HomeMy WebLinkAbout14-4406 r�
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Supreme Couy►r`nodPennsylvania
COui'» OIr;l,oinmon leas For Prothonotary Use Only:
,.
C01 Cove Sheet
�, ;��--• '-� Docket No:
Cumberland" County (u(,'TeM
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S DX Complaint 0 Writ of Summons Petition
0 Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiffs Name: Lead Defendant's Name:
T Consumer Product Distributors Inc. d/b/a/J. Polep Distrib. Express Mart, Inc.d/b/a S&S Mart Partners
I Are money damages requested? 'X Yes No Dollar Amount Requested: Elwithin arbitration limits
(check one) Doutside arbitration limits
N Is this a Class Action Suit? 0 Yes [D No Is this an MDJAppeal? [3 Yes El No
A Name of Plaintiff/Appellant's Attorney: Rebecca L.Trela, Esq.;Wilson, Elser, Moskowitz, Edelman&Dicker LLP
0 Check here if you have no attorney(are a Self-Represented 111'ro Sel Litigant)
Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim,check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
0 Intentional 0 Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution 0 Debt Collection:Credit Card 0 Board of Assessment
0 Motor Vehicle Debt Collection:Other Board of Elections
0 Nuisance Account Stated Dept.of Transportation
0 Premises Liability g Statutory Appeal:Other
S 0 Product Liability(does not include
M_ Employment Dispute:
E mass tort)
C El 0 0 Slander/Libel/Defamation Discrimination
Other: Employment Dispute:Other Zoning Board
T 0 Other:
I 0 Other:
O MASS TORT
0 Asbestos
N 0 Tobacco
0 Toxic"fort-DES
0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste
0 Other: 0 Ejectment 0 Common Law/Statutory Arbitration
B 0 Eminent Domain/Condemnation 0 Declaratory Judgment
0 Ground Rent 0 Mandamus
0 Landlord/Tenant Dispute Non-Domestic Relations
0 Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 0 Quo Warranto
0 Dental 0 Partition 0 Replevin
0 Legal 0 Quiet Title 0 Other:
0 Medical 0 Other:
0 Other Professional:
Updated 1/7/2071
r� 1
CONSUMER PRODUCT
DISTRIBUTORS, INC. :
D/B/A J. POLEP DISTRIBUTION
SERVICES :
705 Meadow Street,
Chicopee, Massachusetts,
Plaintiff
CUMBERLAND COUNTY
V. COURT OF COMMON PLEAS
EXPRESS MART, INC. d/b/a S & S MART CIV. ACTION--LAW
PARTNERS
302 N York Street No. 44L*
Mechanicsburg, Pennsylvania 17055
e-y C= .
and •Qa
rn ca
C= rr-
rn
� rM .,r*s
INDERJIT SINGH CA aco
:
201 Carriage Blvd.
Pittsburgh, Pennsylvania 15239, ;
: —� 1'-
_
Defendants.
NOTICE TO DEFEND
NOTICE AVISO
You have been sued in court. If you wish to defend against the claims Le ban demandado a usted en•la corte. Si usted quiere defenderse de
set forth in the following pages, you must take action within (20)days estas demandas expuest6is en las paginas siguientes, usted tiene viente
after this complaint and notice are served, by entering a written (20)dias de plazo al partir de la fecha de la demanda y la notificaci6n.
appearance personally or by attorney and filing in writing with the court Hace falta asentar una comparaesencia escrita o en persona o con un
your defenses or objections to the claims set forth against you. You are abogado y entregar a la corte en forma escrita sus defensas o sus
warned that if you fail to do so,the case may proceed without you and a objectiones a las demandas en contra de su persona. Sea avisado que si
judgment may be entered against you by the court without further notice usted no se fefiende, la corte tomard medidas y puede continuar la
for any money claimed in the complaint or for any other claim or relief demanda en contra suya sin previo aviso o notificacibn. AdemAs,la corte
requested by the plaintiff. You may Lose money or property or other puede decidir a favor del demandante y requiere que usted cumpla con
rights important to you. todas las provisioner de esta demanda. Usted puede perder dinero o sus
propiedades u otros derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE
FIND OUT WHERE YOU CAN GET LEGAL HELP. DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA
CUMBERLAND COUNTY BAR ASSOCIATION ESCRITA ABAJO PARA AVERIGUAR DODE SE PUEDE
32 BEDFORD STREET CONSEGUIR ASISTENCIA LEGAL.
CARLISLE,PENNSYLVANIA
CUMBERLAND COUNTY BAR ASSOCIATION
717-249-3166 32 BEDFORD STREET
CARLISLE,PENNSYLVANIA0
717-249-3166 !13.75 AD
309087
874064v.2
WILSON,ELSER,MOSKOWITZ,
EDELMAN& DICKER,LLP
Kenneth L. .Racowski,Esquire(I.D.No. 90514)
Rebecca L. Trela, Esquire(I.D.No. 313555)
The Curtis Center, Suite l 130 East
Independence Square West
Philadelphia, PA 19106 Attorneys for Plaintiff
Phone: 215.627.6900 J. Polep Distribution Services
CONSUMER PRODUCT
DISTRIBUTORS, INC.
D/B/A J. POLEP DISTRIBUTION CUMBERLAND COUNTY
SERVICES COURT OF COMMON PLEAS
Plaintiff
CIV. ACTION--LAW
V.
No.
EXPRESS MART, INC. d/b/a S & S MART
PARTNERS
and
INDERJIT SINGH,
Defendants.
Consumer Product Distributors, Inc. d/b/a J. Polep Distribution Services hereby files the
enclosed Complaint against Defendants Express Mart, Inc. d/b/a S & S Mart Partners and Inderjit
Singh, and avers as follows:
1. Plaintiff Consumer Product Distributors,. Inc. d/b/a J. Polep Distribution Services
("J. Polep" or "Plaintiff') is a business corporation organized and existing under the laws of the
Commonwealth of Massachusetts, with a place of business at 705 Meadow Street, Chicopee,
Massachusetts, 0 10 13.
2. J. Polep sells and distributes beverages, candy products, snack products and other
goods to convenience-type stores and gas stations in Pennsylvania, among other places.
3. J. Polep is an authorized dealer and wholesaler of tobacco products and candy,
confections, snacks, toiletries, and other "convenience-store" type products (hereinafter
874064v.2
collectively referred to as the "Products") and regularly engaged in the sale and distribution of
such Products.
4. Upon information and belief, Defendant.Express Mart, Inc. d/b/a S & S Mart
Partners (hereinafter "Express Mart") is a business:corporation organized and existing under the
laws of the Commonwealth of Pennsylvania with a place of business at 302 N York Street,
Mechanicsburg, Pennsylvania 17055.
5. Upon information and belief, Defendant Inderjit Singh ("Singh") is a resident of
the Commonwealth of Pennsylvania and resides at 201 Carriage Blvd., Pittsburgh, Pennsylvania
15239.
6. Upon information and belief, Singh is the Chief Executive Officer and/or owner
of Express Mart.
7. Upon information and belief, at all times relevant, Express Mart regularly
engaged in the purchase and sale of the Products from J. Polep.
JURISDICTION AND VENUE
8. . This Court has jurisdiction over Defendant Express Mart pursuant to 42 Pa.
C.S.A. § 5301(a)(3)(i) because Express Mart is a business corporation organized and existing
under the laws of the Commonwealth of Pennsylvania.
9. This Court has jurisdiction over Defendant Singh pursuant to 42 Pa. C.S.A. §
5301(a)(1)(ii) because Singh is domiciled within this Commonwealth.
10. Venue is appropriate in this Court pursuant to Pa. R. Civ. P. 2179(a)(1) because
Express Mart's registered office is within Cumberland County and pursuant to Pa. R. Civ. P.
1006(a)(1) because a transaction or occurrence took place in Cumberland County out of which
Plaintiff's causes of action arose.
2
874064v.2
COUNT I—BREACH OF CONTRACT
11. J. Polep repeats and realleges each and every allegation set forth in paragraphs
"1"through"11" as if fully set forth herein.
12. On December 11, 2013, Singh, on behalf of Express Mart, executed a "Credit
Application, Security Agreement & Personal Guarantee" (the "Agreement") (a copy of which is
attached hereto and incorporated herein as Exhibit"A").
13. The Agreement and the invoices from J. Polep set forth the terms of the business
relationship between J. Polep and Express Mart, and provided that Express Mart could purchase
Products from J. Polep on credit.
14. The terms of the Agreement were mutually agreed to by the parties, and are
supported by good and valuable consideration.
15. The Agreement is a valid, binding and enforceable contract between J. Polep and
Express Mart.
16. J. Polep has fully performed all of its obligations under the Agreement.
17. On or about December 19, 2013, Express Mart ordered certain Products from
J. Polep for the total price of Five Thousand Eight Hundred Thirty Two and 00/100 ($5,832.00)
Dollars (a copy of the account statement reflecting such purchase is attached hereto and
incorporated herein as Exhibit"B").
18. J. Polep delivered said Products to Express Mart, and invoiced Express Mart for
such Products.
19. Express Mart has not objected to the Products delivered.
3
874064v.2
20. On or about December 26, 2013, Express Mart ordered Products from J. Polep for
the total price of Five Thousand Twenty and 10/100 ($5,020.10) Dollars (see Exhibit"B").
21. J. Polep delivered said Products to Express Mart, and invoiced Express Mart for
such Products.
22. Express Mart has not objected to the Products delivered.
23. Thereafter, on or about January 2, 2014, Express Mart ordered additional Products
from J. Polep for the total price of Three Thousand Five Hundred Thirty Seven and 34/100
($3,537.34) Dollars (see Exhibit `B").
24. J. Polep delivered said Products to Express Mart, and invoiced Express Mart for
such Products.
25. Express Mart has not objected to the Products delivered.
26. Lastly, on or about March 24, 2013, Express Mart was charged the total price of
One Hundred Twenty and 00/100 ($120.00) Dollars for totes that were not returned to J. Polep
(see Exhibit `B").
27. J. Polep delivered said Products to Express Mart, and invoiced Express Mart for
such Products.
28. Express Mart has not objected to the Products delivered.
29. Additionally, Express Mart submitted an electronic funds transfer for Products
previously delivered in the sum of Six Thousand Four Hundred Twenty-Nine and 04/100
($6,429.04) Dollars. However, Express Mart's payment did not clear and accordingly such sum
was added back to the account on December 27, 2013. Express Mart remedied a portion of the
4
874064v.2
invalid EBT submitting two payments against this returned EBT, one for Three Thousand
($3,000.00) Dollars on January 15, 2014 and another for Two Thousand Three Hundred
($2,300.00) Dollars on January 24, 2014. However, this left an outstanding balance on the return
of the sum One Thousand One Hundred Twenty-Nine and 04/100 ($1,129.04), which was billed
back to the account on December 27, 2013 (see Exhibit"B").
30. At this juncture, Express Mart has a total balance due and owing to J. Polep of
Fifteen Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars (see Exhibit`B").
31. Despite demands from J. Polep, Express Mart has failed to make payments for all
the Products delivered.
32. As a result, Express Mart is indebted to J. Polep in the amount of Fifteen
Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars.
33. In addition, pursuant to the express terms of the Agreement, Express Mart is also
obligated to pay to J. Polep a late penalty of 1.5% per month for the unpaid account balance (see
Exhibit"A").
34. Further, pursuant to the express terms of the Agreement, J. Polep is entitled to
recover from,Express Mart "collection costs and attorney's fees," and Plaintiff respectfully
requests judgment for this sum in an amount to be determined at trial (see Exhibit "A").
WHEREFORE, Plaintiff demands judgment against Defendants Express Mart, Inc. d/b/a
S & S Mart Partners and Inderjit Singh, as follows:
(i) Awarding Plaintiff damages in an amount to be determined, but no less than
Fifteen Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars;
(ii) Awarding interest and service fees at a rate of 1.5%per month (18% annually)
for the unpaid sums;
(iii) Awarding Plaintiff attorneys' fees, costs and disbursements of this action
pursuant to the agreement; and
5
874064v.2
(iv) Granting Plaintiff such other relief as the Court deems just and proper.
COUNT II—ACCOUNT STATED
35. J. Polep repeats, re-alleges and incorporates by reference each and every
allegation set forth in paragraphs "1"through "34" as if fully set forth herein.
36. Express Mart is indebted to J. Polep for the unpaid balance of the debt for the
Products. The unpaid balance due and owing to J. Polep is Fifteen Thousand Six Hundred Thirty
Eight and 48/100 ($15,638.48) Dollars.
37. J. Polep provided invoices and statements to Express Mart evidencing such
outstanding debt (see Exhibit"B").
38. Express Mart has not disputed said statements of account.
39. To date, Express Mart has failed to pay the amounts due, as stated in said account.
40. Accordingly, an account has been stated between J. Polep and Express Mart in the
amount of is Fifteen Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars, plus
service and interest charges, attorneys' fees, and collection costs.
WHEREFORE, Plaintiff demands judgment against Defendants Express Mart;Inc. d/b/a
S & S Mart Partners and Inderjit Singh, as follows:
(i) Awarding Plaintiff damages in an amount to be determined, but no less than
Fifteen Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars;
(ii) Awarding interest and service fees at a rate of 1.5%per month (18% annually) for
the unpaid sums;
(iii) Awarding Plaintiff attorneys' fees, costs and disbursements of this action
pursuant to the agreement; and
(iv) Granting Plaintiff such other relief as the Court deems just and proper.
6
874064v.2
COUNT III—UNJUST ENRICHMENT
41. J. Polep repeats, re-alleges and incorporates by reference each and every
allegation set forth in paragraphs "1"through"40" as if fully set forth herein.
42. In the event that it is judicially determined that no contractual relationship exists
between the parties, the truth of which is vehemently denied, then Express Mart has been
unjustly enriched by the receipt and use of the Products, to the detriment of J. Polep, to which no
corresponding benefit was given for its sale and supply of the Products to Express Mart.
43. Under the circumstances, it would be unjust and inequitable to allow Express
Mart to retain said benefits without making fair and reasonable restitution to J. Polep.
44. Accordingly, Plaintiff demands quantum meruit from Express Mart in the amount
of is Fifteen Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars, plus interest.
WHEREFORE, Plaintiff demands judgment against Defendants Express Mart, Inc. d/b/a
S & S Mart Partners and Inderjit Singh, as follows:
(i) Awarding Plaintiff damages in an amount to be determined, but no less than
Fifteen Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars;
(ii) Awarding interest and service fees ata rate of 1.5%per month (18% annually) for
the unpaid sums;
(iii) Awarding Plaintiff attorneys' fees, costs and disbursements of this action
pursuant to the agreement; and
(iv) Granting Plaintiff such other relief as the Courtdeems just and proper.
.COUNT IV—BREACH OF CONTRACT
45. J. Polep repeats and realleges each and every allegation set forth in paragraphs
"1"through "44" as if fully set forth herein.
7
874064v.2
46. In conjunction with the Agreement, Singh signed a "Personal Guaranty," (the
"Guarantee") on December 11, 2013, by which he agreed to be individually responsible for the
outstanding debt of Express Mart (see Exhibit"A").
47. By signing the Guarantee, Singh agreed to personally guarantee and answer for all
the debts of Express Mart owed to J. Polep. Additionally, Singh agreed under the Guarantee to
pay "any and all finance charges, cost of collection and reasonable attorneys' fees" incurred as a
result of Express Mart's non-payment (see Exhibit"A").
48. J. Polep has demanded that Singh pay the debts Express Mart owes to J. Polep.
49. Singh has refused to pay the debts Express Mart owes to J. Polep.
50. Accordingly, Singh has breached the Guarantee.
51. Accordingly, judgment should be entered against him, holding him personally
liable for all sums owed by Express Mart pursuant to the Agreement, in the amount of Fifteen
Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars, plus service and interest
charges, attorneys' fees, and collection costs.
WHEREFORE, Plaintiff demands judgment against Defendants Express Mart, Inc. d/b/a
S & S Mart Partners and Inderjit Singh, as follows:
(v) Awarding Plaintiff damages in an amount to be determined, but no less than
Fifteen Thousand Six Hundred Thirty Eight and 48/100 ($15,638.48) Dollars;
(vi) Awarding interest and service fees at a rate of 1.5% per month (18% annually)
for the unpaid sums;
(vii) Awarding Plaintiff attorneys' fees, costs and disbursements of this action
pursuant to the agreement; and.
(viii) Granting Plaintiff such other relief as the Court deems just and proper.
8
874064v.2
Respectfully Submitted,
WILSON,.ELSER,MOSKOWITZ,
EDELMAN & DICKER LLP
By:
Rebecca L. Trela, Esquire
Attorneys for Plaintiff
J. Polep Distribution Services
Dated: `2
9
874064v.2
VERIFICATION
I, Kathy Riess, hereby verify that I am authorized to make this Verification on
behalf of Plaintiff, Consumer Product Distributors, Inc. d/b/a J. Polep Distribution
Services, and that the facts set forth in the foregoing Complaint are true and correct to
the best of my knowledge, information and belief. I understand that this Verification is
made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification
to authorities.
Kat Ries
Dated: '7 j g f .
874064v.2
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND ��
, Tylcr
_Jr THE PROT!iCAOTIA0.
�
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93[�SEP i_ PN 3; k`o
CUMBERLAND COUNTY
PENNSYLVANIA
OFF oF THE,
Consumer Product Distributors, Inc. dibia J. Polep Distribution Servic
vs.
Express Mart Inc. d/b/a S&S Mart Partners (et al)
Case Number
2014-4406
SHERIFF'S RETURN OF SERVICE
07/2812014 SIeriff Ronny R Anderson, being duly sworn accordinginquiry
for the within named Defendant to wit: Inderjit Singh, but was unable to locate the Defendant in the
Sheriffs baNiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the
within Complaint & Notice according to Iaw.
08/05/2014 Sheriff Ronny R Andersonbeing duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Express Mart Inc. d/b/a S&S Mart Partners, but was unable to
locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint &
Notice aa"Not Served" ot3U2 N. York Street, Mechanicsburg Borough, Mechanicsburg, PA 17050.
Deputies were advised that Express Mart is under new ownership as ofApril 2014.
08/08/2014 11:53 AM - The requested Complaint & Notice served by the Sheriff of AlleghenyCounty upon Inderjit
Singh, personaily, at 201 Carriage Boulevard, Pittsburgh, PA 15239. William Mulien, Sheriff, Return of
Service attached to and made part of the within record.
SHERIFF COST: $84.79 SO ANSWERS,
September 08, 2014 RDNNYRANDERSON, SHERIFF
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
,0? C111146.,
.94,4
OFFICE OF THE SHERIFF
07
Richard W Stewart
Solicitor
Consumer Product Distributors, Inc. d/b/a J. Polep Distribution Se ic
vs.
Express Mart Inc. d/b/a S&S Mart Partners (et al.)
Case Number
2014-4406
SERVICE COVER SHEET
Service Details:
Category: Civi
Manner: Deputize
Notes:
Expires:
reo:
Name: :Inderjit Singh
imary (201 Carriage Boulevard
dress: Pittsburgh, PA 15239
201 CARRIAGE BOULE
Phone: 1 DOB:
Alternate
Address:
Phone:
i Attorney / Originea:
Name:
,Rebecca Trela
[Service Attempts:
Date:
Time:
Mileage:
Deputy:
08/27/2014
[Final Service:
Served:
Adult In
Charge:
Relation:
Date:
Deputy:
Phone:
Zone:
Warrant:
Personally • Adult In Charge • Posted • Other
Mileage
215-627-6900
i_Notes / Special Instructions:
ce Now,
execu
z
z
014-.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Eda Jean Woodward, Notary Public
City of PIVAsburgh, Allegheny County
My Commission Expires May 28, 2016
mEmBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to
ervj the documents herewith and make return thereof according to law.
Return To:
Cumberland County Sheriffs Office
One Courthouse Square
Carlisle, PA 17013
i<5CourityStrt* Sh&fi incleosaft.
Ronny R Anderson, Sheriff
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER, LLP
Kenneth L. Racowski, Esquire (I.D. No. 90514)
Rebecca L. Trela, Esquire (I.D. No. 313555)
The Curtis Center, Suite 1130 East
Independence Square West
Philadelphia, PA 19106
Phone: 215.627.6900
PROI HOND-
fit
20.11., NOV 26 PH 2: 25
CUMBERLAND COUNTY
PENNSYLVANIA
Attorneys for Plaintiff
I Polep Distribution Services
CONSUMER PRODUCT
DISTRIBUTORS, INC.
D/B/A J. POLEP DISTRIBUTION
SERVICES
Plaintiff
V.
EXPRESS MART, INC. d/b/a S & S MART :
PARTNERS
and
INDERJIT SINGH,
Defendants.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIV. ACTION-- LAW
No. 14-4406
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above -captioned matter SETTLED, DISCONTINUED and ENDED
upon agreement of all parties.
Dated: ((M --/f4
903418v.1
Respectfully Submitted,
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
By:
Rebecca L. Trela, Esquire
Attorneys for Plaintiff
I Polep Distribution Services
CERTIFICATE OF SERVICE
Rebecca L. Trela, Esquire, attorney for Plaintiff J. Polep Distribution Services hereby
certify that a true and correct copy of the Praecipe to Settle, Discontinue and End was served on
the following parties and/or counsel of record via First Class United States mail, postage prepaid
on the date set forth below.
Charles Gruenspan
Charles Gruenspan Co. LPA
601 Commerce Park Square Four
23240 Chagrin Boulevard
Cleveland, Ohio 44122
Inderjit Singh
201 Carriage Boulevard
Pittsburgh, Pennsylvania 15239
Rebecca L. Trela, Esquire
Dated: 1( /9 -41/4-
903418v.
(/9 -41/4-
903418v. I