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HomeMy WebLinkAbout05-1368 \ 1::1 ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE G. RADCLIFF, ESQUIRE, Plaintiff NO. OS - 12t.,f' C'v;L 'I-8L~ V. CIVIL ACTION - LAW JERRY CANTOR, 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 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 325. BEDFORD STREET CARLISLE, PA 17013-3302 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE G. RADCLIFF, ESQUIRE, Plaintiff NO. O~ - /]~p (!'~'LL~~ V. CIVIL ACTION - LAW JERRY CANTOR, Defendant COMPLAINT AND NOW, this day of March , 2005, comes the Plaintiff, Diane G. Radcliff, Esquire, and files this Complaint against the Defendant, Jerry Cantor, whereof the following is a statement; 1. The Plaintiff is Diane G. Radcliff, Esquire, an attorney duly authorized to practice law in the Commonwealth of Pennsylvania and having a place of business located at 3448 Trindle Road, Camp Hill, Pennsylvania. 2. The Defendant is Jerry Cantor, an adult individual residing at 3802 Harness Lane, Camp Hill, Cumberland County, Pennsylvania. 3. On or about October 25,2000, Defendant and Plaintiff entered into an oral contract whereby: A. Defendant hired and retained Plaintiff to represent Defendant and Plaintiff agreed to represent Defendant in litigation involving a real estate transaction arising out of Defendant's inability to complete a real estate purchase due to lack of funds in that matter; - 2 - B. Defendant agreed to pay Plaintiff for that representation at her normal and customary rates and charges, then at the rate of $175.00 per hour together with costs based on actual costs incurred. C. Defendant agreed to pay all such billings within thirty (30) days of the invoice date; D. Defendant agreed to pay interest on the outstanding balance at the rate of 1.5% per month if he failed to pay the invoices within the aforesaid thirty (30) day time period. 4. Pursuant to the said oral contract Plaintiff undertook the legal representation of the Defendant, performed all legal services required as the result of that representation, and charged Defendant for said services at the effective hourly rate set forth above for the relevant time periods involved and for the actual amount of the costs incurred as agreed to by the parties. 5. Plaintiff, on a monthly basis, issued bills to Defendant for her services and costs which bills were accepted by Defendant without objection. The monthly charges made to Defendant are itemized on Plaintiff's Client Billing Summary attached hereto marked Exhibit "Au and made a part hereof. 6, Plaintiff completed her services on behalf of Defendant on or about November 29, 2001. 7. As of March 1,2005, Defendant owed Plaintiff the sum of $2,412.79 as evidenced by the bill issued to Defendant dated March 1, 2005, a true and correct copy of which - 3 - is attached hereto, marked Exhibit "B" and made a part hereof. 8. The fair and reasonable value of Plaintiff's services and costs to the date of the issuance of the bill attached as Exhibit "B" is $2,412.79 and is the customary charge of Plaintiff in like cases and is the amount Defendant agreed to pay. 9. Defendant specifically agreed to pay interest on past due balances at the rate of 1.5% per month. 10. Although Plaintiff has demanded payment of the said $2,412.79 balance, Defendant has failed and refused to pay the same. WHEREFORE Plaintiff requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant in the amount of $2,412.79 together with interest at the rate of 1.5% per month from March 1,2005, until the balance is paid in full, plus costs of suit. Respectfully submitted, - 4 - VERIFICATION I, Diane G. Radcliff, Esquire, verify that the statements made in this Complaint are true and correct. I understands that false statements herein are made subject to the penalties of 18 Pa.c.S. Section 4904, relating to unsworn falsification to authorities. - 5 - EXHIBIT "Au PLAINTIFF'S CLIENT BILLING SUMMARY Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, P A 17011 INVOICE I DATE I 3/1ll2005 I TO: Jerry Cantor 3802 Harness Lane Camp Hill, PA 17011 AMOUNT DUE $2,412.79 DATE DESCRIPTION HOURS AMOUNT BALANCE 09/30/2000 Balance forward 0.00 1011 8/2000 Telephone conference with Carol Clark 0.2 35.00 35.00 10/18/2000 Telephone conference with Attorney Getz 0.2 35.00 70.00 10/19/2000 Telephone conference with Attorney Getz 0.2 35.00 105.00 10/24/2000 Telephone conference with Attorney Getz 0.2 35.00 140.00 10/25/2000 Letter to client 0.2 35.00 175.00 10/25/2000 Fax to Attorney Getz 0.1 17.50 192.50 10/31/2000 Letter to Attorney Getz 0.2 35.00 227.50 11/14/2000 Receipt and review fax and Complaint from 0.5 87.50 315.00 Attorney Getz 1lI27/2000 Receipt and review letter from Attorney Wagner 0.2 35.00 350.00 11/28/2000 Conference with client 0.3 52.50 402.50 11/28/2000 Letter to client 0.3 52.50 455.00 11/30/2000 PMT#109. -227.50 227.50 11/30/2000 Telehpone conference with Attorney Getz 0.1 17.50 245.00 12/14/2000 Preparation of Answer and New Matter 1.5 262.50 507.50 1211 5/2000 Letter to client 0.2 35.00 542.50 12/19/2000 File Answer and Courthouse 0.5 87.50 630.00 12/20/2000 Letter to client 0.2 35.00 665.00 12/20/2000 Letter to Attorney Getz 0.2 35.00 700.00 12/22/2000 Letter to client 0.5 87.50 787.50 12/28/2000 Telephone conference with client 0.2 35.00 822.50 12/28/2000 Telephone conference with Attorney Getz 0.2 35.00 857.50 12/28/2000 Letter to Attorney Getz 0.2 35.00 892.50 o l/16/200 I Receipt and Review Letter Attorney Getz 0.3 52.50 945.00 01/22/2001 Letter to Attorney Getz 0.2 35.00 980.00 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 0.00 32.32 35.91 34.19 2,310.37 $2,412.79 TERMS: NET 30 DAYS: 1.5% PER MONTH SERVICE CHARGE ON UNPAID BALANCE AFTER 30 DAYS. (18% APR). VISA AND MASTERCARD ARE ACCEPTED. Page 1 Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 INVOICE I DATE I 3/1112005 I TO: Jerry Cantor 3802 Harness Lane Camp Hill, PA 17011 AMOUNT DUE $2,412.79 DATE DESCRIPTION HOURS AMOUNT BALANCE 01131/2001 !NV #FC 1030. Finance Charge 7.37 987.37 02/09/200 I Receipt and review letter from atty Getz 0.2 35.00 1,022.37 02/12/2001 letter to client 0.2 35.00 1,057.37 02/20/2001 Telephone conference with client 0.2 35.00 1,092.37 02/21/2001 Letter to Atty. Getz 0.4 70.00 1,162.37 02/28/2001 !NV #FC 1081. Finance Charge 16.00 1,178.37 03/31/2001 !NV #FC 1185. Finance Charge 15.37 1,193.74 04/06/200 I PMT -1,178.37 15.37 04/18/200 I 4.18.01. letter to AttyGetz 0.2 35.00 50.37 05/07/200 I 5.7.01. receipt and review ofletter from Atty Getz 0.2 35.00 85.37 05/1 0/200 I PMT #186. -50.37 35.00 05/1112001 5.11.01. letter to client 0.2 35.00 70.00 05/111200 1 5.11.01. preparation of Motion for Arbitration 0.2 35.00 105.00 05/16/2001 5.16.01. telephone confemce with client 0.1 17.50 122.50 OS/22/200 I 5.22.01. consultation with client 0.5 87.50 210.00 06/0 lI200 I Cantor I 15.00 225.00 06/041200 I 6.4.01. preparation of Praecipe for Refemce to 0.2 35.00 260.00 Arbitration 06/04/200 I 6.4.01. letter to Prothonotary 0.2 35.00 295.00 06/06/200 I 6.6.01. receipt and review letter from Atty Getz 0.2 35.00 330.00 06/06/200 I 6.6.01. receipt and review of praecipe for reference 0.1 17.50 347.50 to arbitration from court 06/07/200 I 6.7.01. letter to client 0.2 35.00 382.50 07/3l1200 I INV #FC 1393. Finance Charge 6.23 388.73 08/22/200 I 8.22.01. letter to client 0.2 35.00 423.73 08/3l12001 !NV #FC 1466. Finance Charge 5.99 429.72 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 0.00 32.32 35.91 34.19 2,310.37 $2,412.79 TERMS: NET 30 DAYS: 1.5% PER MONTH SERVICE CHARGE ON UNPAID BALANCE AFTER 30 DAYS. (18% APR). VISA AND MASTERCARD ARE ACCEPTED. Page 2 . Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, P A 17011 INVOICE I DATE I 311112005 I TO: Jerry Cantor 3802 Harness Lane Camp Hill, PA 17011 AMOUNT DUE $2,412.79 DATE DESCRIPTION HOURS AMOUNT BALANCE 09/24/2001 9.24.01. consultation with client 1 175.00 604.72 09/25/2001 9.25.01. letter to client 0.2 35.00 639.72 09/25/2001 9.25.01. preparation of questionaire 0.8 140.00 779.72 09/27/2001 PMT #102. -388.73 390.99 10/10/2001 10.10.01. prepare file and exhibits for 10.10.01. 0.5 87.50 478.49 hearing 10/10/2001 10.10.0I.attend arbiralion 3 525.00 1,003.49 10112/2001 10.12.01. receipt and review of arbitrator's award 0.2 35.00 1,038.49 10/12/2001 10.12.01. lettter to client 0.2 35.00 1,073.49 10/22/2001 10.22.01. telephone conf. with client 0.2 35.00 1,108.49 10/30/2001 10.30.01. office discussion with client 0.1 17.50 1,125.99 10/30/2001 10.30.01 letter to Ally Getz 0.2 35.00 1,160.99 10/31/2001 INV #FC 1567. Finance Charge 1.22 1,162.21 11/01/2001 11.1.01. telephone conf. with Ally Getz 0.2 35.00 1,197.21 11/02/2001 11.2.01. receipt and review 11.1.01. letter from 0.2 35.00 1,232.21 Ally Getz 11/02/2001 11.2.01. letter to client 0.2 35.00 1,267.21 11/07/2001 11.7.01. telephone conf. with Ally Getz 0.2 35.00 1,302.21 11/28/2001 11.28.01. receipt and review letter from Ally Getz 0.2 35.00 1,337.21 11/29/2001 11.29.01. letterto client 0.2 35.00 1,372.21 11/30/2001 INV #FC 1617. Finance Charge 5.79 1,378.00 12/31/2001 !NV #FC 1672. Finance Charge 17.90 1,395.90 01/31/2002 !NV #FC 1725. Finance Charge 21.41 1,417.31 02/28/2002 !NV #FC 1784. Finance Charge 19.24 1,436.55 03/31/2002 !NV #FC 1842. Finance Charge 22.03 1,458.58 04/30/2002 !NV #FC 1896. Finance Charge 21.28 1,479.86 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 0.00 32.32 35.91 34.19 2,310.37 $2,412.79 TERMS: NET 30 DAYS: 1.5% PER MONTH SERVICE CHARGE ON UNPAID BALANCE AFTER 30 DAYS. (18% APR). VISA AND MASTERCARD ARE ACCEPTED. Page 3 . Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 INVOICE I DATE I 311 112005 I TO: Jerry Cantor 3802 Harness Lane Camp Hill, P A 17011 AMOUNT DUE $2,412.79 DATE DESCRIPTION HOURS AMOUNT BALANCE 06/30/2002 !NV #FC 1948. Finance Charge 44.47 1,524.33 07/31/2002 !NY #FC 2006. Finance Charge 23.38 1,547.71 08/31/2002 !NY #FC 2065. Finance Charge 23.74 1,571.45 10/31/2002 !NV #FC 2120. Finance Charge 47.22 1,618.67 11/30/2002 !NV #FC 2174. Finance Charge 23.28 1,641.95 12/31/2002 !NV #FC 2233. Finance Charge 25.18 1,667.13 01/31/2003 !NV #FC 2296. Finance Charge 25.56 1,692.69 03/31/2003 !NV #FC 2351. Finance Charge 49.26 1,741.95 04/30/2003 !NV #FC 2407. Finance Charge 25.07 1,767.02 05/31/2003 !NV #FC 2454. Finance Charge 27.08 1,794.10 06/30/2003 !NV #FC 2508. Finance Charge 26.17 1,820.27 07/31/2003 !NV #FC 2556. Finance Charge 27.89 1,848.16 08/31/2003 !NV #FC 2609. Finance Charge 28.32 1,876.48 09/30/2003 !NY #FC 2665. Finance Charge 27.37 1,903.85 10/31/2003 !NY #FC 2722. Finance Charge 29.17 1,933.02 11/30/2003 !NV #FC 2778. Finance Charge 28.19 1,961.21 12/31/2003 !NY #FC 2826. Finance Charge 30.05 1,991.26 01/31/2004 !NY #FC 2878. Finance Charge 30.51 2,021.77 02/29/2004 !NY #FC 2933. Finance Charge 28.49 2,050.26 03/31/2004 !NY #FC 2988. Finance Charge 31.42 2,081.68 04/30/2004 !NV #FC 3037. Finance Charge 30.35 2,112.03 05/31/2004 !NY #FC 3084. Finance Charge 32.36 2,144.39 06/30/2004 !NV #FC 3132. Finance Charge 31.26 2,175.65 07/31/2004 !NY #FC 3180. Finance Charge 33.33 2,208.98 08/31/2004 !NY #FC 3227. Finance Charge 33.84 2,242.82 09/30/2004 !NY #FC 3279. Finance Charge 32.69 2.275.51 CURRENT 1.30 DAYS PAST 31.60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 0.00 32.32 35.91 34.19 2,310.37 $2,412.79 TERMS: NET 30 DAYS: 1.5% PER MONTH SERVICE CHARGE ON UNPAID BALANCE AFTER 30 DAYS. (18% APR). VISA AND MASTERCARD ARE ACCEPTED. Page 4 . . Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 INVOICE I DATE I 3/1112005 I TO: Jerry Cantor 3802 Harness Lane CampHill,PA 17011 AMOUNT DUE $2,412.79 DATE DESCRIPTION HOURS AMOUNT BALANCE 10/31/2004 INV #FC 3333. Finance Charge 34.86 2,310.37 12/31/2004 INV #FC 3435. Finance Charge 34.19 2,344.56 0l/31/2005 INV #FC 3488. Finance Charge 35.91 2,380.47 02/28/2005 INV #FC 3541. Finance Charge 32.32 2,412.79 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 0.00 32.32 35.91 34.19 2,310.37 $2,412.79 TERMS: NET 30 DAYS: 1.5% PER MONTH SERVICE CHARGE ON UNPAID BALANCE AFTER 30 DAYS. (18% APR). VISA AND MASTERCARD ARE ACCEPTED. Page 5 . EXHIBIT "B" PLAINTIFF'S CLIENT 3/1/05 BILL - 7 - . Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 170]] INVOICE I DATE 3/1/2005 1m Jerry Cantor 3802 Harness Lane CampHill,PA 17011 AMOUNT DUE $2,412.79 DATE DESCRIPTION HOURS AMOUNT BALANCE 01/3112005 Balance forward 2,380.47 02/28/2005 INV #FC 354 I. Finance Charge 32.32 2,412.79 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 32.32 35.91 34.19 0.00 2,310.37 $2,412.79 TEfu\1S: NET 30 DAYS: 1.5% PER MONTH SERVICE CHARGE ON UNPAID BALANCE AFTER 30 DA YS. (18% APR). VISA AND MASTERCARD ARE ACCEPTED. ~ 7O~. \f1 ~"t\:- \f-t _ I.r\ ~ \J ~ ~ :cJ ~~r lJl ~ r ;~,;'I () ('l ';__ .-r\ 18 / cP ......'::-:' ...~- (:"; ,-0 CASE NO: 2005-01368 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RADCLIFF DIANE G ESQUIRE VS CANTOR JERRY CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according t law, says, the within COMPLAINT & NOTICE CANTOR JERRY DEFENDANT was served upon the at 3802 HARNESS LANE , at 1224:00 HOURS, on the 21st day of March CAMP HILL, PA 17011 JERRY CANTOR by handing to a true and attested copy of COMPLAINT & NOTICE together wi h 2005 and at the same time directing His attention to the contents ther of. Sheriff's Costs: Docketing Service Postage Surcharge 18.00 8.88 .37 10.00 .00 37.25 Sworn and Subscribed to before ~.-"- this day of h( ~1tr So Answers: "..,.r<~~;'f~''';:''''tc. d~ f ....--"".;:::.,~... /' - R. Thomas Kline 03/22/2005 DIANE RADCLIFF I \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE G. RADClIFF, ESQUIRE, Plaintiff NO. 05-1368 Civil Term V. CIVIL ACTION - LAW JERRY CANTOR, Defendant STIPULATED JUDGMENT Plaintiff, Diane G. Radcliff, Esquire, and Defendant, Jerry Cantor, hereby stipulate and agree that judgment shall be entered in favor of Plaintiff and against Defendant in the amount of $2,505.54 and in accordance with the following terms: 2,4/J.79 1. The judgment amount is $2,505.54, which includes the following amounts and is hereinafter the "Judgment Amount": Principal Balance Claimed in Complaint $2,412.79 EiliAg r t't'> (Custs} $35.50 Sheriff's SCf,ice reo (Costs) $37.25 .J.l.Jelgl "t'IIl Amount SZ,SOS.S4 2. Defendant shall pay the Judgment Amount, together with interest thereon at the rate of one and one-half (1.5%) percent per month, and payable in monthly installments of two hundred ($200.00) applied first to interest, then to principal. Interest on said amount shall commence as of March 1, 2003. Payment of the $200.00 monthly payments shall commence on the 1st day of May, 2005, and shall be paid monthly thereafter on the 1st day of each month until the full judgment amount and any accrued interest is paid in full. 3. The foregoing notwithstanding, Defendant shall pay the then remaining Judgment Amount in full on January 21, 2006. 4. Defendant shall have the right to prepay all or any part of the Judgment Amount and interest accrued thereon at any time or from time to time without the payment of any premium or any penalties. ... 5. Defendant shall be in default if Defendant fails to make the payment due hereunder within five (5) days of its due date. In the event of said default, the entire principal balance and any accrued and unpaid interest shall become immediately due and payable; and Defendant shall be required to immediately pay said entire unpaid judgment amount together with interest thereon at the rate of one and one-half (1.5%) percent per month from the date of default until paid in full and further together with a stipulated amount of $500.00 for reasonable attorneys fees and costs incurred by Plaintiff in the collection of said remaining judgment amount and interest and such additional costs as may be incurred by Plaintiff in collecting said sum, not heretofore provided. Upon Plaintiff's filing of an Affidavit of Default, in addition to all remedies provided in law of equity, Plaintiff shall be entitled to execute on the Judgment. Further upon such default and filing of the Affidavit of Default, Defendant consents to the immediate execution upon the judgment, any inquisition and extension upon any levy on real estate are hereby waived and condemnation agreed to, and the exemption of personal property from levy and sale on any execution hereon is also herein expressly waived, and no benefit of exemption shall be claimed under or by virtue of any exemption laws now in force or which may hereafter be enacted, Defendant expressly ratifying and confirming all that Plaintiff may do by virtue hereof. The foregoing notwithstanding, no attorney's commission shall be payable nor execution on the judgment shall be permitted unless Defendant is in default of the payment of the sums due hereunder. 6. The terms of this Stipulation shall be entered as a judgment in favor of Plaintiff and against Defendant on the records in the Office of the Prothonotary in and for Cumberland County, the parties authorizing the Prothonotary to enter such judgment in accordance with the terms set forth herein. IN WITNESS WHEREOF, Plaintiff and Defendant, each intending to be legally bound hereby, have set their hands and seals the day and year first above written. ~ ;,3~ ~;, J UfJ,. ~ j PARTIES: /..DtA .RA L1FF, ESQ IRE Plaintiff c~ Y CANTOR, Defendant - 2 - c::> >- >: Cl ~~ rc_ <<::, ... ") t-..- '9 (:_~) l1J~{ C.)t~ ::::i: u--r- l~_ r-~ C8) 0 en (l"': <'-1 u..o.... 0':::: cr.!~ ~,; t-- I..r:> ;'_) lL c:=> C',) o ~ ~ ,~ T) -3 - ~~ C) -:J o 3='i cj ~-() ~ & 0- 0- ~U ~ ') r'-"") ') ';""'1 '.' \:::'" V'I 0 ~;X /0 Xv? ~ o~ C7~. ~~ (l /6 q){! ~ ~ 2:> d5- ~ J0 '< 0 0 x X ~. ~ ~~ 0- ~ Lk ~ \~ Vh '=::' ~ , <r:. , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE G. RADCLIFF, ESQUIRE, Plaintiff NO. 05-1368 Civil Term V. CIVIL ACTION - LAW JERRY CANTOR, Defendant PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment entered in the above referenced matter settled and satisfied. Respectfully submitted, . RA L1FF, ESQUIRE 3448 Trindl oad Camp Hill, PA 17011 Supreme Court I.D. No. 32112 (717) 737-0100 () ~ AA....:.:~ ""Uti:: mrr' z~_~" -;?' r ~;- ~~:: 4- L;.-. j;~'. >~: Z. ~-< ....., = = r:::r" ::I; > -< o " ~:D hi 339 0- ..;:.~C) 1: .r -:5" ~o om );! ~ N J:P :x a .. U1 \D