HomeMy WebLinkAbout20190069 Artisanal Brew Works Meyer Corr 6-11-19 MEYER,
FULLER &
STOCKWELL
tigo. LAKE GEORGE
RLLO ATTORNEYS AT LAW TITLE AGENCY
June 11, 2019
City of Saratoga Springs, Zoning Board of Appeals
City Hall
474 Broadway
Saratoga Springs, NY 12866
Re: Appeal by Quinn Borchardt Brewing, LLC d/b/a Artisanal Brew Works
Property at 41 Geyser Road, Saratoga Springs, NY; TMP 178-1-33
Dear City of Saratoga Springs Zoning Board of Appeals:
In follow up to the May 20, 2019 ZBA meeting, I offer the following:
1. Definition of Bottling Plant: A member of the ZBA requested research on the definition
of bottling plant. As I noted in the meeting, it is our position that it is not Artisanal Brew
Work's burden to define a bottling plant. That is the City's responsibility as the City's
failure to specifically define a bottling plant left that use open to interpretation by City
zoning staff. That interpretation, in turn, is governed by the City's actions and past
precedent, here, with not 1, but 2 uses on this property- a distillery and a brewery. Both
of those uses included:
- "an eating and drinking establishment.";
- "...food preparation or sale of prepared food for consumption on the premises.";
- "...Retail"; and
- "outdoor activity such as food vending, recreational activities, or special events
associated with the brewery".
In addition, how any other municipality defines a bottling plant in their respective zoning
law is irrelevant as to how the City of Saratoga Springs would define a bottling plant, or
more pointedly, how the City of Saratoga Springs already has interpreted what is and is
not a bottling plant in terms of what uses are allowed in relation thereto. Again, all of the
activities set out above which are the point of this appeal have already been approved by
the City as activities associated with an undefined "bottling plant".
1557 STATE RT 9, LAKE GEORGE, NY 12845 Phone: 518-668-219 9 www, & er fu/i icor
Page 12
Thus, it is not for the property owner, or the tenant(here the brewery), to now have to
offer specific definitions to the ZBA. The City bears the burden on the ambiguity it has
created and of now proving why it has the ability to, by change of interpretation, revoke
an already existing vested right.
2. Ambiguity: We noted at the meeting and in our prior papers the issue of ambiguity here.
It is well settled law that ambiguities in zoning interpretation are construed against the
municipality.
At the last ZBA meeting on this matter, the City Attorney's offered: "We are aware that
the applicant has a farm brewer license. That license does permit the applicant to
conduct certain activities within the limits of that license,for which quite frankly the City
has not initiated any objection or indicated that they want that action to discontinue. I
think that the applicant is stretching some of these to a bit of an extreme by indicating
'well does retail mean we can't sell their product'No- they can. But what they can't be
is an eating or drinking establishment and some of the activities that they are doing there
are falling under that purview and have been addressed by the zoning officer."
In addition, Zoning Officer Patrick Cogan offered: "Steve[Shaw] was still the zoning
officer when the business first started." and"Nothing in this interpretation is saying that
the ancillary activities to the brew pub, not the brew pub, to the brewery, the bottling
plant, the tasting room, we're not saying that those ancillary activities aren't allowed
And in fact, this letter was not intended to be a zoning determination. This letter was
requested by the owners of Artisanal Brew Works because they have had multiple
meetings and discussions and they requested clarification on what they are and are not
allowed to do at this location. When the letter says that retail is not a permitted use in
the industrial general zone, the applicant has presented to you that we are saying "no
retail"and what I would tell you is we are not saying "no retail allowed", we are saying
that retail is not a permitted use in this zone so therefore you can't have something in this
building that represents retail. If you are going to have retail it has to be ancillary to the
principal use in this building. We're clear are not saying that they can't sell their own
product. We're not saying that they can't sell 4 packs, glasses with their logo on it, or t-
shirts with their logo on it. No one has ever told them at any time that they are not
allowed to do that. And we know that those are specifically allowed by the farm brewers
license. We have not set any limitations on the things that they're specifically allowed to
do under the farm brewers license business."
"Selling things that are in no way associated with the beer or the products that you are
making at this site. "So when you are having a Christmas tree sale, what we are trying to
say that would only be permitted as accessory to a retail permitted use. You do not have
a retail permitted use. You are allowed some limited retail that is associated with your
principal use. But if there is retail that is going on that can't in any way be tied to the
principal use, its not allowed here."
It is true that for precisely the reasons we find ourselves here today, my clients in the end
asked City staff to 'put things in writing' because depending on who they talked to, they
1557 STATE IRT 9, LAKE GEORGE, NY 12845 Phone: 518-6 6 8-219 9 1A/WWM&y rful Prcorr
Page 13
were getting conflicting advice as to what they, now, could and could not do at the
property. That is, activities such as retail, outdoor seating, food trucks, which had
operated at the property in the past, were now being questioned, with absolutely no
clarity, and indeed still no clarity, as to what is and is not allowed.
So what I would ask you is: how is any business at this site supposed to operate with this
November 2018 interpretation, particularly in light of the testimony at the ZBA meeting?
Retail is allowed, but only if it in"any way" can be tied to the brewery? What does that
mean? With all due respect to the City, that is not how zoning or defined uses works. A
member of the public should, with a reasonable degree of certainty, be able to pick up the
City's zoning law, and have a pretty good idea of what is and is not an allowed use.
With the statement on the record above, Artisanal Brew Works would have to check with
City staff, and if it disagreed appeal to the ZBA, for any "accessory" or"associated"use.
For example, a not for profit benefit would not be allowed, anywhere? Would a TV or
Radio Station, which is allowed in the IND-G zone, be permitted to, for example, have a
"family fun day" and invite not for profits to the property? Hold a fundraiser for
abandoned dogs or cats? Would that not be "associated" with a radio station?
The point is, the explanation on the record did not clarify what is and is not allowed.
Retail is allowed so long as it in any way can be related to the brewery. Retail is allowed
if it is associated with the farm brewery. For the record, the brewery has a"combined
craft brewer" license which is both a farm brewer and a micro-brewer. A copy of the
license is provided with this letter. Is the brewery allowed to sell at its location beer,
wine or cider made by other licensed farm breweries, farm cideries and farm wineries?
All of these are allowed under the license from the State Liquor Authority. Or would the
City initiate an "objection" or indicate "that they want that action to discontinue" as
counsel noted. Clearly that cannot be the course of action for a business in the City of
Saratoga Springs.
Lastly, none of this, and the Zoning Officer did not testify as to, any outdoor activities.
How are those activities "not in any way tied to the principal use?" That is, nothing in
the City's Zoning law, for example, dictates whether or not a tap room must be indoors,
outdoors, or combination indoors and outdoors. What if the taproom was directly on the
first floor and had, for example, garage doors that could open to the outside? Would that
be allowed? What if there were a cement patio? What of the seating under the awning
area of the existing brewery? Is that not allowed? If not, why?
The point of all of the foregoing is ambiguity. The November 2018 determination
created ambiguity, it did not clarify anything. In fact, it revoked uses which were already
allowed. It is not for Artisanal Brew Works to "prove" some definition of a bottling
plant. Indeed, to date, in this instant appeal the City has still NOT defined what is and is
not allowed under a bottling plant.
3. Estoppel vs. Vested Rights: At the last ZBA meeting, one of the members of the ZBA,
and I believe the City attorney, discussed the question of an"estoppel" argument. I
1557 STATE IRT 9, LAKE GEORGE, NY 12845 Phone: 518-668-219 9 1A/WWM&y rfu/16P orr
Page 14
noted, as counsel did, that the question of"estoppel" in a zoning context has long since
been litigated and resolved in New York, and that our argument, indeed perhaps our
future argument, is not based in estoppel. For the record, our argument is, and will be,
based in vested rights to continue the lawful operation.
An estoppel argument is most often associated with some sort of error. That is, where the
zoning administrator or building inspector made some sort of underlying error in a zoning
or planning process, and a property owner or permittee undertakes a project, indeed
perhaps a large project, in"detrimental reliance" on that error. In that instance, there is
said to be no "estoppel" argument against the municipality for such an error because if
there were, it would lead to significant abuse, i.e., conspiracy between an applicant and a
building inspector to the detriment of the municipality, among other reasons. I am
omitting the laundry list of case citations here because that is not the argument, nor is it
relevant.
What is of relevance here is that the City's determination of November 26, 2018
constitutes a change in the interpretation of what is and is not a"bottling plant". To that
end, my clients have invested hundreds of thousands of dollars in their brewery at 41
Geyser Road, Saratoga Springs in reliance on the interpretations previously granted by
the City of Saratoga Springs. Prior administrations have granted a"cabaret", "eating and
drinking establishment" and similar uses as ancillary to the "bottling plant". See for
example the eating and drinking permit provided with this letter, or the cabaret
discussions and permits in the record. That the current administration now wants to
reinterpret and narrow my clients' use is not"estoppel", it is a revocation of my clients'
vested rights in their right to operate what prior administrations interpreted a"bottling
plant" to be. Thus, the genesis of the argument is, and likely in a different venue will be,
vested rights to continue their operation both in the breadth and scope that it has
traditionally been operated.
To vested rights, we most often see these arguments arise when a municipality actually
amends its Zoning law to prohibit a use that is in progress, or already in operation. See
for example Cobleskill Stone Products, Inc. v. Town of Schoharie, 169 A.d.3d 1182, 3rd
Dept. 2019. "Establishing a property right based upon a prior nonconforming use is not
a question of equity and, instead, involves a limited inquiry—whether a party indeed
used,... its real property for the nonconforming purpose at the time that the subject
restrictive zoning ordinance became effective (citations omitted). In contrast, the
doctrine of vested rights is partly grounded in equitable estoppel principles; "[tjhere is
no fixed formula which measures the content of all the circumstances whereby a party is
said to possess 'a vested right'... [so as to] render it inequitable that the[s]tate impede
the individual from taking certain action, "and, accordingly, "[e]ach case must be
determined according to its own circumstances". Analysis of vested rights claims
routinely involve evaluation of factors such as the improvements and expenditures made
to the property and the degree of loss that would be sustained if no vested right were
found." (Citations omitted).
1557 STATE IRT 9, LAKE GEORGE, NY 12845 Phone: 518-668-219 9 www,meyerfull6Prcorn
Page 15
Here, the November 28, 2018 letter is more akin to a zoning amendment. That is, the
City has not established any sort of"estoppel" argument in that the City points to no
"error" in any prior interpretation, and no "error" in my clients' reliance on prior
interpretations, nor does the City point to any reason for this change in interpretation of
its own allowed use, i.e., a"bottling plant".
Thus, yes, we firmly state that the City is estopped from changing its interpretation of
what is and is not allowed under the allowed use of a"bottling plant". We state this out
of the vested rights that my clients have obtained in their use on this property. They did
not change the use, the City changed its interpretation. That is the issue before the ZBA,
and the City has offered zero reasons for this change in position.
4. Splits of revenue: The ZBA asked what the general split of revenue is "in house"vs.
outside sales. First, I do not believe that this is relevant as to whether or not the brewery,
tap room, or ancillary uses are allowed as a"bottling plant". Second, to understand the
context of your question, and perhaps where we believe the discussion is headed, we
should note that the split of business from the tap room vs outside sales is not seasonally
consistent. That is, as the Spring and Summer months turn, distribution to the market
increases. As we turn to the Fall and Winter months, the in house tap room sales are
usually higher than outside distribution. Thus, when we site statistics or percentages, we
need to note that seasonality is not built into these stats. The annualized 2018 figures are
49% of gross sales was distributed (outside), and 51% of gross was in house/taproom.
Note that these include all sales of all items. For 2019 (to date), the figures are running
40% of gross for distribution (outside), 60% for in house/taproom.
Regardless of the percentages, taproom sales are critical to a craft brewery such as
Artisanal Brew Works. The business simply does not survive on distribution alone. The
tap room sales for a craft brewery help keep the distribution cost (i.e., the cost charged
for a half keg)proportional to the market. Put another way, if a craft brewery had to rely
solely on sales in the outside market, I dare say none would profit or thrive, let alone
succeed.
5. Sale of Christmas Trees: At the ZBA meeting, Zoning Officer Patrick Cogan pointed to
the sale of"Christmas Trees" as some disallowed"retail" sales on the property. What
Zoning Officer Cogan failed to state was that the brewery was not selling Christmas
Trees as part of its business. In fact, this event was one of many charitable events that the
brewery holds each year. That particular Christmas Tree event was for the Franklin
Community Center. I am sure the ZBA members are fully aware of the great work that
the Franklin Community Center does for less fortunate families in our area. Artisanal
Brew Works has been proud to support them, and others. Similarly, the brewery has
hosted events for:
- SUNY Schenectady Community College Brewery program;
- Habitat for Humanity;
- Pitney Farms;
- Shelters of Saratoga;
- Ballston Area Community Center;
1557 STATE IRT 9, LAKE GEORGE, NY 12845 Phone: 518-668-219 9 www,meyerfull6Prcorn
Page 16
- Captain Community Human Services;
- Saratoga Mom Prom;
- Alzheimers Association;
- Bob Best Scholarship Fund at the Saratoga Regional YMCA;
- Taste of Wilton (fundraiser for Wilton Food Pantry);
- Albany Medical Center School of Nursing;
- Glens Falls Hospital Foundation;
- Nipper Knolls Equine Center;
- Saratoga Center for the Family;
- Toys for Tots;
- Ballston Spa Community Band;
- Friends of the IBA;
- Automobile Museum of Saratoga Springs
The point is, not a penny from"Christmas Tree" sales went to the brewery. In addition,
the events above may have included sales of various items, auction items, etc., none of
which would constitute "retail". Now, does the brewery benefit from beer and
merchandise sales during events? Of course, it does and we would not mislead the ZBA
by stating otherwise. But that is not devalue the purpose of these events. Indeed, for all
of the events, portions of sale proceeds in the tap room are often donated to the supported
organizations. The brewery supports the local community and hosting events is a legal
way for the brewery to support these organizations. If the City of Saratoga Springs feels
that these events violate the Zoning law, Artisanal Brew Works can advise these
organizations that the events can no longer be held at the brewery given the City's
determination. That does not seem rational to us.
Conclusion: The City of Saratoga Springs did not specifically define in its Zoning law what is
included under the definition of a"bottling plant". The City left that ambiguity to the Building
Inspector as the Zoning Officer in the first instance, see Zoning Law Section 9.1.2. Artisanal
Brew Works is not required and does not have the burden of proving how Black's Law
dictionary, Webster's dictionary, or any other municipality in New York State might define a
bottling plant. Artisanal Brew Works worked with the prior distillery at the location and prior
City personnel to comply with the Zoning law. The fact that the City did not define a"bottling
plant" renders that term open to interpretation and that interpretation and the ancillary uses were
allowed by prior administration. Were this a situation where there was no course of performance
by the City as to what sort of activities are and are not allowed under a "bottling plant", this
entire appeal would be different. However, City's interpretation of what is and is not allowed
under the term"bottling plant" is defined by the City's past actions not only on this brewery, but
also the distillery that previously occupied the property. All of the uses- "an eating and drinking
establishment."; "...food preparation or sale of prepared food for consumption on the premises.";
"...retail"; and "outdoor activity such as food vending, recreational activities, or special events
associated with the brewery", were all allowed on this property as associated with not only the
brewery, but the distillery as well. Now the City seeks to change that interpretation. That, it
cannot do.
1557 STATE IRT 9, LAKE GEORGE, NY 12845 Phone: 518-668-219 9 www,meyerfull6Prcorn
Page 17
No evidence, and no legal argument has been presented to show that"Steve Shaw" who
apparently was the prior Zoning Officer, or any other member of City government who granted
the various permits to Artisanal Brew Works including "eating and drinking establishment" and
"cabaret", were "wrong". What has been shown is that the current Zoning Officer has essentially
re-interpreted what is and is not allowed under a"bottling plant" and that this re-interpretation is
no more clear than it was in November of 2018. This re-interpretation came on the heels of a
request by an attorney for a neighbor. The November 28, 2018 determination, and the testimony
offered last month resulted in more ambiguity- ambiguity that is construed against the City and
in favor of my clients. The change in interpretation impacts my clients' vested rights to their
current use, and that the City cannot due absent a taking of my clients' vested rights with just
compensation.
We should also note that this is not personal. Kurt and Colin have no personal issue with Mr.
Cogan and they appreciate working with him. They simply disagree with his re-interpretation of
the Zoning Law as it directly impacts their business at this location, and this appellate process is
what is required and afforded under New York law for Artisanal Brew Works to protect its legal
rights. Artisanal Brew Works appeal must be granted, and we thank the ZBA for its
consideration of this matter.
Sincerely,
01,40"
Matthew F. Fuller, Esq.
mfuller@meyerfuller.com
1557 STATE RT. 9, LAKE GEORGE, NY 12845 Phone: 518-668-219 9 www, & er fu/I rcorri
NO. 16337 $ moo
CITY OF SARATOGA SPRINGS
OFFICE OF
COMMISSIONER OF ACCOUNTS
D.B.A. Artisanal Brew Works
Know ye that Kurt Borchardt residing at 41 Geyser Road, Saratoga Springs,
NY, in Consideration of one hundred dollars, the receipt which is acknowledged, is
hereby licensed pursuant to Chapter 136 of the code of the City of Saratoga Springs,NY
to operate an eating and drinking establishment at 41 Geyser Road within the City of
Saratoga Springs, for a period one year commencing on 9-6-2016 and ending on the 31st
day of August, 2017.
This license is granted to the said Licensee, individually, is not transferable, and is
issued subject to the strict observance of all local laws, ordinances, and regulations of the
city so far as they apply. It is subject to revocation by the Commissioner of Accounts at
any time, but unless so revoked is to continue in force for the term hereinabove
mentioned.
Dated this 8th day of September, 2016
Commissioner of Accounts of the City of Saratoga Springs
Display in prominent location. Fire Inspection Expires: June 23,2016
A...,
State of New York Department of Health
PERMIT
To Operate a
Food Service Establishment
This is to certify that
QUINN BORCHARDT BREWING, LLC.
the operator of
ARTISANAL BREW WORKS
at
41 GEYSER ROAD
V) '
Located in'the CITY of SARA SPGS.,tin SARATOGA County
; ....,
is granted permission topwrate said establishment in cignwliance with the provisions
,,,..
of Subpart 14- ftite**Ate Sinitary Code and
\ ' iiii.0-41-i f 11 -ilk: .6
iL) ,,,,,,. c ,,t e o owl. -c• ,i ,,s..
. -.,---, v.'.6.,•,,; -,,V., , 1 1
, 1 1,,
IP 1 - 4 . •
(1) This permit is granted subj:,,,'.,to any i 41e1 applicable st , 1 ea and umcipal Laws,
Ordinances, Codes,Rules and ,:i.ulatigP;11,1</ , ,,- , M. • i , 1
' .,, 1
***Menu limited to food items, $i ed on ...bait'
Any changes made to the men,. 1 fl?e II grottty till§ tee gil J li
li
,\\,:-,. iza.....-403.---Aw...., ....z
.x,.---,,,,..... —.4e, ,., ' , 44
***Capacity 70 Seats 6,..„---- - i'" litS)"..... i'11.4 4,:i . 0,'7" OP --.2`
\----;
r---.., ---I$.• ...„ . ,„11.1 „,,r.'"P-'''''''
-r (,, -16-------- ‘-,10110 ,..-
------ C E L SI U------------- --------------
,
,7
Effective Date March 21,2019 (ilt, .
Permit is NON-TRANSFERABLE i
Permit Issuing Official
This permit expires on September 30, 2019 and may be revoked or suspended for cause.
THIS PERMIT SHOULD BE POSTED CONSPICUOUSLY
Facility Code 45-BJ12 Permit Number 45-BJ12 Operation ID 946639
DOH-1320(5/15) (GEN-129)
....._.,,,, .— ,,,,...:.'s,,7;.;,:if,'•i:-6;,-ii ,;;;;;;,::;;;•:-il-T;;;;;;Ifii'iN4r.,.,4...iii'''''':::.f,'":."1;:".?-!'';'''''''',',,'"‘:;-;;.;;;*,,;;',,,' //;-;';"..siiiiiics:
SVIZI!:=i;:l?:'VA'...4.,'47b,',,'''::*''•/;"':PS;1/4
- ..NI•4itif:77-7''',-,.:\,-- -j'o,jz3fe4'7•k,',,T=7:,:7,41.(44,1gZi:!".,:l:%%%''''''''''''''''''''',''';;g:;'‘'''-!...:::,:•.,,r.ii:;'.qi::11;1-1:qt`..''',',Wiii$V4.: 4PiEl;',FP:iii;.'.,:,it,;,irii,i,,
', ,,-,,,,_-,-,N......,'••••••;;;;;;,;;--;111h4F1-..•410,I,,44'S'ik .`4'.w.-7011:::1:1,114;:iii...,.''$z`1,,,i.:''''.!,..!!.';':.';',,,-..'-',' . "';e':--ilil','Afiii,ii.f.',4Zit.tir'iate'•'qi:..
;g7;.iW, ',4".)e..)..4.' s•;..t;. .,..144.4:40,k‘S'''''''1111,'al.'•''',‘'`;:.::-7'. Jo"'---7::'14.:5,4.:*-4...-.:::i:.
.(tel; .. ,:„.i:Sailli:,.4„fe.:14;t6,Vi' rgil.'1,• 1-'41;-,‘,‘'...!,Y',! .."...,95, 4:....,:ir.s,..:: .1!;;ff:i..4,44 1,,,,,,,,;;::.:.ii,,,-,-_-: ..!;,:,..,:: :-.-, ',•;;,/14,x...„.t.:it.i:Ii-zz„-:',.,,r,-,--:„...--,:;.::!..„:;:?•:•,.7,:,,:.:.•:,
••
.1.,,r.,.....i,V,k;,.::,..,- ...•,..,-;,ffkr1,, .., : •..,..../... ,:f1t4--•411-‘: -A%-.1*TV.:1,"';'-aattonew'."''''.4:"-•, '-• ' ....,:i'..:`,•:',Itli•i..3:•I'z•-:.,:.,
aat.t.:.!,:o!.,,,i,!..E.lir-;.....',...F.5-; -',A. 3•I::„,...,if:: ‘Ile.!..,,, =,,,,i,iii:.ft'',1,:,...1.,P.',..,'.065,300.'
,:z:‘,,,,,...u1,.
....,...............,0 .tz.,-71,',...,.,...,,,z,:, .'•-.-- - ......„, , , -, ,,,,,,,,-, r---- .„ ..:4-- - '''
..' ,',77'.7":-.',"-:-:4,-;1:-,„.e.'' ,„.s.,..._1,-- ,i,„..i,oli,,,,4,...,',',:'',-.;,.-;,..,,:,..'''4",e)'w."'.•. ,.. -'''.'''-:- -..-____:::------------- -—— _:.--- I '" ekli.:AV,.....11.7, ,,,,,.v::,.
n up n cpit::.,;;&'''..•..:i4:::."
1 '',•,.''';,i..::;•'.;..1;:ilii.:.L;.
ri frri n
H W
c) Pi
› -- lLi. , K. H ›, H
a) bi 7 0 z
H > ?;:.., 0 > i-
-1 H 17 up > 10_,
Go w n -‹ -4 0 _r
rii .11.z.-',„",,,•-;.:-:24:.
7,. I I m ›, 1- (-; (D tii ,. co -1 , L . i*:. ..
:th
.,,,,,,.., --.....•
M M Pi 1-3 H cl (DCX m01 02m
.. .. .,..
• ....
1 i, 335rTirn
(JO - ..... ..
....t.,....:-........
Ii --- Z > 0 H F., 0 ri/i m W (,, r- ,LC, n .....•••....
•.•_• .... .
.,,,,,,,,•,,,,,.--,,,. _"---_ ' K 0iM
H Lli U) J M ''1,, < -1 7 '''' 0 ',-
*.,:,,ZZ.:,,,It;'Itt•;;',;CI' - 0 0 3 M
,. :atz;;::::'-',-:,.f;:•„
0 M f-,- .-„,1 0 m 7j
Hi '' L.) Z NJ >
, -4
..,....,-,1
o ,--ii 0 m 2 _i 03 w poill , H 1-"' '11
•....,..:#:44:-.1z::::.::,,i' (c-_•2 i 0 0 ›,
ti :,, a
cf) H "11 o co cf.) i r"1 IT ----- 1 4:4 0 uu H3
":4%,);,:z.,..V,:.•;-;,:. :,,,S',
z
n m > cm mmm ....
C 0',
..„i.,;;;;:-;.,,,;:,•::,..teii..fr, ii,-; mm 0), K U)
P-1 1- ° -...-1 6 w '• 4 3,--) m° '
,ii Zi Iji ,,_. P- iii - 2 i ,:, c.) , .... ,,'.-... ......„
'."'3''Mc;:•,•-';1.',6-.a'
•::::::;.'. ,.,:, ...--:-.. LI) 0 u) m zi U P a' Fli, ,--, rii 2 0 D. -1 m
iii:pi v, ?). E g z H LT] Z ,-- -..._, -‹ .,• .......... ;
,.../o',;,.•.,“;:b.
'4tric•:',:iii,;•''',111.t:).0.4.,.' i 0 -4 n 0 r
WM NI.1011.-. ./ 1.,#,.,, ..::..•!,,...,,,,
H 4# v$11,1'.,w,i,,-;;;.),„f;,,,,•„
0 0 niz ,z , (T) m .,. 4
0
•'!'it:11:6,1(44:4141 E cnrn 1-71 n Cn
pi NJ) 1-3 H -o -1 ti c 0
ii ,
0 Lci
i ' - Ilq1,-,Z,:i.,•:•. ;,
C) C 0 C 1:-':
0 7i xi uu z 1. . 3:1 Z ,
,,:„,,, s-tr.!-.41:,;•210$ cn > 0 0 z m
, :•-.1:.1417;.:,:...•..:•61,,...:
',,,Z;tp.,s;;•..',.',....tr '',..:,..' 0 - (f) W ',ti. > 0 -1 ''''‹ - '4 . .....;,,,1::,.:*.,:t7.....t..IA.
trl
ILO 0,
P:i ' . .1k:.,•,'.••-,....-•-•
c > > --, u) i. 4.-
" Jiff!
O -I
0 °
H.
0
m
; 1 CrIln za --Im 33171 I 2F ,,,......
LI I-. 7 _ co -< ,.,
, „LoPk.,',,'''..ct'''.1.11F--'" ....,,-. .*.iki„ '...1.1'•re',''.4V.:.:
0 il T- C
I-' 0 a -Y.j , 13 Idd
m CD
N-) (-)
z 3:1 i z
w Fo riTi D21 q 0 iis.._ 4,..s„., ..:::•,,,:,' -44,„,-;:: .:t.
op
,-1
_„ ...._.. ______
icy,
0- m .
CD ;' , 1. , ;. i :iii' ____±:-__4.---
O'l
0 i=5 tillt1 1 t,
I- -13 z m -, „.„ I wi,' ,,,;,,,.., )
"I > 0 z r;1 1
m z --1 u)
,'''rii:21".ruTA-4 im'f';,,' • l'6,--:,
7, ..NIN1971111;;,,
_ -< ___ --"1 ?„1, _
CD M - M elliti , n so' '.,111'''''.- ;;. --',' lie
cf)
r- ..',.,,,,,,• •,•• •'.',‘.111• `,!'"..''',,, r- 1-
,I fit,..„N„,) ,
-a r > -1
, 1 •
ZZ,ZZ' ,:',. .,,,"rz: m oa 0 K
Z* '''' .!•."'..;,_•i'''':-1.51,1 '1 '' Fii m r71 rn H-
9
44:1Vi7:
rn 0,. i 0 Npti,.i.,•,:ii,'. ..,'...1 .1-T ''.-.•--
....
-1
151. 11 2 c 1 LL-
r u) Z
0 -1 tzi ............I : ...,-;), gr)
i '449,7.,-J.-4i,•,'.,. :LI c c,f) n
1,-- z z ' m • :.•-•;•4.' ':!';' 49'
1,0.4000;;A:eAlt;ii '1:411)1:ii.
- .'"?''''.•,°1.'',,..10,1.14*. Z (I)
H 0 C -I %, '-4411444,,,,H,-.• , 44„,- •'. . ,., - ,,,e.'..!1%.1,i'17/4.
w
m 'r.:Eili•;;:.',1:-!'.,.-...'..0 3, u) a 0 -
co
'..•.....huomiutiP• .44 •,g'.!fb g/".-1,
1!..1.•V:6 4.4 r 440 CC) > M (I) Cr) M , Fri > ............. 1 1.,\,,
1 .\.,\ ', -:-... 'W..,•:-.:"114,
m
r 0 ) I ill*t ,''. ::-,.,71V,,,;-44:4-1;,2!•;.:,
m > m o
S Tv r ,,., ..4,,---„-.....,-;;:-:•;,--
'?„,":.A'•'-!•'':,:il'ilti:;','''''si:' (in r. r- Z ,
r., F, 7,. 6
is,.%;:..,,,•:.,,:,.,...J' ---__._ , , , ,... H H
ki (-) ril LI-1
irl!f:: ,;1 m ---1- w m ,,—,,f'''',.. n r 0 i E I )'', tli X 1-11 i .,;:git•=';',..,;,,--:-
Z hi t-ri
I -it_
i 0 rc°, •Mil i 1-3 H Lii
CO C
se--,
-0 m < — i 1 - H I)
Z M til 1 1 ° 1 .-
0 _nrn i T. ',
,• '1,', >rn -u H M. E p.,.1 h.] 0
-0 13 ...,, 5-,:: IL- H IA
.,__., ...„....,.
hil til
m xi - ,,,....,-
.:;:ti:"1:1371 'lli....--:.'":7 L71 tii
A 9 j••< Fin (cif)) 1) 4-7til al, 2
•; ,,,,,,,,,,.-,,v ai,::i.;,,rvfaii
:',.,--,:',,,:f:,:-ii;A▪ -I,:'?.,;'!•:!;": co 0 0 c rt- i
1 ' c7i 0 n ' 1--3 ' '' -,',;:.,,,,.';::;;.'',4-;,:',•-,;:
0
.-.r.,;•;-•
m 71
} tf0,14:1,:gle,''' ,-0.
6_.) f.--_,,,,,
0 w
-ii jl M., ..'7,z1g.
,iiE110.• 4',""•,,.7.4,!.` -...,j -1 > o -1 1-1 • Q \
, 0 i-,5 0 ,... „ „,, i s 1_3 til - , ,,,',iq.',$.:7,-.2.#•''','
cr.:no 33 ,i,
r ri •• , ..iff:.,`,..-....----;.
cri cn r.21 T. ''
H H rn > -
••
,,,,,,:,•:-:-:..::::',:
,,t, 0.,... • -- -o .„ - P
1-`1 0 113 * ........
[----'
Q.,
pool : --] c, ci
C oj .17_
H ,---..
M z o- 0 . ,,, Lc)
▪ _ .... ...--,.
-,
(....) ° C) (D
O ''< > U-1 U..) C) =• ...• ...,,..,,.1
a . ..
M '.< N,,, .1 -(11 1 -I
, •,..g1111,.... • .... '
DJ
: a) CD 1-'
cr, , z
,-- --, CD ic,
> ,
-0 U) rn
,:, -
>- 'HT > 7171 ' : DC) '--L\-31 '''N-)1
0 , LO. I-'
Z M
Do 0 o
"- "\-, NJ c) 0 it
1-, H .4:,,..,...vo,i:i.u..,•q:1:1).::
:i1•17•?.i'ii,'.1011.'i?:3'4%. _ > 1-
c) P
1
D P ks) 00
'..:4•.';;;:ii:riii;•!-':::,.,--;,,,,; z -I 1-
'•..i?;,,vi-Iiiiiiif:::!..f.ijii;:-:
,
,tiiiii,;%:..ki:,4,4: •0.- - _ .,,, c) P
---------- . , ----------- --- i •::•51,e,•,--4.4:4:•:.&f.•,,,
,......:•A‘%.?::uii....,'. .;....,‘,,,, ( '' --,..,
,. _-,:----.---. _ ..
i ,. ., • - ...,
. ,. .. ... ....,..,
,,,, ,-..-...t%,..it.,•:,..,... .-:•.,. ''----, ------
, . 4 . ,
,., ,'..', ' ... ,•
OIL 1 7 -''. ''''' '
k_,„,..., -ay .,.., ., .,,:-.:,..;_ .05,1.,,,r-.*::' ,:ipil,''k.::;: , , .,•,::41:1C--::,,:.
41.1%-e) ..,:..,;.,•,i;;,... ,,,,,,,.'4_,,, iii,.11,-‘1....t.4•7::;11,4-.17','iii,-,-..: ei ...:111 ..a.re::ei•,,,,,,t.. ,i iktVi'• ::.7:74.1iiiikSif;$(..
ii, i.. . :0,;---7-477.:44'-.'11':`,z;;,:.+4.,:Z '''.: 7'1-* ;;Ve ----'--A, . , ,..`-'41..t.'11‘.k.f., _"...iisrttski.IT.A,5,,,,ILiyAtti;.1,1;0:41,kik:14,47;s ii1-..., •-;,;:fi:,7.fir,,,,,,,,,,,,,„,•,,;,:s,:,-::zq,,,vs,%,tI11,1,,,
'.:-..itir•;,,:.--i--.:-iis-ii-s;,,,,,•••:::41,,‘ 3V .. -:-: .4,,,,,:-A, ::ii,;:;,,* ,.,f'.."'-••;;•Iii,ili., •""I,Wili!'ilV1,14igiliti;;' 1-::' i/fiad'Asks ..fli,*-4%::01,:!!iiii,61;V,;,,,':tiseisis0(flie4,-..,,,..,T.',,iiii'f,:lii,71:',',,'`'''...1`.;',,:::::;*.;;;;;;',7?.i-.4.:i.4.•4t,;'''''',?:`',
".•ttiC,70'lltri,4:ti‘t : ' it
,':i,,."i,'.,;i.:.':_• ,. vf.",..;::...gi.,o`:q.zi-.;#4:t.,,,..i:,:, :z/ki.ii!*t.,,7tto,.,1-,,;;,,.,.;4:-:s,t,,d;.,'.'.,i : ti11SA4t4lw1;4.‘:.!.p•.k:i',t-i'! , C.• e74-1.i.-'i, ?5.:4.011;;.'W.41
,....• ...-
FOLD AND TEAR HERE
.,....