HomeMy WebLinkAbout00-01098
Stephen E. Geduldig, Esquire
Attorney 1.0. No. 43530
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
Post Office Box 999
HarrIsburg, Pennsylvania 17108
(717) 237-7119
E-Mail: seg@tlhlaw.com
CGU INSURANCE GROUP,
SUBROGEE OF PAUL KAUTZ" Jr,
AND PATRICIA KAUTZ
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
NO,
aCC:o- I oQI5 ~ TeI\fY)
Plaintiffs
vs,
CIVIL ACTION - LAW
P P & L, INC.
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served, by entering a written appearance personally or by attorney and filing in
writing with this Court yoUr defenses or objections to the claims set forth against you, You are
warned that if you fall to do so, the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff, You may lose money or property or
other rights important to you,
Central Pennsylvania Legal Services
213A N, Front Street
Harrisburg, Pennsylvania 17101
(800) 932-0356
NOTICIA
LE RAN DEMANDO A USTED EN LA CORTE. Si usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, listed tiene viente (20) dias de plaza al partir de la
fecha de la demanda y la notificacion, Usted debe presentar una apariencia escrito e en persona
o por obogado y archivar en la corte en fonna escrita SliS defensas 0 sus objectiones a las
demandas en contra de su persona, Sea avisado que si usted no se defiende, la corte tomara
medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier
queja 0 alivio que es pedido en la peticion de demanda, Usted puede perder dinero 0 SliS
propiedades 0 ostros derechos importantes para usted,
Central Pennsylvania Legal Services
213A N, Front Street
Harrisburg, Pennsylvania 17101
(800)932-0356
THOMAS, THOMAS & HAFER LLP
By:
Stephen Geduldig, Esquire
305 North Front Street
Post Office Box 999
Harrisburg, P A 17108-0999
(717) 237-7119
Stephen E. Geduldig, Esquire
Attorney J.D. No. 43630
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
Post Office Box 999
Harrisburg, Pennsylvania 17108
(717) 237-7119
E-Mail: seg@tthlaw.com
CGU INSURANCE GROUP,
SUBROGEE OF PAUL KAUTZ., Jr,
AND PATRICIA KAUTZ
IN THE COURT OF C01\1Jvl:ONPLEAS
CUJI.1BERLAND COUNTY, PENNSYL VANIA
NO,
<1.000 - )oq'i? Cu.u-QT€.flJl,,\
Plaintiffs
vs,
CNIL ACTION - LAW
P P &L, INC.
Defendant
COMPLAINT
1, Paul Kautz, Jr, and Patricia Kautz are adult individuals residing at 323 Elgin
Circle, Mechanicsburg, P A 17055.
2, eGU Insurance Group is an insurance-company with offices located at p,O, Box
8851, Camp Hill, PA 17001,
3. Plaintiff, CGU Insurance Company, by way of payments made by it on behalf of its
insureds, Paul Kautz, Jr. and Patricia Kauti has become subrogated to all rights ofrecovery against
the Defendant by their insured,
4, Defendant, P P & 1., Inc, is an entity with its principal office located at 2 N. Ninth
Street, Allento'WIJ, Pennsylvania 18101.
5. The acts and occurrences hereinafter related took place on two separate occasions on
March 22, 1998 and April 17, 1998 when Defendant, P P & L negligently caused or allowed a
power surge which resulted and resultant damages to the personal property of the Plaintiffs,
6, In the exercise of due care and caution, Plaintiffs timely notified the Defendant of
the fIrst power surge on March 22, 1998, Defendant failed to take any corrective action to prevent
the second power surge on April 17, 1998, resulting in additional damages to the personal property
of the Plaintiffs,
7. Following the power surge on March 22, 1998, Plaintiffs suffered damages to their
personal property in the amount of $2,432,60, A subsequent power surge on April 17, 1998
resulted in additional damages to the personal property of the Plaintiffs in the amount of $4,890,90,
for a total loss to Plaintiffs in the amount of $9,768,97,
8. Plaintiffs did not misuse or abuse the products damaged,
WHEREFORE, the amount in controversy not exceeding mandatory arbitration limits,
Plaintiff hereby request that this case be mandated to arbitration,
Respectfully submitted,
THOMAS, THOMAS & HAFER LLP
By:
Stephen E. Geduldig, Esq
Attorneys for Plaintiff
Feb, 24, 2000 8:57AM
CGU Ins. libg, Pa. 17011
No. 5043 p, 2/3
VERIFICATION
I, Trudi Noppenberger, on behalf of CGU Insurance Group verify that the
foregoing action and that the attached document is based upon the information which
has been gathered by me, my counsel and/or others on my behalf in preparation of this
lawsuit. The language of the document is that of counsel and is not mine, I have read
the document, and to the extent that it is based upon information which I have given to
my counsel, n: is true and correct to the best of my knowledge, information, and belief.
To the extent that the contents of the document are that of counsel, I have relied upon
counsel in making this Verification.
I understand that intentional false statements herein are made subject to the
penalties of 18 Pa. C,S, ~4904 relating to unsworn falsifications made to authorities,
Date: "2-(2,dfP
,
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TRUDINOPPENBERGER
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PETERS & W ASILEFSKI
By: Charles E. WasiJefski
Attorney ill #21027
2931 North Front Street
Harrisburg, PA 17110
[717] 238-7555
Attorney for Defendant,
PPL Electric Utilities Corporation
CGU INSURANCE GROUP
SUBROGEE OF PAUL KAUTZ, JR,
and PATRICIA KAUTZ
Plaintiffs
IN THE COURT OF
COMMON PLEAS ,FOR
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. 2000 - 1098 Civil Term
PP&L, INe.
CIVIL ACTION - LAW
Defendant
NOTICE TO PLEAD
TO: PLAINTIFFS AND THEIR COUNSEL
YOU ARE REQUIRED to plead to the within Answer with New
Matter within twenty (20) days of service hereof, or a default judgment may be entered
against you,
PETERS & W ASILEFSKI
Dated: I~ rC/J-D 0'0
&0 Q"d
CHARLES E. W ASILEFSKI
Attorney ID #21027
2931 North Front Street
Harrisburg, PA 17110
[717] 23R-7555
Attorney for PPL
PETERS & W ASILEFSKI
By: Charles E. Wasilefski
Attorney ill #21027
2931 North Front Street
Harrisburg, PA 17110
[717] 238-7555
Attorney for Defendant,
PPL Electric Utilities Corporation
CGU INSURANCE GROUP
SUBROGEE OF PAUL KAUTZ, JR.
and PATRICIA KAUTZ
Plaintiffs
IN THE COURT OF
COMMON PLEAS FOR
CUMBEJ.U,AND COUNTY,
PENNSYLVANIA
:
v.
NO. 2000 - 1098 Civil Term
PP&L, INC.
CIVIL ACTION - LAW
Defendant
ANSWER WITH NEW MATTER
TO PLAINTIFFS' COMPLAINT
NOW COMES, Defendant, PPL Electric Untilities Corporation flkla
PP&L, Inc, ("PPL"), by and tlrrough its attorneys, Peters & W<lsilefski, and answers
Plaintiffs' Complaint as follows:
1. Defendant, PPL, denies the allegations contained in Paragraph 1
of Plaintiffs' Complaint, After reasonable investigation, Defendant, PPL, is without
knowledge or information sufficient to form a belief as to the truth of said allegations
and proof thereof is demanded at trial. In further answer, Defendant, PPL, denies said
allegations pursuant to Pa, R.C.P. 1029(e),
2, Defendant, PPL, denies the allegations contained in Paragraph
2 of Plaintiffs' Complaint, After reasoilllble investigation, Defendant, PPL, is without
knowledge or information sufficient to fonrt a belief as to the truth of said allegations
and proof thereof is demanded at trial. In further answer, Defendant, PPL, denies said
allegations pursuant to Pa, R.C,P, 1029(e),
3. Defendant, PPL, denies the allegations contained in Paragraph 3
of Plaintiffs' Complaint. After reasonable investigation, Defendant, PPL, is without
knowledge or information sufficient to form a belief as to the truth of said allegations
and proof thereof is demanded at trial. In further answer, Defendant, PPL, denies said
allegations pursuant to Pa, R,C,P. 1029(e),
4, Defendant, PPL, admits the allegations contained in Paragraph 4
of Plaintiffs' Complaint. However, Plaintiff lias erroneously used the name PP&L,Inc,
As of February 14, 2000, the entity formerly known as PP&L, Inc, is now PPL
Electric Utilities Corporation::
5. Defendant, PPL, denies the allegations contained in Paragraph 5
of Plaintiffs' Complaint. Said Defendant is advised and therefore avers that some of
the allegations contained in Paragraph 5 are conclusions of law and no further answer is
required, To the extent tha.t an~ answer is necessary, Defendant, PPL, specifically
denies that any incident involving a power surge from PPL facilities occurred on either
March 22, 1998 or April 17, 1998. To the contrary, if an incident occurred on each of
said dates, said incident was not caused nor did it come from Defendant,
2
PPL, facilities, In further answer, it is specifically denied that Defendant, PPL,
was in any way negligent in causing or allowing a power surge to occur. To the
contrary, Defendant, PPI.:, pursuant to its tariff, was not under any dilty -to 'Plaintiff to
protect Plaintiffs' property from the effects of the natural phenomenon known as a
power surge, PlaintiffS were obligated to protect their own property from a power
surge, In further answer, Defendant, PPL, acted in a careful and prudent manner in
providing electrical service to Plaintiffs in accordance with its tariff, Further, no act or
failure to act on behalf of Defendant, PPL, caused Qr contributed to Plaintiffs' alleged
damages. In further answer, Defendant, PPL, denies the said allegations pursuant to
Pa, R,C,P, 1029(e),
6. Defendant, PPL, admits in part and denies in part the allegations
contained in Paragraph 6 of Plaintiff s Complaint, It is admitted that Plaintiffs
contacted Defendant, PPL, sometime after the alleged March 22, 1998 incident. It is
denied, however, that Defendant, PPL, did nothing in response to Plaintiffs
communication to Defendant, PPL. To the contrary, Defendant, PPL, performed
various tests on its facilities to assure that there was nothing wrong with the PPL
facilities servicing Plaintiffs property. The test results revealed that there was no
problems with Defendant, PPL, facilities, If any damage occurred to Plaintiffs
3
property, it was not the result of anything related to the facilities of Defendant, PPL.
In further answer, Defendant, PPL, denies said allegations pursuant to Pa, R,C,P,
1029(e),
7, Defendant, PPL, denies the allegations contained in Paragraph 7
of Plaintiffs' Complaint. It is specifically denied that there was a power surge or that
any damage occurred to any of Plaintiffs' property as a result of any condition on
Defendant, PPL's, facilities for which Defendant, PPL, had a duty to protect Plaintiffs,
With regard to the alleged damages, Defendant, PPL, after reasonable investigation, is
without knowledge or informatioIl sufficient to form a belief as to the truth of said
allegations and proof thereof is demanded at trial. In further answer, Defendant, PPL,
denies said allegations pursuant to Pa, R,C.P. 1029(e),
8, Defendant, PPL, denies the allegations contained in Paragraph 8
of Plaintiffs' Complaint, After reasonable investigation, Defendant, PPL, is without
knowledge or information sufficient to form a belief as to the truth of said allegations
and proof thereof is demanded at trial, In further answer, Defendant, PPL, denies said
allegations pursuant to Pa, R,C.P. 1029(e),
WHEREFORE, Defendant, PPL, demands that Plaintiffs' Complaint be
dismissed.
4
.
NEW MATTER
9. Defendant, PPL, provides electrical service pursuant to its tariff
with the Pennsylvania Public Utility Commission.
10. PUrsuant to the PUC tariff, Defendant, PPL, has no duty to
protect Plaintiffs' property from the effects of the natural phenomena of power surges.
Plaintiffs have the duty to protect their own property from this phenomena.
11. Plaintiffs alleged damages are as a direct and proximate result of
Plaintiffs own negligence in that their electrical service entrance equipment was
defective and did not provide appropriate protection for the Plaintiffs electrical system
and electrical equipment attached to said electrical system and/or failed to properly
maintain their own electrical equipment resulting in damage to their property under the
facts and circumstances of this case.
12. Plaintiffs' alleged claim for damages is barred in whole or in part
by the Comparative Negligence Act.
13. Plaintiffs' claim for damages is barred because Plaintiffs assumed
the risk of damages by not providing appropriate equipment on its property to prevent
events that allegedly occurred that are similar to that which occurred in this matter.
14. Plaintiff's alleged damages occurred as a result of an act of God
5
and not as a result of any act or failure to act on behalf of Defendant, PPL.
WHEREFORE, Defendant, PPL, demands that Plaintiffs' Complaint be
dismissed.
PETERS & W ASILEFSKI
B~~cJ
Charles E. Wasilefski, Esquire
Attorney #21027
2931 North Front Street
Harrisburg, PA 17110
[717] 238-7555
Attorneys for Defendant, PPL
Dated: March 16, 2000
6
VERI FICA TION
I, Joel E. Compton hereby state that I am a Senior Claims Coordinator for
PPL Electric Utilities Corporation, flk/a PP&L, Inc. (PPL), Defendant herein and am
authorized to execute this Verification on its behalf. The attached Answer with New
Matter to Plaintiffs' Complaint is based upon information which PPL has furnished to
its counsel, and information which has been gathered by counsel in the preparation of
the defense of the lawsuit. I have read the Answer and to the extent that the Answer is
based upon information which personnel of PPL have given to its counsel, it is true and
correct to the best of my knowledge, information and belief. To the extent that the
content of the Answer is that of counsel, I have relied upon counsel in executing this
Verification. It is further understood that all statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Date: ...J//tf,ltJO'
OGU Insuranee v.PPL
#2000-1-099 Civil - CUmberland Co,
CERTIFICATE OF SERVICE
This is to certify that I, Pamela J. Crum, a Legal Assistant in the law
offices of Peters & Wasilefski, have this \ \. day o~",,\......
, 2000 served a true
and correct copy of the foregoing ANSWER WITH NEW MATTER TO PLAINTIFFS'
COMPLAINT upon all parties by depositing same in the United States mail, frrst class, postage
prepaid, addressed to the counsel of record as follows:
Stephen E. Geduldig, Esquire
THOMAS, THOMAS & HAFER
305 North Front Street
Post Office Box 999
Harrisburg, PA 17108
~~~~
Pamela J. Crum
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SHERIFF'S RETURN - OUT OF COUNTY
"~"""''''-<.'';
CASE NO: 2000-01098 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CGU INSURANCE GROUP ET AL
VS
P P & L INC
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
P P & L INC
but was unable to locate Them
in his bailiwick. He therefore
deputized the sheriff of LEHIGH
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
21st , 2000 , this office was in receipt of the
On March
attached return from LEBIGH
Sheriff's Costs:
Docketing
Out of County
Surcharge
DEP. LEHIGH CO
18.00
9.00
10.00
30.00
.00
67.00
03/21/2000
.THOMAS, THOMAS
S~_~
R. 'Thomas Kl ine
Sheriff of Cumberland County
& HAFER
Sworn and subscribed to before me
this
. a....-
I, .....-
day of aLl" 'f!
I
;) fl"1n) A.D.
l}'r' P~th~;(Y{~---
~. -Ia The Court of Common Pleas of Cumberland County, Pennsylvania
. .- -- - - ~- ~ - ..
CGU Insurance Group, et. aI.
VS. .
'1 '. .........
p P & L, Inc.
No. 20-1098 Civil
Now,
.3/2/
,20.QfL, I, SHERIFF.OF CUJ\1BERLAND COUNTY, PA, do
hereby deputize the Sheriff of. Lehigh.
County to execute this Writ, this
deputation being made at the request and dsk of the Plaintiff.
~~4f
Sheriff of Cumbefland County,. P A
Affidavit of Service
.
Now,
., "20--, at
o'clock
M. served the
within
upon
at
by handing to
copy of the onginal
a
and made mown to
the contents thereof
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this . day of ___,20
- .-
COSTS
SERVICE
. MILEAGE
AFFIDAVIT
$
$
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SHEI=<IFF OFFICE CI=:HIGR COUNTY COURTHoUSE
455 W HAMILTON ST
ROOM 10t,-ALLENTOWI\1 PA 18'101'-'lE.IQ,
~., -..
,
CGU INSURANCE GROUP
VS
P P & L, II\IC"
DOC#: 2000-CV-0685
: CASE:: 2000-NC-0555
EXPIR, 29-Ma,-2000
DEPOSIT, 30.00
WRIT , COMPLAINT IN CIVIL ACTION
2000-1098 (CUMBERLI';KiD cOUl'4tYl
SERVE' P P 8< L. I NC . ..
~~---~-=~~.:_~~~~:~.:_~===~~~~~~-~~-~~~~~~-~------_.-:---~._-----~~-P-A--~-D--.---
RETURN OF.. SERV I CE
1. NAME OF INDIVIDUAL SERVED,
- P:\ ~'" ~M1L \,0. '!)\.QS- __
\.....lii.~a.\ __~!:.C.
20_~u_ TII1E ,_ \ 'l.2. 5~~ ()--.... ___._
'1.. IN, ~~~ ~,
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2. REU\j I OI\lSH I P TO DEFENDANT,
3. DATE: "b-Ie,-'LOOO
HOURS:
4. LOCATION OF SERVICE,
-'
e UNABLE' TO LOCATE:
,~.l ..
( ) NUMBEF( OF ATTEMPTS TO I_OCATE DEFENDANT AT LAST 1<1\10WN ADDRESS,
1 . DATE & T It1E 2. _DATE & TIME '----
..,. D{-\TE & TIME <I. DATE & TIME
'-' ..
5~ D?'\TE & TII1E 6. DATE & TIME
ACCEPTANCE OF SERV!CE
I HEREBY ACCEPT SERVICE OF THE: LEGAL PROCESS AS OUTLINED ON THE FRONT OF THE
DOCUMENT. THIS SERVICE IS ACC-E:l-'TE"'t1 ON BEHALF OF THE LISTED DEFENDANT (S) AND
I I-IEREB-r-CERTIFY THAT I AI1 AUTHORIZEb -TO DO SO"
PRINTED NAME OF AUTHORIZED AGENT
SIGI\1ATURE OF AUTHORIZED AGENT
DATE,
Tl\V1EL
SO
SWORN AND SUBSCRIBED BEFORE
/~~
NOTARIAL SEAL
SUSAN J. SEDORA, NOTARY PUBliC
CITY OF ALLENTOWN, LEHIGH COUNTY, PA
MY COMMISSION EXPIRES JUNC 25th. 2001
,
"
Paul J. Hennessy, Esquire
O'Brien & Hennessy
142 W. Market Street
West Chester, PA 19382
610-431-2727
Attorney I.D. 65396
Attorney for Plaintiff
CGU Insurance Group
'Subrogee of Paul Kautz, Jr.
and Patricia Kautz
: In The Court of Common Pleas
: Cumberland County, Pennsylvania
vs.
: Civil Action Law
P.P.L., Inc.
: No: 2000-1098 Civil Term
Withdrawal of Appearance
To the Prothonotary:
Please withdrawal my appearance as counsel for the Plaintiff in the above captioned
case.
{J !~ j) I de)
hen E. Geduldig, Esqui
Thomas, Thomas & Hafer
Entrv of Appearance
lease enter my appearance as counsel for the Plaintiff in the above captioned case.
hank you.
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PETERS & W ASILEFSKI
By: Charles E. Wasilefski
Attorney ID #21027
2931 North Front Street
Harrisburg, P A 1711 0
[717J 238-7555
Attorney for Defendant,
PPL Electric Utilities Corporation
CGU INSURA,~CE GROlJP
SUBROGEE OF PAUL KAUTZ, JR.
and PATRICIA KAUTZ
Plaintiffs
v.
PP&L, INC.
Defendant
'.~
IN THE COlJRT OF
COMMON PLEAS FOR
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2000 - 1098 Civil Term
CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PA:
Please mark this matter settled, ended and discontinued.
Dated: 7117/01
O'BRIEN & HENNESSEY GROUP
By:
Paul J. He e
Attorney I 11
Suite 2
142 West Market Street
West Chester, PA 19382
"'--- . ...
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CERTIFICATE OF SERVICE
This is to certify that I, Pamela J. Crum, a Legal Assistant in the law offices
of Peters & Wasilefski, have this \, day of ~~ , 2QOlserved a true and
"'-
correct copy of the PRAECIPE upon all parties by depositing same in the United States mail, ftrst
class, postage prepaid, addressed to the counsel of record as follows:
Paul J. Hennessy, Esquire
O'BRIEN & HENNESSY GROUP
Suite 2
142 West Market Street
West Chester, PA 19382
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Pamela J. Crum
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