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  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
  • Iskyo Aronov Plaintiff vs. Sound Connection Distributors Inc, et al Defendant 3 document preview
						
                                

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Filing# 143006504 E-Filed 01/31/2022 06:55:55 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ISKYO ARONOV, a Florida Resident, Plaintiff, Case No. CACE-21-016867 V SOUND CONNECTION DISTRIBUTORS, INC., a Florida for Profit Corporation,and SHIMON SWISSA, a/k/a SHIMMON SWISSA, a Florida Resident, Defendants. i PLAINTIFF'S FIRST AMENDED COMPLAINT ISKYO Plaintiff, ARONOV, by and through a Florida resident ("Aronov") ("Plaintiff'), its undersigned Counsel, files this First Amended Complaint pursuant to Fla. R. Civ. P. 1.190 against Defendants, SOUND CONNECTION DISTRIBUTORS, INC., a Florida for-profit Corporation,and SHIMON SWISSA, a/kja SHIMMON SWISSA, a Florida resident,and in support thereof allegesas follows: PARTIES, JURISDICTION AND VENUE 1. Plaintiff Aronov is an individual and resident o f Miami-Dade County, Florida. 2. Defendant, Sound Connection Distributors,Inc. ("Sound"), is a Florida for-profit Corporationwhich conducts business in Broward County, with a principaladdress of 2801 Greene Street,Hollywood, FL 33020. 3 Defendant, Shimon Swissa a/k/a Shimmon Swissa ("Swissa"),is an individual and resident of Miami-Dade County, Florida and is otherwise suijuris. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/31/2022 06:55:55 PM.**** 4. This is an action for damages that exceeds $30,000.00 exclusive of costs, interest, and attorneys' fees. 5. Venue is proper in this Court pursuant to Florida Statute Section 47.011 and 47.051 as Broward County is the county where the causes of action accrued and where under the Agreement. its obligations Plaintiffperformed 6. Venue is proper in this Court pursuant to Florida Statute Section 47.011 and 47.051 as Broward County is the county where the property in litigation is located,with an address of: 2801 Greene Street,Hollywood, Florida,33020. 7. Venue is proper in this Court pursuant to Florida Statute Section 47.021 as one or more Defendant(s)resides or has placeof business in a principal Broward County. GENERAL ALLEGATIONS 8 On or about March 22, 2019, Plaintiff Aronov entered into a written and signed .., Agreement, in two writings(hereinafter "the Agreement") with Defendant Swissa, who, upon information and belief,is the principalshareholder of Defendant Sound. This Agreement is marked and attached hereto as composite Exhibit "A." 9- The subjectof the Agreement was the Business and property located at: 2801 Greene Street,Hollywood, Florida,33020 (hereinafter "the Property"). 10. Defendant Swissa is also the President of Defendant Sound, and on information and belief,is the principalor sole shareholder ofDefendant Sound. 11. Defendant Sound is the owner of the Property, but part of Plaintiff's Agreement with Defendant Swissa was that the Property would be transferred by Defendant Sound, to a new entity,named 2801 Greene Street,LLC (hereinafter "the new entity?) 2 12. Swissa agreed to first pay off the two existing"partners"on the Property, to unwind their respectiveShareholder Agreements, which would allow him to reobtain 100% interest in the Property. Swissa would then cause Defendant Sound to transfer the Property to the new entityby using his ownersh* and control of Defendant Sound, therebycausingthe transfer. This was to be done once Plaintiff sent the necessary funds. Plaintiff agreed to furnish said funds via the trust account of Joseph Timlichman Law, PLLC (hereinafter "Timlichman"). Composite Exhibit "A" is signedby Defendant Swissa in his personal capacity. 13. because the Property Additionally, is an investment property which produces rental income, Plaintiff and Defendant agreed as part ofthe Agreement to allocate 50% of all rental income to Plaintiff Aronov and 50% to Defendant Swissa to be paid by Defendant Sound or the new entity.(See Composite Exhibit "A"). 14. In reliance on the above and pursuant to the Agreement, Plaintiff distributed the agreed upon $1,600,000.00, which series of payments were first wired through the trust account of Timlichman, and then paid over to Defendant Swissa. 15. This was done so Swissa could buy out the partners/creditors of its existing shares,reacquire100% interest in the Property and use his control over the stock to order Sound to transfer the Property to the new entityper the Agreement. 16. According to the Agreement, Defendants were obligatedto make Plaintiff a partner of 2801 Greene Street,LLC, once the two priorpartners'respectiveShareholder Agreements were unwound. While the Agreements were unwound with Plaintiff's money, Plaintiff Aronov was never made a partner. 3 17. In fact,Defendant Swissa received $1.6 million from the Plaintiff, paid offthe priorpartners with whom they had entered into a settlement agreement to unwind its respectiveShareholder Agreements, but blatantlyand egregiouslyfailed to uphold any of his to the obligations Plaintiff under the Agreement. 18. To this day, Defendants have failed to add Plaintiff as a partner in the new entity, have not made him an officer in the new entity, have failed to give him any money received as rental income, failed to transfer title to the property to the new entity, and have failed to uphold any of their obligationsunder the Agreement. 19. All conditions precedent,statutory or otherwise,to the maintenance of this action have been performed,waived, excused, or otherwise occurred. 20. Plaintiff Aronov has engaged and retained undersigned Counsel and is obligatedto pay fees for the prosecutionof this Action. Defendants should be liable to reimburse Plaintiff for reasonable attorneys' fees and costs in the prosecutionof this matter. COUNTI BREACH OF CONTRACT 21. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 22. Plaintiff entered into a written Contract and Agreement with Defendant Shimon a/k/a Shimmon Swissa in his personalcapacityon or about March 22,2019. (Composite Exhibit "A"). 23. The written Agreement contained a provisionwhereby Defendant Swissa was obligatedto order or cause Defendant Sound to transfer the Property to a new entityby using his ownersh* and control over Sound's stock. This was to occur immediately after the two 4 partners were paid off and their Shareholder Agreements were unwound. (See composite Exhibit "A"). 24. Defendant Swissa received $1.6 million from the Plaintiff, through Timlichman's trust account, in a series of payments, and paid offthe prior"partners," therebyunwinding both Shareholder Agreements. 25. Plaintiffperformedits obligationsunder the Agreement by transferring $1.6 million to Defendant Swissa, sent through Timlichman's trust account. 26. Defendants breached the written Contract and Agreement, inter alia,by failingto order the transfer of the Property to the new entityafter funds were received from the Plaintiff. 27. Defendants breached the written Contract and Agreement by failingto add Plaintiff as a partner in the new entity, to make him an failing officer of the new entity, to give him any money received as rental income, and failing failing to uphold any of their obligationsas requiredby the Agreement. 28. The Defendants' numerous breaches were material in nature, and Plaintiff relied on the Defendants' representations regardingthe transfer of the Property and his equity/right to rental income from the Property. 29. Defendants' numerous breaches, include the failure to transfer,to this day, the Property or allocate Plaintiff his equity and rental income amounts as per the Agreement. 30. As a direct and proximate result of the Defendants' above listed breaches and Plaintiff Aronov has suffered damages, including, representations, but not limited to, the $1.6 million paid out, compensatory and consequentialdamages and attorneys'fees. 5 WHEREFORE, Plaintiff ARONOV demands judgment against the Defendants for: damages to be determined at trial togetherwith prejudgment and post judgment interests and costs, and attorneys'fees, and for such other and further relief as this Court deems just and proper. COUNT II DECLARATORY JUDGMENT 31. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 32. There is a bona fide,actual,present, and practicalneed for a declaration as to the rightsof the partiesas to: (i)whether the Defendants breached the Contract with Plaintiff; (ii) whether the Defendants breached their duty of Good Faith and Fair Dealings;(iii) whether performance of the contract as per the agreement and; (iv) the Plaintiff is entitled to specific whether the Plaintiff is entitled to an equitable trust established by this Court to properly allocate the shares and interests in the in the Property, and the rental income from the entity, Property. 33. The facts and underlyingthe written Agreement, Defendants' obligations, breaches thereof,are valid and are presentlyor easilyascertainable and support the entry of a judgment. The partieshave legalor equitablerelations affected by the declaratory Defendants' actions and requirejudicialconfirmation as to their rightsand interests and are entitled to have their rightsvalidated by this Court. 34. Plaintiff and Defendants have adverse interests with respect to the new entity, the Property and the equity and interest in rental income thereof and are all properly before this Court. 6 35. Pursuant to Fla. Stat. 86.011 et. seq., PlaintiffAronov seeks a declaratory judgment as to: (i)whether the Defendants breached the Contract with Plaintiff; whether (ii) the Defendants breached their duty of Good Faith and Fair Dealings;(iii) whether the Plaintiff is entitled to specificperformance of the contract as per the agreement and; (iv) whether the Plaintiff is entitled to an equitabletrust established by this Court to properly allocate the shares and interests in the entity, in the Property and the rental income from the Property. 36. The Defendants, through actions,practicesand expressed positions,has shown an interest that is actual,present, adverse, and to the antagonistic Plaintiff' s respectiverightsand interests described in this Amended Complaint. 37. The Defendants' antagonisticand adverse interest is before the Court by proper process. 38. The relief sought is not merely the giving of legaladvice by the Courts or the answer to but would resolve questionsrelated to questionspropounded from curiosity this bona fide controversy in a manner that would assist the partiesin resolvingtheir dispute. WHEREFORE, Plaintiff requests the entry of a declaratoryjudgment resolvingthe facts and issues set forth hereinabove. COUNT III SPECIFIC PERFORMANCE 39. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 40. Pursuant to Florida Statute Section 86.081 and §86.061, Plaintiff seeks specific performance of the Agreement, and an order from this Court directing the Defendants to convey the Property in accordance with the Agreement. 7 41. The Property in question,and the rental income therefrom, are unique in nature and constitute bargained-forconsideration which cannot to Plaintiff, be replacedsolelyby an award of money damages. Plaintiff would be irreparablyharmed if the subjectProperty is not conveyed to Plaintiff in a manner that will allow Plaintiffto receive the benefit of his bargain.Accordingly,this Court should order specificperformance of the Agreement. WHEREFORE, Plaintiff seeks specificperformance of the Agreement. COUNT IV BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING 42. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 43. On or about March 22,2019, Defendant Swissa entered and executed the Agreement with Plaintiff Aronov and was bound by all its terms, conditions,and obligations. 44. The Agreement is a valid,binding Contract. 45. Plaintiff Aronov reasonably expected to receive all the benefits and entitlements as bargained and provided for in the Agreement, includingthe promise by Defendant Swissa to transfer the Property,by using his stock ownership and control to cause Defendant Sound to make the transfer into a new entity. 46. Plaintiff Aronov reasonablyexpected to receive all the benefits and entitlements as bargained and provided for in the Agreement, particularly after Plaintiff performed its obligations through Timlichman's under the Agreement by wire transferring, trust account, $1,600,000.00 to the Defendants so they could pay offthe prior"partners"on the Property. Defendants have not performed any of their obligationsunder the Agreement. 8 47. The covenant of good faith and fair dealingwas implied in the Agreement, and the above-named Defendants had a duty to act in good faith and deal fairly with Plaintiff Aronov. 48. The covenant of good faith and fair dealingimposed a duty on the above-named Defendants not to commit any act that would injurethe rightso f Aronov to receive the expected benefits of the Agreement. 49. Plaintiff Aronov proceeded in good faith to fulfill his duties and obligations under the Agreement and was continuingto do so at the time that the above-named Defendants breached the Agreement. 50. By such conduct as described above, the Defendants acted in bad faith and denied Plaintiff Aronov the benefits o f the Agreement, and thus, breached the covenant o f good faith and fair dealingwith Plaintiff Aronov. 51. As a direct and proximate result ofthe Defendants' breach ofthe covenant of good faith and fair dealing,Plaintiff Aronov has suffered damages in an amount to be proven at trial. WHEREFORE, Plaintiff ARONOV demands judgment againstthe Defendants for: damages to be determined at trial togetherwith prejudgment and post judgment interests and costs, and attorneys' fees,and for such other and further relief as this Court deems justand proper. COUNT V PROMISSORY AND EQUITABLE ESTOPPEL 52. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 9 53. This is an action for promissory and equitableestoppelagainstthe Defendants, pleaded in the alternative to or in addition to other counts of this First Amended Complaint. 54. For the purposes o f this Count, Plaintiff allegesin the alternative that there was no applicableContract, Agreement, or contractual provision,or that promises were made outside of and covering actions by the partiesthat were not covered by any existingcontract otherwise referred to herein. 55. Defendants made misrepresentations of material fact regardingthe transfer of the both the equity of the property and the rental income to the property and regardingallocating Plaintiff. 56. Defendants should have reasonablyexpectedto induce action or forbearance on and in fact did induce action on the part of the Plaintiff in the the part of the Plaintiff, form of $1,600,000.00 in payments sent through Timlichman's trust account. 57. Plaintiffrelied on the representations to his detriment. 58. Plaintiff suffered detriment caused by significant its reliance on Defendants' in reliance thereof,as he never received his equity his change in position misrepresentations, in the entity, Property, or any rental income from the property as agreed. 59. Defendants continue to collect rent payments from the Property and have not given the Plaintiff any o f the rental income. 60. As a result,Plaintiff has suffered damages. WHEREFORE, Plaintiff ARONOV demands judgment againstthe Defendants for: damages to be determined at trial togetherwith prejudgment and post judgment interests and costs, and attorneys'fees,and for such other and further relief as this Court deems justand proper. 10 COUNT VI CONSTRUCTIVE TRUST 61. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 62. This is an action to impose a constructive trust againstDefendant Swissa's interest in the subjectproperty, via his ownership of Defendant Sound's stock. Defendant Sound is the owner ofrecord ofthe Property. 63. This is an equitableaction as Plaintiff has no adequate remedy at law. 64. By virtue o f the Agreement existingbetween the Plaintiff and the De fendants,the Defendants, through Shimon Swissa, promised,explicitly or implicitly, to transfer the Property to a new entityand allocate Plaintiff an ownership interest in the new entityand an interest in the rental income from the Property. 65. Plaintiff actively engaged and assisted Defendants in leasingthe Property to new tenants, in order to create a revenue stream from rental income. 66. By transferring the $1,600,000.00 from the Plaintiff to their own accounts without giving the Plaintiff his due shares,equityor rental income, Defendants wrongfully took property that,in whole or part, rightfully belonged to the Plaintiff. Thus, the Defendants have unjustlyenriched themselves thereby. 67. which are These egregiousactions have resulted in damage to the Plaintiff, in nature, as the Defendants have concealed their true intent under the Agreement irreparable and have failed to this day to allocate the Plaintiff his due shares,equity,and rental income. 68. Plaintiff seeks to impose a constructive trust on the Property,on a portionof Defendant's Swiss's stock in Defendant Sound, the new entity, and all rental income associated with the Property. 11 69. which Defendants will be unjustlyenriched by the payments of the Plaintiff, Defendants' priorpartners' discharged/recaptured interests in the Property,unless this Court imposes a constructive trust in favor of the Plaintiff. 70. Equity requiresthat a constructive trust be imposed in favor ofthe Plaintiff. WHEREFORE, Plaintiff requests this Court, impose a constructive trust on the Property, a portionof Defendant Swiss's stock in Defendant Sound, the new entity,and all rental income associated with the Propertytogetherwith prejudgment and post judgment interests and costs, attorneys'fees,and for such other and further relief as this Court deems justand proper. COUNT VII EQUITABLE LIEN 71. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 72. This is an action to impose an equitablelien againstShimon Swissa's interest in the subjectproperty, via his ownership of Defendant Swissa's stock in Sound. Defendant Sound is the owner ofrecord ofthe Property. 73. This is an equitableaction,and the Plaintiff has no adequate remedy at law. 74. By virtue o f the Agreement existingbetween the Plaintiff and the De fendants,the Defendants, through Shimon Swissa, promised,explicitly to transfer the or implicitly, Property to a new entityand allocate Plaintiff an ownership interest in the new entityand an interest in the rental income from the Property. 75. Plaintiff activelyengaged and assisted in leasingthe Property to new tenants to create a revenue stream from rental income. 12 76. By transferring the $1,600,000.00 from the Plaintiff to their own accounts without givingthe Plaintiff his due shares,equityor rental income, Defendants wrongfully took property that,in whole or part, rightfully belonged to the Plaintiff. Thus, the Defendants have unjustlyenriched themselves thereby. 77. which are These egregiousactions have resulted in damage to the Plaintiff, irreparablein nature, as the Defendants have concealed their true intent under the Agreement and have failed to this day to allocate the Plaintiff his due shares,equity,and rental income. 78. Equity requiresthat an equitablelien be imposed in favor of the Plaintiff. 79. At a minimum, Plaintiff seeks to impose an equitablelien on a portionof Defendant's Swissa's stock in Defendant Sound, the new entity, the Property and all rental income associated with the Property. 80. which Defendants will be unjustlyenriched by the payments of the Plaintiff, Defendants' priorpartners' discharged/recaptured interests in the Property,unless this Court imposes an equitablelien in favor o f the Plaintiff. WHEREFORE, Plaintiff requests this Court, impose an equitablelien on the Property,on a portionof Defendant's Swissa's stock in Defendant Sound, the new entity,and all rental income associated with the Property togetherwith prejudgment and post judgment interests and costs, fees,and for such other and further relief as attorneys' this Court deems justand proper. COUNT VIII UNJUST ENRICHMENT 81. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 13 82. At all times material herein,Plaintiff conferred a benefit upon the Defendants in the form of payments and/or wire transfers totaling $1,600,000.00. 83. The Defendants voluntarilyaccepted and willfullyretained the $1,600,000.00 but have egregiouslyfailed to uphold their under the Agreement, i.e., obligations to transfer the Property and allocate Plaintiff his equityand share o f the rental income. 84. As such, it would be inequitablefor the Defendants to retain that $1,600,000.00 without paying back the value thereof,as described in the precedingparagraph,and the other benefits which Plaintiff was to receive. 85. There is no adequate available legalremedy at law and the Plaintiff has been damaged as stated significantly herein. WHEREFORE, Plaintiff Aronov demands judgment againstthe Defendants for any and all damages caused by Defendants' unjustenrichment, includingbut not limited to the lost rent amounts owed, costs, fees,if applicable, $1,600,000.00 alreadytendered, attorneys' togetherwith any other and further prejudgment and post judgment interest, relief this Court deems justand proper. COUNT IX TEMPORARY AND PERMANENT INJUNCTIVE RELIEF 86. Plaintiff Aronov of paragraphs 1 through 20 hereby incorporatesthe allegations above as if fullyset forth herein. 87. This is an action for temporary injunctive relief, to be made permanent, thereafter, preventingthe transfer,re-sale,conveyance or assignmentof any stock,interest or equityin the Property and of Defendant Sound to a third or subsequent buyer, which is necessary and appropriatein order to maintain the status harm quo and prevent irreparable to Plaintiff Aronov. 14 88. Injunctiverelief is supportedby the attachments made a part of this Amended Complaint. 89. Injunctiverelief is necessary to preserve the status quo ofthe Property. 90. Plaintiff Aronov has suffered harm through the further and will suffer irreparable failures of the Defendants to provide Plaintiff the benefits he was to receive under the Agreement, especiallyif any portion of the Property is conveyed. 91. Plaintiffhas a clear legalrightto the relief requestedfor the reasons set forth throughout this Complaint. Plaintiff is likelyto succeed on the merits of his case as the Defendants have failed to uphold any of their obligations under the Agreement. 92. Plaintiffhas no adequateremedy at law available to protect and preserve its rights under the Agreement. 93. An injunctionserves the publicinterest for the reasons set forth throughoutthis Complaint. 94. Temporary injunctive relief, to be made permanent, should be issued thereafter, by this Court to prevent the transfer, re-sale,conveyance or assignmentof any stock,interest, or equity in the Property and of Defendant Sound to a third or subsequent buyer, which is harm to necessary and appropriatein order to maintain the status quo and prevent irreparable Plaintiff Aronov. WHEREFORE, Plaintiff requests this Court order a temporary injunction, to thereafter, be made permanent, preventingthe transfer,re-sale,conveyance or assignment of any stock, interest,or equityin the Property and of Defendant Sound to a third or subsequentbuyer, which is necessary and appropriatein order to maintain the status quo, togetherwith 15 and other such further or other relief that prejudgment and post judgment interest, this Court may deem justand proper. PRAYER FOR RELIEF WHEREFORE, Plaintiff Aronov respectfullyrequests that this Court grant all of Plaintiffs' a constructive requestedrelief herein, includingestablishing trust in order to transfer/ facilitate the transfer ofthe ownership ofthe Property, specificperformance, equitablelien,compensatory and consequentialdamages, injunctiverelief,attorneys'fees and costs, togetherwith prejudgment and post judgment interest, and other such further or other relief that this Court may deem justand proper. Dated: January 31,2022 Respectfullysubmitted, Greenspoon Marder, LLP MB Law Group, PLLC Joseph S. Geller,Esq.,Partner 21610 Frontenac Court 200 East Broward Blvd., Suite 1800 Boca Raton, FL 33433 Fort Lauderdale, FL 33301 Tel. (516) 587-3342 Tel. (954) 491-1120 MB@mblaw.group Joseph.geller@gmlaw.com Gloria.Donaire@gmlaw.com By-./s/ Matthew I. Bistritzky By-- /s/ Joseph Geller, Esq. Matthew I. Bistritzky, Esq. Joseph Geller,Esq. FLBar No.:1024661 FL Bar No.: 292771 [BALANCE OF PAGE INTENTIONALLY LEFT BLANKI 16 CERTIFICATE OF SERVICE WE HEREBY CERTIFY and correct copy of the foregoing First Amended that a true Complaint has been e-filed and served on John J. Philips Jr., Esq., at: Service@johnjphilipspa.comon January 31,2022. Greenspoon Marder, LLP MB Law Group, PLLC Joseph S. Geller,Esq.,Partner 21610 Frontenac Court 200 East Broward Blvd., Suite 1800 Boca Raton, FL 33433 Fort Lauderdale, FL 33301 Tel. (516) 587-3342 Tel. (954) 491-1120 MB@mblaw.group Joseph.geller@gmlaw.com Gloria.Donaire@gmlaw.com By-./s/ Matthew I. Bistritzky By-- /s/ Joseph Geller, Esq. Matthew I. Bistritzky, Esq. Joseph Geller,Esq. FLBar No.:1024661 FL Bar No.: 292771 17 , ' I \ ( j. i 144 / , R. U-- -TA EXHIBIT "A' 511 -,ti gJJ J 3\ CIYC.R) I,jl..,Ic 17 IO ACKr /87+191.174.Sv?rR I'-I Y? -T Fi'1-C.ICC LD 1 CV hh ILI.CLL i .Z.n,inJ L -:. . -FU-i.-, I L- EXHIBIT "A" 71n ---Dzw.BJD 150?- S1 5Z.USZIHSC C.. .3-1./ --1- .- - -. - - Twn 3 JSOK . 1 227/7?j=3. ---