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Home My WebLink About95-00438 " '. '." , I/) ... " ::~iS:'~<',/~ . ", '(5.?, ".. 'fI ' :<.' ::s . 'VJ; . ._-, , , " ::Y' , . '.: . ',~ ~.'<' -, VI '.'7,' .~;'. 1 ' . I ! 'P.) :,.,.,~'"'' ''';. ~ Hrt'" ~:-~.~:: ; j -'i ~~\:~':~'".. .tli'.:;J., " , ~~t:;.>: ':l ~'" ~l~J:':'" \1-1(t. . 'it ~;-:: ~., 1 ~{r\. ,~.1 ~ . .'~ , li:( <t...., f'~,V;;,:':" ':\~.':_ ',~ ~ i1i,i! : " ",'.'C. "r:t,~\" - .-;. ',~v~ ;p "~ 'J' , ~ ,'( , " ," ,to :',' 'r-. ,-.; , :1-: 00 '~"" )'~ ,-: l() 0" ;',j>- ." '" -. . ~EMOYNE AUTO SA~ES and RICHARD A. QUIG~EY, Plaintiffs ~r T:3 CCURT OF tJCl'!MC!T PI-.:'A.S "'T'l',""""'T "~r;"\ ,"'O~'j"I"'r 1:":'~":"""J VT .!.~ ~I!~ J\,j.~~\.I;'" .J \-'j" _.., .__..JIoJ_ ...._. v. :rO. 95-438 CIVIL TERM '-' I CHARLES E. SWEGER, JR., t/d/b/a SWEGER'S GARAGE, Defendant :IOT!1J'E OF APPEft~ FROM A~"ARD OF :CP3D GP A..lU:.l.'.!.':w.'!'CRS '!'C ~ ...... ?RCT.::CNCT.f1_~Y : ~roti'~e is gi'ren t2t Defendant a?~eals :':'01:1 tl".e a1,a.:'d of tr.a board of' arbit::'atcrs entered 1:. this case on February 26, 1996 A jury trial is demar.ded lJ. (Cr.aek:x cox it' a JU::'y t::,ial is demar.ded. Ct:-.eI"..nse Jury 1:rial is ~;ai"ed.) I hareb:! certi!'1 tha.t . (1) (2) ~~ll~ . xx=~ or application ~s ceen ~~de for ~ermission to proceed L~ forma pau~eris. (st::':!.~<e out t:e i~appl:!.~abl= clause.) ,[ . --1 ~ "'l i,. : Ge~~~l~ ~ire Ap~ellen1: or Attorr-ey for Ap~eller.t I ~TCTE: Tr.e. demand for jury trial on appeal from comculsory arbitration is ~~rned b7 ;\ule i007.1 (b). - (b) No aff'ida'11t or verification is ::"3qtli.!'ed. (' ~ "I ,~. I ..-) .j , , ~-] :'.) ., 1 I' "I::) . , .., t..\ , ., .. LEMOYNE AUTO ~ALES and RICHARD A. QUIGLEY, Plaintiffs IN THE COURT OF' CC~!MON PLEAS 0UM3ERI.Arl!) COtTrlT"!, P3~l!rS'YINA~TIA No . 95-438 CIVIL TERl'l Ii i v. CHARLES E. SWEGER, JR., t/d/b/a SWEGER'S GARAGE, Defendant NOTICE OF APPEAL FROM AWJlJ) OF BOARD OF AHBITRATORS TO '1'::E PRarF.ONCT.lU,Y: I' '. I , " I I Notice is gillen t~t Defendant a?~als from the award of' the board of arbitrators enterel:! ir. this case on February 26, 1996 A jury trial is demanded fJ. (Cheek'" 'cox if' a jury trial is demanded. cthsX".nse jury triaJ. is ~;ai"sd.) I hereby certify tr.at . " I I i , I (1) ~lOOOOI~lIm~~x~*>>~~~JlX=&XlOO<*~ or (2)' ap?licat1on has 'ceen made ror ~ermission to proceed tr. forma pauperis. (Strike I Georg ,8. Faller, Jr., APpea~ant or Attorr. ire ~or Appellant NCTS: The. demand for jury trial on appeal from comoulsory arbitration is gcuerned by Rule i007. 1 (b). (b) No af'f1da'lit or V'eri:'ication is requirec. ",. L') L: If; " ~ i .. Ill~: . V"J ,. I c..'~'-. .- .' ..' ... I ~ .', p:., L'- ()f: '. b . ( ...:'1 ~ C"' (.) , lJ..tl.. ,';"J ....1., C. 1.:: . '"- I ',' .-. ~ l!~ t'~) " U t.n ~~) .. LEMOYNE AUTO SALES and RICHARD A. QUIGLEY. Plaintins IN THE COURT OF COMMON PLEAS OF r.:UMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - LAW NO. 95-438 CIVIL TERM CHARLES E. SWEGER. JR.. t/d/b/a SWEGER'S GARAGE, Defendant ORDER OF COURT ~ AND NOW. this H-day of V\v~ c \..,....,/ . 1996. on consideration of the attached petitioner's Affidavit. leave is granted to the petitioner to proceed in forma pauperis to appeal the arbitrators' award to the extent that he is relieved of all costs in this action. BY THE COURT. _\ J_LV'( (-'~ ~. . J. 1"'/'1' , c-,-.- .: !:' .,:: "-'. .., " '. 1,-. '. :"" ~ ,;. (~ I, . " " I, , " ":":""/" ", "'/1 .. . ~ \ , , ~.\nt."!iIIATAI'II.I:"il.NIIIII'w,\~N:".II'I:ru. 1',uI"III}1)\lHllllfl-l'AM kf\,""t o\tlf.~IOOI ~IAM ; ""1.\1 LEMOYNE AUTO SALES and RICHARD A, QUIGLEY. Plaint ills IN mE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION. LAW NO. 95-438 CIVIL TERM CHARLES E. SWEGER. JR.. t/d/b/a SWEGER'S GARAGE, Defendant PETITION TO PROCEED IN FORMA PAUPERIS Defendant, Charles E. Sweger. Jr.. in the above captioned action respectfully requests this Honorable Court to grunt him leave pursuant to Pa.R.C.P. 1920.62 to proceed in forma pauperis to appeal the arbitrators' award in the above captioned action to the extent that he be relieved of all costs attendant thereto. MA~~O~. DEARDO By: eorge B. Faller. Jr.. Esquir Ten East High Street Carlisle, PA 17013 (717) 243-3341 LLIAMS & OTTO Attorneys for Defendant Date: March 21. 1996 LEMOYNE AUTO SALES and RICHARD A. QUIGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA I I' I t I I ! I i I v, CIVIL ACTION. LAW NO. 95-438 CIVIL TERM A FFIDA VlT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS l' I , CHARLES E. SWEGER, JR.. tldlb/a SWEGER'S GARAGE. Defendant TO THE HONORABLE JUDGES OF SAID COURT: The Petitioner. Charles E. Sweger, Jr.. residing at # I Penn Street, Enola. Cumberland County. Pennsylvania. upon his oath deposes and says: I. I am the named Defendant in the above titled civil cause of action and the Plaintiffs are Lemoyne Auto Sales and Richard A. Quigley. 2. This affidavit is mad" to inform the court as to my status ofindigency and to induce the court to grant me leave to proceed in this cause as an indigent. 3. In making this affidavit, I am aware that perjury is a felony and that the punishment is a fine of not more than $3,000 or imprisonment for not more than seven years or both. 4. I do not have any money on my person. at home. or elsewhere which could be used for the expenses of this proceeding. 5. I do not own real estate. My only assets are C~rHING, . /YE.eSOI..ML , IrE,.I1S I have no other assets. I am not owed any amounts of money by any person. 6. My wife. currently resides at . She is years old. (a) I last lived with my wife [date]. (b) ( do not have information or knowledge as to whether my wife is employed. has any money. owns an automobile. owns real estate. or has any other personal property or assets. 7. I have children: [name]. age_. 8. I am presently employed at PI$tll)L.EO 9. My social security number is /1/-/;c; - ..:2.'33{- 10. I have the following income: $ '?~'?(')o M{J. II. My monthly expenses are as follows: .&"7a:>.ro Nt'. 12. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 13. I verity that the statements made in this affidavit are true and correct. [understand that fal~e statements herein are made su~ject to the penalties of 18 Pa.C.S. ~4904. relating to unsworn falsification to authorities. WHEREFORE. petitioner prays that this Honorable Court grant petitioner leave to proceed in forma pauperis in the above titled action without fee or cost to the petitioner. Dated: March 21, 1996 C/lAlk C. 4,,:jt-l,/1 . Charles E. Sweger, Jr. \ LEMOYNE AUTO SALES and RICHARD A. QUIGLEY. I'lnintiOs IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, I'ENNSYL VANIA v. CIVIL ACTION - LAW NO. 95-438 CIVIL TERM CHARLES E. SWEGER. JR,. t/dlb/a SWEGER'S GARAGE. Defendnnt ATTORNEY'S AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PA llPERIS I, George B. Faller. Jr., Esquire, of the firm of MARTS ON. DEARDORFF. WILLIAMS & OTTO. nttorney for the pnrly petitioning to proceed in forma pauperis. certify that I believe petitioner is unable to pay the costs of instituting this action and that I am providing free legal service to petitioner. Defendant's A01davit showing inability to pay the costs of litigation is attached hereto. MARTSO ,.DEARDORFF, WILLIAMS & OTTO By: o Orge ler, Jr~squire Ten East High Street Carlisle. I' A 17013 (717) 243-3341 Attorneys for Defendant Date: March 21. 1996 ~- "_;' 'l''t:-.....,:-. ,~_ :'. 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COMMOHWIAUH Dr PINNSYLVANIA COUAT OF COMMON PLEAS NOTICE OF APPEAL FROM JUDICIAL DISTAICT DISTRICT JUSTICE JUDGMENT COMMON PlIAS No. 95-438 Civil T~rm NOTICE OF APPEAL Notice is given thot the appellant ho. filed in the above Court of Common PleDl on appeal from the judgment rendered by Ihe Diltrict Justice on I~. dote ond In the co.e mentioned below. .-.- '-----...- oS l{)cGc,{'S 1 ,vPlUANI / 'pE:,u,(..J N I M NA o 6"/?..:'/7Gt::. CIIh'A'LE$H E." SU,~6"'E-<' IV Sr.eeeT C.OOL..;1 LE'hOY,A/.c /14 TO S/)t!.C '" NAltJllE Of APPUlANT .:r.e, 09'- / -O~ SIArt ZP COOf /H 19ocS-c')3/ jDr.lf.ylCb1l} su'(,6C~6/MI9c.c <"11#~r.e: Su.,oEtSrof'..:R tll A I N[Y A NT f'l I A I \Vf,' J CV 19. "9tfJl? -99 LT 19 This black will be signed ONLY when thi. notation i. required under Pc. R.cPJP. No. 100BB. This Nolice of Appeot, when received by the Oi,lriet JUltiee, will operote a. 0 SUPERSEDEAS to the judgment fDl' poSleSlion in thi. co.e. C4,~ C:~~~)kl SlfIIl'ltUro 01 Prothonotary", Deputy If appellant was CLAIMANT (see Pa. R.C.P.J.P. No. 1001 (6) In action belore DIstrict Justice, he MUST FILE A COMPLAINT within twenty (20) days alter liIing his NOTICE 01 APPEAL. , ' { . " . (This section ollann to bo used ONLY when appell,lnt was DEFENDANT Isee Po, HC.P.JP. No, IF NOT USED, detach lrom copy of notice of appeal to bo selVed upon "ppcllcc). PRAECIPE. To Prolhonotory /..E;;f)f'~ j;l./TO s~<..E:S PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE 100 1{ 7) In action before Dls/Jlct Justice. Ent.. rule upon N~no 01 awcll'c{sJ 95-438 Civil Term , oppelleels), to file 0 complaint In thi. appeal (Common Plea. ~ ) within twenty (20) day. 011.. \Ofviee of rule", suff.. entry of Judgment of non pro. CZuk ~_~'~!)'.?L /..., , SlgnatufO 01 awcll.J(f'~()( IUs attomcy 01 agent .' RULE. To LE#t:l)/A..c ;;In-o S/J./.L!:S' Nivno oIawc11ee(./ , oppelleel'), (1) You ore notified thot 0 rule I. hereby entered upon you to file 0 complaint in thi. appeal within t"'enly (20) days ofte, the dote of ...vice of thi. rule upon you by penonol service", by certified", registered moiL ~ (2) If you do not file 0 complaint within this lime, 0 JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. -I (3) The dote of serviee of this rule if .ervice WD' by moil i. Ihe dote of moiling, " ll) fl.) '\ " I, / ,~;. IT' SJgt Jtlxa 01 Ftolhonolw 01 ty Dote: Jlln. 27, .19-1? t.-..t KlPC J I:;HJ04 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (Tills ptool OISOfVlco MUST OE FILED WITIIIN TEN (10) DA YS AFTER II/Iflg rllo f10tica 01 uppulI/, Chack "pphcabla box os) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ,('I;,'~W;>{'l" 'p'.-<,p ;11 AFFIDAVIT: I hereby SWOOf Of olllrm Iholl sorved o a copy 01 th~ Notice of ApP.;oL Common ~'~J1S No, q 5' .. '7!,5"Y " upon Iho District Justice designated ,lho'Oln on (dato 01 somco) C' I ~,7 , 19..22., 0 by porsol'ul ~~!VI,~IL 0 by (cortlfl~.d) (registered) mell, sender's recelet pttnched herelo, and upon tho IIppollee, (nllma) Le/l/"~"-c At(7/!'") S/'7LE'\' ,on C2/"/ , 19.2.LO by pe,sonol servlce,qby (certified) (reglslered) mall, sender's receipt attached herelo. o end lurtherthot I served the Rule 10 File a Complaint accompanying the above Notice 01 Appeal upon the oppellea(s) towhom the Rule was addressed on ,19_ 0 by persona' service 0 by (certified) (registered) moll, sender's receipt attached herele. ; i1..rM{rf ('~ ~~ve7'..e-1-'~1 ! . ;' Signature 01 allla,,' '-,/ r---~---"""''''._''-_.'--'''''''.-1 1/, i ' '1 r " '. ~ . _ ' ~ .. ,.. 'I - ~ I , , "PI i , ...., m '" __J 1" N <.1:> t..T1 ; z 402 135 0],3 Receipt for Certified Mail No 'nsur,onco COVCtoDo Providod 00 not USO 'or IntOfnOllonllf Mail 1500 Reversol ~ ~:LDJ':;:\ 1j ~ <:3 o m M g ("'J.I~\I't.. If K! M 0> 0> - S~{"i o.-',....~ ftt flrWIo:11l"Oeh".\ I"" k.lultl fI".'Ol Sh(l.....~'Il .'I....'hQlrl & 0". Orl......., SHERIFF'S REWllN C(M.lQIJWEALllI OF PENNSYLVANIA: COONTY OF ClMBERLAND In The Court of Common Pleas of Cumberland County, Pennsylvania No. 95-438 Civil Term Complaint in Civil Action Law and Notice Lemoyne Auto Sales and Richard A. Quigley VS Charles E. swenger, Jr. d/b/a SWenger's Garage Timothy Reitz , ~r Deputy Sheriff of Cumberland County, Pennsylvania, who being duly swom according to law, says, that he served the within Complaint in civil Action Law and Notice Charles E. SWenger, Jr. OIDIa Upon Swanger's Garage , The defendant at 2:10 o'clock p.M. EST /}IfJJ'19J:, on the 23 day of February , 19 95 at 1 Penn Street, Enola ,Cumberland County, Pennsylvania, by handing to Charles E. SWenger Jr. a true and attested copy of the Complaint in Civil Action Law and Notice and at the sane time directing his attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge 24.00 8.40 So answers: ..., /' '~ ......,. . ," //J' . ..' '..' ~'. ';"';.., - ... .; . ,. . ~ I ',/~"-~",,,,<,-,/,-:--,,~~ R. Thomas Kline, Sheriff 4.00 36.40 ftI. by Atty. 2-27-95 by rF~f;! tif Deputy Sheriff Swom and subscribed to before me this .1 ..,~ day of 711 AU/--' 19 vS' A.D. ( lie,,"..... C,". )/[l (/1.<. I f'47: ~ I ,~~ Prothonotary COMMOHWIAUH 0' PINHIYLYANIA COUAT 0' COMMON PLlAS NOTICE OF APPEAL FROM JUDICIAL DIIlRICT DISTRICT JUSTICE JUDGMENT COMMOH PUAI No. 95-438 Civil THrm NOTICE OF APPEAL Notice i. gi"", that the appellant ha. filed in the above Caurl of Common Plea. on appeal from the judgment rendered by the District Ju.tice on the doto and In the ca.e mentioned bel""" I 6tULZ;tX5 Aliiim ....UANI / /'E.",uA..J I II< Mf Of OJ 09-/-02 IAU /)4, . 6/J.<'/l6:t.:: C:::;;;AA'Lc.".s- E. ,S;l-l'.:.-~""-<' " c-<-r/ .4 r.e. ST~J;;E/- IPOcS~2?..,/ ( 1Itr1lJ.W1f1 LEill.!JYN.c A/1m s-'>t..r-S '" Sic'1'6C<S6/)~'h<rEJC:::'1MI(Us.E. sIL.'ar<,~ NAIUllf. Of APP(UAN' 0It t.~ AIIORNtY OI,t.C(Nf 1tOR'_c= /Ill. ' ~,I ;/ CV 19. 2. (At.{1.L(.'<L (.., ._'-:llUt:'j1(;"L.. ' :!., lT 19 Thi. black will be ~gned ONLY when this notation i. required under Po. R.cP.JP. No. If appellant was CLAIMANT (soo Pa. R.C.P.J.P. No. 10088. Thi. Notice of Appeal. when received by the Di.trict Ju.tice, will aperete a. 0 1001(6) in action before District Justice, he MUST SUPERSEDEAS to the judgment fOt po.....ion In this co... FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. .. A l'ltn"" Sigllnture 01 Prothonotary ()( Deputy (This see/Ion of form to be used ONLY when appellllllt was DEFENDANT f see PD. R,CP.JP. No, IF NOT USED, detach from copy of notlco 01 appeal /0 be seIVed upon appellee J. PRAECIPE, To Prothonotary /..E.Alt')-'-<.-'lE: /)Llm s/J/rJ' Mmo 01 U/''IOIIl'C(Sj PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE 1 00 1 (7 J in action before Disltic/ Justice. Enter rule upon , appellee(s). to file a complaint In this appeal (Common Plea. No. 95-438 Civil THrm ) within twenty (20) day. after mvice of rule or .ulfer entry of judgment of non pro.. C.t'-UI:~ C~~iLI'P~-L~ , s.anar.... 611lWJ""( or "'" ./_ or agcnl RULE, To LI3"Iit'l)/A..:C: ,l)117l? .S/?/.,cS' NJno oIllWJlloo(" . oppellee(.). (1) You ore notified that 0 rule i. hereby entered upon you 10 file 0 complaint in thl. appoal within twenty (20) day. after the doto of ,",vice of thl. rule upon you by per.onollervice or by certified or regl.tered moil .. , ' (2) If you do notfite 0 complaint within thisti",e. 0 JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. Dolo: I',n..... 0< ..",,, .. ". .. . ..... -. ~ ""'" ,~ .... ., ..,~' JIm. 27, . 19~~ _ b-t...L A~'Ai1- ~:;.. I aolftol ~ ty " \ NJl'C 3 ,;,.fW 1 ~ J< , ,< -- I "\ ....... ~I .... '-.)'0 I\f) cl ~ ~ \ .lJ ....... -- , "6 ...J ...2 (0 ....:.. ~ ~ ~'J..;) c:..) ~ .~ n --,., '-61 lIO SGJldwB UOlltSIWWQ:J Av-. OJ"> en '- ~ IV") ~' I In I\i' :.:: _-r .'. ,r, ,:.;> "'.- i..'.J :.: ., -~ /JI!:)//lOIO 0/111 SplfW reM "APPllI" IUOljM 8)OJOq Jf!:JIJlO 10 .In,JlulJ,S ,UBIIII 10 9JnHlUtJ!S -6L'--:fOAVO SIH! 3W 31l0:f38 0381Il::JS8nS ONV (03WIlI:f:fV) Nil OMS 'OlOJ04 p040Unu IdlOOOJ S,JOpUOS 'IIUW (pOJOISIBoI) (pO!II\lOO) ~q 0 OO!^JOS IUUOSJOd ~q 0 -61 . uo POSSOIPPU SOM OIOIl 041 WOW" 01 (S)00uoddD041 uodo IDOddV 'OMIION O"Dqo OlllBu!~uodWOOOOIUIOldwo::J 0 Oll:f 01 OIOIl 041 PO^'OS 11041 J041101 pUO 0 'OlaJa4 pa40ono Id!ooo. S,IOPUOS 'I!OW (poJOlsIBal) (poII!lloo) ~q 0 OOI^JOS louoslod ~q cr-61 ' Uo' (awou) 'oouoddo 041 uodn puu 'OlOJ04 p040uno IdIOO.J S,JOpUOS '1I0W (pOloISIBol) (pO!l!IJOo) ~q 0 OOI^JOS IUlIoslod ~q 0 '-BI ' (OO!MOS/O %p) uo UIOl041 POluuB!sop oOllsor IOIIISIO 041 uodo ' 'ON SOOld uowwo::J 'Iuodd", 10 OOlloN 041 10 ~doo 0 0 PO^JOS IIu41 wm,u JO JOOMS ~qol04 I :.1IMfOI:l:lV II : :f0 A!NnO:J VINV^1ASNN3d:f0 H! 1V3MNOWWO:J (SOKOq o/quOI,ddu ~004:J '/Coddu /0 0011011 041 6u1/1/1/Jl:fV SA va (01) NJl NIHl1h\ aJ?/J 38 lSnW OOIMOSIO 100Jd S141) .1NIV1dWOO 311:1 0.131ml ONV 1'13dd'l :10 301.10N :10 30lMl3S :10 :lOOl:ld 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag 01' No ~ 09-1-02 OJ N.me Uon Robert V. MANLOVE Add,", 1507 Market Street Camp Hill, PA T.,.,.,..,. 17171 761-0583 17011-0000 SWEGER'S GARAGE/CHARLES E SWEGER JR 1 PENN STREET ENOLA, PA 17025 THIS IS TO NOTIFY YOU THAT: NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: NAME.... Aoonrss liEMOYNE AUTO SALES I 1000 STATE ST LEMOYNE, PA 17043 L ~ DEFENDANT: VS. r; NAME and AOQnEGS SWEGER'S GARAGE/CHARLES E SWEGER JR 1 PENN STREET ENOLA, PA 17025 L ~ Docket No.: CV-0000408-94 Date Filed: 10/18/94 ~ Judgment was entered lor: (Name) LEMOYNE AUTO SALES ~ Judgment was entered against: (Name) SWEGER'S GARAGE/CHARLES E SWEGER JR In the amount of $ 2.482.68 on: D Damages will be assessed on: D This case dismissed without preJudice. D Possession granted. D Possession granted If money judgment Is not satlslled within thirty days. D Possession not granted. D Levy Is stayed lor _ days or D generally stayed. o Objection to levy has been filed and hearing will be held: Date: Place: Time: (Dale) 12/30/94 (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees $?,408.70 $73.98 $.00 $.00 TOTAL $2,482.68 My commission e~plros first Monday 01 January, 2000. AOPC 315.94 T DATE OF JUDGMENT BY FILING A NOTICE OU T OF COMMON PLEAS, CIVIL DIVISION. / SEAL I ! , ..... CJ"). .,. -. -.., ~, '" C,) r~.J ~ --, LAW OFFICES MlRIX &JACODSOX Q BISO DERRY STREET HARRISBURG. PA 17111.'260 ,'717) 561:1$15 . --"~~_.,.-.l I' t' -.~I. ~ . ... ".~.."' -, . --~~ .. - . - r--. LEMOYNE AUTO SALES and RICHARD A. QUIGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW CHARLES E. SWENGER, JR. d/b/a SWENGER'S GARAGE, Defendant NO. 95-438 CIVIL TERM 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 lost 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 Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone (717) 240-6200 LEMOYNE AUTO SALES, and RICHARD A. QUIGLEY Plaintiffs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA 15- ~35' C~..j~ No. 1995 v. . . CHARLES E. SWENGER, JR. d/b/a SWENGER'S GARAGE Defendants, CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW. comes the Plaintiffs, by and through their attorney, Robert Patrick McPherson, and aver as follows: 1. The Plaintiffs, are an adult individual, and a business owned by the individual Plaintiff with a mailing address of lOOO State Street, Lemoyne, PA 17043-k442. 2. The Defendants, are an adult individual and a business owned by the individual Defendant with a mailing address of 11 Penn Street, Enola, PA 17025. 3. On or about September 29, 1994, the Defendant requested permission of the Plaintiff to move a 1979 Ford pick-up truck and a trailer which was connected to the truck, which he stated was blocking his access to the Plaintiff's place of business. 4. The Defendant then proceeded to leave the Plaintiff's place of business with the Plaintiff's vehicle and trailer without the Plaintiff's permission. 5. The Defendant returned the pick-up truck in a damaged condition later that evening but did not return the trailer. 6. When the Defendant took tho pick-up truck, the truck was in good condition and without any damage and the trailer was in 1 good operating condition. 7. When the Defendant returned the pick-up truck the following damages were observed by the Plaintiff: a. The permanently attached trailer hitch was bent to a 90 degree angle. b. The hub cap was bent inward. c. The exhaust pipe was twisted so as to need repair. d. The manual transmission was broken and the truck could only be driven in second gear. e. The R & R shift tube, which controls the shifting of gears in the manual transmission was broken. f. The running and break lighting systems were torn. COUNT I (NEGLIGENCE) 8. Paragraphs 1 through 7 are incorporated herein as if set forth fully and at length. 9. The Defendant owed a duty to the Plaintiff not to use the Plaintiff's vehicle without the Plaintiff's permission. 10. The defendant also owed a duty to the Plaintiff not to harm the Plaintiff's property. 11. The Defendant breached his duty when he damaged the Plaintiff's property without permission of the Plaintiff. 12. The Plaintiff suffered damage to his property because of the actions of the Defendant. 13. The necessary repairs to the Plaintiffs I truck and 2 . . trailer cost the Plaintiffs $1593.70 and are itemized as follows: a. trailer tongue $386.00 b. replace light wiring $29.70 c. replace step bumper $386.00 d. replace clutch & flywheel $579.00 e. retrieve trailer and cars $210.00 f. repaint trailer $60.00 g. loss of use of vehicles $200.00 14. The Defendant stated to the Plaintiff that he was attempting to return two cars owned by the Plaintiff which he possessed at his place of business, when the vehicles were damaged. l5. Because of the willful, malicious, and careless actions of the Defendant the Plaintiff was required to use the service of a tow truck to retrieve not only the cars but also to retrieve the trailer. l6. The Plaintiff also noticed a heavy odor of alcohol on the breath of the Defendant when he returned the damaged truck. Wherefore, the Plaintiffs respectfully request this Honorable Court to award them compensatory damages in the amount of $l593.70 and punitive damages for the Defendant's willful misconduct in the procurement and harm he caused to the Plaintiffs' property, and any other damages the Court deems just and appropriate. COUNT II (BREACH OF CONTRACTl l7. The Plaintiff offered to transfer $500.00 to the 3 . . ~ Defendant to buy parts to repair a 1984 Subaru car owned by the Plaintiff which the Defendant was to repair. 18. The Defendant accepted check number 1028 drawn on the Plaintiffs bank account to buy the parts and use said parts to fix the car. see Exhibit "A". 19. The Defendant failed to use the money of the Plaintiff to buy the parts, rather the Defendant cashed the check and confiscated the proceeds in contravention of the contract and never fixed the car as promised. 20. In consideration for buying the parts as promised the Defendant would receive payment for his services to repair the car and to travel to get the parts. Wherefore, the Plaintiff respectfully requests this Honorable Court to award him compensatory damages in the amount of $500.00, and any other relief the Court deems just and appropriate. COllNT III (NEGLIGENCE I 21. The Plaintiff promised the Defendant that he would pay him if he would replace an engine in a Dodge car that the Plaintiff owned. 22. The Defendant negligently removed the exieting engine and in the process destroyed many of the connections and wiring needed to replace the engine. 23, The actions of the defendant were unworkmanlike and he breached his duty to fulfill his obligations and in the process 4 caused damage to the property of the Plaintiff. 24. The Plaintiff incurred $315.00 in damages for the negligent conduct of the Defendant. Wherefore, the Plaintiff respectfully requests thie Honorable Court to award him $315.00 in compensatory damages and any other relief that the Court deems just and appropriate. Respectfully submitted, Mirin & Jacobson Dats: February 2l, 1995 Robert patr ck McPherson 8150 Derry Street Harrisburg, PA 17l11-5260 ID# 72670 Attorney for Plaintiffs 5 . . VERIFICATION I, A. Richard Quigley, do hereby certify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that the false statements contained herein are subject to penalties of 18 Pa.C.S.A. 54904 relating to unsworn statements to authorities. A~1iiY f..... '" : ~ 1.-1 "'-j (~'l " >., ;-, '~.Ll - t.~., n... 6 I I , i' I' 1. I i IJ') ~ ~ >. '" ,- .f'" UJt:;;~"1 ~2"~'::"'; l.I..oC.J.-i ~!.;~e~ ~ l.....-)- ~] "I~ ~llu, In. ....:r .:Uil.t.j;"~ . .', t; ;' ~ iJ 1":.1., '. ~ ~(..\ ~ LD ~ 0") '" ~ ~ STONE LAFA VER & STONE ATTORNEYS AT LAW .,'" BRIDGE STREET POST OFFICE OOX E Nr.w CUHlltUn.AHIl. PA, 17070 CHARLES H. STONE JON F. LAFAVEA DAVID HEAN STONE GERALD J. SHEKLETSKI TELEPHONE 1717) 77A.7435 TELECOPIER 1117J 77A.3aaD NOTICE OF HEARING LEMOYNE AUTO SALES AND RICHARD A.Quigley, Plaintiffs v. CHARLES E. SWENGER, JR d/b/a SWENGER'S GARAGE IN THE COURT OF COMMON PLEAS-OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-438 CIVIL TERM PLEASE TAKE NOTICE that the Arbitrators appointed by the Court in the above matter will hold a hearing on Monday, February 26, 1996 at 1:00 p.m. in the second floor hearing room of the OLD Court House in Carlisle. If this date is not satisfactory to any party involved, please ocntact all Arbitrators and other parties to determine the next possible day, after the date fixed herein, obtain a hearing room through the Court Administrator's office and if all is satisfactory for everyone concerned, give a written notyce to all Arbitrators all parties. \)... k ~~if '" p...n "Clh72e---___..... Joh-F. LaFaver, Chairman and counsel for - January 22, 1996 TO: Judith F. DOlgos, Esq, Atty. for Plaintiffs 8150 Derry St Harrisburg, PA 17111-5260 George B. Faller, Jr., Atty. for Defendant 10 East High Street Carl1sle, PA 17013 Charles Rector, Esq., Artibrator 831 Market Street Lemoyne, PA 17043 Robert Kline, Esq., Arbitrator 32 South Bedford Street Carlisle, PA 17013 ,. LEMOYNE AUTO SALES and RICHARD A. QUIGLEY Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW NO. 95-438 CIVIL TERM CHARLES E. SWENGER, JR. (sic) Sweger, a/b/a 5WENGER'S: GARAGE, Defendant JURY TRIAL DEMANDED PLAINTIFFS' RESPONSE TO NEW MATIER ENTERED BY DEFENDANT Paragraphs 1 through 24 of Plaintiffs' original Complaint are herein incorporated by reference. 25. It is denied that the damages were caused in whole or in part by Plaintiffs' comparative negligence, 26. The averment on paragraph 26 is a conclusion of law to which no response is required. However, should a response be required, it is denied that the Plaintiffs' Complaint is barred by the doctrines of waiver and accord and satisfaction. PLAINTIFFS' RESPONSE TO COUNTERCLAIM ENTERED BY DEFENDANT 27. It is denied that the conduct of the Plaintiffs have in any way cause the Defendant to sustain damages of any amount. WHEREFORE, Plaintiff requests that Defendant's Counterclaim be dismissed with prejudice. MIRIN & JACOBSON By Dated: September 28,1995 Attorneys for Plaintiff ~' CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Plaintiffs' Response to New Matter and Counterclaim was served this date by depositing same in the Post Office at Harrisburg. PA, first class mail. postage prepaid. addressed as follows: George B. Faller. Jr.. Esquire MARTSON, DEARDORFF, WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 MIRIN & JACOBSON By Dated: September 28, 1995 Attorneys for Plaintiffs '.1'") en ~ ., "'"= ~-r .-r '":;'> CD e-, ".) "- '" v, ... ORDER OF THE COURT AND NOW, 7)LLtrnh'i/L I J.. 1993. in consl,deralion of the 1.0regoingpetitlon, LJJIV 1.../'I/Avt/L .Esq.CAnIZ.J~..s AECicJiG . Esq, f!.oJ-:,f.('J- /(/: N 'f= , Esq., are appointed arbitrators in the above-captioned action as prayed for. BT!:-.! f J( P. J. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Plaintiffs' Petition for appointment of arbitrators, was served this date by depositing same in the Post Office at Harrisburg, PA, first class mail, postage prepaid, addressed as follows: George B. Faller, Jr., Esquire MARTSON, DEARDORFF, WILLIAMS & OTJ'O Ten East High Street Carlisle, PA 17013 MIRIN & JACOBSON By stUlL/111m L1Q~ J\J~ith F. Dolgos, squire 8150 Derry Street Harrisburg, P A 17111-5260 Dated: September 29, 1995 Attorneys for Plaintiffs ~ () o , ~ ~ -~ ,-.. tl.l!,.-l [,)1 : -( , ~~ff: Cl . c; J..Ju. d Ll;t'l f'. -. II. e> 1"", ~: .. -- ,0:.' ~.. " I."':":.: _. ;~i '. :): ,i j;./j f'~! 'ii.' ('1 ~:.J ".L~ a .:1" c.., ,,' l.:.J tr) u, ~ !-i "' .. ~ ~ !f? =>-, ~;; C'l " L.") " co ~... ... c!5 F,\f'ILESlJIATARLE'-L1ENERAL [)OC\)~9l)lAP I~ C~DYlo.9'Ol_1117PM am.r.s OYI0r'9SOI.2UI P~l LEMOYNE AUTO SALES and RICHARD A. QUIGLEY. Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW NO. 95-438 CIVIL TERM CHARLES E. SWENGER, JR. d/b/a SWENGER'S GARAGE, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON, DEARDORFF, WILLIAMS & OTTO in behalf of Defendant Charles E. Swenger, Jr. d/b/a Swenger's Garage in the above matter. By George . Faller, Jr., Esquire 1.0. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: March 10, 1995 , , CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postago prepaid, addressed as follows: Robert Patrick McPherson, Esquire MIRIN & JACOBSON 8150 Derry Street Harrisburg, PA 17111-5260 MARTS ON, DEARDORFF, WILLIAMS & OT.I'O By Geo ge B. Ten East igh Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: March 10, 1995 F'. II '" ., , \ , U"' l-n , .. ';"1= ',' \.-.- M .. C) -;:r , .. = .J; . (", _4~ ..;11... ~ ~ ~ El- ~ . :i ~ ~~ ., 7.... ~ lilt~ffi '0 ~ 0 < ffii:J ~~ ~h!~ ~~~~ !313 ~Ul ~ ~ ~ ~ ~~~~ ~8 M ~ 8 ~ ~~ ~~ a. .... ~..:. . ~ ~ ~ 8 iffi o eJfJl > t.i~ ~ - ~ ... <~ ~ :( ~~~~ ~ ~..r 0'" iil !3 "'~ c.lffi5~ I~ ~~ I!":l ::l ~ < ~ ~ ~e ~ ~ '0 ~ < ~ ~ . . . ' . f.IJ'ILEll."II1ATAnLLiOENERA,I. ()OC\mllJAN 11J.u CrntcdOYIlV9'OIUI7PM Rnucd DlIl:\'9'DIllUPl.t LEMOYNE AUTO SALES and RICHARD A. QUIGLEY. Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW NO. 95-438 CIVIL TERM CHARLES E. SWENGER, JR. d/b/a SWENGER'S GARAGE. Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER AND CO! INTERCLAIM TO PLAINTIFFS' COMPLAINT TO: LEMOYNE AUTO SALES and RICHARD A. QUIGLEY, Plaintiffs, and their attorney, ROBERT PATRICK McPHERSON, ESQUIRE YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER AND COUNTERCLAIM WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. I. Admitted. 2. Admitted except that the Defendant's name is Charles E. Sweger, Jr. d/b/a Sweger's Garage. 3-4. Denied. To the contrary, Mr. Quigley walked outside and handed the keys to the Defendant. Mr. Quigley did this with knowledge that the Defendant was going to bring the Dodge Aries back to his property in Lemoyne because it was taking too much needed room at the garage. The Defendant had used the truck and trailer before on numerous different occasions. Furthennore, the Plnintiffwas asked on four different days throughout the prior month to please move the Dodge, but did not do so. 5-6. Admitted. 7. It is admitted that the Defendant returned the pickup truck. As to the specific avennents, Defendant responds as follows: a. Denied. To the contrary. the hitch was bent at a 20 degree angle by the Defendant; b. Denied. To the contrary, the hub cap was not bent inward by the Defendant; c. Denied. To the contrary. the exhaust pipe was not twisted so as to need repair by the Defendant; d, Denied. To the contrary, the manual transmission was not broken and the truck could only be driven in second gear by the Defendant; e. Denied. To the contrary. the R & R shift tube, which controls the shifting of the gears in the manual transmission was not broken by the Defendant; and r. Denied. To the contrary, the running and brake lighting systems were not torn by the Defendant. COUNT I - NEGLIGENCE 8. Paragraphs I through 7 of this Answer are hereby incorporated by reference. 9. Any implication that the Defendant used Plaintil1's vehicle without his permission is denied. 10. Admilled that the Defendant owed a duty to the Plaintiff to exercise reasonable care. II. Denied. To the contrary. the Defendant did not breach his duty. 12. Denied. To the contrary, any damages which Plaintiff may have incurred arc exceeded by the damages stated in Defendant's counterclaim. 13. Denied. To the contrary. any damages which were sustained by the Plaintiff arc clearly inflated. 14. Denied. 15. It is denied that the Defendant commitled any wilful, malicious. or careless actions or any other tortious conduct. As to the remaining averments of this paragraph, the answering Defendant is without knowledge or information sufficient to form a belief as to its truth or falsity and proof is demanded. 16. Denied. WHEREFORE, Defendant request that Plaintiffs' Complaint be dismissed with prejudice. COIINT II - BREACH OF CONTRACT 17- I 8. Admilled. 19. Denied. To the contrary, the Defendant was also owed monies on a Dodge Aries that was never paid for parts. labor and storage. 20. Admilled. WHEREFORE, Defendant requests that Plaintiffs' Complaint be dismissed with prejudice. COIINT III - NEGLIGENCE 21. Admilled. 22. Denied. To the contrary. the engine was partially dismantled at the Plaintifi's property by another person who never returned. At that point, parts were missing and damaged prior to being brought to the Defendant's property. 23. Denied. To .he contrary, Defendant's actions were workmanlike and did not breach any duty owed to Plaintiff. 24. Denied. To the contrary, the Defendant was not negligent and owes Plaintiff no damages. WHEREFORE, Defendant requests that Plaintiffs' Complaint be dismissed with prejudice. NRWMATTER 25. The damages were caused in whole or in part by the Plaintitl's comparative negligence. 26. The Plaintiffs' Complaint is barred by the doctrines of waiver and accord and satisfaction. WHEREFORE, Defendant requests that Plaintiffs' Complaint be dismissed with prejudice. COUNTERCLAIM 27. As a result of the conduct of the Plaintiff, the Defendant has sustained damages in an amount that is yet undetermined. WHEREFORE, Defendant demands judgment on his counterclaim against the Plaintiff in an amount less than $20,000.00. plus interest and costs. MARTS ON, DEARDORFF, WILLIAMS & OTTO By / George Faller, J.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: March 13, 1995 Attorneys for Defendant VERIFICATION The foregoing Defendant's Answer with New Maller and Counterclaim to Plaintiffs' Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the 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 correct to the best of my knowledge, infonnntion and belief. To the extent that the content of the document is that of counsel. I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 11904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments. I may be subject to criminal penalties. ,..1 ~ If () ~ {.JCI<zl't'.J. C .~VIV.(.:tJl! 1-. . Charles E. Sweger, Jr. . ~. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant's Answer with New Matter and Counterclaim to Plaintiffs' Complaint was selVed this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid. addressed as follows: Robert Patrick McPherson, Esquire MIRIN & JACOBSON 8150 Derry Street Harrisburg, P A 171 11-5260 MARTSON, DEARDORFF, WILLIAMS & OTTO By George aller, Jr., Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: March 13, 1995 (717) 5604-0828 FAX: 581-1816 ,JUDI'I'II t'QANct:6 DOLCO& ATTORNEY AT LAW 6150 DERRY STREET HARRISBURG, PA 17111.5260 ()~ I' j . ... ,...... ""'L I .' ..<~ Lt C/u.,A....~IJ ,-o,[;,v4. c 'I, ,of ... J. .d.~ JCt".-<- .(.'1 '0.... . ~ ~ 1, 1> - ... l~ ,0(\ .. " .u' ['('III,'" I'V ",.h, 5;;,vl""- Il~l,) ) ) ) ) 1',- ~ I) .. .JeLI,'>\I(j" I ~..jl- ) <!. :S""."'C'\<"l.'''' G-u'''':lLOA4H In The Court of Cocmon Pleas of I,,) ,rCd' ( ,I Cumberland County, Pennsylvania ,/ \,\ (, lJ, 'fc{) V (:/C - ,/ '? ? llo. "', ..,.~-~ 19'/5 ( ,('I" .j "L, -I NL I- lle do .01l111lllly swear (or aHirm) the Con.titution of the United States ~Qalth and thet we ~i11 discharge the (;I that we will support, obey and defend and the Constitution of this Co~on- duties of ("-, office "'i~}"Q~elity. /'-7):L1..}-j cilt.f/7to-. ,?-Or ~ 7- j -(n)'- , .~ /,/ ~~'!ll.r:nan .' ~.i ./ ,....{t.o..f.- C__- - J) i .' , c , I ,'.:, I' , , " [< I. , " , " , " I."., L. , , I I 1 ....WARD I ,-I , WIl, "the" Undersigned arbitrators, having been duly appointed and sworn (or af~irmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) c( 7z:'t./lL..-:U.t-t./J.-t' . Arbitrator. dissents. (Insert name 1: applicable. ) Oa te of Hearing~.J I~ ':).. l- I r, (/ I, I , jat. of Award: ].,1/ ),t.- Iqflro Q.. l/~ %l ,;J.ut~;)V -0').32- 1/' ~ \1" '1" "Cll' --------- -- _ / . " ' . a_r.:urn . "-'. c-i;t';~KQ~~ ~ ~OTIC~ OF ~y OF AWARD ~ow. the .;]Io~av or _q;~"A'J' ,19~, at~, .1:.:1.. the above avard was entered upon the docket and notice thereof given by ~il to the ~arties or their attorneys. Arbitrators' cocpensation :0 be paid upon appeal: $ ~"lI,!r ~:.~Ilc ...L ( c. "!AI"':., UJ( L ) Prothonotary - )0",-, . {( . u.... ,"-(pc 4..' Oe,?u~? 3y: ..J/I"~ In t.n - L:':.: ,.... C'.J r..., n; -. :t.:: 81_ ~ ~~ ~~ ~ " ::l :i 0 .~ H "'\ '7. r- .. i:J 'w ~~ ~ 0 < - i~~ C>:Cl ~.g~l;;~ gjt3 ;~ ~ 0"';.': ffi~ ,",H :x:~ ~ 0 ~o( rJ'i8 ~ ,.:J :> ""n. ... r': ';l n.1 Cll/) ~~~ . B Yl ::: ~ .~ ~.,: ij- '-"~ ~ gm . Ui~ ~:E:~ ';:::~ 0 ::: 7. ~~H ~zu~z o tJ ~~ :> t.i~ lii~~ ~ 0 P. "' ~~. "" ~u~ ~tl ~~~"ul ~~ !31ii l/)!il 0;.. I"..l ~~ t( W .. tI) ~~ - e ....1:/ ::l W tl " < ~ ~ '"''0 '\:l 0( ~gj ~ u'O ~u ~ < U ~1Il ~ e f:J~ Q