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Home My Public Portal About2019-42 Approving former Mayor Mayra Lindsay's reimbursement of Attorney's feesRESOLUTION NO. 2OI9-42 A RESOLUTION OF THE VILLAGE COUNCIL OF THE VILLAGE OF KEY BISCAYNE, FLORIDA, APPROVING FORMER MAYOR LINDSAY'S REQUEST FOR REIMBURSEMENT OF ATTORNEY'S FEES RELATING TO AN INVESTIGATION INTO AN ALLEGED SUNSHINE LAW VIOLATION; PROVIDING FOR AUTHORIZATION; AND PROVIDING FOR AN EFFECTIVE DATE. \ryHEREAS, on or about May 11, 2018, the Miami-Dade State Attorney's Office (the "State Attorney") opened an investigation into an alleged sunshine law violation committed by former Mayor Lindsay (the "Former Mayor") while she was still serving as Mayor of the Village (the "Investigation"); and \üHEREAS, on March 27,2019, the State Attorney issued a Closed-Out Memo concluding the Investigation and determining that "based on the totality of the circumstances and Lindsay's cooperation and candor, this matter is being closed without filing of charges;" and \ilHEREAS, on April 2,2019, the Village Manager received a letter, attached as Exhibit "4," from the Former Mayor's attorney requesting reimbursement of her legal fees incurred in the defense of the Investigation; and WHEREAS' after careful review and consideration, the Village Council has determined to reimburse the Former Mayor in an amount not to exceed $35,457.50 for her attorney's fees because the Investigationarose from (1) the performance of the Former Mayor's official duties and (2) while serving a public purpose; and WHEREAS' the Village Council finds that this Resolution is in the best interest and welfare of the residents of the Village. NOW, THEREFORE, BE IT RESOLVED BY THE VILLAGE COUNCIL OF THE VILLAGE OF KEY BISCAYNE, FLORIDA AS FOLLOWS: Section 1.Recitals. That each of the above-stated recitals are hereby adopted, confirmed, and incorporated herein. Section 2. Approval. That the Village Council approves the reimbursement of the Former Mayor's attorney's fees relating to the Investigation in an amount not to exceed $35,457.50. Section 3. Authorization. That the Village Council authorizes the Village Manager to take any and all action necessary to implement the intent and purpose of this Resolution. Section 4. Effective Date. That this Resolution shall be effective immediately upon adoption. PASSED and ADOPTED this 1lth day of June, 2019. V/. DAVEY, MAYOR A IN CLERK APPROVED AS TO FORM AND LEGALætu VILLAGE ATTORNEY 2 Rothman ,:--i;' Associates, P.A. Attorneys at Law Established, 1980 Soutleast Financial Center . Suite 27?0 200 South Biscayne Boulevard r Miami, Florida 33131 Telephone (305) 358 - 9000 o Telefax (505) 374 - 5747 Website :ro thmanlawyers. com DAVID B. ROTHMAN dbr@ro thmânlawyerr.com Boãd Certiñed in Criminal lrial l-aw JEÀNNE T. MELENÐEZ jtm@rotùmatrlawyers.com State & Federal Criminal Defense Bar &JQC Defense Bar Admission Reprecen ta!ion September 12,2018 Honorable Mayra Peña Lindsay Mayor, Village of Key Biscayne RE: Legal Representation of Mayor Mayra peña Lindsay Dear Mayor Lindsay: I am pleased you wish to engage my fîrm to represent you. This letter is intended to set forth our understanding as to the naLure and scope of the legal services I have agreed my iawfirm will render, the amount of our fees for thesè services, and the terms upon lv'ñich you øtt pay these fees. l. NaÉurp qf Les¡l Servi$-qd. You have engaged my firm to represent you in a matter that occurred during, in the course of and as part of your duties as Mayoiof the Village of Key Biscayne presently being investigated by The Miami-Dade Commission on Ethics ¿ pu¡lic Trust and the Miami-Dade State Attorney's Office. As of the date of this letter agleement, I cannot make, and have not rnade any representations or guarantees concerning the óutcome of the matter' The scope of representation is limited to the matter and will only b" expanded through a written agreement between us. 2. Fees for Serryiceq. You will be charged, and you agree to pay for services on the basis of hourly rates: my standard hourly rate is $650.00; theìtandard hourly rate for my associate attorney, Jeanne M. Melendez, is $475.00, and $200.00 for attorney Jerãmy Knight. i, personally, will hle my appearance and be your lawyer in this matter. you will Ue bitte¿ monthly at our hourly rates. 3. Costs. You will be charged for costs and expenses, which may include chargesfor: investigation, travel, photocopies, facsimiles, postage, ãlectronic ,.rr*rh, court reporting and filing fees. In addition to fees for legal services, you àg."r to pay my firm for such coits *ã expenses incurred. In the event unusually large costs or advances are anticipated, I reserve the right to require that you establish a direct relationship with the outside vendorìn question. 4. Payment pf lçes and Cos,!g. The invoices will be submitted to you on a periodic basis, usually each month and each invoice will be due and payable when rendåred. payment is expected within 15 days of invoice date. J Engagement Letter to Mayor Mayra peña Lindsay Re: Miami-Dade Commission on Ethics & public Trust September 12,2018 Page2 !. Commqncçme4f of Represe.Ft¿tio,g. If the foregoing is agreeable to you, please acknowledge your understandjng and agreement 6y signing thls letter and delivering it io rny firm, together with payment of the deposit set forth abovã. Your confidence in Rothman & Associates, P.A. is sincerely appreciated and I assure you every effort will be made to perform our services in a prompt, effrcieni and effective manner. Sincerely, & Associates, P.A. B DBR\ag AGREED AND ACCEPTED on this, the l2-*day of september,201g. MA YRA PEÑA Rothman f7 Associates, P. A. Rothman Associates, P.A Attorneys at Law Establishcd 1960 DAVID B. ROTHMAN dbrOrorburanlawycn.com Soard Ccrttñcd in Crioinal Tlial l¿w JEANNE T. MELENDEZ jtm0rothmrnlewycn.com Southeast Fínancial Cencer r Suite 277O ?00 South Biscayne Boulevard r Miami, Florida 99131 Telephoae (305) 858 - 9000 . Tclefax lgOS') 574 - 5741 Website:rothmanlawyers.com Sta¡e & federal Criminel Dcf¿¡¡c Bar &.fQC Defcnse Brr Adnisrion Rcprcscntation April2,2019 Ms. Andrea Agha Village Manager Village of Key Biscayne Village Hall, Suite 210 88 West Mclntyre Street Key Biscayne, FL 33149 Re: Mayrr LÍndsay - Reimbursement of Legal Fees Dear Ms. Agha: Afrer almost a year-long joint investigation by the Miami-Dade Commission on Ethics & Public Trust (Commission) and the Miami-Dads State Attorney's Office (SAO), including multiple sworn witness interviews and extensive document discovery, both organizations have now separately closed their investigations without bringing any charge. Mayra Lindsay testified under oath, on the record, that she was acting in the best interest of the Village in reacting to a situation not of her creation, and that she did not act unethically or in violation of any law. In its Report closing the ethics investigation, dated November 29, 2018, the Commission concluded "lt was determined that this matter would be closed with no further action as the evidence does not support the conclusion that the Mayor intentionally violated any matters within the jurisdiction of the Ethics Commission." The SAO concluded in its Report, dated March 27, 2019, "Based on the totality of the circumstances and Lindsay's cooperation and candor, this matter is being closed without filing of charges." Mayra Lindsay's conduct was at all times legal and appropriat€. Mayra did the right thing by protecting the Village's confidential collective-bargaining strategies and information from public disclosure, The allegations lodged against her that led to the joint investigation lryer€ without merit.l Nonetheless, there were serious accusations such that Mayor Lindsay was immediately compelled to seek counsel. The Village Attomey assisted Mayor Lindsay by contacting me and refening the I Sadly, it appears from a careful review of the underlying facts and documents involved in this matter that at least one person involved in the decision to instigate the complaint that led to the joint investigation was motivated solely by personal animus against the Mayor. s : J I I 3 Ms. Andrea Agha, Village Manager Village of Key Biscryne Re: Møyra Lindsøy - Reimbursemenl of Legal Fees Apríl 2, 2019 Page 2 Mayor to me for representation as my practice areas are criminal defense and ethics representation. Accordingly, she.hired my firm. Now that the joint investigation has been successfully concluded, with both organizâtions closing out their investigations with no finding of wrongdoing, the Village of Key Biscayne should, and based upon the facts and the law, must pay the former Mayor's legal fees, an invoice for which is attached. The Facts The underlying facts are straightfonlard. One of the Village's consultants had just issued a confidential report with actuarial information regarding pensions in the context of negotiations with the Key Biscayne unions. After a special Council meeting, Councilmember Katie Petros advised that she wanted to have a meeting on the issue of pensions with the then-Mayor. Then- Councilmember Luis de la Cruz indicated that he also wanted to attend the meeting. The clerk nçticed a "public" meeting to take place on March 1,2018, about "Pcnsion.'n When the Mayor arrived at the meeting, Councilmember Petros came to meet her stating there was a problem as a member of the public, Donald Elisburg, wanted to anend the meeting. Normally, all meetings between two or more elected officials must be open to the public and in the 'osunshine" pursuant to Fla. Stat. $ 286.01L The Florida legislature, however, created an express statutory exception to the sunshine law for meetings relating to "collective bargaining" which "shall be closed and exempt from the provisions." S€ Fla. Stat. $ 447.605; see also $ 447.605(3) ("All work products developed by the public employer in preparation for negotiations, and during negotiations, shall be confidential and exempt from the provisions of s. I19.07(1), F.S."). Knowing this, Mayor Lindsay immediately called Stephen Helfman for advice. Mayor Lindsay testified in her sworn statement her memory of the conversation with Mr. Helfman was that he confirmed that pension issues relate to collective bargaining negotiations and, therefore, were exempted from the requirements of open meetings. She further testified he confirmed that if the meeting had been improperly noticed as a public meeting it should be "cancelled." Mayor Lindsay then walked into the meeting, explained the situation, and Mr. Elisburg left. Apparently, at some point thereafter, but before the councilmembers left the room, Councilmember de laCruzbrought up, and it was briefly discussed, that he wanted the Village to hire a consultant to help understand the actuarial documents. Almost two months after this meeting, on or about 4pri123,2018, Mr. Elisburg fïled a complaint with the Commission claiming that he was improperly excluded from a "sunshine" meeting. The SAO became involved. Again, I was hired to defend these charges that resulted in the two investigations. I had multiple meetings with both the olient and the agencies. I assisted the former Mayor in her written witness Rothman f4 Associates, P. A. .: ; 3 Ms. Andreq Agha, ïillage Manager Village of Key Biscayne Re: Mayra Lindsay- Reimbursement ofLegal Fees April2, 2Al9 Page 3 statement, as well as her swom testimony before the SAO and the Commission. I also prepared an extensive legal brief for the SAO demonstrating that: the Mayor at all times acted appropriately because the meeting was improperly noticed as'opublic" when the collective-bargaining exemption applied; the Mayor was appropriate in terminating the publicly noticed meeting; and any subsequent discussion relating to the pension or hiring experts to explain the actuarial analysis did not violate Florida Law. See Florida Government in the Sunshine Manual, at 48 (*If a statute exempts meetings from the requirements of s. 286.011, F.S., the meetings are also exempt from the notice provisions in that statute that would otherwise apply."). The Commission determined on November 29,2018-shortly after Mayor Lindsay's sworn testimony-that the Commission would close out the case because there was no evidence of wrongdoing. Interestingly, the Commission's close-out memorandum also indicated that" on or about November 2,2018-the day of her sworn testimony-the SAO indicated "that it did not intend to prosecute the mayor criminally," although for some reason the SAO waited until March 27,2019, to provide notice to us that it was closing the case with no further action. The.{,aw on Çovernment Reimbursement of Lcsal Fees for Defendins Conduct of Ollicials in Carrvine Out their Duties As you know, on or about September 14,2018, the then-Mayor submitted a written rqquest for the Village to authorize payment of her legal defense. Robert Meyers, Esq., of Weiss Serota, responded that there was no "proof of a formal state or local ethics charge," thus the request wris 'opremature." We determined to wait for the expected favorable resolution of this matter before responding but suffice it to state that neither the Village ordinance nor the applicable common law, which Mr. Meyers did not discuss, requires "proof of a formal state or local ethics chatge," For well over a century, Florida courts have recognized that public offrcials are entitled to legal representation at public expense to defend themselves against litigation arising from the performance of their official duties while serving a public purpose- See Thornber v. City of Ft. llalton Beach,568 So" 2d 914 (Fla. 1990); Miller v^ Carbonelli, 80 So. 2d 909 (Fla. 1955); Williams v. City of Miami,42 So. 2d582(Fla. 19a9); Peckv. Spencer,26Fla.23, 7 So. 642 (1890). The purpose of this common-law rule is to avoid the chilling effect that a denial of representation might have on public offîcials in performing their duties properly and diligently. Nuzum v' Valdes, 407 So. 2d277 (Fla. 3d DCA l98l). As stated in Ellison v. Reid,397 So. 2ù352 (1st DCA l98l): Therc is no doubt a valuable public purpose is served in protecting the effective operation and maintenance of the adminisnation of a public officc. If a public officer is charged with misconduct while performing his offisial duties and while Rothman f4 Associates, P. A. lvÍs. ,4ndrea Aghø, Village Manager Village of Key Biscayne Re: Mryra Lindsay - Reimbwsement of Legal Fees Ápril2,20l9 Page 4 serving a public purpose, the public has a primary interest in such a controversy and should pay the rearionable and necessary legal fees incurred by the public offrcer in successfully defending against unfounded allegations of official misconduct. As then-Attorney General Robert Butterworth spellecl uut ilt Attorney Ceneral Opinion AOO 94- I l, in deciding whether reimbursement for legal defense of an offîcial is required, the question is not whethcr there is "proof of a formal state or local ethics charge," rather the question is whether the proceeding is one "in which civil or criminal liability may arise." Importantly, this common-law entitlement to attomey's t'ees arises independent of statute, ordinance, or charter. Lamela v. City af Sunrise,423 So. 2d974.976 (4th DCA 1982). That said, Key Biscayne's ordinance,2-21, aiso provides that the Village may pay for the legal defense of "any action or proceeding'" brought against an official "for acts or omissions ari.sing out of and i¡r the course and scope of the Official's function." Again, there is no requirement of a "formal state or local ethics charge" as Mr. Meyers suggestecl, Here, a "Complaint" was filed against Mayor Lindsay. She then received'onotice" of the two investigations that related to her actions taken in the course of her duties as Mayor. At the advice of the Village Attorney, she retained me and my firm to defend her. Now that she has been completely cleared of any wrongdoing, with no ethics or other charges filed, the Village is required by law and compelled by the facts to pay for then-Mayor Lindsay's successful detbnse. Because the law and simple fairness support this request, I strongly urge the Viliage to pay the attached invoice. Very truly yours, &P.A. ryr, David Enclosure DBR\ag Rothrnan f4 Associates, P. A. 'l Ûylal2ot9 JM Rothman Associates, P.A. Attorneys at Law Establishcd 198A Southeast Financial Center r Suite 2770 200 South Biscayae Boulevard o Miami, Florida 33131 Tclephone (305) 358 - 9000 . Telefax (EO1l 374 - 1147 Web¡ite:rothmanlawyers.com lnvoice submitted to: Lindsay, Mayra Date gy Servlce Summary ln Reference To: Sunshino Law llatter (Labor) 09/ttl20r8 rM Mlæellaneous Conference with Mayra and David; internal conference with David; review Key B¡scayne website; review chader provision and review David's bio for request Email Email from David; intemal conferences with David and Annie re: Retaaner Ag reernent language Conference Conference with Mayra and David Meeting Meeting with Mayra Convergtion Conversation with ASA Isis Perez and conversation with Mayra and emails to both Convercation Conversation with Isis Perez rc state criminal case and conversation with Mayra Research Research Meeting Prep for meeting and meet¡ng wlth Mayra and Alvin Mixdlanæus Internal conference with David; research and review case materials Emall Emails with Mayra and with prosecutor scheduling interuiew and follow up conversåtion w¡th Mayra Relsearch Research; internal conferences with David; conference wit Mayra and David Meet¡ng Mee$nı with Mayra and Jeanne and follow up re documents provided by Mayra Revlew Review case materíals and drafting submission to State Attorneys Offlce and Commission on Ethics and Public Trust 091L212018 JM 09lL2l2or8 DR 091t7120t8 DR 09/18/2018 DR o9lt9l2aL8 DR aelzalzors DR 0912412018 JM a9125120r8 DR 0el26lz0L8 JM 0912612018 DR DAVID A, ROTHMAN dbrOro thmanlewycrr.com Board Ccrtiñcd in C¡tminal Triel I¿w JBANNE T. MELENDEZ j tmOrothurnlewyarr. com Statc & Fcderal Criminal Dcfcncc Bar &JQC Dcfen¡c Bar Admis¡iou Rcpreccntation lnvoice # 80897 lnvoice Dete þ¿U02r20tg :or Services Through þ410212019 Terms:il/A Hours/Rate Amount 1.90 ðt $ 475.00/hr $ 902.s0 0.50 at S 475.00/hr $ 237.50 1.20 at $ 650.00/hr $ 780.00 0.90 at $ 475.00/hr 0.70 at $ 650.00/hr 0.80 at $ 650.00/hr 1.50 at $ 6s0.00/hr 2.00 at $ 650,00ihr 4.50 at $ 475.00/hr 0.50 at $ 650.001hr $ 427.s4 $ 4ss.00 $ 520.00 $ 97s.00 $ 1,300.00 $ 2,137.50 $ 325.00 ; : J a .,1 Il : I) 5.20 at $ a75.00lhr $ 2,470.00 2.00 at $ 650.00ihr $ 1,300.00 09l27paL8 JM 3.00 at $ 475.00/hr $ 1,425.00 .) DR JM DR 0912712018 DR 0912812Aß DR 09128120t8 JM 10/0u2018 JM LAl0u20L8 DR LA|AU2078 JM LolozlzotB DR Preparation PREP for meeting tomorrow morning - review dos and prepare questions to prepare Mayra for her testimony next week Preparation Prepare Mayra for testimony Dnft Drafting Submission Letter Mixdlanæus Draftinglediting Bio section; drafring Personal Statement; editing letter submission; email to David; drafting legal analysis and revieur of research Edtt Review and edit several versions of the personal statement, the letter to the prosecutor and the investigator and the bio Mlællanæus Conference with Mayra and David edits to Personal Stâtement and Letter Submission; review legal Research and Drafting Legal Anaþsis Submission; internal conference wlth Davld Meeting Final prep for meeting, induding final revisions of personal statement and letter submission and meeting with MayraMi llanæus Emails and calls to try to schedule interview Conference Internal conference with David Revise Review and revlse flrst draft of submisslon to be submitted after Mayra's interview by the State Meeting Preparation for meeting and meeting with Mayra ín advance of tomorrow's taking of her statement Prcparation Preparation for statement and stâtement taken by state and ethics commission Convercation Conversation with Al Undsay Drafr Work on draft of letter to State following statement Review Review and proofing legalanalysis submission; emails to and from Aþin and Mayn and David; additlonaledits to Submission; internal conference with David Edit Emails with Al, Mayra and JTM re final version of letter to State Email Emall to prosecutor and investigator for ethics commission with final submission with factual and legal arguments and emails with Mayra re same Conversation Conversation with Assistant State Attorney Isis Perez and follow up conversat¡on wlth Mayra re same Converætion Conversation with Myra and Al re how we will proceed Conversation Emails and then conversation with Isis Perez re Village seminar concept Ønve¡stion Conversation with Mayra Email Emalls with Isis Perez seeking update Converstion Conversation with Isis, email to Mayra and conversatlon with Mayra Mtællanæus Conversatlons with Mayra and Al, conversation with prosecutor and emails with Mayra and Al Converstlon Conversation with Isis Perez re clo.cs¡g language Rothman f7 Assıciãtes, P. A. 1.20 at $ 650.00/hr $ 780,00 1.50 at $ 650,00/hr $ 975.00 5.50 at $ 475.00/hr $ 2,612,50 3.00 at $ 650.00/hr $ 1,950.00 2.00 at $ 650.00/hr 4.50 at $ 475.00/hr 5.20 at $ 475.00/hr 0.30 at $ 650.00/hr 0.10 ät $ 475.00/hr 0.40 at $ 650.00/hr 0.20 at $ 650.00/hr 1.00 at $ 650.00/hr 1.20 at $ 475.00/hr 0.20 at $ 650.0û/hr 0.30 at $ 650,00/hr 0,50 at $ 650.00/hr 0,50 at $ 650.00/hr 0.20 at $ 650,00/hr 0.20 at $ 650.00/hr 0.60 at $ 650.00/hr 1.00 at $ 650.00/hr $ 1,300.00 $ 2,137.50 $ 2,470.00 $ 195.00 $ 47,s0 $ 260,00 $ 130.00 $ 6s0.00 $ s70.00 $ 130.00 $ 19s.00 $ 32s.00 $ 32s.00 $ r30.00 $ 130.00 $ 390.00 $ 6s0.00 ßl22l2Ot8 t0l2sl20L8 tol26l20t8 LUAUzAß ru0u2aß Ltlo2lzoLS DR 1U05/2018 DR LLIOTI2OL$ JM tll07l2aß DR 1U08/2018 DR üla3lzaß DR 9tlßl¿aß DR 0r/0812019 DR 01/10/2019 DR 0Ll3tl2oL9 DR 03112120t9 DR 03lL4lzolg DR DR DR 2.50 at $ 650.00/hr $ 1,625.00 3.00 at $ 650.00/hr $ 1,950.00 0.60 at $ 650,00/hr $ 390.00 ailß120t9 DR 0.30 at $ 6s0.00/hr $ 19s.00 o3l2u2ot9 DR a3l25l2ot9 DR a3l26l2oL9 DR a312712019 DR Enail Emails with prosecutor and with Mayra and Al re status Ena¡l Email from Mayra witñ certific¿te of completion of ethics course and emailto Isis Perez wlth certificate Miælhnæus Emails with Mayra, receipt and review of Ethics Commission's report, three conversatlons w¡th the prosecutor re the Ethics Commission report, 3 conversations with Mayra Meeting Meeting with ASA Perez and obtaining a copy of the closeout memo from her 1.50 at $ 650.00/hr $ 975.00 0,40 at $ 650.00/hr $ 260.00 0,40 at $ 650.00/hr 0.30 at $ 650.00/hr $ 260,00 $ 19s.00 Total Hours: 63.30 firs TotalLabor: S 36,457.æ Total lnvoice Amount: $ 35,¿157.50 Previou¡ B¡lance: S 0.00 Balance (Amount Due): $ 35,457.50 Sincerely David Rothman Please make check payable to: Rothman & Assoc¡ates, P.A. Rothman f4 Associates, P. A. Ilosantoffi Hogrn Lorcllr US LLP 600 Bñd(.llAwnuc Sulþ 27(xt illi&ni, FL 3:t131 T +1 305 ¡l$g 6300 F +1 305 459 6500 wr*.hogrnlovcllc,com Vla E-filrll Ç USPS Gedifled M¡il May 8, 2019 Ms. Andrea Agha Village Manager Village d Key Biscayne 88W. Mclngre Street Key Biscayne, FL 33149 Re: Demand for Payment ¡nd Requert for Special Pre¡entation Dear Manager Agha: Pleass let this confirm that immxliat+past Mayor Mayra Lindsay is formally demanding reimburs€ment of legal fees stemming frorn an unfounded and failed ethícs complaint filed on May 7, 2018, regarding a rneeting Mayor Lindsay attended as part of her offcial duties while serving a public purpos€ for the Village of Key Biscayne. We further respectfr¡lly requ€st to be placed on the agenda for a fifteen-minute special presentation to address this topic at the May 21,2019 Council meeting, We intend to provide a package of information and legal support for Councll's review in advance of the meeting. Kindly confirm that this Ítem has been placed on the agenda at your earlieet convenienca, Very yours, Alvin Lindsay Partner alvin. lindsay@hoganlovells.com D 305 459 6633 t{ogrn LoÉllr uE LLl, t¡ ¡ lm5 {.b.¡ly glrlrrlþ qrü¡rt h m oiãn ol co¡ñür lfgrì Lov¡r' Û m ir¡nl(fl¡l r{rl F*t¡Ð l¡lr ftIfr fi€e¡n Lü,.r¡ u8 LlPlfldl{oemtoyll¡htrû¡o.flLP.yflJìomo.¡¡û Ah.¡¡t AÍÉrde ttitrrr 8.fì9 Bitr¡ndÍr Eorlú 8n,t.- C6.orÉtp.h0r o.nvr û¡Ô.t 0rJ¡rdcÍ F.¡údú $aíÉrrre H{þl Ho Ch¡ 5l Cû fbï Ksle Hqr¡bñ Jolta¡üaaùirg Lo.ró.r to¡ AÁe-r Ls¡..r¡åourg fad¡t þdcû Cly I¡¡ñ¡ ¡¡T¡t Minrr..po¡¡ lbt.rrry t¡o¡cûr t¡r¡c¡r l¡rYo.f( ¡lorll:nvr0.'i, Pri¡ P¡úr PllL.¡p¡ir Radri-aro Ron¡ S¡FrrrO¡co SlôP¡¡o Shr{,L f¡¡rønvtt Síne?orÒ Byûia? lorte r.rrar Waûrhgþnoc Asod¡d¡ficar: 8.r(¡ea¡{ ¡lr¡.L SlrlgñaFTZ Ulúù-|J l¡gÔ. tuiür8avi: C¡ntaf|' Jeau.rrlôúg Lór¡¡v{a For nÞaa iúormalüt.t w.lìoC¡lorü1€om \lt l 706187tt6æ - C{3l3t rl