Relevant bibliographies by topics / Probate law and practice, massachusetts

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Academic literature on the topic 'Probate law and practice, massachusetts'

Author: Grafiati
Published: 29 July 2024

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Journal articles on the topic "Probate law and practice, massachusetts"

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Milović, Jovana. "Probate proceedings conducted by a notary public in the Republic of Serbia." Zbornik radova Pravnog fakulteta Nis 61, no. 94 (2022): 153–71. http://dx.doi.org/10.5937/zrpfn1-37068.

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The introduction of the notary public service in the Serbian legal system has introduced a number of novelties in matters concerning inheritance law. The most important of them is the possibility of entrusting the probate proceedings in inheritance cases to notaries public. In the Serbian legal system, probate proceedings dealing with inheritance matters have traditionally beed conducted competent courts. This long-standing tradition is difficult to break with. Thus, the Serbian legislator still envisages the jurisdiction of the court to discuss inheritance matters, but now there is a possibility of entrusting this procedure to a notary public, when it is deemed to be expedient. In this paper, the author examines the judicial practice and the public notaries practice in an attempt to determine the justification of entrusting some probate proceedings to notaries public. Concurrently, the author analyzes the possibility of transferring competences for conducting probate proceedings entirely to public notaries. In the author's opinion, it is a realistic possibility considering that the hetherto practice of public notaries in probate proceedings speaks in favour of this legal solution, particularly taking into account the reduced caseload and timeframe needed to complete these non-litigious probate proceedings.
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Ashadi, Ikhwan, Putra Hutomo, and Amelia Nur Widyanti. "KEPASTIAN HUKUM MENGENAI HIBAH WASIAT DITINJAU BERDASARKAN UNDANG-UNDANG NOMOR 1 TAHUN 2022 TENTANG HUBUNGAN KEUANGAN ANTARA PEMERINTAH PUSAT DAN PEMERINTAH DAERAH." SENTRI: Jurnal Riset Ilmiah 2, no. 9 (September 10, 2023): 3646–54. http://dx.doi.org/10.55681/sentri.v2i9.1519.

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Book of Civil Law (KUHPer), the concept of Grant is divided into two forms, yaito Grant and probate grant. The basic difference between the two is that the grant is made while the grantor is still alive, while the will grant is only carried out after the will grantor dies. The law regarding grants is regulated in Article 1666 of the Civil Code, while probate grants are regulated in Article 957 of the Civil Code. Related to the collection of duties on the acquisition of land and building rights, although the acquisition value of non-taxable taxable objects is regulated by local regulations under Article 46 paragraph 8,. in this study raised the issue of how the implementation of probate grants in the practice of law in Indonesia? And how the legal certainty of probate grants in terms of Law No. 1 year 2022 on the financial relationship between Central and local governments?by using the theory of Agreement and The Theory of legal certainty The method used in this study is normative legal research is legal research literature or secondary data with sources of primary, secondary and tertiary legal materials. The approach used legislation approach, case approach, conceptual approach and analytical approach. And legal material collection techniques are carried out by identifying and inventorying positive legal rules, book literature, journals and other legal material sources, for legal material analysis techniques (interpretation) grammatical interpretation, systematic interpretation and legal construction methods. That the court will certify the will if it meets the requirements of the law, checks for compliance with the provisions of applicable law, and ensures that there are no disputes that prevent the execution of the grant. The implementation of this will grant is a harmonization between the principles of treaty law and agrarian law. Although it is a form of agreement, the probate Grant is also subject to agrarian regulations governing land and property rights. Thus, the legal process in accordance with the applicable provisions is important to maintain the validity and continuity of the implementation of the probate Grant and protect the rights of the parties involved and that Law No. 1 of 2022 on financial relations between Central and local governments has an important impact on the legal certainty of the implementation of probate grants in Indonesia, especially in terms of the protection and management of donated property. Although it does not directly regulate probate grants, it does provide a broader legal context that can support clarity of procedure and protection of the rights of grantees
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Fielding, Stephen. "Mediation in the Church of England: Theology and Practice." Ecclesiastical Law Journal 13, no. 1 (December 13, 2010): 65–69. http://dx.doi.org/10.1017/s0956618x10000815.

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This paper1 addresses the practical aspects of mediation. Experienced mediators will know what mediations look like and feel like and need no reminding how effective mediation has become as a means of resolving disputes. My own practice as a mediator – which tends to focus on inheritance and probate disputes, where the emotional element is often highly toxic – has some parallels with the mediation of Church disputes where an understanding of and sensitivity to theology is crucial.
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Lund, John M. "The Contested Will of “Goodman Penn”: Anglo–New England Politics, Culture, and Legalities, 1688–1716." Law and History Review 27, no. 3 (2009): 549–84. http://dx.doi.org/10.1017/s0738248000003904.

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In February 1704, a Boston laborer named Thomas Lea found himself surrounded by townspeople as he lay on his deathbed. These spectators had gathered hoping to hear a much anticipated confession of the crimes they believed Lea had committed fifteen years earlier during the Dominion of New England. In Suffolk County, many townspeople had long maintained that Lea and others had used the confusion and chaos generated by the unsettling political and legal transformations introduced to New England during the 1680s to surreptitiously gain legal title to the estate of a prosperous Braintree, Massachusetts, landowner named William Penn. Standing by Lea's bedside, one witness, who believed Lea had perjured himself at the 1689 probate administration of Penn's estate, demanded: “Thomas can you as you are going out of the World answer at the Tribunal of God to the Will of Mr Penns, which you have sworn to[?]” “Was Mr Penn living or Dead when this Will was Made?” In the presence of assembled witnesses, Lea acknowledged, “he was dead.” Other townspeople pressed Lea to reveal the role he played in what many believed had been a murder for inheritance scheme. They reminded Lea that Penn's corpse had been found covered “in blood, in his own dung” with “a hole in his back, that you might turn your two fingers into it” and, even more disturbing, “one of his [Penn's] stones in his codd [scrotum] was broken all to pieces.” Averting the onlookers' gaze, Lea “turned his head aside the other way, saying what I did I was hired to do.” For these witnesses, the death-bed confession confirmed the rumors of Lea's crimes and strengthened their belief that a wave of corruption introduced in the 1680s had sabotaged New England's distinctive Puritan jurisprudence. Indeed, townspeople had labored for years to overturn the 1689 probate of Penn's estate in an effort forestall the crown's efforts to bring New England into political and legal conformity with the dictates of the growing English empire.
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Fernandez, Angela. "Record-Keeping and Other Troublemaking: Thomas Lechford and Law Reform in Colonial Massachusetts." Law and History Review 23, no. 2 (2005): 235–77. http://dx.doi.org/10.1017/s0738248000000298.

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Historians have long discussed the different ways in which the first professional lawyer to practice in Massachusetts Bay Colony, Thomas Lechford, was at odds with colony authorities in his three-year stay there—from June 27, 1638 to August 3, 1641. Some accounts have focused on his religious views, since Lechford disagreed with the strict forms of church membership prescribed by the colony's religion, Congregationalism. When he returned to England, Lechford wrote a book called Plain Dealing in which he argued against this form of religious organization, claiming that he had received enough first-hand experience to recommend a return to the Church of England. This book has been an important source of information on religious and political arrangements in colonial Massachusetts, and so for many, the picture of Lechford as religious dissenter is familiar. Another important picture of Lechford, especially familiar to historians of the American legal profession, is Lechford the impecunious lawyer disbarred for the unethical practice of law. Lechford himself had written, “I am…forced to get my living by writing petty things, which scarce finds me bread.” He had been disbarred for “embracery,” pleading to a jury out of court, and it was assumed that this combination of circumstances forced him to return to England. James Savage wrote under his biographical entry for Lechford: “left here, aft. vain attempt to earn bread.” Other nineteenth-century scholars of colonial Massachusetts said much the same thing. William Whitmore, in an introduction to a collection of Massachusetts colonial laws, wrote that Lechford “was finally starved into returning to England.”
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Davis, Corey S., Alexander Y. Walley, and Colleen M. Bridger. "Lessons Learned from the Expansion of Naloxone Access in Massachusetts and North Carolina." Journal of Law, Medicine & Ethics 43, S1 (2015): 19–22. http://dx.doi.org/10.1111/jlme.12208.

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States are rapidly modifying law and policy to increase access to the opioid antidote naloxone, and the provision of naloxone rescue kits (NRK) for use in the event of overdose is becoming increasingly common. As of late 2014 the majority of states had passed laws increasing naloxone access, and nearly as many have modified emergency responder scope of practice protocols to permit Emergency Medical Technicians (EMTs) and law enforcement officers to administer the medication. While the text of these laws is generally similar, their implementation varies among states.This article outlines experiences and lessons learned from two diverse states, Massachusetts and North Carolina. In Massachusetts naloxone access initiatives were well underway before formal legislative action occurred, while in North Carolina the passage of a naloxone access law served as a catalyst for the creation of new programs and facilitated the scale-up of existing ones. In both states legislative action was necessary to permit the prescription and dispensing of naloxone to the friends and family members of people who use opioids, a key legal change.
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Wayne, Abby Brown. "Comment on Kartell v. Blue Shield of Massachusetts, Inc.: An Antitrust Analysis of Blue Shield's Reimbursement Schemes." American Journal of Law & Medicine 11, no. 4 (1986): 465–500. http://dx.doi.org/10.1017/s0098858800006754.

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AbstractIn Kartell v. Blue Shield of Massachusetts, Inc., the First Circuit held that Blue Shield's reimbursement practice known as the “ban on balance billing” did not constitute an unlawful restraint of trade in violation of the antitrust laws. Underlying the First Circuit's decision was deference to what it viewed as efforts by Blue Shield and by the Commonwealth to promote cost containment.This Comment argues that, to the contrary, under an appropriate analysis of antitrust law, the practices employed by Blue Shield did constitute unreasonable restraints of trade on the physicians' service industry in Massachusetts, given Blue Shield's market dominance in the Commonwealth. The Comment also argues that such inhibition of the competitive functioning of this industry is unwise, and that costs should instead be contained by effectuating the antitrust laws and encouraging the development of competitive forces within this industry.
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Silver, James, William H. Fisher, and Emily Silver. "Preventing Persons Affected by Serious Mental Illnesses from Obtaining Firearms: The Evolution of Law, Policy, and Practice in Massachusetts." Behavioral Sciences & the Law 33, no. 2-3 (March 4, 2015): 279–89. http://dx.doi.org/10.1002/bsl.2170.

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Zhang, Xiangrong, Xiao Han, Chen Li, Xu Tang, Huiyu Zhou, and Licheng Jiao. "Aerial Image Road Extraction Based on an Improved Generative Adversarial Network." Remote Sensing 11, no. 8 (April 17, 2019): 930. http://dx.doi.org/10.3390/rs11080930.

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Aerial photographs and satellite images are one of the resources used for earth observation. In practice, automated detection of roads on aerial images is of significant values for the application such as car navigation, law enforcement, and fire services. In this paper, we present a novel road extraction method from aerial images based on an improved generative adversarial network, which is an end-to-end framework only requiring a few samples for training. Experimental results on the Massachusetts Roads Dataset show that the proposed method provides better performance than several state of the art techniques in terms of detection accuracy, recall, precision and F1-score.
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Dougherty, Shaun M., Todd Grindal, and Thomas Hehir. "The Impact of Career and Technical Education on Students With Disabilities." Journal of Disability Policy Studies 29, no. 2 (May 7, 2018): 108–18. http://dx.doi.org/10.1177/1044207318771673.

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Evidence suggests that participating in career and technical education (CTE) in high school, on average, positively affects general education students when transitioning from education to the workforce. Yet, almost no large-scale causal research has explored whether academic benefits also accrue to students with disabilities in CTE. This omission is glaring given that students with disabilities participate in high school CTE programs at high rates. We use multiple years of administrative data from Massachusetts to estimate the effect of participating in CTE on the academic outcomes of students with disabilities. Compared with peers with similar disabilities who do not participate in CTE, students with disabilities in CTE programs perform comparably on standardized measures of student achievement but have higher probabilities of graduating from high school on time or earning industry-recognized certificates. Implications for policy and practice, particularly with regard to scaling access to similar programs, are discussed.
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Dissertations / Theses on the topic "Probate law and practice, massachusetts"

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Ramsay, David Peter. "Toward a new wills variation act." Thesis, 1997. http://hdl.handle.net/2429/5978.

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Most common law and civil law jurisdictions have laws in place to provide a safety net so that those who are unfairly disinherited will be able to claim a share in a deceased's estate. Since 1920, British Columbia has been one of those jurisdictions in which a testator's distribution scheme may be varied at the discretion of the Court. However, the absence of a stated purpose of the legislation, a broad judicial discretion to determine what is adequate provision for a spouse and children and the failure of the Supreme Court of Canada in Tataryn v. Tataryn to bring certainty and predictability to the law point to a need for reform. The goal of this thesis is to complete the sentence "the purpose of legislation restricting testamentary freedom is . . . . " and to make recommendations for legislative change to accomplish this purpose. An overview of the law in British Columbia today and the arguments for reform will be outlined in chapters 1, 2 and 3. Chapters 4 through 8 will examine a number of topics to extract policies which might assist in the formulation of a dependant's relief statute's purpose. Historical concepts, family, intestacy and wrongful death legislation as expressions of values will be reviewed. From the doctrine of unjust enrichment, a cause of action independent of a statute, a contract or a tort, but now widely used in claims between family members, will be extracted principles which recognize compensation for the contribution of services and money between family members. Empirical studies about testators' intentions, family and other private relations will be noted in chapter 9. Lastly, chapter 10 will make a number of recommendations for reform. These include: (a) A statement of the statute's purpose. Persons who have lived together in a relationship of some permanence with financial and emotional interdependence should share equally the assets acquired during their time together and the survivor's need for support should be recognized. Children's support needs should also be met but the testamentary autonomy of persons should be subject only to these two objectives. (b) The broadening of categories of claimants to include cohabitants and stepchildren with the introduction of age and dependency criteria for the latter. (c) Criteria to be used in making reasonable financial provision for spouses and children. (d) A priorities scheme. (e) The right to waive the statutory rights by agreement. No attempt is made to provide recommendations for all of the issues that would arise under a new statute.
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Du, Plessis Jan Abraham. "Artikel 2(3) van die Wet op Testamente 7 van 1953." Diss., 1999. http://hdl.handle.net/10500/16693.

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Text in Afrikaans, abstract in Afrikaans and English
Title page in Afrikaans and English
Die verhandeling handel oor die howe se hantering van testamentere geskrifte wat nie aan die testamentsformaliteite voldoen nie. Die posisie voor die inwerkingtreding van artikel 2(3) word eerste bespreek. Daarna bespreek ek die wysigings wat aanbeveel is deur die regskommissie. Vervolgens bespreek ek die inwerkingtreding van artikel 2(3) wat aan die howe die bevoegdheid gee om 'n testamentere geskrif wat nie aan die formaliteite voldoen nie tot geldige testament te verhef. Die spesifieke probleemareas met die interpretasie van artikel 2(3) word uitgelig en in detail bespreek. Daarna maak ek 'n aanbeveling dat 'n handtekening of merk op 'n testamentere geskrif 'n drempelvereiste moet wees alvorens 'n hof dit kan kondoneer. Ek sluit af met 'n opinie oor hoe die artikel in die toekoms geinterpreteer behoort te word.
The dissertation is about the way in which the courts handle testamentary writings which do not comply with the formalities of a will. Firstly I discuss the position before the implementation of section 2(3). Thereafter I discuss the recommendations of the law commission. Then I discuss the implementation of section 2(3) which empowers the court to legalise a document which does not comply with the formal requirements of a will. The specific problem areas with regard to the interpretation of section 2(3) are highlighted and discussed in detail. Thereafter a recommendation is made that a signature or a mark on a testamentary writing must be a prerequisite before a court can consider condoning it. I conclude my dissertation with an opinion on how this section should be interpreted in the future.
Jurisprudence
LL. M. (Legum)
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Hollows, Emma. "Kofifi/Covfefe: How the Costumes of "Sophiatown" Bring 1950s South Africa to Western Massachusetts in 2020." 2020. https://scholarworks.umass.edu/masters_theses_2/933.

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This thesis paper reflects upon the costume design process taken by Emma Hollows to produce a realist production of the Junction Avenue Theatre Company’s musical Sophiatown at the Augusta Savage Gallery at the University of Massachusetts in May 2020. Sophiatown follows a household forcibly removed from their homes by the Native Resettlement Act of 1954 amid apartheid in South Africa. The paper discusses her attempts as a costume designer to strike a balance between replicating history and making artistic changes for theatre, while always striving to create believable characters.
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Books on the topic "Probate law and practice, massachusetts"

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P, Warner Joseph, Reynolds Hanson S, Bixby Brian D, and Massachusetts Continuing Legal Education, Inc. (1982- ), eds. Massachusetts probate manual. 2nd ed. Boston, MA: Massachusetts Continuing Legal Education, 2003.

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P, Warner Joseph, Reynolds Hanson S, and Bixby Brian D, eds. Massachusetts probate manual. Boston, MA: Massachusetts Continuing Legal Education, 1996.

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Barry, Richard C. The new Massachusetts uniform probate code. [Boston, MA]: MCLE, 2011.

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C, Barry Richard, and Massachusetts Continuing Legal Education, Inc. (1982- ), eds. The new Massachusetts uniform probate code: An overview. Boston, MA: MCLE, 2009.

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C, Barry Richard, and Massachusetts Continuing Legal Education, Inc. (1982- ), eds. The new Massachusetts uniform probate code: An overview. Boston, MA: MCLE, 2009.

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C, Barry Richard, and Massachusetts Continuing Legal Education, Inc. (1982- ), eds. The new Massachusetts uniform probate code: An overview. Boston, MA: MCLE, 2009.

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Manus, Deborah J. The probate and administration of estates in Massachusetts. Boston, MA: Massachusetts Continuing Legal Education, 2003.

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M, Uddo Eleanor, ed. How to probate an estate in Massachusetts: With forms and checklist. Clearwater, FL: Sphinx Pub., 1997.

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Court, Massachusetts Trial. Proposed supplemental rules of the Probate and Family Court. [Boston, Mass.]: [Massachusetts Trial Court], 2011.

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Barry, Richard C., and Anthony R. Nesi. The new MUPC is here... and now. [Boston, MA]: MCLE, 2012.

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Book chapters on the topic "Probate law and practice, massachusetts"

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Dyson, Henry. "Donation-Partage And Donation De Biens A Venir." In French Property And Inheritance Law-Principles And Practice, 295–99. Oxford University PressOxford, 2003. http://dx.doi.org/10.1093/oso/9780199254750.003.0032.

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Abstract It might safely be assumed that the laws of a country whose citizens’ ability freely to dispose of their assets by will is as circumscribed as it is in France by the existence of the reserve would not provide its practitioners with much trouble in the administration of estates of deceased persons. One of the leading notaires, with much experience of probate work, considers that very many administrations lead to hard fought family disputes and that the reason lies precisely with the reserve. This is because, whilst there is intended to be equality of inheritance between issue, the rule of the reserve, as is explained in Chapter 28, is based on the limitations placed on what proportion of ‘gifts whether made inter vivos or by will’ (C.civ.art.913) an individual may make without impinging on what his issue are entitled to inherit.
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Pomeranz, Jennifer L., Thomas G. Merrill, and Kevin R. J. Schroth. "Government Authorities." In Public Health Law in Practice, C2—C2P208. Oxford University PressNew York, 2023. http://dx.doi.org/10.1093/oso/9780197528501.003.0002.

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Abstract This chapter discusses the authorities of the federal and state governments to support public health. The U.S. Constitution granted the federal government specific powers to pass laws that Congress has used to affect public health. Federal public health policymaking has grown through expanded use of its powers to tax and spend and to regulate interstate commerce. The federal regulatory agencies use their expertise to address public health, the environment, and safety. The states, however, continue to have primary responsibility for protecting the health of their inhabitants through their police power. The Constitution reserved this power for the states. Each state enacts laws pursuant to the police power to protect the public health, safety and welfare, and they additionally have an agency that is responsible for protecting public health. The chapter discusses Jacobson v. Massachusetts, an important Supreme Court decision that affirms the right of the states to pass laws that protect public health. The chapter also covers the authorities utilized by local governments.
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Declercq, Eugene, and Richard Lacroix. "The Immigrant Midwives of Lawrence: The Conflict between Law and Culture in Early Twentieth-Century Massachusetts*." In Midwifery Theory and Practice, 376–90. Routledge, 2018. http://dx.doi.org/10.4324/9781315050553-18.

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Pfander, James E. "The Origins of Uncontested Adjudication." In Cases Without Controversies, 19–32. Oxford University Press, 2021. http://dx.doi.org/10.1093/oso/9780197571408.003.0002.

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This brief chapter explores the origins of non-contentious or voluntary jurisdiction, tracing its appearance in Roman law and its incorporation into the practice of civil law systems of Europe. After examining uncontested adjudication in England, this chapter tracks its arrival in British North America. Building on English forms that were themselves rooted in civil law, colonial courts in North America used uncontested process to handle such familiar matters as the probate of decedents’ estates and the exercise of equity and admiralty jurisdiction.
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Finlay, John. "Furth of Scotland." In George Craig of Galashiels, 189–206. Edinburgh University Press, 2023. http://dx.doi.org/10.3366/edinburgh/9781399514835.003.0009.

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Law agents in Scotland often had to deal with matters extraneous to their jurisdiction. In Craig’s case this included dealing with solicitors in London, the north of England, Dublin and also attorneys in Jamaica. These dealing related to a variety of issues including probate and debt recovery. There were also financial and other arrangements to be made for clients temporarily overseas, such as those on military service. Craig also made arrangements to assist emigrants to America and, in particular, New South Wales where experienced shepherds, in particular, were in demand. Local practice was not divorced from the imperial context and, in a variety of ways, Craig encountered clients whose experiences abroad affected his legal and banking practice and his network necessarily extended to lawyers and bankers in England and elsewhere.
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White, G. Edward. "Travel and Romance." In Justice Oliver Wendell Holmes Law and the Inner Self, 225–52. Oxford University PressNew York, NY, 1993. http://dx.doi.org/10.1093/oso/9780195081824.003.0008.

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Abstract From the time he returned from Civil War service in the summer of 1864 until his departure to Washington to serve on the Supreme Court of the United States in December 1902 Holmes’ life was overwhelmingly centered in Boston and overwhelmingly oriented toward his professional pursuits. He lived with his parents while attending law school and during his first years in practice, and after his marriage in 1872 continued to live in his father’s household for two years. In October 1873 Wendell and Fanny Holmes purchased a farm in Mattapoisett, Massachusetts, on Buzzards Bay, where Holmes’ partner George Shattuck was a summer resident, and spent at least three weeks of every summer from 1873 to 1888, excluding 1882, in Mattapoisett. They initially owned one-half of the house, with the caretaker living in the other, and in 1883 purchased the whole. In the spring of 1888 the house burned to the ground in a brushfire.
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Stark, Evan. "The Revolution Unfolds." In Coercive Control, 21–49. Oxford University PressNew York, NY, 2007. http://dx.doi.org/10.1093/oso/9780195154276.003.0002.

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Abstract Sara Buell mounted a podium in the Green Room at the White House. A strong-willed prosecutor known for her “get tough” policies with domestic violence perpetrators in Quincy, Massachusetts, Buell is a Harvard Law School graduate and a dynamic public speaker. Along with a San Diego prosecutor, Casey Quinn, she pioneered evidence-based or “no drop” prosecution, the controversial practice of proceeding with charges against perpetrators irrespective of a victim’s wishes. Advocates disagree about the wisdom of this approach. But these differences were no more evident in the room than the gulf that normally separated champions of women’s rights from the conservative Republicans present. Buell introduced President Bill Clinton, who would publicly sign the Violence Against Women Act (VAWA), Title IV of the Violent Crime Control and Law Enforcement Act. Moments before the president entered with Attorney General Janet Reno and Secretary of Health and Human Services Donna Shalala, a line of women’s advocates stolidly embraced Senator Orrin Hatch, the bane of reproductive rights, as well as liberal Senator Joseph Biden, a key architect of VAWA. The president needed this alliance to protect a crime bill that contained death penalty and sentencing provisions opposed by liberals along with a prevention agenda opposed by the Right. The makeup of the group also symbolized a growing propensity to define violence against women as a crime problem. But the main thought on our mind was the unprecedented national audience we had garnered. The president identified Buell as a survivor of abuse and former welfare mom as well as a justice pioneer and pronounced domestic violence “the most important criminal justice issue in the United States.
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Conference papers on the topic "Probate law and practice, massachusetts"

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Maksurov, Alexey. "COORDINATION RULES OF LAW ON THE COORDINATION OF THE ACTIVITIES OF INDIVIDUAL AUTHORITIES UNDER THE MASSACHUSETTS CONSTITUTION." In SCIENTIFIC PRACTICE: MODERN AND CLASSICAL RESEARCH METHODS. European Scientific Platform, 2021. http://dx.doi.org/10.36074/logos-26.02.2021.v1.21.

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