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Home My WebLink About02-2452 IRVING L. ABRAMSON, ESQUIRE ATTORNEY I.D. NO. 29293 ONE HARFORD LANE RADNOR, PA 19087 (610) 964-7611 BRENDA BAILEY ATTORNEY FOR PLAINTIFF v. : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : CIVIL ACTION-LAW : NO. O~-~Ij~ Ci()~l't-~ : JURY TRIAL DEMANDED ANN L. HAWBAKER 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 and notice are served, by entering a written appearance personally or by an 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 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 A 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 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 IRVING L. ABRAMSON, ESQUIRE ATTORNEY I.D. #29293 ONE HARFORD LANE RADNOR, PA 19087 (610) 964-7611 BRENDA BAILEY ATTORNEY FOR PLAINTIFF v. : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : CIVIL ACTION-LAW NO. O~ - ,;('I~ C, 0; l ~~ JURY TRIAL DEMANdED ANN L. HAWBAKER COMPLAINT I. Plaintiff, Brenda Bailey, is an adult individual residing at 604 West Keller Street, Mechanicsburg, Pennsylvania. 2. Defendant, Ann L. Hawbaker, is an adult individual residing at 403 Pine Road, Mt. Holly Spings, Pennsylvania. 3. At all times material to this Complaint, the plaintiff, Brenda Bailey, was the owner/operator of a 1994 Ford Taurus vehicle bearing Pennsylvania registration No. MVY-797. 4. At all times material to this Complaint, the defendant, Ann L. Hawbaker, owned, possessed, controlled and/or leased a 1988 Plymouth Grand Voyager bearing Pennsylvania registration No. CDC-5220. 5. On or about July 5, 2002, at or about 7:20 p.m., the plaintiff, Brenda Bailey, was operating her motor vehicle in an easterly direction on West Simpson Street, at or near its intersection with South High Street, Mechanicsburg Borough, P A when the defendant, Ann L. Hawbaker, traveling in a northerly direction on South High Street, failed to stop for the stop sign at South High and West Simpson Streets, colliding directly into the plaintiff's vehicle, which had the right-of-way, violently striking same and forcing Plaintiff's vehicle into the path of another vehicle. 6. The defendant's negligence consisted more fully in the following: a) Failure to keep her motor vehicle under control; b) Failure to properly obey traffic signals and yield the right-of-way to others; c) Failure to keep a safe distance between plaintiff's car and defendant's car; d) Failure to keep a proper lookout; e) Failure to properly regard the rights and safety of plaintiff; f) Failure to obey highway signage and traffic conditions; specifically~ failure to yield to traffic where defendant was controlled by a stop light on 5' Street Highway; g) Violation of the pertinent provisions of the Pennsylvania Motor Vehicle Code. 7. Solely as a result of defendant's negligence as aforesaid, the plaintiff, Brenda Bailey, was caused to sustain serious and permanent injuries, including, but not limited to severe acute cervical strain and sprain with injury to myoligamentou5 structures, mild concussion, ecchymosis of the left lower leg, ecchymosis and abrasion of the right leg, right hip injury, neck/shoulder injury, exacerbation ofTMJ, post-traumatic stress syndrome, sort term memory loss and a shock to her nerves and nervous system, and injuries yet to be determined, and pain and suffering for all of which plaintiff has been caused to expend and will continue to be caused to expend large sums of money for medical treatment. 8. Plaintiff's earning capacity has been permanently diminished. 9. Plaintiff has sustained the loss oflife's pleasures. 10. Plaintiff elected the full tort option under her insurance coverage in effect at all times material to this Complaint. WHEREFORE, plaintiff demands judgment against defendant, Ann 1. Hawbaker, in an amount in excess of $50,000.00. ~ IR 1. ABRAMSON, ESQUIRE Attorn y for Plaintiff VERIFICATION Brenda Bailey hereby states that she is the Plaintiff in this matter and verifies that the statements made in the foregoing are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. ~,~). 6.alf B NDA BAILEY ~.. ;. " -c,. ~ '(.::) ~7i ~~~ ... ~D~ f' I 9 G ~ ff! tJ ~'f- '-.(, C> g N :?' :x -om ~ f11{rl -< ~t;~ ~~;;-, r::c:; ~ JS; () ""'0 )>c ~ -' '7, .j _.~ -n rrl~ ;'-1 ':J \ .;~ ,"..n ~_,)r"5 ,,';fn ~~ 35 -< -0 :J,;;. ::-? JJ '0 ... .. , ::;.. 8 SHERIFF'S RETURN - REGULAR CASE NO: 2002-02452 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BAILEY BRENDA VS HAWBAKER ANN L RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAWBAKER ANN L the DEFENDANT , at 1745:00 HOURS, on the 24th day of May at 403 PINE ROAD 2002 MT HOLLY SPRINGS, PA 17065 by handing to DAYN HAWBAKER, HUSBAND 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 Affidavit Surcharge So Answers: 18.00 4.14 .00 10.00 .00 32.14 r~ ~<~ R. Thomas Kline OS/28/2002 IRVING ABRAMSON Sworn and Subscribed to before By: ~,r7~/ Deputy Sherif V me this 3-<-<-l day of q,o... .J..m,J., A.D. C1A~ (J fn,;.h-<, ~ P othonotary F:\FILES\DA T AFILE\DONEGAL.D0C\207-pra.l/tde Created: 06/13/0201:48:47 PM Revised: 06/13/0201:51:31 PM 3050.207 BRENDA BAILEY, Plaintiff IN THE COURT OF C MMON PLEAS OF CUMBERLAND CO TY, PENNSYLVANIA v. ANN L. HAWBAKER, Defendant PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAM & OTTO on behalf of Defendant in the above matter. 'Jl~ By Thomas J. Willi , Es uire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Dated: June 13,2002 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorf Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by de ositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as foIl ws: Irving L. Abramson, Esquire 1 Harford Lane Radnor, PA 19087 MARTSON DEARDORFF WILLIAMS & OTTO By Tricia D. Eckenroad Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: June 13, 2002 (") C) 0 c: f'V '. $: C- \)(i:7 c.:: ~ 111 f~' 7",.... 2:;:;_, ." i-n z;:;: .- r-, (f)~.: .,,~ :';Jy r:;!Sc; , )(- :;jY, KL... ;t:loo (~ i!5 )> ::]: '--;;.oG ~O Orn ~ j;! ~ :tJ c.) -< F:\FILES\DAT AFILE\DONEGAL.DOC\207-ans.l/tde Created: 06/13/0201:48:47 PM Revised: 06/27/0203:34:51 PM 3050.207 BRENDA BAILEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-2452 CIVIL ACTION LAW ANN L. HAWBAKER, Defendant JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT AND NOW, comes the Defendant, Ann L. Hawbaker, by and through her attomyes, MARTSON DEARDORFF WILLIAMS & OTTO, and files this Answer in response to Plaintiffs Complaint as follows: 1. Admitted based on information received. 2. Admitted. 3. Admitted based on information received. 4. Admitted. 5-6. Denied pursuant to Pa. R.C.P. 1029 (e). 7 -10. Denied. After reasonable investigation, Defendant does not have any knowledge or information sufficient to form a belief as to Plaintiffs injuries, medical treatment, medications, hospitalization, or tort option either now or in the future. NEW MATTER 11. The averments of paragraphs 1 through 10 of this Answer are incorporated herein by reference. 12. Plaintiff s recovery is barred orreduced by the Pennsylvania Motor Vehide Financial Responsibility Law as amended. 13. Plaintiff or her representatives chose the limited tort option by signing a valid selection form. 14. Plaintiffs injuries do not involve death, serious impairment of bodily function or permanent disfigurement. WHEREFORE, Defendant demands judgment in her favor and dismissal of Plaintiffs Complaint with prejudice. MARTSON DEARDORFF WILLIAMS & OTTO \tv J.t ~ By Thomas J. W' r s, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: June 27, 2002 The foregoing Answer is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language ofthe document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correctto the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. VERIFICATION This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. aM/. ;(fbl~k Ann L. Hawbaker I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Answer was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: CERTIFICATE OF SERVICE Irving L. Abramson, Esquire 1 Harford Lane Radnor, PA 19087 MARTSON DEARDORFF WILLIAMS & OTTO aD. Eckenroad ast High Street Carlisle, P A 17013 (717) 243-3341 Dated: June 27, 2002 IRVING L. ABRAMSON, ESQUIRE ATTORNEY I.D. #29293 ONE HARFORD LANE RADNOR, P A 19087 (610) 964-7611 BRENDA BAILEY ATTORNEY FOR PLAINTIFF v. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION-LAW : NO. 02-2452 : JURY TRIAL DEMANDED ANN L. HAWBAKER PLAINTIFF'S REPLY TO NEW MATTER 11. No response is required. 12. Denied. This is a conclusion oflaw to which no response is required. 13. Denied. It is denied that the plaintiff chose or is bound by the limited tort option; on the contrary, as alleged in her Complaint, the plaintiff validly selected the full tort option. 14. Denied. This is a conclusion of law to which no response is required; by way of further response, it is specifically alleged that plaintiffs injuries involve serious impairment of bodily function and other serious injuries. WHEREFORE, Plaintiff demands judgment against the defendant as alleged in her Complaint. IRV G . ABRAMSON, ESQUIRE Attorney for Plaintiff VERIFICATION IRVING L ABRAMSON, ESQUIRE hereby states that he is the attorney representing the Plaintiff in this matter and verifies that the statements made in the foregoing are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. o S2 -o5~; l2.:[; 2[.- UJ;.. .-/'# .., st~ ;~ t~j >c: ~ -.. S N L_ -D 1-'- --, ::::3 \i'i (.J , 5J -~ 0 .~ ~2 C ~"'0 " -? '-::: -j ~I l) ," n \ \, c-- 2- '" 7- .--", ~2 4.:0 , (- ) r- C ~f: ';':;:..,. ; .-r, C-J -'>" --:' c;; ,- . r-, , p:: !._" Cf? ' , c. ~ ."-;>' .~, 2 ....,:, ,;'-4 c.:.> :< IN THE COURT OF COMMON PLEAS OF CU:MBERLAND COUNTY BAILEY Vs. () )~- :< LJj J.. NO.-9424~2 HAWBAKER CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.2:2 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 THOMAS J WILLIAMS, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 11/12/04 THOMAS J WILLIAMS, ESQUIRE 10 E HIGH ST ~~ CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3581 File #: M315765 By: Patti Martin IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BAILEY Vs. HAWBAKER No. 0,~2452 TO: IRVING ABRAMSON, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You hav43 twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 10/22/04 THOMAS J WILLIAMS, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES IgHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 By: Patti lllartin Enc(s): Copy of subpoena(s) Counsel return card File #: M315765 . . ADDENDUM TO SUBPOENA BAILEY Vs. No. 0.;(- ;~452 HAWBAKER CUSTODIAN OF RECORDS FOR: DR RAY DRUM ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX (~S AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREA1~ENT RENDERED TO: NAME: BRENDA BAILEY ADDRESS: 500 APPALACHIAN DR MECHANICSEmRG PA DATE OF BIRTH: 11/06/64 ANY AND ALL DENTAL RECORDS. CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN . COMPLETE .AND RETURN RECORDS ARE AITACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS PATIENT BILLING RECORDS / XRAYS have been destroyed X-RAYS Authorized signature for DR RAY DRUM Date CUMBERLAND M315765-01 *** SIGN AND .RETURN THIS PJ~GE *** , , ,.-'. c' c: ..-..;) 4:.:.:....> ~~ Cl -'h --' - t": II.!:"::::,;}, S (~-. : .., .,: C:J ('-,) .. r,.) (; ) . Ii . ~,. m THE COURT OF COMMON PLEAS OF CUlVlBERLAND COUNTY BAILEY Vs. NO. 022452 HAWBAKER CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.2:! AS a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 THOMAS J WILLIAMS, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s) . Date: 07/14/05 ~~ THOMAS J WILLIAMS, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL L,EGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 3350-3581 By: CollE.en Laird File #: M322769 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BAILEY Vs. HAWBAKER No. 022452 TO: IRVING ABRAMSON, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND TIlINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 06/22/05 THOMAS J WII..LIAMS, ESQUIRE 10 E HIGH s'r CARLISLE, ~~ 17013 ATTORNEY FOR DEFENDANT INQOIRIES SIElOOLD BE ADDRESSED TO: MEDICAL LEGM. REPRODUCTIONS, INC. 4940 DISST~~ STREET PHILADELPHIA, PA 19135 (215) 335-3581 By: Colleen Laird Enc(s): Copy of subpoena(s) Counsel return card File #: M322769 aJIoM)NWEl\LTIi OF PENNSYLVANIA axJNl'Y OF ClJMBE1UAND BAILEY Vs. Fi Ie No. 022452 HAWBAKER ~rnDICAL BILLING REQUESTED SUBPOENA TO PROCllX:E DOCU1ENTS 1:lR n; I NGS FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22 STATE FARM INS CO, PO BOX R, NEW CUMBER~m PA 17070 TO: ATTN: CLAIMS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doct.rnent!; OS~nlft'TACHED AnDENDu.M at MEDICAL LEGAL 1l.EPRODUCTIONS'(Aa~Pess~940 DISSTON ST. I PRILA" -px-----. You may deliver or mail legible copies of the doctrnents or produce things requested hi this subpoena, together with the certificate of carpliance, to the party making th;, request at the address listed above. You have the right to seek in advance the reasonablE cost of pre9aring the copies or producing the things sought. If you fail to produce the doctrnents or things required by this subpoena within t~enty (20) days after its servke, the party serving thin subpoena may seek a court orde;' o::rrpelling you to carply with it. n; I S SUBPOENA WAS N.AJoE : ADORESS : I SSUED AT 'THE REQUEST OF THE FOLLOf/ I NO PERSON: THOMAS J WILLIAMS, ESQ 10 li: pTr::~ q'j' LAKLL~~!, PA 17013 TELF.PH:lNE: SU'REt>E COJRT 10# ATTORNEY FOR: 215-335-3212 DEFENDANT BG: COJR,: /l~ - Prothoncltary!C ark, 1 .h rM. e... .J-:/ ~.J/ R-, L M322769-01 DATE:"J.J. "'.: Seal of Division :2 '7 ~/Y). ('" the t '--- ~ DePuty (Eff. 7/97) ADDENDUM TO SUBPOENA BAILEY Vs. No. 022452 HAWBAKER CUSTODIAN OF RECORDS FOR: STATE FARM INS CO COMPLETE COPY OF THE FIRST PARTY BENEFIT FILE, ~~ICAL BILLS, WAGE LOSS INFORMATION, MEDICAL REPORTS, FIRST PARTY BENEFIT PAYOUT SHEET AND DEC SHEET FOR CLAIM #38J388784. PERTAINING TO: NAME: BRENDA BAILEY ADDRESS: 604 W KELLER ST MECHANICS BURG PA DATE OF BIRTH: 11/06/64 SSAN: 177604517 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - '.. - - - - - - - - - - - - - RECORD CUSTODIAN . COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, iI~ormation and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS A V AILABLE: I hereby certi fy that. a thorough search has been made and that no record of the fOllcMing documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Authorized signature for STATE FARM INS CO Date CUMBERLAND M322769-01 *,u SIGN AND RETURN THIS PAGE *,u o c: ~ - "-' C7:::) =, c.n <--- C.:.: ,- o -n ...... :l:""""rl n,p -om ~::;~6 ,-~~ ;::) :"'";.rn :.~ ~.u -< ex> -0 ::a:.: t'-.J N N F:\FILESIDATAFlLElDonegaJ3050ICurrentI207\207.pra Created: 7/13105 8:30AM Revi5ed: 7/13105 8:30AM BRENDA BAILEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-2452 CIVIL ACTION LAW ANN L. HAWBAKER, Defendant JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above captioned case settled and discontinued and issue a certificate reflecting same. By Irvi e Abramson, Esquire One Harford Lane Radnor, PA 19087 (610) 964-7611 Attorneys for Plaintiff Date: i~4~ 6 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Irving L. Abramson, Esquire I Harford Lane Radnor, PA 19087 MARTS ON DEARDORFF WILLIAMS & OTTO . , f)~~ 'cia D. Ecke11Jroad en East High Street Carlisle, P A 17013 (717) 243-3341 Dated: August 10, 2005 (') ~ .e:~. .iJr~: n":I'- --y.., .t...__ -:;"1 ~-~~. ~(- ...--( } 'j:~ (~.~ Z' :;l. ~ = cJ' 2:: G") o -0 ::.e: t? ~ ;f,::n a~ "5..,., --:......, " ~ -" C5 ~ ~ r 0::>