HomeMy WebLinkAbout09-8733RITE AID HDQTRS. CORP.,
vs.
VUPOINT SOLUTIONS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
NO. c- '
p S?7 3 -3 c N> >
CIVIL ACTION - LAW
Defendant.
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 written appearance personally or by 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, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES
THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone: (717) 249-3166
RITE AID HDQTRS. CORP.., IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
• NO.
vs.
VUPOINT SOLUTIONS, CIVIL ACTION - LAW
Defendant.
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mds adelante en las siguientes paginas, debe tomar acci6n dentro de los
pr6ximos veinte (20) dias despuds de la notificaci6n de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por
escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier
otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mds aviso adicional. Usted puede perder dinero o propiedad u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. Sl
USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA
OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE
QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE
OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE
CUALIFICAN.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone: (717) 249-3166
RITE AID HDQTRS. CORP., IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
NO. D y r g`
Vs.
VUPOINT SOLUTIONS, CIVIL ACTION - LAW
Defendant.
COMPLAINT
Plaintiff Rite Aid Hdqtrs. Corp. ("Rite Aid"), by its undersigned attorneys, files
this Complaint alleging as follows:
PARTIES
1. Rite Aid is a Delaware corporation with its principal place of business at
30 Hunter Lane, Camp Hill, Pennsylvania 17011.
2. On information and belief, defendant VuPoint Solutions ("VuPoint") is a
is a California corporation with a principal place of business at 17583 Railroad Street, City of
Industry, CA 91748.
JURISDICTION AND VENUE
3. This court has jurisdiction pursuant to 42 Pa.C.S. §93l(a).
4. Venue in this Court is proper because the cause of action arose in
Cumberland County and a transaction or occurrence took place out of which the cause of action
arose in Cumberland County.
RELEVANT FACTS
5. Rite Aid is a national drug store chain with its principal office in
Cumberland County, Pennsylvania.
6. At all times relevant to this Complaint, VuPoint was involved in the
manufacture, sale and distribution of consumer electronics including, but not limited to, cameras
and camcorders (collectively "Cameras")
7. Rite Aid and VuPoint entered into several agreements regarding the sale
of VuPoint Cameras in Rite Aid's retail drug stores.
In May, 2005, Rite Aid and VuPoint entered into a Guaranteed Sales
Agreement ("GSA") in which VuPoint "guarantee[d] the sale of [VuPoint's] product to Rite Aid
at both Customer Service Centers (i.e. distribution centers) and retail locations." A true and
correct copy of the GSA, a valid and enforceable written contract, is attached to this Complaint
as Exhibit A.
9. Under the GSA, Rite Aid had the right to return all unsold product to
VuPoint for a cash refund.
10. Specifically, the GSA provided:
If at any time Rite Aid determines in its sole discretion that
Vendor's product(s) performance continues to be unacceptable,
Rite Aid will have the right to return at Vendor's expense all
unsold product(s) to Vendor's facility in return for Vendor's cash
payment to Rite Aid for any products for which Rite Aid has paid,
but have not been sold.
See Exhibit A.
11. Rite Aid and VuPoint also entered into a Rite Aid Returns Agreement
("Returns Agreement") that provided the manner in which VuPoint's products could be returned
to VuPoint. A true and correct copy of the Returns Agreement, a valid and enforceable written
contract, is attached to this Complaint as Exhibit B.
-2-
12. The Returns Agreement permitted VuPoint to direct how Rite Aid should
handle damaged, defective, outdated and discontinued goods ("unsaleable product"). See Exhibit
B.
13. VuPoint decided that the unsaleable product should be scanned and
shipped back to VuPoint and VuPoint agreed to pay a fee for this particular method of
disposition. See Exhibit B.
14. VuPoint also agreed to pay freight charges and Vendor Compliance
Charges for distribution of VuPoint's product.
15. In addition, the Returns Agreement signed by VuPoint provided that
VuPoint would be charged fees for the unsaleable product ("USI unsaleables"), and that such
USI unsaleables would be deducted from the amount due to VuPoint. See Exhibit B.
16. VuPoint also entered into a Promotional Funding Agreement with Rite
Aid whereby it agreed to fund the marketing and advertising of VuPoint's products. A true and
correct copy of the Promotional Funding Agreement dated October 1, 2007, a valid and
enforceable written contract, is attached to this Complaint as Exhibit C.
17. Pursuant to the Promotional Funding Agreements, VuPoint agreed to
deduct the marketing costs from the amounts owing by Rite Aid. See Exhibit C.
18. VuPoint also signed Rite Aid Incremental Investment Agreements
whereby it agreed to fund retail store markdowns, scandowns, fixture displays and manufacturer
coupons. True and correct copies of the Incremental Investment Agreements, valid and
enforceable written contracts, are attached to this Complaint as Exhibit D.
19. Due to the fees and expenses charged pursuant to the agreements listed in
paragraphs 7 through 18 above ("Fees"), as of December 16, 2009, VuPoint's account with Rite
-3-
Aid has a $135,944.29 negative balance, which is expected to grow after all returns are processed
and other account charge backs are applied.
20. On information and belief, the amount due and owing to Rite Aid will
continue to increase.
21. As of the date of the filing of this Complaint, VuPoint is in breach of the
GSA, Returns Agreement, Promotional Funding Agreement, Incremental Investment Agreement
and other related account contracts and agreements because it refuses to pay Rite Aid the
negative balance on its account.
COUNTI
BREACH OF CONTRACT
22. Rite Aid incorporates the averments in paragraphs I through 21 above as
if fully set forth herein.
23. As noted in paragraphs 7- 22 above, Rite Aid and VuPoint entered into
various valid and enforceable written agreements under which VuPoint agreed to pay certain
Fees.
24. To date, VuPoint owes Rite Aid $135,944.29 in Fees. A statement of the
account of the negative balances and summary sheets reflecting this amount is attached as
Exhibit E.
25. Despite repeated requests, VuPoint refuses to pay the negative account
balance of $135,944.29 to Rite Aid.
26. Rite Aid has performed all conditions precedent under the GSA, Returns
Agreement, Promotional Funding Agreement, Incremental Investment Agreement and all related
agreements under the account.
-4-
27. VuPoint is in breach of the GSA, Returns Agreement, Promotional
Funding Agreement, Incremental Investment Agreement and all related agreements because it
has failed to pay the negative balance on its account.
28. As of December 16, 2009, Rite Aid has suffered damages in excess of
$135,944.29, an amount that will increase as additional returns and other Fees are processed, due
to the breaches of VuPoint.
WHEREFORE, Rite Aid requests judgment in an amount in excess of
$135,944.29, plus interest, costs and all other amounts deemed appropriate by the Court.
COUNT II
UNJUST ENRICHMENT
29. Rite Aid incorporates the averments in paragraphs 1 through 28 above as
if fully set forth herein.
30. In the event VuPoint contends no contractual relationship exists, Rite Aid
is entitled to recover the outstanding amounts to prevent VuPoint from being unjustly enriched.
31. As is customary in the industry, VuPoint was to pay for certain Fees
associated with the sale of its product.
32. VuPoint owes Rite Aid $135,944.29 in Fees.
33. Rite Aid has a reasonable expectation to receive the Fees incurred.
34. VuPoint reasonably should have expected to pay the Fees as such Fees are
custom in the industry.
35. It would be inequitable for VuPoint to receive the benefit of the
$135,944.29 still owed to Rite Aid.
36. In the event the contracts are deemed to be unenforceable, Rite Aid has no
adequate remedy at law.
-5-
37. Rite Aid is entitled to collect the outstanding balance, plus interest, from
VuPoint under the doctrine of unjust enrichment.
-6-
WHEREFORE, Rite Aid requests that judgment be entered against VuPoint in the
amount of $135,944.29 plus interest, costs and all other amounts deemed appropriate by the
Court.
Respectfully submitted,
Brian P. Downey, Esquire (PA 59891)
Frederick Alcaro (PA 91555)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
P.O. Box 1181
Harrisburg, PA 17108-1181
717.255.1155
717.238.0575 Fax
downeyb@pepperlaw.com
alcarof@pepperlaw.com
Date: December 18, 2009 Attorneys for Plaintiff
Rite Aid Hdgtrs.Corp.
-7-
VERIFICATION
Allen Brown signs this Verification on behalf of Rite Aid Hdqtrs. Corp., and does
hereby verify that the foregoing Complaint was prepared with the assistance and advice of
counsel, and in reliance upon counsel's advice; that the document, subject to inadvertent or
undiscovered errors, is based upon and therefore limited by the records and information still in
existence, presently recollected and thus far discovered in preparation of this document; and that
subject to the limitations set forth herein, the statements contained in this document are true and
correct to the best of his knowledge, information and belief. The language of the foregoing
document is that of counsel.
It is understood that the statements herein are made subject to the penalties of
18 Pa. C.S. § 4904 relating to unsworn falsification to authorities.
Ntm b ?w-%
ALLEN BROWN
Date: December 16, 2009
,? ?, b t'+
06/26/05 08:02 PAZ 717 731 6762 RITE AID CAT NAN 0 021
RITE AID CORPORATION
GUARANTEED SALES AGREDIE.NT
Rite Aid will consider Vendor"s product(s) for distribution and sale under the terms and
conditions set forth in this Agreement. In consideration of Rite Aid's agreement to review a new
catty into its mix, as Well as in consideration of the mutual premises contained herein, the parties
agree as follows:
1. Vendor will guarantee the sale of Vendor's product(s) to Rite Aid at both Customer
Service Centers (i.e. distribution centers) and retail locations.
2. During the first one hundred twenty (120) days, or such other period as Rite Aid may
determine in its sole dlscreliort (it being understood by Vendor that Rite Aid nay
tam this Agreement in its sole discretion at arty time, for any reason wbatsoeu+er)
following the date if tin Vendor's first delivery of product(s) to Rite Aid (the "Review
(i period"), Vendor's account will be on a review status to permit Rite Aid to assess the
performance of the product(s). During tluc Review Period, Rite Aid will pay only for
those product(s) that are actually sold, and Rite Aid's payment will be reduced by any and
all cash discounts or other debit amounts ('including, but not limited to, advertising,
displays, markdowns and price protection) due to Rite Aid. if at the end of the Review
Period, Rite Aid ddermWM in its sole discretion, that the Vendor's product(s) is not
selling at as acceptable rate, then Rite Aid will have the right to (a) require Vendor to
review and modify Vendor's marketing plan to ensure future success and (b) extend the
due date of the original invoice submitted by Vendor. Rite Aid also has the right to '
require a cash payment, as described in paragraph (3) below. The foregoing rights arc not
exchnive. At the end of the Review Period, Rite Aid may terminate this Agreement,
place the Vendor on Rite Aid's customary payment terns, or extend the Review Period as
Rite Aid, in its sole discretion, so desires.
3. If at any time Rite Aid determines In its sole discretion that Vendor's product(s)
performance continues to be unable, Rite Aid will have the right to return at
Vendor's expense all unsold product(s) to Vendor's facility in retum for Vendor's cash
payment to Rite Aid for any products for which Rite Aid has paid, but have not been sold.
i vendor's payment to Rite Aid shall be made (a) by who transfer of immediately
available funds or certified check, and (b) no later than fifteen (15) days after Rite Aid
has returned the product(sj Vendor acknowledges and agru cs that in the event that any of
Vendor's allowances are funded with "free product" from Vendor, that "free product"
will be treated identically to product purchased from Vendor by Rite Aid. This
includes„ but is not limited to, returns of this product to Vendor.
4. Upon settlement of Vendor's account, all outstanding invoices will be paid promptly, less
any and all cash discounts or other debit amounts dux to Rite Aid.
RwwbWWU2M
08/26/0 09!02 FAI 717 731 1732 RITE AID CAT HAV ® 023
S. The terms and conditions of this Agreement are in addition to, and in no way limit, Rite
Aid`s rights and =&e$ under Rite Aid's Vendor Profile, standard terms and conditions
or purchase orders. In the event of inconsistency between the tabus and conditions of the
Agreement and any of the foregoing documents, this Agreement will 90vC .
6. The parties agree that Pemsylvanla law govoras this Agreement not withstanding its
couNds of law provisions. Arty lawsuit brought with regard to this Gmranteed Sales
Agreement will be vcnued in the Court of Common Pleas, Cumberland County,
Peanrytvania.
7. Thee pia specifically agree that 13 Pa. C.S.A. 12326 & 2327(b) are inapplicable and
that Vendor will accept returned goods m their "as-e condition.
8. All returns are at risk of vendor.
9. Vendor can not assign any product covered by this Agreement to any third party without
the express written consent of a Vice President of Category Management.
Rite Aid is enthusiastic about the opportunity to distribute product(s) into the marketplace. Rite
Aid wishes you every success In your endeavor to provide a product that is unique. Please allow
Rite Aid to assist you in your distnbWon needs by arranging for a duly authorized officer to sign
and data this Agreerncat on behalf of your company, and return the executed letter to Rite Aid's
Merchandising DepartmcnL
Vendor:
By.
Authorized Signature
Date: ?-3
Title: /??OFl1 /T
i
ROWM2M
I_ ??
?y `1i IUD
06/26/05 06:59 FAX 717 731 4732 RITE AID CAT NAN Olb
.I
RITE AID RETURNS AGREEMENT
Please note: A Ewarab Returns AummW must be no out for each vendor number.
Company "M Vup*t Solutions
Contact Name: Lauren Kukkamaa____?_ Phone #561.575,2110
Fax #587.748.0450
Vendor Number: E-Mail Address: LaunlnK®vupointsokMons corn _____,_
kwoioe Address: Shipping Address:
17513 Ralboed Sheet 435 South 0 Street l
Chy off. CA 9174E Ctry of lodtnvy, CA 91746
Category Manager.
TERMS OF /40REEMENT•
A. Utlsateable Merchandise
r
1. AI! vendors will be charged the folkwing proaaing Tees for damaged, detective, outdated. end discontinued `
goods. These fees are based on the findings from the Joint Industry Task Force
Study (JIRx
DPC (Direct Product Cost) $0.085
Post Damage $0.111
Ops through Scan: 50.101
$0.297
2 All vte xkW3 must delarmine a method of disposition fa their unsaleable products. Based on the
COOODESCRIPTIONS listed below. the vendor repressntattve wM check pre ft method his/her company has
authorized Rite Aid to use. The additional charge. shown in 0 at the end of the description. will be added to the
charges above.
cow DESCRIPTION OR COSTI
COPT „_ Sears and dispoeMon b left up to the discretion of Rae Aid ($0.020)•
DM_ Scam and donate ($0.030)
ROPT San, Hold. Venda RevtewlCenter Option (30.127)
RDON ` Scan. Hold, Vendor Review, Donate ($0.137)
RTAK Scan, Hold, Vendor Review, Take ($0.174)
RSHP _ Scan. Hold, Vendor Review, Ship ($0.188)
Nob. AA Vendor Review marelrandlse will be held ihr21
drtys after Invoke dab tbrnview. At that titres N ?
M rev brwd, or1?no decision has boon pro vided by the menufech~ the prodrxl wfii be disposed of at
Me d 1scretton of Me Aid
SHSK _ g San and ship back to vendor ($0.180)
OPEN RAN REQUIRED WITH THIS OPTION RAM 2050430t.KA .
Rev 07raM
08/26/03 09:00 FAX 717 731 1732 RITE AID CAT NAN 018
Rite AM Retums Agreement
Pace 2
3. All proddxcia, will be billed at Rile Aid's ht cost + JIR billing indoors (DPC, Post Damage Handling,
Rec Charges. DapoOm Charges) union otherwise agreed to in writing by Rlte Aid Corpornion.
Vendor bU ft Is not to exceed 130% of Rtts Mira fist east
4. a All changes b30pdo? sag Inwritin Aid Corporation. Approved pocky changes will take
within
r approval.
5. All vendors will agree to orward a copy of their current national policy regarding recdamadon to be 1
reviewed by Rb Aid Corporatism. This will be sent to:
RKe Aid Corporation
30 Hunter Lane
Camp Hill, PA 17011
Attention: Manager, Front End Returns
B. Recap Merchandise «Plesse note: The dispositions on page 1 pQ NOT apply to redacts. A
separate agreement MUST be filled out for all recaps at the time the tscap b being aWvated.
This allows a vendor to have a separate dispoeltion on recaps than they have on damaged
and outdated return.
1
The sipnahm below by the appropriate Category Manager of Rite Aid Corporation and the vendor
representative of said company denote their understanding and aceeptence of the above agreemea
i
L 0j
Signaturr?e?(}Vendor epnneennta?Urve) ?Date S rs by . ) pa
?^"''? '''•?? />K- Rlts Aid Corporation
Company
Rev 07r=
? x? r? ?? ?
Page 1 of 1
Contract # 0204,920
i Rite Aid Promotional Funding Agreement
Fiscal Year 2009
Ccmpany llama: yUPOtNT SOLUTIONS
B-Iling Address: ATTN: MICHELLE YANG Category Ma
Hagar, HUBER, JAY
17583 RAILROAQ STREET Vendor it: 39896
Contact CITY OF INOUSTRY CA 91748
Dick Onrgne
Email Phone. .
Fax*. 3a1748o4+sp
vUPOIQINT SOLUTIONS
V PP prorLU nod (Supplier) t'"00Y agrees to participate in Rite Aid's Fiscal Yea@009
be d• r 00 % of Rite Aidp s ra In the amount indicated herein. The amount to be Not purr February 28. 2009 asesof Suppileu'a Paid 0 the Supplier will
belowa yhe 200 (but not lose than dthe M evelop atlntum Promotional betw?n r'? and
Funding Will be u nFunding Coor set pforth
rop
by Supplier's Rigs Aid Cat_ and olk g ? rnaricetin
Products in?toAid..s?otaa y np Pro?notfn and advancin ®MPPoK deonted appropriate
dirrnnulion of any the sale* negotlgtsd prfclnS' payment terms . volume Incentives, rind not in substitution for or
purchase inc®rrtivse, fundin rebates, other contract
tuKl hale, new iv 9 for retail markdov.Tte, off-shelf die Singie
items. new store allowances, Health R
e source vice Partip Check Rebate
Participation, Rite Aid Health and t3eau ?? Rite Ad
pro9rgms n tY Expos, Rite Aid Foundation Charity paypn Trade Show
ow existing or that msy be developed from time to time. Golf Classic, or other
The Suppliers Minimum Promotional Funding Commitment is firm and non-cancelable. Proof of
or about of the motional Funding Canmltment wig ?'? o+virlq by Rite Aid to
8/1!08 , 11/1/08 and 2/1/09 occur In 4 equal ina6slmMts on
The Promotional Fundi
February 28, 2009 n9 basodon Not purchases between March 2, 2008
below. the additional {tindl lust Net Purchasea exceed the Fore and
n9 will be billed and deducted in the final Invoicing Net Purchases set faith
MINHNIU g an or about 3/1/08.
M PROMOTIONAL FUNDING COMMITMENT:
FORECAg-rE0 5
?u?Mn=ra san.x,i.. ?r..r.,,.? t!j./ (?•?. $2,800 Wo
Rift Ale C°bpory 140.0
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AL_ STA*E I. E6AL"' 800-222-0.510
VUPOINT SOLUTIONS v#39898
Statement of Account as of 11-25-09
Descrtpt(on Gross Amt ,Shortage Prlulna N ft Ant
Advertising Allowances Total $ (208,728.57) $ $ $ (208,728.57)
B/E Conversion Display Funding Total $ (50,000.00) $ $ $ (50,000.00)
Connolly Audit Total $ (34,964.00) $ $ $ (34,964.00)
Connolly Primary Post Audit Total $ 34,964.00 $ $ $ 34,964.00
Direct Warehouse Returns Total $ (345,729.30) $ $ $ (345,729.30)
Freight Charges Total $ (5,253.01) $ $ $ (5,253.01)
Invoice Total $ 1,532,937.72 $ (80,642.92) $ (20,321.87) $ 1,431,972.93
Invoice Audit- PRG Total $ (2,000.00) $ $ $ (2,000.00)
Offset Transaction Total $ 00,000.00 $ $ $ 100,000.00
Single Check Rebate Escrow Total $ (18,274.46) $ $ $ (18,274.46)
SMD Internal Post Audit Total $ (2,230.00) $ $ $ (2,230.00)
Store Markdowns Total $ (35,185.00) $ $ $ (35,185.00)
TPR Markdowns Total $ (2,777.50) $ $ $ (2,777.50)
Trade Show Even Year Total $ (22,500.00) $ $ $ (22,500.00)
USI Recalls Total $ (558,114.16) $ $ $ (558,114.16)
USI Unsaleables Total $ (408,945.22) $ $ $ (408,945.22)
Vendor Compliance Charge Total $ (8,180.00) $ $ $ (8,180.00)
Grand Totals $ (34,979.50) $ (80,642.92) $ (20,321.87) $ (135,944.29)
- Includes Hold Amount
C:\Documents and Settings\downeyb\Local Settings\Temporary Internet Files\OLK13D\[Vupoint Solutions v#39898 11-25-09 as1
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