Florida Option Contract

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					         IN THE SUPREME COURT OF FLORIDA

                CASE NO. ___________



           HENRY I. PASS and EILEEN PASS,

                     Petitioners,

                         vs.

                ADRIAAN ANGELUS,

                     Respondent




ON APPEAL FROM THE THIRD DISTRICT COURT OF APPEAL
                CASE NO. 3D02-3343




        PETITIONERS’ BRIEF ON JURISDICTION




                   HENRY I. PASS, ESQ., PRO SE
                   EILEEN PASS, PRO SE
                   401 East City Avenue, Suite 200
                   Bala Cynwyd, PA 19004-1117
                   (610) 660-8001
                                             (610) 660-8004 Fax.




                                       TABLE OF CONTENTS


TABLE OF AUTHORITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

..                                                                                                              ii

STATEMENT OF THE CASE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

..                                                                                                              1

STATEMENT OF THE FACTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

..                                                                                                              2

SUMMARY OF THE ARGUMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

.                                                                                                               4

ARGUMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

..                                                                                                              5

        I.       The Third District Court of Appeal Opinion expressly and
                 directly conflicts with longstanding Florida law which
                 recognizes the validity of option contracts supported by
                 adequate consideration for exercise of the option and the
                 conveyance of the property after the optionor’s death . . . . . . . . . . . 5

        II.      The Third District Court of Appeal misapplied the law by
                 erroneously relying on Williams v. Williams, 6 So. 2d 275 (Fla.
                 1942), a case materially at variance with the instant case . . . . . . . . . . 8
CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

CERTIFICATE OF SERVICE

CERTIFICATE OF COMPLIANCE




                                                    ii
                                   TABLE OF AUTHORITIES

                                                  Cases

Acheson v. Smith, Inc.
     148 So. 576 (Fla. 1933) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Angelus v. Pass
      2003 Fla. App. LEXIS 7021 (Fla. 3d DCA 2003) . . . . . . . . . . . . . . . . . . .                    2

Arlt v. Buchanan
       190 So. 2d 575 (Fla. 1966) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Brown v. Brown
     156 So. 2d 683 (Fla. 2nd DCA 1963) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Chase Federal Savings and Loan Association v. Schreiber
      479 So. 2d 90 (Fla. 1985) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Colwin v. Salmon, et al.
      13 So. 2d 190 (Ala. 1943) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
      8

Crowley v. Bass
     445 So. 2d 902 (Ala. 1989) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Fleming v. Fleming
      352 So. 2d 895 (Fla. 1st DCA 1977) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Galatis v. Plasman
      80 So. 2d 918 (Fla. 1954) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4, 7

Gibson v. Avis Rent-A-Car System, Inc.
     386 So. 2d 520 (Fla. 1980) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5, 9

In re Estate of Jorstad
       447 N.W. 2d 283 (N.D. 1989) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.      8


                                                     iii
In re Estate of Weinsaft
       647 S.W. 2d 179 (Mo. App. 1983) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
       8

Kelley v. Burnsed
      805 So. 2d 1101 (Fla. 1st DCA 2002) . . . . . . . . . . . . . . . . . . . . . . . . . .4, 7, 8

Lesro v. Kello, et al.
      42 N.E. 2d 836 (Mass. 1942) . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . 8

O’Berry v. Gray
     510 So. 2d 1135 (Fla. 5th DCA 1987) . . . . . . . . . . . . . . . . . . . . . . . . . 4, 7, 8

Palm Beach Estates v. Croker
     143 So. 792 (Fla. 1932) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .   7

Parramore v. Parramore
     371 So. 2d 123 (Fla. 1st DCA 1978) . . . . . . . . . . . . . . . . . . . . . . . . . . . .7, 12

Powell v. King
     338 So. 2d 56 (Fla. 3d DCA 1976) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Ricks v. Loyola
      822 So. 2d 502 (Fla. 2002) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5, 9

Rosen v. Florida Ins. Guar. Ass’n,
      80 So. 2d 502 (Fla. 2002) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5, 9

Steinberg v. Sachs
      837 So. 2d 291 (Fla. 2001) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .     5

Wale v. Barnes
      278 So. 2d 601 (Fla. 1972) . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . 5, 9

Williams v. Williams
                                                                                           .
      6 So. 2d 275 (Fla. 1942) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2, 4, 5, 9, 10


                                    Constitutional Provisions

                                                     iv
                                                                                                      .
Art. V, §3(b)(3), Fla. Const. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5, 8, 10

Art. X, §4, Fla. Const. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
      1

                                           Statutory Provisions

§ 732.502, Fla. Stat. (2001). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1, 4


                                              Other Authority

Raymond T. Elligett, Jr. and John M. Scheb, Florida Appellate
  Practice and Advocacy (Second Edition) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.       5

Florida Appellate Practice, Fifth Edition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.     5

44 Fla. Jur. 2d, Real Property Sales and Exchanges § 24. . . . . . . . . . . . . . . . . . . . 6

77 Am. Jur. 2d, Vendor and Purchase § 38. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6




                                                         v
                             STATEMENT OF THE CASE

      This appeal arises from the trial court’s decision which held that a letter dated

March 8, 2000 (“Letter”) to Petitioner Henry Pass (“Henry”) from his Aunt Ruth

(“Ruth”) was a valid and binding option contract (“Option Contract”) supported by

adequate consideration for the sale of Ruth’s condominium (“Condominium”) to

Petitioners. The trial court also held that the Option Contract was supported by adequate

consideration under Florida law: love and affection and a commitment by Henry to

distribute Ruth’s jewelry after her death in accordance with the Letter.

      Respondent, Ruth’s estranged daughter, appealed to the Third District Court of

Appeal (“3rd DCA”), disputing the trial court’s holding that the Letter constituted an

option contract supported by adequate consideration.1 The 3rd DCA, in a per curiam

decision rendered by Judges Schwartz, Fletcher and Nesbitt, reversed the trial court’s

order. The 3rd DCA, in diverting from the issue of whether the Letter constituted a valid




1
       Of particular significance, the Record before the 3rd DCA never addressed the
issue of whether the Letter constituted a testamentary disposition under § 732.502, Fla.
Stat. (2001). The issue before the trial court was solely whether the Letter constituted a
valid and binding option contract supported by adequate consideration. Moreover, the
issue of consideration was exhaustively briefed before the trial and district courts, yet
was never addressed in the 3rd DCA’s opinion. Notwithstanding the foregoing, since
the Condominium was Ruth’s homestead property, consideration was not required for
the enforceability of the Option Contract under Article X, Section 4 of the Florida
Constitution. See, e.g., Chase Federal Savings and Loan Association v. Schreiber, 479
So. 2d 90 (Fla. 1985).

                                             1
option contract supported by adequate consideration, held that the Letter constituted a

testamentary transfer of property which did not comply with the statutory requirements

of a will. In support of its decision, the 3rd DCA erroneously relied on the Supreme

Court’s holding in Williams v. Williams, 6 So. 2d 275 (Fla. 1942), a case involving

factual and legal issues which are entirely at variance with the case under review.2

                             STATEMENT OF THE FACTS

      In the Letter, Ruth granted Petitioners an option (“Option”) to purchase her

Condominium for $100. The Option, by its express terms, was exercisable after Ruth’s

death. The Letter read in part as follows:

      Dear Henry –
             I completed my will with Morris Engelberg and you will get copies
      soon.
             I could not include my Condo because he said that if I was ever sued
      I could lose my home.
             If I am still here when I die, I would like to sell it to you and Eileen for
      $100 – [sic]
             I also did not put in my jewelry because there would be a tax on
      them.
             My intentions are to leave Eileen the engagement diamond that is on
      a chain, my diamond wedding band and the string of pearls that was
      George’s first gift to me.
             Everything else should go to Nancy Weinberg if she wants it.

2
       Angelus v. Pass, Appendix Slip Opinion. On June 18, 2003, the 3rd DCA denied
Petitioner’s Motion for Certification which asked the 3rd DCA to certify as a question
of great importance: “May an option to purchase property be created under Florida
contract law so as to be enforceable and exercisable after the death of the optionor?”
Appendix: 3

                                              2
      ...
            I know you will take care of everything as I desire. Thank you for
      being my nephew.
            Love Aunt Ruth (over)

      [On reverse of page]
      None of my Jewelry [sic] to Deborah.

      The “Deborah” referred to in the last line of the Letter is Respondent, Ruth’s long

estranged daughter, who resided in New Zealand and had changed her name to Adriaan.

Ruth died on December 25, 2001. Thereafter, Henry, along with Ruth’s Florida estate

planning attorney, Morris Engelberg (“Engelberg”), were appointed as the Co-Personal

Representatives of Ruth’s estate.

      By letter to Engelberg dated March 29, 2002, Petitioners exercised their Option to

purchase the Condominium and remitted the sum of $100.00 to Engelberg in accordance

with the Letter. On April 5, 2002, Petitioners filed a Statement of Claim in the Circuit

Court for Miami-Dade County, Probate Division, for specific performance of the Option

Contract. On April 24, 2002, Respondent filed an objection to the Claim. On June 11,

2002, Petitioner filed a Petition for Declaratory Judgment and Specific Performance with

the trial court. On May 6, 2002, Respondent moved for, and Petitioners consented to,

the appointment of an Administrator Ad Litem to assess and evaluate the Statement of

Claim. By Order dated June 12, 2002, the trial court appointed Richard E. Brodsky, Esq.

as the Administrator Ad Litem (“Administrator”).


                                           3
      The parties then briefed the issues at length for the Administrator and, on July 30,

2002, the Administrator filed his report (“Report”) with the trial court. In his Report, the

Administrator concluded that the Letter constituted a valid and binding option agreement

supported by adequate consideration which granted Petitioners the legally enforceable

right to exercise the Option and purchase the Condominium after Ruth’s death for

$100.00. On November 20, 2002, the trial court entered an Order Adopting and Entering

the Report of the Administrator Ad Litem for Specific Performance (“Order”). On

December 2, 2002, Respondent filed a Motion for Reconsideration of the Order. This

Motion was denied by order of the trial court dated December 10, 2002.

      Respondent then appealed the Order to the 3rd DCA. The 3rd DCA, erroneously

relying on Williams v. Williams, 6 So. 2d 275 (Fla. 1942), reversed the holding of the

trial court on June 18, 2003 (“3rd DCA Opinion”) by opining that the Letter was a

testamentary transfer of property which did not comport with the statutory requirements

of a will under § 732.502, Fla. Stat. (2001) (“Statute of Wills).

                          SUMMARY OF THE ARGUMENT

      This Court should grant discretionary review because the 3rd DCA Opinion, in

declaring the Option Contract to be invalid, is in express and direct conflict with

longstanding Florida precedent recognizing the validity and enforceability of option

contracts supported by consideration involving the exercise of the option and the

                                             4
conveyance of property after the property owner’s death. See Galatis v. Plasman, 80

So. 2d 918 (Fla. 1954); O’Berry v. Gray, 510 So. 2d 1135 (Fla. 5th DCA 1987); Kelley

v. Burnsed, 805 So. 2d 1101 (Fla. 1st DCA 2002).

      Consistent with the foregoing, this Court’s jurisdiction is further established as a

result of the 3rd DCA’s misapplication of the law in the instant case by relying on

Williams v. Williams, supra, involving factual and legal issues materially at variance with

those under review.3

      In the instant case, the 3rd DCA based its opinion on Williams v. Williams, supra,

a case involving the validity of a deed which did not take effect until the grantor’s death.

In direct contrast, both factually and legally, the present case involves the validity of the

Option Contract for the purchase of property which was an executed contract4

supported by adequate consideration under well established Florida law. Unlike the deed

in the Williams case, the Option Contract in the instant case took effect and was

operative during the optionor’s lifetime and was not a testamentary disposition governed


3
       Numerous cases support this Court’s discretionary jurisdiction resulting from
misapplication of precedent including Ricks v. Loyola, 822 So. 2d 502 (Fla. 2002); Rosen
v. Florida Ins. Guar. Ass’n, 80 So. 2d 291 (Fla. 2001); Gibson v. Avis Rent-A-Car
System, Inc., Inc., 386 So. 2d 520 (Fla. 1980) (citing Wale v. Barnes, 278 So. 2d 601
(Fla. 1972)). See also Raymond T. Elligett, Jr. and John M. Scheb, Florida Appellate
Practice and Advocacy (Second Edition) at page 22, and Florida Appellate Practice
(Fifth Edition), §6.23.
4
       See Acheson v. Smith, Inc., 148 So. 576 (Fla. 1933); Steinberg v. Sachs, 837 So.
2d 503 (Fla. 3d DCA 2003).

                                             5
by the Statute of Wills. 5

                                       ARGUMENT

I.     THE 3RD DCA OPINION EXPRESSLY AND DIRECTLY
       CONFLICTS WITH LONGSTANDING FLORIDA LAW WHICH
       RECOGNIZES THE VALIDITY OF OPTION CONTRACTS
       SUPPORTED BY ADEQUATE CONSIDERATION FOR THE
       EXERCISE OF THE OPTION AND CONVEYANCE OF THE
       PROPERTY AFTER THE OPTIONOR’S DEATH.

       In the instant case, both the Report and Order correctly concluded that the Letter

constituted a valid, binding and enforceable option contract between Ruth and

Petitioners. In reversing the Order, the 3rd DCA Opinion establishes a conflicting rule

of law that an owner of property cannot enter into what is otherwise a binding,

enforceable and operative option to convey property that takes effect during the op-

tionor’s lifetime but is not exercisable by the optionee until after the optionor’s death.

       The 3rd DCA’s self-imposed policy driving the foregoing rule appears to have

been its apparent reluctance to permit the conveyance of interests in property after death

of the property owner other than through testamentary formalities. At the same time, this

rule abrogates the historic legally recognized right to enter into contracts that are made

and become operative during the property owner’s lifetime and which are intended to be




5
       § 732.502, Fla. Stat. (2001).

                                             6
binding upon the heirs and estates of the contracting parties. 6 By refusing to enforce the

Option Contract, the 3rd DCA Opinion effectively nullifies the historic relationship

between contracts and wills, and, if not reversed, could cast a chilling effect on the

sanctity of a party’s fundamental freedom of contract, eliminate a long established right

of conveying interests in property pursuant to option and other contracts entered into

during a property owner’s lifetime, and effectively thwart the fundamental policy of the

right to freedom of contract between parties sui juris.

      Florida has consistently recognized the validity of option contracts for the transfer

of property after the death of the optionor without regard to compliance with the

statutory requirements of a will. See Galatis v. Plasman, 80 So. 2d 918 (Fla. 1954);

Palm Beach Estates v. Croker, 143 So. 792 (Fla. 1932); Kelley v. Burnsed, 805 So. 2d

1101 (Fla. 1st DCA 2002); O’Berry v. Gray, 510 So. 2d 1135 (Fla. 5t h DCA 1987).7

Whether or not the Letter complied with the Statute of Wills is completely irrelevant to

the case at bar. The 3rd DCA Opinion not only directly and expressly conflicts with

specific Florida precedent relating to option contracts which, like the present situation,


6
       An option to purchase realty, unless otherwise limited by its terms or by
necessary implication therefrom, is enforceable against the heirs, devisees, and
representatives of a deceased optionor. 44 Fla. Jur 2d, Real Property Sales and
Exchanges, § 24. See also 77 Am Jur 2d, Vendor and Purchases, § 38.
7
       See also Powell v. King, 338 S. 2d 56 (Fla. 3d DCA 1976), in which the 3rd DCA
upheld the validity of an option contract entered into during the life of the optionor
decedent but not exercisable until after the optionor’s death.

                                             7
involve a non-testamentary grant from the optionor to the optionee, it is also in direct

conflict with Florida cases, and those from other jurisdictions, addressing the creation,

validity and enforceability of option con-tracts, including, without limitation, shareholder,

partnership and other agreements granting options to acquire real and personal property

upon the death of a party.

      In Galatis v. Plasman, supra, this Court upheld an option contract for the

purchase of stock after the death of the optionor. In Galati s, a mother and son had

entered into a stock option contract permitting the son to exercise the option after his

mother’s death, and purchase the stock from his mother’s estate. After his mother’s

death, the son gave notice to himself as Administrator of the estate of his election to

exercise the option. In confirming the lower court’s conclusion that the decedent was

free to contract with her property in any manner that she saw fit, the court held that the

stock option contract was valid and binding on the mother’s estate.

      Similarly, in both Kelley v. Burnsed, supra, and O’Berry v. Gray, supra, the fact

that options to purchase real estate were not exercisable until the death of the optionors

did not preclude the respective district courts from concluding that the options were

exercisable after the optionors’ death and fully enforceable against the estates of the




                                             8
optionors. 8

       The Option Contract was not testamentary. It was an executed and operative

contract made during Ruth’s lifetime. The Florida precedent establish the requisite

conflict for the Court to accept jurisdiction in this case.

II.    THE 3RD DCA MISAPPLIED THE LAW BY RELYING ON A CASE
       MATERIALLY AT VARIANCE WITH THE INSTANT CASE.
       This Court’s jurisdictional grant under Article V, § 3(b)(3) reaches to where the

district court misapplies the law by basing its opinion on a case, which “involves a

situation materially at variance with the one under review.” Ricks v. Loyola, 822 So. 2d

(Fla. 2002); Rosen v. Florida Ins. Guar. Ass’n, 80 So. 2d 291 (Fla. 2001); Gibson v.

Avis Rent-A-Car System, Inc., 386 So. 2d 520 (Fla. 1980) (citing Wale v. Barnes, 278

So. 2d 601 (Fla. 1972)); Arlt v. Buchanan, 190 So. 2d 575 (Fla. 1966)). This case,

where the 3rd DCA’s reliance upon Williams and the Statute of Wills is particularly

flawed, constitutes such a misapplication of the law. Here, the Option Contract was




8
       At least four other jurisdictions have held that if an option to convey property
meets the necessary common law requirements for the formation of a binding option
contract, the option is enforceable against the optionor’s estate, notwithstanding that it
does not meet the testamentary formalities of a will or that it is exercisable after the
optionor’s death. Crowley v. Bass, 445 So. 2d 902 (Ala. 1989); Colwin v. Salmon et
al., 13 So. 2d 190 (Ala. 1943); In re Estate of Jorstad, 447 N.W. 2d 283 (N.D. 1989);
In re Estate of Weinsaft, 647 S.W. 2d 179 (Mo. App. 1983); Lesro v. Kello, et al., 42
N.E. 2d 836 (Mass. 1942).


                                               9
entered into by Ruth as optionor over 21 months before her death, and expressly

provided for the Option’s exercise and the purchase of the Condominium after her death.

The legal issues surrounding the Option Contract involved Ruth’s intent, the Statute of

Frauds, consideration and the clarity of the contract itself. The Option Contract by its

express terms was not and could not have been a testamentary disposition. The facts

and legal issues of Williams are neither analogous nor relevant.

      In Williams, this Court focused on a purported conveyance of real property within

a trust that did not take effect until the trustor’s death. The Court’s rationale for

invalidating the conveyance emanated solely from the conveyance not becoming

operative during the decedent’s lifetime. By direct contrast, an option creates an interest

in property and becomes operative upon its grant.

      The instant case simply involves a common law option contract, which became

operative, valid and binding as an executed contract under Florida law upon its grant and

delivery9 by Ruth, the optionor, during her lifetime. See Acheson v. Smith, Inc. and

Steinberg v. Sachs, supra. Unlike Williams, the validity, efficacy or delivery of a deed

or a conveyance within or without a trust are not in question, and the 3rd DCA

misapplied the Williams holding in declaring the Option Contract invalid because it did


9
       See Parramore v. Parramore, 371 So. 2d 123 (Fla. 1st DCA 1978); Fleming v.
Fleming, 352 So. 2d 895 (Fla. 1st DCA 1977), and Brown v. Brown, 156 So. 2d 683
(Fla. 2nd DCA 1963).

                                            10
not “come within the statutory requirements of a will.” This finding conflicts with the

well established law of Florida. The Williams holding is inapposite to the present case,

and its use by the 3rd DCA was a manifest misapplication of law.


                                     CONCLUSION

      It is apparent, for the reasons stated herein, that the 3rd DCA relied on a case

involving legal and factual issues materially at variance with the case under review.

Moreover, the 3rd DCA Opinion conflicts with other Florida decisions on the same

question of law. In order to resolve the conflict and to correct the misapplication of law,

this Court should accept jurisdiction to review this case.

                                    Respectfully submitted,


                                    ______________________________
                                    HENRY I. PASS, ESQ., pro se



                                    EILEEN PASS, pro se




                                             11
                            CERTIFICATE OF SERVICE

      I HEREBY CERFITY that a true and correct copy of the foregoing Brief and

Appendix were served by U.S. mail this 28th day of July, 2003, upon all parties listed

below:



Richard Wolfe, Esquire                          Marlene Silverman, Esquire
Pathman Lewis, LLP                              Barry Rothberg, Esquire
One Biscayne Tower, Suite 2400                  Greenberg Traurig, P.A.
2 South Biscayne Boulevard                      1221 Brickell Avenue
Miami, FL 33131                                 Miami, FL 33131
Counsel for Respondent                          Counsel for Co-Personal
                                                Representatives of the Estate of Ruth
Terry McConnell, Esquire                        T. Snyder
H. Hugh McConnell, P.A.
201 Alhambra Circle, Suite 1102                 Steven W. Cutler, Esquire
Coral Gables, FL 33134                          Litow, Cutler & Zabludowski, LLC
Co-Counsel for Petitioners,                     350 E. Las Olas Blvd., Suite 1250
                                                Ft. Lauderdale, FL 33301
Morris Engelberg, Esquire                       Counsel for Trust Beneficiary Nancy
Engelberg & Milgrim                             Weinberg
Yankee Clipper Center
3230 Stirling Road – Suite 1
Hollywood, FL 33021
Counsel and Co-Personal
Representative for the Estate of
Ruth T. Snyder




                                   _________________________________
                                   HENRY I. PASS, ESQ.
                       CERTIFICATE OF COMPLIANCE

      I HEREBY CERTIFY that in accordance with Florida Rule of Appellate

Procedure 9.210 this Brief is in 14 Point Times New Roman Font.




                                 __________________________________
                                 HENRY I. PASS, ESQ.

				
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