(Brotherhood of Railway, Airline and Steamsh·n Clerks, ( Freight Handlers, Express and Station. Fmp'-yes PARTIES TO DISPUTE: (rangor and Aroostook Railroad Company



(1) Carrier violated the rules of the current Clerks' Agreement dated September 31, 1950, as amended, particularly, scope Rule 1 (b) and Rule 3b, among other:., when effective, at close of work, Friday, August 28, 1970 it abolished its last remaining clerical position at Searsport, Maine, and unilatcrally assigned all clerical duties, work and incidentals appurtenant thereto, that were performed by tl,e Clerk at this point to employees, (Supervisory Agent and Assistant Agents) of anokher craft and class who held no seniority rights under said agreement for its performance.

(2) Carrier shall now compensate, Clerk, Mr. A. A. Ashey, Jr. for all wage lasses commencing August 31, 1970 and everyday thereafter until said violations are corrected a
OPINTON OF BOARD: This claim arose when Carrier abolished its last remaining
clerical position at Searsport, Maine, effective August 28,
1970, Claimant was the incumbent of the position.

Prior to August 28, 1970, the Carrier naintained the following station `once at Searsport.

TITLE OF POSTPION ASSIGNED HOURS REST DAYS
Germinal Agent 8:00 A.M. - 12:00 Noon Sunday
1:00 P.M. - 5:00 P.M.
Assistant Agent 6:30 A.M. - 2:30 P.M. Sunday & Monday
Assistant Agent 8:00 A.M. - 12:00 Noon Sunday & Tuesday
1:00 P.M. - 5:00 P.M.

'1er'< 6:00 A.M. - 2:00 P.M. Saturday & Sunday




TITLE OF POSITION ASSIGNED HOURS REST DAYS
Terminal Agent 8:00 A.M. - 12:00 Noon Sunday
1:00 P.M. - 5:00 P.M.
Assistant Agent 6:30 A.M. - 2:30 P.M. Sunday & Monday
Assistant Agent 6:30 A.M. - 2:30 P.M. Saturday & Sunday

Before this dispute arose claimant spent approximately three hours daily in the yard with the switcher crew of a local which ran between Northern Main Junction and Searsport weighing of cars. According to Carrier "The remainder of his day was spent in general station work a after the abolishment of the position, we first note a statement made on the property by Carrier, to by Mr. Ashey because there was no. longer sufficient work to justify retaining a full-time clerk" (Emphasis supplied). This is an admission that some clerical work remained after the abolishment of the clerical position. We note also that, in refuting Petitioner's contention that almost all cars must be weighed, Carrier conceded that a "very And since there is no dispute that claimant previously performed the car weighing work, this, too, constitutes an admission that some of the clerical duties remained after the position was abolished. It is also noteworthy that the starting time of the second assistant agent was changed from 8 am to 6:30 am, which placed both the agents on the common schedule of 6:30 2m to 2 pm. This change is highly suggestive that the second assistant agent was needed at an earlier starting time to perform clerical work previously performed at that time by the claimant. In light of the foregoing, and on the whole record, we find that a preponderance of evidence of record shows that some of the duties of the clerical position remained after it was abolished and that thereafter such duties were performed by the remaining station force.

On these facts the Petitioner contends that Carrier unilaterally assigned the duties of the abolished clerk position to the Terminal Agent and Assistant Agents and that such action violated Rules 1(b), 13(a), and 49 of the applicable Agreement. Carrier's position is that the duties of the abolished position did not belong to the clerks exclusively, that other crafts, as well as supervisory personnel, had performed these duties, that Agents and Operators were the first to perform the station work, that the Terminal Agent and members of another craft had, in fact, performed all of the work of claimant during the period of his employment and that because of the erosion of traffic at that terminal, the ebb and flow principle did, in fact, provide for the use of the craft of employees necessary to perform the station work.

                          Docket Number CL-19727


              The pertinent Rules are as follows:


              "RULE 1 - SCOPE- EMPLOYES AFFECTED


              (b) Positions and work within the scope of this agreement belongs to the employes covered thereb in this agreement shall be construed to permit the removal of positions or work from the application of these rules, oxcept in the manner provided in Rule 49."


              "R('1,1? 13 - CHANGE IN TITLE, RATE OR CHARACTER OF WORK


              ta) When there is a sufficient increase or decrease in the duties and responsibilities of a position, or change in the character of the service required, compensation for that position will be promptly adjusted with the General chairman, but established positions shall not be discontinued and new ones created under a different reducing the rate of pay or evading the application of these rules."


              "RULE 49 - DATE EFFECTIVE AND CHANGES


              This agreement shall be effective as of September 1, 1949, and shall continue in effect until it is changed as provided herein or under the provisions of the Railway Labor Act as amended. Should either party to this agreement desire to revise or modify these rules, thirty (30) days' written advance notice, containing the proposed chan and conference shall be held immediately on the expiration of said notice unless another date is mutually agreed upon."


        Under prior Opinions of this Board the text of Rule 1(b) above has been held to preserve to the Clerk's Organization all work being performed under the Clerks' Agreement, on the effective date thereof, until it is negotiated out in the manner provided by Rule 49. Also this preservation of work has been held to be paramount to the defenses asserted herein by Carrier, including the principle of ebb and flow. In commenting on a text similar to the instant Rule 1(b) in Award 6357 (McMahon), this Board stated:


              "It is true, as Carrier contends, that for many years prior to filing of these claims, approximately 35 years, that a portion of the crew calling duties was performed by Telegraphers, or other clerical employes. and such was the custom and practice on this particular railroad. But when the Ag


r
                    Award Number 19719 Page 4

                    Docket Number CL-19727


        "July 1, 1945, and the Scope Rule was rewritten, we must hold that the practice and custom of using employes other than regularly assigned Crew Callers, was completely abrogated by the parties when the Scope Rule 1 was rewritten, and, further, that the Scope Rule as rewritten is clear and concise and is in no way ambiguous. It is,therefore, the opinion of the Board that Carrier has violated the provisions of the Scope Rule as alleged. Nor can it be said that a continuance of the practice from the effective date of the rewritten Scope Rule to the time of filing the claims herein, on June 29, 1949, would reestablish the custom and practice as formerly under the original Scope Rule."


The same text was before us in Award 7129 (Carter), wherein this Board said:

        "The record is clear that at the time the scope rule was agreed upon, Clerks were performing the work in question. The rule preserves the work for the Clerks. Awards 6141, 6357, 6444, 6937, 7047, 7048. While some of the scope rules in the foregoing cases provide in effect that positions may not be removed from the agreement except by negotiation, the rule here involved p be removed except by agreement. The use of the term 'work' in addition to the term 'positions' must be given meaning. We must presume that the propriety of the rule as written was fully considered by the parties before it was agreed upon. The work here involved was taken from Clerks and given to Telegraphers without negotiation. It is a violation of the rule."


This Board's rulings in Award 8500 (Daugherty) are also pertinent, since that Award dealt with a dispute quite similar to the instant dispute. In that Award we stated that:

        "* When the Carrier abolished Clerical Position No. 196,

        at least some of the work previously associated exclusively with

        said position remained to be performed; and after said abolition it

        was performed by the Agent. The work of the clerical position was

        not wholly abolished; at least some of it was transferred to the

        Agent's position, i.e., it was removed from the scope of the Clerks'

        Agreement and placed under the scope of the Telegraphers' Agreement.

        Then, under this Board's rulings in numerous Awards (e.g., 5785, 5790,

        and 7372) interpreting this same Rule 1 (e) or similar rules and hold

        ing that work is the essence of positions, said Rule prohibited the

        Carrier from acting as it did in the instant case. In the absence of

        the language of this Rule as interpreted by this Division, the so-called

        'ebb and flow' principle would apply and Carrier's behavior would be

        judged blameless. But said language and interpretation compels the

        conclusion that Carrier's abolition of Clerical Position No. 196 in

        the manner it did constituted violation of said Rule. ****"


        See also Awards 11586 (Dorsey), 12414 (Coburn), and 11127 (Dolnick).

                    Award Number 19719 Page 5

                    Docket Number CL-19727


It is true that Award 13249 (Hamilton), cited by Carrier, did deny a claim involving these same parties and this same scope rule. However, that Award dealt with a dispute concerning unassigned work performed on the claimant's rest days by a tel claimed to be preserved to the clerks by the scope rule. More important, Award 13249 did not discuss this Board's above cited rulings on the meaning of the term "positions and work" in the instant rule and, consequently, we believe it is not appropos to the issues raised by this record.

On the basis of the foregoing Awards, and on the whole record, we find that Carrier violated the Agreement. However, business at Searsport was on the decline when this claim was progressed on the property; the position of the second Assistant Agent was abolished on January 29, 1971, five months after this claim arose. We are therefore mindful that, while the instant record shows the continued existence of some of the duties of the abolished clerk position, the situation may have changed since this record was made, Consequently, we intend that our Award sh the duties of the clerical position was in fact performed by the retained station force and not otherwise. Accordingly, and upon the stated condition, we shall sustain the claim for the period August 31, 1970 until the end of the violation.

        FINDINGS: The Third Division of the Adjustment Board, upon the whole record and all the evidence, finds and holds:


        That the parties waived oral hearing;


That the Carrier and the Employes involved in this dispute are respectively Carrier and Employes within the meaning of the Railway Labor Act, as approved June 21, 1934;

That this Division of the Adjustment Board has jurisdiction over the dispute involved herein; and

        That the Agreement was violated.


                      A W A R D


        Claim sustained in accordance with the Opinion.


                            NATIONAL RAILROAD ADJUSTMENT BOARD

                            By Order of Third Division


ATTEST:
Executive Secretary

Dated at Chicago, Illinois, this 30th day of April 1973.
          CARRIER NEMBERS' DISSENT TO AWARD :i0. 19719

          DCCKET N0. CL-19727


This Award is palpably erroneous and we must vigorously dissent thereto.

        The Neutral states:


          "* ` * More important, Award 13249 did not discuss this Board's above cited rulings on the meaning o_° the term 'positions and work' in the instant rule and, consequently, we believe it is not appropos to the issues raised by this record."


Award No. 13249, cited by the Carrier, involved the some parties and involved the identical rule as in the dispute here. The orgais0ation listed the same Avards in that submission as were cited in the instant case. None of the wards quoted in this Award (No. 19719) involved thi_ Carrier, nor in fact did any of cited Awards.

        In Award No. 13249 Referee Hamilton stated:


          "This Board has held on numerous occasions, that where the work at a particular location decrease, and there is telegrapher work remaining, it is proper to retain the telegrapher, and assign to him clerical work to fill out his tour of duty, when he is not occupied with telegraphy or communication duties.


          "In this particular case, the record shows that the work load decreased on Sundays, so that only one employe was required. Telegrapher duties remained t be performed. Therefore, in essence, the Carrier abolished the position of clerk, by failing to call him on Sunday, and assigned this work to the talegrapher. We are of the opinion that the Carrier had the prerogative to act in this manner.


          "There is no question that if the volume of work for the regular days of the position would have so diminished, the Carrier could have properly acted in the same manner, and resigned the remaining duties of the clerk to tae tale ;rcpher. We see no reason that this same procedure would not be applicable in the instant case."

To say that .Award No. 13249 "is not appropos to the issues raised in this record" is, to say the least, incredible.

        This is truly a maverick Award and, as such, is a nullity.


x. F. M. Braidwood

P. C. Carter

    -~.< (I,_ .4


;~
f~,s _ , J . if' .' n..
W. b. Joa,s

        ~A~.r~


G. L. Naylor

G. i·1. Youhn ( f
        LABOR P~ENBER' S ANSWER

                TO

                CARRIER i'EI,1BERS' DISSENT TO AWARD 19719 (DOCKET CL-19727)


            Notwithstanding statements made by Carrier Members in their Dissent, Award 19719 is a sound decision. It correctly interprets Rule 1(b) of the parties' Agreement reading:


              "Positions and work within the scope of this agreement belongs to the employes covered thereby, nothing- in this agreement shall be construes', to permit the removal of positions or work from the application of these rules, except in the vanner provided in Rule 49." The clear literal language of Rule 1(b) has been the subject of decision many times by this Board. Sore of these decisions were cited by the Peforee in support of his correct holdings in AwsrC; 197110-. In addition to the Awards cited, the Referee could have also cited Award No. 1 of Public Law Board No. 954 adopted September 8, 1972. In that decision, Chairman and Neutral 1'ember.P"r. John H. Dorsey, decided a dispute cont quoted,above. Award No. 1 of Public Law Board 954, among other things, held:


                  "The weight of authority of Third Division, National

                  Railroad Adjustment Board case law co-nel:- fln<lin~g

                  that w:i°!1 the Fcope Rule of an anrnn-,nL o.-..,~.r.··~,~,~o.~

                  posM.ons ar.d mork' that we^k once aSSign" !"7 aV

                  cqrrler to ern^7.o e: within ".^.e collective -i:~in_^

                  unit thereby becomes vested w4=hin- the

                  unit and may nit to ^Fmeve exc~F~t by agreeme.^.t

                  kietween tg r4e s.

                  t ~t ~r


                  Carrier's alleged de°ense of past practice fails for the following reasons: (1) a Scope .Mile such as


y .S!v
      "paragraph (b) in the BRAC Af-reement is not ambiguous in the light of the case law of the Third Division, .'!ational °ailroad Adjustment Board; (2) parole evidence is admissible, material and relevant in the interpretation of an ^_mbi.-uous provision of an aprreement only to arrive at the intent of the parties; or, to find history, tradition,, custom exclusivity of contractual investment of rif-ht to work tinder a scope rule general in nature - paragraph (b) of the confronting Scope Rule is specific;


      The economic conseauences of a bona f?-de contract are not material, relevant or opersuasive value before a "orum char-ed with its interpretation and application. If a party to a collective bargaining af·reement .`.'finds, b·.· experience, that as to it the terms) are economically onerous, the remedy is collective far.-ainin-. This ?oard is without "uri3diction to entertain such an argument and resolve it by fiat.


        ~ t


      For the foreroinf; reasons ire find and hold that Carrier violated and violates raragraph (b) of the Scope Pule when it assigned or assigns the work herein involved to an employe rot within the collective bar^aininC unit of the BPAC Agreement. (Underscoring supplied)


Thus it is clear, notcrithstandin7 what has been said in Carrier I"embers' Dissent, the clear unambiguous provisions of Pule 1(b) vests in cmployee covered t:; the Cler!;s' Agreerent work per- formed ;Y Clerks until such `=re as it is negotiated out in the manner provided. by rule 44.
Dissenters rely on the unsound and incorrect decision in Award 13249. Award 13249 is i-rrong for at least three reasons.

                              -2- LABOR '!Ei'BTFP'S AidS'_ER TO CADET " .'nERS' '2?. ':~;T TO Ae'ARD 171 (DOCKET CL-19 ,727) .

This is vividly demonstrated by the Referee's lan;;ua.-e explainin,-, that "it is not appropos t 19719 opens with a partial quote of the e:cplanation why Award 13249 is in error. 7he full.p<=r.,Craph _"rom which this partial quote v-s extracted i:: repeated below:

      "It is ;:rue that Award 13249 (Hamilton), cited b;Y Carri_-r, did deny a claim involvinIg these sa^': p:rtieS 'nd this sain°_ .^-.cope rile. Hol;ever, that A~rarP. ce_-=t wit:: a dispute cencernin7, u..-

              :oria. Iv_forred r,n t:ie claimant':, r%,-t

      ase` :_u ;^_ days b' a tel a 7rapher, ~;::_. not .:itl: the abo! ishr:ent of a rosit_on claimed to be preserved to th clc-1;: b;; t'ie Scope rule. r'ore I.,.portant, A::ard 132'49 did not d_scuss t:;iS Poard'- ;hove cited ruli.r.LS on the -eanin~; of the term 'po-i t ions and ::o^'.:' in tl.e instant rule and:, cons ec:ucntly, we believe it is not ap;:ropos to the issue, rais-


Award 1324? rad: several -eneralized and Cratuite:!S statements not needed or connected with the issue in dispute. Even if such statements were necessary to decide the dispute, they, nonetheless, ii:ere still incorrect. Award 132410 does not cite a single.Award as authority for its holding,, and Referee Ha-ilton clearly ignored the body of lair concerned with the 1.orlc on Unassigned Day:: izsue, this, notwiths on Unassicned D=;. ,:as covered by Decision Ho. 2 of the FortyHour Week Cormit~ee, wherein that Comm
                            -3- LAEOR I'EI'3LR'S :."S:;~'R TO CA'RIE: ~'II'HEPS' DISS=^·170 AWARD 19719 (DOCK7T CL-1 972 ; )

      "***the intent of Section 3.(i) is that where i-fork is required ?:;; the carrier to to performed on a day ::rich i.3 not a part of any -icsiCnment, either .^.n av:ilabl:a extra or unassiCned employee who would otherwise not l>>ve 4^ hour-- of work that week or the re~ul-.r employec ray be used; unless such work is perfo:7-ed ty .a:: availabl~= extra or unassiF,ned omplo,,c a who would otherwise not lave 40 hours of r:orl: t::st weal:, the renular emplo;;ee shall he used. Where "lork is required to be performed on a hcl.i:iay which: is not a part of any assirnmc=nt the rer.ular employee shall be used. * * * "


and wa-. also covered by rior A,:vards:

                Ar:aard Referee

                7297 Edw. r^. Carter

                8204 Sidney A. 'r:ol,°f

                8303 II. Raymond Cluster

                8414 Horace C. Vokcun

                10290 Robt. J. I;lilson

                10533 Jerome A Levinson

                1?_957 Benjamin H. ,.lolf

                l3l42 Daniel House

P2~'1S_in 1~1, 2, a:,=. tli- Ai:;ar~F°, cited ililmedi^,tccl.' above, estab
lish that even if the applicable Scope Rule was of the "General
type" rule, referee Hamilton's decision in P,ward 13249 ryas palpr_
bly.erroneous. That this conclusion is correct is evidenced by
the fact that numerous Awards, subsequent to the adoption of
Award 7,32119, have rot follo,:;ed Award 13249, and have reached correct conclusions. Such Awards show that '.ward 13249 is a nullity on the Work or. fna:;signed Days' issue:

              Award Referee

              14137 1'urray 1". Rohman

              15615 John J. 1'cGovern

              16252 "ilton Friedman

              16571 Bill Heskett


                            -4- LABOR ;IE".BER'S ANSWER TO CARRIE liEI-BERS' DISSENT TO APIA^D 19719 (DOCKET CL-15727)

                      Award Referee

                      16672 John J. McGovern

                      17028 Daniel House

                      17425 furray I4. P ohman

                      17581 Paul C. Dugan

                      17619 Paul C. DuCan

                      173114 .Arthur W. Devine

                      18092 David Dolnick

                      13245 Paul C. Dur;an

                      19260 Arthur W. Devine

                      183!16 john H. Dorsey

                      18549 Robert 4. O'Brien

                      19856 Clement P. Cull

                      1°039 Cene T. Ritter

                      19322 Gene T. Ritter

                      19361! Paul C. DuZ1n

                      19439 Robert M. O'Brien

          AccordinGly, the neutral deciding Award 19719 was left with no

          alternative but to hold that Award 13249 was palpably in error.

          The Majority in Award 19719 correctly stated:


          "Under rn_nr Opinions of this Board the text of

          !Zulu :1·`,b) 1i_nvc has beon held to preserve to the

          Cle7k=' Cr_aninstion all work bent performed. un

          der the Cleric' Agreement, on the effective date

          theroof, until it is nejotiated out in the manner

          provided by Rile 49.

          This statement is supported by the Awards cited in the Opinion

          of the Public Law Board cited above, in this Answer, and by

          Award 7168, Peferee Carter, stating:


              "Under this portion of Rule 1, work may not be transfei·red from under the Agreement to employes under ^.nother aCreement except by negotiation. The wcrK of the rule are plain and the intent is clear. In the confronting: case no positions were transferred but that there was a transfer of work cannot be doubted. The ACreemont was made by the Carrier and the Organization and, its meaning teing claar, it is the "unction of this Roard to enforce it 4s made."


                                      _5_ LABOR -E"BFR'S ANSWER TO C,^-,R:;! NE?'REFS' DISJfa;T ':0 AWARD 1971 (DOCKET CL-1^727)


i
Referee Coffey held in Award 7349:

"ale have it on good authority that the Employes were compelled to resort 7:o arbitration to Get the protection trey see in a rule that embraces both positions n.nd work. They stress what is now stated in clear and unambiguous terms, as an obliSition of contract, that ' * * * nothing in this agreement shall be construed to permit the r application of these rules, * '' '' except by agreement between the parties signatory hereto.' ."

Referee ^orsey held in Award 11586:

"In prior Ay:rds of this Board it has been establ'_s::e:; that when the Sccpe ?-'ale provides _hat 'T=_itionu or 7ork' may .not be removed from the lgr_e-.ent exc:pt by negotiation, _ Carrier's anila`eral action abolishina a 'position' and assigning :.e ' .:.o:::' to another clazo or craft
                            1Ytt

is a violation of the Agreement.

in Award 11127, Referee Dolnick stated:

"The m _ _- Award 7'72 (Carter) ,._ ccnpa^able
. .a,.:.. _.
to the _ _,._s i.^. t._._ dispute before us. :e lul°
invoivel ~av al z, comp arablol to Rule 1(e)· of the
Clerks' k.jreewent. ,. said:

    'Several ai:ardz of this Division have held that .ales similar to Rule 1 (L) require that tKe work o_° a position may not `c removed from the <a pplii^a.tion of the =-reement -ycept by aareement or mediation.'


Referee Coburn held in Award 12414:

"As has teen Stat":a, the effective date of tin Agreement leforp us is j anus.";; 1, 1957. The evidence .7taK'i3Ksv that from and af!!°-' that date ..n`. ._ ,.._ ._. ^n·1 ,^=^:: nlericM _poniticns sat .'Iey,.n:ilie ..er°. abolished a.^.d the t,icket.seilin7 .^rk divi0nd tetwenn the Q'n`_ remaininj- Ticket Clerk is Spptcmber ~PO October

                  -6- LABOP 7"77n,__S n.·~St.~P TO f`;.:'.°__


                        7EKBERSt , TSSENT TO ATAID __(DOCK7;T !'E-=n 7 27 \

    "of that ;,rear, t~·,ployes covered by t:ie APreement were enna_ed in the wor:: of handlin_- ticket sales and ?-r: duties ···.-.l ated t'iereto. Thc-Y 7:ere so engaged i hen the -°s becare ~P^lieable. Thereafter, t,;,..:! -.oziticn of Tic::c` C.er'.: .:i·? the ;:o?:. of oclll-..- tic:·:etc appprt :in_:,~ t ereto could not be rer:oved unj?cr the cle._ o.t.d e:.:plicit 'anF-un.-e of the rule ey.cept t:,; .re_-otiation -tend ar ·^eement of the nart.tes. Al·,ards 3Cr3, c7'_ 05(10, 9673 and 1)416 are C5irectly in point and controll_nC.


      As to t.;:ard 114,)5 (Third Supplemental) also relied u:: b.,: the .Carrier and 'involvin;; thes part!-e: and the identical ."cope rule, apparently there t!-.e referee o:as per;;uaded to -^p-l_y the test of evcl,as-ve ::."2·:: rerfor:-ance and fc`.=nd that the evidcn^e to mect it was insufficit·nt. Out position =-, a:: has been stated, that the special Scope .^i,:le prcvisions of the AEree7.ent in evi.dence 1.=re obvi:;te the necessity of showin;- suc excl,,:Fi- o perfor-.ance by the ·-ovinC party."


And, Referee F?:use stated in Ai.:a:,d 16126:

      ,:or!: 1.; C;escrib·_'. above r.. covereC'· 1.y the . .^.ope Rule and under Parac-raph ('s) of th::` Rule, ;ay not be re:.:oved "tom cover ,,,,-e of the Agreement except t,.agree:rent of the parties."


Also, see Awards:

              At:ard Referee

              6357 Donald F. i"cT'l.hon

              6937 A. Langley Coffey

              7129 Edw. F. Carter

                8236 Edw. P.^ Lynch

              11983 Jim A. Rinehart

              148811 John II. Dorsey

              1760,) Gene T. Ritter

              17934 Chas. :. Ellis


      Examination of the abundance of authorities, the literal


lan-uaFe of tt:e rule, and the record, clearly establishes that

                      =7- LABOR Fr7"°EP" f.:TSWER TO

                                    '%ISr'ICARRI

                              ;., ·n;_~ r -.,m _O AWARD 1^''

                              '. Sc.- , , .


                              (DnCI'ET CL-=1727)

it is Carrier 1"embers' Discent to Award 19719 that is a r~

t;,· - not Award 19719.

                                        pj.


                            ~;. Tletcher, Labor ~..'er:cer

                            =73


                                        LAFC~ i2,;·=~T~" 1 <· r rrn·,rT·.~ m ~. n


                                        1:?:I·:^t'.ic.' D1;;~.."^ TO F.r;.~.7~ 1 ~7ln.

                                        ir·nr·, _l r1

                                        \i.·~.I:T Cir _ 7.:71


. ·..31!:1,: