01/07/2011 9;16PM FAX 

1^0001/0023 

Michael Seiig, MD, FACC. CR-H 

28l6 0refieldRoad 

Allentown, PA. 18104 

^^PARTMENTOF 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, DC . 

Federal Aviation Administration 

Laura Ponto, Latonyo Williams 

Complainants 

M & R Helicopters, UC> 

Respondent 

WID5D Ob 0 

Honorable Judge Ronnie Yoder 

Docket: 2010-1211 

MOTION FOR HEARING LOCATION IN ALLENTOWN. PA 

AND NOW, comes respondent, MICHAEL B. SELIG. MD, FACC, principle 

for MR Helicopters, LLC. (MRH) (non-operational since 2007) whom avers and 

files the following Motion to establish the Hearings in the above case^ to be held 

at the US District Court locoted at 504 W. Hamilton Blvd. Allentown, PA, the 

place of origination and original Jurisdiction. 

1. On October 1, 2010, an the informal hearing was held with Ms Ponto at 

which time it wos discussed a court location for a future hearing in Allentown, PA, 

at the US District Court. It was confirmed to as an option and jointly agreed to, 

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2. While there were many discussions concerning the Deposition 

location of Latonya Williams, few details were discussed concerning the actual 

hearing location. 

"^ 3. It is respondents position that the most appropriate and proper 

hearing location since the violation was investigated, initiated and generated 

by Ms Williams coming to the Allentown location, requiring 2 visits (specifically to 

the joint cardiology/air charter office), the site of the alleged violation occurred 

in Allentoy/n, would only follow suite that the hearing location should thereby 

also be held in the Allentown location, being the place of origin and original 

jurisdiction. 

4, The complainants evaded and circumvented in the past the main 

reason for requesting the Allentown location, as stated in respondents letter of 

November 24, 2010, namely the respondents primary role in the Lehigh 

community as a solo, private practice cardiologist (for the last 23 years) with 

hospital and outpatient responsibilities. To leave the area would pose undue 

hardship to his patients. It is not reasonable or proper to burdened or 

Inconvenience neutral party patients or a physician for a violation that he did 

not initiate, was an innocent bystander to and that appears to lack legal merit. 

5. It would not be proper, reasonable or ethically or morally appropriate 

for the court to compromise his clinical responsibilities in his office or in the 

hospital in a manner that would delay, interrupt continuity of care or 

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compromise patient care and potentially pose increase liabilities or risk to him or 

his patients in his role of proyiding his emergent, acute and chronic public 

health care services to the community. 

6. Respondent would be led to believe thai the Honorable Judge Yoder 

would need to set up the hearings at the US District Court located at 504 

Hamilton Street, Allentown, PA. 18101, unless otherwise notified. 

WHEREFORE, the respondent prays that this Honorable Court will grant the 

Hearings Location at the US District Court located at 504 W. Hamilton Blvd, 

Allentown, PA. 18103, thereby with respect to others by minimally interrupting his 

cardiology proctice and care of his patients. 

Respectfully Submitted, 

Michael B. Seiig, MD, FACC. 

Date. 

VvV .Vy^ 

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I210004/0023 

Michael Seiig, MD. FACC, CR-H 

2816 0refleldRoad 

Allentown, PA. 18104 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviation Administration 

Laura Ponto, Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

V. 

Honorable Judge Ronnie Yoder 

Docket: 2010-1211 

MOTION TO HAVE THE PRE-TRIAL DEPOSITION OF LATONYA WILLIAMS 

AT GALLAGHER REPORTING. ALLENTOWN, PA. 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, principle 

for MR Helicopters, LLC, (MRH) (non-operational since 2007) whom overs and 

files the following Motion to have the pre-trial Deposition of Latonya Williams 

under Rule §13.225 at the Gallagher Reporting and Video in Allentown. PA. 

1. On December 1, 2010, respondent faxed and filed a Molion for 

Deposition of Latonya Williams to Ms Ponto, to take place in Allentown, PA. 

2. Complainants failed to respond to the motion within the 10 day 

deadline. 

3. In complainants response dated December 20, 2010, complainant 

agreed to make available Ms Williams for Deposition and cited erred dates of 

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availability for the pre-trial deposition of "January 28, 2010, February 1-4, 2010, 

February 8-11. 2010 or February 15-17, 20)0". 

4. The meeting place of Washington, DC was mentioned. At no time 

did respondent request or agree to a hearing at the Philadelphia, PA or 

Washington, DC locations. 

5. On December 21, 2010, respondent filed a motion to specifically 

request the deposition to be in the Allentown Locotion. 

6. On January 13, 2011, complainants served their response 13 days 

later. In that reply, Miami, Florida was mention as a suggested location, wtiich 

also is unacceptable to the respondent. 

7. It would be most appropriate, proper and reasonable that since the 

violation occurred, investigated, initiated and generated by Ms Williams by 

coming to the Allentown Location, requiring 2 visits (specifically to the joint 

cardioiogy/air charter oftlce) then it would only follow suit that the deposition, 

defense and substantiation of claims thereby be held in the Allentown location, 

where the alleged violation occurred and the location of the originating 

jurisdiction. 

8. Ms Williams standard practice is lo travel to remote locations to 

perform inspections with the only intent to find and impose civil penalties against 

operators. She stated to the respondent that she "travels all over as part of her 

job", therefore it would not be an inconvenience for her to come once ogain to 

the Allentown area as she did to Initiate the violation. 

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9. The complainants again evaded and circumvented the main 

reason for respondents request for the Allentown location, as stated in his letter 

of November 24, 2010, namely the respondents primary role in the Lehigh 

Community as a solo, private practice cardiologist (for the last 23 years) with 

hospital and outpatient responsibilities. To leave the area would pose undue 

hardship to his patients. It would not be proper or reasonable to burden or 

inconvenience neutral party patients and a physician tor an alleged violation 

that he did not Initiate, has coused no harm, lacks legal merit and on very weak 

grounds. 

10. It would not be proper, reasonable or morally or ethically 

appropriate to compromise a physicians clinical responsibilities in his office or in 

the hospital in a manner that would delay, Interrupt continuity of core or 

compromise patient care and potentially increase liabilities or risk lo him or his 

patients in his role of providing emergent, acute and chronic public heath care 

services to the community 

11. The respondent hereby proposes the following: Assuming the prior 

suggested dates were meant to apply to 2011, using a time of 10 am, Ms William 

can chose the date most fitting to her schedule to appear at the Allentown 

location namely at : 

Gallagher Reporting and Video, LLC. 

1600 Lehigh Parkway East, Suit 1H 

Allentown. PA 18103 

Once the date is selected that best suits her schedule for the pre-trial 

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deposition, respondent will firm up the other details. 

12. Respondent agrees to cover the costs pertaining to the meeting 

area and court reporter directly with Gallagher Reporting. 

WHEREFORE, the respondent prays that this Honorable Court will grant the pretrial deposition of Latonya Williams in Allentown, PA, the originating location and 

jurisdiction of the alleged violation. 

Respectfully Submitted, 

Michael B. Seiig, MD, FACC, 

Date Y^^^ 

4 of 4 

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Michael Seiig, MD. FACC, CFI-H 

2816 0refield Rood 

Allentown, PA. 18104 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C, 

Federal Aviation Administration 

Cynthia Dominik, Laura Ponfo, 

Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Federal Docket. No: 2010-1211 

RESPONDENT'S MOTION FOR JUDGMENT TO DISMISS 

TRUTHS OF ADMISSIONS 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, CFI-H, 

principle for M & R Helicopters, LLC, (MRH) (non-operational since 2007) whom 

avers and files the following Motion for Judgment for complainants failing to 

plead to specific number allegations and thereby making admissions of truth. 

&y failure to address the specific pleadings and thereby evading and 

circumventing respondent's specific allegations, complainants have indubllably 

and injuriously propagated redundant and iterate pleadings for a case that 

appeared void ob iriilio. 

1. Throughout this litigation, the complainants have refused to address 

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specific numerated paragraphs in breach of Federal Rule 10(b). By failure to 

address a pleading that then deems that allegation an admission of the truth to 

that pleading under § 13.208(f). The complainants thereby admit by default to 

the following truths: 

a. That Vincent Roots the FAA auditor in January 2004, was not aware of 

the drug/alcohols programs new definition of employer and did not inform 

respondent. 

b. That the complainants are trying to hold the respondent liable tor a 

regulations that even its oyn FAA officers were not aware of and thereby an 

admission of truth. 

c. That the compldinants are therefore trying to hold the respondent to 

a higher standard than th^ir own FAA officers, thereby voiding the legitimacy of 

the complaint and demon|strates malicious prosecution. 

d. By way of Judicial Estoppels and legal inconsistency, the 

complainants have admitted to formally releasing the prior lA mechanic found 

to be on his full time employers Drug/Alcohol program by Ms Williams leller of 

September 23, 2010 (Exhibit 1), thereby complainants should follow suit with legal 

consistency by releasing Ed Baker who was also on his full time employers 

drug/alcohol program, voiding the legitimacy of the complaint. 

e. The Respondents Motion to Quash, Strike or Dismiss Complaint, with 

associated brief was faxed on November 29, 2010 and sent to Mr Pontes 

department on November 30, 2010. The due date was December 9, 2010. An 

eso/eoo® sua * vvd sfiseeteos xvd 6S:SL LL03/fo/so 
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obiection or response was not received or served until December 13, 2010, past 

the due date under § Rule 13.218(d). Complainants failed to provide proof of 

when that document was received and served. 

f, On November 30, 2010, respondents motion to Strike Allegation was 

faxed and sent to Ms Pontes department to which no objection or answer was 

received within the 10 day deadline under § Role 13.218(d). A late answer was 

also provided in the correspondence received on December 13, 2010. 

2. Throughout this litigation, complainants have not pleated facts with 

sufficient specificity and in accordance to standard practices. The purpose of 

these practices is to confine the pleading party proof to only those acts alleged, 

thus enabling a responding party to prepore their defense^. 

3. Throughout this litigation, complainants filed late responses to 

motions past the 10 day deadline motion period under § Rule 13.218(d), for 

example, not using actual dates of service in attempts to impair the dignity of 

this court. 

4. In summary, 

a. It has become apparent that the conduct by Ms Williams and hAs Ponio 

represents procedurol and prosecutorial overreaching. 

b. That the complainants are trying to hold the respondent to a higher 

standard than their own officials in regard to regulations that were not evident or 

known. 

'Baker v Rangoa, 324 A.2d 498, 505 (Pa Super Ct. 1974 

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c. There ore issues of judicial estoppels, legal inconsistency and procedural 

defects, 

d. That inappropriate action has been taken against a small single pilot 

operation that has been operating in the red for years and had long stopped 

operating in due diligence, good judgment and good faith, according to 

regulations due to human factors of a tragic divorce case scenario in order to not 

expose the public to undue risk. 

e. Rapidly initiated the appropriate changes once respondent became 

aware in good faith, despite not performing operations for years prior, 

f. That precious scarce judicial resources are being squandered on a case 

that appears frivolous, trivial, without merit, while representing an aggressive 

prosecutorial pursuit that lacks proper initiative, perspective or good judgment. 

g. The legal pursuit is not worth the cost at the tax payer's expense or for 

judicial economy. 

f. The statue of limitations was exceeded. Respondent makes note of the 

complainant confirmation and admission that the last alleged violation of Mr 

Baker occurred on July 24, 2008 and further alleges the notice of proposed Civil 

Penalty was served on July 23, 2010, stating thot it was 1 day before the 2 year 

stotue of limitations, The complaint was sen/ed and received on July 27, 2010, 3 

days pastttie statute ot limitations. The complaint is therefore time barred. 

Complainants failed again to respond, evaded and circumvented these facts 

presented In respondents brief supporting complaint dismissal faxed 12-20-20' 

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g. Also of note Is that the operations had already stopped for the time of 

the alleged violations. 

WHEREFORE, the respondent prays that this Honorable Court will grant the 

Motion for judgment to dismiss this case in efforts of judicial economy. 

Respectfully Submitted, 

Michael B. Seiig, MD, FACC , CFI-H 

Date \ -

.-^-AV 
01/07/2011 8:17PM FAX @10013/0023 

O .''t-^'::r':,u:.h.^ i^il'U 

or'rrSSSoo 2895 SW 145th Avenue. Suite 148 

Federal Aviation 

Admrnrstrollon 

September 23, 2010 

File Number: 2010SO950353 

Dr. Michael B. Seiig 

President 

M And R Helicopters. LLC 

2045 Westgate Drive 

Bethlehem, PA 18017 

Miramar, FL 33027 

Certified Mail > Return Receipt Requested 

Dear Dr. Seiig; 

On July 21 and 23, 2009, we inspected M And R Helicopters, LLC's drug and 

alcohol testing programs to determine compliance with 49 CFR part 40 and 14 CFR 

part 120, (formerly 14 CFR part 121, appendices I and J). This letter addresses 

which issue described in the letter of investigation that is still under investigation 

and which Issues we will close with administrative action. 

The following issue included in our August 14, 2009. letter of investigation (File 

Number: 2009SO950434) will be addressed in separate correspondence: 

• M and R Helicopters, LLC did not determine that Edward Baker, a contractor, 

was covered under a FAA-mandated drug and alcohol testing program prior 

to using his services. 

We havre reviewed all available information concerning the following issues from our 

August 14, 2009, letter of investigation (File Number: 2009SO950434); 

1. M and R Helicopters, LLC did not determine that Eugene Mcintosh, a contractor, 

was covered under a FAA-mandated drug and alcohol testing program prior to 

using his sen/ices. 

2. M and R Helicopters, LLC did not conduct pre-employment drug tests and 

receive verified negative test results prior to hiring Eugene Mcintosh and Edward 

Baker to perform safety-sensitive functions, 

We have decided not to take legal enforcement action for these apparent violations. ) 

Instead, we are issuing this warning notice. J 

http;//Yvvyw,faa.gov/about/office_org/heac)quarters_offlce$/av9/offices/aam/drug_alcohol/ 

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We continue to expect compliance with all applicable drug and alcohol regulations. 

Sincerely, 

^^::;^<^:=^>«^^rf5^ ^C<i.tCt^iC^*-*-^^ < , 

Lat(^ya B. Williams, inspector 

Eastern Compliance and Enforcement Center 

Drug Abatement Division 

Office of Aerospace Medicine 

U.S. Department of Transportaiion Feaeral AvIaUon Admlnistraifon 

eso/tLo l S WQ * 

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Michael Seiig, MD, FACC. CFI-H 

28i6 0refield Road 

Allentowa PA. 18104 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviation Administration 

Cynthia Dominik, Laura Ponto, 

Latonya Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

Honorable Judge Ronnie Yoder 

Federal Docket. No: 2010-1211 

RESPONDENT'S REPLY TO COMPLAINANTS RESPONSE TO JUDGMENT TO DISMISS 

FAILURE TO PROPERLY RFSPOND OR MEET FILING DEADLINES 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, CFl-H, 

principle for M & R Helicopters, LLC, (MRH) (non-operational since 2007) vv/hom 

avers and files the following Reply to complainants response to the motion for 

JUDGMENT pertaining to the ongoing complainants failure to properly respond 

or ansv^er filing deadlines in accordance to §13.21B(d). When complainants did 

respond, they failed to plead facts with sufficient specificity in a collaborative 

conclusionary manner, evaded and circumvented specific pleadings, thereby 

adding redundancy and repeated pleadings, squandering scarce judicial 

resources, in malicious and frivolous prosecution, therefore the comploint should 

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be required to be dismissed, 

1. Throughout Ihis litigation, the complainants have refused to address 

specific numerated paragraphs in breach of Federal Rule 3. 

2. Throughout this litigation, complainants have not pleated facts with 

sufficient specificity and in accordance to standard practices. The purpose of 

these standard practices is fo confine the pleading party proof to only those 

acts alleged, thus enabling a responding party to prepare their defense', 

3. Complainants have filed late responses to motions past the 10 day 

deadline period under § Rule 13.218(d). for example, not using actual dates of 

service in attempts to impair the dignity of this court, 

4. The Respondents Motion to Quash, Strike or Dismiss Complaint, with 

associated brief was faxed [Exhibit 1 fox confirmation sheet) to Mr Pontes 

department on November 29, 2010, sent by mall on Novennber 30, 2010. The 

due dote was December 9, 2010. An objection or response was not received or 

served until December 13, 2010, past the due dote under § Rule 13.218(d) 

(Exhibit 2). 

5. Ms Ponto failed to present any evidence as to when the response 

was actually received in her response to this matter. A date was indicated on 

the document itself as to when it was drafted, does not represent on actual 

date of service. 

6. Ms Dominik of the FAA enforcement division of the chief counsel 

'Baker v Rangos, 324 A.2d 498, 505 (Pa Super Cr. 1974 

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colled respondent directly to his personal cell phone admitting that the 

complainants con not file responses v*/ithin the 10 day deadline period, would in 

breach of this regulation and thereby requested a continuance directly to 

respondent. Exhibit 3 shows call log of respondent's telephone showing Ms 

Dominiks number 202-267-7560. 

7. Respondent refused o continuance and requested the case be 

dismissed on these grounds. 

8. Ms Pontos defense is that she never filed a formal continuance, 

perhaps knowing that respondent already denied her verbal request in the 

telephone inquiry by Ms Dominik. 

9. On November 30, 2010, a respondents motion to Strike Allegation was 

faxed and sent to Ms Pontos department to which no objection or answer was 

received within the 10 day deadline under § Rule 13.218(d) (Exhibit T-fax 

confirmation sheet) A late answer was also provided in the collaborative 

correspondence received on December 13, 2010 (Exhibit 4). 

11. There Is no reason for counsel to not be able to respond to any of 

the above deadline dates in accordance to the FAA Rules of CMl Penalty 

Proceedings 14 C.F.R. §13.16 and subpart G, as the Office of Chief Counsel 

employs many attorneys, handles thousands of violations yeariy and therefore 

alternatives ore readily available to cover or substitute for vacation, illness or 

other reasons as is evidenced by Ms Dominik calling directly ihe respondent. 

12. This case does not have exclusive authority of only Ms Ponto, as 

eZO/LlO® SWQ <r VVd stLseetsos XVd 00:9 L UOS/frO/SO 
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there have already been other intervening attorneys that have reviewed or 

been involved in the case, including Peter Lynch, Esq., (letter October 21, 2010, 

(exhibit 1 ], Ctiuries Roley, Esq. (October 1, 2010 telephone hearing, transcripts 

outstanding), Ms Cynthia Dominik, Esq. (Telephone call December 8, 2010). 

13. Respondent avers there is no excuse or reason for late filing of 

objections or answers. 

14, By complainants not addressing all numerated paragraphs, thereby 

selectively answering some and evading and circumventing other pleadings or 

using insufficient specificity in their pleadings, complainants have added 

redundancy and repeated pleadings, squandering scarce judicial resources, in 

malicious and frivolous prosecution, therefore the complaint should be required 

to be dismissed, 

WHEREFORE, the respondent prays that this Honorable Court will grant the 

Motion for judgment to dismiss the case due to late filing and other procedural 

defects in accordance to Rules 13.218(d). 

Respectfully Submitted, 

Michael B. Seiig, MD, FACC, CFI-H ^ 

Date V ^ 

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Michael Seiig, MD, PACC . 

.:^- 2816 Orefield Road 

Allentown, PA. 16104 

T ^ M NOV Z 9 2010 

U.5. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviotlon Administration 

Laura Ponto, Latonya wmiams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

FAA Case: No: 2009SO950434 

RESPONDENT'S MOTION TO QUASH, STRIKE OR DISMISS COMPLAINT 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, 

principle for MR Helicopters, LLC, (MRH) whom overs and files the following 

MOTION TO QUASH, STRICKEN OR DISMISS THE COMPLAINT submitted by the 

Federal Aviation Administration associate Laura Ponto, Esq, hereby asserting by 

respondent thai the allegations made in the complaint are not proper or 

reasonable and thereby the complaint should be Quashed, Stricken and 

Dismissed. 

1. On July 21. 2009, FAA Officers. Latonya Williams and Kimmy Poon 

appeared for the initial scheduled inspection at the joint office of Lifeline 

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1210022/0023 

Michael Seiig, MD, FACC. 

2816 Orefield Road 

Allentown, PA. 18104 liiY*^^ 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

Federal Aviation Administration 

Laura Ponto, Latonyo Williams 

Complainants 

M & R Helicopters, LLC. 

Respondent 

FAA Cose: No: 2009SO950434 

RESPONDENT'S MOTION TO STRIKE ALLEGATION. 

MR BAKER WAS NOT ON A DRUG/ALCOHOL PROGRAM 

AND NOW, comes respondent, MICHAEL B. SELIG, MD, FACC, 

principle for MR Helicopters, LLC, (MRH), (no longer existing) whom avers and 

files the following MOTION to Strike the Allegation claimed by Ms Latonya 

Williams that Mr Baker was not on an approved Drug/Alcohol program during 

the stated period. 

1. On July 21, 2009, FAA Officers, Latonya Williams and Kimmy Poon 

appeared for an inspection of the drug and alcohol abatement records at the 

prior office of MR Helicopters, LLC. 

2. On July 23, 2009, FAA Officer, Latonya Williams returned alone for the 

of 3 Hk^ Y 

eso/ssol SWQ * VVd StLSeGt20 2 XVd L0:9L LL0S/t?0/20 
01/07/2011 S 19PM FAX ig|yu.iJ/wy^ o 

U.S. DEPARTMENT OF TRANSPORTATION 

Federal Aviaflon Aclmlnlstrcitlon 

Cynthia Dominik, Laura Ponto, 

Latonya Williams 

Complainants 

M & K Helicopters, UC. 

Respondent 

Honorable Judge Rcnnl« Yod«i 

Docket: 2010-1211 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY thai I have this day served the foregoing entrie(s): 

Deposition or Latonya Williams and Federal Hearing Location 

MOTION FOR HEARING LOCATION IN ALLENTOWN. PA 

MOTION TO HAVE THE PRE-TRIAL DEPOSITION Of LATONYA WILLIAMS 

At GALLAGHER REPQRTIMG. ALLENTOWN. PA. 

RESPONDENT'S MOTION FOR JUDGMENT TO DISMISS 

TRUTHS OF ADMISSIONS 

RESPONDENT'S REPLY TO COMPLAINANTS RESPONSE TO JUDGMENTTO DISMISS 

FAILURE TO PROPERLY RESPOND OR MEET FILING DEADLINES 

upon all parties of record in this proceeding, in accordance with ttie requirements ot Rule 29 

pursuant to 28 U. S. C. § 1746 , 

Service bv fir^t-class mail, Dostaae prepaid nddressed as follows: 

Federol Aviation Administration 

800 Independence Avenue, SW 

Wilbur Wright Avenue-Suite 2W1000 

Washington, D.C. 20591 

Att: Hearing Docket Clerk, AGC-43 0 

FAX 202 493 5142 

Laura Ponto, Esq. 

Enforcement Division/AGC-300 

Office of the Chief Counsel 

FAA 

800 Independence Avenue, SW 

Washington, DC 20591 

FAX 202 267 5106 

The Honorable Ronnie A. Yoder 

US Department of Transportation 

Office ot Hearings, r^-20, Room El 2-320 

1200 New Jersey Avenue. S.E, 

Washington, DC 20590 

FAX 202 366 7536 

^ ^ 

\.\.n 

Michael B. Seiig, MD, FACC. 

2816 Orefield Road 

Allentown. Pa. 16104 

610 360 3953 

Date; .t-^-^A 

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