Mission expenses Vera Jourova

Response to this request is long overdue. By law, under all circumstances, Secretariat General of the European Commission should have responded by now (details). You can complain by requesting an internal review.

Martina Tombini

Dear Secretariat General of the European Commission,

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am hereby requesting access to documents summarising the mission of Commissioner Vera Jourova to Avignon and Prague from 29th July to 29th August 2018. Specifically documents which provide the justification of the expenses of mission and basis and rationale for the commissioner’s participation in “an intensive week long French course”, a summary of the activities for the remainder of the month-long mission, including the purposes of visits to each city.

I also seek documents relating to this “French Language course” such as documents that demonstrate that Commissioners are permitted to charge travel to language courses as part of their mission expenses. In addition, I seek documents relating to the payment for the language course (including the decision to pay for it, and the total amount spent on it), at least to the extent that it was paid for by the European Commission.

I remain at your disposition to answer any questions or clarifications you might have related to this request.

Yours faithfully,

Martina Tombini

Secretariat General of the European Commission

Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
 
 
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
 
 
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
 
 

References

Visible links
1. https://eur-lex.europa.eu/legal-content/...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...

Secretariat General of the European Commission

1 Attachment

Dear Madam,

 

Thank you for your request for access to documents. Unfortunately, you
have not indicated your postal address which is required for registering
and handling your request in line with the procedural requirements.

 

Please send us your full postal address at your earliest convenience.

 

Pending your reply, we reserve the right to refuse the registration of
your request.

 

You may, of course, use directly the electronic form for entering your
request:
[1]http://ec.europa.eu/transparency/regdoc/....

 

Yours faithfully,

 

ACCESS TO DOCUMENTS TEAM (GD)

 

[2]cid:image001.png@01D45409.F767C980

European Commission

Secretariat-General

SG C.1

[3][email address]

 

 

 

show quoted sections

Martina Tombini

Dear Secretariat General of the European Commission,

My apologies for the inconvenience.
My postal address is Calle Cava de San Miguel 8, 4 centro, 28005, Madrid, Spain.

Yours sincerely,

Martina Tombini

Secretariat General of the European Commission

Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
 
 
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
 
 
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
 
 

References

Visible links
1. https://eur-lex.europa.eu/legal-content/...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...

ve_sg.accessdoc (SG), Secretariat General of the European Commission

1 Attachment

Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping

[5]Ares(2019)3115395 - Gestdem 2019/2760 - RE: access to documents request
- Mission expenses Vera Jourova

Sent by ve_sg.accessdoc (SG) <[DG SG request email]>. All responses have
to be sent to this email address.
Envoyé par ve_sg.accessdoc (SG) <[DG SG request email]>. Toutes les
réponses doivent être effectuées à cette adresse électronique.

Dear Madam,

 

Thank you for your e-mail dated 10/05/2019. We hereby acknowledge receipt
of your application for access to documents, which was registered on
10/05/2019 under reference number GestDem 2019/2760.

 

In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents, your application
will be handled within 15 working days.

 

The time limit will expire on 04/06/2019. In case this time limit needs to
be extended, you will be informed in due course.

 

You have lodged your application via the AsktheEU.org website. Please note
that this is a private third-party website which has no link with any
institution of the European Union. Therefore, the European Commission
cannot be held accountable for any technical issues or problems linked to
the use of this system.

 

Please note that the private third party running the AsktheEU.org website
is responsible and accountable for the processing of your personal data
via that website, and not the European Commission. For further information
on your rights, please refer to the third party’s privacy policy.

 

We understand that the third party running that website usually publishes
the content of applicants’ correspondence with the European Commission on
that website. This includes the personal data that you may have
communicated to the European Commission (e.g. your private postal
address).

 

Similarly, the third party publishes on that website any reply that the
Commission will send to the email address of the applicants generated by
the AsktheEU.org website.

 

If you do not wish your correspondence with the European Commission to be
published on the AsktheEU.org website, you can provide us with an
alternative, private e-mail address for further correspondence.

 

In that case, the European Commission will send all future electronic
correspondence addressed to you only to that private address.

 

Yours faithfully,

 

ACCESS TO DOCUMENTS TEAM (GD)

 

[6]cid:image001.png@01D45409.F767C980

European Commission

Secretariat-General

SG C.1

[7][email address]

 

 

 

show quoted sections

ve_pmo.2(PMO), Secretariat General of the European Commission

1 Attachment

Please find attached document Ares(2019)3652706 from SCOGNAMIGLIO Giuseppe (PMO) dated 06/06/2019.

Veuillez trouver ci-joint le document Ares(2019)3652706 de SCOGNAMIGLIO Giuseppe (PMO) daté du 06/06/2019.

Dear Secretariat General of the European Commission,

This is a confirmatory application sent by Martina Tombini on behalf of Access Info Europe. The Confirmatory application is submitted as set out in Article 7(2) of Regulation (EC) No 1049/2001, to challenge the refusal to provide access to documents with details on the mission expenses of Commissioner Vera Jourova, with your reference GESTDEM 2019/2760.

In your response you correctly summarise that the request sought document relating to the mission of Commissioner Vera Jourova to Avignon and Prague from 29th July to 29th August 2018. You write:
More specifically, you would like to obtain documents which “provide the justification of the expenses of mission and basis and rationale for the commissioner’s participation in “an intensive week long French course”, a summary of the activities for the remainder of the month-long mission, including the purposes of visits to each city”.

Your response however fails to list the second part of my request, which read as follows:
I also seek documents relating to this “French Language course” such as documents that demonstrate that Commissioners are permitted to charge travel to language courses as part of their mission expenses. In addition, I seek documents relating to the payment for the language course (including the decision to pay for it, and the total amount spent on it), at least to the extent that it was paid for by the European Commission.

Access Info asks the Commission to reconsider its position on the following grounds.

1. Code of Conduct establishes the principle of transparency: In its response the Commission refers to the Code of Conduct for the Members of the European Commission and the Code of Good Administrative Behaviour implies a redundancy to ask for further details on the expenses of EU Commissioners.

Access Info has previously welcomed the Code of Conduct and the proactive publication of mission costs that it mandates, out of recognition of the benefits of transparency. The Code of Conduct states that mission costs will be published unless a series of public interest reasons come into play; these reasons include public security, defence, international relations, and other exceptions to be found in Article 4.1.a) of Regulation 1049/2001.

Interestingly, the Code of Conduct does not make reference to Article 4.1.b) of the same regulation, which protects the privacy and the integrity of the individual. It might be assumed that this is because the proactive publication of the travel expenses of Europe’s top officials was not considered to be something particularly problematic in terms of data protection.

Indeed, the Code itself establishes the public interest in making public information that is linked to very limited and specific items of personal data, namely the names of the Commissioners who travelled on public business and at the taxpayers’ expense. Quite rightly, the Code does not require the publication of other personal data that might well cause damage to the Commissioners, such, to imagine an example, the numbers of their bank accounts into which any reimbursements might be paid.

It is also important to note that, at least since the adoption of the Code of Conduct, all the Commissioners are informed in advance of the fact that mission expenses associated with their names will be made public.

As an additional point, we note that in your response you note that the Code of Conduct permits mission expenses to be claimed when Commissioners travel, and that: “A mission is defined as travel in the exercise of his or her duties by a Member away from the Commission's place of work.” Hence it should be possible to confirm that such duties include attending language courses.

2. The Commission failed to identify the documents that fall under the scope of this request: In your response you do not specifically identify which documents it holds that it has determined to fall under the scope of this request. This means that in preparing this confirmatory application, we are somewhat in the dark as to how to structure some of the arguments. For example, we do not know if some of the information is held in databases from which it could be extracted, or whether it comes in the form of a travel claim, invoices, memos, emails or other material which would provide clarity as to on what the funds were spent.
We therefore ask you to provide more details in your response to this confirmatory and a list of the documents that you have identified that fall under the scope of this request.

3. Regulation 1049/2001 applies: Whilst the Code of Conduct requires certain proactive publication, it in no way establishes a specific regime for access to documents, and with respect to this request, it is Regulation 1049/2001 that must be considered.

The Code of Conduct can neither limit nor be the basis for deciding on whether or not further information be released to the public.

Regulation 1049/2001 is the instrument that sets out the mechanisms for implementing the right of access to documents as protected in Article 15 of the Treaty of the Functioning of the European Union and in Article 42 of the Charter of Fundamental Rights. These require that “Union institutions, bodies, offices and agencies shall conduct their work as openly as possible.”

Hence any documents requested under these rules are to be considered to be, prima facie, in the public domain unless an exception applies.

4. The requested documents do not relate in their entirety to privacy or personal data. The Commission asserts that the “documents falling under the scope of your request contain information concerning identified natural persons, namely Commissioner Vera Jourova and they reveal in a detailed manner how, where and when the Commissioner spent these amounts. Therefore, they undoubtedly consist of information that qualifies as personal data.”

There are two problems with this conclusion. The first is that part of my request sought documents which have nothing to do with Commissioner Jourova, but are much more general in nature. These documents are those in part of the request that you have ignored in your response, namely documents demonstrating that Commissioners are permitted to charge travel to language courses as part of their mission expenses.

The second is that it is already known, from the proactively published travel expenses, that Vera Jourova was associated with the spending of certain amounts of money. What has been requested here is additional details about the nature of the spending. Details of how public funds are spent on public business are not private data per se. That it was a particular Commissioner who spent the funds is already public, and hence to provide details relating to that spending such as the decision making process around undertaking certain missions would not have any impact at all on privacy or personal data as the name of the person is already in the public domain and the fact that the mission was undertaken means that it should have already fulfilled the conditions of the Code of Conduct; what we have asked for here is information about the decision-making process rather than any further personal details. Hence, it is entirely possible for the Commission to respond to the request without providing any further personal data.

The same argumentation goes for the part of the request that you do not seem to have considered: I sought documents relating to the payment for the language course, including the decision to pay for it, and the total amount spent on it, at least to the extent that it was paid for by the European Commission. This is information that you either hold or do not hold, that details spending of public funds. The fact that the Commissioner attended the French course is already known. Reporting to the public as to whether or not the Commission paid for it and, if so, the cost, would not intrude on the privacy or personal data of the Commissioner.

Furthermore, to the extent that the documents to relate to personal data – one might imagine, for example, that the justification for the course includes an evaluation of the level of competence in the French language of the Commissioner – could easily be redacted so as to provide partial access to the documents. Such partial access is mandate by Regulation 1049/2001 for any information that does not fall under one of the exceptions. Given that the Commission has not invoked any other exception, it should be possible to provide at least partial access to these documents. We urge you to reconsider your decision and to supply us with the documents requested, with any genuinely personal data redacted as appropriate.

5. The Commission has failed to properly apply Regulation No. 2018/1725. Following its conclusion that all the requested documents fall under the scope of Article 4.1.b) of Regulation 1049/2001, the Commission the conducts an analysis using Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data.
Even in the event that it would be correct to conclude that Article 4.1.b) applies to the entirety of the requested documents (which we contest), we believe that the Commission has erred in its interpretation of Regulation No. 2018/1725.
In the first instance we note that the fact that the Commissioners will be aware of the Code of Conduct and the proactive publication of the travel expenses, means that they will have a high expectation that their personal data (meaning in this case only their names, no more) will be made public associated with the spending per trip undertaken on public business and using public funds. Indeed, in this sense the Code of Conduct establishes a legal basis for the publishing of the data, deriving as it does from the principles of transparency set out in the treaties of the European Union, and confirmed repeatedly in the case law of the Court.

From this it can be assumed that the Commissioners have been informed of the processing of their personal data, which will be for purposes of account keeping and auditing, and also for purposes of transparency and accountability to the European public. Such processing of this data would then be in line with Article 5 of Regulation 2018/1725, given that a request for access to documents from any citizen is in and of itself an affirmation of the purpose of the processing, which is to ensure transparency; no further arguments should be needed by the requester. (We would argue that Article 6 also applies given that the purpose of transparency is an end compatible with that for which the data were collected).

Without prejudice to our assertion that the fact that data about the spending of public funds by Europe’s highest level public carrying out public activities about which much related information has been made public, Access Info has set out in Point 5 below our arguments as to the public interest in providing these documents.

Now, once the public interest has been established, the Commission is obliged to apply the balancing test ensuring that the principle of proportionality is taken into account, to determine whether release of the data would indeed prejudice legitimate interest. There is nothing in the decision notice to demonstrate that the Commission did indeed carry out such a balancing.

Nor is there any evidence in your decision that you have examined in detail the nature or scale of the harm that would be caused to the person whose privacy personal data you are assert that you are protecting (Commissioner Jourova in this case). The Court of Justice has ruled that the assessment of harm to a protected interest should be done so as to demonstrate how the protected interest would be actually and specifically undermined by release of the documents.

6. There is a public interest in providing this information: First, by stating clearly in our request that it was made in exercise of “the right of access to documents in the EU treaties, as developed in Regulation 1049/2001,” Access Info explicitly established a legitimate public interest in obtaining the information and had indicated to the Commission the legal grounds for providing the documents out of “compliance with a legal obligation to which the controller is subject” (Article 5).

The principles of good governance and participation set out in Article 15 TFEU as developed through the case law of the European Court of Justice as well as decisions of the European Ombudsman clearly point to the principle of maximum possible transparency in the spending of public funds. This includes transparency around the use of public funds, which is what this request is about. Hence these provisions establish a prima facie necessity to process and transfer this data.

Access Info Europe is a human rights organisation whose mission is to promote transparency, in particular to permit public participation, and to promote accountability and to support the fight against corruption. We provide support to those interested in obtaining information, including civil society, journalists, and members of the public. Our mission is to use access to information and access to documents rules to secure access to information which we believe should be public, consistent with the international human rights standards on the right of access to information which permit only limited exceptions.

As a civil society organisation, Access Info Europe plays a watchdog role akin to that of journalists in line with the European Court of Human Rights jurisprudence on access to information (see, for example, the case of Társaság a Szabadságjogokért v. Hungary, App. No. 37374/05, ECHR, 14 April 2009). We therefore have a legitimate interest in obtaining information about the use of public funds, and this request forms part of that line of enquiry.

Access Info Europe both requests information itself and assists others in obtaining information. When Access Info Europe makes requests such as this one via the AsktheEU.org website the data becomes available to all members of the European (and indeed the global) public for them to exercise their rights to participation, to engage in public debate, to hold public bodies accountable.

Such transparency is essential in the current political context, where there is rising Euroscepticism and with it an ongoing debate about the role and functions of Commissioners, as well as more broadly about the salaries and expenses payments made by European taxpayers to public officials in Brussels. Basic information such as how the Commissioners spend funds, with details on how the funds are used, is essential to have an informed and accurate debate about the way in which Brussels functions.

Access Info Europe aims with this request to contribute directly and specifically to that public debate, sharing, as we have done in the past, such information in order to broaden and deepen understanding of the use of public funds in Brussels, and hence to provide greater legitimacy to the work of the European Commission.

As noted above, we very much welcome the proactive publication of mission expenses by the Commission, as a result of our campaigning, as we strongly believe that of such transparency can ensure a fact-based debate about the European Union, permitting misinformation to be countered.

This is why Access Info Europe calls on the Commission thoroughly to review the refusal to provide the requested documents, full and adequately taking the above arguments and reasoning into account.

Please do not hestiate to contact me should you require any clarifications on this confirmatory application.

Yours sincerely

Martina Tombini
Access Info Europe

ve_sg.accessdoc (SG), Secretariat General of the European Commission

[1]Ares(2019)4155536 - Gestdem 2019/2760 - confirmatory request

Sent by ve_sg.accessdoc (SG) <[DG SG request email]>. All responses have
to be sent to this email address.
Envoyé par ve_sg.accessdoc (SG) <[DG SG request email]>. Toutes les
réponses doivent être effectuées à cette adresse électronique.

Dear Madam,

Thank you for your email dated 27/06/2019 by which you request, pursuant
to Regulation No 1049/2001 regarding public access to European Parliament,
Council and Commission documents, a review of the position taken by DG
HR/PMO in reply to your initial application GESTDEM 2019/2760.

We hereby acknowledge receipt of your confirmatory application for access
to documents which was registered on 01/07/2019 (Ares(2019)4155293).

Your application will be handled within 15 working days (22/07/2019). In
case this time limit needs to be extended, you will be informed in due
course.

Please be informed that the answer to your confirmatory application is a
formal Commission decision that will be notified to you by express
delivery. Thank you for providing your contact phone number, so that the
external delivery service can contact you in case of absence.

Please note that the Commission will not use your phone number for any
other purpose than for informing the delivery service, and that it will
delete it immediately thereafter.

Yours faithfully,

Access to documents team (RC)
SG.C.1
Transparency

show quoted sections

ve_sg.accessdoc (SG), Secretariat General of the European Commission

1 Attachment

Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping

[5]Ares(2019)4744446 - 1st holding reply TOMBINI 2019/2760

Sent by ve_sg.accessdoc (SG) <[DG SG request email]>. All responses have
to be sent to this email address.
Envoyé par ve_sg.accessdoc (SG) <[DG SG request email]>. Toutes les
réponses doivent être effectuées à cette adresse électronique.

Dear Ms Tombini,

 

I refer to your email of 27 June 2019, registered on 1 July 2019, by which
you submit a confirmatory application in accordance with Article 7(2) of
Regulation (EC) No 1049/2001 regarding public access to European
Parliament, Council and Commission documents ("Regulation (EC) No
1049/2001").

 

Your confirmatory application is currently being handled. Unfortunately,
we have not yet been able to gather all the elements needed to carry out a
full analysis of your request and to take a final decision. Therefore, we
are not in a position to reply to your confirmatory request within the
prescribed time limit expiring on 22 July 2019. Consequently, we have to
extend this period by another 15 working days in accordance with Article
8(2) of Regulation (EC) No 1049/2001. The new deadline expires on 12
August 2019.

 

However, I can assure you that we are doing our utmost to provide you with
a final reply within the next 15 working days. I regret this additional
delay and sincerely apologize for any inconvenience this may cause.

 

Yours sincerely,

 

María OLIVÁN AVILÉS
Head of Unit

[6]cid:image001.gif@01D13362.41D673C0

European Commission

Secretariat General

Unit C.1 (Transparency, Document Management and Access to Documents)

 

 

References

Visible links
1. file:///tmp/cid:filelist.xml@01D5407D.4D11A7B0
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/ext/doc...

ve_sg.accessdoc (SG), Secretariat General of the European Commission

1 Attachment

Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping

[5]Ares(2019)5198069 - 2nd holding reply- TOMBINI 2019/2760

Sent by ve_sg.accessdoc (SG) <[DG SG request email]>. All responses have
to be sent to this email address.
Envoyé par ve_sg.accessdoc (SG) <[DG SG request email]>. Toutes les
réponses doivent être effectuées à cette adresse électronique.

Subject: Your confirmatory application for access to documents under
Regulation (EC) No 1049/2001 – GESTDEM 2019/2760

 

Dear Ms Tombini,

I refer to your email of 27 June 2019, registered on 1 July 2019, by which
you submit a confirmatory application in accordance with Article 7(2) of
Regulation (EC) No 1049/2001 regarding public access to European
Parliament, Council and Commission documents[6]^[1] (‘Regulation (EC) No
1049/2001’).

I also refer to our holding reply of  22 July 2019, by which the time
limit for replying to your confirmatory application was extended by 15
working days, pursuant to Article 8(2) of the Regulation. This extended
time limit expires on 12 August 2019.

 

I regret to have to inform you that we will not be able to respond within
the extended time-limit, as we have not yet finalised internal
consultations and have not yet been able to gather all the elements needed
to carry out a full analysis of your request and to take a final decision.

 

I can assure you that we are doing our utmost to provide you with a final
reply as soon as possible. I regret this additional delay and sincerely
apologise for any inconvenience this may cause.

 

Yours sincerely,

 

María OLIVÁN AVILÉS
Head of Unit

[7]cid:image001.gif@01D13362.41D673C0

European Commission

Secretariat General

Unit C.1 (Transparency, Document Management and Access to Documents)

 

 

------------------------

[8][1]      Official Journal L 145 of 31.5.2001, p. 43.

References

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1. file:///tmp/cid:filelist.xml@01D550F3.63CDBBC0
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/ext/doc...
6. file:///tmp/foiextract20190812-1938-4psuj4#_ftn1
8. file:///tmp/foiextract20190812-1938-4psuj4#_ftnref1