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Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 1 of 12 PageID #: 1 RECEIVED JUN 14 2021 UNITED STATES DISTRICT COURT U S DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DISTRICT Of MO ST. LOUIS C/O 4113 Shreve Avenue Saint Louis, Missouri 63115 Email gberey86@yahoo.com 314-776-8444 cell Gary-Louis: Berry -Proper Persona CLAIMANT Case No vs CIVIL RIGHT VIOLATION CITY OF SAINT LOUIS, a municipal 42§ 1983,1985, 1986 1988 corporation 1200 Market Street DEPRIVATION OF RIGHTS Saint Louis, Missouri 63103 UNDER COLOR OF LAW 18 241 Actor: Tishaura Jones-Mayor AND CONSPIRACY 242 Actor: Geoffrey Rose- Law enforcement DSN11516 Actor: l5'Unknown at this time- law enforcement Actor: Benjamin Ellerman-Law enforcement DSN 11718 JURY TRIAL DEMAND nd Actor: 2 Unknown at this time-Law enforcement DEFENDANTS DEPRIVATION OF RIGHTS UNDER COLOR OF LAW 42§1983, 19851986AND 18 USC 241AND 242 CIVIL RIGHTS VIOLATION JURISDICTION AND VENUE Claimant brings this claim under 42 U.S.C. Section 1983,1985 1986 1988 and 18 USC 241 and 242. The court has jurisdiction of this action 28 U.S.C. Sec. 1391 and of the parties. Venue is proper in this judicial district as the incident complained of occurred in this district. Claimant bring this action for himself and others similarly situated. Claimant alleges his claims as followed: 1 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 2 of 12 PageID #: 2 PARTIES Claimant, Gary-Louis: Berry an inhabitant on the land in Saint Louis Missouri a homeless man. DEFENDANTS l.Defendant City Of Saint Louis, in the state of Missouri is a Municipal Corporation and are considered a person and falls under the liability of 1983. 2. Defendant Actor: 'Ilshaura Jones-Mayor is and was elected as Mayor for the City of Saint Louis and is the executive official of the government body of the Municipal Corporation of the City of Saint Louis. 3. Defendant Geoffrey Rose is a law enforcement officer for the City of Saint Louis. Defendant was a~ting under color of state law and in the course and scope of his employment as a law enforcement officer with the City of Saint Louis at all times material. 4. Defendant 1st unknown officer is a law enforcement officer for the City of Saint Louis. Defendant was acting under color of state law and in the course and scope of his employment as a law enforcement officer with the City of Saint Louis at all times material. 5. Defendant Benjamin Ellerman is a law enforcement officer for the City of Saint Louis. Defendant was acting under color of state law and in the course and scope of his employment as a law enforcement officer with the City of Saint Louis at all times material. 6. Defendant 2nd unknown officer is a law enforcement officer for the City of Saint Louis. Defendant was acting under color of state law and in the course and scope of his employment as a law enforcement officer with the City of Saint Louis at all times material. Civil Complaint On or about December 16, 2019 approximately at 6:30 pm I was traveling on 11th and Farrar street in my private automobile heading to work located in Edwardsville in Illinois, when a police cruiser flash it's lights on me, I pulled over and await for the Police Officer to come to my car. The officers came to my car, ask me for a drivers license, I told the officer that I did not have a drivers license, the officer then instructed me to get out of my automobile, which I did. When I got out the officer told me to turn around and put handcuffs on me and begin going in my pockets and took my wallet out then sat me on the curb. The officer went to his cruiser and the other officer began searching my automobile. After the 2 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 3 of 12 PageID #: 3 officer finished his search of my automobile, he came around to I was sitting and ask me was I some sort of "Sovereign citizen" I did not reply. The other officer came out of his cruiser, and informed his partner that I didn't have any warrants, the officer stood me up, and removed the handcuffs. The officer that check to see if I had any warrants, handed me back the State ID, (but not my wallet, which I didn't realize at that time because of me thinking of being late for work), the officer informed me that I would be getting citation in the mail. The other officer that was asking me was I some sort of Sovereign Gitizen went to the back of my private property and ripped off the declaration that was secure to my car by (2) two screws, took a picture of it and told me not to put it back on and handed it to me. When I got to work that is when I realize my wallet was gone, because my work ID is how I get in the building of DB Schenker, which is were I worked which made me 7 minutes late and awarded a point for being late. On or about December 21,2019 I went to the police station on Jefferson and Dr King Drive to find out about my wallet, the desk officer stated· that the officers that made the traffic stop said that he put it on top of my car and I must have lost it. I never received any tickets in the mail ... On February 7th 2021 while watching the super bowl, at half time me and a friend went to the store and I was stop by the police and he stated that the reason that he stop me was my one of my brake lights was not working, then he ask me for a driver license and I told him that I didn't have one, (I gave him an old driver license from 2014, which my wife had kept for herself after we had met, she gave it to me because she was concern about me not having any ID on me), while the office~ was checking on the ID I gave him, when the officer return he told me that he could take me to jail because I had warrants, I told him that I didn't have any warrants, he told me I did but he was going to let me go. NO citations. On March 30th 2021, I was traveling in my automobile and I was stop again on Euclid and St. Louis avenue the officer told me that the reason that he had stop me because my brake light was out, he then asked for a drivers license, I told him that I didn't have one, I gave him a temporary Illinois State ID, he instructed me to get out the car and I began tjdeo recording on my phone while standing with the other officer while his partner checked on my ID. After about 20 minutes the officer came from his cruiser and gave me 5 or 6 citation and he informed me that I had warrants. And they let me go on my way. I went on Shreve avenue and call the police station to verify that I had warrants, which the police officer on the phone confirms. On or around February 16th 2021 I went down to Traffic Court and spoke with a clerk and ask her could I get copies of the citations, which she gave to me and she offer to remove the warrants and give me a new court date, I respectfully declined. These citation was from the traffic stop of December 16th 2019, that was to be mailed to me but never was. I had no idea that these citation existed which is why I did not believe the first time when it was told to me that I had warrants. Claimant had no idea that the warrants existed, had Claimant knew he would 3 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 4 of 12 PageID #: 4 had took step to address the matter right then. Because Claimant never received those citations that was to be mail to Claimant-Claimant had no "cause of action". These citation had altered dates and the time, the time on the citation was 2231 (10:30 pm), but the actual time was 6:30 the date was December 16, 2019, but on the citation it written 2/16/2020 (February 20 th 2020). Claimant had seen two (2) citations 1) not having insurance 2) no license plates, how Claimant did not get a citation for NO DRIVER'S LICENCE. After getting these citation from the traffic court I communicate by certified mail to the Mayor Krewson in a "private administrative process" on March 24th 2021, hoping to resolve this matter. However, after 30 days plus the allotted time given to respond, I then called the Mayor's office to inquire about my communication to the mayor, I was informed that the mayor never read it but instead my communication was sent it to their legal department. Because there was an election coming up I hoped that the new mayor "Jones" would communicate with me concerning the issue. On May 6 th I was told by the reception that I should try to restart my communication with the new mayor, and was given her "ms. Jones" email. On May 6th I email the new mayor and send my number and email asking for her or SOMEONE from her office to contact claimant about the issue. On May 26th after no one reached out to me I called again, and was told by receptionist that she would look for my email, but that she would get back with me today May 26th either way. On the 26th I was contacted by someone from the Mayor's offices telling to go ahead and file my lawsuit and they will respond to it then. CAUSE OF ACTION PER EACH DEFENDANT 1. Defendant City Of Saint Louis, in the state of Missouri is a Municipal Corporation and are considered a person and falls under the liability of 1983. "Official municipal policy includes the decisions of a government's lawmakers, the acts of its policy making officials, and practices so persistent and widespread as to practically have the force of law. But it is not law, (see united states Constit. Article 6 para 2) instead it infringed my constitution rights and the policy, practice and custom is unconstitutional per the united states constitution of America and united states Supreme Court has settled the matter the right to to travel. (See, SHAPIRO vs THOMSON 394 US 618 April 21 st 1969). (b) Municipal Policy, Custom, Practices Even if there is not an explicit policy, a plaintiff may establish municipal liability upon a showing that there is a permanent and well-settled practice by the municipality which gave rise to the alleged constitutional violation. See City of St. Louis v. Praprotnik, 485 US. 112, 127 (1988). It is well established that the City of Saint Louis policy practice and custom is to issues citations for not having driver license's, no registration no insurance, and have established a traffic court to collect fines, fees and other penalties. Which the Lawmakers, officials, that would include Darlene Green, Lewis Reed, Vernon Betts, Mavis Thompson, Adam Layne Gregory F.X. Daly and all 28 aldermen all have a 4 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 5 of 12 PageID #: 5 fiduciary duty to the public to disclose information and to protected the citizens from fraud deceit and concealment the public has a right to know what their rights are. It is the same policy, practices customs and ordinances that cause me to fear for my life when in my automobile (c) Municipality's Failure to Train The plaintiff also establish municipal liability by demonstrating that the alleged constitutional violation was caused by a failure to train municipal employees adequately. When I have been stopped by law enforcement and I inform them that they are violating my Rights, and show them by law which I have Posted on my private property, the law enforcement responses are that you are required to have driver's license registration and insurance in the city of saint Louis. Which shows the inadequate training of law enforcement. The three elements to demonstrate the failure to train are: (1) the training program must be inadequate '"in relation to the tasks the particular officers must perform"'; (2) the city officials must have been deliberately indifferent "'to the rights of persons with whom the [local officials] come into contact"'; and (3) the inadequacy of the training "must be shown to have 'actually caused' the constitutional deprivation at issue." The first element is the task of the law enforcement agency that they engage with the public and that all of the men and women that the law enforcement come in contact with are not corporate citizen, i.e. 14 amendment citizens, which the supreme court speaks of_"Duality citizens which I am NOT (14 amendment citizen). Also that the Driver License is a Contract, which was not disclosed to me or the public at large and that the entering into this contract, the government is requiring me to give up my Right to Travel in exchange for The Privilege to Drive, which I did not consent and do not consent. The Right to Travel is well-settled and the Right is not one the government can give nor take away. The Right is inherent from God not from government or man. The law enforcement are not being taught that the Driver License is a Contract and that everyone is not apart of that contract, only IF they voluntary to be apart of the contract. Nor are the law enforcement trained in Uniform Commercial Code, which Missouri adopted in 1963 and are mandate to follow meaning the City of Saint Louis, which the lawmakers, and public officials does not seem to be following either. As set forth in Clearfield Trust Co. v. United States, 318 U.S. 363-371, states: "Governments descend to the level of mere private corporation, and take on the characteristics of a mere private citizen where private corporate commercial paper [i.e. Federal Reserve Notes] and securities i.e.[checks, etc] is concemed.... For purposes of suit, such corporations and individuals are regarded as entities entirely separate from government." Bank of United States v. Planter's Bank, 9 Wheaton (22 U.S.) 904, 6 L. Ed. 24; U.S. v. Burr, 309 U.S. 242; In re King - Porter Co., CA 5th, 1971, 446 And; See also 22 U.S.C.A. 286(e), the real party in interest is not the de jure "United States of America" or "State", but "The Bank" and "The Fund." (22 U.S.C.A. 286, et seq., C.R.S. 11-60-103 The second element, that the city of Saint Louis show a deliberate indifferent as to who this contract applies to and the City of Saint Louis applies is to All inhabits and fail to disclose this information to 5 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 6 of 12 PageID #: 6 the public, which is a form of deceit. It has been well established in the Courts that there is a distinct difference between the automobile and the motor vehicle. Also in U.C.C. has also define the automobile as "Consumer Goods", which All states are mandate to follow the Uniform Commercial Code. And in there statutes it talks about Commercial Driver Licenses (CDL) The third element, because of the facts and the well established LAW meaning the united states Constitution of America and endless Court cases from the u s supreme court and district courts across the country there can be no question that the actions of the law enforcement was the !2ause of the violations, which the law enforcement took an oath to support this same Constitution. As well as the officials which they have breached. Claimant alleges that the Defendant City of Saint Louis did 1. deprive Claimant of his right to travel in his private automobile 2. That the policy, practices custom, ordinances was the direct cause of Claims injury 3. Fraud by concealment 4. Breach of Contract oath of office 5. Emotional Distress and mental anguish for future encounters with law enforcement officers, whereas African American male are getting killed in traffic stop regularly across this country. Which Claimant's fear 6. Slavery (Force Compliance to contract no held) 2. Defendant Tishaura Jones-Mayor is the Executive official, she too took an oath to support the u.s Constitution. What this Claim concerning Tishaura Jones-Mayor is NOT respondent superior claim. Tishaura Jones-Mayor was given the opportunities to address these Claims in the email forward to her office and was advised by the Claimant that her non response or silence constituted her acceptance of any liability concerning my claim instead Tishaura Jones-Mayor remain Silence and accepted the liability. (See Owens v City of Independence, Missouri), Qualified immunity based on "Good Faith",Tishaura Jones-Mayor was given opportunities to resolve or at the least address the issue with Claimant, yet as the Claimant was told on May 26th to file the lawsuit from her office by Ms. Deuster, so there was no "good faith" Tishaura Jones was also the treasure for the City of Saint Louis were as Tishaura Jones collected revenue from the unconstitutional violation of parking citations and other related citation. Tishaura Jones-Mayor is an elect official and has a duty to the Public to inform the inhabits of their Rights. Which the Claimant reaching out to Tishaura Jones-Mayor failed to inform Claimant of his Rights. Tishaura Jones-Mayor fraudulent concealment withheld from the Claimant material facts that the Driver Licenses is a voluntary contract and that it is not required of me, or License Plates, which she 6 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 7 of 12 PageID #: 7 has a duty to do so. Tishaura Jones-Mayor is a policy maker and final decision maker and have chosen to conceal that the City of Saint Louis policy, practice and customs are unconstitutional and for revenue purposes only, to issues a license and demand a fee, (See Murdock v Penn. 319 US 105) "no state may convert any secured liberty into a privilege and issue a license and a fee for it". The fact that Tishaura Jones-Mayor is a Municipal official, Tishaura Jones-Mayor actions and inaction allowed for Claimant constitutional rights, which this right is well established to be violated. Claimant alleges that Tishaura Jones-Mayor caused Claimant injury: 1. Deprivation of Rights through Policy, Practices and Customs which are well established in the City of Saint Louis. 2. Breach of her Oath of Office to Support the US Constitution 3. Emotional Distress and mental anguish for future encounters with law enforcement officers, whereas African American male are getting killed in traffic stop regularly across this country. Which Claimant's fear. 4. Slavery (Force Compliance to contract not held) 3. Defendant Geoffrey Rose- Law enforcement did violated Claimant rights depriving Claimant his right to travel, did illegally seize Claimant property, handcuffing Claimant, searched Claimant person, and denying Claimant due process of law when he did not give Claimant citations right then and there. Geoffrey Rose- Law enforcement did destroy Claimant's private property by his action of tearing Claimant declaration off his automobile. Claimant alleges that Geoffrey Rose did cause Claimant's injury 1. Conspire with another to deprive Claimant his right to travel in Claimant private automobile 2. 4th amendment Seized my property 3. illegal placing Claimant in handcuffs 4. illegal searching Claimant 5. illegally searched Claimant property 6. excessive force 7. destroying Private Property 8. threatening, intimidation 9. violation of freedom to express speech l51 amendment 10. breach of oath 11. Slavery (Force Compliance to contract not held) 12. Deny Due Process To Claimant 13. Falsification of Document 4. Defendant unknown law enforcement did violated Claimant's rights by illegally searching Claimant's automobile. Both defendants also conspired to deprive Claimant's of his rights because of the declaration that was on Claimant's private property, by tearing it off and threatening Claimant not to put it back on Claimant's private property. 7 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 8 of 12 PageID #: 8 Claimant alleges that unknown law enforcement officer did cause Claimant's injury 1. Conspire with another to deprive Claim his right to travel in Claimant private automobile 2. 4th amendment Seized my property 3. illegal placing Claimant in handcuffs 4. illegal searching Claimant 5. illegally searched Claimant property 6. excessive force 7. destroying Private Property 8. threatening, intimidation 9. violation of freedom to express speech 1st amendment 10. breach of oath 11. Slavery (Force Compliance to contract not held) 5. Defendant Benjamin Ellerman Law enforcement did deprive Claimant's right to travel seize his property and issued Claimant 5 or 6 citations. Claimant alleges that Benjamin Ellerm~n did cause Claimant's injury 1. Conspire with another to deprive Claimant his right to travel in Claimant private automobile 2. 4th amendment Seized my property. 3. violation of freedom to express speech 1st amendment 4. breach of oath 5 Slavery (Force Compliance to contract not held) 6. Defendant unknown law enforcement did deprive Claimant's right to travel seize his property. Claimant alleges that unknown law enforcement officer did cause Claimant's injury 1. Conspire with another to deprive Claim his right to travel in Claimant private automobile 2. 4th aml';!ndment Seized my property. 3. violation of freedom to express speech 1st amendment 4. breach of oath 5 Slavery (Force Compliance to contract not held) 8 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 9 of 12 PageID #: 9 POLICE POWERS 10th AMENDMENT Police power. An authority conferred by the American constitutional system in the Tenth Amendment, U.S. Const., upon the individual states, and, in tum, delegated to local governments, through which they are enabled to establish a special department of police; adopt such laws and regulations as tend to prevent the commission of fraud and crime, and secure generally the comfort, safety, morals, health, and prosperity of its citizens by preserving the public order, preventing a conflict of rights in the common intercourse of the citizens, and insuring to each an uninterrupted enjoyment of all the privileges conferred upon him or her by the general laws. The power of the State to place restraints on the personal freedom and property rights of persons for the protection of the public safety, health, and morals or the promotion of the public convenience and general prosperity. The police power is subject to limitations of the federal and State constitutions, and especially to the requirement of due process. Police power is the exercise of the sovereign right of a government to promote order, safety, security, health, morals and general welfare within constitutional limits and is an essential attribute of government. Marshall v. Kansas City, Mo., 355 S.W.2d 877, 883. Policy. The general principles by which a government is BLACK'S LAW DICTIONARY® SIXTII EDITION MEMORANDUM OF CONSTITUTION LAW, U.S. CONSTITUTION US SUPREME COURT, U.C.C Am Jur 2d 16 sec. 97" Then a constitution should receive a liberal interpretation in favor of the citizen is especially true with respect to those provisions which were designed to safeguard the liberty and security of the citizen in regard to both person and property. (see note 31, Bryer's v United States 273 U.S.28. Am Jure 16, sec 155: Since the constitution is intended for the obseivance of the judiciary as well as other p~ of government, and the judges are sworn to support its provisions the courts are not at liberty to overlook or disregard its commands or countenance evasions thereof. It is their duty in authorized proceedings to give full effect to the existing constitution, and to obey all constitutional provisions irrespective to their opinion of the wisdom or the desirably of such provisions, and irrespective of the consequences. Thus is said that the courts should be in our alert to enforce the provisions of the United States Constitution, and guard against their infringement by legislative fiat or otherwise. In accordance with these basic principles the rule is fixed that the duty in the proper case to declare a law unconstitutional cannot be declined, and must be performed in accordance with the delivery of judgment of the tribunal before which the validity of the enactment is directly drawn into 9 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 10 of 12 PageID #: 10 question. If the constitution prescribes one rule, and the statute another, in a different rule, it is the duty of the court to declare that the constitution and not the statute governs in cases before them for judgment. Am Jur 2d sec 256: The general rule is that an unconstitutional statute, whether federal or state, though having the form and name of law is reality no law; but is wholly void and ineffective for any purpose. Since unconstitutionality dates from the time of the enactment, not merely from the date of the decision so branding it. An unconstitutional law in legal contemplation is as inoperative as if it had never been passed. Such a statute leaves a question that it purports to settle just as it would be had the statute not ever been enacted US Constitution Article 1 section 9 No Bill of Attainder or ex post facto Law shall be passed. Which are traffic tickets are unconstitutional, also see Am jur16 2d 114 "summary proceeding" which are traffic tickets Marbury v. Madison, 5 U.S. 137 (1803). This is one of the leading cases in the history of the U.S. The opinion of the court was "Anything that is in conflict is null and void of law; Clearly for a secondary law to come in conflict with the supreme was illogical; for certainly the supreme law would prevail over any other law, and certainly our forefathers had intended that the supreme law would be the basis for all laws, and for any law to come in conflict would be null and void of law. It would bear no power to enforce, it would bear no obligation to obey, it would purport to settle as though it had never existed, for unconstitutionality would date from the enactment of such a law, not from the date so branded by a court of law. No courts are bound to uphold it, and no citizens are bound to obey it. It operates as a mere nullity or a fiction of law, which means it doesn••t exist in law. Marbury v. Madison, 5 U.S. 137 (1803). *163 * The very essence of civil liberty certainly consists in the right of every individual to claim protection of the laws, whenever he receives and injury. One of the first duties of government is to afford that protection, In Great Britain the king himself is sued in the respectful form of a petition and he never fails to comply with the judgment of his court Murdock v Penn. 319 US 105) "no state may convert any secured liberty into a privilege and issue a license and a fee for it". 10 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 11 of 12 PageID #: 11 Shuttlesworth v Birmingham Al 373 US 262 Said that if the state does convert your right into a privilege and charge a license and a fee for it you can ignore the license and fee, and engage in the right with impunity. Owen v City of Independence, Mo. 445 US 622 (1980) and Maine v Thiboutot, 448 U.S.l (1980) "Whenever they violate your constitutional rights they do so at their own peril" Boyd v United States,116 US 616: The court is to protect against encroachment of constitutionality or security liberty Simmons v United States, 390 U.S 377 (1968) "There can be no sanction or penalty imposed upon one because of his exercise of constitutional rights" Bennett v Boggs 1 baldw 60 "Statutes that violate the plain and obvious principles of common right and common reason are null and void" Would we not say that these judicial decisions are straight to the point=that there is is no lawful method for government to put restrictions or limitations on rights belonging to the people? Other cases are even more straight forward "The assertion of federal rights when plainly and reasonably made, is not to be defeated under the name of practice" SHAPIRO vs. THOMSON, 394 U. S. 618 Further, the Right to 1RAVEL by private conveyance for private purposes upon the Common way can NOT BE INFRINGED. No license or permission is required for 1RAVEL when such 1RAVEL IS NOT for the purpose of [COMMERCIAL] PROFIT OR GAIN on the open highways operating under license IN COMMERCE. "The rights of the individuals are restricted only to the extent that they have been voluntarily surrendered by the citizenship to the agencies of government. Maine v Thiboutot, 448 U.S.l (1980) Civil Rights Attorney's Awards Act of 1976, 42§ 1988 which provides that attorney's fee my be awarded to the prevailing party in any action to enforce a provision of 1983 and which makes no exception for statutory 1983 action-Moreover it follows from the legislative history and from the Supremacy Clause the fee provision is part of the 1983 remedy whether the action is brought in a federal court or as was the instant action, in a state court Pp. 8-11 U.C.C. has also define the automobile as "Con.sumer Goods" 11 Case: 4:21-cv-00685-RLW Doc. #: 1 Filed: 06/14/21 Page: 12 of 12 PageID #: 12 REQUEST FOR RELIEF Plaintiff incorporates the preceding paragraphs by reference herein. WHEREFORE, Claimant seeks the following relief I. Declaratory Judgment II. Injunction relief sufficient to protect Claimant from ongoing harassment and intimidation of Defendants and future emotional distress and Mental anguish Emotional Distress and mental anguish for future encounters with law enforcement officers, warrants whereas African American males are getting killed in traffic stop regularly across this country. Which Claimant's fear. III. Punitive Damages sufficient to punish them and deter further wrongdoing IV. Actual and compensatory damages sufficient to make him whole. V. Treble Damages VI. Such other and further relief as the Court deem just and proper VII. Jury Trial Demanded. Respectfully submitted, \---_ ~ k \:¼,,? ~ Gary-Louis: Berry 0 ")tJ Dated &,-;-- /4 - 2, o a l 12