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HomeMy WebLinkAbout08-2024 SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY I.D. NO. 15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 Attorney for Plaintiff PATRICK SMITH COURT OF COMMON PLEAS 85 Carol Place CUMBERLAND COUNTY New Cumberland, PA 17070 V. ALAMO RENT A CAR NO. d$ - a ?C? l : ivi? I eT M 6929 North Lakewood Avenue, Suite 100 Tulsa, OK 74117-1808 and RODERICK O' KORLEY 6804 Dublin Terrace Birmingham, AL 35212 NOTICE TO DEFEND 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 WRI'T'TEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY I.D. NO. 15711 Attorney for Plaintiff 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 PATRICK SMITH COURT OF COMMON PLEAS 85 Carol Place CUMBERLAND COUNTY New Cumberland, PA 17070 V. ALAMO RENT A CAR NO. 0 P- A d i y 6929 North Lakewood Avenue, Suite 100 Tulsa, OK 74117-1808 and RODERICK O' KORLEY 6804 Dublin Terrace Birmingham, AL 35212 CIVIL ACTION COMPLAINT 1. Plaintiff is an individual residing at the above-stated address. 2. Defendant, Alamo Rent A Car (hereinafter referred to as "Alamo"), is a rental car company with an office at the above-stated address. 3. Defendant, Roderick O'Korley (hereinafter referred to as "O'Korley"), is an individual residing at the above stated address. 4. On or about July 12, 2007, Plaintiff was the owner of a vehicle which was parked on the 100 block of South 2n1 Street in Harrisburg, Pennsylvania, when Defendant, Alamo, by and through its agent, servant, workman or employee, O'Korley, did so negligently and carelessly operate a vehicle North on 2nd Street and struck Plaintiff's parked vehicle causing damage set forth more fully hereinafter. 5. The Negligence and carelessness of the Defendant, Alamo, by and through its agent, servant, workman or employee, O'Korley, and the negligence of O'Korley in its own right consisted of the following: (a) Operating a motor vehicle without due regard for the rights, safety and position of the Plaintiff herein; (b) Driving at an excessive rate of speed under the circumstances; (c) Failing to keep a proper lookout; (d) Failing to keep his motor vehicle under proper and adequate control under the circumstances; (e) Exhibiting a reckless and wanton disregard for the rights and safety of the plaintiff herein; (f) Violating the various ordinances and statutes of the Commonwealth of Pennsylvania pertaining to the operation of motor vehicles under the circumstances; and (g) The defendant was negligent and careless in many other respects, as will be shown in the hearing on this matter. 8. As a result of the aforesaid negligence and carelessness, Plaintiff's vehicle sustained damages as evidenced by a true and correct copy of estimate attached hereto, made part hereof and referred to as Exhibit "A". WHEREFORE, Plaintiff, Patrick Smith, demands judgment against Defendants, Alamo Rent A Car and Roderick O'Korley, individually, jointly and severally in the sum of $2,992.38 together with interest from July 12, 2007 and costs of suit. SANDLER & MARCHESINI, P.C. 71 &J By: P UL N. SANDLER, ESQUIRE Attorney for Plaintiff EXHIBIT "A" Estimate Pagel of 5 Estimate #5750446 Print Toggle Pictures Desk Review Field Review Desk Audit Field Audit Encompass Insurance Mid-Atlantic Claims Region ESTIMATE OF RECORD Insured/Owner Information Insurance Company Information Adjuster Information Name NOT ASSIGNED Insured SMITH Owner PATRICK SMITH Address Line 1 4242 CARLISLE PK STE 15 Address Line 2 City CAMP HILL State Zip AL 17011 Phonel (717) 774-5070 Phone2 (717) 364-3838 Fax Email Inspection Location Information Inspection Location Field Address Line 1 4444 CARLISLE PK Address Line 2 City CAMP HILL State Zip PA Phonel Phone2 Fax Contact Name Contact Email Claim Information Claim No Z0072961011 Claimant No Policy No 263698427 Loss Type Collision Deductible $500.00 Miscellaneous THIS IS NOT AN AUTHORIZATION TO REPAIR.THIS APPRAISAL IS BASED ON THE DAMAGES INSPECTED BY THE APPRAISER.NO SUPPLEMENTS FOR ADDITIONAL DAMAGE, LABOR OR RATES WILL BE CONSIDEREDWITHOUT APPROVAL PRIOR TO COMPLETION OF ANY SUPPLEMENTAL Company Type ID Company Number Company Name Encompass Insurance Mid Atlantic Claims Region Address Line 1 P.O. Box 16203 Address Line 2 _ City Reading State Zip PA 19612 Phone Fax Company Email a@c.com Contact Name KATHY KEISER Contact Title Contact Phone (610) 401-2283 Contact Email Appraiser Information Written By JAMES E MINNICH Company ID Code Company Encompass Insurance Mid-Atlantic Name Claims Region Email james.minnich@encompassins.com License No 151398 File No Address Line P P.O. Box 16203 1 Address Line 2 City Reading State Zip PA 19612 Phonel (610) 698-4878 Phone2 Fax Estimate Information Estimating ADP PenPro Platform Est Sw Version 4.12 Est Sw Unique File 0000137 ID Est Sw Supplementsol No Est Sw Transation S Type Est Sw Committed Committed Status PC Supplement No 256 Repair Facility Information Facility ID Code Facility SUN MOTOR CAR'S INC Address Line 1 4444 CARLISLE PIKE Address Line 2 City CAMP HILL State Zip PA 17011 Phonel (717) 737-3030 Phone2 Fax (717) 901-9034 Fed Tax ID License No Bar No Contact Name Contact Email Calendar of Events Loss Date 7/1212007 Assignment 7/27/2007 Inspection 8/03/2007 Est Sw Created 8/03/2007 PC Created 9/28/2007 3:27:36 PM Estimate Page 2 of 5 REPAIRS.SUPPLEMENT HOTLINE: FAX (972) 5101561 VOICE MAIL (610) 4012382ESTIMATE REVIEWED WITH VEHICLE OWNERESTIMATE FAXED Notes AND MAILED TO BODY SHOPAT TIME OF ESTIMATE BODY SHOP WAS UNAVAILABLE TO REVIEW ESTIMATE WITHBETTERMENT EXPLAINED TO VEHICLE OWNER Comments Vehicle Information Database Code 3138 Model E350 Paint Tone License Plate No GFC0668 Type Paint Stage 2 License Plate State PA Body Style STD SEDAN Paint Code 1 VIN WDBUF56I36A785497 Trim Code Paint Code 2 Condition Trim Color Paint Code 3 Production Date ??/???? Molding Code Primary Point of Year 2006 Engine 6CYL GASOLINE 3.5 Impact Right Front Center Make Code 3 Mileage 25569 Secondary Points Make Description MERCEDES-BENZ Color SILVER Right Side of Impact Equipment Options HEATED FRONT SEATS ;MOONROOF ;REAR SIDE IMPACT AIRBAGS;TWO STAGE Line Items Line Ver Operation Part Type Description OEM/Vendor Qty Price Ext Part Part Labor Labor System # Part Number Adj Adj Units Type Notes % Amt 1 E R&R OEM Mldg,Frt Bumper Cover 21188002129040 1180.00 T 180.00 RT (ORDER BY COLOR) 2 E Remove/Install Mldg,Frt Bumper Cover RBcI ASSEMBLY LT 3 E Repair Cover,Front Bumper REPAIR 1 0 T Body Cover,Front Bumper 4 E Refinish (BLEND PAINT/ CLEAR REF 011.8F 3.1 T Refinish WHOLE PANEL) 5 E Addl Labor Front Bumper Cover ADDTL LABOR 1.9 T Body 6 E Remove/Install HHTadlamp Assy,Halogen R&I ASSEMBLY 0.3 T Body 7 E Repair Fender,Front RT REPAIR 3.0 T Body 8 E Refinish Fender,Front RT REF 004.2V 2.8 T Refinish 9 E Repair Mldg,Fender Side R/R REPAIR (CLEAN AND POLISH) 0_2 T Bod Y 30 E Remove/Install MIdg,Fender Side R/R R&I ASSEMBLY 0.1 T Body 11 E Remove/Install Skirt,Inner Fender RT R&IASSEMBLY 0.2 T Body 12 E Remove/Install Skirt,Inner Fender RT RW ASSEMBLY 0.5 T Body 13 E Repair Door Shell,Front RT REPAIR 1.5 T Body 14 E Refinish Door Shell,Front RT REF 008.1V 2.3 T Refinish 15 E Remove/Install RMl g,Front Door Side R&I ASSEMBLY 0.3 T Body 16 E Remove/Install W/Strip,Front Door RT R&I ASSEMBLY 0.5 T Body 17 E R&R OEM MIdg,Front Door Belt RT 2116900480 1 42.50 T 42.50 .0.2 T Body 18 E Remove/Install Applique,Frt Door Fram R&I ASSEMBLY RT 0.2 T Body 19 E Remove/Install Handle,Front Door Otr RW ASSEMBLY RT 1.4 T Body 20 E Remove/Install W/Strip,Frt Door Lwr RT R&I ASSEMBLY 0.2 T Body 21 E Remove/Install W/Strip,Front Door RT R&I ASSEMBLY 0.2 T Body Estimate Page 3 of 5 Glass,Front Door T RT 22 E Repair (CLEAN AND INSPECT REPAIR 0.3 T Body ONLY) 23 E Remove/Install RCTannel,Front Glass Ru R&I ASSEMBLY 0.5 T Body 24 E Repair Door Sheli,Rear RT REPAIR 2.5 T Body 25 E Refinish Door Shell,Rear RT REF 006.7V 2.0 T Refinish 26 E Remove/Install Mldg,Rear Door Side RT R&I ASSEMBLY 0.3 T Body 27 E Remove/Install Applique Assy,Rear Dr R&I ASSEMBLY 0.1 T Body 28 E Remove/Install Mldg,Rear Door Belt RT R&I ASSEMBLY 0.2 T Body 29 E Remove/Install HRTndle,RR Door Outer R&I ASSEMBLY 0.6 T Body 30 E Remove/Install W/Strip,RR Door Lower R&I ASSEMBLY RT 0.1 T Body 31 E Remove/Install W/Strip,Rear Door RT R&I ASSEMBLY 0.5 T- Body 32 E Remove/Install R annel,Rear Glass Run R&I ASSEMBLY 33 E Remove/Install Rear Vent Glass R & I R&I ASSEMBLY 2.2 T Body 34 E Repair Wheel,Front RT (CLEAN REPAIR AND POLISH ONLY) UT Body 35 E Remove/Install Front Wheel R & I RT R&I ASSEMBLY 36 E R&R Lamp,Side Marker RT 2038201421 37 E R&R OEM Housing,Mirror Outer 20381006649040 RT (ORDER BY COLOR) 1 167.00 T 167.00 0.5 T Body 38 E R&R OEM Mirror,Outer R/C RT 2038105076 1 165.00 T 165.00 0.3 T Body 39 E R&R OEM RGl ss,Minor Outer R/C 2038100221 1 87.00 T 87.00 40 E Repair COLOR SAND AND BUFF Repair 1_5 T Body 41 E Addl Labor COVER CAR/ INCL SET Additional Labor 42 E R&R Aftermarket FLEX ADDITIVE 1 8.00 T 8.00 43 E R&R OEM CORROSION Replace OEM PROTECTION 1 5.00 T 5.00 0 _3 T Body 44 E Sublet Sublet HAZARDOUS WASTE Sublet 1 3 00 T 3 00 REMOVAL . . 45 E Sublet Sublet WHEEL BALANCE (RT Sublet FRONT WHEEL) 1 15.00 T 15.00 46 E Addl Labor COLOR TINT Additional Labor 0.5 T Body 47 E R&R Aftermarket CERAMIC CLEAR ' (LOCAL PPG SUPPLIER) 1 80_00 T 80.00 48 E Remove/Install Panel,Frt Bmpr License R&I ASSEMBLY 0.2 T Body 49 E Remove/Install Spoiler,Lower Front R&I ASSEMBLY 50 E Remove/Install Lamp Assembly,Fog LT R&I ASSEMBLY 51 E Remove/Install Lamp Assembly,Fog RT R&I ASSEMBLY 52 E Remove/Install Lamp,Side Marker LT R&I ASSEMBLY 53 E Remove/Install Lamp,Side Marker RT R8Q ASSEMBLY 54 E Remove/Install Grille,Frt Bmpr Cvr R&I ASSEMBLY 0.2 T Body 55 E Addl Labor OFrt verhauper Cvr ADDTL LABOR 2.1 T Body Panel,Quarter RT 56 E Blend (REQUIRED FOR REF 006.9V REFINISH OF 1.3 T Refinish WINDSHIELD PILLAR) Pillar,Windshield RT 57 E Repair,Partial (CHIP IN POST FROM PARTL.REPR 0.5 T Body MIRROR HITTING IT) 58 E Refinish Pillar,Windshield RT REF 004.41 1.2 T Refinish 59 E Blend Door,Fuel Filler RT REF 001.OV 0.2 T Refinish Bumper Assembly,Rear 60 E Remove/Install (LOOSEN RT END FOR R&I ASSEMBLY 0.6 T Body PAINT) 11ttn-/Aa7,%a7Aa7 nrnrPCCnlaim.c cnm/weh/clients/generic/F.timate Form. asnx?dnCi Estimate Page 4 of 5 61 E Remove/Install 62 E Remove/Install Taillamp Assembly RT R&I ASSEMBLY Mldg,Roof Drip RT R&I ASSEMBLY 1.2 T Body 0.3 T Body Summa ry Type Supp Units / Rate Other Misc Base Markup Discount Gross Tax Rate Totalsr Amt Parts OEM 646.50 0.00 0.00 646.50 6.0000% Aftermarket 88.00 0.00 0.00 88.00 6.0000% Total Parts Labor Body E01 Body S01 Refinish E01 Refinish Sol Total Labor Material Paint Total Material Sublet Sublet Total Sublet Other Charges Total Other Charges Taxes Sales Tax Total Taxes Estimate Totals Estimate Total Previous Total Current Supplement Customer Pay Deductible Related Prior Damage Appearance Allowance Betterment Customer Total Insurance Pay - - 734 50 Insurance Pay 500.00 2492.38 charges At-A-Glance Estimate has no charges. Vendor Info Estimate has no relevant vendor information. IMPORTANT INFORMATION ABOUT ENCOMPASS'S CHOICE OF PARTS POLICY This estimate may list parts for use in the repair of your vehicle that are manufactured by a company other than the original manufacturer of your vehicle. These parts are commonly referred to as aftermarket parts or competitive parts, and would be designated on this estimate as "QUAL REPL PARTS", "A/M" or "COMP REPL PARTS". Such parts may include cosmetic outer body crash parts such as hoods, fenders, bumper covers, etc. 0.00 0.00 734.50 - 734.5( 25.40 44.00 1117.60 0.00 0.00 1117.60 6.00000/a 2.60 44.00 114.40 0.00 0.00 114.40 6.0000% 10.20 44.00 448.80 0.00 0.00 448.80 6.0000% 2.70 44.00 118.80 0.00 0.00 118.80 6.0000% - - 1799.60 0.00 0.00 1799.60 - 1799.60 12.90 21.00 258.00 400.00 270.90 - - 270.90 6.0000% - - 258.00 - 270.90 0.00 0.00 270.90 - 270.90 - - 18.00 0.00 0.00 18.00 6.0000% - - - 18.00 0.00 0.00 18.00 - 18.00 - - - 0.00 0.00 - 0.00 2823.00 6.0000% - 169.38 - - 169.38 - - - - 169.38 0.00 0.00 169.38 - 169.38 2992.38 2685.09 307.29 500.00 htti)://www.i)rocessclaims. comlweb/clients/genericlEstimateForrn. asDx?docid=268900.9 Estimate Page 5 of 5 Encompass guarantees the fit and corrosion resistance of any aftermarket/competitive outer body crash parts that are listed on this estimate and actually used in the repair of your vehicle for as long as you own it. If a problem develops with the fit or corrosion resistance of these parts, they will be repaired or replaced at Encompass's expense. This guarantee is limited to the repair or replacement of the part. However, if you choose not to use one or more of the aftermarket/competitive outer body crash parts that may be listed on this estimate in the repair of your vehicle, Encompass will specify the use of original equipment manufacturer parts, either new or recycled at Encompass's option, at no additional cost to you. Encompass does not separately guarantee the performance of original equipment manufacturer parts, and makes no representation about the availability of any manufacturer's guarantee. IMPORTANT INFORMATION ABOUT ENCOMPASS'S CHOICE OF PARTS POLICY This estimate may list parts for use in the repair of your vehicle that are manufactured by a company other than the original manufacturer of your vehicle. These parts are commonly referred to as aftermarket parts or competitive parts, and would be designated on this estimate as "QUAL REPL PARTS", "A/M" or "COMP REPL PARTS". Such parts may include cosmetic outer body crash parts such as hoods, fenders, bumper covers, etc. Encompass guarantees the fit and corrosion resistance of any aftermarket/competitive outer body crash parts that are listed on this estimate and actually used in the repair of your vehicle for as long as you own it. If a problem develops with the fit or corrosion resistance of these parts, they will be repaired or replaced at Encompass's expense. This guarantee is limited to the repair or replacement of the part. However, if you choose not to use one or more of the aftermarket/competitive outer body crash parts that may be listed on this estimate in the repair of your vehicle, Encompass will specify the use of original equipment manufacturer parts, either new or recycled at Encompass's option, at no additional cost to you. Encompass does not separately guarantee the performance of original equipment manufacturer parts, and makes no representation about the availability of any manufacturer's guarantee. IMPORTANT INFORMATION ABOUT ENCOMPASS'S CHOICE OF PARTS POLICY This estimate may list parts for use in the repair of your vehicle that are manufactured by a company other than the original manufacturer of your vehicle. These parts are commonly referred to as aftermarket parts or competitive parts, and would be designated on this estimate as "QUAL REPL PARTS", "A/M" or "COMP REPL PARTS". Such parts may include cosmetic outer body crash parts such as hoods, fenders, bumper covers, etc. Encompass guarantees the fit and corrosion resistance of any aftermarket/competitive outer body crash parts that are listed on this estimate and actually used in the repair of your vehicle for as long as you own it. If a problem develops with the fit or corrosion resistance of these parts, they will be repaired or replaced at Encompass's expense. This guarantee is limited to the repair or replacement of the part. However, if you choose not to use one or more of the aftermarket/competitive outer body crash parts that may be listed on this estimate in the repair of your vehicle, Encompass will specify the use of original equipment manufacturer parts, either new or recycled at Encompass's option, at no additional cost to you. Encompass does not separately guarantee the performance of original equipment manufacturer parts, and makes no representation about the availability of any manufacturer's guarantee. x.44..•//aa.•rtv rr?no.nnn?nimn nnm /iva}?Inli VERIFICATION I, PATRICK SMITH, hereby verify that the facts set forth in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. E4 PATRICK SMITH Tc? P ? ? C .p L 00 00 0 V C"^ ^-a ., ? ci t .z r, 77, s 0 SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY I.D. NO. 15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 PATRICK SMITH V. ALAMO RENT A CAR and RODERICK O' KORLEY Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 08-2024 AFFIDAVIT OF SERVICE I, Paul N. Sandler, Esquire, being duly sworn according to law, deposes and says that a true and correct copy of the Complaint in the above matter was served upon Defendant, Alamo Rent A Car, on April 7, 2008 as evidenced by a true and correct copy of return receipt attached hereto as Exhibit "A". and Roderick O'Korley on April 7, 2008 as evidenced by a true and correct copy of return receipt attached hereto as Exhibit "B". SANDLER & MARCHESINI, P.C. Sworn to and Subscribed before me this „36""day of u,._e_ , 2008 OTARY PUBLIC By: PAUL SANDLER, ESQUIRE Attorney for Plaintiff T 01 :: ¦ Complete items 1 2, 3 'Also a A item 4 tf Restricted Deliveryis desired.' Agent ¦ Print your name and address on the reverse ' O Addresses so that we can return ttie card to you. B. Received b, rPOnted PF MLDMNWY tb the k of the mailpiece, ¦ Attah this card UU5 or on the front if space p*ftit§. y 64.*y address different from Item 1? Oyes 1. Arfide Addressed to: g If YES, enter delivery address below: O No E RV 3.- SV e j rvlceerttfleType d Mom 0 Express Mail ? Registered (,ietum Receipt for Merdtandba 4. Restrricte ed d Mall Mary? fE t?aW) O Ym 2. ARlole r4uml?er 7007 302:0 D U1 1280 19-29 (fiwmrer<fnxie 9*0ce lebef) P$ Form 3811, February 2004 Domestle Return Receipt 102595.02-WI540 :A a Complete item`s 1 ?' ; 3: J a=; 0 t ; s item 4 N Restricted Delivery v ? ¦ Print your name aril addre ,on so that we can retum thh card to you: x } ( Name) Date of Dellve y X Attach this card to the back bf the mailpiece, j' or on the front If space Permits. 4- dilfererit kem 1? 0 Yes aD.? eINePY . Article Addressed to: 1 0 No If ill=s, ester delivery add ` below ff 1 L 3. $4vlce TYPO Cent ed mail 0 Swess Mail f ^ /7 L_1_C1 `JC-x l T 1 ? 0 Registe?ecJ ?etum Recelpt for Merchandise F' 0 Insured Mail 0 C-00. ? } 3 Off. I 4. Restricted DelivW Pft Fee) 0 Yes 2. ArddeNumber i 7007 3020 0001 1280 1806 R s 102595-024A-1540 Ps Form 3811, February 2004 Domestic Retum Receipt SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY I.D. NO. 15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 PATRICK SMITH V. ALAMO RENT A CAR and RODERICK O' KORLEY Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 08-2024 ORDER TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case SETTLED, DISCONTINUED AND ENDED. S MARCHESINI, P.C. By: PAUL . SANDLER, ESQUIRE Attorney for Plaintiff 5?-, ?? f--tl'1 . ?? ? 4 ? -'y , 3-. ,, ,?. ' ? ..- "?? t'4 =1 i' . , t. ?'' `.G ..? ...--