Reasons and Decision – Murat Mike Hacikyaner

Person who is the subject(s) of the decision: Murat Mike Hacikyaner

Date of decision and reasons: August 21, 2025

Panel: François T. Ramsay, Chairperson’s Delegate

Reasons for decision

Introduction

[1] These reasons and the decision concern the professional activities of Murat Mike Hacikyaner before the Immigration and Refugee Board of Canada (IRB). They are intended to determine whether Murat Mike Hacikyaner is acting as a paid representative before the IRB and, if so, whether this undermines the integrity of IRB processes and, if applicable, the sanctions that should be imposed on him.

[2] In the context of this review process concerning the conduct of Murat Mike Hacikyaner, the panel ordered the non‑disclosure of and a publication and distribution ban on all the information contained in the Refugee Protection Division (RPD) files in which Murat Mike Hacikyaner is acting as a representative.

Background

[3] Murat Mike Hacikyaner is neither a lawyer nor a notary nor an articling student; he is not a member in good standing of any provincial law society or of the Chambre des notaires du Québec. He is also not a member in good standing of the College of Immigration and Citizenship Consultants.

[4] On February 10, 2025, Murat Mike Hacikyaner was providing representation without a fee or other consideration in 35 cases before the RPD and one case before the Refugee Appeal Division (RAD) of the IRB. In those cases, Murat Mike Hacikyaner presented himself as an unpaid representative.

[5] Between 2011 and 2024, Murat Mike Hacikyaner was listed as counsel in a total of 90 cases, divided among the four IRB divisions, namely, the Immigration Division (ID), the Immigration Appeal Division (IAD), the RPD and the RAD.

[6] In the context of those cases, Murat Mike Hacikyaner declared four different addresses over the years, all located in office buildings in the City of Montréal, in the Province of Quebec.

[7] On September 20, 2024, in an interlocutory decision, an RPD member concluded that Murat Mike Hacikyaner was compensated for services he rendered to a refugee protection claimant in relation to his refugee protection claim, which included representing him before the IRB. The member prohibited him from continuing to represent the claimant.

[8] On the digital professional social networking platform LinkedIn, in a profile under the name Murat Mike Hacikyaner, he is identified as “consultant.”

[9] In light of the above, in a letter dated February 10, 2025,^{Footnote 1} the IRB informed Murat Mike Hacikyaner that it would be reviewing the matter to determine whether he should be permitted to represent a person who is the subject of an IRB proceeding or be prohibited from doing so. It is stated that, in the context of that review, the content of the files in which he is acting or has acted as a representative, the four professional addresses he declared between 2011 and 2025,^{Footnote 2} the documents appended to said letter, namely, the list of his cases,^{Footnote 3} the reasons for the above-mentioned interlocutory decision,^{Footnote 4} and the excerpt from the LinkedIn profile^{Footnote 5} concerning him, may be taken into consideration.

[10] Furthermore, the IRB invited Murat Mike Hacikyaner to provide his written comments regarding the above no later than February 28, 2025. Lastly, the IRB informed Murat Mike Hacikyaner that, upon receiving his comments or in the event that no response was received by February 28, 2025, it would proceed with the review of his professional activities before the IRB and determine whether he would be permitted to represent a person who is the subject of an IRB proceeding or be prohibited from doing so.

[11] On February 28, 2025, Murat Mike Hacikyaner sent a letter (hereinafter the Response) to the IRB in response to its letter.^{Footnote 6} He states that he does not agree with the allegations outlined in the letter. He claims to be and to have always been an unpaid representative before the RPD. He carries out his duties from an office and is also an accountant and an official interpreter for two agencies. He considers his clients to be close friends and members of his family, whom he tries to help adapt to the Canadian way of life. The fees that may have been charged and the monetary compensation that may have been received from those individuals have nothing to do with their representation before the IRB. He states that he is prepared to defend himself to continue helping his clients.

[12] On March 26, 2025, while acknowledging receipt of the Response, in reference to it, the IRB sent a second letter, in which it invites Murat Mike Hacikyaner to submit, no later than April 11, 2025, any evidence that, in his opinion, could enable the IRB to conduct a full review of his status.^{Footnote 7}

[13] The IRB further informed Murat Mike Hacikyaner that, upon receiving his comments or in the event that no response was received by April 11, 2025, it would proceed with the review of his professional activities before the IRB and determine whether he would be permitted to represent a person who is the subject of an IRB proceeding or be prohibited from doing so.

[14] No response to the second letter or any evidence was received from Murat Mike Hacikyaner within the time limit or thereafter. It is in this context that the panel will proceed to review the professional activities of Murat Mike Hacikyaner before the IRB and render a decision concerning his right to act as a representative of a person who is the subject of an IRB proceeding.

Jurisdiction and authority

[15] The IRB has the jurisdiction and even the duty to safeguard the integrity of its processes. In Rezaei,^{Footnote 8} the Federal Court adopted the position taken by the Honourable Justice Sopinka of the Supreme Court in Prassad:^{Footnote 9}

We are dealing here with the powers of an administrative tribunal in relation to its procedures. As a general rule, these tribunals are considered to be masters in their own house. In the absence of specific rules laid down by statute or regulation, they control their own procedures subject to the proviso that they comply with the rules of fairness and, where they exercise judicial or quasi-judicial functions, the rules of natural justice. [Emphasis added.]^{Footnote 10}

[16] The Federal Court then specifically states the following:

Given the procedural framework of the IRB, … it has the inherent jurisdiction to monitor its own procedures in order to ensure its integrity. Indeed, denial of the jurisdiction of the IRB to ensure the integrity of its processes would be a disservice to its stakeholders. These stakeholders include not only the claimants who appear before the Board and its divisions, but also the Canadian public at large….^{Footnote 11}

[17] To that end, in the absence of a specific statutory or regulatory procedure, the IRB, through its delegate, has the ability to take any action that may be necessary, including suspending a representative's right or prohibiting them from appearing on behalf of another person before it.

[18] In accordance with the provisions of subsection 159(2) of the Immigration and Refugee Protection Act^{Footnote 12} (the Act), the Chairperson of the IRB has delegated the undersigned to review the actions of Murat Mike Hacikyaner before the IRB; to determine if he is acting as a paid representative before the IRB and, if so, whether that undermines the integrity of its processes; and to take, if applicable, any action that may be necessary, including prohibition from representing a person who is the subject of an IRB proceeding.

Issues

[19] The panel is of the view that there are two issues:

Do Murat Mike Hacikyaner's actions before the RPD undermine the integrity of IRB processes?
If so, is a measure aimed at suspending or prohibiting the right to represent a person who is the subject of an IRB proceeding warranted? If so, which one, for what period of time, and on what conditions?

Determination

[20] The panel determines that Murat Mike Hacikyaner is acting as a paid representative before the IRB and that his actions undermine the integrity of IRB processes.

[21] The panel determines that prohibiting Murat Mike Hacikyaner from representing any person in any matter and from appearing on behalf of any person in any proceeding before any division of the IRB is warranted. This prohibition takes effect immediately and will remain in effect indefinitely.

Analysis

Legal context

[22] The Act provides that any person who is the subject of a proceeding before the IRB has the right to be represented by counsel.^{Footnote 13} That counsel may not be compensated in any way, with the exception of lawyers, notaries and paralegals who are in good standing with the law society of a province or the Chambre des notaires du Québec, and members in good standing of the College of Immigration and Citizenship Consultants with the Class L3 RCIC‑IRB licence, who may be compensated for providing representation before the IRB.^{Footnote 14}

[23] Any individual who contravenes the foregoing, that is, who is compensated in any form whatsoever for providing representation when not authorized to do so, commits an offence under the Act. That act is punishable by a fine of not more than $50,000 or imprisonment for a term of not more than two years, or both.^{Footnote 15}

[24] The Policy for Handling Immigration and Refugee Board of Canada Complaints Regarding Unauthorized, Paid Representatives (the Policy) reiterates the principle that, as part of its duty to safeguard the integrity and effectiveness of its processes, the IRB must ensure that counsel representing persons who are the subject of IRB proceedings have the right to do so, in accordance with the applicable legislative provisions.^{Footnote 16} As part of fulfilling its obligations, the Board may proceed with the review of the actions of counsel to determine whether they are paid a fee or receive other consideration for their services and, if so, whether they are permitted to be.^{Footnote 17}

[25] Section 5.5 of the Policy states that the following are among the indications suggesting that counsel provided services in exchange for a fee:

frequent appearances as an unpaid representative (of greater concern if combined with any of the additional factors below);
information contained in IRB records that counsel has charged a fee or received other consideration in the past to represent and appear before the IRB, or currently charges fees or received other consideration for other paralegal services, yet now claims to be acting as an unpaid representative before the IRB;
relevant information from a source outside the IRB, including: the Canada Border Services Agency (CBSA), Citizenship and Immigration Canada (CIC), the College of Immigration and Citizenship Consultants (CICC), or media reports;
relevant information received from a present or former client of that counsel, or other members of the public; or
relevant information contained in a file before the Federal Court.^{Footnote 18}

Conduct of Murat Mike Hacikyaner before the Refugee Protection Division

Analysis of files

[26] As part of its review, the panel analyzed the 93 RPD files^{Footnote 19} in which Murat Mike Hacikyaner has acted as a representative for claimants since 2011. In particular, the panel focused on the Basis of Claim Forms (BOC Forms) and on the Notices of Representation without a Fee or other Consideration (NRWFOCs).

[27] The BOC Form is a form signed by the person claiming refugee protection. When that person is represented by counsel, counsel is responsible for reviewing the content of the BOC Form with the person before submitting it. In signing it, the person declares either that they are able to read the language in which the BOC Form has been completed and that they understand its content, or that it has been interpreted to them in its entirety and that the information they have provided in the form is complete, true and correct.

[28] The NRWFOC indicates the name of the individual representing the person claiming refugee protection as unpaid counsel in all IRB proceedings. The form is signed by the individual identified as counsel and by the person claiming refugee protection. In signing, the individuals declare that the information they have provided in the form is complete, true and correct.

[29] In 84% of the files under review, the persons claiming refugee protection indicate, in response to question 9(a) of the BOC Form, that they have counsel.^{Footnote 20} In all these files, counsel is identified, in question 9(b) of the BOC Form, as Murat Mike Hacikyaner. In 76% of these files, it is indicated that he is not a lawyer, notary or member of the RCIC and that he is acting as an unpaid representative, advisor or consultant.^{Footnote 21} In 19% of these files, Murat Mike Hacikyaner is described as a friend of the claimants.^{Footnote 22}

[30] In 85% of the files under review, there are NRWFOCs signed by both Murat Mike Hacikyaner and the claimants.^{Footnote 23}

The interlocutory decision

[31] In File No. MC3-11620, the claimant states in his BOC Form, signed on April 21, 2023, that he has counsel who will assist him with his refugee protection claim before the RPD. He identifies him as Murat Mike Hacikyaner, unpaid counsel. On November 17, 2023, the RPD received an NRWFOC from Murat Mike Hacikyaner. In that document, signed on the same day by Murat Mike Hacikyaner and the claimant, the counsel's address is listed as 433 Chabanel Street, Montréal, Quebec, H2N 2J9.

[32] On April 8, 2024, the RPD sent a notice to the claimant and Murat Mike Hacikyaner, summoning them to a hearing on June 13, 2024. On May 30, 2024, Murat Mike Hacikyaner submitted an application to change the date and time, explaining that he would be out of the country on the scheduled hearing date. On June 3, 2024, the RPD denied the application. The decision also indicates that the parties must be present, as required, at the hearing on June 13, 2024.

[33] On June 13, 2024, Murat Mike Hacikyaner was absent. The claimant was present. He was accompanied by a person whose name appears in the BOC Form as the person who translated the document for the claimant. After that person described to the member the assistance that she had provided to the claimant at the claimant's request in the days leading up to the hearing and then left the hearing room, the claimant answered the member's questions. He stated under oath that he was not aware of the reasons why his counsel Murat Mike Hacikyaner was absent, that he paid him, that he had already paid him $1,500, and that he would have to pay him another $750 later. He added that he was not ready to proceed, asked that Murat Mike Hacikyaner be removed from the record, and indicated that he wanted to retain the services of new counsel. The date of the new hearing was set for July 3, 2024.^{Footnote 24}

[34] On July 3, 2024, the claimant appeared alone. He informed the member that he had been unable to retain the services of another counsel and that he was ready to proceed. However, the hearing had to be rescheduled, as the claimant stated that he had not received the Minister's notice of intervention. The hearing was postponed to September 6, 2024.^{Footnote 25}

[35] On September 4, 2024, the RPD received an NRWFOC from Murat Mike Hacikyaner. In that document, signed by Murat Mike Hacikyaner and the claimant on August 20, 2024, counsel's address is listed as 4865 Jean Talon W., #322, Montréal, Quebec, H4P 1W7.

[36] On September 6, 2024, the claimant and Murat Mike Hacikyaner were present at the hearing. The claimant confirmed the mandate of Murat Mike Hacikyaner. In accordance with the above-mentioned provisions of the Policy, the member then shared with them her concerns regarding the content of the claimant's statements at the hearing on June 13, 2024.

[37] At the hearing, the member informed Murat Mike Hacikyaner of the statements made by the claimant at the hearing on June 13, 2024, concerning the amounts that the claimant had allegedly paid him or would have to pay him. She gave him the opportunity to respond. The claimant answered for him, stating that these were case file fees and that they were intended entirely for the interpreter. For his part, Murat Mike Hacikyaner reiterated several times that he had not been paid, that he would not be paid, and that he would not be receiving other consideration; he did not take money to represent or advise the claimant or other persons. He stated that all of the amounts paid by the claimant were received by the interpreter to [translation] “submit all the papers, all the documents, and to assist the claimant before immigration.”^{Footnote 26} When confronted with the above-mentioned statements by Murat Mike Hacikyaner, the claimant stated that [translation] “at the time, Mr. Hacikyaner and the interpreter were working together, and that it was the money they needed for fees. He did not know where that money went afterwards.”^{Footnote 27} In response to a subsequent question that the member put to him directly, the claimant stated that he had not thought of asking for a receipt for those payments, as it was a law firm, to which Murat Mike Hacikyaner reacted, stating that neither he nor the interpreter were lawyers, that he was merely an unpaid representative.^{Footnote 28}

[38] In the interlocutory decision rendered following that last hearing, the member concluded that, on a balance of probabilities, Murat Mike Hacikyaner was paid for services rendered to the refugee protection claimant in that case, which included representation at the IRB hearing. She based that conclusion on the following: lack of evidence—other than the testimony of Murat Mike Hacikyaner—that all the money disbursed by the claimant was intended for the interpreter; the claimant's statement that he thought it was normal to pay lawyer fees; and the spontaneous statements made by the claimant, in the absence of Murat Mike Hacikyaner, at the hearing on June 13, 2024, that the latter was paid, that he had taken an amount of $1,500 and that an additional sum of $750 would be paid to him. As a result, she prohibited Murat Mike Hacikyaner from representing the claimant.^{Footnote 29}

Murat Mike Hacikyaner's statements

[39] As noted above, in his response, Murat Mike Hacikyaner states that he is an unpaid representative, an accountant, as well as an official interpreter for two agencies. He performs all his duties from an office. He considers his clients to be close friends or members of his family. The amounts he may have charged them or received from them have nothing to do with their representation before the IRB. He states that he is prepared to defend himself to continue helping his clients. No evidence of any kind has been submitted to corroborate his statements, although he twice had the opportunity to do so.

Conclusions and decision

[40] In light of the above, the panel notes that, since 2011, and, in particular, since 2022, Murat Mike Hacikyaner has provided and continues to provide, on a recurring basis, services in representing persons appearing before the various divisions of the IRB. In 2022, 2023, and 2024, Murat Mike Hacikyaner acted as a representative in no fewer than 75 cases before all IRB divisions.

[41] The panel also notes that, on February 10, 2025, he was acting as a representative not in one or two cases, but in 35 RPD cases and 1 RAD case simultaneously. The services he provides in that context are similar in every way to those provided by a lawyer, a notary, a paralegal, or an immigration consultant within the meaning of the Act.

[42] The panel notes the conclusion drawn by the RPD member in the above-mentioned matter. Based on the spontaneous statements made by a claimant at a hearing and in the absence of evidence to the contrary, the member concluded that Murat Mike Hacikyaner was being paid for his services and that, as such, he was violating the provisions of section 91 of the Act. In accordance with the provisions of the Policy, she prohibited him from continuing to act as counsel in the matter.^{Footnote 30}

[43] The panel also notes that Murat Mike Hacikyaner identifies himself on the digital professional social networking platform LinkedIn^{Footnote 31} not as an [translation] “accountant” or “translator,” professional activities that he also claims to engage in, but instead solely as a “consultant,” without any qualifier that would suggest that he engages in that activity on a volunteer basis.

[44] Incidentally, the panel notes that, in all those files, the addresses associated with Murat Mike Hacikyaner are all located in office buildings, a fact that he confirms in his response dated February 28, 2025, when he states, [translation] “Yes, I carry out my work in an office.”^{Footnote 32}

[45] The panel also notes that, despite the invitation extended to him, not once, but twice, Murat Mike Hacikyaner submitted no evidence to comment on the information brought to his attention by the IRB or to support his own statements. In fact, no documents, whether in the form, for example, of invoices, receipts, correspondence, or income tax returns, confirm his statements that he acts as an accountant and official interpreter, or even that the amounts he allegedly charged or collected were [translation] “for things other than representation before the Board”. He simply expresses his disagreement with the information raised by the IRB and states that he is prepared to defend himself before the Board [translation] “to continue helping my very dear clients, who have become like family, in all their needs and initiatives.”^{Footnote 33}

[46] Lastly, the panel cannot ignore the fact that Murat Mike Hacikyaner uses the word “client” in his response when referring to the claimants he represents at no charge. However, the common meaning of the word “client,” as defined by the French-language dictionary Le Robert, is a [translation] “person who purchases or requires services in exchange for payment”.^{Footnote 34}

[47] The panel is of the view that the above points are indications that provide it with a basis to conclude, on a balance of probabilities, that Murat Mike Hacikyaner has received and continues to receive some form of compensation for representing clients before the RPD and before the other IRB divisions. The panel concludes that he is in violation of the provisions of section 91 of the Act.

[48] The panel is also of the view that, as such, Murat Mike Hacikyaner shows a blatant disregard not only for the law, but also for IRB processes. He also causes serious prejudice to his clients by endorsing their statements about him—which he knows to be false—in the documents that they sign and submit, thereby potentially casting doubt on the truthfulness of their statements when they are in a vulnerable and precarious situation.

[49] The panel is of the opinion that, by acting in this manner, Murat Mike Hacikyaner seriously undermines the integrity of IRB processes.

[50] In the panel's view, this conduct warrants a serious deterrent to ensure the integrity of the IRB and its processes, and also to protect the integrity and interests of Canadian residents and, specifically, the individuals that Murat Mike Hacikyaner currently represents or may be called upon to represent in the future.

[51] The panel therefore prohibits Murat Mike Hacikyaner from representing any person in any matter and from appearing on behalf of any person in relation to proceedings before any IRB division. This prohibition is indefinite and takes effect immediately.

Order

[52] The panel orders the registrars of all IRB divisions to notify any person represented by Murat Mike Hacikyaner that he is prohibited from representing any person or appearing on behalf of any person in any proceedings before any IRB division as of the date of this decision. The prohibition will remain in effect indefinitely.

François T. Ramsay

August 21, 2025

Encl.: Confidentiality order

IRB Translation
Original language: French

Footnotes

Footnote 1

Letter to Murat Mike Hacikyaner from the Immigration and Refugee Board of Canada (IRB), dated February 10, 2025.

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Footnote 2

The addresses are as follows:

4865 Jean‑Talon West, Suite 222, Montréal, QC, H4P 1W7
433 Chabanel West, Suite 1123‑A, Montréal, QC, H2N 2J9
6830 Avenue Du Parc, Suite 420b, Montréal, QC, H3N 1W7
469 Jean‑Talon West, Suite 210, Montréal, QC, H2N 1R4

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Footnote 3

Annexes A and B.

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Footnote 4

Annex C.

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Footnote 5

Annex D.

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Footnote 6

Letter to the IRB from Murat Mike Hacikyaner, dated February 28, 2025.

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Footnote 7

Letter to Murat Mike Hacikyaner from the IRB, dated March 26, 2025.

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Footnote 8

Rezaei v.Canada (Minister of Citizenship and Immigration), [2003] 3 FC 421.

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Footnote 9

Prassadv.Canada (Minister of Employment and Immigration), [1989] 1 SCR 560.

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Footnote 10

Endnote 8, para. 64.

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Footnote 11

Endnote 8, para. 70.

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Footnote 12

The provision reads as follows:

159(2) The Chairperson may delegate any of his or her powers under this Act to a member of the Board, except that
…
(d) powers in relation to the Immigration Division or the Refugee Protection Division may only be delegated to the Deputy Chairperson, the Assistant Deputy Chairpersons or other members, including coordinating members, of that Division.

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Footnote 13

The provision reads as follows:

167(1) A person who is the subject of proceedings before any Division of the Board and the Minister may, at their own expense, be represented by legal or other counsel.

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Footnote 14

Subsections 91(1) and (2) of the Act provide as follows:

91(1) Subject to this section, no person shall knowingly, directly or indirectly, represent or advise a person for consideration—or offer to do so—in connection with the submission of an expression of interest under subsection 10.1(3) or a proceeding or application under this Act.
(2) A person does not contravene subsection (1) if they are
(a) a lawyer who is a member in good standing of a law society of a province or a notary who is a member in good standing of the Chambre des notaires du Québec;
(b) any other member in good standing of a law society of a province or the Chambre des notaires du Québec, including a paralegal; or
(c) a member in good standing of the College, as defined in section 2 of the College of Immigration and Citizenship Consultants Act.

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Footnote 15

The relevant provisions of the Act read as follows:

124(1) Every person commits an offence who
(a) contravenes a provision of this Act for which a penalty is not specifically provided or fails to comply with a condition or obligation imposed under this Act;
…
125 A person who commits an offence under subsection 124(1) is liable
(a) on conviction on indictment, to a fine of not more than $50,000 or to imprisonment for a term of not more than two years, or to both; or
(b) on summary conviction, to a fine of not more than $10,000 or to imprisonment for a term of not more than six months, or to both.

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Footnote 16

Articles 5.1 and 5.2 of the Policy read as follows:

5.1 The IRB supports counsel representation in its proceedings in accordance with the Regulations.
5.2 The IRB has a duty to safeguard the integrity and effectiveness of its processes by ensuring that counsel who appear in its proceedings are, in fact, permitted to represent clients under the Regulations.

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Footnote 17

Article 5.4 of the Policy reads as follows:

5.4 Where a member, an employee or a party has concerns during a proceeding that a representative who claims to be unpaid may, in fact, be charging a fee or receiving other consideration, they should raise those concerns on the record. The person who is the subject of the proceeding may be asked whether they understood the declaration that they signed. They may also be asked to confirm on the record whether they have at any time paid, or will pay or otherwise compensate their representative for their services in representing, advising or consulting on their behalf in the proceeding before the IRB. Counsel should then be given the opportunity to address those concerns and the matter may be dealt with during the proceeding, with the member either allowing or not allowing the representative to act as counsel in that proceeding. However, the commissioner may also determine that an examination is warranted in this matter under this policy and, if applicable, follow the steps outlined in section 5.6 below.

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Footnote 18

Article 5.5 of the Policy reads as follows:

5.5 Possible indications that a representative who claims to be unpaid may actually be charging a fee or receiving other consideration, include, but are not limited to:
frequent appearances as an unpaid representative (of greater concern if combined with any of the additional factors below);
information contained in IRB records that counsel has charged a fee or received other consideration in the past to represent and appear before the IRB, or currently charges fees or received other consideration for other paralegal services, yet now claims to be acting as an unpaid representative before the IRB;
relevant information from a source outside the IRB, including: the Canada Border Services Agency (CBSA), Citizenship and Immigration Canada (CIC), the College of Immigration and Citizenship Consultants (CICC), or media reports;
relevant information received from a present or former client of that counsel, or other members of the public; or
relevant information contained in a file before the Federal Court.

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Footnote 19

MB9-00078; MB7-04636; MC1-00786; MB9-21862; MB9-21863; MB9-21864; MB9-21865; MC0-00879; MC0-0929; MC1-04494; TC0-00499; TC2-18355; TC2-18356; TC2-18357; TC2-18358; MC2-19747; MC2-18206; MC2-23171; MC2-23173; MC2-23176; MC2-23177; MC2-18606; MC2-15213; MC2-15234; MC2-22328; TC2-18910; MC2-21457; MC2-21456; MC2-21455; MC2-21453; MC2-19474; MC2-19475; MC2-19476; MC2-17521; MC2-10566; MC2-11794; MC2-11339; MC3-05647; MC3-05646; MC3-05642; MC3-05639; MC2-15203; MC2-15195; MC2-15200; MC2-22514; MC2-20660; MC3-05614; MC3-03674; MC2-28455; MC2-13474; MC3-03498; MC3-04402; MC2-11412; MC3-11627; MC3-03635; MC3-03625; MC3-05059; MC2-18602; MC2-09179; MC2-14236; MC2-27488; MC3-11530; MC3-12110; MC3-24079; MC3-39263; MC3-29171; MC3-35984; MC3-38652; MC3-38655; MC3-38661; MC3-51225; MC3-51227; MC3-51230; MC3-52540; MC3-56579; MC3-66963; MC3-66965; MC3-71256; MC3-71259; MC3-71261; MC4-08096; MC4-08099; MC4-08100; MC3-10807; MC3-42074; MC4-68418; MC4-68419; VC4-14766; MC4-36936; MC3-52624; MC4-07501; MC3-65421; MC3-67855.

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Footnote 20

MC1-04494, TC2-18355, TC2-18356, TC2-18357, TC2-18358, MC2-19747, MC2-18206, MC2-23171, MC2-23173, MC2-23176, MC2-23177, MC2-18606, MC2-15213, MC2-15234, MC2-22328, TC2-18910, MC2-1457, MC2-21456, MC2-21455, MC2-21453, MC2-19474, MC2-19475, MC2-19476, MC2-17521, MC2-10566, MC2-11794, MC2-11339, MC3-05647, MC3-05646, MC3-05642, MC3-05639, MC2-15203, MC2-15195, MC2-15200, MC2-22514, MC2-20660, MC3-05614, MC3-03674, MC2-28455, MC2-13474, MC3-03498, MC3-04402, MC2-11412, MC3-11627, MC3-03635, MC3-03625, MC3-05059, MC2-18602, MC2-14236, MC2-27488, MC3-11530, MC3-12110, MC3-24079, MC3-39263, MC3-29171, MC3-35984, MC3-38652, MC3-38655, MC3-38661, MC3-52540, MC3-56579, MC3-66963, MC3-66965, MC3-71256, MC3-71259, MC3-71261, MC4-08096, MC4-08099, MC4-08100, MC3-10807, MC3-42074, MC4-68418, MC4-68419, VC4-14766, MC4-36936, MC3-52624, MC4-07501, MC3-65421, MC3-67855, MC3-36936, MC4-48221, MC4-62864, MC5-00337, MC5-04617.

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Footnote 21

MC1-04494, MC2-18206, MC2-23171, MC2-23173, MC2-23176, MC2-23177, MC2-22328, TC2-18910, MC2-21457, MC2-21456, MC2-21455, MC2-21453, MC2-19474, MC2-19475, MC2-19476, MC2-17521, MC2-11339, MC3-05647, MC3-05646, MC3-05642, MC3-05639, MC2-22514, MC2-20660, MC3-05614, MC2-28455, MC2-13474, MC3-03498, MC2-11412, MC3-11627, MC3-03635, MC3-03625, MC3-05059, MC2-18602; MC2-14236, MC2-27488, MC3-11530, MC3-12110, MC3-24079, MC3-39263, MC3-29171, MC3-35984, MC3-38652, MC3-38655, MC3-38661, MC3-56579, MC3-66963, MC3-66965, MC3-71256, MC3-71259, MC3-71261, MC4-08096, MC4-08099, MC4-08100, MC3-10807, MC3-42074, MC4-68418, MC4-68419, VC4-14766, MC4-36936, MC3-52624, MC4-07501, MC3-65421, MC3-67855, MC3-36936, MC5-00337, MC5-04617.

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Footnote 22

TC2-18355, TC2-18356, TC2-18357, TC2-18358, MC2-19747, MC2-18606, MC2-15213, MC2-15234, MC2-10566, MC2-11794, MC2-15203, MC2-15195, MC2-15200, MC3-04402, MC3-52540, MC4-48221, MC4-62864.

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Footnote 23

MB7-04636, MC1-00786, MB9-21862, MB9-21863, MB9-21864, MB9-21865, MC0-00879, MC0-00929, MC1-04494, TC0-00499, TC2-18355, TC2-18356, TC2-18357, TC2-18358, MC2-19747, MC2-18206, MC2-23171, MC2-23173, MC2-23176, MC2-23177, MC2-18606, MC2-15213, MC2-15234, MC2-22328, TC2-18910, MC2-21457, MC2-21456, MC2-21455, MC2-21453, MC2-19474, MC2-19475, MC2-19476, MC2-17521, MC2-, 0566, MC2-11794, MC2-11339, MC2-15203, MC2-15195, MC2-15200, MC2-22514, MC2-20660, MC3-03674, MC2-28455, MC2-13474, MC3-03498, MC3-04402, MC2-11412, MC3-11627, MC3-03635, MC3-03625, MC3-, 5059, MC2-18602, MC2-09179, MC2-14236, MC2-27488, MC3-11530, MC3-12110, MC3-29171, MC3-38652, MC3-38655, MC3-38661, MC3-51225, MC3-51227, MC3-51230, MC3-52540, MC3-56579, MC3-66963, MC3-66965, MC3-71256, MC3-71259, MC3-71261, MC4-08096, MC4-08099, MC4-08100, MC4-68418, MC4-68419, VC4-14766, MC3-65421, MC3-67855.

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Footnote 24

Supra, endnote 4, paragraphs 5 and 6.

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Footnote 25

Idem, paragraph 7.

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Footnote 26

Idem, paragraph 9.

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Footnote 27

Idem, paragraph 10.

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Footnote 28

Idem, paragraph 11.

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Footnote 29

Supra, endnote 4.

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Footnote 30

Idem.

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Footnote 31

Supra, endnote 5.

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Footnote 32

Supra, endnote 6.

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Footnote 33

Idem.

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Footnote 34

Le Robert – Online Dictionary, https://dictionnaire.lerobert.com/definition/client.

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