IN THE HIGH COURT OF SOUTH AFRICA

(WESTERN CAPE DIVISION, CAPE TOWN)

Case No: 14669/2019

In the matter of:

CARIN THERESA RHOODE GELDERBLOM First Applicant

EMILY SMITH Second Applicant
VUYO MBOZI Third Applicant
BEULAH MEYER Fourth Applicant
NATASHA PERSENT Fifth Applicant
XOLANI SIBOKO Sixth Applicant
PATRICIA GEYSER Seventh Applicant

and

THE CITY OF CAPE TOWN Respondent

and

THE GARDENS NEIGHBOURHOOD WATCH Applicant

For admission as Amicus Curiae

ATLANTIC SEA BOARD ACTION GROUP Applicant

For admission as Amicus Curiae

CAMPS BAY BUSINESS FORUM Applicant

For admission as Amicus Curiae

SEA POINT FRESNAYE BANTRY BAY RATEPAYERS’

AND RESIDENTS’ ASSOCIATION WATCH Applicant
For admission as Amicus Curiae

HEADS OF ARGUMENT – AMICI CURIAE

INTRODUCTION

1. The Gardens Neighbourhood Watch, the Atlantic Sea Board Action Group,

Camps Bay Business Forum and the Sea Point Fresnaye Bantry Bay

Ratepayers’ and Residents’ Association Watch apply to be admitted as amici

curiae in the interim interdict application launched by above-mentioned seven

Applicants against the City in relation to the enforcement of its By-Law relating

to Streets, Public Places and the Prevention of Noise Nuisances (2007) (“the

Streets By-Law”) and the Integrated Waste Management By-Law (2009 as

amended) (“the Waste By-Law”) or collectively “the By-Laws”.

2. The interdict sought was to operate until the final determination of review

proceedings, still to be instituted, challenging the lawfulness of the City’s

action pursuant to the By-Laws including the issuing of fines, compliance

notices and summonses to the Applicants and the enforcement of same.

3. The amici curiae Applicants are supported in their application by the further

following organisations:

3.1. The Greenpoint Neighbourhood Watch1;

3.2. The Greenpoint Ratepayers’ and Residents’ Association2;

3.3. The Mouille Point Ratepayers Association3;

3.4. The Camps Bay Community Policing Form4;

1 A copy of their letter of support is annexure TNG2: p 331 with a supporting affidavit by its Chairperson,
Mr Scheltema: pp 399A-C
2 A copy of their letter of support is Annexure TNG3: p 332 with a supporting affidavit by its Co-
Chairperson, Ms Knight: pp 396-8
3 A copy of their letter of support is Annexure TNG4: p 333 with a supporting affidavit by its Chairperson,
Ms Hamman-Kempen: pp 393-5
4 An affidavit by its Chairperson, Mr Marsh, is at pp 370-84

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 3.5. Camps Bay and Clifton Ratepayers Association5;

3.6. Avenue Response CC6; and

3.7. The Cape Chamber of Commerce and Industry7.

4. Although two separate applications were made, these heads of argument are

filed on behalf of all of the amici curiae Applicants, who make common cause.

ATTITUDE OF THE PARTIES TO THE AMICI CURIAE

5. On 21 October 2019 a letter was sent to the parties requesting that they

consent to the admission of the amici curiae8. The Applicants’ attitude was to

requesting the aspirant amici curiae to deliver an application whereupon they

would assess their position9. The City had no objection to the amici joining.10.

6. An application was duly instituted and on 22 November 2019 an order by

agreement was made in which the amici Applicants were granted leave to: 1)

submit written argument, and 2) submit oral argument at the hearing of the

main application.

7. The City filed an affidavit consenting to the admission of the amici curiae

provided their admission does not delay the hearing of the matter on

3 December 201911. The Applicants have filed no further papers.

5 A copy of their letter of support is Annexure GT4: p 427-8

6 A copy of their letter of support is Annexure GT5: p 429-30
7 A copy of their letter of support is Annexure GT6: p 431
8 Letter requesting admission is Annexure TNG5: pp 334-5
9 Applicants’ letter in response is Annexure TN6: pp 337-8
10 Ms Nöckler-Golding’s affidavit: p 314, para 10
11 Affidavit of Mr Bosman: pp 500-5

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8. Accordingly, it is for this Court to decide whether 1) to admit the amici

Applicants, and 2) to allow the evidence of the amici Applicants set out in their

supporting affidavits.

SUBMISSIONS ON THE JOINDER OF THE AMICI CURIAE

9. The Applicants did not file a Rule 16A notice when instituting their application

for an interim interdict. Their attitude is that at this juncture no such notice

needed to be filed. Any reference in their founding affidavit to the alleged

breach of various provisions of the Constitution they submit applies to “the

review proceedings which our clients intend to institute against the city in due

course”12.

10. However, when substantiating the requirements for an interim interdict, the

Applicants submit that “in fact [they] enjoy clear rights under the Constitution,

and the issuing by this honourable court of an interim interdict is essential in

protecting these rights pending the final determination by the courts as to

whether the conduct of the respondent in enforcing the relevant by-laws

amounts to a violation of these rights”13.

11. It is the amici Applicants’ contention that this application, even at this stage,

raises constitutional issues and is a matter of public interest requiring the

Applicants to issue a Rule 16A notice. However, Rule 16A(9) emphasises the

wide discretion a High Court enjoys when it provides that a court “may

dispense with any of the requirements of this rule if it is in the interests of

12 Applicants’ letter, Annexure TNG6: p 337

13 Ms Gelderbloem founding affidavit: p 23, para 72

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 justice to do so”14. Rule 16A(8) moreover provides that “[t]he court hearing an

application to be admitted as an amicus curiae may refuse or grant the

application upon such terms and conditions as it may determine”.

12. As discussed by the Constitutional Court in Children’s Institute v Presiding

Officer of the Children's Court, District of Krugersdorp and Others15, although

friends of the court played a variety of roles at common law, Rule 16A was

specifically intended to facilitate the role of amici in promoting and protecting

the public interest. The rule increases access to the courts by creating space

for interested non-parties to provide input on important public interest matters.

The Constitutional Court has cited with approval the matter of S v Engelbrecht

(Centre for Applied Legal Studies intervening as Amicus Curiae) 16 which

emphasized that amici play an important role by ensuring that courts consider

a wide range of options and are well (or better) informed. The touchstone as

to whether an amicus will be allowed to lead evidence in each particular case

will be determined according to whether it is in the interests of justice to do

so.17

13. The requirement in Rule 16A(2) is that the party seeking to be admitted is an

“interested party”. The amici Applicants are quite obviously interested parties.

It is reflects badly on the Applicants that this was not immediately conceded.

The burdens resulting from the Applicants’ conduct, and failure of the City to

enforce the By-laws, fall squarely on the amici Applicants’ members. They

14 In the matter of Shelfplett 47 (Pty) Ltd v MEC for Environmental Affairs & Development Planning and
Another 2012 (3) SA 441 (WCC), a notice pursuant to Rule 16A had not been filed and the Court
exercising its powers in terms of Rule 16(9) gave certain directions
15 2013 (2) SA 620 (CC) (‘Children’s Institute case’) at para 26
16 2004 (2) SACR 391 (WLD) para 14
17 Children’s Institute case, para 32

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 have to live with the appropriation of public spaces, such as parks, sidewalks

and the like by street people; they have to deal with the consequences of

urinating and defecation and needles lying around in public places; they have

to deal with aggressive begging and harassment; and they have to deal with

the littering and the blocking of the municipal drains. In short, amici

Applicants’ members are the people in whose interest the by-law were

adopted and are to be enforced. The lack of enforcement impacts directly on

them.

14. The amici Applicants provided a comprehensive description of the above in

their applications for admission as amici. The Applicants, having insisted on

these applications to be brought (instead of just agreeing to the admission of

the amici Applicants), elected not to file any answering affidavits in response.

The basis on which they oppose the admission as amici is accordingly not

clear.

15. Whatever the objection may be, it is submitted that the applications for

admission should be granted. As is clear from the above, the amici

Applicants seek to intervene in the proceedings because they have interests

of their own, which interests are sought to be protected by the by-laws. It is

further in the interests of justice for this Court to admit the amici Applicants

and to receive the evidence set out in their supporting affidavits.

16. Both sides of the story must be heard. The City is not representing the views

of the communities who are affected by the Applicants’ conduct. The City has

its own agenda and views. Those may overlap to the extent with the views of

the amici Applicants but they are not the same, as we will demonstrate in

these heads.

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17. In the alternative, if the Court is not willing to exercise its powers in terms of

Rule 16A(9), then it is submitted that the Court in terms of section 173 of the

Constitution has the inherent power to regulate its own process which

includes the ability to admit and allow amici to adduce evidence if the interests

of justice so demand18. We then contend that a proper case has been made

out for admission under section 173.

THE EVIDENCE OF THE AMICI CURIAE APPLICANTS

18. The amici Applicants represent the residents living in the City Bowl and

Atlantic Seaboard and see the enforcement of the By-Laws as one of the

measures taken by the City to deal with the problems caused by people living

on the streets.

19. Individual members of the amici Applicants support numerous initiatives

aimed at assisting persons residing on the streets in the City, for example

Ladles of Love, which is a feeding scheme, the Haven Night shelter and

Community Who Cares. They also all support the City’s initiatives in dealing

with the complex problem of persons living on the streets and agree with the

City’s denial (with reference to its initiatives, amongst other the Culemborg

Safe Space) that the Applicants have no choice but to reside in public

places.19 Although some persons living on the streets agree to relocate to

shelters and benefit from the City’s interventions, as attested to by Messrs Du

18 Children’s Institute case, para 17

19 See for example: the Mouille Point Ratepayers’ Association partners who work with Straatwerk/Ophelp
(Ms Nöckler-Golding’s affidavit: p 318, para 19), the work done by the Camps Bay Community Police
Forum (Mr Marsh’s affidavit: pp 375-7; paras 5-11)

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 Plooy20 and Gordon21, the majority refuse the offered assistance, preferring to

remain on the streets.

20. The amici Applicants believe that if persons choose to remain on the streets

and engage in behaviour prohibited by the By-Laws, the City must be able to

enforce its By-Laws. If this cannot be done, then the By-Laws will for practical

purposes not exist for a portion of society. Such a situation cannot be allowed

to develop.

21. The social phenomenon of persons residing on the streets impacts on the

rights of the residents represented by the amici Applicants. The affidavits

proffered by the amici Applicants attest to the following:

20.1 The first is the squatting in areas not designated for human habitation

and not geared to deal with the physical mess and litter strewn and the

human excrement and waste on the surface on the streets, rocks, on

the beaches, in the bushy areas and on pathways. This in turn

negatively impacts on tourism, on the physical health of all residents

and visitors to the beach from all walks of life and on the sensitive

fauna and flora which have as their habitat those areas and which

ought to be able to function as ‘green lungs’22.

20.2 The second is what as referred to as “skarreling”, i.e. scratching around

in dustbins for food and whatever odds and sods they deem to have

value to use, consume or sell. This involves the breaking open of bin

bags and either scattering of the contents directly onto the pavements

20 Mr Du Plooy’s affidavit: pp 385-8

21 Mr Gordon’s affidavit: pp 389-92
22 Mr Marsh’s affidavit: p 372, para 4.1

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 or carting away the entire bag to the their settlements in the bush,

where the contents are disgorged and left, creating an extra mess and

additional health threat and attracting the aforesaid flies, rats, mice and

cockroaches. Eventually the waste either clogs the stormwater

systems or builds up to such a degree that the City’s Solid Waste

Management Teams are required to collect the waste in truckloads23.

20.3 The third issue relates to the physical clean-up operations that are

required to restore these areas to what they should be, which involve

tons of litter collected by volunteers, already taxed community

organisations or overburdened City teams. Massive clean-up projects

are currently undertaken by residents, volunteers, private companies

and private owners at great expense. If the City can no longer assist

by at least addressing the human element of these projects and/or are

prevented from removing articles that are deemed to be personal

belongings, including old discarded cardboard, plastic, nappies, scrap

material etc. then these public-private partnerships will simply be

collapse, at great negative impact to the area and the environment as a

whole24. The Gardens Neighbourhood Watch permanently employs

four persons who previously used to live on the streets and spends

approximately R135 000.00 annually on removing litter, most of which

is generated by persons living on the streets and lies in and around

their encampments. The litter consists of amongst other things black

bags which are removed from rubbish bins on collection days and then

23 Mr Marsh’s affidavit: p 373, para 4.1

24 Mr Marsh’s affidavit: pp 373-4, para 4.3

9
 ripped open there or taken to other areas where the bags are

rummaged through and the contents thereof left strewn around the

streets. Other litter include discarded begging signs, used condoms,

and sharp objects (hypodermic needles)25.

20.4 The fourth factor is the direct threat to protected and endangered

wildlife. The Camps Bay Community Forum in their clean-up

operations have unveiled the illegal slaughtering of guinea fowl, rock

rabbit (dassies), rooikat, porcupine and various birdlife by people living

in the bushes for food. This even includes the occasional dog and cat

that goes missing, which skeletal remains are sometimes found in and

around settlements deep in the bushy areas months later. This is

unnecessary because of the many community support initiatives and

NGO’s which provide food and the opportunity for people on the street

to earn money to sustain themselves and not just their drug habits26.

20.5 Fifthly is the threat of fire as persons living on the streets fail to adhere

to the laws prohibiting the starting of fires in the open. All the fires

which have caused loss and damage to property which the Camps Bay

Community Police Forum have attended have been started by people

living informally and illegally in the bushes. As the fire makers have

often been under the influence of alcohol or other substances, there

25 Ms Nöckler-Golding’s affidavit: pp 315-6, para 15.2 and Annexures TNG9: pp 345-50; TNG11: p 356,
TNG12: pp 357-9
26 Mr Marsh’s affidavit: p 374, para 4.4

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 have been many instances where they have died in the fires that have

started.27

22. Against this background, we now turn to set out two arguments which we

hope will assist the Court in the resolution of the matter.

AMICI ARGUMENT ONE: PRIMA FACIE RIGHT

23. Homelessness in the sense of people living on streets is not an uniquely

South African phenomenon. Many cities around the world battle with this

issue.

24. In the circumstances, we respectfully submit that the Court may benefit from

having regard to the jurisprudence in foreign countries regarding the

enforcement of by-laws against the homeless. To this end, we briefly discuss

below one fairly recent Canadian decision and one very recent American

decision.

25. Although guidance can be derived from these judgments, one must bear in

mind that the cities in these countries have vastly superior resources to the

City of Cape Town to tackle the problem of homelessness. There are also

other differences. To mention an important one: those cities are far less

dependent on tourism than the City of Cape Town. The actions of the

homeless are particularly destructive of the tourist industry and hence

particularly detrimental to a city such as Cape Town where business and the

(working) poor depend on the hotel, guesthouse and restaurant industry for a

living.

27 Mr Marsh’s affidavit: p 374, para 4.5; Ms Nöckler-Golding’s affidavit: p 327, para 50

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26. Subject to those caveats it is useful to consider the two foreign decisions.

27. The first is the Canadian case of Abbotsford (City) v. Shantz, 2015 BCSC

1909 (available on CanLII). The approach in this case appears to be that it is

unconstitutional to fine (ticket) the homeless for erecting structures to shield

themselves from the elements at night provided that the structures are

erected on public property (parks) provided that there is insufficient space

available in shelters. The homeless may be prevented from leaving the

materials used in the park during the day.

28. The second is the judgment of Robert Martin and others vs City of Boise

(United States Court of Appeals for the Ninth Circuit, handed down on

4 September 2019)28. In summary, the majority found that the City cannot bar

street people from lying down to sleep in public property, unless there is

somewhere else provided. Again, the judgment turned on the non-availability

of alternatives. It must be noted that the City of Boise has approached the

United States Supreme Court for leave to appeal against the judgment of the

Ninth Circuit.

29. But the point we wish to make is that the present Applicants have not shown

there is no space in the shelters (Safe Space, in particular) for them. Even if

there is not enough space, at best for them they are only entitled to erect

some kind of shelter on suitable public property at night. They cannot

“occupy” the public property during the day. The Canadian and American

jurisprudence further demonstrate that the homeless do not have general

immunity from being fined, regardless of their behaviour.

28
https://law.justia.com/cases/federal/appellate-courts/ca9/15-35845/15-35845-2019-04-01.html

12
30. The difficulty for the Applicants in the present matter is that they never sought

to address the fundamental issues, and in particular the issue of alternatives.

The Applicants appear to be under the impression that they must always have

a choice as to whether they want to stay on the street or use the shelters; and

if so, the terms on which they will use them (cohabitating with a partner of

choice etc). This is not the case, as the foreign judgments show.

31. In short, a much more balanced approach than the position contended for by

the Applicants must be adopted. The Applicants simply have no concern

whatsoever for the consequences of their actions and lifestyle on others,

including the working poor. Even if there is insufficient space in the shelters

for them so that they are obliged to sleep in public spaces, a balance must still

be struck between the rights of street people and the rights of other citizens’

to live in a safe and clean environment. It would not be permissible for the

City, for instance, to require the homeless not to set up temporary shelters in

areas which are primarily suburban, or tourist areas where businesses, hotels

and guest houses are very vulnerable due to the activities of the homeless.

The question is where the line should be drawn in order to achieve the

appropriate balance.

32. Instead of dealing with the fundamental issues described above, the

Applicants busy themselves with esoteric questions, such as whether, as a

matter of principle, homelessness should be dealt with as a law enforcement

issue;29 and whether the City’s power to grant exemptions from the by-laws is

29
Applicant’s heads of argument at para 9

13
 too wide and may lead to arbitrary decision-making.30 This is not where the

debate should be.

AMICI ARGUMENT TWO: BALANCE OF CONVENIENCE

33. We know from the City’s answering affidavit that there are no pending

enforcement proceedings of the by-laws in respect of three of the Applicants.

The court hearing dates in respect of the other four have not yet been

determined.31

34. It is submitted that it is preferable that the constitutionality of the by-laws, and

their validity of their enforcement, be determined on concrete facts. Such

facts should emerge from the proceedings before the Municipal Courts, rather

than from the present interdict (and ultimately, review) proceedings. Motion

proceedings are not conducive to fact-finding. Facts are better established by

way of trial in the Municipal Courts. Should any of the four Applicants who still

face such proceedings be convicted, that conviction can be appealed, along

with a constitutional challenge to the by-laws or conduct of the City’s metro

police.

35. If granted, the kind of pre-emptive interdict sought in the present matter will

constitute a drastic invasion of the principle of separation of powers. It will

mean that no compliance notices, fines etc can be issued to the Applicants

under the by-laws. Although the order will only be granted in favour of the

Applicants, it will be difficult for the City to thereafter enforce the by-laws

against any other similarly situated person. What is accordingly in effect

called for, is the temporary suspension of the by-laws, in respect of a class of

30
Applicant’s heads of argument at para 78
31
Affidavit of Mr Bosman: para 39.1

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 people32. This is the kind of order which causes the so-called “separation of

powers harm” referred to the Constitutional Court in National Treasury and

Others v Opposition to Urban Tolling Alliance and Others 2012 (6) SA 223

(CC) (“Outa”) and Tshwane City v Afriforum 2016 (6) SA 279 (CC).

36. In these kinds of matters, where an entire enforcement regime is sought to be

interdicted pending review proceedings, the granting of interdictory relief

should be limited to the “clearest of cases”.

37. This is clearly not such a case.

38. Firstly, there is no reason why the proceedings before the Municipal Courts

should not proceed and why the constitutional matters cannot be resolved on

appeal, with reference to facts established at trial in the Municipal Courts.

39. Secondly, the events over the last three months show how immediate and

debilitating the consequences of such interdicts can be. More particularly:

39.1. In the three months since the Applicants and the City on 5 September

2019 agreed to a temporary order suspending the enforcement of the

By-Laws until the hearing of the interdict application, the inability of the

City to enforce its By-Laws has had a tangible effect in the

neighbourhoods represented by the amici Applicants.33

39.2. Since the interim interdict, Gardens has experienced a significant influx

of additional persons living on the streets from across the City. The

Gardens Neighbourhood Watch’s litter collection ballooned from an

32
In the Applicant’s heads of argument at para 98.4, relief is in any event sought on behalf of all homeless
persons. It is not clear on what basis this is done, as the requirements for a class action has not been
fulfilled
33 Ms Nöckler-Golding’s affidavit: p 319, para 22

15
 average of 400 bags a month to 600 bags a month, a 50 percent

increase. The graffitti’ing of buildings and bridges have markedly

increased, along with a sharp rise in criminal activity, apparently by

people living in ‘Stroompie’34, which has become increasingly

populated in recent weeks. Since these events a number of shacks

have also suddenly sprung up in the McKenzie Street Park and are

proliferating.35

39.3. Conversations with street people by the Gardens Neighbourhood

Watch members have revealed the belief that, because the Applicants

reside in the Gardens area and fall to be exempt from by-law

enforcements, they should also move here to benefit from the same

protection.36

39.4. The Camps Bay Community Police Forum has observed a marked

increase of people living on the streets claiming the mantle of alleged

‘homelessness’. A number of these are known to the Forum as

hardened criminals or gangsters who claim to be ‘homeless’ in order to

make use of the chance to establish themselves on the streets whilst

Law Enforcement has had its hands tied when in fact they are

executing criminal activities to their own benefit at the expense of local

residents, visitors, tourists and businesses in the area.37

34 Photographs of ‘Stroompie’ are Annexure TNG10: pp 351-355

35 Photographs of the McKenzie Street Park are Annexure TNG16: pp 367-9
36 Ms Nöckler-Golding’s affidavit: pp 327-8, paras 51-3, Confirmatory affidavit of Mr Rees, the Chair of the
Gardens Neighbourhood Watch: pp 400-2
37 Mr Marsh’s affidavit: pp 381-2, paras 22-5

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40. The Applicants contend that the balance of convenience is in favour of the

granting (or extension) of interim relief. They contend that they would be

severely prejudiced by the continued, unlawful enforcement of the By-Laws

whereas there is no prejudice to the City if the interdictory relief is granted.38

41. It is submitted that the correct enquiry is not whether there is prejudice to the

City (only) but whether there is prejudice to the public, including other

residents, for whom the amici Applicants are a voice.

42. For the reasons set out above, if prejudice to the public and the residents are

considered, the balance is convenience does not favour the granting of relief.

43. If granted, the by-laws will be rendered unenforceable against a class of

people. This will result in separation of powers harm and the kind of

lawlessness described above.

44. If not granted, all that will happen is that (four) of the Applicants will have to

face proceedings in the Municipal Court. If these matters proceed, and if

those Applicants are convicted, they can (and no doubt will) appeal and raise

their constitutional concerns in the appeal.

CONCLUSION

45. The amici Applicants support the City’s enforcement of its By-Laws as one of

the measures taken by the City to deal with the problems caused by people

living on the streets at night. The amici Applicants and the other supporting

organisations fund massive social interventions, which should be balanced by

a sense of responsibility from those on the streets and the active enforcement

of the City’s By-Laws. It is difficult enough dealing with the social issues in

38 Ms Gelderbloem’s founding affidavit: p 24, para 76

17
 relation to the many people choosing to live on the streets without the City

being able to enforce its By-Laws in appropriate cases and after following the

correct procedures.

46. It is submitted that the amici Applicants have an interest in whether or not the

interdict is to be extended until the Applicants institute their

review/constitutional challenge proceedings and those proceedings are finally

determined. The Applicants undertook in their papers to file their papers in

this review within 20 days.39 That period has long since expired and this fact

alone should indicate that this process could still take years during which time

the impacts already noticed as described above would continue to increase.

47. It is submitted that factual submissions are relevant and will assist the Court in

this public interest matter by providing a more detailed and nuanced

understanding of the social context within which the application for the

interdict is to be decided.

48. The amici Applicants ask that they be admitted and in addition to making

written and oral submissions that the evidence in their affidavits form part of

the papers before the Court and be taken into consideration when deciding

whether to extend the operation of the interdict. It is submitted that the Court

should not extend the operation of the interdict.

H J DE WAAL SC
A ERASMUS
Chambers
Cape Town
25 November 2019

39 Ms Gelderbloem’s affidavit: p 8, para 12.2

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 AMICI APPLICANTS’ LIST OF AUTHORITIES

1. Children’s Institute v Presiding Officer of the Children's Court, District of

Krugersdorp and Others 2013 (2) SA 620 (CC)

2. S v Engelbrecht (Centre for Applied Legal Studies intervening as Amicus

Curiae) 2004 (2) SACR 391 (WLD) para 14

3. Abbotsford (City) v. Shantz, 2015 BCSC 1909

4. Robert Martin and others vs City of Boise (United States Court of Appeals for

the Ninth Circuit, handed down on 4 September 2019)

5. National Treasury and Others v Opposition to Urban Tolling Alliance and

Others 2012 (6) SA 223 (CC)

6. Tshwane City v Afriforum 2016 (6) SA 279 (CC)

19