Green Paper on improving the efficiency of the enforcement of judgments in the European Union: the attachment of bank accounts {SEC(2006) 1341}
Date: 2006-10-24
Institutions: European Commission
Subjects: European judicial area, bank, bank deposit, judicial cooperation in criminal matters in the EU, jurisdiction, seizure of goods

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 24.10.2006 
COM(2006) 618 final 

GREEN PAPER 

ON IMPROVING THE EFFICIENCY OF THE ENFORCEMENT OF JUDGMENTS 
IN THE EUROPEAN UNION: 
THE ATTACHMENT OF BANK ACCOUNTS 

(presented by the Commission) 

{SEC(2006) 1341} 

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GREEN PAPER 

ON IMPROVING THE EFFICIENCY OF THE ENFORCEMENT OF JUDGMENTS 
IN THE EUROPEAN UNION: 
THE ATTACHMENT OF BANK ACCOUNTS 

The purpose of this Green Paper is to launch a broad consultation among interested parties on 
how  to  improve  the  enforcement  of  monetary claims  in  Europe.  The  Green  Paper  describes 
the problems of the current situation and proposes the creation of a European system for the 
attachment of bank accounts as a possible solution.  

The Commission invites interested parties to submit comments before 31 March 2007 to the 
following address: 

European Commission 
Directorate-General for Justice, Freedom and Security 
Unit C1 – Civil Justice 
B - 1049 Brussels 
Fax: +32-2/299 64 57 
E-mail: jls-coop-jud-civil@cec.eu.int 

Interested parties are requested to mention explicitly if they do not wish their comments to be 
published on the Commission’s website. 

The  Commission  intends  to  organise  a  public  hearing  on  the  subject  matter  of  the  Green 
Paper. All those responding will be invited to attend. 

1. 

INTRODUCTION 

1.1. 

Shortcomings of the current situation 

Enforcement  law  has  often  been  termed  the  “Achilles’  heel”  of  the  European  Civil  Judicial 
Area.  While  a  number  of  Community  instruments  provide  for  the  jurisdiction  of  the  courts, 
the procedure to have judgments recognised and declared enforceable and mechanisms for co-
operation of courts in civil procedures, no legislative proposal has yet been made for actual 
measures  of  enforcement.  To  date,  execution  on  a  court  order  after  it  has  been  declared 
enforceable in another Member State remains entirely a matter of national law. 

Current  fragmentation  of  national  rules  on  enforcement  severely  hampers  cross-border  debt 
collection. Creditors seeking to enforce an order in another Member State are confronted with 
different legal systems, procedural requirements and language barriers which entail additional 
costs  and  delays  in  the  enforcement  procedure.  In  practice,  a  creditor  seeking  to  recover  a 
monetary claim in Europe will most commonly try to do so by obtaining an attachment1 of his 

1 

Note  on  the  terminology:  The  term  “attachment”  in  this  Green  Paper  denotes  a  procedure  which 
attaches or freezes a debtor’s moveable property which is in the hands of a third party and prevents the 
third party from giving up possession of the property. 

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debtor’s  bank  account(s).  Such  procedures  exist  in  most  Member  States  and,  if  working 
efficiently, can be a powerful weapon against recalcitrant or fraudulent debtors.  

However,  while  debtors  are  today  able  to  move  their  monies  almost  instantaneously,  out  of 
accounts  known  to  their  creditors  into  other  accounts  in  the  same  or  another  Member  State 
creditors  are  not  able  to  block  these  monies  with  the  same  swiftness.  Under  existing 
Community instruments, it is not possible to obtain a bank attachment which can be enforced 
throughout  the  European  Union.  Notably,  the  Regulation  44/2001  (Brussels  I)2  does  not 
ensure that a protective remedy such as a banking seizure obtained ex parte is recognised and 
enforced in a Member State other than the one where it was issued3.  

The  Commission  already  noted  the  difficulties  of  cross-border  debt  recovery  in  its  1998 
Communication  ‘Towards  greater  efficiency  in  obtaining  and  enforcing  judgments  in  the 
European Union’4. In view of the diversity of Member States’ legislation and the complexity 
of the subject, it proposed to confine reflection initially to the problem of banking seizures5. 
Two  years  later,  the  Programme  on  Mutual  Recognition  called  upon  the  Commission  to 
improve  attachment  measures  concerning  banks6.  In  2002,  the  Commission  issued  an 
invitation to tender for a study on making more efficient the enforcement of judicial decisions 
within the European Union. The study's report analyses the situation in the then 15 Member 
States and proposed several measures to improve the enforcement of judicial decisions in the 
European  Union,  notably  the  creation  of  a  European  order  for  the  attachment  of  bank 
accounts, a European protective order to the same effect and a number of measures enhancing 
the transparency of the debtor's assets7. The latter issue will be dealt with in a Green Paper to 
be published in 2007. 

The  problems  of  cross-border  debt  recovery  risk  constituting  an  obstacle  to  the  free 
circulation of payment orders within the European Union and an impediment for the proper 
functioning of the Internal Market. Late payment and non-payment jeopardises the interests of 
businesses and consumers alike. The differences in the efficiency of debt-recovery within the 
European  Union  also  risk  distorting  competition  among  businesses  operating  in  Member 
States as between efficient systems of enforcing payment orders and those where this is not 
the case. Community action on this subject therefore needs to be considered. 

2. 

A  POSSIBLE  SOLUTION:  A  EUROPEAN  SYSTEM  FOR  THE  ATTACHMENT  OF  BANK 
ACCOUNTS 

A possible solution would be to create a European order for the attachment of bank accounts 
which  would  allow  a  creditor  to  secure  a  sum  of  money  due  to  or  claimed  by  him  by 
preventing the removal or transfer of funds held to the credit of his debtor in one or several 
bank  accounts  within  the  territory  of  the  European  Union8.  Such  an  order  would  have 

2 
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8 

Regulation (EC) No 44/2001 of 22 December 2000, OJ L 12, 16.1.2001 p. 1. 
ECJ judgment of 21.5.1980, C-125/79 (Denilauler) 
Commission communication to the Council and the European Parliament, JO C 33, 31.1.1998, p. 3. 
Cf. Communication (Fn 1), p. 14s. 
Programme of measures for implementation of the principle of mutual recognition of decisions in civil 
and commercial matters, OJ C 12, 15.1.2001 p. 1, 5. 
Study No. JAI/A3/2002/02. The final report is available at 
http://ec.europa.eu/justice_home/doc_centre/civil/studies/doc_civil_studies_en.htm.  
A  European  order  could  also  be used  in relation  to  a  civil  claim  arising out of  fraudulent  or  criminal 
activity. 

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protective  effect  only,  i.e.  it  would  block  the  debtor’s  funds  in  a  bank  account  without 
transferring these to a creditor. The procedure would be subject to conditions for granting of 
the order including an adequate level of debtor protection. An attachment order issued in one 
Member State would be recognised and enforceable throughout the European Union without 
the need for a declaration of enforceability.  

Such a system could be established by designing a new and self-standing European procedure, 
which  would  be  available  in  addition  to  measures  existing  under  national  law,  or  by 
harmonising Member States' national rules on the attachment of bank accounts by means of a 
directive.  In  the  latter  case,  additional  provisions  would  need  to  be  made  to  ensure  the 
recognition and enforcement of an attachment order issued in one Member State throughout 
the European Union.  

The  decision  whether  or  not  to  initiate  legislation  in  this  area  will  be  subject  to  an  impact 
assessment in which will be analysed the extent of the problems of cross-border debt recovery 
and the effectiveness of possible alternatives to European rules. The suggestions outlined in 
this paper do not prejudice the outcome of the impact assessment. 

Question  1:  Do  you  see  a  need  for  a  Community  instrument  for  the  attachment  of  bank 
accounts as a way to improve debt recovery in the EU? If so, should it create a self-standing 
European  procedure  or  harmonise  Member  States'  legislation  on  the  attachment  of  bank 
accounts? 

Question  2:  Do  you  agree  that  a  Community  instrument  should  be  limited  to  protective 
orders  preventing  the  withdrawal  and  transfer  of  monies  standing  to  the  credit  of  bank 
accounts? 

3. 

PROCEDURE FOR OBTAINING AN ATTACHMENT ORDER 

3.1. 

Circumstances in which a creditor can apply for an Attachment Order 

The question arises at which stages the creditor, in the process of the pursuit of a monetary 
claim, should be able to apply for a attachment order under the European system. Potentially 
there are four points in time at which the creditor might apply for such a protective order to 
safeguard his rights. 

–  prior to the initiation of legal proceedings on the merits of the claim, 

–  concurrently with the raising of the principal action, 

–  at any later stage during the course of judicial proceedings and 

–  during the period between the issue of an order in one Member State and of a declaration 
of  enforceability  of  the  order  in  the  Member  State  where  the  account  of  the  debtor  is 
located. 

It is argued that the creditor should be granted maximum flexibility by enabling him to apply 
for an attachment order at any stage of the procedure. On this basis, careful thought has to be 
given  to  the  adequate  protection  of  the  debtors’  interests,  in  particular  when  considering  an 
application  for  provisional  measures  prior  to  the  main  proceedings.  An  attachment  order  in 

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the  European  system  would  complement  and  be  compatible  with  existing  European 
instruments in the field of civil justice. 

Question 3: Should an attachment order be available in all of the four circumstances outlined 
above in paragraph 3.1 or only in some of them? 

3.2. 

Conditions of issue 

An attachment order could be granted by a court in summary proceedings on application by 
the creditor, using a form of application available in all Community languages. The creditor 
would first have to persuade the court that he had a justifiable claim on the merits against the 
debtor  ("fumus  boni  iuris").  An  enforceable  right  -  a  court  order  or  authentic  instrument  - 
should suffice as proof of the claim. A creditor seeking an attachment order before obtaining 
an enforceable right would need to supply evidence to support the claim.  

Next the creditor would have to demonstrate urgency, such as that there exists a real risk that 
enforcement  of  the  claim  may  be  frustrated  if  the  measure  is  not  granted  ("periculum  in 
mora"). Variations among Member States’ legal systems requires careful consideration as to 
the  exact  nature  of  this  condition,  bearing  in  mind  the  necessity  to  adequately  balance 
creditors’ s and debtors’ interests. 

Finally,  the  court  should  be  able  to  require  the  creditor  to  provide  security  or  caution  to 
protect  the  debtor  against  any  loss  or  damage  were  the  measure  to  be  set  aside  in  the  main 
proceedings. Here questions arise as to whether the amount of the security should be left to 
the  discretion  of  the  court  or  to  national  law  and  also  whether  an  obligation  to  provide 
security  can  be  established  without  harmonising  the  creditor’s  liability  for  any  losses  the 
debtor  may  suffer  from  wrongful  use  of  the  attachment  if  the  creditor  ultimately  fails  to 
establish his claim. 

Question 4: What onus should lie on the creditor to persuade the court that he has a claim 
against the debtor sufficient to justify the granting of an attachment order?  

Question  5:  Should  urgency  be  a  condition  for  granting  an  attachment  order  prior  to 
obtaining an enforceable title? If so, how should this condition be defined? 

Question 6: Should the court have discretion when granting an attachment Order to require 
the creditor to provide a security deposit or a bank guarantee? How should the amount of any 
such security deposit/guarantee be calculated? 

3.3. 

Hearing of the debtor 

In line with current practice in some Member States, it could be argued that there should be 
no hearing on the application or notification to the debtor prior to the execution of the bank 
attachment since this would be counter-productive to the aim of preventing monies moving to 
the potential detriment of the creditor and safeguard the "surprise effect" of the measure. In 
this case, the debtor would be notified of the attachment simultaneously with its execution and 
be given the possibility of contesting its enforcement.  

Question  7:  Should  the  debtor  be  heard  or  notified  prior  to  the  granting  of  a  bank 
attachment? 

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3.4. 

Details of account information required  

The  question  arises  as  to  the  type  and  extent  of  information  about  the  debtor’s  account(s) 
which the creditor would have to provide when applying for an attachment order. While it is 
plain  that  he  should  state  the  exact  name  of  the  debtor,  the  degree  of  detail  needed  on  the 
account is more difficult to determine. Particularly controversial is the question whether the 
creditor has to give the exact account number(s). Given that bank attachments are granted in 
some  Member  States  without  this  information  and  that  it  will  often  constitute  an 
insurmountable  obstacle  for  the  creditor  to  detect  it,  it  can  be  argued  that  the  exact  account 
number(s) should not be an indispensable requirement. Nevertheless the information provided 
by the creditor has to be detailed enough as to allow the bank to identify its customer and to 
minimise  the  incidence  of  erroneous  seizures  due  to  mistaken  identities.  It  should  be 
considered whether, in addition to the exact name of the debtor, it would suffice to require the 
details of the bank branch where the account(s) are situated. 

Question  8:  What  should  be  the  minimum  degree  of  account  information  required  for  the 
issue of an Attachment Order? 

3.5. 

Jurisdictional Issues 

Since  in  most  Member  States  courts  deciding  the  main  proceedings  have  competence  for 
protective measures, it could be argued that a court which has jurisdiction on the merits under 
the relevant rules of Community law should be competent also for a protective order under the 
European system. 

In  addition  to  the  court  which  has  jurisdiction  in  the  principal  action,  the  attachment  order 
could be granted by the courts of the Member State of the defendant’s domicile, if different; 
and/or the courts of any Member State in which a bank account against which an attachment 
is to be used, is located. 

Given  that  the  aim  of  the  European  instrument  would  be  to  remedy  the  current  situation  in 
which the creditor has to go to the Member State where the account is situated, there might be 
a case for enabling the creditor to choose between the different fora mentioned above.  

Question 9: Do you agree that the courts having jurisdiction for the merits of the case under 
relevant Community law and/or the courts where the account is situated should be competent 
to  grant  an  attachment  order?  Should  the  court  of  the  defendant’s  domicile  always  have 
jurisdiction  to  issue  an  attachment,  even  if  it  does  not  have  jurisdiction  under  Regulation 
44/2001? 

4. 

AMOUNT AND LIMITS OF AN ATTACHMENT ORDER IN THE EUROPEAN SYSTEM 

4.1. 

Amount to be secured 

Limiting the attachment to a specific amount rather than allowing the blocking of the entire 
balance standing to the credit of the debtor in the account(s) seized would discourage abuse 
and  be  proportionate.  This  amount  should  be  based  on  the  sum  claimed  by  the  creditor 
(including any interest payments and judicial expenses due to the creditor). It would need to 
be  considered  to  what  extent  additional  amounts,  notably  future  interest  payments  and 

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expenses  of  the  creditor  in  applying  for  and  executing  the  attachment  (costs  of  lawyers, 
enforcement officers and the bank(s)), should be secured by the attachment. 

Question 10: Do you agree that the attachment should be limited to a specific amount? If so, 
how should this amount be determined  

4.2. 

Costs of the banks 

It  is  arguable  that  the  execution  of  a  bank  attachment  and  the  monitoring  of  the  amounts 
standing  to  the  credit  of  a  debtor’s  account  create  certain  costs  for  the  banks.  It  is  also 
arguable  that  banks  should  execute  attachments  as  a  matter  of  public  duty  and  absorb  any 
costs  arising  as  a  part  of  their  operating  expenses.  From  time  to  time  banks  themselves  are 
also creditors, or have creditors as customers, so they also have an interest in the successful 
recovery  of  claims.  Hence,  the  question  arises  as  to  whether  the  banks  should  be  paid  for 
carrying  out  their  functions  in  relation  to  attachments  and,  if  so,  whether  the  amount  they 
would be entitled to should be capped on a national or a European level. It will also have to be 
considered  whether  a  creditor  should  be  obliged  to  pay  the  bank  prior  to  execution  of  the 
attachment or whether the bank should deduct the amount payable from the seized account.  

Question  11:  Do  you  consider  that  the  banks  should  be  paid  for  the  execution  of  an 
Attachment  Order?  If  so,  should  the  amount  to  which  they  would  be  entitled  be  capped? 
Should the creditor have to pay the bank in advance or should the amount due be deducted 
from the credit balance of the account seized? 

4.3. 

Attachment of several, joint and nominee accounts  

If  the  creditor  wants  to  block  simultaneously  several  accounts  situated  in  one  or  different 
Member States because the amount in one account might be insufficient to cover the claim the 
question  arises  if  and  how  the  amounts  seized  in  each  of  these  accounts  can  be  limited  in 
order to prevent an attachment of double or triple the amount due. This problem is similar to 
the  situation  already  existing  in  some  jurisdictions  where  an  attachment  served  on  the  head 
office  of  a  bank  attaches  all  accounts  in  the  local  branches  of  the  bank.  One  possibility  to 
address  the  problem  could  be  to  provide  for  the  transfer  of  the  amount  due  to  a  separate 
account  and  to  unblock  the  accounts  seized.  Consideration  would  have  to  be  given  to  the 
question how such a system could operate with different banks and across different Member 
States. 
Questions also arise about the attachment of joint accounts, e.g. accounts in the name of both 
spouses, and of nominee accounts, i.e. accounts in which the account owner holds monies on 
behalf of the debtor. 

Question 12: If an attachment order is to extend to several accounts, how should the sum to 
be seized be allocated among each of the accounts? 

Question 13: How should the attachment of joint and nominee accounts be dealt with? 

4.4. 

Amounts exempt from execution 

To  protect  the  debtor's  dignity  and  his  family  life,  certain  sums  must  be  exempt  from 
execution,  notably  such  sum  as  the  debtor  is  allowed  to  retain  for  his  alimentary  needs  and 
those of his family. Consideration will therefore have to be given as to at what moment any 
such sum should be determined and how, whether by the judge issuing the attachment, by the 
enforcement authority executing it or by the bank where the account is situated? Should this 

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question be dealt with ex officio or solely upon request by the debtor? Finally, how should this 
amount be defined and calculated - pursuant to the law of the Member State where the order 
was issued, pursuant to the law of the Member State where the account is situated or pursuant 
to  a  harmonised  European  regime  which  would need to specify the amounts in  an adequate 
manner for example by a generic or an index-linked rule? 

Question 14: Should the question whether amounts are exempt from execution be dealt with 
ex officio when issuing/executing the attachment or should the onus be on the debtor to object 
on this ground? How and by whom should the amount exempt from execution be calculated 
and on what basis? 

5. 

EFFECTS OF AN ATTACHMENT ORDER 

5.1. 

Implementation  

Once an attachment order has been issued by a court in a Member State, the question arises 
how it should be implemented. Given the need to act swiftly and the purely protective nature 
of the instrument, it is suggested that an attachment should take effect directly throughout the 
European Union without any intermediary procedure (like a declaration of enforceability) in 
the Member State requested being required.  

The  ways  of  transmitting  the  attachment  from  the  issuing  court  to  the  bank  holding  the 
account to be seized will need to be considered. The procedure has to balance the creditor’s 
interest  to  effect  a  speedy  transmission  with  the  interests  of  the  debtor  and  the  bank  to 
minimise  unjustified  seizures.  The  cross-border  transmission  of  documents  is  governed  by 
Regulation  1348/20009  which  provides  for  the  direct  transmission  of  an  attachment  order 
from  the  court  to  the  bank  by  postal  services.  While  this  method  already  allows  for  a 
relatively rapid service of judicial decisions, additional consideration should be given to the 
question  whether  the  use  of  electronic  communication  can  be  used  to  further  speed  up  the 
transmission  process.  In  order  to  achieve  the  policy  objective  to  render  the  freezing  of 
accounts more efficacious, it is suggested that a bank attachment should operate electronically 
at all or most of the stages of the procedure, i.e. from the court granting it to the bank holding 
the  account.  It  would  need  to  be  assessed  which  mechanisms  will  have  to  be  devised  to 
provide for an appropriate degree of security in the transmission process and whether the use 
of an electronic signature would suffice to certify the identity and competence of the issuing 
authority and guarantee the accuracy of the data transmitted. 

It would also have to be considered which time limit the bank would have to respect in order 
to  implement  the  attachment,  i.e.  whether  the  account  would  be  blocked  immediately  upon 
receipt or within a specified time period following receipt of the attachment by the bank, and 
how  transactions  should  be  treated  that  have  been  initiated  before  the  service  of  the 
attachment order was effected on the bank. 

The  banks  should  be  required  to  inform  the  competent  enforcement  authority  whether  the 
attachment has ‘caught’ any funds standing to the credit of the debtor in the account(s) seized. 
Ideally,  this  information  would  also  be  transmitted  electronically.  In  this  context, 

9 

Council  Regulation  1348/2000  of  29  May  2000  on  the  service  in  the  Member  States  of  judicial  and 
extrajudicial documents in civil and commercial matters; OJ L 160, 30.6.2000, p. 37. 

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consideration  will  have  to  be  given  as  to  how  an  appropriate  level  of  data  protection  and 
banking secrecy can be guaranteed in this process.  

Question  15:  Do  you  agree  that  the  exequatur  procedure  should  be  abolished  for  the 
attachment order? 

Question 16: How should an attachment order be transmitted from the issuing court to the 
bank where the account is situated? What time limit should the bank have to respect in order 
to  implement  an  attachment?  What  should  the  effect  of  an  attachment  order  be  on  ongoing 
operations? 

Question 17: Do you agree that upon receipt of an attachment, it should be the duty of the 
banks  to  inform  the  enforcement  authority  whether  and  to  what  extent  an  attachment  has 
successfully secured the monies liable to be paid by the debtor to the creditor? 

5.2. 

Protection of the debtor 

Once  an  attachment  order  has  taken  effect,  the  debtor  will  have  to  be  informed  that  his 
account has been blocked and given the right to contest the attachment or to have its amount 
restricted. It will have to be considered who should convey this information to the debtor. It is 
suggested  that  the  debtor  should  be  formally  notified  by  the  court  or  enforcement  authority 
effecting  the  attachment.  It  is  expected  that,  in  addition,  as  a  matter  of  business  relations 
between  the  banks  and  their  customers,  the  banks  will  inform  the  debtor  as  soon  as  the 
attachment is carried out.  

It is clear that the debtor must have the right to contest an attachment, but it will need to be 
considered which authority would be competent to hear his objection, the court having issued 
the bank attachment or the court at the place where the account is situated. It will also need to 
be considered whether the grounds for objection (e.g. payment of the debt, prescription of the 
claim) would need to be harmonised on a European level in order to ensure the efficacy of the 
envisaged instrument. It is suggested that the permissible grounds of objection should differ 
depending on whether the attachment is granted on the basis of an existing enforceable right 
or independently of any such. It is furthermore suggested that, where an attachment is granted 
prior  to  the  commencement  of  judicial  proceedings  in  the  principal  action,  it  will  not  be 
upheld if the creditor does not raise the principal action within a specified time period (e.g. 
one month).  

Finally, the question arises to what extent the creditor should be liable if an attachment proves 
to be unfounded and whether his liability should be harmonized on a European level or left to 
national law. 

Question 18: When and by whom should the debtor be notified formally that an attachment 
has been granted and taken effect?  

Question 19: Should the attachment be revocable or lapse automatically if the creditor does 
not file the principal action within a specific time period?  

Question 20: On what grounds and to what extent should the debtor be entitled to object to 
the order for an attachment? Which court should be competent to hear the debtor’s objection 
against an attachment? 

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Question 21: Should the creditor’s liability in case the attachment proves to be unfounded be 
harmonized on a European level and, if so, how? 

5.3. 

Ranking of competing creditors 

If several creditors compete for the amounts held to the credit of a debtor’s bank account, the 
question arises how the different creditors should rank outside insolvency proceedings. While 
some Member States give priority to the first creditor serving the protective order on the bank, 
others apply a group principle similar to the distribution of monies in insolvency proceedings. 
It  will  therefore  have  to  be  considered  whether  this  question  should  be  harmonised  on  a 
European  level  or  left  to  the  law  of  the  Member  State  where  enforcement  takes  place.  A 
similar  question  arises  with  respect  to  the  ranking  of  a  freezing  order  in  the  context  of 
criminal or administrative proceedings.  

Question  22:  Should  there  be  European  rules  that  determine  the  ranking  of  competing 
creditors? If so, which principle should apply? 

5.4. 

“Transformation” into an executory measure 

A  creditor  who  has  blocked  his  debtor’s  account  by  means  of  an  attachment  order  might 
eventually  obtain  an  order  in  the  principle  action  that  is  enforceable  in  the  Member  State 
where  the  account  is  situated,  whether  by  a  declaration  of  enforceability  under  Regulation 
44/2001 or by providing a certificate issued under the rules of the new European procedures 
for small or uncontested claims. This creditor will want to have the seized funds transferred to 
his own account or receive the money by other means. It will need to be considered how an 
attachment can in this case be transformed into an executory measure effecting the transfer of 
the amount seized to the creditor.  

Question  23:  How  should  an  attachment  order  be  transformed  into  an  executory  measure 
once the creditor has obtained an order which is enforceable in the Member State where the 
account is situated?  

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