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Home My WebLink About05-5658 DANIEL L. and JENNIFER E. KOISHAL, husband and wife, Plaintiffs, v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 2005 -~IcSf' CIVIL TERM JOSEPH T. and KRISTY L. SCHWARZ, husband and wife, t/d/b/a L. S. JOSEPH PLUMBING, Defendants. CIVIL ACTION JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint, order 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 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, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 Americans with Disabilities Act of 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. DANIEL L. and JENNIFER E. KOISHAL, husband and wife, Plaintiffs, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2005 - S l..S P CIVIL TERM JOSEPH T. and KRISTY L. SCHWARZ, husband and wife, t/d/b/a L. S. JOSEPH PLUMBING, Defendants. CIVIL ACTION : JURY TRIAL DEMANDED COMPLAINT AND NOW, this 31 st day of October, 2005, come the Plaintiffs, DANIEL L. KOISHAL and JENNIFER E. KOISHAL, husband and wife, by and through their attorneys, Irwin & McKnight, and make the following Complaint against the Defendants, JOSEPH T. SCHWARZ and KRISTY L. SCHWARZ, husband and wife, t/dIb/a L. S. JOSEPH PLUMBING, averring as follows: 1. Plaintiffs are Daniel L. Koishal and Jennifer E. Koishal, husband and wife, adult individuals principally residing at 8 West Butler Street, Mount Holly, Pennsylvania, 17065. 2. Defendants are Joseph T. Schwarz and Kristy L. Schwarz, husband and wife, t/dlb/a L. S. Joseph Plumbing, principally residing and transacting business at 119 Hill Street, Mount Holly, Pennsylvania, 17065. 3. At all times relevant hereto, Defendants held themselves out to be in the business of Custom Bathroom Remodeling. 4. On or about March 7,2005, Plaintiffs received an initial estimate from Defendant, Joseph T. Schwarz, to completely remodel Plaintiffs' upstairs bathroom. A true and correct copy of the proposal from Defendant is attached hereto and incorporated herein as Exhibit "A." 5. As noted on Exhibit "A," one third of the contract price was due upon the Plaintiffs' signing of the contract, one third was due upon start of the work, and the balance was "due upon completion and customer satisfaction." 6. Prior to beginning the work, Defendant, Joseph T. Schwarz, promised that the project would take no longer than ten (10) days to complete. 7. Defendants began work on or about June 6, 2005. 8. From June 17, 2005, through August 7, 2005, Defendant, Joseph T. Schwarz failed to keep several promised completion dates 9. On or about June 19, 2005, Defendant, Joseph T. Schwarz communicated to Plaintiffs that he would have trouble completing the project due to a recent loss of employees. Plaintiffs and Defendants agreed that Plaintiff, Daniel L. Koishal, would assist Defendants in working on the project and could deduct his time from the final bill. 10. From the beginning of the project until August 7, 2005, Defendants and employees frequently failed to show up for work, often for days at a time. 11. The work Defendants did accomplish was of such poor quality that Plaintiffs have been forced to hire another contractor to finish the work which Defendants failed to complete. In 2 addition the new contractor will be required to repair much of the work which was performed improperly by the Defendants. COUNT I BREACH OF CONTRACT & WARRANTY 12. The averments of fact alleged in paragraphs one (I) through eleven (II) are made a part hereof and incorporated herein by reference. 13. Despite numerous promises to the contrary, the Defendants failed to deliver the remodeled upstairs bathroom which they had represented and promised to the Plaintiffs, thereby breaching their contract with the Plaintiffs. 14. Defendants, by and through its authorized agents and employees, continued to attempt to provide a fully remodeled upstairs bathroom for the Plaintiffs over several months from May 30, 2005, until August 7,2005. 15. The Defendants specifically breached their contract for the remodeling job which was not completed as promised, and the work that was done was of such poor quality that: A. Defendants failed to completely remove the original flooring and walls III order to ensure that the new flooring would be level. As a result, the new flooring and fixtures are not level; B. As a further result of the uneven floor, the trim work cannot be finished correctl y; C. Defendants failed to complete the siding work as agreed, causing Plaintiffs to pay for such work out of pocket; 3 D. Some of the fixtures which the Defendants ordered for the Plaintiffs were unusable as ordered, necessitating Plaintiffs to order replacement fixtures. The Defendants took the original fixtures back to the store for credit, but failed to reimburse the Plaintiffs for the new fixtures as orally agreed; E. The plumbing work installed by the Defendants vibrates and is generally below the standards of good workmanship; F. The electrical work was left unfinished, and the work that was accomplished falls below code; and G. Defendants failed to properly install or finish both the flooring and dry walling. 16. Defendants breached the contract with Plaintiffs by failing to complete the remodeling project in accordance with the parties' agreement. 17. Defendants breached their warranty by not providing to Plaintiffs a remodeled upstairs bathroom anywhere close to customer satisfaction. 18. Defendants expressly and through implication warranted that they were well qualified to remodel an upstairs bathroom and would complete the job with workmanlike quality. 19. Defendants breached the contract and their warranty by not finishing the remodeling project and by failing to provide workmanlike quality. 20. Despite numerous opportunities, Defendants have been either unable or unwilling to repair the defective workmanship and finish the project. 4 21. Despite repeated demands, Defendants have refused and continue to refuse to refund Plaintiffs the money paid by them as part of the contract. The Defendants have also failed to pay the Plaintiffs for their costs of repair and completion of the work due to Defendants' breach of contract. 22. As a result of Defendant's breach, Plaintiffs will be forced to hire another contractor to repair the defective work and finish the remodeling. 23. As a result of Defendants' breach of contract and breach of warranty and in order to fix Defendants' defective workmanship, Plaintiffs will incur replacement and cover costs in excess of the sums paid to Defendants. WHEREFORE, Plaintiffs respectfully request that this Court award damages against the Defendants in an amount less than the arbitration amount of Thirty-Five Thousand and no/lOO ($35,000.00) Dollars, together with reasonable attorney fees, costs and interest as permitted hy law and such other and further relief as this Court shall deem fair, just, and proper. COUNT II UNJUST ENRICHMENT 24. The averments of fact alleged in items one (I) through twenty-three (23) are made a part hereof and incorporated herein by reference. 25. Plaintiffs have conferred benefits on Defendants by payment of their checks on March 7, 2005 and June 10,2005. 26. Defendants have received and acknowledged receipt of payment by Plaintiffs. 5 27. Defendants have not performed satisfactory services to justify the value of the benefit which they received from Plaintiffs. 28. It is and continues to be inequitable for Defendant to retain the payment by Plaintiffs without satisfactorily completing the upstairs bathroom remodeling project as contracted by the parties. WHEREFORE, Plaintiffs respectfully request that this Court award damages against the Defendants in an amount less than the arbitration amount of Thirty-Five Thousand and no/lOO ($35,000.00) Dollars, together with reasonable attorney fees, costs and interest as permitted by law and such other and further relief as this Court shall deem fair, just, and proper. COUNT III VIOLATION OF THE PENNSYL VANIA UNFAIR TRADE PRACTICES AND CONSUMER PROTECTION LAW 29. The averments of fact alleged in items one (I) through twenty-eight (28) are made a part hereof and incorporated herein by reference. 30. In agreeing to the contract with Defendant, Plaintiffs relied upon the assurances by Defendants and their employees that they were qualified to completely remodel a bathroom and would do so in a workmanlike manner. 31. Defendants and employees further assured Plaintiffs that the work would be completed within a reasonable period of time. 6 32. Defendants and employees further assured Plaintiffs that the work would be done to their satisfaction. 33. Plaintiffs relied upon the promises, assertions and representations of Defendants agents and employees as inducement to agree to allow Defendant to perform the remodling work. 34. The misrepresentations by Defendant's agents and (~mployees are in direct violation of SS 20l-2(4)(vii), 20l-2(4)(x), 20l-2(4)(xiv) and 20l-2(4)(xxi) of the Pennsylvania Unfair Trade Practices and Consumer Protection Law. 35. Under S 20l-9.2(a) of the Pennsylvania Unfair Trade Practices and Consumer Protection Law, "[t]he court may, in its discretion, award up to three times the actual damages sustained [...]." 36. Furthermore, the court "may provide such additional relief as it deems just and proper." S 20l-9.2(a). 37. Also under S 20l-9.2(a), "[t]he court may award to the plaintiff, in addition to other relief provided in this section, costs and reasonable attorney fees." WHEREFORE, Plaintiffs respectfully request that this Court award damages against the Defendants in an amount less than the arbitration amount of Thirty-Five Thousand and no/lOO ($35,000.00) Dollars, together with treble damages and reasonable attorney fees against the Defendant, and such other and further relief as this Court shall deem fair, just, and proper. 7 By: Dated: October 31 st, 2005 Respectfully Submitted, Matthew A. Mc t, Esquire Supreme Court. . #:93010 Marcus A. 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VERIFICATION The foregoing document is based upon information which has been gathered by our counsel and ourselves in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. , , 0- ~I 'A j'~)/ij,o. NN ER E. KOISHAL Date: October _, 2005 CERTIFICATE OF SERVICE 1 the undersigned hereby certify that on this 31st day of October, 2005, a copy of the Complaint was served by first-class, postage prepaid United States mail in Carlisle, Pennsylvania upon the following: Albert Nicholas Peterlin, Esquire Attorney for Defendant GATES, HALBRUNER & HATCH, P.c. 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 IRWIN & McKNIGHT 'Matthew A. M ght, Esquire Supreme Court J.D. No: 93010 60 West Pomfret Street Carlisle, P A 17013 (717) 249-2353 Attorneys for Plaintiffs, Daniel & Jennifer Koisha1 -kl. lf1 Ul (Jl - l>-J C> \\1~ E (:> 7'J J".. \:t. ~ ,--..., .'~...C'\ .u ,.. SHERIFF'S RETURN - REGULAR CASE NO: 2005-05658 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KOISHAL DANIEL L ET AL VS SCHWARZ JOSEPH T ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SCHWARZ JOSEPH T the DEFENDANT , at 1450:00 HOURS, on the 14th day of November, 2005 at 119 HILL STREET MT HOLLY SPRINGS, PA 17065 by handing to KRISTY SCHWARZ, WIFE 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 Postage Surcharge So Answers: 18.00 5.76 .37 10.00 .00 34.13 ,/F~'~2c~'~ ,,"o.j ~ A ~ ../~._." .. .'" "', _/ --,~-r R. Thomas Kline . 11/15/2005 MARCUS MCKNIGH Sworn and Subscribed to before By: .~ Deputy Sheriff me this of A.D. ry / . SHERIFF'S RETURN - REGULAR CASE NO: 2005-05658 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KOISHAL DANIEL L ET AL VS SCHWARZ JOSEPH T ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SCHWARZ KRISTY L the DEFENDANT at 1450:00 HOURS, on the 14th day of November, 2005 at 119 HILL STREET MT HOLLY SPRINGS, PA 17065 by handin9 to KRISTY SCHWARZ a true and attested copy of COMPLAINT & NOTICE t0gether with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ,~~ 1"'''' ",' R. Thomas Kline .," <<:.-;;."'~':<.~ 11/15/2005 MARCUS MCKNIGH Sworn and Subscribed to before By: me this ;(,;z.. ,L day of ~ dM~AD ? . ? ~tary /I , SHERIFF'S RETURN - REGULAR CASE NO: 2005-05658 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KOISHAL DANIEL L ET AL VS SCHWARZ JOSEPH T ET AL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SCHWARZ KRISTY L TDBA L S JOSEPH PLUMBING the DEFENDANT at 1450:00 HOURS, on the 14th day of November, 2005 at 119 HILL STREET MT HOLLY SPRINGS, PA 17065 by handinq to KRISTY SCHWARZ 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 So Answers: 6.00 .00 .00 10.00 .00 16.00 ,-""~.' , 'I R. Thomas Kline 11/15/2005 MARCUS MCKNIGHT Sworn and Subscribed to before By: me this ,,?.2N"'i.. day of 7U~. A.D. DANIEL L. and JENNIFER E. KOISHAL, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2005-5658 CIVIL TERM JOSEPH T. and KRlSTY L. SCHWARZ, husband and wife, tJdlb/a L.S. JOSEPH PLUMBING. Defendants : CIVIL ACTION : JURY TRIAL DEMANDED PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Matthew A. McKnight and Marcus A. McKnight, III, counsel for Plaintiffs, Daniel L. Koishal and Jennifer E. Koishal, in the above action respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is less than $35,000.00 3. The counterclaim of the Defendant in the action is $0.00. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: Sean M. Shultz, Esquire, Matthew A. McKnight, Esquire and Marcus A. McKnight, III, Esquire. Respectfully submitted, IRWIN & McKNIGHT Dated: )j; J /O~ ~. Attorney LD. #93010 Marcus A. McKnight, III, Esquire Attorney LD. #25476 60 West Pomfret Street Carlisle, P A 17013 (717) 249-2353 Attorney for Plaintiffs, Daniel L. Koishal and Jennifer E. Koishal, husband and wife . ' CERTIFICATE OF SERVICE -Jl I, the undersigned hereby certify that on this 11.: day of May, 2006, a copy of the Petition for Appointment of Arbitrators was served by first-class, postage prepaid United States mail in Carlisle, Pennsylvania upon the following: Sean M. Shultz, Esquire KNIGHT & ASSOCIATES, P.C 11 Roadway Drive, Suite B Carlisle, PA 17013 IRWIN & McKNIGHT at A. McKnight, Esquire upreme Court J.D. No: 93010 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for the Plaintiffs, Daniel L. Koishal and Jennifer E. Koishal ,~ '- ~ '-J Lv \':l(\ tJ ~ 0\ "'J ~ ~ I ~ , "- ~ (") ~ <- -:-l ..., 1'1'; c: . ZLi;l ;7f-: cr~) -~ r;:: " 'J> ,~(~~, ): roO -..,< Z -..a -~: ,....., = C::;:. 0"' ::lr :>>- -< o "T1 ~:n :o~. .J,], . o ::;J ;fl 7') ""1 ::.,,,0 CStn :-1 ?O -< ...., " :x "-> .. &'" 0'\ ~-_.... . . . DANIEL L. and JENNIFER E. KOISHAL, husband and wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2005-5658 CIVIL TERM JOSEPH T. and KRISTY L. SCHWARZ, husband and wife, t/dIb/a L.S. JOSEPH PLUMBING. Defendants : CIVIL ACTION : JURY TRIAL DEMANDED ORDER OF COURT AND NOW, this ISU- day of ~ ,2006, in consideration of the foregoing Petition, jY\().h~ ~ 12. 1V\c ~ and (b.~ ~~~ ) ~ ~ointed arbitrators in the above-captioned ~~tion. BY~1~ , J. >- ~ UjO UZ rr:C; 1..1.... ~r 0'" 2:,0 ::1& cr:UJ iE 15 C) N ;;c a.. CO >- ""I: ;;C "" = = <--I if ~~ {J';\~ -~ . "" ~~ >- ..... .~~~ -' :~( :}.;;,~ So::? iJ~ 5 u DANIEL L. and JENNIFER E. KOISHAL, husband and wife, In The Court of Common Pleas of Cumberland Plaintiffs JOSEPH T. and KRISTY L. SCHWARZ, husband and wife~ t/d/b/a L.S. JOSEPH PLUM~ING Defendants County, Pennsylvania NOf005 _ 5658 CIVIL TERM Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution States and the Constitution of onwea1th and that we will discharge the duties 0 ~-If~ Signature Marlin R. McCaleb P. Kutulakis D. Koch Name (Chairman) Law Offices - Marlin R. McCaleb Law Firm TIN: 23-2393754 219 East Main Street Address &im4 ~1L.,L.9. Law Firm Name rJJ::,~ &-w tJ1; {t?j> 36 South Hanover Street Address 28 South Pitt Street Address Mechanicsburg, PA 17055 City, Zip Carlisle, PA 17013 Carlisle, PA 17013 City, Zip City, Zip 1It /60.2:L Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) fA :::: ::;:;: ~ ::;;~~~~;:;,~// ~~.jf #j/C,CfCj #I /dl f/1 Date of Hearing: ~.L'J- ti"6 Date of Award: ~ ft:J - '6 . Arbitrator, dissents. (Insert name if applicable.) Now, the .l;;;~ day of ~..l..d , 20 () (., , at "I.' Ii, P.M., the above award was entered upon the docket and notice ther f gIven by maIl to the parties or theIr attorneys. Arbi~tors' compensation to be paid upon appeal: $ dl.. r p. U!J rothonotary By: Deputy , ~~~~~~ p~g:I , _~ ~ f,)3..-Ul- ~ 7>>. ~. r;. M~ t27n<~ZJ!~ ~ o C :f= i=,'. "-) g (J <::;-. "Tl :::.- --I c ::r G:, n'i :!" ~ ,~;~",,: :31: ,. ___<n ~:-. -2:) rf1 ~ co ~ ;;2~ :;i " 'lo. DANIEL L. KOISHAL and JENNIFER E. KOISHAL, Husband and Wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2005-5658 CIVIL TERM JOSEPH T. SCHWARZ and KRISTY L. SCHWARZ, Husband and Wife, tJdlb/a L.S. JOSEPH PLUMBING, Defendants. CIVIL ACTION - LAW. PRAECIPE TO ENTER JUDGMENT AND ASSESS DAMAGES To Curtis R. Long, Prothonotary: Kindly enter judgment in favor of the Plaintiff and against the Defendant on the attached Report and A ward of Arbitrators dated ~lv~ 22, 2006, rendered following a hearing and no timely appeals having been filed. . fl(J; Please assess judgment in favor of Plaintiff as follows: Amount of Judgment Post Judgment Interest $4,295.00 / $ 42.95 TOTAL $4,249.00 IRWIN & McKNIGHT Date: November 3,2006 ~~ Matthe . cKnight, Esquire Supreme Court I.D. No. 93010 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED ON THE JUDGMENT AS INDICATED. Date: /f - j-(!~ ~ ~ 2 ~u OTHONOTARY , \~ ~ < " CERTIFICATE OF SERVICE I, Matthew A. McKnight, Esquire, do hereby certify that I have served a true and correct copy of the Praecipe to Enter Judgment and Assess Damages upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Sean M. Shultz, Esq. Knight & Associates P.C. 11 Roadway Dr., Suite B Carlisle, P A 17013-8806 Date: November 3,2006 IRWIN & McKNIGHT dU~ · Maithew A. McKnight, Esquire Supreme Court ID. No. 93010 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Plaintiff 2 ~. .. DANIEL L. and JENNIFER E. KOISHAL, husband and wife, In The Court of Cornmon Pleas of Cumberland PlaintiffS JOSEPH T. and KRISTY L. SCHWARZ, husband and wifeL t/d/b/a L.S. JOSEPH PLUMtlING Defendants County, Pennsylvania Nofo05 - 5658 CIVIL TERM Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution States and the Constitution of~onwealth and that we will discharge the duties 0 0 d:;P~ ~ . Si_ Si ~ D. Koch Marlin R. McCaleb Name (Chairman) Law Offices - Marlin R. McCaleb Law Finn TIN: 23-2393754 219 East Main Street Address ~ ~ IL4wkb-s. L, t... 9: Law Firm Name -r{IJ. rp (-/(l^f $ (t'j? Ilaw Fmn 36 South Hanover Street Address 28 South Pitt Street Address Me~anicsburg, PA 17055 City, Zip Carlisle, PA 17013 . Carlisle, PA 17013 City, Zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affIrmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) f~:;~ ;A'if:J~"~~~itl1jt;-:// ~~-If Date of Hearing: zr.- ,,0- tl6 Date of Award: ~ ft? - ,6 Now, the .J.;J ~( day of ~A.u...l' , 20 () (,. , at 4j.' IS, P.M., the above award was entered upon the docket and notice there~f given by mail to the parties or their attorneys. A.rbitr~tors' compensation to be paid upon appeal: $ d. Cj tJ . t."i ;/,~"\ I q// . ,; l_/?l)/'f,/ . l---e/~ By: ( ..../- rJrothonotary Deputy ~ -- <;><\ ~\ ~ ~- ~ '?- "J ~ ~ c::J ~ c-. 0- (") c ~~:. r-' g cr' -r,' o ........ \ (.;J <;f; .-\ :::1.:-1'1 p'\ r::: -~~. <.(,Q -^~~\~~\ i~::~~l brtl ~\ .J" a. ~ ::;::: :::- c:> -1