boardman v phipps criticismeast hampton press classifieds

If you see Sign in through society site in the sign in pane within a journal: If you do not have a society account or have forgotten your username or password, please contact your society. Select your institution from the list provided, which will take you to your institution's website to sign in. HL (majority 3-2) held that S and B would hold their acquired shares as constructive trustees for the beneficiaries. The direct tyranny will come on by and by, after it shall have gratified the multitude with the spoil and ruin of the old institutions of the land.Samuel Taylor Coleridge (17721834), From scenes like these old Scotias grandeur springs,That makes her loved at home, revered abroad;Princes and lords are but the breath of kings,An honest mans the noblest work of God!Robert Burns (17591796), "It is perhaps stated most highly against trustees or directors in the celebrated speech of Lord Cranworth L.C. Oxbridge Notes in-house law team. The trust property included a substantial shareholding in a private company. A fiduciary agent has to account to for any profits acquired by reason of the his fiduciary position and the opportunity or knowledge resulting from it, even if the principals could not have made the . Boardman and another trustee, Fox, therefore . For faster navigation, this Iframe is preloading the Wikiwand page for Boardman v Phipps . Do not use an Oxford Academic personal account. % It concludes that the conduct-based approach in Boardman v Phipps should be rejected, and that the unjust enrichment-based approach provided by Warman International Ltd v Dwyer should be The claim for repayment cannot, however, be allowed to extend further than the justice of the case demands. A breach of a fiduciary duty is of strict liability, regardless of their intention Boardman v Phipps 1967 1. Current issues of the journal are available at http://www.journals.cambridge.org/clj. In my view it means that the reasonable man looking at the relevant facts and circumstances of the particular case would think that there was a real sensible possibility of conflict; not that you could imagine some situation arising which might, in some conceivable possibility in events not contemplated as real sensible possibilities by any reasonable person, result in a conflict.". Lord Cohen said the information is not truly property and it does not necessarily follow that, because an agent acquired information and opportunity while acting in a fiduciary capacity, he is accountable. Part II describes the rationales for adopting each of the approaches to awarding allowances to dishonest fiduciaries. Penn v Lord Baltimore (1750) Paul Mitchell . %PDF-1.5 The majority disagreed about the nature and relevance of information used by Boardman and Phipps. To purchase short-term access, please sign in to your personal account above. enough, and that am attempt to take control of the company should be initiated. Boardman v Phipps. Boardman v Phipps (1967) Michael Bryan; 21. His lordship, with respect . Study with Quizlet and memorize flashcards containing terms like Intro, Intro for fiduciaries, Boardman v Phipps (1967) and more. Register, Oxford University Press is a department of the University of Oxford. Lord Denning MR, Russell LJ and Pearson LJ upheld Wilberforce J's decision and held that Boardman and Phipps had breached his duty of loyalty, which arose as they had become self-appointed agents representing the trust, by putting themselves in a conflict of interest. Many of these journals are the leading academic publications in their fields and together they form one of the most valuable and comprehensive bodies of research available today. Another beneficiary (P) claimed conflict of interest and demanded her share of the profit, because of S fiduciary role. The proceedings. With the full knowledge of the trustees, Boardman and Phipps purchased a majority stake of the shares themselves. They bought a majority stake. Lord Upjohn also agreed with Lord Cohen that information is not property at all, although equity will restrain its transmission if it has been acquired by a breach of confidence. 399, 400 (PC). It furthers the University's objective of excellence in research, scholarship, and education by publishing worldwide, This PDF is available to Subscribers Only. He and a beneficiary, Tom Phipps, went to a shareholders' general meeting of the company. Boardman, the The beneficiary principle in the 21st century, Subscription prices and ordering for this journal, Purchasing options for books and journals across Oxford Academic, Receive exclusive offers and updates from Oxford Academic. <> The majority disagreed about the nature and relevance of information used by Boardman and Phipps. John Phipps and another beneficiary, sued for their profits, alleging a conflict of interest by Boardman and Phipps. The problem was that the trust instrument itself did not allow the investment of, Boardman purporting to act on behalf of the trust (relationship of agenc, discovered the likely cost of the shares and purchased the shares in his own, At all points, Boardman had acted honestly, After Boardman had purchased the controlling interest in the company. S+QMS^ kUeH|8H4W,G*3R]wHgMY&,*Hu`IcFWB Therefore, Boardman was speculating with trust property and should be liable. in. Therefore S and B invested themselves and the company did very well, improving the value of the shares held by themselves individually and by the trust. His statement has . This item is part of a JSTOR Collection. Boardman appealed against a finding that he was a constructive trustee for, or agent did not necessarily render him accountable for profit from its use, yet in, the present case, as both the information which satisfied B and P, purchase of the shares would be a good investment and the opportunity to bid, came as a result of B acting on behalf of the trustees B and P, trustees of five eighteenths of the shares in the company for the respondent and, were liable to account to him for the profit thereon accordingly, Human Rights Law Directions (Howard Davis), Tort Law Directions (Vera Bermingham; Carol Brennan), Marketing Metrics (Phillip E. Pfeifer; David J. Reibstein; Paul W. Farris; Neil T. Bendle), Public law (Mark Elliot and Robert Thomas), Commercial Law (Eric Baskind; Greg Osborne; Lee Roach), Introductory Econometrics for Finance (Chris Brooks), Criminal Law (Robert Wilson; Peter Wolstenholme Young), Principles of Anatomy and Physiology (Gerard J. Tortora; Bryan H. Derrickson), Electric Machinery Fundamentals (Chapman Stephen J. Paragon Finance plc v DB Thakerar & Co (a . But they did not obtain the fully informed consent of all the beneficiaries. *Lecturer in Law at University of East London, Email: Search for other works by this author on: The Author (2008). The trust benefited by this distribution 47,000, while Boardman and Phipps made 75,000. The Trustee (T) refused to let them invest on behalf of the trust. As the judge said: "it would be inequitable now for the beneficiaries to step in and take the profit without paying for the skill and labour which has produced it.". "And it is a rule of universal application, that no one, having such duties to discharge, shall be allowed to enter into engagements in which he has, or can have, a personal interest conflicting, or which possibly may conflict, with the interests of those whom he is bound to protect. However, to do this he needed a majority shareholding in the company. Viscount Dilhorne. Boardman v Phipps answers this question: in the affirmative. P0Y|',Em#tvx(7&B%@m*k law since Boardman v Phipps. A fiduciary shall not profit from his position, Appeal dismissed; the defendants were liable to account for the shares and profits to the trust beneficiaries, but the liberal allowance was maintained, A fiduciary agent has to account to for any profits acquired by reason of the his fiduciary position and the opportunity or knowledge resulting from it, even if the principals could not have made the profits themselves with such opportunity or knowledge, unless the principal has given his informed consent, The profits will be held on constructive trust for the principal by the fiduciary agent, but the board may make allowance to the fiduciary agent for expenditure and work expended to acquire the profit, The defendants, Boardman and another, were acting as solicitors to the trustees of a will trust, and therefore were fiduciaries but not trustees, The trustees were minority shareholders in a private company which was being inefficiently managed, Boardman and one of the beneficiaries under the trust, in good faith, personally financed the purchase of a controlling interest in the company, in order to reorganise it to the benefit of the trust holding, Both the personal and trust holdings increased in value as a result of the reorganisation; one of the other beneficiaries therefore sought an account of the personal profits made by the defendants, Wilberforce J, in the High Court, held that the defendants were liable to account for the profit less the money spent on realising that profit; but at the same time made a liberal allowance for the work put in to realise that profit, The defendants appealed to the Court of Appeal, who dismissed their appeal; they subsequently appealed to the House of Lords. He attended the annual general meeting of Lester &amp; Harris Ltd, a company in which the trust had a substantial shareholding. S;70[`J)LQ,ecX_LK,*q3>~ B=eA* He (and a beneficiary) purchased shares in a company in which the trust already had a substantial holding. Whether or not the trust or the beneficiaries in their stead could have taken advantage of the information is immaterial: p. 111A, The question whether or not there was a fiduciary relationship at the relevant time must be a question of law and the question of conflict of interest directly emerges from the facts pleaded, otherwise no question of entitlement to a profit would fall to be considered. The Trustee (T) refused to let them invest on behalf of the trust. Pettitt v Pettitt (1970) and Gissing v Gissing (1971) John Mee; 22. He also obtained detailed trading accounts of the English and Australian arms of the business. This authentication occurs automatically, and it is not possible to sign out of an IP authenticated account. Copyright 2023 StudeerSnel B.V., Keizersgracht 424, 1016 GC Amsterdam, KVK: 56829787, BTW: NL852321363B01, co-appellant was another son of the testator, described as constructive trustees by virtue of a fiduciary relationship to the, B decided along with one of the trustees that the company was not doing well. will. Request Permissions, Editorial Committee of the Cambridge Law Journal. Boardman v Phipps [1967] 2 AC 46, [1966] 3 WL R 1009, [1966] 3 All ER 721. They wanted to invest and improve the company. stream Some societies use Oxford Academic personal accounts to provide access to their members. Boardman v Phipps (1967) was an example of the application of strict liability. . Shibboleth / Open Athens technology is used to provide single sign-on between your institutions website and Oxford Academic. I think there should be a generous remuneration allowed to the agents. S+QMS^ kUeH|8H4W,G*3R]wHgMY&,*Hu`IcFWB He said unequivocally that knowledge learnt by a trustee in the course of his duties is not property of the trust and may be used for his own benefit unless it is confidential information which is given to him (i) in circumstances which, regardless of his position as a trustee, would make it a breach of confidence to communicate it to anyone or (ii) in a fiduciary capacity. Cambridge University Press is committed by its charter to disseminate knowledge as widely as possible across the globe. His liability to account depends on the facts. The majority agreed unanimously that liability to account for the profits made by virtue of a fiduciary relationship is strict and does not depend on fraud or absence of bona fides, and so Phipps and Boardman would have to account for their profits. On the 1st March, 1962, the Respondent John Anthony Phipps com- menced an action against his younger brother, Thomas Edward Phipps and Mr. T. G. Boardman, a solicitor and partner in the firm of Messrs. Phipps & . The trust benefited by this distribution 47,000, while Boardman and Phipps made 75,000. Did Boardman and Tom Phipps breach their duty to avoid a conflict of interest, despite the fact that the company made a profit and they had obtained (some) consent from the beneficiaries? If the defendant has done valuable work in making the profit, then the court in its discretion may allow him a recompense. His daughter, Mrs Newman, was one of the trustees. Show all summaries ( 46 ) Priority of trustees indemnity inter se: pari passu or first in time priority? His Lordship distinguished Regal (Hastings) v Gulliver by restricting Regal Hastings to circumstances concerned with property of which the principals were contemplating a purchase. Each issue also contains an extensive section of book reviews. For more information, visit http://journals.cambridge.org. Material Facts Boardman was the solicitor for a family trust. Cambridge University Press (www.cambridge.org) is the publishing division of the University of Cambridge, one of the worlds leading research institutions and winner of 81 Nobel Prizes. F5aE}*?fxl1oA+;{ S>"~qOf~AcW|g[ VFaxb'o Tns34}#rPDB Proprietary relief in Boardman v Phipps 3 the trustees, although Ethel, who suffered from senile dementia, took no active role in the trust affairs at the material time. Some societies use Oxford Academic personal accounts to provide access to their members. This article explores how the dissenting judgment of Lord Upjohn in Boardman v Phipps has been preferred by the lower courts and why the courts have adopted such a position. The institutional subscription may not cover the content that you are trying to access. Boardman v Phipps (1967) was a classic illustration of the principles set out in Lord Russell's statement. Oxbridge Notes uses cookies for login, tax evidence, digital piracy prevention, business intelligence, and advertising purposes, as explained in our O(Grx+Q_[%Dm%|(Dy m%Cn(Dy(o%~(Jg(Q[tJD|(R(GIAK(xRph1%Z'-Y!bO-FDY b<9hHJO-F?!b<98HO-F!b-f b. Such persons will, however, be entitled to payment on a liberal scale for their work and skill. BOARDMAN and Another v. PHIPPS Viscount Dilhorne Lord Cohen Lord Hodson Lord Guest Lord Upjohn. F5aE}*?fxl1oA+;{ S>"~qOf~AcW|g[ VFaxb'o Tns34}#rPDB <>>> Annetts v McCann (1990) 170 CLR 596. Special emphasis is placed on contemporary developments, but the journal's range includes jurisprudence and legal history. students are currently browsing our notes. Lord Upjohn was in dissent in Boardman v. Phipps, but his dissent was "on the facts but not on the law": Queensland Mines Ltd. v. Hudson (1978) 52 A.L.J.R. Boardman V Phipps - Judgment - House of Lords House of Lords The majority of the House of Lords (Lords Cohen, Guest and Hodson) held that there was a possibility of a conflict of interest, because the solicitor and beneficiary might have come to Boardman for advice as to the purchases of the shares. They suggested to a trustee (Mr Fox) that it would be desirable to acquire a majority shareholding, but Fox said it was completely out of the question for the trustees to do so. Associated Provincial Picture Houses Ltd v Wednesbury Corporation [1948] 1 KB 223. Don't already have a personal account? Is it a conflict? The House of Lords maintained the strict rule that historically equity has imposed on a fiduciary. On this Wikipedia the language links are at the top of the page across from the article title. His liability to account depends on the facts. [1] The trust assets include a 27% holding in a company (a textile company with factories in Coventry, Nuneaton and in Australia through a subsidiary). He said unequivocally that knowledge learnt by a trustee in the course of his duties is not property of the trust and may be used for his own benefit unless it is confidential information which is given to him (i) in circumstances which, regardless of his position as a trustee, would make it a breach of confidence to communicate it to anyone or (ii) in a fiduciary capacity. %PDF-1.5 The majority of the House of Lords (Lords Cohen, Guest and Hodson) held that there was a possibility of a conflict of interest, because the solicitor and beneficiary might have come to Boardman for advice as to the purchases of the shares. The trust assets include a 27% holding in a textile company called Lexter & Harris. His Lordship regarded Boardman to be liable because he acquired the information in the course of the fiduciary relationship and because of the fiduciary relationship. His Lord Cohen (on a point with which Hodson and Cohen agreed): S had placed himself in a position of potential CoI, for example if the trustees asked his advice on the merits of buying more shares in the company. They wanted to invest and improve the company. It depends on the circumstances. in Aberdeen Railway v. Blaikie, 136 where he said: "And it is a rule of universal application, that no one, having such duties to discharge, shall be allowed to enter into engagements in which he has, or can have, a personal interest conflicting, or which possibly may conflict, with the interests of those whom he is bound to protect. (Keech v Sandford 1726) - landlord would not grant new lease to beneficiary so trustee took in his own name. Boardman felt that by asset-stripping the company he could increase the value of the shares. He and a beneficiary, Tom Phipps, went to a shareholders' general meeting of the company. Society member access to a journal is achieved in one of the following ways: Many societies offer single sign-on between the society website and Oxford Academic. ", The phrase "possibly may conflict" requires consideration. Boardman v Phipps seems like a more onerous application of rule against an unauthorised profit than that in Regal Hastings, all that is apparently required for a fiduciary to be liable is that ' a reasonable man looking at the relevant facts would think there was a real possibility of . Final, Pharmaceutical Calculations practice exam 1 worked answers, Acoples-storz - info de acoples storz usados en la industria agropecuaria. xksgD2u$N+xH)%"dU &c~m_WMnny|t80^olIv"+E] mv}f"gv UY Fe_go_eu6[xGLBdUS-?b\4?s=}GO0upAQ![*`E"~ In April 1997, Mrs Newman and her husband granted a lease of 1 Vicarage . For librarians and administrators, your personal account also provides access to institutional account management. Land law - Introduction to land law with description of its history, Introduction to Sports Massage and Soft Tissue Practices, Legal and Professional Aspects of Optometry (BIOL30231), Access to Health Professionals (4000773X), Business Data Analysis (BSS002-6/Ltn/SEM1), Introductory Chemistry (0FHH0023-0901-2018), Introduction toLegal Theory andJurisprudence, Introduction to English Language (EN1023), Cell Membranes - Lecture notes, lectures 1 - 24. 39^40. By using Applicant VEAL of 2002 v Minister for Immigration & Multicultural & Indigenous Affairs [2003] FCA 437. Click the account icon in the top right to: Oxford Academic is home to a wide variety of products. They owed fiduciary duties (to avoid any possibility of a conflict of interest) because they were negotiating over use of the trust's shares. They owed fiduciary duties (to avoid any possibility of a conflict of interest) because they were negotiating over use of the trust's shares. T he appellant B was a solicitor who acted as an advisor to the trustees. 7 Boardman v. Phipps [1967] 2 A.C. 46, 124 per Lord Upjohn. 25% off till end of Feb! It publishes over 2,500 books a year for distribution in more than 200 countries. privacy policy. On this, Lord Denning MR said (at 1021). Part II describes the rationales for adopting each of the approaches to awarding allowances to dishonest fiduciaries. Lord Upjohn also agreed with Lord Cohen that information is not property at all, although equity will restrain its transmission if it has been acquired by a breach of confidence. The full text is available here: http://www.bailii.org/uk/cases/UKHL/1966/2.html, -- Download Boardman v Phipps [1967] 2 AC 46 as PDF --, Transvaal Lands Co v New Belgium (Transvaal) Lands & Development CO [1914] 2 Ch 488, http://www.bailii.org/uk/cases/UKHL/1966/2.html, Download Boardman v Phipps [1967] 2 AC 46 as PDF. They owed fiduciary duties (to avoid any possibility of a conflict of interest) because they were negotiating over use of the trusts shares. Sealy, Commercial Law and Commercial Reality (London 1984), pp. 4 0 obj House of Lords. Boardman v Phipps [1966] UKHL 2 is a landmark English trusts law case concerning the duty of loyalty and the duty to avoid conflicts of interest. They suggested to Mr Fox, a trustee, that it would be desirable to acquire a majority shareholding, but Fox disagreed. Read more about this topic: Boardman V Phipps, Judgment, A severe though not unfriendly critic of our institutions said that the cure for admiring the House of Lords was to go and look at it.Walter Bagehot (18261877), The welcome house of him my dearest guest.Where ever, ever stay, and go not thence,Till natures sad decree shall call thee hence;Flesh of thy flesh, bone of thy bone,I here, thou there, yet both but one.Anne Bradstreet (c. 16121672), You see how this House of Commons has begun to verify all the ill prophecies that were made of itlow, vulgar, meddling with everything, assuming universal competency, and flattering every base passionand sneering at everything noble refined and truly national. Boardman v Phipps is a leading authority on the no-conflict rule. Facts: Boardman was solicitor of family trust, which included a 27% holding in a textile company. endobj See below. The case for tracing forward not backward through an overdraft. Mr Tom Boardman was the solicitor of a family trust. In 1996 Mr Clarke settled 150,000 on trust to benefit various family members including his grandchildren, Brooke and Billy. However, they would be able to retain a generous remuneration for the services he performed. If the agent has been guilty of any dishonesty or bad faith, or surreptitious dealing, he might not be allowed any remuneration or reward. When on the society site, please use the credentials provided by that society. Tom Boardman was a solicitor for a family trust. 'Rules of equity have to be applied to such a great diversity of circumstances that they can be stated only in the most general terms and applied with particular attention to the exact circumstances of each case. Boardman and Tom Phipps, a beneficiary of the trust, attended a general meeting of the company. Do not use an Oxford Academic personal account. Choose this option to get remote access when outside your institution. Enter your library card number to sign in. WI[y*UBNJ5U,`5B1F :IK6dtdj::yj S;70[`J)LQ,ecX_LK,*q3>~ B=eA* trust. In the present case, as the purchase of the shares was entirely out of the question, Regal Hastings was said to be inapplicable. Chase Manhattan Bank v Israel-British Bank Ltd, Industrial Development Consultants v Cooley, https://en.wikipedia.org/w/index.php?title=Boardman_v_Phipps&oldid=1123060721, Creative Commons Attribution-ShareAlike License 3.0, [1965] Ch 992, [1965] 2 WLR 839 and [1964] 1 WLR 993, Viscount Dilhorne, Lord Cohen, Lord Hodson, Lord Guest and Lord Upjohn, This page was last edited on 21 November 2022, at 15:30. <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 17 0 R 22 0 R 23 0 R 25 0 R 35 0 R 36 0 R 40 0 R 42 0 R] /MediaBox[ 0 0 594.96 842.04] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> But when, as in this case, the agents acted openly and above board, but mistakenly, then it would be only just that they should be allowed remuneration. It is not contended that the trustees had such knowledge or gave such consent. p. 117D G, The relevant rule for the decision of this case is the fundamental rule of equity that a person in a fiduciary capacity must not make a profit out of his trust which is part of the wider rule that a trustee must not place himself in a position where his duty and his interest may conflict.: p. 123C, Whether there is a possibility of conflict depends on whether the reasonable man looking at the relevant facts and circumstances of the particular case would think that there was a real sensible possibility of conflict: p. 124B, Note that in this case, not only did the principals, which are the trust beneficiaries, no lose anything, but they actually profited from the increase in value of shares held under the trust as a result of the actions of defendants thus it can be surmised that regardless of whether any wrongdoing or harm was caused to the principal, the fiduciary is liable for all profits acquired as a result of his position. The trust benefited by this distribution 47,000, while Boardman and Phipps made 75,000. The Cambridge Law Journal publishes articles on all aspects of law. However they were generously remunerated for their services to the trust. principal shareholder group, Boardman obtained information about the factories of Lester & Harris in Coventry and Nuneaton and its property in Australia. Therefore, Boardman was speculating with trust property and should be liable. This is a famous case in which John Phipps successfully claimed that, flowing fro. ), Rang & Dale's Pharmacology (Humphrey P. Rang; James M. Ritter; Rod J. 2010-2023 Oxbridge Notes. The solicitor to a family trust (S) and one Beneficiary (B)-there were several-went to the board meeting of a company in which the trust owned shares. His Lordship regarded Boardman to be liable because he acquired the information in the course of the fiduciary relationship and because of the fiduciary relationship. This article explores . &Thb;ynxP\ -|tLo9sRx[8-a5& 'vd `f@). Published by Oxford University Press. Become Premium to read the whole document. However the court exercised its inherent jurisdiction to make a monetary award to S for his services to improving the value of the trust. 3 0 obj criticism, see L.S. This article is also available for rental through DeepDyve. Access to content on Oxford Academic is often provided through institutional subscriptions and purchases. The House of Lords maintained the strict rule that historically equity has imposed on a fiduciary. way. my lords. Wilberforce J held that Boardman was liable to pay for his breach of the duty of loyalty by not accounting to the company for that amount of money, but that he could be paid for his services. The articles and case notes are designed to have the widest appeal to those interested in the law - whether as practitioners, students, teachers, judges or administrators - and to provide an opportunity for them to keep abreast of new ideas and the progress of legal reform. Boardman was speculating with trust property and should be liable. able to bring it back to profit, and the trust fund benefited. However, the circumstances were quite different to those in Boardman v Phipps. CASE BRIEF TEMPLATE. Mr Boardman (the trust's solicitor) investigated the affairs of the company, initially on behalf of the trust, and gained useful information. Coke v Fountaine (1676) Mike Macnair; 3. endobj The proposition of law involved in this case is that no person standing in a fiduciary position, when a demand is made upon him by the person to whom he stands in the fiduciary relationship to account for profits acquired by him by reason of his fiduciary position and by reason of the opportunity and the knowledge, or either, resulting from it, is entitled to defeat the claim upon any ground save that he made profits with the knowledge and assent of the other person.: The appellants obtained knowledge by reason of their fiduciary position and they cannot escape liability by saying that they were acting for themselves and not as agents of the trustees. Constructive trusts, unjust enrichment, tracing 2010 Cases, Written by Oxford & Cambridge prize-winning graduates, Includes copious academic commentary in summary form, Concise structure relating cases and statutes into an easy-to-remember whole. 1 0 obj The residuary estate included 8000 shares in J.ester & Harris Ltd., an underperforming private company with issued share capital of 3l),000 1 ordinary shares. 2011 Editorial Committee of the Cambridge Law Journal (eg- acting for multiple people) a. When on the institution site, please use the credentials provided by your institution. Nicholas Collins, The no-conflict rule: the acceptance of traditional equitable values?, Trusts & Trustees, Volume 14, Issue 4, May 2008, Pages 213224, https://doi.org/10.1093/tandt/ttn009. It was irrelevant that S had acted in an open and honest (and profitable!) This is because there is no possibility the trustee would seek Boardman's advice to purchase the shares and at any rate Boardman could have declined to act if given such request. endobj Case summary last updated at 24/02/2020 14:46 by the View the institutional accounts that are providing access. Here you will find options to view and activate subscriptions, manage institutional settings and access options, access usage statistics, and more. stream <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 17 0 R 22 0 R 23 0 R 25 0 R 35 0 R 36 0 R 40 0 R 42 0 R] /MediaBox[ 0 0 594.96 842.04] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>>

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