HomeMy WebLinkAboutCivil Case: Wagner vs Plan Commission STATE OF INDIANA ) IN THE HAMILTON SUPERIOR COURT
) SS: NO. 2
COUNTY OF HAMILTON ) CAUSE NO. 29D02-0102-CP-0070
GERALD L. WAGNER and )
PATRICIA WAGNER, )
)
Plaintiffs, )
)
v. )
)
CARMEL CLAY PLAN COMMISSION )
and CARMEL CITY COUNCIL, )
)
Defendants. )
MOTION TO DISMISS AND DESIGNATION
OF EVIDENCE IN SUPPORT OF THEREOF
Defendants, the Carmel City Council (the"Council") and the Carmel Clay Plan Commission
(the "Plan Commission"), by counsel, pursuant to Indiana Trial Rule 12(B), moves the Court to
dismiss the amended complaint filed by Plaintiffs Gerald L. Wagner and Patricia Wagner as it lacks
merit, no violation of the Open Door Law occurred and is time-barred. In support thereof, the
Council submits its Memorandum of Law in Support of Motion To Dismiss, submitted
contemporaneously herewith, and designates the following evidence.
1. Affidavit of Ramona Hancock and all exhibits attached thereto.
2. Affidavit of Diana Cordray and all exhibits attached thereto.
3. Affidavit of Anne Mullin O'Connor.
4. Commission Meeting Minutes of October 17, 2000, attached as Exhibit A to the
Affidavit of Ramona Hancock.
5. Special Study Committee Meeting Minutes of December 5, 2000, attached as Exhibit
B to the Affidavit of Ramona Hancock.
6. Special Study Committee Meeting Minutes of December 12, 2000, attached as Exhibit
C to the Affidavit of Ramona Hancock.
7. Agenda for Special Study Committee Meeting of December 12, 2000, attached as
Exhibit D to the Affidavit of Ramona Hancock.
8. Certification of Commission's Recommendation on Petition for Parkwood Crossing
West PUD dated December 21, 2000, attached as Exhibit E to the Affidavit of
Ramona Hancock.
9. Plan Commission Rules of Procedure, approved December 21, 1999, attached as
Exhibit F to the Affidavit of Ramona Hancock.
10. Council Meeting Minutes of January 8, 2001, attached as Exhibit A to the Affidavit
of Diana Cordray.
11. Land Use Committee Meeting Minutes of January 18, 2001, attached as Exhibit B to
the Affidavit of Diana Cordray.
12. Notice for Land Use Committee Meeting of January 18, 2001, attached as Exhibit C
to the Affidavit of Diana Cordray.
13. Land Use Committee Meeting Minutes of January 31, 2001, attached as Exhibit D to
the Affidavit of Diana Cordray.
14. Notice for Land Use Committee Meeting of January 31, 2001, attached as Exhibit E
to the Affidavit of Diana Cordray.
15. Council Meeting Minutes of February 5, 2001, attached as Exhibit F to the Affidavit
of Diana Cordray.
-2-
•
Respectfully submitted,
MOLITOR, GRISHAM & YESTER, P.A. McHALE, COOK & WELCH, p.c.
11711 N. Meridian St.. Suite 200 1100 Chamber of Commerce Building
Carmel, IN 46032 320 North Meridian Street
(317) 843-5511 Indianapolis, Indiana 46204
(317) 634-7588
John R. Molitor [9313-49]
Douglas C. Haney [11207-49]
By
Steven D. Hardin [16734-53]
Brad R. Maurer [21730-49]
Attorneys for Defendant, Carmel Clay Attorneys for Defendant, Carmel City Council
Plan Commission
-3-
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served upon
the following by first class United States mail, postage prepaid, this _ day of March,
2001:
Gregory K. Silver
342 Massachusetts Ave., # 400
Indianapolis, IN 46204
(317) 263-9417
Jack Lawson
Daniel Deeb
Randall L. Morgan
200 E. Main Street, Suite 800
P.O. Box 800
Fort Wayne, IN 46801-0800
(219) 422-0800
Brad R. Maurer
249088 -4-
STATE OF INDIANA ) IN THE HAMILTON SUPERIOR COURT NO.2
) SS:
COUNTY OF HAMILTON ) CAUSE NO. 29D02-0102-CP-0070
GERALD L. WAGNER and )
PATRICIA WAGNER, )
)
Plaintiffs, ) Post-it7)Fax Note 7671 Date// 7 IPa°yes,
T d i�i�r�!Fro /2/2 �27
V
V. ) Co//DDeeppttt.. ( Co.
) Phone# Phone#
CARMEL CLAY PLAN COMMISSION ) Fax# /„ //._ ��/ ') Fax#
and CARMEL CITY COUNCIL, )
)
Defendants. )
SUPPLEMENTAL AFFIDAVIT OF RAMONA HANCOCK
Ramona Hancock, being duly sworn, deposes and states:
1. My name is Ramona Hancock. I am over 18 years of age, and I suffer from no
disability that would render my testimony incompetent.
2. I am fully competent to make this Affidavit, and I have personal knowledge of the
facts stated herein.
3. I am an Indiana resident and currently serve as the Secretary and Administrative
• Assistant for the Carmel Plan Commission. I have served in this position continuously since
approximately October, 1992. I maintain all official records of the Plan Commission and its
committees, including the public minute books, and am the officer having the legal custody of the
official records for the Plan Commission and its committees. The Special Study Committee is a
committee of the Plan Commission.
4. The documents attached hereto as Exhibits A through F are certified and attested
to be official, true and accurate copies of records of the Plan Commission and its committees.
Exhibits A through F are identical to the exhibits attached to my March 9, 2001, affidavit,
0
except for Exhibits B and C. Exhibits B and C now include executed signature pages. Exhibit
B also includes page 14, which originally was unintentionally omitted.
5. Notice for the December 12, 2000, Special Study Committee meeting ("December
12 Meeting") was given by posting the notice and agenda, attached hereto as Exhibit D, at the
entrance to the location of the meeting at Carmel City Hall, in the public display case at Carmel
City Hall, at least forty-eight (48) hours before the meeting, excluding Saturdays, Sundays and
legal holidays. Carmel City Hall, located at One Civic Square, Carmel, Indiana, is the principal
office of the Plan Commission and its committees, including the Special Study Committee, and
is the building where the December 12 Meeting was held. I also delivered notice of the December
12 Meeting by depositing in the United States mail with postage prepaid to all news media which
delivered by January 1, 2000, an annual written request for such notices.
6. I was present at the December 12 meeting, and no rule, regulation, ordinance, or
other final action was adopted by reference to agenda number or item alone at the December 12
Meeting. The December 12 Meeting was open to the public, and members of the public were
present and spoke at the December 12 Meeting. As the December 12 Meeting progressed, I kept
a memorandum on which I recorded the members of the Special Study Committee, the governing
body, present at the meeting. I also recorded in the memorandum the general substance of all
matters proposed, discussed and/or decided at the December 12 meeting by the Special Study
Committee. I also recorded in the memorandum the general substance of all matters discussed by
the members of the public. I also recorded in the memorandum all votes taken at the December
12 Meeting.
7. The memorandum of the December 12 Meeting was available to the public for the
purpose of informing the public of the Special Study Committee's proceedings and was open for
0
public inspection and copying by at least mid-January, 2001.
I AFFIRM, UNDER THE PENALTIES FOR PERJURY, THAT THE
FOREGOING REPRESENTATIONS ARE TRUE.
By: A /j1 <
Ramona Hancock, Secretary and
Administrative Assistant for the
Carmel Plan Commission
Executed on o? ,49a,
252159.1
0
03-16-01 10:00 MCHALE COOK & WELCH ID=3176342925 P10/11
STATE OF INDIANA ) IN THE HAMILTON SUPERIOR COURT
) SS: NO. 2
COUNTY OF HAMILTON ) CAUSE NO.29D02-0102-CP-0070
GERALD L. WAGNER and )
PATRICIA WAGNER, )
)
Plaintiffs, )
)
v. )
)
CARMEL CLAY PLAN COMMISSION )
and CARMEL CITY COUNCIL, )
)
Defendants. )
AFFIDAVIT OF RAl1IONA HANCOCK
Ramona Hancock, being duly sworn,deposes and states:
1. My name is Ramona Hancock and I am over 18 years of age.
2. I am fully competent to make this Affidavit and I have personal knowledge of facts
stated herein and/or the facts stated herein are based upon true and accurate records of the Carmel
Plan Commission("Plan Commission").
3. I am an Indiana resident and currently serve as the Secretary and Administrative
Assistant for the Plan Commission.
4. Notice of the December 12,2000,Special Study Committee meeting was given both
at the December 5 Special Study Committee meeting and by posting notice of the meeting,attached
as Exhibit D hereto,at Cannel City Hall at least forty-eight(48)hours in advance of the meeting and
by providing notice of the meeting to the media.
5. The documents attached to this affidavit as Exhibits A through F are certified to be
official,true and accurate records.
03-16-01. 10:00 MCHALE COOK & WELCH ID=3176342925 P11/11
I.
I AFFIRM,UNDER THE PENALTIES FOR PERJURY,THAT THE
FOREGOING REPRESENTATIONS ARE TRUE.
By: �//�''.T-?.11-,/(%J'i%Vi....:,_
Ramona Hancock, Secretary and
Administrative Assistant for the
Cannel Plan Commission
Executed on i�� (//k/ c 7 Cam%/
2479322
•
COUNTY OF HAMILTON ) ' : T.IT..THE HAMILTON SUPERIOR COURT
SS:
STATE OF- INDIANA —, .
• ) • . . . .:='.-.CAUSE NO. 290 0 2- 0 to 2 OR
GERALD L. WAGNER and .
PATRICIA WAGNER,
- PLAINTIFF • . . _ --!�
vs .
CARMEL CLAY PLAN COMMISSION:.and • � �� \-`1
CARMEL CITY COUNCIL,. . •
<b
l
DEFENDANT S 9 N
.
sioNS. . '�
■
David' Cremeans.;:.:President ;
TO DEFENDANT: (Name) Carmel Clay. Plan. Commission
(Address) One. Civic Square.
' Carmel, IN. 460,33.',,::
You are hereby. notified that:::youhave been sued by the person
named as Plaintiff and in the Cour't.' &.idicated above.
The nature' of 'the suit agairiSt 'you. is stated in the Complaint
which is attached to this . Summons-::.: Ialso states the relief sought or
the demand made against you by tWPl1intif f .
An answer or other appropriate :response. in writing to the
Complaint must be, filed either .by<you: or your attorney within twenty
( 20 ) days commencing the day ,;after>:you receive this Summons, (or
twenty-three ( 23) days if this ,Sons was received by mail) , or a
judgment by default. may be rendered..against you for the relief demanded
by Plaintiff .
If you have a,.claim for relief. against the Plaintiff arising from
the same transaction sor occurrence;r,..you must assert it in your written
answer . .
FEB 0 2 2009 a. X11
•
Dated
CClerk. '.Hami' -. ':y. : S '•ei�""'or court
Gregory K. Silver S • 34-49:-.
Beckman Lawson LLP
Attorney for Plaintiff. Attorney;°Numb'er PO Box 800
342 Massachusetts Av. #400 . Ft. Wayne, In 46801-0800
Co-Counsel for Plaintiffs
Address 219 422-0800
Indianapolis, IN .46204 .
(317) 263-9417
Telephone
The following manner of :service.service ouimons is hereby designated:
_ - Registered or Certified::Maal
Service on individual at:<'above address : County
Service on agent: i
: ( specfy} '=
Service by Publication .'
o •
•
CLERK'S. CERTIFICATE OF MAILING (
I hereby certify that on the. • day of , 19 `, I
mailed a .copy 'of this Summons arid'-a .copy of the Complaint to t=ae -- ---
.. •
Defendant - by mail, repuesting a
return receipt, at . the address. furnished by the Plaintiff.
Dated •
.Clerk..Hamilton County Courts
p
RETURN ON SERVICE Off' SUMMONS BY MAIL
•
°"
hereby certify that the. attached .return receipt was received by
Nm s , wing that the s�uinmons and a copy of the Complaint mailed to the
Den ant, was accepted on the. day of ,19
- . :I -hereby certify that the attached return receipt was received by
me on the .. day of . • , 19 , showing that the
summons and a copy of the Complaintas returned not accepted.
. I hereby certify that the: attaced return receipt was received by
me showing that the Summons and a..'copy of the Complaint mailed to the
Defendant, was accepted by (age) . on
behalf of said Defendant on the.. - day of ,19
Cl.erkHamilton County Courts
SERVI.CE`ACKNOWLEDGED
A copy . of• the. within Summons and. a copy of the Complaint attached
thereto were received by me at: .
Dated .
..Signature of Defendant
•
RETURN OFSERVI:CE 'OF SUMMONS
I 'hereby, certify that I have .served the within Summons :
( 1) By delivering a copy of the .sumrnons and a copy of the Complaint to
• the Defendant on the day o:f- - , 19
( 2 ) By leaving a copy of the Summonsand a copy of the Complaint:
a) at the :dwelling place.: or..:usual place of abode of the
Defendant
b) with a person of su•itableage and discretion residing
therein, namely . and by mailing a copy of the
Summons to the Defendant , by .firs;t`.class mail, to the address listed on
the Summons , the last known addre,ss. :`of the Defendant.
R
Sheriff of Hamilton county, Indiana
BIT
•
02//s 01/01 11:19 FAX 2194201013 Bechar,Lawson,Sandler Z002
• uV'THELitg o� .. • • COURT
•
GERALD L. WAGNER and ��` �E -2 Nu 9,,)2
PATRICIA WAGNER . ' •
(Caprion) VS- )Case ftl(lbf bee. _ D`�
CARMEL. CLAY PLAN COMMISSIO �}�,�...��`-�°` (ra e'st�pPlie y lecs,hen cam is filed)
CARMEL CITY CALINCII..
CLERK.IlA II TOf1 COUNrt COURTS, •
APPEARANCE BY ATTORN� YI N CIViL. CASE
Party Classification: Initiating % gesiOndiiig Intervening
1. The undersigned attorney and all attorneys listed-ontthis;form now appear in this case for the following
parry member(s): Plaintiffs'
2. Applicable attorney information for service'•as resru,ed:by Trial Rule 5(B)(2) and for case
information as required by Trial Rifles 3.1 and 77(B)is•as:follows:
Name: Greeory K.Silver _' Arty Number: 331-49
Address: _ 342 Hassachuse.t.ts •Av.: 4Q0 Phone: 263-9417
Indianapolis, IN • 461.04. • FAX: 263-9411
Coiaputer Address:
[List on continuation page the addiE onal to i neys.appearingfor above parry member(s)f
3. There are other parry members: ..Yes No..x_. (I f"yep Ifs?an continuation page.)
4. If fuss initiating parry filing this.ccm, the Clem:i§-.requested to assign this case the following Case
Type under Administrative Rule 8<b)(3): v3..
eee:•Doo V .olations
5. I will accept service by FAX at the above np r oted cutinber: Yes x No •
6. This case involves support issues'. Yes-. _•• Noy•(eyes. supply social security plumbers for all
family members on connnuation page-)
7. There are related cases: Yes. • No elf}r : liiion continuation page)
8_ This form has been served on all other parties . C.ertifiaate of Service is attached: Yes x No
9_ Additional information required by local rule • • •
Dated,: 2/4- /O1 -Law•
. •:A,ttO6tey information shown above
•
AppcaraDea Format for,Use by Attor04*in Civil Cal,es::.tl,0?S:•'. ;}. •
02/01/01 11:19 FAX 2194201013 Beclman,Lawson,Sandler a003
,' .
APPEARANCE FORMAT--CONTINUATION PAGE(Civil Case for Use by Attorney)
Case Number:
First Listed Party Member: _ ••
Continuation of Item 2(Attorney information for party member,.as applicable): _ •
Jack.W. Lawson 8719-02
Name:•:�uda.ii f Mnr r� Atty Number: 11388-�+4 • . .
Address: Beckman Lawson, LLP Phone: (219.)• 422-0800 •
200 E. in t., S�i.te , P.O. x O-FAX• (219) 420-1013
P6tc tayrte, 111-4-61301=0/300 Computer Address: _ • .
•
Name: . Any Number: • _ .•
Address: Phone: • - w.
• FAX:
Computer Address: .
Name: Any Number: _
Address: Phone:
• FAX: .
. Computer Address:•
Continuation of hem 3 (Other party members not represented by this attorney)
Continuation of Item 6 (Social Security numbers of all family members in cases involving support):
Name: a SS n Name: ' SS4 •
Name: SS 4 Name: SS#
Name: SS 4 Name: SSA
Name: . SS 4 . _ Name: SS4
•
Continuation of Item 7 (Caption and case number of related cases):
Caption Case Number •
-- Caption Case Number ' • '
Caption _ Case Number , .
--_.._.Caption- .. -- ....-- •-- • -- • _•• • -• -• - . . ' . Case Number
Aushnrfy:Parsuant to Trial Rule 3.J,this form shall be f+lzd at zh'e time an ado),is commenced or when a parry first
appears In anagencies,the requested information shall be suppEsd n en it becomes available. Parties shall advise the court
of a change in information previously provided to the court This format is approved by the Division of State Court
Administration. . - •. --
Use'addirional continuation pages if needed•CLb055b - .
•
F !LED
STATE OF INDIANA ) IN THE HAMILTON SUPERIOR COURT
COUNTY OF HAMILTON ) 2001 FE -2 Kg.§P\10.NO. �9 0 02- 0 10 2 p t 'b ' 1i
GERALD L. WAGNER and 1
PATRICIA WAGNER, CLERK,HAMILTON COW Y COyR1S
)
Plaintiffs, )
)
v. ) COMPLAINT
)
CARMEL CLAY .PLAN COMMISSION )
and CARME.L CITY COUNCIL, )
)
Defendants. )
COUNT I
Plaintiffs, Gerald L. Wagner and Patricia Wagner, by counsel, for Count I of their
Complaint against the Carmel Clay Plan Commission (the "Commission") and the
Carmel City Council (the "City Council") allege and state:
1. An application to rezone the real estate described on the addendum
attached to this Complaint as Exhibit "A" was considered by the Commission in
December 2000 (the "Application"). The Application proposed to allow a new
commercial development commonly known as Parkwood West on said real estate.
2. Plaintiffs are the owner of real estate at 21 l West 96111 Street ("Plaintiffs'
Real Estate"). Plaintiffs' Real Estate is located in affected proximity to Parkwood West.
3. Plaintiffs reside at Plaintiffs' Real Estate and would be adversely affected
by Parkwood West and its traffic and other impacts to the area.
4. On December 12, 2000, the Special Study Committee (the "Committee"),
a subcommittee of the Commission, held a special meeting (the "Meeting"). The
purported purpose of the Meeting was to allow the Committee to deliberate and make
recommendations regarding the traffic impacts relative to the Application.
5. Although only 7 of the 15 members of the Commission were also
members of the Committee, more than 7 Commission members (a majority) actually
attended the Meeting.
6. At the Meeting, the Committee also received information from others,
including representatives of the applicant.
7. The Meeting constituted a "meeting" of the Commission under IC 5-14-
1.5-2(c).
8. The Commission took "official action" on "public business" at the
Meeting as said terms are defined at IC 5-14-1.5-2.
9. The Meeting was not noticed, held or conducted in accordance with IC 5-
14-1.5-4 and IC 5-14-1.5-5.
10. Plaintiffs were not aware of the Meeting, that the Committee would
• receive comments from those other than Committee members or that a majority of the
Commission would receive information, deliberate and make recommendations at the
Meeting. Plaintiffs did not attend the Meeting.
• 11. The Committee presented its recommendation and findings to the
Commission at or before a public hearing of the Commission concerning the Parkwood
West rezoning proposal on December 19, 2000 (the "Hearing"). The Commission
specifically did not allow any remonstrator to give traffic-related testimony at the
Hearing incorrectly stating that it had already allowed such testimony at the Committee
J:\User\DJD\Work\Iicartlandcomplaint.doc 2
•
meeting. Based in whole or part on the findings and recommendations of the Committee,
following the Hearing, the Commission voted 11-3 in favor of the Application.
12. Plaintiffs became aware of the Meeting and its attendance only after
counsel for Plaintiffs were orally advised by Commission staff on January 5, 2001 that a
majority of Commission members attended the meeting. In providing this verification,
the Commission staff stated that they were relying on the memories of those who
attended the Meeting because other means of verification did not then exist.
13. Under IC 5-14-1.5-7(a), Plaintiffs are entitled to maintain an action against
the Commission to obtain a declaratory judgment, enjoin threatened or future violations
of IC 5-14-1.5-1 et seq., or to declare void any decision of the Commission which was
wholly or partially based on a meeting held in violation of IC 5-14-1.5-1 et seq.
• WHEREFORE, Plaintiffs respectfully ask that this Court, after considering the
evidence in this case, enter an order:
(a) Declaring void the decision of the Commission regarding the Application,
(b) Declaring void the decision of the Committee regarding the Application,
(c) Enjoining the Commission and Committee from future violations of IC 5-14-
, 1.5-1 et seq.
(d) Awarding Plaintiffs their reasonable attorney fees, and
(e) Awarding Plaintiffs all other just and proper relief.
•
J:\User\DJD\Work\hcartlandcomplaint.doc 3
•
COUNT II
Plaintiffs, by counsel, for Count II of their Complaint against the Commission and
the City Council, allege and state:
14. Plaintiffs reallege and incorporate Paragraphs 1-13 of this Complaint as if
fully set forth herein.
15. IC 36-7-4 and Section 31.6.4(6) of the Carmel Zoning Ordinance require
that the Commission conduct a public hearing on the Application before the City Council
may act upon the Application.
16. The City Council has been advised by remonstrators to the Application
that the Commission has not yet held the required public hearing in accordance with law.
Nonetheless, the Application is currently pending before the City Council.
17. The City Council is expected to take its final vote on the Application to
uphold or reject the recommendation of the Commission as soon as February 5, 2001.
Such action by the City Council constitutes a threatened violation of IC 5-14-1.5-1 et seq.
WHEREFORE, Plaintiffs respectfully ask that this Court, after considering the
evidence in this case, enter an order enjoining the City Council from acting upon the
Application, awarding Plaintiffs their reasonable attorney fees and for all other just and
proper relief.
Respectfully submitted,
KAI
Grego4 K. Silver, #331-49
342 Massachusetts Av. #400
Indianapolis, IN 46204
(317) 263-9417
J:\User\DJD\Work\heartlandcomplaint.doc 4
' and
BECKMAN LAWSON, LLP
Jack W. Lawson, #8719-02
Daniel J. Deeb, #19320-53
Randall L. Morgan, #18087-49
200 E. Main Street, Suite 800
P.O. Box 800
Fort Wayne, IN 46801-0800
(219) 422-0800
Attorneys for Plaintiffs
•
•
•
J:AUserADJD\Work\heartlandcontplaint.doc 5
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