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Home My WebLink About06-2348 Johnson. Duffie, Stewart & Weidner By: David W. DeLuce 1.0. No. 41687 Elizabeth D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 dwd@jdsw.com Attorneys for Plaintiff HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHARITY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Ole - 231ft CiUl(T&...Vy\. CIVIL ACTION - LAW v. ROBERT AUGUSTIN, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de 105 pr6ximos veinte (20) dras despues de la notifrcaci6n de esta Demanda y Aviso radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamaci6n 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALlFICAN. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Johnson. Duffie, Stewart & Weidner By: David W. Deluce I.D. No. 41687 Elizabeth D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 lemoyne, Pennsylvania 17043-0109 (717) 761-4540 dwd@jdsw.com Attorneys for Plaintiff HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHARITY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O~ - ;nLfr C.iUlL '--r~flJ-Vl CIVil ACTION - LAW v. ROBERT AUGUSTIN, Defendant COMPLAINT AND NOW, comes the Plaintiff, Holy Spirit Hospital of the Sisters of Charity, by and through its counsel, Johnson, Duffie, Stewart & Weidner, and in support thereof avers as follows: 1. The Plaintiff, Holy Spirit Hospital of the Sisters of Charity (hereinafter "Hospital"). is a not-for-profit corporation with a principal place of business at 503 North 21st Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Robert Augustin, is an adult individual residing at 1298 Letchworth Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. This action arises out of two separate occurrences where the Defendant came to Hospital for medical services. 1 4. In the first instance, Defendant came to Hospital on October 16, 2003 to the emergency room. 5. On October 16, 2003, the Defendant received medical services from the Hospital for which he was billed in the amount of Four Thousand Four Hundred Fifty- Three ($4,453.00) Dollars. 6. From November 11 through November 12, 2005, Defendant was admitted to Hospital and received medical services there for which he was billed in the amount of Fourteen Thousand Eight Hundred Forty-Five Dollars and sixty-one cents ($14,845.61). 7. The bills for services rendered on October 16, 2003 and November 11-12, 2005 remain unpaid and total Nineteen Thousand Two Hundred Ninety-Eight Dollars and sixty-one cents ($19,298.61). (Copies of the aforesaid bills containing the medical services provided have been sent to the Defendant and are not attached hereto due to its personal content.) 8. Hospital has sent numerous letters and made numerous attempts to collect on these bills, and Defendant has failed and refused to pay them. COUNT 1- BREACH OF CONTRACT 9. The averments of Paragraphs 1 through 8 are incorporated herein by reference. 10. Hospital rendered Defendant medical services on October 16, 2003 and November 11-12, 2005 for which Defendant is obliged to make payment. 11. There was an implied contract between Hospital and Defendant, that Defendant would pay Hospital for its medical services provided. 12. Despite requests by Hospital to Defendant, no payment has been made by the Defendant to Hospital on account of either of these bills. 2 WHEREFORE. the Plaintiff, Holy Spirit Hospital of the Sisters of Charity, request this Honorable Court to award judgment against the Defendant in the amount of Nineteen Thousand Two Hundred Ninety-Eight Dollars and sixty-one cents ($19,298.61) plus interest, costs, and any other relief that the Court deems appropriate. COUNT 11- UNJUST ENRICHMENT 13. The averments of Paragraphs 1 through 12 are incorporated by reference herein. 14. Hospital provided medical services to the Defendant at Defendant's request on October 16, 2003 and November 11-12, 2005 for which it has not received compensation. 15. As such, the Defendant is unjustly enriched. WHEREFORE, Plaintiff, Holy Spirit Hospital of the Sisters of Charity, requests this Honorable Court to award judgment against Defendant in the amount of Nineteen Thousand Two Hundred Ninety-Eight Dollars and sixty-one cents ($19,298.61) plus interest, costs, and any other relief that the Court deems appropriate. Date: If?! /0 b avid W. Del Attorney I.D. No. 41687 Elizabeth D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 lemoyne, Pennsylvania 17043-0109 (717) 761-4540 dwd@jdsw.com eds@jdsw.com :273516 3 . ' VERIFICA TlON I, James Jones, Director of Patient Financial Services, for Holy Spirit Hospital of the Sisters of Charity, verify that I am authorized to make the statements herein and that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. !j4904 relating to unsworn falsification to authorities, HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHARITY By: J ctor of Patient Financial Services Dated: ~ /:Lv /2-0010 I I P <l... -p \ ."_. ~ (8 \t VI. Ul . VI. ....::t "'v V ~ ..t:.. ~ - ...i'l - w tA D +- r " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HOL Y SPIRIT HOSPITAL OF TIlE SISTERS OF CHARITY Plaintiff v. ROBERT AUGUSTIN Defendant No. 06-2348 Civil Term CNIL ACTION - LAW ANSWER TO COMPLAINT: 1. Admitted 2. Admitted 3. Admitted 4. Admitted 5. Admitted 6. Admitted 7. Admitted 8. Admitted and Denied. Defendant did not refuse to pay. Defendant was unable to pay due to inability to perform his work anywhere near the level of his pre-injury capability. During this latest period defendant has experienced extreme financial hardship. i.e. other crucial bills have also piled up, not just the hospital costs. Defendant has made sincere efforts to find help for his medical costs as suggested by the hospital's social service~ department. Unfortunately, the fact that the defendant owns real estate has disqualified him from availing himself of these -- ~ services. He has attempted, on his o~ to sell a property to help defray these expenses. 1614 Randolph has been listed since November 2005. An uncooperative tenant was evicted in the early spring of 2006 and the property continues to be actively advertised in the multi-list. Even this property has a mortgage, but there is certainly some equity there. Defendant has also been trying to refinance his own residence at 1298 Letchworth, but the delinquencies incurred during the recent ill health resulted in denial of this route for funds. Defendant has never been offered a payment plan. He would like to arrange to pay his debt over a period of time. COUNT I-BREACH OF CONTRACT 9. The avennents of Paragraphs 1 through 8 are incorporated herein by reference with exceptions noted in number 8. 10. Admitted and Denied. Defendant went to hospital for help. In both occurrences defendant checked himself out of hospital because help seemed to be slow and expensive in coming. In the latter occurrence the original medical problem (excruciating pain in upper right leg) was ignored or preempted by a battery of tests for other issues that ran up the bill inappropriately in the opinion of defendant. Some of these tests were repeated twice in the day and a half defendant was in hospital. The two CAT scans alone cost twice what they would have cost from another provider contacted by defendant earlier in the week. Defendant was offered a 15% discount due to the fact that he was ~ but this was for a cash payment in full. If defendant had been able to make a cash payment in full he would have had health insurance and this would be less of an issue. Defendant has been searching for affordable health insurance, but has been repeatedly denied due to previous health issues. In the most recent occurrence defendant was actually being prepped for an appendectomy, another unneeded, unnecessary, and expensive procedure that had nothing to do with the pain in his leg. It was at this point that defendant had had enough and left the hospital. 11. Admitted and Denied. The defendant agreed to an implied contract to treat his leg pain. The extensive departure from this focus without adequate consultation and discussion limited defendant's understanding and commitment to further broadening that contract, particularly when he was already concerned about the expense of treatment for the leg. 12. Admitted. Defendant did, however, request to work out a payment plan that would include installments over time. Defendant talked to three different women (does not know their names) regarding this request. WHEREFORE, the defendant requests a fair billing, only for appropriate services and would be willing to negotiate some sort of payment plan until he can sell or refinance enough property to meet this obligation. ., " properties UNJUST ENRICHMENT 13. The averments ofParagrapbs 1 through 12 are incorporated by reference herein with the qualifications stated by defendant. 14. Admitted and Denied. Hospital did not focus on immediate problem that brought defendant to hospital. To the extent that services went further afield than requested, defendant feels that costs became inflated beyond appropriate level. 15. Denied. The defendant's medical emergency was not adequately addressed. The defendant continues to suffer economic hardship, not unjust enrichment. As his health improves he intends to satisfy his debts to the best of his ability. WHEREFORE, Defendant requests additional time for negotiation of both amount and timing of payments to be made to Holy Spirit Hospital of the Sisters of Charity. Respectfully submitted, S-'-/Z.d6 ,./ // ~/4-/ L~~/' Robert G. Augustin Defendant , ~ . .' ~' ." ',"", (:. \ ~ .' j; i,,' ~ .< ~.. 'e ~ ' ;\ '.; 1,' o c: ;:~ t':: r-..;) = = 0.... ~ ~ nl ::0 r- -Om ;:9'0 ',,) ,1. ~j~ i--S:D :;:",0 Om ~ -< ?= ...lo"'- -< 1.0 ::::- :J: \9 ,J:- ,. HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHARITY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. ROBERT AUGUSTIN, : NO. 06-2348 Defendant PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Elizabeth D. Snover, Esquire, counsel for the Plaintiff 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 $19,298.61 plus interest and costs. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: David W. DeLuce, Esquire and Elizabeth D. Snover, Esquire WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By EI~ES~ Attorneys for Plaintiff ORDER OF COURT AND NOW, this day of , 2006, in consideration of the foregoing Petition, , Esquire and , Esquire and , Esquire are appointed Arbitrators in the above-captioned action as prayed for. BY THE COURT: J. o.> ' -.. CERTIFICATE OF SERVICE AND NOW, the Jf1!:y day of ~ ' 2006, the undersigned does hereby certify that she did this date serve a copy of the fcgegoing document upon the parties of record by causing same to be deposited in the United States Mail, first-class postage prepaid, in Lemoyne, Pennsylvania, addressed as follows: Mr. Robert Augustin 1298 Letchworth Road Camp Hill, PA 17011 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER BY~~ Elizab D. Snover 1.0. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 {717} 761-4540 eds@jdsw.com :277787 ~ ~ 1'-..) c:::) ~ ,~:.:) -1"1 7:J f\ c,:c t \) ~. .- C r'~) ""- ~ ~ -c~. ~ ~ r~'\? ~ ~ - ~ '-D' - . ' Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVil ACTION - LAW HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHARITY, v. ROBERT AUGUSTIN, : NO. 06-2348 Defendant PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Elizabeth D. Snover, Esquire, counsel for the Plaintiff 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 $19,298.61 plus interest and costs. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: David W. Deluce, Esquire and Elizabeth D. Snover, Esquire WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By El~ES~ Attorneys for Plaintiff ORDER OF COURT J; /// day of ~__ ,2006, in consideration of the foregoing Petition, ,ESqUi~fi..L.. '1i1~uire and , Esquire are appointed itrators in the above-captioned action as prayed for. >- ~ 1"--=--' LtJ ~.~~ (). ;'~:- \. ~t. LuLL ,~lU -if; '-'- o N '" ~) v, C:.':) = "" , ~ co U") ,",,'.- c;;:::;'; '. (3 ..... CERTIFICATE OF SERVICE AND NOW, the ~day of ~ ,2006, the undersigned does hereby certify that she did this date serve a copy of the tcgegOing document upon the parties of record by causing same to be deposited in the United States Mail, first-class postage prepaid, in Lemoyne, Pennsylvania, addressed as follows: Mr. Robert Augustin 1298 Letchworth Road Camp Hill, PA 17011 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: ~~ Elizab D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 eds@jdsw.com :2n787 ~.... r.> "1.9. ".., C-") 0 .;::::;:> - c;:> .on P, ?\ ~ s r.:.-::;..... :;;l (~,- ;; ~:::; (n~ \) , .,,):~:, ~ N - '.,"',l":\ ~ .: ~ , ' - ~:; "-!;;:. ~-:-; 4 f- - ' -;:('") -" "..-t\ ~ r:? .::~\ --, C> r-: - ~~ - u:, \l' - SHERIFF'S RETURN - REGULAR CASE NO: 2006-02348 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOLY SPIRIT HOSPITAL OF THE SI VS AUGUSTIN ROBERT SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon AUGUSTIN ROBERT the DEFENDANT , at 1901:00 HOURS, on the 3rd day of May , 2006 at 1298 LETCHWORTH ROAD CAMP HILL, PA 17011 by handing to ROBERT AUGUSTIN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: Cf... j j:,lI{ / b & 18.00 26.40 .39 10.00 .00 54.79 .~~4L-~ R. Thomas Kline 05/04/2006 JOHNSON DUFFIE STEWART WEIDNER A.D. Sworn and Subscribed to before By: me this day of /" Prothonotary hOLY 'Pf~)\ H07fJ1AL ~L-fVtL5)~t~5 dfc:rat;1'1 Plaintiff I f2-D 111' d A t-t 1l..1 ~ir 0') " Defendant In The ~rt {\f ("n....trlr~ii]~lt~ ef'Cumberland County, Pennsylvania No.Q.6..- ;:4 , ~ Civil Action - Law. Oath We do sol~mnly swear (or affirm) that we will support, obey and defend the Constitution bfthe United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ~(A.\cll \ Row ti l1f\Llco.y Law Firm ~~. l-hW ~ ' C~, (l\~ PA (10 I~ City, . Zip :l'/~"'t9.4 Award We, the undersigned arbitrators, having been duly appointed and swom (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) Law Firm I () l>> -' N((j-ki 71 Address Ca~ ,,,:>/X/A )/0/"7 City,. Zip =tt 1:J.535 MrAft{ {eLL M cc-bL \. . Name ~YMI~ KCtfl!;f O. Ma.~ Name M tl~ ." JJ~ pc., Law Firm tf330 CAJ1~ 11le. A.d'-c.n G:.."4/JfJ{, ~i VTOI/ 'if lI'1q~ e~Cl(tlL'<.tY\~~t~L~f,.~f: IJt.~i~~t/;7i(fr ]. r;-~~_DO,f}1f"f~f~ ~-~._- L_____ , J d I \ ~ lob . . I . Arbitr8.tor, dissents. (Insert name if applicable.) Date ofHearing: I 0/ Ir/176 Date of Award: L b ( JCI..! iJ/; Now, the ~ day of fr:tnbe.t' ,20 011, , at I :DA , L.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ ~q{) fY) By: hDL-Y , P,)2-) -( HO?fr\AL ~l-f~~5/~td5 dfd"at;t1 Plaintiff I j2..o \1-e,u A tA.1l.1 ~ l' 01 ... Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 6 b - ~ , ~ Civil Action - Law. Oath We do sol~mnly swear (or affinn) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we wiIl discharge the duties of our office with fidelity. ~ ~~.. l~W ~ · C~, l \ \u P A (1 Q I~ City, . Zip :t/d."'~4 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.) ~ld ~{JR Name (Chairman Law Firm I 0 l.N ~ N((rkl7-( Address Ca~\71'( PA J/017 City, ' Zip =It 1;),535 . Name <;~tcll \ AdlAI {1 lird-Cclif Law Firm ~0ItI'7 Karerl O. Ma.~ Name ~~7I:M~ Pc tf330 ~J~ 1!J:e.. A.d.c.u g;:f U/( I~p ,ryoJ I "if 1l1q~ (j'j.t;jM-'<fu~;f:it: ~b~~~~~~/~(ff j t ~ - 00 '''1~ f ~ J Y\ l' . 12 ) J () h 't lob . . ., I .' Arbitrator, dissents. (Insert name if applicable.) ~ DateofHearingjO II"t/tr6 · -f:!!io I V}J/ Date of Award: /D!}(:r.!iJ6 . Notice of Entry of Award Now, the ,qth day of fr.it>ber- ,20 0'" , at i :Da.. , ~.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. ~q{) 00 Arbitrators' compensation to be paid upon appeal: $ By: Deputy . ~ io: E"t1- Copi$ ~ ~~th D.&1~r~f(o.se tl i~ A ttt'(\ ~berte. ~ _0(., IO-~ d-D\L.f? poev-e 8 ~ Q J: =: " Q i:o n :1:' -of ooS. ~ ~~: \D :<c., )>c ""'0 ~Cl :x 0-- ~ - ~~ ... ~ 0 N )1 .. ,. , ": ""'1'\ .. (f{';~,' . .~ .. Johnson, Duffie, Stewart & Weidner By: David W. Deluce I.D. No. 41687 Elizabeth D. Snover 1.0. No. 200997 301 Market Street P. O. Box 109 lemoyne, Pennsylvania 17043-0109 (717) 761-4540 HOLY SPIRIT HOSPITAL OF THE SISTERS OF CHARITY, Attorneys for Plaintiff Holy Spirit Hospital of the Sisters of Christian Charity IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVil ACTION - LAW ROBERT AUGUSTIN, NO. 06-2348 Defendant PRAECIPE TO ENTER JUDGMENT AND NOW, this J../St day of November, 2006, no appeal having been taken from the Arbitrators' Award in the above captioned matter, enter judgment on the award reached by the Arbitrators on October 6, 2006 in favor of Plaintiff Holy Spirit Hospital of the Sisters of Christian Charity and against the Defendant. I}....-f.t€, ~~ o-P 1'1i/.I/~.J.oo-tl+ JOHNSON, DUFFIE, STEWART & WEIDNER By: l~ -. vfdi-~ Elizabe~ Snover, Esq. JUDGMENT AND NOW, this /0 +~ay of ~k..L . ,2006, judgment is entered as above requested in favor of Plaintiff Holy Spirit Hospital of the Sisters of Christian Charity and against Defendant Robert Augustin. CURTIS R. LONG, PRO HONOTARY .1 D8131::1ty By: .. CERTIFICA TE OF SERVICE AND NOW, this c2lJ f day of November, 2006, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Robert Augustin 1298 Letchworth Road Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER By: EI~e~~ 4 P ~ -() Ji.. , 0 t ~ C J.J -J -- () 'Q r F t- V, ~ ~ :D ~ t- ( - ~ Q. g cr- .~ ::r:-n ~ 01 G C"> :ss 0 : ':'1$ _r '.?olD ( ..... () "'~'. --- -\ c~ _ ~ C .... ::D Z. _ ~ :2 rv ~ t;. F' E- r j}