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Home My WebLink About94-02583 / ~ ~ ...... . ... d . . , JOHNNY D. VICKIE L. and wife, GILBERT AND GILBERT, husband PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-2583 CIVIL MICHAEL T. KELLEY AND WEST SHORE TAXI COMPANY, DEFENDANTS CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT 1. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 2. Admitted in part; denied in part. It is admitted only that Defendant, Michael T. Kelley is an adult individual. The remaining allegations of this paragraph are denied. To the contrary, Defendant, Michael T. Kelley maintains an address of P.O. Box 391, Mechanicsburg, Pennsylvania, 17055. 3. Admitted in part; denied in part. It is admitted that Weet Shore Taxi Company is a Pennsylvania Corporation which maintains a place of business at 2103 Old Hollow Road, Mechanicsburg, Pennsylvania. The remaining allegations of this paragraph are denied. 4. Denied. After reasonable investigation and inquiry, Answering Defendants arc without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. . .. . . . . . . 5. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 6. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 7. Admitted. 8. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 9. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 10. Denied. The allegations of this paragraph constitute conclusions of law to which no responsive pleading is required and accordingly, the same are denied, and strict proof thereof is demanded at trial. By way of further answer, Answering Defendants specifically deny all allegations of negligence as set forth in this paragraph together with its subparts (a) through (h). To the contrary, at all times relevant to the material allegations set forth in Plaintiff's Complaint, Answering Defendants acted with reasonable care under the circumstances. -2- . . . . . 11. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 12. Denied. The allegations of this paragraph constitute conclusions of law to which no responsive pleading is required and accordingly, the same are denied, and strict proof ther~of is demanded at trial. COUNT I. 13. Answering Defendants incorporate by reference their responses to paragraphs 1 through 12 above as if fully set forth at length herein. 14. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 15. Denied. After reasonable investigation and inquiry, Answering Defendants are without informaLion sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 16. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 17. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a -3- . . . . . belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 18. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. 19. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. WHEREFORE, Defendants, Michael T. Kelley and West Shore Taxi Company demand judgment in their favor and against Plaintiffs together with interest, costs and attorney's fees. COUNT II. 20. Answering Defendants incorporate by reference their responses to paragraphs 1 through 19 above as if fully set forth at length herein. 21. (a) - (d) Admitted. 22. Denied. The allegations of this paragraph constitute conclusions of law to which no responsive pleading is required and accordingly, the same are denied, and strict proof thereof is demanded at trial. By way of further answer, Defendants specifically deny that Michael T. Kelley operated a motor vehicle in a negligent and/or careless manner. To the contrary, at all times relevant to the material allegations set forth in -4- ~ . . Plaintiffs' Complaint, Answering Defendants acted with reasonable care under the circumstances. 23-28. Denied. After reasonable investigation and inquiry, Answering Defendants are without information sufficient to form a belief as to the truth of these allegations and accordingly, the same are denied and strict proof thereof is demanded at trial. WHEREFORE, Defendants, Michael T. Kelley and West Shore Taxi Company demand judgment in their favor and against Plaintiffs together with interest, costs and attorney's fees. COUNT III. 29. Answering Defendants incorporate by reference their responses to paragraphs 1 through 28 above as if fully set forth at length herein. 30. Denied. The allegations of this paragraph constitute conclusions of law to which no responsive pleading is required and accordingly, the same are denied, and strict proof thereof is demanded at trial. WHEREFORE, Defendants, Michael T. Kelley and West Shore Taxi Company demand judgment in their favor and against Plaintiffs together with interest, costs and attorney's fees. COUNT IV. 31. Answering Defendants incorporate by reference their resp~nses to paragraphs 1 through 30 above as if fully set forth at length herein. 32. Denied. The allegations of this paragraph constitute conclusions of law to which no responsive pleading is required -5- . .. , , . " . J . . . . - . and accordingly, the same are denied, and strict proof thereof is demanded at trial. WHEREFORE, Defendants, Michael T. Kelley and West Shore Taxi Company demand judgment in their favor and against Plaintiffs together with interest, costs and attorney's fees. NEW MATTER DIRECTED TO PLAINTIFFS 33. Plaintiffs have failed to state a cause of action upon which relief can be granted. 34. Plaintiffs' claims are barred by the Pennsylvania Worker's Compensation Statute and/or any other applicable worker's compensation statutes. 35. Plaintiffs' claims are barred and/or limited by the Pennsylvania Comparative Negligence Statute and/or any other applicable comparative negligence statutes. 36. Plaintiffs' claims are barred and/or limited by the doctrines of res judicata and/or collateral estoppel. 37. Plaintiffs' claims are barred by the applicable statute of limitations. 38. Plaintiffs' claims are barred by the Pennsylvania Motor Vehicle Financial Responsibility Law and/or any other applicable statute. WHEREFORE, Defendants, Michael T. Kelley and West Shore Taxi Company demand judgment in their favor and against Plaintiffs together with interest, costs and attorney's fees. -6- d!; .. ~,.. ,. ...'f'- :I:: I 'J' r:1_ ,oil" 0' t." . r- :-.' ~ 1. .-f N 1" . , , , , ..., . '.. .-. I' . . ... .. :II: I.. ;: " ~ ~~-<w~f!;~ ~ UI, ~ n ~~ ~ ~ ~ g · ID ~a ~~ ~. a:a ~;fmrp.~ '!1-'(J) ~ g ;~; I ~ I~~ i ~ ;.) ", -- I '-.J ....... ~ ~ '\-(, - "" " 1'0\) "'*' ., ~ ~ I' -::r- ...'J l.n..... C'~ ~~ . ~ C) i "" , 'V " 1\'\ 1\) .,... "- ~ '\\~ ~ ...... '-<0 Z :c:>: < ?;;;:1'-< ~~ 0 m~ tIl n 0 !z! . O~~ H "l '< ~, ;:1 >-le- e) gj~ 0 ~ H :CHZ e- ~ "l :>> < HtrlO< ....~ H !il>-l "l 0 I!.H e- }'ll'""O H Sl n trl. . . ;:1 0 0 ... ~ lii OZ \0 ~~ ClCl tIl 11l \0 HH H >-l ~ I ~ e-e- 0 0 lJjlJj :z: 0 "'!;: o!:! SlSl n "l 0 11l :c 0 .>-l >-l !iij 0 '" l?~?;; "ll ~ l-' e?;; :;! ~?;;O ~. ::> 0< ::> tIlO :z: ~ rt ~ '" .... ~ '" ...., ~ rt ...., 0 :z: III III tIl ~ . . 'd~~i;, . . ~ ~ g i ffi l1. :z: o . a ~ o [L U o t:l ~ ~ m ~ 8 ~ [) III ... ij ><'2 t:l~~ ~~2l o ;:;U .J~ ~f-> 3] ":'tl .J ij '" I a '" QJ '" :z: t:l .... 0 63 ..: r.. ,..l f-> :... ;>, ~ ~ u..., ~ I IMI E t ~~[ . ~ ~ ~ ~ I. f M i i i :!ai~~I!Y ~o J S z III ~~ QUl~~ =.:1 Z It ~ >- ~ III t:l ... ~ ~ m ... III C ~!E 3 l1. . f->f-> IHi mm .J.J HH t:lt:l :z: o H III ~ H t:l .J ~ H U . iii f->[5 j;jrn ;if-> ~~ t:l.JW ilil~ H3 ~ Ut:l g~~ .J H ~ U o :z: III > l" (~~ 1:\-, r. '"'b -.l, ~ a ~ ..... - t-\ ) '- '.' ._: "Il f!'= ... (\J \.\1 ~t: -.t'\" ""''-''\ .. . '~ <--1. t.u "- C'- , N !:j \.- ~ . .. '.... ," I- . ~ " ....J ::I: ~ (.;', ~ "" '" ~ ,l..J'o.l ~ ,-, C" - .... o' ., .. ~ ~ l........, v f~" LIW Ollleol 01 NIIIS B, Blnn, Esqul.. p,o, Box 51B5 135 NMh Ooorgo Bt. BuilD 303 York, PA 17405,5185 " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JOHNNY D. GILBERT AND I No. CIVIL 1994 VICKIE L. GILBERT, HUSBAND I AND WIFE, I Civil Action - Law Plaintiffs, I ,f~ 4// OL-.\J-1..L JL vs. I ,)~8"j MICHAEL T. KELLEY AND I WEST SHORE TAXI COMPANY I Jury Trial Demanded I Defendants I NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action within twenty (20) days after this complaint or document and notice are served by entering a written appearance personally or by attorney and fil1ng 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 document, 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. Court Administrator Cumberland County Courthouse, 4th Floor 1 courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 submitted I ILES S. BENN, ESQUIRE BYI RICHARD ROBINSON, ESQ. Attorney ID# 51356 Attorney for Plaintiffs 135 N. George St., Suite 303 York, PA 17405-5185 (717) 852-7020 1 IN THB COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA CIVIL DIVISION JOHNNY D. GILBERT AND VICKIE L. GILBERT, HUSBAND AND WIFE, NO. CIVIL 1994 Plaintiffs CIVIL ACTION - LAW vs. MICHAEL T. KELLEY AND WEST SHORE TAXI COMPANY, Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiffs, Johnny D. Gilbert and Vickie L. Gilbert, Husband and Wife, by and through The Law Offices of Niles S. Benn, Esquire, and submit the within Complaint, the following of which is a statementl 1. Plaintiffs' are Husband and Wife, and adult individuals residing at 3506 Green Street, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant, Michael T. Kelley, is believed to be an adult individual residing at 99 West Portland Street, #3, Mechanicsburg, Cumberland County, Pennsylvania. 3. Defendant, West Shore Taxi Company, is a Pennsylvania Corporation with registered offices at 2103 Old Hollow Road, Mechanicsburg, Cumberland County, Pennsylvania. 4. The Facts and circumstances herein after related took place on May 30, 1992 at or about 4146 a.m., on the Law Ollleea 01 NIIe.S,lIenn,Eaqulre principal Coadway of East Simpson Street, at the P,O, Box 5185 135 Nonh Oeorge 51. 5ulle 303 York, PA 17405.5185 2 Law Ollleaa 01 Nil.. B. Benn, Eaqulre P.O. So. 5185 135 North Ooorgo 51. Sullo 303 York. PA 17405.5185 intersection with South Arch Street, Mechanicsburg Borough, Cumberland County, Pennsylvania. 5. At that time and place, Plaintiff, Johnny D. Gilbert, was proceeding in an easterly direction on East Simpson Street, operating a 1986 Ford Econoline Xl with Registration Number SBA-679. 6. At that time and place, Defendant, Michael T. Kelley, was proceeding in an northerly direction on South Arch Street, approaching the intersection of East Simpson Street, operating a 1984 Ford Crown Victoria, registration number TX-20985, owned by Defendant, West Shore Taxi Company. 7. At that time and place, Defendant, Michael T. Kelly, was acting under the control, at the direction and within the course of his employment with Defendant, West Shore Taxi Company. 8. At that time and place, Plaintiff was proceeding on East Simpson Street through the intersection with South Arch Street, when the vehicle being operating by Defendant, Michael T. Kelley, was caused to strike Plaintiff's vehicle. 9. As a result of the collision, Plaintiff was caused to be jostled and thrown about the vehicle, suffering severe personal injury, including but not limited tOI retinal detachment, cervical and thoracic pain, lumbar pain, concussion, pain in the occipital area of the head, left lower leg and ankle pain, left lower abdominal pain, photopsia, severe shock to the nerves and nervous system, 3 Law Ollleo. 01 Nil.. B. Benn, Eaqulre P,O, So. 5185 135 Norlh Ooorgo 51. 5ulla 303 York. PA 17405.5185 and other sever permanent personal injuries, and claim is made therefore. 10. The within described personal injuries sustained by Plaintiff were the direct and proximate result of the negligence of Defendant, Michael T. Kelley, as follows I a. failing to keep his vehicle under control I b. failing to maintain his vehicle at a safe speed I c. failing to maintain proper control over his vehicle to stop within the assured clear distance ahead, d. failing to apply his brakes in time to avoid striking Plaintiff's vehicle I e. failing to keep a proper lookout for the presence of other motor vehicles I f. failing to yield the right of waYI g. failing to observe and obey traffic control signals I and, h. failing to operate his vehicle within the rules and regulations of the motor vehicle code. 11. Plaintiffs' Johnny D. Gilbert and vicki Gilbert, were Husband and Wife at the time of the accident, and have continuously resided in the household since the time of the accident. 12. Defendants, Michael T. Kelley and West Shore Taxi Company, are jointly and severally liable. 4 Law Ollie.. 01 Nil.. B. Benn, Eaqulre P.O, 80. 5185 135 North Ooorg. 51. Bulla 303 York, PA 17405.5185 COUNT 1L JOHNNY D. OILlBRT v. MICHAlL T. KILLIY 13. Paragraphs 1-12 are incorporated herein by reference if fully set forth. 14. As a result of the within deocribed injuries, Plaintiff has incurred a loso of wageD, and may do so in the future, and claim is made therefore. 15. As a result of the within deocribed injuries, Plaintiff has incurred out of pocket medical expenses, and may do so in the future, and claim is made therefore. 16. As a result of the within deocribed injuries, Plaintiff has incurred out of pocket property damages in the amount of $780.45, and claim is made therefore. 17. As a result of the within deocribed injuries, Plaintiff has experienced Devere mental pain and suffering, and will do so in the future, and claim is made therefore. 18. As a result of the within deocribed personal injuries, Plaintiff haD experienced a restriction of his pursuit of daily activitieo, and will do DO in the future, and claim is made therefore. 19. As a reoult of the within described personal injuries, Plaintiff haa loot the companionohip, society and consortium of hiD wife, Plaintiff Vickie L. Gilbert, and will do so in the future, and claim is made therefore. WHEREFORE, Plaintiff, Johnny A. Gilbert, respectfully requests this Honorable Court to enter judgment against Defendant, Michael T. Kelley, in an amount in excess of Ten !i Thousand ($10,000.00) Dollars, interest, costs of suit and delay damages, if applicable. COUNT II. JOHNNY D. GILBBRT v. WEST SHORE TAXI COMPANY 20. Paragraphs 1-19 are incorporated herein by reference as if fully set forth. 21. At the time of the accident, Defendant, Michael T. Kelley, was acting as an agent, authorized representative and/or servant of West Shore Taxi Company, as follows I a. Defendant, Michael T. Kelley, was acting within the scope of his employment with Defendant, West Shore Taxi Company I b. Defendant, Michael T. Kelley, was operating a vehicle owned by Defendant, West Shore Taxi Company I c. Defendant, Michael T. Kelley, was in the course of performing services for the benefit of Defendant, West Shore Taxi CompanYI d. Defendant, Michael T. Kelley, was acting upon the direction and at the control of Defendant, West Shore Taxi Company. 22. Defendant, West Shore Taxi Company, knew or should have known that Defendant, Michael T. Kelley, would operate Law Ollie.. 01 NlleaB.Benn,Eaqulre the motor vehicle owned by Defendant, West Shore Taxi P,O. 80. 5185 135 North OOOI~. 51. Company, in a negligent and careless manner. 5ull. 303 York. PA 17405.5185 6 23. As a reoult of the within deocribed injuries, Plaintiff has incurred a 1000 of wageD, and may do so in the future, and claim iB made therefore. 24. As a result of the within deocribed injuries, Plaintiff has incurred out of pocket medical expenses, and may do so in the future, and claim is made therefore. 25. As a result of the within described injuries, Plaintiff has incurred out of pocket property damages in the amount of $780.45, and claim io made therefore. 26. As a reuult of the within described injuries, Plaintiff hao experienced oevere mental pain and suffering, and will do 00 in the future, and claim is made therefore. 27. As a reoult of the within described personal injuries, Plaintiff haD experienced a restriction of his pursuit of daily activitieo, and will do so in the future, and claim is made therefore. 28. As a result of the within described personal injuries, Plaintiff haD lost the companionship, society and consortium of hiD wife, rlaintiff Vickie L. Gilbert, and will do so in the future, and claim is made therefore. WIIEREFOR~:, Plaintiff Johnny D. Gilbert, respectfully request this lIonorable Court to enter judgment against Defendant, West Shore 'raxi Company, in an amount in excess of Ten Thousand ($10,000.00) Dollars, plus interest, costs Law Ollleea 01 Nlleal,lenn,laquhe of Buit and delay damages, if applicable, in the po. Bo. 5105 135NorlhOeOlUISI alternative, find the Defendant, Michael T. Kelley, in an Buill 303 York, PA 1740Hl05 7 amount in excess of Ten Thousand ($10,000.00) Dollars, plus interest, costs of suit and delay damages, if applicable. COUNT II I . VICKIB L. GILBBRT VS. MICHAEL T. KBLLEY 29. Paragraphs 1-28 are incorporated herein by reference as if fully set forth. 30. As a direct and proximate result of the injuries sustained by her Husband, Plaintiff, Johnny D. Gilbert, Plaintiff, Vickie L. Gilbert has lost the companionship, society and consortium of her husband, Johnny D. Gilbert, and will do so in the future, and claim is made therefore. WHEREFORE, Plaintiff, Vickie L. Gilbert, respectfully requests this Honorable Court to enter judgment against Defendant, Michael T. Kelley, in an amount in excess of Ten Thousand ($10,000.00) Dollars, interest, costs of suit and delay damages, if applicable. ~NT IV. VICKIB L. GILBBRT vs. WEST SHORE TAXI COMPANY 31. Paragraphs 1-30 are incorporated herein by reference as if fully set forth. 32. As a direct and proximate result of the injuries sustained by her Husband, Plaintiff, Johnny D. Gilbert, Plaintiff, Vickie L. Gilbert has lost the companionship, Low Ollie.. 01 NII..S,Benn,Eaqulre society and consortium of her husband, Johnny D. Gilbert, p.o, so. 5185 135 North Ooorgo BI. and will do so in the future, and claim is made therefore. Sullo 303 York. PA 17405,5185 '" Iii lil I? .~ ~~~ l ".bf::' ,,~ ti~~ "0 w~~ ~~>< \..:' U) ~ :.. \LI ~ LL t:: CJ Z . ~ ~ It ~O !l:Cl/lfa N ~ IIlCJ ~ ~~d~ ~ ~ ~;1[ Q ,,') 0 f.\; ..... -" '" g oil llt:t:, ~4: ~:I ~~,: N ...~ ~_l. -0 :\! ;:;(, :!.: IH' S;t:. W ;]~~ L ~ 8 N ~ N ~ ~ ~ p.. ~ . ~ ~ ra. 8 i ~ ~ ~ el ~ 'tl ~.2l .e.... ...... ~ :l .. .c tl .... . nI ~~~ aa ClCl . . . I=lt-lGl m~~ g~~ .. - .. ~il o GI ~j~ '::1 1-<0 ~ffi ~ ~~ i t I!; ~ ! f~~ d .. U).- u. j oJ~ji~ ~ ~i]~!~ ~ ~I~~~[ ~l;j ~ ~I U ZI=l "" 0 ~ S~ J. <( ~ ; ~~ "... a ..f:; \oj...., .-: "I l, _} " 111.:1-,:, .. i~l " i :,,!.:. .....1).;:'- N -( :r ~... (.~ '-:0:1;"'" W ;;,,.<-,:1 U1 "-r~-:r.;~ -0 .t~t::4..~''''1 :s: a... ....,.. "'.., . .J:.. " , ., - ~ Lew Ollie.. 01 Nile. 8, Benn, Eaqulre P,O, Bo. 5185 135 North Ooorge 61. Bulle 303 York, PA 17405.5185 IN THB COURT OF COMMON PLEAS CUMBBRLAND COUNTY, PBNNSYLVANIA JOHNNY D. VICKIE L. and wife, GILBERT AND GILBERT, husband Plaintiffs NO. 94-2583 CIVIL vs. MICHAEL T. KELLEY AND WEST SIIORE TAXI COMPANY Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED REPLY TO NEW MATTBR AND NOW, comes the Plaintiffs, Johnny D. Gilbert and Vickie L. Gilbert, by and through their attorneys, The Law Offices of Niles S. Benn, Esquire, and submits the within Reply to New Matter, the following of which is a statement I 33. Denied. This paragraph is a legal conclusion which requires no reply. To the extent a reply is necessary, said paragraph and the averments contained therein are specifically denied. 34. Denied. This paragraph is a legal conclusion which requires no reply. To the extent a reply is necessary, said paragraph and the averments contained therein are specifically denied. 35. Denied. This paragraph is a legal conclusion which requires no reply. To the extent a reply is necessary, said paragraph and the averments contained therein are specifically denied. 36. Denied. This paragraph is a legal conclusion which requlres no reply. To the extent a reply is 1 ! ~ ~ ;... ::r: :( ; ...--r ..... :.." ,', .,." ,~ t,; ~ ..:I l1< Ii" ~ o U It< o :;; l::> o U r.:a IS < ... ~ ~ ~ l1< . ~ o U ~ r.:a ~ U It< . . . l'\..:ICI .... ~~~ ~U'tl 0"'1: ..,>1Il 'tl I: III ,c III ~ll . :;;:;; r.:ar.:a """" .~ ..:I ...... uu Ii" ... III .... .... .... ... I: ." III ..... l1< . III :> . ~ III 'tl...... I: l1< I: to :c to O'tl ><UI: r.:a .. ..:I....... ..:1:<.. !:l~l'\ ..:~ o ..:1= ~: Uti) ~~ . , ..:I ... > ... U .., <Xl '" N I ... '" ~ ... l::> : . l~i ~J~ft~ ~ai~~l~ ~~ I ~ ~ ~ [ . o Ii" '. ,., .... ,'-, In ,oO ", ....'1 ::l. 4"- .. .( :; l:R UCT lJ q 12 PH 195 i",' "I . h'~; lftt r iJ ~ I II .'(. \ I Y 1,'\