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HomeMy WebLinkAbout07-0694 C2 CONSTRUCTION LLC, : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CLAIMANT CIVIL ACTION -LAW FCM BUILDERS, INC. OWNERS : No. Q''j -- ~ 4Y ~~,(~ MECHANICS LIEN Claimant, C2 CONSTRUCTION LLC., through the undersigned counsel, files this claim against the improvements and property at 13 Mount Allen Drive, Mechanicsburg, Pennsylvania, for a payment due to Claimant as a contractor for labor and materials furnished by Claimant and the sanding and finishing of wood floors. In support of the claim, the Claimant avers the following statement; The owners, or reputed owners, of the property are FCM Builders, INC., with an address at 13 Mount Allen Drive, Mechanicsburg, Pennsylvania 17055. 2. Claimant is C2 Construction LLC., a Pennsylvania limited liability company having its address at RR 4, Box 4130, Duncannon, Pennsylvania 17020. The improvements on the property which is the subject of this claim are the construction of the concrete walls and foundation of a building located at 17 Thompson Lane, Mechanicsburg, Pennsylvania, as per invoice # 25 attached as Exhibit "A". 4. The labor and materials for which the debt is due were furnished pursuant to an oral agreement with owner under which the contractor was to be paid for the time and materials furnished at its standard rate and prices which is reflected upon Exhibit "A". Sc~xacx_& ~.,I~T~~1~1_~~G~ LAW OFFICES 5. The labor and materials furnished consist of the following: construction of concrete walls, foundation of building, and other miscellaneous concrete work. 6. Claimant has been paid $4,815.49 toward the debt due Claimant for the stated labor and materials as per Owners' check #327 dated December 29, 2006. A copy of that check is attached as Exhibit "B". There is due and owing a balance of TEN THOUSAND DOLLARS ($10,000.00), for which this claim is made. Respectfully submitted: SCHRACK &LINSENBACH LAW OFFICES By: BRIAN C. LINSENBACH, ESQ. (87360) Attorney for Claimant 124 West Harrisburg Street P. O. Box 310 Dillsburg, PA 17019 Telephone: 717-432-973 3 Fax: 717-432-1053 Scx~cx~ ~nvs~v~acx LAW OFFICES C2 CONSTRUCTION LLC, : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CLAIMANT FCM BUILDERS, INC. CIVIL ACTION -LAW OWNERS : No. VERIFICATION I, DAVID E. LENIG, of C2 CONSTRUCTION LLC, a Plaintiff herein, verify that the facts set forth in this Complaint are true and correct to the best of my knowledge, information, and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. §4904) relating to unsworn falsification to authorities. DAVI E. IG Sc~- cx ~ Lws~vs~cA LAW OFFICES NOkJ-09-2006 11:24 AM THE UPS STORE . 224 Amity Road Duncannon, PA 17020 881 To _ FChd Builder 131 Allen Drtvo ~sniwatrg,PA 17035 17179382392 P. 02 IIIVVICB ~ ~ ~1I/Z006 is POjecENob Terms / "? lane Due on receipt Item qw~ ~~~ 9'x l0" 2s7.5 ceoc+eoe walla ~" 7x8" 8.81 ooactete wails 3'x8" 22 coopate walla 63 8arag~e wall joint bolts + ~~ 94 fbuodatloo anchota vertex ~ W° O~ dO'0r 2 32"ul ha~aaeirt window bulkheads 1 fl~utted door 3 step in waU haght/and of wall ~p rebar 1 caseate plsoemaft tnrck 514 84 rebar is been a piaasur+e woeting witfi y~oaf Raba 41.00 10.337.30 39.00 343.39 29.00 638.00 19.00 1,19'7.00 40.00 160.00 1.23 117.50 33.00 140.00 110.00 220.00 100.00 100.00 35.00 105.00 800.00 500.00 0.85 436,90 TOts;l st4,at s.a9 ~'` l~ ~~ __ ~~ -~ ~ ~ G~ ~ r__ ~~ _. -~ ~ r r t^ ~ i ~ CJ _ ~, ~.r ~, ) ~.{~ C,> -= 4 Bryan W. Shook, Esquire ID # 203250 The Law Office of Darrel C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone- (717) 975-9446 Fax - (717) 975-2309 [3Shook a dc~llatim.net Attorney for Defendant C2 CONSTRUCTION LLC, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No: 07-694 FCM BUILDERS, INC, :CIVIL ACTION -LAW Defendant NOTICE TO PLEAD To: C2 Construction, LLC c/o Brian C. Linsenbach, Esquire 124 West Harrisburg St. P.O. Box 310 Dillsburg, PA 17019 You are hereby notified to plead to the enclosed Preliminary Objections within twenty (20) days from the date of service hereof or a default judgment may be entered against you. Date: ~ s v1 ~' oZ (~~ Respectfully Submitted, ~. Bryan W. Shook, Esquire I.D. # 203250 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Plaintiff 5 Bryan W. Shook, Esquire ID # 203250 The Law Office of Darrel C. Dethlefs 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975-9446 Fax - (717) 975-2309 P,Si~Sx~kri dcdl<~~~.nei Attorney for Defendant C2 CONSTRUCTION LLC, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :No: 07-694 FCM BUILDERS, INC, :CIVIL ACTION -LAW Defendant DEFENDANT'S, PRELIMINARY OBJECTIONS TO PLAINTIFF'S MECHANICS LIEN AND NOW, comes the Defendant, FCM Builders, Inc., by and through their attorneys, THE LAW OFFICE OF DARRELL C. DETHLEFS, by Bryan W. Shook, Esquire, and hereby files Preliminary Objections to the Plaintiffs Mechanics Lien and avers as follows: 1. Upon information and belief, Plaintiff, C2 Construction, LLC, is Pennsylvania Limited Liability Company with an address at RR 4, Box 4130 Duncannon, PA 17020 2. Defendant, FCM Builders, Inc., is a registered Pennsylvania corporate entity with its registered business office located at 13 Mount Allen Drive, Mechanicsburg, PA 17055. 3. Plaintiffs, hereby files Preliminary Objections to Defendant's Mechanics Lien for the reason set forth below. PRELIMINARY OBJECTIONS, IN THE NATURE OF A DEMURRER, PURSUANT TO Pa. R.C.P. 1028(a)(4) 4. Paragraphs 1 through 3 are incorporated herein by reference and as though fully set forth below. 5. Rule 1028(a)(4) allows a party to preliminarily object to a pleading if the pleading is legally insufficient. 6. Plaintiff's Mechanics Lien is legally insufficient. 7. Plaintiff's Mechanics Lien incorrectly names FCM Builders, Inc. as the owner of 13 Mount Allen Drive, Mechanicsburg, PA 17055. 8. Defendant, FCM Builders, Inc. is not the owner of 13 Mount Allen Drive, Mechanicsburg, PA 17055. 9. Plaintiff believes, and, therefore, avers, that Plaintiff has filed their Mechanics Lien against the wrong party. 10. Plaintiff's Mechanics Lien seeks to place an encumbrance upon the property located at 13 Mount Allen Drive, Mechanicsburg, PA 17055 however the work done by Plaintiff, as per Plaintiff's invoice #25 dated 9/11/2006 at 17 Thompson Lane, Mechanicsburg, PA 17055. (See also Plaintiff's Mechanics Lien ¶ 3). 11. Plaintiffs do not, in their Mechanics Lien seek to place the Mechanics Lien on 17 Thompson Lane, Mechanicsburg, PA 17055, but instead seek to place the Mechanics Lien on 13 Mount Allen Drive, Mechanicsburg, PA 17055. ti 12. Defendant, believes, and, therefore, avers that Plaintiff has filed their Mechanics Lien against the wrong property. 13. Additionally, Defendant believes, and therefore, avers, that they were not notified of the claim by Plaintiff, C2 Construction, LLC as required pursuant to 49 PA. C.S.A. § 1501. 14. Defendant believes that Plaintiff's Mechanics Lien is legally insufficient in that Plaintiff has failed to show that FCM Builders is the owner of 13 Mount Allen Drive, Mechanicsburg, PA 17055 and that the lien was incorrectly filed against 13 Mount Allen Drive, Mechanicsburg, PA 17055 when the work, which is the issue of the lien, was completed as per Plaintiff s invoice #25 dated 9/11 /2006 at 17 Thompson Lane, Mechanicsburg, PA 17055. (See also Plaintiff's Mechanics Lien ¶ 3). WHEREFORE, for the reasons set forth above, Defendant, FCM Builders, Inc., respectfully requests that this Honorable Court sustain the Preliminary Objections and dismiss Plaintiff's Mechanics Lien as legally insufficient. A hearing is respectfully requested. Respectfully Submitted, Law Office of Darrell C. Dethlefs, Date: S a I - oZ ~7 ~, Brya .Shook, Esquire I.D. # 203250 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Plaintiff z C2 CONSTRUCTION LLC, Plaintiff v. FCM BUILDERS, INC, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :No: 07-694 :CIVIL ACTION -LAW CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant's Preliminary Objections to Plaintiff's Mechanics Lien, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: C2 Construction, LLC c/o Brian C. Linsenbach, Esquire 124 West Harrisburg St. P.O. Box 310 Dillsburg, PA 17019 Respectfully Submitted, Dated: J ~vZ ("~~7 By: ~/- Bry W. Shook, Esquire I.D.# 203250 2132 Market Street Camp Hill, PA 17011 Attorney for Plaintiff ~ ~ C2 CONSTRUCTION LLC, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 07-694 FCM BUILDERS, INC, :CIVIL ACTION -LAW VERIFICATION I hereby verify that the statements of fact made in the foregoing Preliminary Objections, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. further certify that I am authorized by FCM Builders, Inc. to make this verification. Date: S~ l Y o~ CM uil ers, nc. By: r` ~ ~""> c-; . i ~1 aa., rws ... ,, -Ci .-i "'f- 'T'1 ('~ ~ 3'"' µ ; ~.) ' ~- ~ $ ,~ ~ y. _ _., ~ ~ ~ ~ ` ., --a ~ ~ ~ : -. J C2 CONSTRUCTION LLC, Plaintiff vs. FCM BUILDERS, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07-694 ANSWER TO DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S MECHANICS LIEN AND NOW, comes the Plaintiff, C2 CONSTRUCTION LLC, by and through its attorney, Brian C. Linsenbach, and files the following response to Defendant's Preliminary Objection to Plaintiffs Mechanic's Lien and avers as follows: 1. Admitted. 2. Admitted. 3. Denied. The Plaintiffs did not file Preliminary Objections. ANSWER TO PRELIMINARY OBJECTIONS IN THE NATURE OF A DEMURRER, PURSUANT TO Pa. R.C.P. 1028(a)(4) 4. Paragraphs Number 1 through 3 are incorporated herein by reference and as though fully set forth below. 5. The averment contained therein is a conclusion of law to which no response is necessary. SCHRACK~ 6. Denied. The averment contained is a conclusion of law to which no response is I il~tS~ required. To the extent an answer is required, Plaintiff states its claim is legally sufficient. LAW OFFICES 7. Denied. Plaintiff s Mechanic's Lien does not incorrectly name FCM Builders, Inc. as the owner of 13 Mount Allen Drive, Mechanicsburg, PA 17055. In fact, averment Number 1 of the Mechanic's Lien states that FCM Builders, Inc. has an address of 13 Mount Allen Drive, Mechanicsburg, PA 17055 and averment Number 3 states "The improvements on the property which is the subject of this claim are the construction of the concrete walls and foundation of a building located at 17 Thompson Lane, Mechanicsburg, Pennsylvania, as per invoice #25 attached as Exhibit "A." Averment Number 3 specifically states the property subject to the claim is 17 Thompson Lane, Mechanicsburg, Pennsylvania. 8. Denied. After reasonable investigation, the Plaintiff is without knowledge or information sufficient to form a belief as to the truth of the averments contained therein and strict proof is demanded at trial. 9. Denied. Plaintiff does not believe it has filed a Mechanic's Lien against the wrong party. In fact, the Mechanic's Lien was filed against 17 Thompson Lane, Mechanicsburg, Pennsylvania and during the search of an independent abstractor, the Lien was discovered; therefore, it is properly filed. A copy of the independent abstractor's search is attached as Exhibit ..A ~~ 10. Denied. Plaintiff s Lien does not seek to place an encumbrance upon the property at 13 Mount Allen Drive, Mechanicsburg, PA 17055. Plaintiff placed an encumbrance upon the property at 17 Thompson Lane, Mechanicsburg, Pennsylvania, as per Plaintiff s Lien Paragraph Number 3, as well as evidenced by the abstractor's search. 11. Denied. (for the same reasons as above in Paragraph Number 10) 12. Denied. Plaintiff filed a Mechanic's Lien against 17 Thompson Lane, Mechanicsburg, Pennsylvania. 13. Denied. Defendant was notified of the Mechanic's Lien and Notifications are attached as Exhibits "B" and "C." Sc~cx ~ ~~iSENBACH 14. Denied. Plaintiffs Lien is legally sufficient and it shows that Defendant, FCM LAW OFFICES Builders, Inc., is the owner of 17 Thompson Lane, Mechanicsburg, Pennsylvania, which is the subject of the Lien as per Paragraph Number 3 of the Mechanic's Lien. The introduction to the Mechanic's Lien incorrectly stated "13 Mount Allen Drive, Mechanicsburg, Pennsylvania", which was not and averment within the Lien itself. WHEREFORE, for the reasons stated above, Plaintiff prays this Court to deny the Defendant's Preliminary Objections filed by Defendant. Respectfully submitted: SCHRACK & LINSENBACH LAW OFFICES BRIAN C. LINSENBACH, ESQUIRE I. D. No. (87360) Attorney for Plaintiff 124 West Harrisburg Street, P. O. Box 310 Dillsburg, PA 17019 Telephone: 717-432-973 3 Fax: 717-432-1053 Sc~-cx L~raBacA. LAW OFFICES C2 CONSTRUCTION LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION -LAW FCM BUILDERS, INC., Defendant No. 07-694 VERIFICATION I, DAVID E. LENIG, of C 2 Construction LLC, am authorized to make this Verification on its behalf. I have read the foregoing Answers and state that the facts forth therein are true and correct to the best of my knowledge, information, and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. §4904) relating to unsworn falsification to authorities. Date: G D ~ ID E. LENIG SCHRAC~~ L~~v~c~ LAW OFFICES C2 CONSTRUCTION LLC, Plaintiff vs. FCM BUILDERS, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07-694 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer to Defendant's Preliminary Objections to Plaintiffs Mechanics Lien, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Bryan W. Shook, Esquire Law Office of Darrel C. Dethlefs 2132 Market Street Camp Hill, PA 17011 c~ 7 ~7 Date i~-~ ~ BRIAN C. LINSENBACH, ESQ. (87360) SCHRACK &LINSENBACH Law Offices 124 West Harrisburg Street Post Office Box 310 Dillsburg, PA 17019 Telephone: 717-432-9733 Fax: 717-432-1053 Sccx~ L~~v~,~ LAW OFFICES MAY-O7-2007 10:37PM FROM- IvIVEN J. BAIRD 37 S. Hanover Street, Carlisle, Pennsylvania ] 7013 (717) 243-5732 FAX (717) 243-8110 STATEMENT FOR T1TLE 'WORK PERFORMED DATE: May 7, 2007 TO: Brian C. Linsenbach, Esq. RE: Miller PROPERTY SEARCHED: Two owner search: 1510 Thompson Lane, Parcel # 13-10-0258-034 AMOUNT TO REMIT: ~ 45 T-139 P.001/009 F-539 THANK YOU I~AY-07-2007 10:37P~1 FR0~1- TITLE REPORT SUMMARY DATE: May 7, 2007 CLIENT: Linsenbach T-139 P.002/009 F-539 LOCATION: 1510 Thompson Lane, This is the address for the parcel number provided. DESCRIPTION: Cumberland County Lower Alten Township Parcel Nr. 13-10-0258-034 Plan: Lot: Plan Book: Page: PRESENT OWNERS: Alison M. Miller GRANTOR: FCM Builders, Inc. DEED BOOK: 2780 Page 1660 DATE OF DEED: 12/29/06 DATE REC 1/9/07 MORTGAGES: FROM: Alison M. Milier TO: MERS (GMAC Mtg., LLC} DATED: 12/29/06 RECORDED:1/9/07 IN MTG. VOL: 1978 PAGE: 4779 AMOUNT OF $ 240,000 DELINQUENT TAXES: None JUDGMENTS/LIENS (Includes buyers if full names provided): Mechanics Lien in 07_ RESTRICTIONS: None new EASEMENTS/RIGHTS OF WAY: Rights granted to PPL Electric Utilities Corp in Misc. Bk 730 page 4165. ASSESSMENTS: LAND: 32,940 IMPROVE: 478,300 TOTAL: 509,240 THIS REPORT DOES NOT INCLUDE DOMESTIC RELATIONS ARREARAGES SEARCH DATES: 5/31/06 to 5/2/07 Previous owner, FGM Builders, Inc. took title in Deed Book 274 page 4504. T-139 P~003/009 F-539 MAY-07-2007 10:37P1~ FROM- ' ' %" / ~' ~f ~ ~ -lo~ ~--b3 ~~~ JqN 9 Pal 2 49 Ta: Parcel #: ~S DEED +~ Made the ~~ ~ day of ~ c-rwi./ in the yew of our Loral two thousand six (2006). BE7~VSF.N FC1VI BIJ~LDER~~IC_. hereinafter referred to as '~'GRAIVTOR" and ALi90N M.,_,~R. muried woman, hereinafter rofened to as "GRANTEE„ W1<TNESSETH, that in cansidcratian of THREE HLf 1~tDRSD TSOUSANtD aed 1V0/'100 (5300,000.00) DOLLARS, in hand paid the reoaipt whereof is hereby aclmowledged, the said GRANTOR does hedYby gent and convey to the said GRANTEE, its st'~ccessors and assigns, all those certain premises ape+cifically hereinafter described. ~~ SEE LEGAL DESCRIPTION ATTACHED AS EXIFHBIT "A" BEING THE SAME PBEI4IISES which Jeffrey P. Beckett sad Jody F. Beckett, husl+~nd and wife, by Decd datod May 31, 2046 end recorded June 2, 2006 in the Qffice of the tecorder of Deeds in and for Cumberland County, Pemtsylvauia, in Book 274, Page 4504, granted and conveyed unto Ft..,M Builders, inc., GRANTOR bcreio. ?OCETBER with all aid singular the improvements, ways, water, water~aurses, right, liberties, privileges, hexeditatttenfa and spptuttnauces whatsoever thereunto belonging, or in any wise appg, and the reversions and c+anaindcts, rents, issues and pmfSts thereof; and also, all the estate, right, title, interest, use, trust, property, possession, clam. ~d demand whatsoever, of the Grantors, in law, equity or otherwise, howsoever, in and *a the seine and every part theroof. ~ TO tIAYE AND Z iD HDI.D the said lots or pixel of gromd above described, with the ~uildangs and imprnvem~ts thereon erected, hereditaments and premises hereby grautad ar mentioned, and intended so to be, with the appu~rttenances, untio the said Crrantee, the Gtaniee's h,cirs and assigns, to and for the pmpor use and benefit of the said Grantee, the C,rantee's hairs and assigns, forever_ ,, B00lf ~"~~ PACI~~j~;Q ~~. I~AY-~7-2007 10:38P~1 FR01~- EXHIBIT "A" T-139 P.0041009 F-539 ALL TIiAT CERTAYN piece or parcel of land situate in Lower Allen Township, G`umberlaad County, Pemtsylvamia, bounded and descn'bed as follows, to wit: BEGINNING at a point in the center line of public road leading from the Slabc Hill-Lisburn Road to the Fulling Mill, said point being 306.00 feet measured eastwardly along the center line of said road from the intersection of said center line with the westerly line of the said road from Slate Hill to Lisburn; thence continuing along the center line of said public road to the Fulling Mill, North 64 degrees Past, 365.00 feet, mioze or less, to a point on the Iands, South 26 degrees East, 145.00 feet, more or less, to a poi thence by land now or formerly of Rohland, Sough 64 degrees West, 365.00 fart to a point; thence by the same, North 2b degrees V~si, 145.00 feet to the point or place of BEGINNING. UNDER AND SUBJECT to conditions, restrictions and casements of prior record pertaining to the premises. ~~>; r ,+ ~. ~~. ~;imt~rlami Cu~r.1;Y K,ticordEr ?€ IieG~~ Inst!rtts!er~t filir~~ T e .~/~q~(~ttaei~pt~ tea+.~~ ,s~ A 1p n it.strR LW!-'1Qi~Vv if ~7~c~'1 iT:1l~QV Resar~s: >7ET~~FS ~IiL£i•; ~~ ii.~~ i•'EED - iIRIT erg. ~E3T ~fi01~ s~.Ort i.~'~K fil,iQ1 T~ ~~~i,~r'1 i ~ brH ~ 1~.5C _ c ca zt~~T ~~ c.oa R£C. T 13:~~ ?..3 Chec6cl~ ~~t4 t,;G G'hzck~ d8k3 1;~,f,QO.~ ~esk1E RAF ~,:~J 'ii.~~J.3~ T~tai R~ei~re~..,:.., ;i:~;6.54 800K ~'~$ P~6f1~. ' ~IIIY=07-2007 10:3BPN FROM- T-139 P.005/009 F-539 AND the said GRANTOR does hereby WARRANT SPECIALLY the property herein conveyed. IlV W1TNE35 WHEREOF, said GRANTOR has hereunto set his hand and seal the ciay and year firstabove-written. R'l~1VE FYederi~ck C. Miller, President FCM Buildccs, Inc. COM, MONWEALTB OFPENNSYLVANL4: ., ~. On this, the day of ~ , A.D., 2006, before rte, Notary 1°iubli~ the undersigned officer, P~~j3' gpPe~e1d FREDERICK C. MII.I.ER, President, FCM BujWen, Ite., brown to nu, (or satisfactorily pm-aen) to be the person(s) whose name(s) is/are subscribed to the within ~nstruntent, and ac~Enowledged that hels~ie/they executed the wine for the purposes therein conuttned ,; IN fYITNF.S.S WlI$REOF, I her s my banal and official seal, ~TM of F~s~nvMrt- ~~} r+oesw s~ No hlic nsna~ C. DeMrefs. Nooh-PUbtc e~ KaMsr;•Pn~yhanl~ ~~.a,,, or Nolades I hereby certify that the precise residcnce of the Grantees is: ~ ~~ Attornay iYAgeat for Grantees BDQI( 4~$ PAGE~S6,~ r~ ~r,~ ~ ~ ~:~ ~T2C-~ (~ •.. ^~ r .., l,.l `T . `: 7 ""'s €'~~T ;~{f ` -f ~. ~ -~