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HomeMy WebLinkAbout05-4075 Lindsay Gingrich Maclay. ES<[1Iire Daley. Zucker & Gingrich. LLC 1029 Scenery Driye Harrisburg. PAt 7109 (7 t 7) 6574795 Imada\..(l d/.gla\\.coIl1 IN THE CQURT OF COMMON PLEAS QF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN S. JORDAN, Plaintiff v. CIVIL ACTION - CUSTODY DocketNo.2005- &(t17,!{ ~~ MARK D. JORDAN, Defendant (In Custody) 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 for Custody 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 Petition or for any other claim or relief requested by the Petitioner. You may lose money or property or other rights important to you. YQU SHQULD TAKE THIS PAPER TQ YQUR LAWYER AT ONCE. IF YQU DQ NOT HAVE A LAWYER QR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, Pennsylvania 17101 (717) 232-7536 NOTICIA Le han demando a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archiver en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas u puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualguir queja 0 a1ivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiendacles 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADQ IMMEDIATAMENTE. SI NO TIENE ABQGADO 0 SI NQ TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSQNAL 0 LLAME POR TELEFQNQ A LA QFICINA CUYA DIRECCION SE ENCUENTRA ESCRlTA ABAJO PARA AVERlGAUAR DONDE SE PUEDE CQNSEGUIR ASISTENCIA LEGAL. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburg, Pennsylvania 1710I (717) 232-7536 DALEY, ZUCKER & GINGRICH, LLC Attorneys for Plaintiff JN THE COURT OF COMMON PLEAS QF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN S. JQRDAN, Plaintiff v. CIVIL ACTIQN - CUSTODY Docket No, 2005 - Lj 075 c..~ v ,', - ,""..... MARK D. JORDAN, Defendant (In Custody) CQMPLAlNT FOR CUSTODY AND NOW, this ~day of ~!t;" , 2005, comes Plaintiff, Kathleen S. Jordan, by and through her attorneys, Daley, Zucker & Gingrich, LLC, and files the following Complaint for Custody, and in support thereof avers as follows: I. Plaintiff, Kathleen S. Jordan, is an adult individual who currently resides at 3 8na Lane, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred to as "Mother"). 2. Defendant, Mark D. Jordan, is an adult individual who currently resides at 2902 Chesterbrook Court, Apartment 208, Camp Hill, Cumberland County, Pennsylvania (hereinafter referred to as "Father"). 3. Plaintiff, Kathleen S. Jordan, is the natural mother of two (2) minor children, Kaitlyn Louise Jordan, whose date of birth is July 15, 1994 and Abigail Jo Jordan, whose date of birth is August 15, I997 (hereinafter collectively referred to as the "Children"). 4. Defendant, Mark D. Jordan, is the natural father of the Children. 5. The Children were not born out of wedlock. 6. The parties were married on September 25, I993 in Mechanicsburg, Cumberland County, Pennsylvania and subsequently separated on January I6, 2005. 7. Mother seeks to affirm and memorialize the Parties' custody agreement. As such, she requests that an Order be issued in the form attached hereto, memorializing and cementing the Parties' Stipulation and Agreement for Custody, as set forth in Paragraph I6, herein. 8. Mother's current address is 3 Sna Lane, Mechanicsburg, Cumberland County, Pennsylvania, where Mother has exercised shared legal and primary physical custody of the Children since the Parties' separation. 9. Father's current address is 2902 Chesterbrook Court, Apartment 208, Camp Hill, Cumberland County, Pennsylvania. Since the date of the Parties' separation, Father has continued to exercise shared legal custody of the Children and has exercised periods of partial custody of the Children as the Parties hereto have agreed. 10. The relationship of Plaintiff to the Children is that of natural mother. I I. The relationship of Defendant to the Children is that of natural father. 12. Mother has no information of any other custody proceeding concerning the Children pending in any court of this Commonwealth. 13. Mother does not know of a person, not a party to this proceeding, who has physical custody of the Children or claims to have physical custody or visitation rights with respect to the Children. 14. The best interest and permanent welfare of the Children will be served by granting the relief requested because: a. Plaintiff is the natural mother of the Children; b. Defendant is the natural father of the Children; c. Both Mother and Father have a warm, loving relationship with the Children; d. Both Mother and Father have, in the past, and will continue to provide a stable, loving home environment for the Children; e. Both Parties and the Children will benefit from memorializing and formalizing their Custody Stipulation and Agreement and from having their Agreement entered as a Court Order. 15. Each parent whose parental rights to the Children have not been terminated and the person(s) who has physical custody of the Children have been named as Parties to this action. There are no other persons who are known to have or claim to have a right to custody or visitation of the Children. 16. Both Father and Mother request that the following Custody Stipulation and Agreement be entered as a Court Order: a. The Parties shall have joint legal custody of the Children. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the lives' of their Children, including educational, medical, and religious decisions. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well- being, including, but not limited to, all decisions regarding their health, education and religion. The custodial parent shall inform the non-custodial parent immediately of all medical and dental appointments and problems pertaining to the Children. If the Children are sick and is unable to attend school or other planned activities, the parent then having custody will notifY the other parent as soon as practicably possible. Each parent shall notifY the other parent of any medical, dental, optical, counseling and other appointments of the Children with health care providers, sufficiently in advance thereof so that the other party can attend, if he or she so chooses. Pursuant to the terms ofPa.C.S. ~5309, each parent shall be entitled to equal access to all records and information pertaining to the Children, including, but not limited to, the Children's school, medical, dental, religious and other important records, the residence address of the Children and the other parent. As soon as practical after the receipt by a party, copies of the Children's school schedule, special events notifications, report cards, and similar items shall be provided to the other Party. To the extent one (1) parent has possession of any such records or information, that parent shall be required to share same, or copies thereof, with the other parent within such reasonable time as to make the records or information of reasonable use to the other parent. The custodial parent shall provide copies of the Children's report cards and other reasonable papers affecting the Children's education, medical condition or welfare. Notwithstanding that both parents shall share legal custody, non-major decisions involving the Children's day-to-clay living shall be made by the parent then having custody, consistent with the other provisions of this Stipulation. b. Physical custody of the Children, as that term is defined in the Custody Act, shall be primarily with Mother, subject to Father's periods of partial custody as the Parties and Children may agree. c. Transportation for custody purposes shall be divided by the Parties as equally as possible. In the event that there is no specific provision governing the custody exchange, above, the parent who is to receive custody at the time of the exchange is to provide for transportation from the residence of the other parent. At all times, the Children shall be secured in appropriate passenger restraints. No person transporting the Children shall consume alcoholic beverages prior to transporting the Children. No person transporting the Children shall be under the influence of any alcoholic beverages while transporting the Children. d. The holiday schedule shall be at such times as the Parties and the Children may agree. e, The summer vacation schedule shall he at such times as the Parties and the Children may agree. f In the event that either parent, during their respective scheduled periods of custody, would need to leave the Children for a period of at least two (2) hours with a non- family member, the custodial parent will first check with the non-custodial parent to ascertain if the non-custodial parent is available to watch the Children. In the event that neither parent is able to watch the Children, the custodial parent will then be responsible for obtaining the appropriate supervision for the Children. g. In the event that either Party is more than thirty (30) minutes late for a custody exchange, in the absence of a telephone call or other communication from the parent transporting the Children, the other Party may assume that the parent who is late has chosen not to exercise that period of custody, the period will be forfeited, and the other Party will be free to make other plans with the Children. h. To the extent possible, each party shall provide the other with at least forty- eight (48) hours advance notice of school, sporting, or other extracurricular activities. Both Parties shall agree to honor and participate in the activities that the Children wish to engage in. During the times that each of the parents have custody of the Children, they will make certain that the Children attend any previously-scheduled extracunicular activities. The Parties are directed to be supportive of the activities and will transport the Children to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the Children are able to participate in those events. Neither parent, however, shall commit the Children to any activity unless the Children definitely desire to attend that activity. Participation in activities which take place during the school year is contingent upon the Children maintaining passing grades in school. Neither parent shall commit the Children to activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If the Children are involved in an activity which occurs during both parents' periods of custody, both parents shall cooperate in providing transportation of the Children to the activity. However, the then-custodial parent shall not be required to take the Children to that activity if the custodial parent and Children are out of town during that activity, for a previously-scheduled vacation. In the event that the custodial parent is unable to deliver the Children to the particular activity, the parent who has custody of the Children at that time shall notifY the non-custodial parent, who shall be entitled to pick up and deliver the Children to the designated activity. The custodial parent shall make certain that the Children are ready for pick-up in time sufficient to enable the Children to timely attend the activity. Should the custodial parent elect not to take the Children to a defined activity period for two (2) times, then the non-custodial parent shall have the right to assume that he or she will be responsible for transporting the Children to that activity until appropriate transportation is provided. I. In the event that the Children are unable to attend school due to illness or school closings or delays due to weather, etc., it is the responsibility of the parent then having custody to arrange alternate care for that day and to notify the non-custodial parent of the Children's illness. J. In the event that either Party is planning to take the Children out of this Court's jurisdiction for an overnight trip, they must provide reasonable notice and contact information for the locations at which the Children will be staying. k. Both Parties are expected to use common sense in scheduling telephone caUs to talk to the Children. Both Parties and/or their spouses/significant others are hereby directed to refrain from preventing the parent who may be calling from talking to the Children, or preventing the Children from calling the other parent, provided that the phone calls are not excessively frequent nor too long in duration that they disrupt the Children's schedule, or interfere with the custodial parent's period of custody. 1. Each of the Parties and any third Party in the presence of the Children shall take all measures deemed advisable to foster a feeling of affection between the Children and the other Party. Neither Party shall do nor shall either parent permit any third person to do or say anything which may estrange the Children from the other parent, their spouse or relatives, or injure the Children's opinion of the other Party or which may hamper the free and natural development of the Children's love, affection and respect for the other parent. The Parties shall not use the Children to convey verbal messages to the other parent about the custody situation or changes in the custody schedule. m. In the event that a significant matter arises with respect to the medical care, education, or financial care of the Children such as a change in occupation, health insurance, educational expenses, or residence of a Party, those matters shall be discussed with the other Party before any change is made by either parent. n. Each Party shall confer with the other on all matters of importance relating to the Children's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the Children's education and social adjustments. Each Party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the Children and the custody situation. Each Party shall supply the name, address and phone numbers of any persons in whose care the Children will be in for a period in excess of seventy-two (72) hours, and for each person or entity which may provide daycare for the Children, excluding current daycare providers, relatives, or public school institutions. o. Emergency decisions regarding the Children shall be made by the parent then having custody. However, in the event of any emergency or serious illness of the Children at any time, any Party then having custody of the Children shall immediately communicate with the other Party by telephone or any other means practical, informing the other Party of the nature of the illness or emergency, so the other parent can become involved in the decision-making process as soon as practical. The term "serious illness" as used herein shall mean any disability which confines the Children to bed for a period in excess of seventy-two (72) hours and which places the Children under the direction of a licensed physician. p. The welfare and convenience of the Children shall be the pnme consideration of the Parties in any application of the provisions of this Stipulation and Agreement. Both parents are directed to listen carefully and consider the wishes of the Children in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. q. Neither Party shall drink to the point of intoxication when the Children are in their custody. r. The Parties are free to modify the terms of this Stipulation and Agreement, but in order to do so, the Parties must be in complete agreement to any new terms. s. The Parties agree to cooperate with one another in an effort to foster a loving, meaningful relationship between the Children and each parent. t. Any major, long-term modifications of this Stipulation and Agreement need to be in writing, agreed to by both Parties, and executed with the same formalities as this Stipulation. Minor, short-term changes can be made orally, if agreed upon by both Parties. In the event that either Party is not in agreement with a proposed change, this Stipulation and Agreement will control the custodial arrangement until such time as the Parties are able to agree. u. This Stipulation, Agreement and/or Order shall supercede all prevIous custody Agreements and/or Orders. v. In the event that either Party breaches any provision of this Order, he or she shall be responsible for any and all costs incurred to enforce the Order, including, but not limited to, court cost and counsel fees of the other Party. In the event of breach, the other Party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order in the form attached hereto, thereby confirming the parties' Stipulation and Agreement for Custody. Respectfully Submitted, DALEY, ZUCKER & GINGRICH, LLC By: Attorneys for Plaintiff VERIFICATION AND CONFIRMATION OF STIPULATION/AGREEMENT We, KATHLEEN S. JORDAN, and MARK D. JORDAN, hereby verify that the facts set forth in this Complaint and Stipulation and Agreement are true and correct to the best of our respective knowledge, information and belief We understand that false statements herein are made subject to the penalties of 18 PaC.SA ~ 4904, relating to unsworn falsification to authorities. Furthermore, by the voluntary execution of this Confirmation, we do each unequivocally express our mutual consent that the terms as outlined in the Custody Stipulation and Agreement, above, are being entered into freely and voluntarily and we therefore request that the amicable custody arrangement, as set forth in said Stipulation, be entered as an Order of Court in the form attached hereto, without the necessity of a Custody Conciliation, Hearing or other formal proceeding. Date: ~ / g /05 I I Date: p /2-/2- oat' 0h-!J.~ Mark D. Jords( Defendant ').'ht~1J ;{II"'~ 1), ~( .1"1. ,~ ~ ~ --J w ~ '- '-. '- ~ '0 ....... ' <<>-- ~ {~ ~ ' , ~~~ ~ '- y:. t....... C'1' \ ,p C') ,,'f l~ :;. ,'... -1. -------- C)' RECEIVED AUG 10 Z005l Lindsay Gingrich Maclay. Esquire Daley. Zucker & Gingrich. LLC 1029 Scenery Dri,-e Harrisburg. P A 17109 (7171 657-t795 Imaday.adzgla\\.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN S. JORDAN, Plaintiff v. CIVIL ACTION - CUSTODY Docket No. 2005 - .y't:> /5' ~ MARK D. JORDAN, Defendant (In Custody) ORDER OF COURT AND NOW, this --llti- day of ~ .....U 2005, upon presentation and consideration of the within Complaint and the Stipulation and Agreement incorporated therein, and upon agreement of the parties, it is hc~eby ORDERED and DECREED as follows: I) The Parties shall have joint legal custody of the Children. Joint legal custody means the right of both parents to control and to share in making decisions of importance in the lives of their Children, including educational, medical, and religious decisions. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well- being, including, but not limited to, all decisions regarding their health, education and religion. The custodial parent shall inform the non-custodial parent immediately of all medical and dental appointments and problems pertB~ning to the Children. If the Children are sick and are unable to attend school or other planned activities, the parent then having -y custody will notify the other parent as soon as practicably possible. Each parent shall notify the other parent of any medical, dental, optical, counseling and other appointments of the Children with health care providers, sufficiently in advance thereof so that the other Party can attend, ifhe or she so chooses. Pursuant to the terms ofPa.C.S. ~5309, each parent shall be entitled to equal access to all records and information pertaining to the Children, including, but not limited to, the Children's school, medical, dental, religious and other important records, the residence address of the Children and the other parent. As soon as practical after the receipt by a party, copies of the Children's school schedule, special events notifications, report cards, and similar items shall be provided to the other PaIty. To the extent one (I) parent has possession of any such records or information, that parent shall be required to share same, or copies thereof, with the other parent within such r,easonable time as to make the records or information of reasonable use to the other parent. The custodial parent shall provide copies of the Children's report cards and other reasonable papers affecting the Children's education, medical condition or welfare. Notwithstanding that both parents shall share legal custody, non-major decisions involving the Children's day-to-day living shall be m:we by the parent then having custody, consistent with the other provisions of this Stipulation. 2) Physical custody of the Children, as tihat term is defined in the Custody Act, shall be primarily with Mother, subject to Father's periods of partial custody as the Parties and Children may agree. 3) Transportation for custody purpOsel; shall be divided by the Parties as equally as possible. In the event that there is no specific provision governing the custody exchange, above, the parent who is to receive custody at the time of the exchange is to provide for transportation from the residence of the other parent. At all times, the Children shall be secured in appropriate passenger restraints. No person transporting the Children shall consume alcoholic beverages prior to tran!~porting the Children. No person transporting the Children shall be under the influence of any alcoholic beverages while transporting the Children. 4) The holiday schednle shall be at such times as the Parties and the Children may agree. S) The summer vacation schedule shall be at such times as the Parties and the Children may agree. 6) In the event that either parent, during their respective scheduled periods of custody, would need to leave the Children for a period of at least two (2) hours with a non- family member, the custodial parent will first che:ck with the non-custodial parent to ascertain if the non-custodial parent is available to watch the Children. In the event that neither parent is able to watch the Children, the custodial parent will then be responsible for obtaining and paying for the appropriate supervision for the Children. 7) In the event that either Party is mor,e than thirty (30) minutes late for a custody exchange, in the absence of a telephone call or other communication from the parent transporting the Children, the other Party may assume that the parent who is late has chosen not to exercise that period of custody, the period will be forfeited, and the other Party will be free to make other plans with the Childrcm. 8) To the extent possible, each Party shall provide the other with at least forty- eight (48) hours advance notice of school, sporting, or other extracurricular activities. Both Parties shall agree to honor and participate in the activities that the Children wish to engage in. During the times that each parent has custody of the Children, they will make certain that the Children attend any previously-scheduled extracurricular activities. The Parties are directed to be supportive of the activities and will transport the Children to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the Children are able to participate ill those events. Neither parent, however, shall commit the Children to any activity unless the Children definitely desires to attend that activity. Participation in activities which take place during the school year is contingent upon the Children maintaining passing grades in schoo!. Neither parent shall commit the Children to activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If the Children are involved in an activity which occurs during both parents' periods of custody, both parents shall coope:rate in providing transportation of the Children to the activity. However, the then-custodial parent shall not be required to take the Children to that activity if the custodial parent and Children are out of town during that activity, for a previously-scheduled vacation. In the event that the custodial parent is unable to deliver the Children to the particular activity, the parent who has custody of the: Children at that time shall notify the non-custodial parent, who shall be entitled to pick up and deliver the Children to the designated activity. The custodial parent shall make certain that the Children are ready for pick-up in time sufficient to enable the Children to timely attend the activity. Should the custodial parent elect not to take th,e Children to a defined activity period for two (2) times, then the non-custodial parent shall have the right to assume that he or she will be responsible for transporting the Childrerl to that activity until appropriate transportation is provided. 9) In the event that any of the Children are unable to attend school due to illness or school closings or delays due to weather, etc., it is the responsibility of the parent then having custody to arrange alternate care for tlllllt day and to notify the non-custodial parent of the Children's illness. 10) In the event that either Party is plamting to take the Children out of this Court's jurisdiction for an overnight trip, they must provide reasonable notice and contact information for the locations at which the Children will be staying. 11) Both Parties are expected to use common sense in scheduling telephone caDs to talk to the Child. Both Parties and/or their spouses/significant others are hereby directed to refrain from preventing the parent who may be calling from talking to the Children, or preventing the Children from calling the, other parent, provided that the phone calls are not excessively frequent nor too long in duration that they disrupt the Children's schedule, or interfere with the custodial parent's period of custody. 12) Each of the Parties and any third Party in the presence of the Children shall take all measures deemed advisable to foster a feelilng of affection between the Children and the other Party. Neither Party shall do nor shalll:ither parent permit any third person to do or say anything which may estrange the Children from the other parent, their spouse or relatives, or injure the Children's opinion of the othe:r Party or which may hamper the free and natural development of the Children's love, affection and respect for the other parent. The Parties shall not use the Children to conv€:y verbal messages to the other parent about the custody situation or changes in the custody schedule. 13) In the event that a significant matter arises with respect to the medical care, education, or financial care of the Children such as a change in occupation, health insurance, educational expenses, or residence of a P:IIrty, those matters shall be discussed with the other Party before any change is made by either parent. 14) Each Party shall confer with the other on all matters of importance relating to the Children's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the Children's education and social adjustments. Each Party agrees to keep the other informed of his or hlrr residence and telephone number to facilitate communication concerning the welfare of the Children and the custody situation. Each party shall supply the name, address and phone numbers of any persons in whose care the Children will be in for a period in excess of seventy-two (72) hours, and for each person or entity which may provide daycare for the Children, excluding current daycare providers, relatives, or public school institutions. 15) Emergency decisions regarding the Children shall be made by the parent then having custody. However, in the event of any emergency or serious illness of the Children at any time, any party then having custody of the Children shall immediately communicate with the other party by telephone or any other means practical, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision-making process as soon as practical. The term "serious illness" as used herein shllill mean any disability which confines any of the Children to bed for a period in excess of seventy-two (72) hours and which places the Children under the direction of a licensed physician. 16) The welfare and convenience of the Children shall be the prime consideration of the Parties in any application of tile provisions of this Stipulation and Agreement. Both parents are directed to listen carefully and consider the wishes of the Children in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. 17) Neither party shall drink to the point of intoxication when the Children are in their custody. 18) The Parties are free to modify the tenns of this Stipulation and Agreement, but in order to do so, the parties must be in complete ~igfeement to any new terms. 19) The Parties agree to cooperate with one another in an effort to foster a loving, meaningful relationship between the Children and each parent. 20) Any major, long-term modificatiolls of this Stipulation and Agreement need to be in writing, agreed to by both Parties, and executed with the same formalities as this Stipulation. Minor, short-term changes can be made orally, if agreed upon by both Parties. In the event that either Party is not in agreement with a proposed change, this Stipulation and Agreement will control the custodial arrangement until such time as the parties are able to agree. 21) This Stipulation, Agreement and/or Order supercedes all previous custody Agreements and/or Orders. 22) In the event that either Party breaches any provision of this Order, he or she shall be responsible for any and all costs incurred to enforce the Order, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shal1 have the right, at his or her election; to S1lJe for damages for S1lJch breach or to seek such other and additional remedies as may be ava~lable to him or her. BY THE COURT, -1MJ~cJA ,1. ~c? (, b \iiNV/\"J,Si\t.~?d 1 'NIl,!'--, '1;./'l,;''':''''ii/\Ir''If'\ t\.i.. '1.....',./ ;) l,',1,,-:,;,"'H IV 2 I :2 Hd II ~nv SOUZ Al:lVIONOHlOfJd 31{l :lO 3::llJ3Q-CJ31!::l