# Motion to Dismiss or Affirm — Chicago, St. Paul, Minneapolis & Omaha Railway Co. v. United States > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386403_0287%3A06 ## Record - **Collection:** Supreme Court brief - **Document type:** Motion to Dismiss or Affirm - **Published:** January 1, 1944 - **Citation:** 322 U.S. 1 ## Text CHARLES ELMO: sree Senn RL RY anki a sen aaa rcamrasyaaps: — - FILE COPY aes it F CROPLEY ‘ ULERK SUPREME COURT OF ‘THE. UNITEDL STATES OCTOBER TERM, 1965. "No. 482 WAY CORFAR?, ET AL., CHICAGO, ST. PAUL, MINNEAPOLIS & OMAHA RAIL- . Appellants, . vs. THE UNITED. STATES OF AMERICA, INTERSTATE COMMERCE COMMISSION, ET AL. _ APPEAL FROM THE DISTRICT COURT OF THE UNITED STATES FOR © 7 THE DISTRICT OF MINNESOTA. . Perry R. Moore, _ | Freperick H. StTincHFIELD, ‘ Counsel for Appellec, 4 er ee ered Cornelius W. Styer. STINCHFIELD, MacKALL, | Crotnse & Moorz, Of Counsel. INDEX. \ es ; Supszct Inpex. : Motion to didmniss or affirm: 7 ee a RE a ay PES SEAGATE Am a EE A The Commission’s erat of authority under '. the ‘‘Grandfather’’ application to serve intermediate Minnesota points on Routes — _ land 2 was plainly correct ............. 5 As to intermediate points on Route 3...... - Eastbound operation RS PGR eee VB -Appellee’s nists, Ca and amendments 22 Cm tO \ Beetles casey oh kes ‘Tanz oF Chee Crrep. ; Alton R. Co. v. U; 8. etal: 315 P\8.15.:../.00 1B: . . Brown Motor Freight Lines, Inc., 2M. C. C. 667... .. 16° Dougherty Storage and Van Co., 3M. Cia. ..... 16 Federal Radio Commision v. Nelson Bros. Bond & Mig. Co., 289 U. S. 266, 77 L. Ed. 169,58 Sup. Ct. : 627, 89 A. RE SUES 4-2 Sr atlas ee 26 Kansas City S. R. Co. v. U. S., 931 U.S. 423, 58 L. ; tf ee an ots Nee o ie ee | Loving v. U. S., 32 Fed. Supp. 464, 310 U. S. 609, 84 : LL, Ed. 1387, 60 Sup. MM Fog ce N McArthur, et al. v..U.8., 315 U.S. 787, 86 L. Ed. 1192, ie cd, REE UA Aen ere ene. 12. ‘Nathan I, Snyder, 7 M. C. C. 500. 15 . Rochester Telephone Corp. v. U. 8., 307 U. ‘s. 125, 50 4 |” IG Cae ea a 25 — Transfer & Storage. Co., BMCS, 6 M. C. C.::\ a eed er he oni. do's ag 25 ante CORT xs BG) U.S. v. Carolina Freight Carriers oe 315 74" , MS arises ( Pee RL EERE ECESEEP EEE 12, 26 U.S. v. Maher, 307 U. S: 148 1 eg GE ee pees 21 Washburn ates Company, 29 M. C.C.116...** ; <> eee ee See eee te | INDEX StTaTurTEs Crren. Act of September 18, 1940, Chapter 722, Title 1, ia: tion 1, 54 Statutes. 899, amending Chapters 1 1, ry is and 13 of Title 39 U. S. Code. - Interstate Commerce Act: Section 206 (Added huwust @ 9, 1935, as. eaten é June 29, 1938 and September 18, 1940 (49 U.S. ‘IN THE UNITED STATES: DISTRICT COURT i: -’ DISTRICT OF MINNESOTA _ «> FOURTH DIVISION Civil Action No. 811. - _ CHICAGO, SAINT PAUL, MINNEAPOLIS AND , OMAHA RAILWAY COMET ET AL., kgs 7 Plaintiffs, , . vs. . at ‘UNITED STATES OF AMERICA; perenshyae COM: ' MERCE COMMISSION ; axv CORNELIUS _ Dorxe Business As NonTHERN Transrontation Company, - rf ens y " GLENDENNING MOTORWAYS, ‘ING... Intervening Defendant. >. a7 | -. MOTION TO AFFIRM AND DISMiss. Appellee, Cornelius W. tise, pursuant to Rule’ 12, Paya: aph 3, and Rule 7, Paragraph 4, moves that the jetgwent : d decree of the District Court be affirmed. The ground of the above motion is that the questions upon’. which the decision of the cause depends are so unsubstantial ag hot to need further argument. ° -. This'is a direct appeal from the final judgment and de- . eree\entered herein on June 12, 1943, of a specially consti- « {, re, lu —"* oh f Ps ome 4 _— “2 5 totanat a . ONT DIGS LLG SERIE LE EAM HN RAT ROME IS CMON RY AE ABI 0 BG ZINE ZY r : STYER, — ( vives | . | \ - tuted court of three judges. The judgment and decree were entered in conformity with the.findings of fact, conclusions of law and decision of the court entered upon that date. _ Appellants’ ‘complaint prayed that a portion of an order of the Interstate Commerce Commission be set aside, and annulled. Thé lower court adjudged a dismissal of the com- plaint. : Service of the documents set forth i in Rule 12, sid asaalt 2, was made upon Appellee Styer on August-19, 1943. ‘ARGUMENT. Kas Acaiinien -will be addressed to the content of the as- signed errors, and.to that portion of the appellants’ juris- dictional statement wherein it contends that the questions involved are substantial. Each of the latter documents raise the same points. | : The decision of the Lower Court, and-the Commission's . order,.well state the nature of the proceedings before thé -Commission. “It need ‘not be repeated here. Upon this motion it suffices to say that Appellee Styer projected the business of a. motor carrier but two months before thé Grandfather date of June 1, 1935, and filed two applications with the. Interstate Commerce Commission for certificates of _ public convenience and necessity. | _ One of the applications was filed pursuant to the Grand. | . fatherClause of the Act. Its determination depended upon ‘thé proof of ‘bong fide operation as a common carrier by ‘motor vehicle on June 1, 1935, over the route ‘or routes or within the territory Sale Teta | ‘1 See. 206 (Added Augtst 9, 1935, as amended June 29, 1938, and: * September 18, 1940.) (U. S. Code, title 49, see. 306.) (a) Exeept as otherwise provided in this seetion 210a, no common carrier by motor vehicle subject to.the provisions of this part shall engage in any interstate’ . or foreign operation on any public highway, or. within any reservation - under the exclusive jurisdiction of the United States, whless there is in ‘ ae Ree eae a We have emphasized’ “route or routes’? because the Act ’ ‘ contemplates operations over routes—not to and from -points, as appellants contend.- See Sec. 208, Part II, Inter-. . State Commerce Act (U. S: Code, Title 49, Sec. 308). In this application, Appellee Styer sought the right to | operate between Minneapolis and St. Paul, Minnesota, here- after.called the Twin Cities, and Mi over three routes designated by the Commission, the Court - and the parties as Routes Nos. 1, 2 and 3, A large number of the intermediate poirits upon each of these foutes lies in South Dakota. The remainder are Minnesota points. The right to.operate over routes 1 and 2, with service to all infermediate points upon the routes, was authorized by the ‘ _ Commission under this application (Grandfather). In ad- . dition, and pursuant to the same application, the Commis- : sion authorized Appellee to operate over Route 3, but be- . tween terminal points only, viz., the Twin Cities and Mitch- ell,.South.Dakotu. Service to the intermediate points on Route No. 3 was denied by the Commission under this ap- plication. | | a foree with respect to such carrier a certificate of public convenience and necessity issued by the Commission authorizing such operations: Provided, . however, That, subject to section 210, if any such carrier or predecessor in interest was in bona fide operation as a common carrier by motor vehicle on June 1, 1935, over the route or routes or within the territory for which . application is made and has so operated since that time, or if engaged in furnishing seasonal service only, was in bona fide operation on Juné@1, © 1935, during the season ordinarily covered by its operation and has so operated since that time, except in either instance as. to interruptions of service ver which the applicant or its. predecessor .in interest had no control, the Commission shall issue such certificate without requiring proof that public convenience and necessity will be served by such operation, and: . without further proceedings, if application for such: certificate is made t: the Commission as provided in’paragraph (b). of: this section and within - _ one hundred and twenty days after-this section, shall’ take effect, and if such carrier was registered-on June 1, 1935, under any code of fair com- petition requiring. registration,. the fact of registration shall be evidence of bona fide operation to be considered ‘in connection with the issuance of . a i such certificate. ee db hell, South Dakota, - 4. “The other application, embracing the three routes, was filed pursuant to Section 207 (a), and its determination de- — pended upon the finding by the Commission that the public ~ convenience and necessity required the operation. The | Commission, having gratited the right to serve between the terminal points on Route 3 under the Grandfather.Clause - . application, authorized Appellee, under ‘he- ‘public con- - venience and necessity’’ application, to serve the intermedi- . ate points on Route.3.?_ . The question before the Court, therefore, deat only with intermediate points on established routes. The Commis- sion’s finding that there were bona fide operations on the grandfather date between the termini, the Twin Cities on the one hand, and Mitchell, South Dakota on the other hand, is nat questioned. The finding that there were bona fide operations on the grandfather date from the. Twin Cities over the ‘routes to the intermediate route points in South Dakota, and from those South Dakota intermediate route points to the Twin Cities, is not questioned. — The issue is reduced to the correctness of the Commis- sion’s grantof authority to serve small parts of these three routes, viz.: those intermediate points lying along the routes within the State of Minnesota. The issue as to the inter- mediate Minnesota point§ on routes 1 and 2 arises under the grandfather applicatioh_ The issue ‘concerning the in-” : termediate points on route 3 arises under the ‘‘public con- venience and necessity’’ application. In. short, the Commission, with foundation here undis- puted. properly authorized the appellee Styer: to serve be- » ‘tween the terminal points and to and from‘a large number of the intermediate points upon the routes. . Appellants. object to the Commission’s inclusion of certain intermediate , “points upon ‘the routes—being those in Minnesota. The © 3 Other routes not here’ pertinent were granted, and some were denied. Commission in accordance with the statute, Section 206(a) granted the routes. The appellants by this action seck to . “break up’’ the routes granted. and compel the motor car- tier to refuse proffered shipments of the public destined ‘to these Minnesota points, even though the trucks pass through each of them daily. Suth a situation does not pro- mote ‘‘economical and efficient service * *: * in trans-. © portation * * *.’’ ds required by the national transporta- tion policy. (Act of September 18, 1940, Chapter 722, Title _ 1, Section 1, 54 Statutes 899, amending Chapters 1, 8, 12 and ¥ 13 of Title 39 U. 8. Code.) : The Commission’ . | Grant of Authority under the “@rand- _ father’ Application to Serve- Intermediate Minnesota Points on Routes 1 and 2 Was Plainly Correct. : ) Appellants attack the Commission’s order in the respects above mentioned upon two grounds. The first ground is that there was no ¢évidence offered as to “grandfather serv- -ice’’ to these intermediate route points in Minnesota, a service on or before June 1, 1935. The Commission, in the assailed order, found as ‘follows: ‘¢‘Prior.to June 1, 1935 applicant served the intermedi- ate points on routes 1, 2, 4 and 5 of Brookings, Iroquois, Forestburg, and Madison, (South Dakota points). Applicant does not claim the right to, transport inter- ‘state shipments from the Twin Cities to’ points on his routes in Minnésota, but claims that such points were served eastbound from South Dakota. Although the proof of service at intermediate points on the above ‘routes 18 not impressive, when considered in connection with the fact that operations by applicant were insti- tuted only 2 montlis prior to the statutory date and the testimony of applicant that he.did not limit his service _.« to terminal points but held out service to all inter- /~ . mediate points and actually solicited such business, we are convinced that he should be authorized to serve’ 2u , i ©) io. 6 all intermediate points on routes 1, 2, 4, and 5, and that a restriction to serve certain intermediate points ‘in oné direction only would make the authority granted unnecessarily comptionted and it will not be —" 7 (on insert) : “The lower court, after citing emnnneii Commission deci- . sions, stated the long established is followed by the | Commission: “The Cemileslin he | in effect, ruled.i in tnlion pro- ceedings that proof of actual operations as a common. . carrier to and from termini and.some intermediate points on a regular route, coupled with evidence of a.. holding out of service and of a willingness and ability to sérve all points on the route whenever shipments are offered, will justify a finding of bona fide operation to - and between all points on the route. See Nevitt Com- mon Carrier Application, 4M. C. C. 298, 299-300; Con- solidated Freight Linés, Ine., Common Carrier Appli- cation, 11 M. C. C. 131,136; Knaus Common Carrier. Application, 20 M..C. C. 669, 671; Los Angeles-Seattle Motor Express, Inc., Corimon Carrier Application, 24 - M.C. C. 141, 145; Tarbet Common Carrier — 31 M.C.C. 63, 66-67. ” (Our emphasis) ‘The lower court further found: 2 “There was evidence before the ¢ Comntission sufficient “to justify the inference that prior to June 1, 1935, | ' Styer was able to serve intermediate points in Minhe- ay. sota on routes 1, and 2, and had held out service to such. _ Points. ”*. (Our emphasis) Upor the precise issue, here prveatited, the lower court correctly said: : “In the ins tant ; e, it is ie that the osinmin ‘sion regarded the proof of actual service between - termini and to intermediate points in South Dakota,- - together with the evidence which terided to prove that _ Styer was offering and was able to serve intermediate ‘points, whether in Minnesota or South Dakota, on the ‘grandfather’ routes, as sufficient to justify the grant ' -. which it made to Styer. Proper deference ‘must be paid to the Commission’s interpretation of the law which it enforces, Gregg Cartage & Storage Co. v. United States, 316 U. 8. 74, 88, and, if there is any war-——- rant in the record for the judgment of the Commission, it must stand. Rochester Telephone Corp. v. United States, 307, U. S. 125, 145-146. We think that the Com- -mission’s determination that Styer was entitled to the ghts granted because of his bona fide operations. as . _ ‘a common carrier on and prior-to June 1, 1935 did not ~ amount to an abuse of power.”” Py Sh And again : - “Tt must be. true, however, that the Commission, in determining the nature and extent of the ‘ grand- ~ father’’ rights of a carrier in a particular case, is not ' “ required todo so with mathematical precision, and that, within reasonable bounds, its estimate of the character _. and scope of the carrier’s bona fide operation on and . prior to June 1, 1935, must be, accepted by the courts, which cannot substitute their judgment for that of the’ Commission.”’ 4 * ’ Inasmuch as bona fide operation onthe ‘‘grandfather’’ date without dispute .existed betweén terminal points and to and from intermediate points in South Dakota, the only issue is whether or not there was evidence which tended tq prove that Appellee Styer was able and was offering to serve the remaining intermediate points in Minnesota. His ability to serve these points cannot be questioned. His trucks daily operated over the routes and through the in- ‘termediate Minnescta points. There was no ‘‘operating”’ or other reason why, on June’ 1, 1939, he could not have eo. ee 8 served thine points had the business heen offered. bai | testified upon this point as follows : “ Slayton (2, 4) Lake Crystal ... Tracy. _ “Twanhoe” - - Fairmont Balaton : Redwood Falls: - Mankato. : "Lamberton VAs ae Adrian | ° - Springfield -New Ulm — ve May we add that Appallaxt’ s. abstract of Exhibit 7 is’ ‘not complete. The exhibit itself reflects many more ship-— . ments’ each year of operation from April 1, 1935, to No- REE OI eine DELETE LAG EET SSL ALO ELD SIE BOIL ES Be SIE EG *. : . , . a oF SERRE eee rene ttre z a oe . Ue In addition, the Cominission, 3 in its decision, found: that _ the applicant’s business grew to more than a million —: per month. .. ; The point is that ek: 3 on April 1, 1935, projested a motor carrier business which ‘embraced all intermediate - points on routes land 2 on the grandfather’ date. He had > been i in business but. two months. No business is bern full | grown. It takes time to develop it. It was as Styer testified ‘because of various contacts ts at some of these towns, we got much more freight there. I was born at Huron and was well acquainted there, and consequently, Huron developed faster than at some other points. ’’ = s Statement — of Evidence, pp. , 5 : ‘The fact that he ‘obtained traffic to these Minnesota points . after June 1, 1935, simply meant that such traffic was the -fruit of his efforts at solicitation from the beginning of his business on April 1, 1935, and extending to and on the grandfather date of June 1, It corroborated, .we submit, . his own testimony of solivitation at ‘those points prior to ' and on the grandfather date. The record contains several like evidences of Styer’s ° - Offer to’serve these intermediate route points i in, Minnesota. “he above is sufficient to demonstrate that the Commission’s _ finding was based upon ‘substantial evidence. _. Itis apparent that the principal: question in this case is '. one of fact. In reaching a conclusion the Commission was - called upon to weigh the evidence.: It did so. It believed Styer’s testiniony that he did solicit traffic to and from ~ these Minnesota points and that service thereto was em-* _ braced within the general plan which he projected: ‘on April _-A, 1935. ‘It is the law, as we understand it, that the Court will not. declare invalid the Commission’ s decision where the case turns upon the weight which, the Commission gives to the evidence before it: ~ ¥ A 7s 12 ‘We submit that a substantial question is not presented to this Court where the principal question: involved :i is the. weight ‘of the evidence before the Commission. In McArthur et al. v. United States,'315 U. S. ‘787, eae L. Ea. 1192, 62 Sup. Ct. Rep. 915, the.court“granted the | motion to affirm upon the ground that the questions therein ‘invglved were not substantial. A reference to the lower woth’ ’s decision (44 Fed. 697) indicates to us that the oply "question there involved was whether or not:there was sub-: ° stantial evidence in support of the Commission’ 8 disposition of the problem. : In Alton R. Co. et al. v. United States, et re 315 v. S. , at 23, the court said: ‘The weighing of such evidence fivolves 4 in part a judg-_ - ment based on the characteristics of the highly special- ized transportation service involved. Thus, as we have— said, that function is. peculiarly one. for the Conmis- sion, not for the’ ‘courts. is ; And again: “The question whether his Ginnie ina : pactioglir _' state was ‘bona fide’ is a question of ‘fact for the Com- - mission to determine. * * * ‘‘Our task is ended if there is evidence to support the _ Commission’s finding of bona fides. ”’ In United ‘States ‘et al. v. Carqlina Freight Carriers Cor- : poration, 315 U. 8. 475, at 481,. the court said: * ‘That involved a weighing of specific. ey idence. in light of the complexities of this transportation service. The judgment réquired is highly expert. Only where — the error is — may we say that the Commission. wage e / = again at 483: ©«'We would not disturb ‘those ‘siindialidian if only a 7 question as to the weight of the evidence was involved. - = . . ‘‘That entails not sally a . weighing of evidence but the exercise of an expert judgment on the intricacies of the . transportation problems which are involved.; That function is reserved —— for the Commission. ; ‘(Citing cases. ge : : Loving v. United States, et al.; 310 U. ‘Ss. 609, 84 L. Ed.. 1387, 60 Sup.:Ct. Rep. 898, this court affirmed the. ae court’s decision in Loving v. United States, 32 Fed. 464. In the latter case the three judge court said: ‘Tt is further held that’ the determination of. contro- in bona fide operation within the immunizing period of: the Statute, was entrusted to the Interstate Commerce Commission. See United States v. Maher, supra. This to review. the proof submitted ‘to the Commission 4 in the | ve —— case.”’ _ And again: ee ean eee “The hearing of. evidence is an exclusive function of | or as little weight to-evidence as it seems proper. — ing cases. y" -. The granting of authority undery the “Public Conve nience and Necessity ”’ application to serve intermediate points on ~ route 3 is plainly correct. ‘ As to the Intermediate. Points on Route3. -As aforesaid, the Commission, pursuant to proof under the ‘‘Grandfather’”’ application, granted this Appellee the right to operate ovér route 3, serving termini of Minneapolis and St. Paul on the one hand, and Mitchell, South Dakota, on the other hand, but without service to the intermediate verted matters of fact arising in-whether a carrier was. . court is therefore powerless to hear the evidence or _- .the Commission and it may disbelieve or disregard any .. evidence as it seems unconvincing; it may give as much: - 0 Saas. dak italia as ok Gta aed ang sks AGONY aan . 4 points on that route. The. route aatniile — a from. _ the Twin. Cities through Mankato, Worthington, Jackson. _ and Luverne, Minnesota, and Sioux Falls, South Dakota, to Mitchell, South Dakota. : The correctness of the Commission’ 's finding heii dopenie : upon proof of public convenience and-necessity, not upon’ — operation prior to and on June 1, 1935. - In this case, Con- gress has co nded the Commission to make paramount the interests of > public. — - Sioux Falls, South Dakota is the bareest point in popu- _ . - lation upon the route, and at the hearing much of the testi-8 - mony. centered about need for service at that point. . In its: report the Commission also devoted much of its discussion to the showing respecting Sioux Falls. The Commission ; said, respecting the entire route > : z “There is other service between the Twin Cities and : points on applicant ’ s routes in South Dakota by rail and motor carriers, and no witness testified directly, that, applicant’s service was absolutely neeessary in the conduct of ‘his business. However, the te sti ony of ‘these witnesses, when considered i in connection with - the evidence of past operations by applicant. coniitel’ continuously since prior to October 15,1935; the volume ~ of freight handled by him and the fact: that the business ©” ’- of other carriers operating in the same territory. has * also grown during the years immediately preceding the. . hearing, is convincing evidence that his service is ful- filling a public need and that we should not require thie, discontinuance of his existing service between the Twin _ Cities and Sioux Falls, Yankton, and intérmediate , points on routes 3, 6, 9, 10, and 11 in connection with ° _ operations over the routes applicant is found entitled to operate by reason of his ‘grandfather’ rights.”” (PP. 40, 41; Commission’s Decision) (Our emphasis:) The evidence concerning past operations to all points, including intermediate points, was voluminous. Appellee” Styer had commenced business. but two months before the REAR ARY teY URTIE Deaw stay + 15 grandfather date. Thereafter, and in the normal, natural -- course of his business, traffic to and from all intermediate points was developed: The Commission said: _ : * “Applicant has shown that his business has grown con- tinuously until in 1938 he was handling more than ‘ 1,000,000 pounds of freight per month.” *» (P. 40, Com- ; mission’ *s Decision. is We submit that the actual use of saves over a long period “of time is the highest and best praof“of public. convenience “wind necessity. The public will not patronize an unneces- _ sary service—at least for an extended period. * The Commission has long held that proof of past: opera- tions is evidence of public: convenience and necessity. -We cite but a few of the Commission’s decisions thereon: In’ Washburn Storage Company, Extension of Opgrations, 29 ) M. C. C. 116; the Commission said: 7 **We have consistently held that long-continued succesii earriér, a public‘ utility; could pick and choose the points _ ’ he desired to serve. - If the Commission were to authorize. a carrier to serve. Point A, ‘permit him to avoid service to_ point B, authorize point C and omit point D—all on: the ‘same route and but a few miles apart—it would result in- ‘confusion to shippers.. . There ‘are thousands upon thou-: sands of small towns in this country. A large shipper - should not be forced to ascertain whether carrier X serves points B, C and D, or whether carrier ‘Yserves point “A ee and carrier Z serves point KE, all on the same route. ‘This result does not promote eficient service to the public. Such Situations must have impressed the Commission because - jt refused. fo permit the restriction Styer offered.” . Adminjstrative. questions will’ not. be disturbed by the ‘Courts so long as the Commission: stays within - bounds of its statutory powers. « _.: Rochester Telephone Corporation v.° United States, ~ . 807 U.S. 125, 59 Sup. Ct. Rep. 754. - _ Kansas City S. R. Co. v. United States, 231 U. 8. 423, 58 8 Law Ed., 296. _ |“ Upited: States: v. Caroling Freight Cette Corpine iC tion, 316 U.S. 475. | yA Federal Radio Commission y. Nelsom Br Bros. Bond Be POPES. Mtg. Co. C198H), 999 UF 906, 316, 377, TE Ye Reged 4166, 53 8. Ct. 627, 89 A. L. B.406. | - Yaaguanel: as the wisdom of the diapesition: of such aes tions is for the administrative body and not forthe Comm , oa - issues concerning them are not substantial. 5-744 ‘ CONCLUSION. . We submit that the questions Gaieed are 80 unsubstan- R* tial as not to‘require-further argument. ; - * . The only questions raised are: (1) the weight to be | given the evidence, and (2) administrative questions con- cernjng which the Court cannot substitute its judgment for that of the Commission. _ The law is, and ought to be, that these questions are not for.the Courts, but for the expert judgment of the Commission. No other questions are here - presented: 5 : ) ; ; | Srmcarmp Mackats Cacunes & Moosg : AND PERRY R. Moorz, : Fer ‘opelleg Styer. 4