stating that a password protected email had been received but the Defendant was not able to open it and requested a paper copy of the communication.  The communication also pointed out the ongoing medical conditions that the Defendant suffers from. 

Personal Circumstances

19. It is disputed that  the Claimant is sympathetic to the Defendant’s personal circumstances outlined in her defence. It is disputed that this does not impact her liability in this matter. It is disputed that the Claimant offered the Defendant an opportunity to provide evidence of her circumstances, however she did not respond. The Defendant avers that the Claimant has ignored all requests to send letters instead of password protected emails that the Defendant was unable to open.

20. It is disputed that the Claimant takes its customers ability to repay their debt very seriously. It is disputed that if Judgment is obtained the Claimant, they  will ensure to work with the Defendant to ensure her account is managed correctly.  The Defendant avers that the Claimant is a bulk purchaser of portfolios of  delinquent accounts who conduct no due diligence into whether the data they are purchasing is correct or not or if the persons associated with the account number are vulnerable or not. The Claimant is required to provide the instrument of assignment, upon which they rely, to show if litigation is permitted under this agreement against vulnerable persons.  The Court is respectfully invited to ask the Claimant to view the Deed of Assignment and verify the terms and conditions relied on by the Claimant and to ensure that the document is singed in compliance with Section 44 of the Companies Act 2006. The Defendant avers that no legal assignment exists and the maxim 'Caveat Emptor' applies - Let the buyer beware. 

The Defendant also avers that the Claimant has purchased the benefit of the Void Agreement which is simply not owed to the Alleged Assignor and as such the maxim 'Nemo dat quod non habet' applies as 'no one gives what they do not have'.

Summary

21. It is disputed that the Defendant has no real dispute or defence to this debt. It is disputed that the Defendant does not deny entering into, making use of or defaulting on the outstanding balance. It is disputed that the Defendant merely believes it to be Statute Barred. It is disputed that the Claimant has evidenced that this is not true. The Defendant avers that she is not legally trained and as such put in a defence that disputed owing the alleged debt without knowing the legal technicalities of how to phrase the fact that the Void Agreement was in fact void from the outset.  

22. It is disputed that the documentation enclosed by the Claimant in their paginated bundle sufficiently evidences that the Defendant entered into the Agreement with Virgin, failed to make all of the agreed payments, and the outstanding debt has been assigned to the Claimant.  The Defendant avers that the Claimant is issuing bulk robotic claims using Microsoft templates that simply paste in the names of Alleged Assignors and account numbers to a standard template to issue bulk claims, as demonstrated in the Claimant identifying 'Virgin' as the Alleged Assignor in their point. The Defendant invites the Court to strike out this claim for abuse of process under CPR 3.4(2)(b).

23. It is disputed that he Claimant has acted in good faith throughout these proceeding and has offered the Defendant ample opportunities to engage and address this matter on an amicable basis without Court Action. The Defendant avers that the Claimant's actions are unreasonable and vexatious. The Defendant has disputed both owing any money to the Alleged Assignor or the Claimant and the Claimant has simply ignored the Defendant who is Vulnerable and has been subjected to undue stress by the Claimant's flat refusal to communicate with the Defendant.  

Conclusion

24. For the reasons set out above, the Court is invited to strike out the Claimant's claim pursuant to the provisions of CPR 3.4 (2) (a) in that it discloses no grounds for bringing these proceedings.  The Claimant is put on notice that the Defendant intends to exercise her right to cross examine any witness relied on by the Claimant at trial. 

STATEMENT OF TRUTH

I believe that the facts in this Witness Statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

[NAME OF DEFENDANT] - Defendant

Signed: [NAME OF DEFENDANT]

Dated: 22/03/2023