`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 1 of 15 PagelD: 14
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`EXHIBIT “A”
`EXHIBIT “A”
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`
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`
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`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 2 of 15 PagelD: 15
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 2 of 15 PageID: 15
`
`a
`
`Michael Heinemann, Esq.
`Attorney Id. No. 035252012
`LAW OFFICE OF MICHAEL HEINEMANN, PC
`15 America Avenue, Suite 404
`Lakewood, New Jersey 08701
`(732) 905-0282
`Attorneyfor Plaintiff
`--+-----------~------------------------------2---x
`
`C G HEALTHCARE LLC, d/b/a CEDAR
`HILL HEALTHCARE,
`
`SUPERIOR COURT OF NEW JERSEY
`LAW DIVISION: MORRIS COUNTY
`
`Plaintiff,
`
`DOCKET NO. MRS-L-001664-21
`
`- against-
`
`CIVIL ACTION
`
`AETNA HEALTH,INC.
`
`SUMMONS
`
`Defendant.
`eeeeeeneneen eens cence weenneerseeeeeneseceeneeeex
`
`From The State of New Jersey To The Defendant Named Above:
`
`The plaintiff, named above, has filed a lawsuit against you in the Superior Court
`ofNew Jersey. The complaint attached to this summonsstates the basis for this lawsuit
`
`If you dispute this third-party complaint, you or your attorney mustfile a written answer
`
`or motion and proof of service with the deputy clerk of the Superior Court in the county
`
`listed above within 35 days from the date you received this summons, not counting the
`
`date you received it. (A directory of the addresses of each deputy clerk of the Superior
`
`Court is available in the Civil Division ManagementOffice in the county listed above and
`
`online at http:/Awww.njcourts.gov/forms/10153_ deptyclerklawref.pdf.). If the complaint is
`
`one in foreclosure, then you must file your written answer or motion and proof of service
`
`with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton,
`
`NJ 08625-0971. A filing fee payable to the Treasurer, State of New Jersey and a
`
`completed Case Information Statement (available from the deputy clerk of the Superior
`
`Court) must accompany your answer or motion whenit is filed. You must also send a
`
`1 O
`
`8O521 0807
`
`(if
`‘hs
`“
`
`
`
`
`
`
`GON: 210805120979 seq: 0805210007 EF ACCOUNTABLE ]
`
`
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 3 of 15 PageID: 16
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 3 of 15 PagelD: 16
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`\#
`|
`
`copy of your answer or motion to plaintiff's attorney whose name and address appear
`above, or to plaintiff, if no attorney is named above. A telephone call will not protect
`
`your rights; you mustfile and serve a written answer or motion (with fee of $175.00 and
`
`completed Case Information Statement) if you want the court to hear your defense.
`
`If you do not file and serve a written answer or motion within 35 days, the court
`
`may enter a judgment against you for the relief plaintiff demands, plus interest and costs
`of suit. Ifjudgment is entered against you, the Sheriff may seize your money, wages or
`
`property to pay all or part of the judgment.
`
`If you cannot afford an attorney, you may call the Legal Services office in the
`
`county where youlive or the Legal Services of New JerseyStatewide Hotline at 1-888-
`
`LSNJ-LAW (1-888-576-5529). If you do not have an attorney and are not eligible for
`
`free legal assistance, you may obtain a referral to an attorney by calling one of the
`
`Lawyer Referral Services. A directory with contact information for local Legal Services
`
`Offices and Lawyer Referral Services is available in the Civil Division Management
`
`Office in the county listed above and online at
`
`http://www.njcourts.gov/forms/10153_deptyclerklawref.pdf.
`
`/S/ Michelle M. Smith, Esq.
`Clerk of the Superior Court
`
`Dated: August 2, 2021
`
`To: Aetna Health, Inc.
`9 Entin Road, Suite 203
`Parsippany, New Jersey 07054
`
`2 G
`
`8052, 0087
`
`
`
`Don: 210805120979 seq: 0805210007 EF ACCOUNTABLE ]
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 4 of 15 PageID: 17
`Case 4iRsav-dhr664-3 VariSii2d29Goer Pre PolledrG2rpane 1p: Rawedagh taugegelD: 17
`1
`
`Michael Heinemann, Esq.
`Attorney Id. No. 035252012
`Law OFFICE OF MICHAEL HEINEMANN, PC
`15 America Avenue, Suite 404
`Lakewood; New Jersey 08701
`(732) 905-0282
`Attorneyfor Plaintiff
`necesene cence seeeeesweenenee eeese eeeee sees an==x
`C G HEALTHCARE LLC, d/b/a CEDAR
`HILL HEALTHCARE,
`
`SUPERIOR COURT OF NEW JERSEY
`LAW DIVISION: MORRIS COUNTY
`
`DOCKET NO. MRS-L-
`
`Plaintiff,
`
`- against-
`
`AETNA HEALTH,INC.
`
`CIVIL ACTION
`
`COMPLAINT
`
`Defendant.
`‘
`eex
`Plaintiff, C G Healthcare LLC, d/b/a Cedar Hill Healthcare by its attorneys, Law
`
`Office of Michael Heinemann, PC, hereby complains of Defendant, Aetna Health, Inc.
`
`upon information and belief, alleges as follows:
`
`|
`1. PARTIES
`Plaintiff, C G Healthcare LLC, d/b/a Cedar Hill Healthcare(“Cedar Hill”)
`
`|
`
`1.
`
`at all relevant times, was andis a limited liability company licensed to do business in the
`
`State of New Jersey with its principal place of business located at 110 Grove Avenue,
`
`Cedar Grove, New Jersey 07009.
`
`2.
`
`Atall times material hereto, Cedar Hill was and is engagedin the business
`
`of providing skilled nursing homecare services.
`
`3.
`
`Defendant, Aetna Health, Inc. (“Aetna”), is a corporation organized under
`
`the laws of the State of New Jersey with a principal address of 9 Entin Road, Parsippany,
`
`New Jersey 07054.
`
`4,
`
`At all times material hereto, Aetna was and is engaged in the business of
`
`
`
`
`
`Gon: 210805120979 seq: 0805210007 EP ACCOUNTABLE
`]
`
`85218007 |
`
`
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 5 of 15 PageID: 18
`Case 4R8qv.chi664-2 ORSi2020GDI ANB Phileer Gore1D: Reved2ot Zéulrege!D: 18
`
`providing health insuranceto its insureds.
`
`I]. FACTUAL BACKGROUND
`Plaintiff brings this action as a result of Aetna’s refusal to pay for the
`
`5.
`
`treatment that the Plaintiff provided to Aetna’s insureds.
`
`6.
`
`The following is a list, respectively identifying Aetna’s insureds who
`
`received care at Plaintiff's facility, the period of time such care was received and amount
`
`Aetna owesthe Plaintiff.
`
`aaa[RTE [ESO
`
`LB. 06/01/20-06/19/20|$6,093.18|
`
`
`
`
`08/01/20-08/17/20
`
`
`
`
`
`01/01/20-01/07/20
`
`ps[eet[soc
`
`02/07/20-03/01/20|$3,910.59
`
`
`
`
`
`
`
`
`
`aaa
`
`
`
`
`
`03/05/20-04/01/20|$5,541.23
`
`01/08/20-01/31/20|$3,592.16
`
`02/1 1/20-03/01/20|$2,528.40
`
`07/06/19-07/23/19|$2,708.76
`
`7.
`
`At all
`
`times hereinafter mentioned, for the period during which the
`
`Plaintiff provided care to Aetna’s insureds, the insureds were covered pursuant an Aetna
`
`insurance policy.
`
`
`
`Gon: 210805120979 seq: 0805210007 EF ACCOUNTABLE ]
`
`805210007
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 6 of 15 PageID: 19
`Case RSWV00665-9 \OFSH20RPBHDa7 ANE PGiPar eSrRaHs ID: Resedzol Agubege!lD: 19
`
`8.
`
`At all
`
`times hereinafter mentioned,
`
`for the period during which the
`
`Plaintiff provided care to Aetna’s insureds, the insureds assigned their Aetna benefits to
`
`the Plaintiff.
`
`9.
`During the above noted respective treatment periods, Aetna’s insureds
`were patients at the Plaintiff's facility where theyreceived necessary treatment and care.
`
`10.
`
`Aetna issued pre-authorizations for the care the Plaintiff provided to
`
`Aetna’s insureds, confirming that Aetna would pay the Plaintiff for the care it provided to
`
`Aetna’s insureds.
`
`11.
`
`The Plaintiff promptly notified Aetna and provided all necessary
`
`documentation to ‘obtain coverage and payment which was owed for the above noted
`
`treatment.
`
`12.
`
`Aetna refused to pay the Plaintiff claiming that Plaintiff is not entitled to
`
`payment due to Aetna’s audits allegedly demonstrating that Aetna had previously
`
`overpaid the Plaintiff for unrelated claims.
`
`13.
`
`The Plaintiff attempted to contact Aetna to contest the alleged audits and |
`
`their refusal to pay the subject claims.
`
`14.
`
`However, Aetna has been unwilling to discuss or explain their refusal to
`
`pay the subject claims.
`
`15.
`Despite numerous requests for payment from the Plaintiff, Aetna has
`failed to pay for its insured’s treatment at the Plaintiff's facility.
`
`
`
`
`
`COUNTI
`Breach of Contract
`‘Plaintiff repeats each and every allegation contained in those paragraphs
`
`16.
`
`of the Complaint marked and numbered “1”through “15”, inclusive, with the same force
`
`
`GON: 210805120979 seq: 0805210007 EP ACCOUNTABLE
`]
`
`G885210007
`
`:
`
`
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 7 of 15 PageID: 20
`Case 4RBAVebh664-2M ORStoRPevant Ans PhUper Sor? ID: Reyeo204 AsyrewelD: 20
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`and effect as thoughfully and at length set forth herein.
`
`17.
`
`Aetna breached the pre-authorization agreement when it
`
`inexplicably
`
`failed to remit paymentfor the skilled nursing services providedto its insureds during the
`
`above notedrespective treatment periods.
`
`18.
`
`As a result of this breach, the Plaintiff has suffered damages in the amount
`
`of at least $48,913.71.
`
`WHEREFORE,Plaintiff respectfully requests judgmentas follows:
`(a)
`Awarding Plaintiffcompensatory damages in an amount of$48,913.71,
`
`_ plus lawful interest;
`
`(b)
`
`Awarding Plaintiff its costs and expenses, including reasonable attorneys’
`
`fees and the costs and disbursementsofthis action, in such sum to be
`
`determined by the Court.
`
`(c)
`
`Granting Plaintiff such other and further relief as this Court may deem just
`
`and proper.
`
`COUNT II
`Unjust Enrichment
`19._‘Plaintiff repeats each and every allegation contained in those paragraphs
`
`|
`
`of the Complaint marked and numbered “1” through “18”, inclusive, with the same force
`
`and effect as though fully and at length set forth herein.
`20,
`Upon information and belief, Aetna has collected monies for providing
`health insuranceto its insureds andits insureds received care from the Plaintiff.
`
`21. Asa result of Aetna’s unwillingness to pay for its insured’s treatment,
`
`Aetna has been unjustly enriched.
`
`
`
`GON: 210805120979 seq: 0805210007 EF ACCOUNTABLE ]
`
`Q8O521000!
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 8 of 15 PageID: 21
`Case MRSLORGEE-2MOSdi20PPSWESTANP PgWG BTRadsIp: Pevedert AeukepelD: 21
`
`4
`
`*
`
`WHEREFORE,Plaintiff respectfully requests judgment as follows:
`
`(a)
`
`Awarding Plaintiff compensatory damages in an amountof $48,913.71,
`plus lawfulinterest;
`|
`
`(b)
`
`Awarding Plaintiff its costs and expenses, including reasonable attorneys’
`
`fees and the costs and disbursements ofthis action, in such sum to be
`
`determined by the Court.
`
`(c)
`
`Granting Plaintiff such other and further relief as this Court may deem just
`
`and proper.
`
`COUNTI
`Promissory Estoppel
`Plaintiff repeats each and every allegation contained in those paragraphs
`
`22,
`
`of the Complaint marked and numbered “1”through “21”, inclusive, with the same force
`
`and effect as though fully and atlength set forth herein.
`
`Aetna made representations and engaged in conduct which reasonably led
`23.
`the Plaintiffto believe that it would pay for Aetna’s insureds treatment.
`
`24.
`
`Despite these promises and representations, Aetna has not paid the
`
`Plaintiff for its insured’s treatment.
`
`25.
`As a result, of Defendant’s promises and conduct and Plaintiffs
`reasonable reliance thereof, plaintiff has suffered damages in the amount of| at least
`
`$48,913.71.
`
`WHEREFORE,Plaintiff respectfully requests judgmentas follows:
`
`(a)
`
`Awarding Plaintiff compensatory damages in an amount of $48,913.71,
`
`plus lawful interest;
`
`
`
`
`
`GON: 210805120979 seq: 0805210007 EF ACCOUNTABLE ]
`
`O8O5210007
`
`
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 9 of 15 PageID: 22
`Case 4sQVickh664-24oRSHi202PSpoat Ane PheerapesIp: Pewedogh teazggelD: 22
`
`(b)
`
`Awarding Plaintiff its costs and expenses, including reasonable attorneys’
`
`fees and the costs and disbursements ofthis action, in such sum to be
`determined by the Court.
`|
`
`(c)
`
`Granting Plaintiff such other and further relief as this Court may deem just
`
`and proper.
`
`COUNT IV
`Breach of Covenant of Good Faith and Fair Dealing
`Plaintiff repeats each and every allegation contained in those paragraphs
`
`26.
`
`of the Complaint marked and numbered “1” through “25”, inclusive, with the same force
`
`and effect as though fully and at length set forth herein.
`
`27.
`Aetna acted with an improper motive and injured Plaintiff's nghts and
`benefits under the pre-authorization agreement which denied Plaintiffs the benefits ofthe
`pre-authonzation agreement.
`|
`
`28.
`
` Asaresult of this breach, the Plaintiff has suffered damages in the amount
`
`of at least $48,913.71.
`
`WHEREFORE,Plaintiff respectfully requests judgment as follows:
`
`(a)
`
`Awarding Plaintiff compensatory damages in an amount of $48,913.71,
`
`plus lawful interest;
`
`(b)
`
`Awarding Plaintiff its costs and expenses, including reasonable attorneys’
`
`fees and the costs and disbursements ofthis action, in such sum to be
`
`determined by the Court.
`
`
`
`
`
`
`
`GON: 210805120979 seq: 0805210007 EP ACCOUNTABLE ]
`
`G85 210007
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 10 of 15 PageID: 23
`Case 2ifasty-664eGr-WVcrab2d2acenerny br PyleGOearslpHaugh? alrba4gagelD: 23
`
`(c)
`
`Granting Plaintiff such other and further relief as this Court may deem just
`
`and proper.
`
`Dated: July 30, 2021
`
`LAW OFFICE OF MICHAEL HEINEMANN,PC
`Attorneyfor Plaintiff, C G Healthcare LLC, d/b/a
`Cedar Hill Healthcare
`
`ay: Nur Nee
`
`Michael Heinemann,Esq.
`
`CERTIFICATION OF NO OTHER ACTIONS
`Pursuant to Rule 4:5-1, it is hereby stated that the matter in controversy is not the
`
`subject of any other action pending in any other court or of a pending arbitration
`
`proceeding to the best of my knowledge and belief. Also, to the best of my knowledge
`and belief, ne other action or arbitration proceeding is contemplated. Other than the
`
`parties set forth in this pleading, I know of no other parties that should be joined in the
`
`above action. In addition, I recognize the continuing obligation during the course of the
`litigation tofile and serve on all other parties and with the Court an amendedcertification
`
`if there-is a change in the facts stated in the original certification.
`
`Dated: July 30, 2021
`
`
`
`LAW OFFICE OF MICHAEL HEINEMANN,PC
`
`AttorneyforPlaintiff
`
`By:
`
`/
`
`Michael Heinemann, Esq.
`
`
`GON: 210805120979 seq: 0805210007 EF ACCOUNTABLE
`]
`
`O895 218007
`
`
`
`Case 29RSCV-OHGEIMVERRE2ONCINENT PA RyledNOMBRUDRayed?virBdegelD: 24
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 11 of 15 PageID: 24
`(
`
`4
`
`CERTIFICATION OF COMPLIANCE WITH RULE 1:38-7(c)
`
`I certify that confidential personal identifiers have been redacted from documents
`
`now submitted to the Court and will be redacted from all documents submitted in the
`
`future in accordance with Rule 1:38-7(b).
`
`Dated: July 30, 2021
`
`LAW OFFICE OF MICHAEL HEINEMANN,PC
`Attorney for Plaintiff
`\
`By: pr \\eH
`Michael Heinemann, Esq.
`
`DESIGNATION OF TRIAL COUNSEL
`
`Pursuant to Rule 4:25-4, Michael Heinemann, Esq. is hereby designated as trial
`
`‘counsel for Plaintiff. in the above captioned matter.
`
`Dated: July 30, 2021
`
`LAW OFFICE OF MICHAEL HEINEMANN,PC
`Attorney for Plaintiff
`
`By:
`
`tenn
`Michael Heinemann, Esq.
`
`
`
`
`
`GON: 210805120979 seq: 0805210007 EF ACCOUNTABLE ]
`
`8805210007
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 12 of 15 PageID: 25
`Case 27S:ithGeelyGrabPFUTERE AM BPOMPaNstp: LeVadH PragrgegelD: 25
`
`MORRIS »sCOUNTY
`SUPERIOR COURT
`COURT STREET
`MORRISTOWN
`
`NJ 07960
`
`(862} 397-5700
`COURT TELEPHONE NO.
`COURT HOURS
`68:30 AM - 4:30 PM
`
`TRACK ASSIGNMENT NOTICE
`
`JULY 30, 2021
`DATE:
`C G HEALTHCARE LLC, D/B/A VS AETNA HEALTH,
`RE:
`DOCKET: MRS L -001664 21
`
`INC
`
`THE ABOVE CASE HAS BEEN ASSIGNED TO:
`
`TRACK 2.
`
`300 DAYS AND RUNS FROM THE FIRST ANSWER OR 90 DAYS
`DISCOVERY IS
`FROM SERVICE ON THE FIRST DEFENDANT, WHICHEVER COMES FIRST.
`
`THE PRETRIAL JUDGE ASSIGNED IS:
`
`HON WILLIAM J. MCGOVERN
`
`IF YOU HAVE ANY QUESTIONS, CONTACT TEAM
`(862) 397-5700.
`
`AT:
`
`Gol
`
`IF YOU BELIEVE THAT THE TRACK IS INAPPROPRIATE YOU MUST FILE A
`CERTIFICATION OF GOOD CAUSE WITHIN 30 DAYS OF THE FILING OF YOUR PLEADING.
`PLAINTIFF MUST SERVE COPIES OF THIS FORM ON ALL OTHER PARTIES IN ACCORDANCE
`WITH R.4:5A-2.
`.
`ATTENTION:
`
`ATT: MICHAEL HEINEMANN
`
`MICHAEL HEINEMANN, PC
`15 AMERICA AVE
`STE 404
`LAKEWOOD
`
`NJ 08701
`
`ECOURTS
`
`
`
`
`
`GON: 210805120979 seq: 0805210007 EP ACCOUNTABLE ]
`
`85210087
`
`
`
`
`
`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 13 of 15 PageID: 26
`Case 2:21-cv-16476-JMV-ESK Document 1-3 “Filed,o9/02/21 Page 13 of 15 Pagef
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`Case 2:21-cv-16476-JMV-ESK Document 1-3 Filed 09/02/21 Page 14 of 15 PageID: 27
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`a. Case 2:21-cv-16476-JMV-ESK
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`MAILROOM
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`157 FARMINGTON AV
`HARTFORD CT 06756
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`7777 MARKET CENTER AVE
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`EL PASO TX 79912
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`TRACKING #: 12 273 O3W 24 5685 4494
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` GON: 210805120979 seq: 0805210007 EP ACCOUNTABLE ]
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