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COMMONWEALTH OFMASSACHUSETTS
BRISTOL, ss. SUPERIOR COURT DEPT.
C.A. NO, 2173-CV-00516
CHRISTY RICHARD,
Plaintif
BRISTOL, SS SUPERIOR COURT
- FILED
ATTUCK, LLC,
JUL 22 2021
Trustee of the 88 Harrison Trust
u/d/t dated September 7, 2005, as Trustee of MARC J. SANTOS, ESQ.
COLKEN TOWNHOUSE CLERK/MAGISTRATE
CONDOMINIUM TRUST u/d/t
dated October 4, 2006,
Defendant.
AMENDED VERIFIED COMPLAINT FOR INJUNCTIVE RELIEF
Plaintiff Christy Richard, pursuant to Mass. R. Civ. P. 15(a), hereby amends the Complaint
filed on July 20, 2021 and commences this action for injunctive relief against the Colken Townhouse
Condominiums for violations of to Massachusetts General Laws, c. 183A and the by-laws of the
Colken Townhouse Condominium Trust when it refused to issue documents necessaty to effectuate
the sale of her condominium unit located in Fall River, Massachusetts. Richard alleges the
following:
THE PARTIES
1 Plaintiff CHRISTY RICHARD (“Richard”) is an individual, female person of legal
age and a resident of Fall River, Massachusetts. At all times:relevant to this action, Richard owned the
condominium unit known as Unit 101 of the Colken Townhouse Condominiums located at 88
Harrison Street, Fall River, Massachusetts 02723.
2. Defendant COLKEN TOWNHOUSE CONDOMINIUM TRUST u/d/t dated
October 4, 2006 was created under Massachusetts General Laws, c. 183A as a condominium of unit
owners consisting of five (5) units located at 88 Harrison Street, Fall River, Massachusetts 02743
(the “Colken Townhouse Condominiums”). The Colken Townhouse Condominium Trust is being
sued through its Trustee, Attuck LLC, Trustee of the 88 Harrison Trust u/d/t dated September 7,
2005. At all times relevant to this action, Defendant Colken Townhouse Condominium Trust
maintained, managed, regulated, and preserved the Colken Townhouse Condominiums.
JURISDICTION AND VENUE
3. The jurisdiction of this Court is invoked pursuant to Mass. Gen. Laws c. 214, § 1.
Page 1 of6
4. Venue is proper because the actions complained of occurred in Bristol County,
Massachusetts.
5 Personal jurisdiction exists over Defendant in that it maintains sufficient minimal
contacts in the Commonwealth of Massachusetts. Specifically, Defendant engages in systematic and
continuous activity in the Commonwealth of Massachusetts. Moreover, the actions complained of
herein occurred in the Commonwealth of Massachusetts.
FACTUAL ALLEGATIONS
6. Richard owns Unit 101 by way of a deed dated October 31, 2006 and recorded on
November 1, 2006 in the Bristol County Registry of Deeds at Book 6466, Page 316.
7. Richard is a licensed real estate agent.
8. In early April 2021, Richard decided to put her unit up for sale.
9. Richard quickly found an interested buyer named Lyndsey Julius (“Julius”).
10. On April 27, 2021, in anticipation of the sale of her unit, Richard sent an e-mail to
Gregory Koldys, Esq., attorney for Colken Townhouse Condominiums, requesting “a copy of
financial statements, condo docs, proof of insurance .... [and] a 6D certificate for the sale of [het]
condo.” [Ex. AJ.
11. On May 20, 2021, Richard entered into a Purchase and Sales Agreement with Julius
(hereinafter the “Buyer”) to sell Unit 101 with an agreed upon closing date of June 29, 2021 (Ex. B).
12, In order to convey clear title to the Buyer, Richard is required to obtain and record
in the chain of title a statement from Colken Townhouse Condominiums as required by Mass. Gen.
Laws, c. 183A(6)(d) that there are no outstanding fees owed for common expenses and assessments
that could result in a lien on the property. In real estate conveyancing circles, this document is more
commonly known as a “6(d) Certificate.”
13. Defendant is the only entity or person who has the power and the ability to issue a
6@) Certificate on behalf of Colken Townhouse Condominiums in order to allow Richard to convey
clear title of her property to the Buyer.
14. In order for the Buyer to obtain final lender approval a mortgage so she can proceed
with the closing on the unit, more commonly known as a “clear to close,” the Buyer is required to
provide her lender with the following documents: (1) a completed HUD Condominium
Questionnaire; (2) a condominium budget; (3) the condominium declaration of trust; (4) the
condominium by-laws; and (4) a mastet condominium insurance policy with the lendet’s mortgagee
clause: Norcom Mortgage, ISAOA/ATIMA, P.O. Box 1317, Avon, CT 06001 (collectively the
“Buyer condominium documents”).
15. Neither the defendant, nor Attorney Koldys ever tesponded to Richards’ April 27,
2021 e-mail.
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16. On June 7, 2021, Richards still had not received the 6(d) Certificate and the Buyer
condominium documents, so she hand-delivered to Attorney Koldys’ office in Dartmouth,
Massachusetts a type-written list of the requested items the Buyer’s mortgage broker sent her (the
“June 7, 2021 list”).
17. The June 7, 2021 list included a 6(d) Certificate and the Buyer condominium
documents. Richard also wrote by hand the Buyer’s name on the June 7, 2021 list.
18. Richard also hand-delivered to Attorney Koldys’ office a blank HUD Condominium
Questionnaire.
19. During the month of June, as the June'29, 2021 closing date was quickly
approaching, Richard left several messages with staff at Attorney Koldys’ office to follow up on the
status of the 6(d) Certificate and the Buyer condominium documents, however, no one ever
returned her phone calls.
20. On June 28, 2021, due to Defendant’s refusal to provide the 6(d) Certificate and the
Buyer condominium documents, Richard and the Buyer were forced to extend the closing date of
the sale to July 30, 2021.
21. On July 1, 2021, Richards’ attorney e-mailed a blank HUD Condominium
Questionnaire to Attorney Koldys (Ex. C).
22. Neither the defendant, nor Attorney Koldys ever responded to Richards’ attorney’s
July 1, 2021 e-mail.
23. On Friday, July 9, 2021, Richards’ attorney called Attorney Koldys by phone and
informed him that unless Defendant produced the 6(d) Certificate and the Buyer condominium
documents by the close of business on Monday, July 12, 2021, Richard would take legal action.
24, On July 14, 2021, Richards’ attorney e-mailed Attorney Koldys requesting the status
of the requested documents (Ex. D) (“Does your client intend to provide those condo documents”)
25. Neither the defendant, nor Attorney Koldys ever responded to Richards’ attorney’s
July 14, 2021 e-mail. .
26. As of the time of the filing of this complaint, Defendant has refused to produce the
6(d) Certificate and the Buyer condominium documents despite Richard’s repeated requests.
COUNTI
VIOLATION OF MASS. GEN. LAWS, c. 183A § 6(d)
27. Plaintiff heseby incorporates by reference paragraphs 1-26 of this Complaint as
though fully set forth herein.
28. Mass. Gen. Laws, c. 183 § 6(d) (“Section 6(d)”) provides in pertinent part:
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The statement shall be furnished within ten business days after receipt of a written
request, upon payment of a reasonable fee, and shall be binding on the organization
of unit owners, the governing body of the organization of unit owners, and every
unit owner; provided, however, that no fee shall be required of any mortgagee, in
connection with a foreclosure of a mortgage, who has given the organization notice
of its intention to foreclose a mortgage upon the unit:
Mass. Gen. Laws, c. 183 § 6(d).
29. On Apzil 27, 2021 and June 7, 2021, Richard made written requests to Defendant
through its attorney for the 6(d) Certificate, however, Defendant failed to produce the statement within
10 days as required by Section 6(d).
30. Defendant never responded to any of Richard’s requests for the 6(4) Certificate.
31. Defendant never informed Richard of the required fee to process the 6(d) Certificate,
which she would have paid had she received proper notification.
32. Defendant’s conduct as described above constitutes a violation of Mass. Gen. Laws, c.
183 § 6(d).
33, Plaintiff has been harmed thereby.
COUNT II
VIOLATION OF THE COLKEN TOWNHOUSE CONDOMINIUM TRUST BY LAWS
34. Plaintiff hereby incorporates by reference.paragraphs 1-33 of this Complaint as
though fully set forth herein.
35. Article II of the Colken Townhouse Condominium Trust By Laws (“Article IT”)
gives the Colken Townhouse Condominiums the power to execute instruments that are in the best
interest of the Unit Owners. : Article IIprovides in pertinent pat:
Generally, in all matters not hearing otherwise specified, to control, manage and
dispose of the trust property as if the trustees were the absolute owners thereof and
do any and all acts, including the execution of any instruments, which their
performance thereof shall be shown to be in their judgment for the best interests of
the Unit Owners.
‘The Colken Townhouse Condominium Trust By Laws, Art. II at 7.
36. Selling Unit 101 is in Richards’ best interest.
37. Richards does not have the power to issue documents necessary to effectuate the
sale of her unit — a 6(d) Cettificate and the Buyer Condominium Documents — but rather, only
Defendant has this power.
38. By refusing to issue the 6a) Certificate and the Buyer Condominium Documents,
Defendant had violated the Colken Townhouse Condominium Trust By Laws.
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39. Plaintiff has been harmed thereby.
COUNT IT
BREACH OF CONTRACT
40. Plaintiff hereby incorporates by reference paragraphs 1-39 of this Complaint as
though fully set forth herein. ~ ‘
41. As 2 condominium owner, and for valuable consideration paid, Richards enjoye the
benefits conferred upon her by the Colken Townhouse Condominiums including the performance
of administrative tasks on her behalf such as issuing a 6(d) Certificate and the Buyer Condominium
Documents in the event of a sale.
42. _—_ By refusing to issue the 6@) Certificate and the Buyer Condominium Documents,
Defendant has failed to perform the contractual obligations it owed to Richard as a unit owner.
43. Defendant’s conduct as described above constitutes 2 breach of contract.
44. Plaintiff has been harmed thereby.
COUNT IV
BREACH OF FIDUCIARY DUTY
45. Plaintiff hereby incorporates by reference paragraphs 1-44 of this Complaint as
though fully set forth herein.
46. The Colken Townhouse Condominiums owe a fiduciary duty to its Unit Owners to
act in their best interest at all times.
47, Selling Unit 101 is in Richards’ best interest.
48. By refusing to issue the 6(d) Certificate and the Buyer Condominium Documents
without any explanation whatsoever, Defendant has breached a fiduciary duty it owes to Richard.
49. Plaintiff has been harmed thereby.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays that the Court grant the following relief,
An order directing Defendant to do the following; (1) issue a 6(d) Certificate to Richard that
sets forth the outstanding common expenses and assessments, if any, owed by Richards to
Colken Townhouse Condominiums in connection with her ownership of Unit 101; (2)
complete a HUD Condominium Questionnaire; (2) provide a copy of the condominium
budget; and (4) provide a copy of the master condominium insurance policy with the
lender’s mortgagee clause: “Norcom Mortgage, ISAOA/ATIMA, P.O. Box 1317, Avon, CT
06001.”
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An order declaring that the acts and practices complained of herein are in violation of
Massachusetts General Laws, chapter 183A and the Colken Townhouse Condominium
Trust By Laws.
3. An order enjoining and permanently restraining Defendant from further violations of
Massachusetts General Jaws, chapter 183A and the Colken Townhouse Condominium
Trust By Laws.
A finding that Defendant stands liable to Plinuiff for an award of Plaintiffs reasonable
attorneys’ fees, litigation costs and other costs of this action, together with a post-trial hearing to
determine the amount of Plaintiff s reasonable attorneys’ fees taxable to Defendant, along with
a determination of the Plaintiffs litigation costs and expenses taxable to Defendant and
Such other and further relief as this Honorable Court deems just and proper.
VERIFICATION
Christy Richard, being duly sworn, deposes and says that she is the plainuiff in the above-
entitled action, that she has read the foregoing complaint and knows the contents thereof, and that
the same is true of her own knowledge, except as to matters therein and stated to be alleged on
information and belief and as to those matters she believes them to be tue. Richard relies on yje
whierek_
ue Yar, CHRISTY RD
Plaintiff,
CHRISTY RICHARD
By Her Atorney,
s/ Mark P. Gagli: i
Mark P. Gagliardi (MA BBO #657622)
LAW OFFICE OF MARK P. GAGLIARDI
201 Wayland Avenue, Suite §
Providence, RI 02906
(401) 277-2030 (office)
(401) 87-6666 (cell)
(401 > 77-202 1 fax)
ark@r sliarcilawe net
Date: July 21, 2021
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ae COMMONWEALTH OFMASSACHUSETTS BRISTOL, ss. SUPERIOR COURT DEPT. C.A. NO, 2173-CV-00516 CHRISTY RICHARD, Plaintif BRISTOL, SS SUPERIOR COURT - FILED ATTUCK, LLC, JUL 22 2021 Trustee of the 88 Harrison Trust u/d/t dated September 7, 2005, as Trustee of MARC J. SANTOS, ESQ. COLKEN TOWNHOUSE CLERK/MAGISTRATE CONDOMINIUM TRUST u/d/t dated October 4, 2006, Defendant. AMENDED VERIFIED COMPLAINT FOR INJUNCTIVE RELIEF Plaintiff Christy Richard, pursuant to Mass. R. Civ. P. 15(a), hereby amends the Complaint filed on July 20, 2021 and commences this action for injunctive relief against the Colken Townhouse Condominiums for violations of to Massachusetts General Laws, c. 183A and the by-laws of the Colken Townhouse Condominium Trust when it refused to issue documents necessaty to effectuate the sale of her condominium unit located in Fall River, Massachusetts. Richard alleges the following: THE PARTIES 1 Plaintiff CHRISTY RICHARD (“Richard”) is an individual, female person of legal age and a resident of Fall River, Massachusetts. At all times:relevant to this action, Richard owned the condominium unit known as Unit 101 of the Colken Townhouse Condominiums located at 88 Harrison Street, Fall River, Massachusetts 02723. 2. Defendant COLKEN TOWNHOUSE CONDOMINIUM TRUST u/d/t dated October 4, 2006 was created under Massachusetts General Laws, c. 183A as a condominium of unit owners consisting of five (5) units located at 88 Harrison Street, Fall River, Massachusetts 02743 (the “Colken Townhouse Condominiums”). The Colken Townhouse Condominium Trust is being sued through its Trustee, Attuck LLC, Trustee of the 88 Harrison Trust u/d/t dated September 7, 2005. At all times relevant to this action, Defendant Colken Townhouse Condominium Trust maintained, managed, regulated, and preserved the Colken Townhouse Condominiums. JURISDICTION AND VENUE 3. The jurisdiction of this Court is invoked pursuant to Mass. Gen. Laws c. 214, § 1. Page 1 of6 4. Venue is proper because the actions complained of occurred in Bristol County, Massachusetts. 5 Personal jurisdiction exists over Defendant in that it maintains sufficient minimal contacts in the Commonwealth of Massachusetts. Specifically, Defendant engages in systematic and continuous activity in the Commonwealth of Massachusetts. Moreover, the actions complained of herein occurred in the Commonwealth of Massachusetts. FACTUAL ALLEGATIONS 6. Richard owns Unit 101 by way of a deed dated October 31, 2006 and recorded on November 1, 2006 in the Bristol County Registry of Deeds at Book 6466, Page 316. 7. Richard is a licensed real estate agent. 8. In early April 2021, Richard decided to put her unit up for sale. 9. Richard quickly found an interested buyer named Lyndsey Julius (“Julius”). 10. On April 27, 2021, in anticipation of the sale of her unit, Richard sent an e-mail to Gregory Koldys, Esq., attorney for Colken Townhouse Condominiums, requesting “a copy of financial statements, condo docs, proof of insurance .... [and] a 6D certificate for the sale of [het] condo.” [Ex. AJ. 11. On May 20, 2021, Richard entered into a Purchase and Sales Agreement with Julius (hereinafter the “Buyer”) to sell Unit 101 with an agreed upon closing date of June 29, 2021 (Ex. B). 12, In order to convey clear title to the Buyer, Richard is required to obtain and record in the chain of title a statement from Colken Townhouse Condominiums as required by Mass. Gen. Laws, c. 183A(6)(d) that there are no outstanding fees owed for common expenses and assessments that could result in a lien on the property. In real estate conveyancing circles, this document is more commonly known as a “6(d) Certificate.” 13. Defendant is the only entity or person who has the power and the ability to issue a 6@) Certificate on behalf of Colken Townhouse Condominiums in order to allow Richard to convey clear title of her property to the Buyer. 14. In order for the Buyer to obtain final lender approval a mortgage so she can proceed with the closing on the unit, more commonly known as a “clear to close,” the Buyer is required to provide her lender with the following documents: (1) a completed HUD Condominium Questionnaire; (2) a condominium budget; (3) the condominium declaration of trust; (4) the condominium by-laws; and (4) a mastet condominium insurance policy with the lendet’s mortgagee clause: Norcom Mortgage, ISAOA/ATIMA, P.O. Box 1317, Avon, CT 06001 (collectively the “Buyer condominium documents”). 15. Neither the defendant, nor Attorney Koldys ever tesponded to Richards’ April 27, 2021 e-mail. Page 2 of 6 16. On June 7, 2021, Richards still had not received the 6(d) Certificate and the Buyer condominium documents, so she hand-delivered to Attorney Koldys’ office in Dartmouth, Massachusetts a type-written list of the requested items the Buyer’s mortgage broker sent her (the “June 7, 2021 list”). 17. The June 7, 2021 list included a 6(d) Certificate and the Buyer condominium documents. Richard also wrote by hand the Buyer’s name on the June 7, 2021 list. 18. Richard also hand-delivered to Attorney Koldys’ office a blank HUD Condominium Questionnaire. 19. During the month of June, as the June'29, 2021 closing date was quickly approaching, Richard left several messages with staff at Attorney Koldys’ office to follow up on the status of the 6(d) Certificate and the Buyer condominium documents, however, no one ever returned her phone calls. 20. On June 28, 2021, due to Defendant’s refusal to provide the 6(d) Certificate and the Buyer condominium documents, Richard and the Buyer were forced to extend the closing date of the sale to July 30, 2021. 21. On July 1, 2021, Richards’ attorney e-mailed a blank HUD Condominium Questionnaire to Attorney Koldys (Ex. C). 22. Neither the defendant, nor Attorney Koldys ever responded to Richards’ attorney’s July 1, 2021 e-mail. 23. On Friday, July 9, 2021, Richards’ attorney called Attorney Koldys by phone and informed him that unless Defendant produced the 6(d) Certificate and the Buyer condominium documents by the close of business on Monday, July 12, 2021, Richard would take legal action. 24, On July 14, 2021, Richards’ attorney e-mailed Attorney Koldys requesting the status of the requested documents (Ex. D) (“Does your client intend to provide those condo documents”) 25. Neither the defendant, nor Attorney Koldys ever responded to Richards’ attorney’s July 14, 2021 e-mail. . 26. As of the time of the filing of this complaint, Defendant has refused to produce the 6(d) Certificate and the Buyer condominium documents despite Richard’s repeated requests. COUNTI VIOLATION OF MASS. GEN. LAWS, c. 183A § 6(d) 27. Plaintiff heseby incorporates by reference paragraphs 1-26 of this Complaint as though fully set forth herein. 28. Mass. Gen. Laws, c. 183 § 6(d) (“Section 6(d)”) provides in pertinent part: Page 3 of 6 The statement shall be furnished within ten business days after receipt of a written request, upon payment of a reasonable fee, and shall be binding on the organization of unit owners, the governing body of the organization of unit owners, and every unit owner; provided, however, that no fee shall be required of any mortgagee, in connection with a foreclosure of a mortgage, who has given the organization notice of its intention to foreclose a mortgage upon the unit: Mass. Gen. Laws, c. 183 § 6(d). 29. On Apzil 27, 2021 and June 7, 2021, Richard made written requests to Defendant through its attorney for the 6(d) Certificate, however, Defendant failed to produce the statement within 10 days as required by Section 6(d). 30. Defendant never responded to any of Richard’s requests for the 6(4) Certificate. 31. Defendant never informed Richard of the required fee to process the 6(d) Certificate, which she would have paid had she received proper notification. 32. Defendant’s conduct as described above constitutes a violation of Mass. Gen. Laws, c. 183 § 6(d). 33, Plaintiff has been harmed thereby. COUNT II VIOLATION OF THE COLKEN TOWNHOUSE CONDOMINIUM TRUST BY LAWS 34. Plaintiff hereby incorporates by reference.paragraphs 1-33 of this Complaint as though fully set forth herein. 35. Article II of the Colken Townhouse Condominium Trust By Laws (“Article IT”) gives the Colken Townhouse Condominiums the power to execute instruments that are in the best interest of the Unit Owners. : Article IIprovides in pertinent pat: Generally, in all matters not hearing otherwise specified, to control, manage and dispose of the trust property as if the trustees were the absolute owners thereof and do any and all acts, including the execution of any instruments, which their performance thereof shall be shown to be in their judgment for the best interests of the Unit Owners. ‘The Colken Townhouse Condominium Trust By Laws, Art. II at 7. 36. Selling Unit 101 is in Richards’ best interest. 37. Richards does not have the power to issue documents necessary to effectuate the sale of her unit — a 6(d) Cettificate and the Buyer Condominium Documents — but rather, only Defendant has this power. 38. By refusing to issue the 6a) Certificate and the Buyer Condominium Documents, Defendant had violated the Colken Townhouse Condominium Trust By Laws. Page 4 of6 39. Plaintiff has been harmed thereby. COUNT IT BREACH OF CONTRACT 40. Plaintiff hereby incorporates by reference paragraphs 1-39 of this Complaint as though fully set forth herein. ~ ‘ 41. As 2 condominium owner, and for valuable consideration paid, Richards enjoye the benefits conferred upon her by the Colken Townhouse Condominiums including the performance of administrative tasks on her behalf such as issuing a 6(d) Certificate and the Buyer Condominium Documents in the event of a sale. 42. _—_ By refusing to issue the 6@) Certificate and the Buyer Condominium Documents, Defendant has failed to perform the contractual obligations it owed to Richard as a unit owner. 43. Defendant’s conduct as described above constitutes 2 breach of contract. 44. Plaintiff has been harmed thereby. COUNT IV BREACH OF FIDUCIARY DUTY 45. Plaintiff hereby incorporates by reference paragraphs 1-44 of this Complaint as though fully set forth herein. 46. The Colken Townhouse Condominiums owe a fiduciary duty to its Unit Owners to act in their best interest at all times. 47, Selling Unit 101 is in Richards’ best interest. 48. By refusing to issue the 6(d) Certificate and the Buyer Condominium Documents without any explanation whatsoever, Defendant has breached a fiduciary duty it owes to Richard. 49. Plaintiff has been harmed thereby. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays that the Court grant the following relief, An order directing Defendant to do the following; (1) issue a 6(d) Certificate to Richard that sets forth the outstanding common expenses and assessments, if any, owed by Richards to Colken Townhouse Condominiums in connection with her ownership of Unit 101; (2) complete a HUD Condominium Questionnaire; (2) provide a copy of the condominium budget; and (4) provide a copy of the master condominium insurance policy with the lender’s mortgagee clause: “Norcom Mortgage, ISAOA/ATIMA, P.O. Box 1317, Avon, CT 06001.” Page 5 of 6 An order declaring that the acts and practices complained of herein are in violation of Massachusetts General Laws, chapter 183A and the Colken Townhouse Condominium Trust By Laws. 3. An order enjoining and permanently restraining Defendant from further violations of Massachusetts General Jaws, chapter 183A and the Colken Townhouse Condominium Trust By Laws. A finding that Defendant stands liable to Plinuiff for an award of Plaintiffs reasonable attorneys’ fees, litigation costs and other costs of this action, together with a post-trial hearing to determine the amount of Plaintiff s reasonable attorneys’ fees taxable to Defendant, along with a determination of the Plaintiffs litigation costs and expenses taxable to Defendant and Such other and further relief as this Honorable Court deems just and proper. VERIFICATION Christy Richard, being duly sworn, deposes and says that she is the plainuiff in the above- entitled action, that she has read the foregoing complaint and knows the contents thereof, and that the same is true of her own knowledge, except as to matters therein and stated to be alleged on information and belief and as to those matters she believes them to be tue. Richard relies on yje whierek_ ue Yar, CHRISTY RD Plaintiff, CHRISTY RICHARD By Her Atorney, s/ Mark P. Gagli: i Mark P. Gagliardi (MA BBO #657622) LAW OFFICE OF MARK P. GAGLIARDI 201 Wayland Avenue, Suite § Providence, RI 02906 (401) 277-2030 (office) (401) 87-6666 (cell) (401 > 77-202 1 fax) ark@r sliarcilawe net Date: July 21, 2021 Page 6 of 6