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Home My WebLink About04-4828 JOHN KEENER, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS OF OF CUMBERJLAND COUNTY, PA v. HMCC, INC. CIVIL ACTION - LAW DEFENDANT NO. D'I- '1PJ.'i ~ IL- 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 attorn(:y 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 nay 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 LAYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TIIA T MY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 JOHN KEENER, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS OF OF CUMBERll.AND COUNTY, PA v. HMCC, INC. CIVIL ACTION - LAW DEFENDANT NO. ()l.j - 4. f ~l r Q;;;J T.J.- COMPLAINT 1.) Plaintiff is John Keener, Inc, a Pennsylvanda corporation with its place of business in Silver Springs Township, Cumberland County, Pennsylvania. 2,) Defendant is HMCC, Inc., a Pennsylvania corporation doing business as Hearn & Co, whose office is at 9 Brenneman Circle, Mechanicsburg, Pennsylvania ( Silver Springs Township ), 3,) On April 18, 2203, plaintiff and defendant made a contract whereby plaintiff agreed to supply labor and material to install grout under precast cells which defendant installed at Muncy prison for which defendant agreed to pay plaintiff$14,962,OO. A copy is attached as Exhibit A. 4.) Plaintiff furnished labor and material to complete said work in a timely and workmanlike manner on or before May 30, 2003. 5.) Plaintiff has demanded payment of the contract price of $14,962,00 but defendant has failed and refused to pay the same andl said amount is due and owrng. WHEREFORE, plaintiff demands judgment of defendant in the amount of $14,962,00 plus interest and costs. September,.2i 2004 i /, I \. f? p ''J---l rn . c.~ J M, Eakin l'vta'rket Square Building Mechanicsburg, Pa 17055 (717) 766-3172 ID # 06351 JOHN KEENER, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS OF OF CUMBERLAND COUNTY, PA v. HMCC, INC. CML ACTION - LAW DEFENDANT NO. VERIFICATION I, Paul A. Keener, Jr., Vice President of John Ke:ener Inc., hereby verify that the statements of fact made in the foregoing instrument 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 c;ontained in 18 Pa. C.S, 4904, relating to unsworn falsification to authoriti , .>,'i("1~:._ -.~_',,"i()5',TEX;\C;(, i,RC,,'AD :-MECT"iiliJ, ics"l'l-"u -rill. PA 17055 _~~ ,,_.._PfIO~~~(!~7.\.6~?-:()~~~.~~~'::.:E!2~:!_~~86___. Prooosa! April 18. 2UU3 Hearn & Company 9 Brenneman Circle MechanicsulJ/g. PA 17055 Alln: Dave Keefer RE: Muncy Prison DGS Project # 574-26 Dear Dave: This is to confirm our price of $14,962.00 to install 7000'psi non-shrink grout under the precast cell units at the new Muncy Prison addition. Job to be performed in accordance with all General Conditions with the cDntract and specifications and drawings by the Commonwealth of Pennsylvania Department of General Services. We will be supplying union labor that will have all necessary clearances, including drug testing. We will need clear access to the site along with water and electricity. Prior to the start, we must inspect and record any damaged or stained precast cell units or cell floors. Our price is based on completing the exterior joint at the second floor from the CareW's scaffolding. Payment should be made within 30 days of billing with no retainage held. WE PROPOSE to furnish labor and material - complete in accordance with above specifications, and SUbject to conditions found within this agreement, for the sum of: Fourteen thousand nine hundred and sixtY two dollars and no cents ($14,962 <;IOl Payment to be made as follows: within 30 daw of bi"'",! with no retainal!e held ACCEPTED. The above prices, specifications, and ""nditions are satisfactory and are hereby accepted. You are authorized 10 do the w....k as specified. Pa}ment will be made as outlined above. Respectfully submitted. Dale ~f Acce.'/~,,'afl~: ; - -', " BV: ''-I-' JOliN E. KEENER, INC BY:~r. BY: NoIe: This proposal may be withdrawn by us If not B<X:epled wilhin ~ t> days. Exhibit A Pleme .Ign and return one copy /0 our office. Keep one copy for your records. _.._""-_.._"'~_.._-'.-._.._---'_.'--.~-------_._-_.-------~"_..._----,-----_._- QUALITY MASQNI1Y SINCE 196,' 0 ....., 0 = c: C;:;) -n ~ -~ .to r t :<.;,.. (.I) :e." ;:g I)) . rr: ~ nlF; ;:~ :~f'l :gf9 e ft ;;:~. C N U)r.':: .c- C")(l, "- "" ~;:) c;i-f ~ "- ?:;;;: -c' .,j ~ 9~ V, ~, .;;:: ~ ~ )>(~: C3 U ~ '-1 - 2: ). -1 W ~]. -<. N --, !9 SHERIFF'S RETURN - REGULAR CASE NO: 2004-04828 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JOHN KEENER INC VS HMCC INC CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HMCC INC was served upon the , at 1436:00 HOURS, on the 28th day of September, 2004 DEFENDANT at 9 BRENNEMAN CIRCLE MECHANICSBURG, PA 17055 by handing to LAURIE WAGNER, OFFICE MANAGER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6,66 .00 10.00 .00 34,66 Sworn and Subscribed to before me this .1& day of (Aa.u_ .,;)/X)<( A.D. L.l. ~a /vuoP" > AJ~ 1"J;frothonotary . -r / So Answers: r~~ R, Thomas Kline 09/29/2004 JOHN MEAKIN BY:~ - Deputy er:1ff LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire J.D. No. 68805 103 Mechanics Street Doylestown, PA 18901 (215) 230-8800 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION JOHN KEENER, INC. CIVIL ACTION NO. 04-4828 Plaintiff ATTORNEY 1.0. # 68805 v. HMCC, INC. Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of defendant, HMCC, Inc., in the above-captioned matter. sc~eldman, Esquire Attorney for Defendant 0 '" 0 = c: = 11 ;:;;: .z::- 0 -04 "1:'.11."(; :r:." rn(rt CJ z::: -~ I"n p= ~~ ~~~' N :B~ v:J 0 ~C --I -.) ~n -U -r:'; i':) ::n .Z ~,; 3: ZC j; C/ C::>rn C ~ ~ -\ (11 ;S.o (X) -< LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire 1.0. No. 68805 103 Mechanics Street Doylestown, PA 18901 (215) 230-8800 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION JOHN KEENER, INC, CIVIL ACTION NO. 04-4828 Plaintiff ATTORNEY 1.0. # 68805 v. HMCC, INC. Defendant DEFENDANT, HMCC, INC ~ ANSWER TO PLAINTIFF'S COMPLAINT iirITH NEW MATTER Defendant, HMCC, Inc., by its attorney, Scott L. Feldman, Esquire, hereby files the following Answer to Plaintiff's Complaint with New Matter and avers as follows: 1. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of paragraph 1. 2. Admi tted. 3. Admi tted in part, denied in paJ::t. It is admitted only that the document attached to Plaintiff's Complaint is a writing and as such, speaks for itself. The remaining averments of this paragraph are specifically denied and strict proof demanded. 4. Denied. It is specifically denied that Plaintiff furnished labor and materials to complete said work in a timely and workmanlike manner on or before May 30, 2003. By way of further answer and to the contrary, Defendant incorporates its New Matter as set forth below. 5. Admitted in part, denied in part. It is admitted only that Plaintiff has demanded payment of $14,962.00. The remaining averments of this paragraph are specifically denied and strict proof demanded. WHEREFORE, Defendant, HMCC, Inc., respectfully requests this Court dismiss Plaintiff's Complaint or, in the alternative, enter judgment in its favor and against Plaintiff, together with attorney's fees, costs and interest. New Matter 6. Defendant incorporates paragraphs 1 through 5 as if fully set forth herein. 7. The parties' agreement (Exhibit "A" to Plaintiff's Complaint) requires in relevant part that Plaintiff perform grouting services at the Muncy, Pennsylvania prison project "in accordance with all General Conditions with the Contract and specifications and drawings". 8. The Contract referred to is the Subcontract Agreement dated December 19, 2002 by and between Defendant and Rotondo Weirich Enterprises, Inc. ("RWE"). 9. The Contractor and General Contractor, RWE and Mar-Paul Company, Inc., have each withheld payment to Defendant claiming that it failed to complete the grouting services which it was required to perform and has thus forfeited its right to receive any sums otherwise due under the contract. 10. Specifically, in litigation pending between said parties in the Court of Common Pleas of Montgomery County, PA at Docket No. 04-14607, Rotondo Weirich has averred that "as a result of the failure of performance, RWE was forced t:o correct the defects thereof and to incur additional costs in an effort to complete Hearn's obligations under said contract". 11. good and therefore. Plaintiff failed to perform the contracted services in a workmanlike manner and is not entitled to payment 12. Plaintiff's Complaint fails to state a claim against Defendant upon which relief can be granted. 12. Plaintiff's claims are barred by the Doctrine of Estoppel. 13. Plaintiff's claims are barred by the Doctrine of Waiver. 14. Plaintiff's claims are barred by the doctrine of unclean hands. WHEREFORE, Defendant, HMCC, Inc., respectfully requests this Court dismiss Plaintiff's Complaint or, in the alternative, enter judgment in its favor and against Plaintiff, together with attorney's fees, costs and interest. Respectfully submitted, s~~an, Esquire Attorney for Defendant, HMCC, Inc. LAW OFFICES OF SCOTT L. FELD~ BY: Scott L. Feldman, Esquire 1.D. No. 68805 103 Mechanics Street Doylestown, PA 18901 (215) 230-8800 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION JOHN KEENER, INC. CIVIL ACTION NO. 04-4828 Plaintiff ATTORNEY I.D. # 68805 v. HMCC, INC. Defendant VERIFICATION Scott L. Feldman, Esquire hereby states that he is an attorney duly authorized to practice in the Courts of the Commonwealth of Pennsylvania; that he is attorney for Defendant, and that as such he is authorized to take this Verification on his client's behalf, who is outside the jurisdiction of the Court and whose verification can not be obtained wi thin the time allowed for filing this pleading; and that the statements made in the foregoing Answer with New Matter are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: 1C7(21lt:J~ A//- LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire 1.D. No. 68805 103 Mechanics Street Doylestown, PA 18901 (215) 230-8800 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION JOHN KEENER, INC. CIVIL ACTION NO. 04-4828 Plaintiff ATTORNEY I.D. # 68805 v. HMCC, INC. Defendant CERTIFICATE OF SERVICE I hereby certify that on Tuesday, October 26, 2004, I caused a true and correct copy of the foregoing document (Answer with New Matter) to be served on counsel for Plaintiff by first class mail, postage prepaid, addressed as follows: John M. Eakin, Esquire Market Square Bldg. Main and Market Streets Mechanicsburg, PA 17055 BY: A~J-- sc~:t L. Feldman, Esquire Attorney for Defendant (') c:: ;:{,~ fl.~: '~~)I' . .., .....' " ,'.- ~ ::-:J.' , r..:: :: ..c,..... 1,_ 'j.; - ~:U :l -< '" = C:::> .- o r. -I N \.D C) -n -4 ;:r:-n 1I1f'" -rJrn :'1')0 O{l. :-;j -I C,"""od ..,.d(') t:)rTl '--1 "",,. S~J -< ,J ::1' ", V1 a> JOHN KEENER, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS OF OF CUMBERlAND COUNTY, PA v. CIVIL ACTION - LAW HMCC, INC. DEFENDANT NO. 04-4828 REPLY Plaintiff responds to defendant's New Matter as follows: 6. Paragraph of incorporation. 7. Exhibit A to Plaintiffs Complaint speaks for itself. 8. After reasonable investigation plaintiff is without sufficient knowledge to form an opinion of the truth of the averment and proof is demanded. 9. After reasonable investigation plaintiff is without sufficient knowledge to form an opinion of the truth of the averment and proof is demanded. 10. After reasonable investigation plaintiff is without sufficient knowledge to form an opinion of the truth of the averment and proof is demanded. 11. It is denied that plaintiff failed to perform his duties under the contract and on the contrary all services were performed in a workmanlike manner. 12-14 The allegations of Paragraphs 12, 13 and 14 are conclusions of law to which no responsive pleading is required. (Note there are two Paragraphs 12 and this response applies to both.) Dated: ,') ir <Le...i- () y WHEREFORE plaintiff demands judgment as set: forth in the Complaint. !/",~ T? b l Yh- &.4' J~ . Eakin Mar~:t Square Building Mechanicsburg, PA 17055 (717) 766-3172 ID # 06351 JOHN KEENER, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS OF OF CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW HMCC, INC. DEFENDANT DY- lj~l.<;; NO. VERIFICATION I, Paul A. Keener, Jr., Vice President of John Keener Inc., hereby verify that the statements of fact made in the foregoing instrument 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. 4904, relating to unsworn falsification to authorities. Paill A.dlll JOHN KEENER, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS OF OF CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW HMCC, INC. DEFENDANT NO. 04-4828 CERTIFICATE OF SERVICE I, John M. Eakin, certify that on October 29,2004, I served a true and correct copy of the attached Reply upon the following by depositing the same in the U.S. Mail, First Class, postage paid, at Mechanicsburg, Penn.sylvania, address~ to the following: Scott L. Feldman, Esquire 103 Mechanics Street Dolylestown, PA 18901 ~ ~~ Square Building Mechanicsburg, PA 17055 (717) 766-3172 ID # 06351 (') f'o..;J 0 c:::::. C c::> 'Tl ~:: ..r::- "1:1 G/l 0 :t-n [':lrr; n L:ll -f lTl F~ Zt" N -om (O,c ~O? I-'~ \,0 0 gu < -0 -1'. >e. - - 2.1 Z (.-! :x ....() 5>~ N am ~ -.-\ w ~ Co..) .< John Keener, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4828 CIVIL HMCC, Inc. RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: John M. Eakin ,counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ 14, 962 . 00 The counterclaim of the defendant in the action is None The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: Scott 1.. Fel dm::m, F.Rqlli re 101 Mech~nics Street, Doylestow~, PA 18901 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ORDER OF COURT AND NOW, ~.A~~..) foregoing petition, ;1 ~ .~! ~ Esq., and )j~ ktf~ actions) as prayed for. f ~ctfUny SUbmi,~~ )<tJ.- )1 \ 'C ~v lJ /' , l-9~, in consideration of the r Esq.. ~ ~/.4~A ~ ,Esq,. are appointed arbitrators in the above captioned action (or BY7{IMr PJ. 'rj11\!'~imASt<\!:::d ),lr\Jrl(~~:'~.,~ )<:~;;iV.Jno OS : I ~{d 8- NVr ~aaz AdVlONOH10dd 3Hl :30 . 38f,j;l(}{l3llj ("J ~ C"''''' ---I "~.. ... c~ '~ J i- ll) ("; r....,) \) C'j .' \) - ~ ~ ~ ( ~ r::) 0 V) "'. ~. l:~ .-- ~ ~ '~"... C) ~ --..:..... .. . .-,. LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire I, D. No. 68805 103 Mechanics Street Doylestown, PA 18901 (215) 230-8800 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION IJOHN KEENER, INC, Plaintiff CIVIL ACTION NO. 04-4828 ATTORNEY I,D. # 68805 v. I HMCC, INC. Defendant SUGGESTION OF BANKRUPTCY To the Honorable Court: Please be advised that on April 20, 2005, Defendant, HMCC, Inc., filed a Petition in Bankruptcy in the United States District Court for the Middle District of Pennsylvania (#1:05-bk-02612-MDF) pursuant to Chapter 7 of the Bankruptcy Code, An automatic stay as to all proceedings has thus been imposed in accordance with Section 362(a) of the Bankruptcy Code, 91;v1/~ Date 40/), Scott L, Feldman, Esquire Attorney for Defendant ,- "II ,.~ LAW OFFICES OF SCOTT L. FELDMAN BY: Scott L. Feldman, Esquire I, D. No, 68805 103 Mechanics Street Doylestown, PA 18901 (215) 230-8800 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION I JOHN KEENER, INC. Plaintiff CIVIL ACTION NO. 04-4828 ATTORNEY I,D. # 68805 v. IHMCC, INC. I Defendant CERTIFICATE OF SERVICE I hereby certify that on Friday, April 29, 2005, I caused a true and correct copy of the foregoing document (Suggestion of Bankruptcy) to be served on counsel for Plaintiff by facsimile and by first class mail, postage prepaid, addressed as follows: John M. Eakin, Esquire Market Square Bldg. Main and Market Streets Mechanicsburg, PA 17055 BY: ~~ Scott L. Feldman, Esquire Attorney for Defendant - (; ~~; ~; J::';) L'_..l"l "2,'~ ..:.>.:. \ (,,) L~ ::2 o 41 ._1 -"C -'0 rn-;::-- '-(-,';::I: ~ "'--' ~ :>("~; . \:~ ~J\~, <"':;( , " T" #.,......,' ...;~- - - , ~~'--\ :!~~ .". r--) U;;; - V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4828 CIVIL JOHN KEENER, INC. HMCC, INC. IN RE: ARBITRATION ORDER OF COURT AND NOW, May 4, 2005, the Court having been informed that the defendant, HMCC, Inc., filed a petition in Bankruptcy, and an automatic stay as to all proceedings has thus been imposed in accordance with Section 362(a) of the Bankruptcy Code, the arbitration hearing previously scheduled has been cancelled, and the panel of arbitrators shall be vacated. Robert R. Black, Esquire, Chairman of the Arbitration Panel, shall be paid the sum of $50.00. G vRobert R. Black, Esquire Chairman of the Arbitration Panel 36 South Hanover Street Carlisle, PA 17013 vScott M. Dinner, Esquire 3117 Chestnut Street Camp Hill, PA 17011 ./Scott L. Feldman, Esquire 103 Mechanics Street Doylestown, PA 18901 v11illary Dean, Esquire Ten East High Street Carlisle, PA 17013 ./John M. Eakin, Esquire Market Square Building Mechanicsburg, PA 17055 -It1!$; ~_O" ~,O o \i I ".\i-..'"'" ".... 1\_i.I\Ji: 'Iiv' S , 'S II I 1,.._ 1.',.""",1 COOi " ,'it, . " .; " :\tiV.c::,;'{'.;,:J 3Hl :10 3JL!::C}'-(FnH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN KEENER, INC., CASE NO. 04-4828 Plaintiff CIVIL ACTION - LAW v. HMCC, INC., Defendant NOTICE OF BANKRUPTCY FILING Please be informed that HMCC, Inc., has filed a Petition under Chapter 7 of the United States Bankruptcy Code in the United States Bankruptcy Court for the Middle District of Pennsylvania to Case No. 1-05-02612 and as a result thereof, the above-captioned action is stayed until further Order of the United States Bankruptcy Court. The undersigned executes this Notice for purposes of giving notice only; and the providing oHhis Notice is not intended to enter an appearance in the within case. CUNNINGHAM & CHERNICOFF, P.C. ~/.f'} ~I Robert E. Che 0, Attomey Ident. No. 23380 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 Date: 3"UYI~ J..~ 'l()oj F:\HOME\KMA\HMCC\KEENER. D CERTIFICATE OF SERVICE I, Kimberly M. Adams, a paralegal with the law firm of Cunningham & Chernicoff, P.c., hereby certifies that on ::::i...V\e.... ';;L'1_, 2005, a true and correct copy of the foregoing NOTICE OF BANKRUPTCY FILING was served by facsimile and U.S. first-class mail, postage prepaid, on the following: John M. Eakin, Esquire Markel Square Building Mechanicsburg, P A 17055 Scott 1. Feldman, Esquire 103 Mechanics Street Doylestown, PA 18901 Donald B. Hearn 9 Brenneman Circle Mechanicsburg, PA 17055 CUNNINGHAM & CHERNICOFF, P.C. By: ~~ nt (J,J) ('A ~ Kimbe y M. Adams, Paralegal / '- 0 ~ ~ c. ~ .,,1'" ~e --ote ~ f'fHn % :z; 'J;' "'~ ~1' ~ ;);1 - n!:<" \P 0. ~)i, ~ ~::B '-. %~ ;zc :IC . ,C) 5>c ~ "" ~ ~ ~ Q) -