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Subpoena Rec'd 1-12-24 - Records for Grace Elizabeth Schmidt{j$,E C [E [I V E fTh lf' -I--J I J,il, j'." i 2 2/)2,4 J..,_,ik-- - --ll_a-rX'yi)'r"l<y, !l -"""" L."'-"""J" 'a o " ' g4-RT1NO CITY CLERK - A $ten Deposfitnon Seriee, LLC 1755 Witttngton Place, Suite 750 Dallas Texas 75234 Telephone (972) 488-5555 - (800) 346-4405 - WD8,Custodian@wdsli Secure File Upload - littps://securefiles.wdslezal.com/filedro CITY OF CUPERTINO - HUMAN RESOURCES DIVISION 10300 TORRE AVENUE CUPERTINO, CA 95014 HUMAN RESOURCES TELEPHONE: 408-777-3227: 408-777-3109 SUBPOENA FOR RECORDS RE: Records Regarding: GRACE ELIZABETH SCHMIDT; DOB; 08/19/1964; SS#: XXX-XX-6458 Our Ref. #: 7646LOO3 Please Contact: Jolene Standridge x226 Enclosed please find a subpoena that authorizes the release of records. See Attachment 3 for the records being requested. I. PLEASE RELEASE -ALL RECORDS AS NAMED ABOllE, JNCLUDING ALL FILES AND EVERY PIECE OF PAPER - AS REQUESTED. 2. Please date and sign the attached Declaration/Certification of Records - Tliis Autlienticates tlie provided record. 3. DONOTSTAPLEORPROWDEDOUBLE-SIDEDPAGES, -4. ALL FEES MUST BE PRE-APPROVED (WE WILL ASK FOR PAGE COUNT PRIOR TO APPROVING FEES). WE PREFER RF,CORDS SENT IN ELECTRONIC FORMAT WHEN POSSIBLE - VIA PORT AL/CD/EMAIL OR ANY OTHER ELECTRONIC MEDIA. ANY UNAPPROVED FEES WILL NOT BE PAID AND RECORDS WILL BE RETURNED. IF NOT AVjuLABLE ELECTRONICALLY, PLEASE MAIL THE RECORDS TO THE ABOVE ADDRESSi NOT THE ADDRESS ON THE SUBPOENA. 5. Please allow the following authorized copy services: I. Written Deposition Service, LLC - Rob Glucroft or designated agent: 21021 Ventura Blvd., Ste 410; Woodland Hills, CA 91364 (828) 97 4-8837 Completing this documentation properly and in a timely fashion will al{ow our client to enter the records in court as evidence, likely, without having the records custodian present at the time of trial, %B appreciate you producing all records requested, by the due date! Shoukl you liave any questions, please PLEASE CALL - 1-800-346-4405. Thank you for your assistance in this matter. Should you have any questions, please call Joleiie Standrtdge x226@ 800-346-4405. Sincerely, Jolene Standridge x226 ATTORNEY OR PARTY WITHOIIT ATTORNEY ( Name, 8iale Bar number and addreee) Rob Greeni S+nte Bar #i 216116 8imoii Greengtone Paiiiitier, PC 3780 Kllroy Airport Way, Sultii 540, Long Beacl5 CA 90806 TELEPHONE NO.! (562) 590-3400 FAX NO. (opiibnai)i E-MAIL ADORfftiS (OptlanaQ: ATTORNffY FOR (Name}: Plainliff FOR COURT USE ONLY tNAME OF COURTi SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREET ADDRESS: Los Angeles County Superior Courl MAILING AOORESS: l l I N. Hill Street Lot Angeln CA 9DD12 BRANCH NAME:CASE NUMBER: 23S?G:V18!il3PLAINTIFF/PETITIONER: GRACE SCHIVImT and ANTHONY SCHMIDI" DEFENDANT/FIESPONDENT: ARKEMA, INC,, ET Al, ForPrDoEduPcotsiolTn'oofNBsusuiBnPesOsERNeAcords I THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, If known}: CUSTODjANOFRECORD5;FOR: CITYOFCUPERTINO.HUMANRESOuRCESDM5>ION:10300TORREAVENUE, CUPERTINO, CA 9501 4 1, YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described iii item 3, as follows: To (name of deposition officer): Written Deposition Service, LLC On (date): 1/22/2024 At (time): 10am Location (address).' 21021 Ventura Blvd., Ste, 410, Woodland Hills, CA 91364 Ph: (800) 346-4405 Do not release tlie requested records to the depositton officer prior to the date and time stated above. i a. by delivering a true, legible, and dutIable copy of the bu.qiness records described in item 3, enclosed ir. a sealed inner Wit)l tlie addres.i in item I determined under Evidence Code section 1 563(b) c. by making the original business re.cords described in item 3.available for Inspection at your business address by the IXlattorney's representattve and permitting copying at your bustness address under reasonable conditions during LJnormal business hours 2. The rer;ords are to be produced by the date and tfme shown in item 1 (but not sooner than 20 days affar the jssuance of the deposition subpoena, or 15 days affer service, whichever date fs later). Reasonable costs of locating records, makjng them available or copying them, and postage, if any, are recoverable as set forth /n Evidence Code ser;tion 1563(b). The records shall be accompanied by an affldavit of the custodlan or other qualified witness pursuarit to Evidence Code section 1561. 3. The records to be produced are described as fo[lows: G Continued on Attachment 3. 4. IFYOu HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER CODE OF CML PROCEDURE SECTION '1985.3 0R i985.8 AND A MOTION TO QUASH OR AN OEIJECTION HAS BEEN SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PART)ES, WITNES8ES, AND CONSUMER OR EMPLOYEE AFFECTED MUST BE OBT AINED BEFORE YOU ARE REQUIRED TO PRODUCE: CONSUMER OR EMPLOYEE RECORDS. DISOBEDIENCE OF THIS SUBPOENA MAY BE PuNlSHED AS CONTEMPT BY THIS COURT. YOU WiLL ALSO BE LIABLE FOR THE SUM OF FIVE HuNDFlED DOL.LARS AND ALL DAMAGEf RESuLTlNG FROM YOUR FAILLIRE TO OBEY. Date issued: pob (,reen iTYPE OR PRINT NAMS) Form Adopled For Mendelory Use liidlclal Councll of CallTomla /S/ Rob Green iSIGNATuRE OF PERSON IS8U1NG SuBPOENA) Attorrrey for Plaintiff (TITLE) [Pyoof QT ggrvli.a sea rmetse) DEPOSITION SUEIPOENA FOR PRODUCTION OF BUSINESS RECORDS Code oT CMI Procedure 2€l20.3tO, 2020.440 Government Code 88097.1 wmiv.tourls.tta.gov iPLAINTIFF/PETITIONER: GRACE SCHMIDT and ANTHONY SCHIViIDT I i I, DEFENDANT/RESPONDENT: ARKEMA, INC., ET AL l' II CASE NUMBER: 23STCV18513 PROOF OF SERVICE FOR DEPOSITION SLIBPOENA FOR PRODUCTiON OF BuSiNESS RECORDS 1. I served this Deposition Subpoena forPmduction ofBusiness Recoms by personally delivering a copy to the person served as follows: a Person served (name): b. Address where served: c Date of delivery: d Time of delivery: e. (1) D Witness fees were paid. Amount............... $ (;) D Copying fees were paid. Amount................. $- f Fee for service.. 2. I received this subpoena for seWce m (date): 3: Person serving: a Not a registered California process server. b. California sheriff or marshal. c D Registered California process server. d. C J Employee or independent contractor of a registered California process server, B l) Exempt from registration under Business and Professions Code section 22350(b). f D Registered professional photocopier. , l) Exempt from reistration under Business and Professions section 22451. h Name, address, telephone number, and, if app(icable, county of registration and number: I declare under penalty of perjuiy under the laws of the State of California that the foregoing is true and correct. Date: (For California or marshaJ use only) I certify that the foregoing is true and correct. Date: {SIGNATURE) (SIGNATURE) SllaPa) @EV. Januay 12012) DEPOS(TION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS Page 2 Grace Sc}imidt and Anthony Schmidt vs, Arkema, Inc., et al Court Cause No,: 23STCV18513 Attachment 3 Records Pertaining to: GRACE ELIZABETH SCHMIDT DOB: 08/19/1964 CUSTODIANOF RECORDS FOR: CITYOFCUPERTINO -HUMAN RESOURCES DIVISION 10300 TORREA VENUE CUPERTmO, C4 95014 RECORDS REQUESTED: ANY AND ALL EMPLOYMENT AND PAYROLL RECORDS INCLUDING BUT NOT LIMITED TO THE EMPLOYMENT FILE 40MPENSATION RECORDS, !1:MPLOYMENT APPLICATION RE'UMES TRAINING ugcox.r.js, ATTENDANCE OR TIME RECORDS PERFORMANC EVALUATIONS INCIDENT OR ACCIDENT REPORTS, INSURANCE RECbRDS WORKERS REPORTS MEDICAL HENEFITS OR OTHER BENEFITS THAT MAY HAVE BEEN PAID OR AVAILABLE TO THE INDIVIDUAL 40IK AND RETIREMENT PLANS REPRIMANDS HH5By, 4yHBHH3oHs 7y7pHyn 7cOyHs,scoq;,,poHDy;H,,,,gv5g;usUcH MAGNETIC FORM AND ANY OTHER THING IN POSSESSIONT CUSTODY OR CONTROL OF SAID WITNESS PENT AINING TO GRACE ELIZABETH SCHMID 'i'ir.Rll'NTEN [)agpos.tyxo% SEIR !C:E Custodian Certification RECORDS PERT AINING TO: GRACE ELIZABETH SCHMIDT RECORDS REQUESTED FROM: CITY OF CUPERTINO - HUMAN RESOURCES DIVISION RECORDS REQUESTED: ANY AND ALL EMPLOYMENT AND PAYROLL RECORDS, INCLUD'JNG BUT NOT LJ)MITED TO, THE EMPLOYMENT FILE, COMPENSATION RECORDS, EMPLOYMENT APPLICATIONS, RESUMES, TRAINING RECORDS, ATTENDANCE OR TIME RECORDS, PERFORMANCE EVALUATIONS, mCIDENT OR ACCIDENT REPORTS, INSURANCE RECORDS, WORKERS AND/OR UNEMPLOYMENT COMPENSATION, LISTING OF SALARY FOR EACH YEAR, WAGE AND PAYROLL FILES, W-2 FORMS, 1099 FORMS, DISCIPLINARY RECORDS, SICK TIME REPORTS, MEmCAL BENEFITS OR OTHER BENEFITS THAT MAY HAVli: BEEN P,AID OR AVAILABLE TO THE mDffiDUAL, 401K AND RETIREMENT PLANS, REPRIMANDS, NOTICES, RESIGNATIONS, TERMmATION RECORDS, CORRESPONDENCE, EVERY SUCH RECORD, INCLUDING BUT NOT IIMITED TO, THOSE EXlSTmG IN ELECTRONIC OR MAGNETIC FORM, AND ANY OTHER THING IN POSSESSION, CUSTODY OR CONTROL OF SAID WITNESS PERT AINmG TO CERTIFICATION OF CUSTODIAN OF RECORDS "Please initial the appropriate blankAND sign tliis fi>rm below. CERTIFICATION OF RECORDS COPIED (Custodian's initials0!te0rl,1,al records aVal.labie at thl,Tlie copies of the records submitted herewith are true and accurate copies time, To the best of my knowledge, the records were made at or near the time of occurrence of the matters set fortli by, or from information transmitted by, a person with knowledge of those matters. The record was kept in the course of the regularly conducted business activity, and was made by the regularly conducted activity as a regular practice. No documents have been intentionally witlilield ii'i order to avoid their being copied. If we have only part of the records, sucli records as are available are provided. to us for identification; the described records do not exist. No copies or records are transmitted because we do not liave records. CERTIFICATION OF LOST RECORDS (Custodian's initials A thorough search has been made for the documents described in the requl based on the information provided to us for identification, no such records were found. No copies are transmitted because we do not have such records. It appears the records were lost unintentionally, and not due to bad faith. aFl";"re"c'ordXCgrIi; gFtheDrEeqsuTesRt OweYreEgsHoEyCeda""spasrt(oCfuosu1rondo'ramnalsc'onu'r'sfeal:ms and in accordance with our records retention and destruction polices. It is our policy to destroy records evei'y ears. No copies or records are transmitted because we do not have records. Records were destroyed as part of our normal business, and not due to bad faith. I understand this certification is done under penalty of making a false statement, and if I falsely ceitify, I may be subject to criminal penalties. Print Name:Dated: Signature:Phone #: Order No. 76461.003 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Brake Barnumber, end address).' Rob Green; State Bar# 216116 Siinon Greenstoiie Panatler, PC 3780 :Kllroy Airport Way, Siiite 540, Long Bench, CA 90806 TELEPHONE: (562) 590-3400 FAX NO. (Optional) A'nORNEY FOR (Name) Plnintiff FOR COURT USE ONLY NAME OF couti'r: SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREET AODRF_S8: L.os Angeles County Superkua Couri MAILING AODR5SS: }If N. Hill Sltael Lot Angeleii CA 'XH112 BRANCH NAMEi l' I PLAINTIFF/PETITONER: GRACE SCHMIDT and ANTHONY SCHMIDT DEFENDANT/RESPONDENT: ARKEMA, INC., ET AL CA8E NUMBER: 23STCV18513 NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION (Code Clv. Porc., % 1985.3, 1985,8) (RECOR[)S ONLY - NO PERSONAL APPEARANCE IS NECESSARY) NOTI(E TO CONSUMER OFI EMPLOYEE: To GRACE ELIZABETH SCHMIDT through attorney of record and all other counsel: (See List) 1. PLEASE TAKE NOTICE THAT REQUESTING PARTY: Simon Gi'eenstone Panatier, PC SEEKS YOu# RECORDS FOR EXAMINATION by the parties tO thiS aCtiOn On (SpeCif7 date): 1/22/2024 The records are described in the subpoena directed to witness (specify name and address of person or entity from whom records are sought.' CUSTODIAN OF RECORDS FOR: CITY OF CUPERTINO - HUMAN RESOURCES DIVISION' 10300 TORRE AVENUE, CUPERTINO, CA 95014 A COP!/ of the subpoena is attached. 2. IF YOU OBJECT to the production of these records, YOU MUST DO ONE OF THE FOLLOWING BEFORE THE DATE SPECIFIED. IN ITEM a. OR b. BELOW: a. If you are a party to the above-entltled action, you must file a motion pursuant to Code of CMI Procedure section i987.1 to quash or modify the subpoena and give notice of that motion to the witness and the deposition officer named In the subpoena at least five days before the date set for production of the records. b. If you are not a party to this action, you must serve on )he requesting party and on the witness, before the date set for production of the records, a written otJection that states the specific grounds on which production of such records should be prohibited. You may use the form below to object and state the grounds for your objection. You must complete the Proof of Service on the reverse side indicating whether you personally served or mailed the obJection. The obJection should not be filed with the court. WARNiNG: IF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED IN ITEM "I, YOUR RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES. 3. YOU OR YOUR ATTORNEY MAY CONTACT THE UNDERSIGNED to determine whether an agreement can be reached in Wriling tO cancel Or limit the SCOpe Of the subpoenai If nO SuCh agreement IS reaChedl and if }Ou are mat OtherWiSe represented by an attorney in this action, YOU SHOULD CONSULT AN ATTORNEY TO ADVISE YOU OF YOUR RIGHTS OF PRIVACY, Date: 12/5/2023 Rob Green iTYPE OR F'RINT NAME) /s/Rob Green lAlaNA'l'UHE u: peout:stiva PAR'rV X Ait'ORNeY) OEIJECTION BY NON-PARTY TO PRODUCTION OF RECORDS 1. 2. [1 lobjecttotheproductionofallofmyrecordsspecifiedinthesubpoena. € I object only to the production of fhe following specified records: 3. The specific grounds for my objection are as follows: Date: (TYPE OR PRINT NAME)ISIGN ATURE) [ IR(:QUE8T1NG PARTYi iATTORNEY IProoT or seivlce on revera) Form adapted For Msndalory Use Judicisl Council of Calllornla NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION (Code Clv. Proc 1985.3, 1985.6) Code of Clvil Ptocedute 982 ia)( l 5.2) Rev. Jaiiuary T, 2000 Page * of 2 niarliir H "l(srirs 1 I ':::::;,:'.:::;.:'.",::::,:a,":..",".'HONysCIlMrDT lICASE NUMB::STcv 18513 PROOF OF OF SERVICE OF NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Code Clv. Proc., §§ 1985.3,1986.6) [1 PersonalService [J Mall 1. A( the time of service I was at least 18 years of age and not a party to this legal action. 2. lservedacopyofkheNoticetoConsumerorEmployeeandObjeckionasTollows(checkeitheraorb): a. € Personal servlt,e. I personally delivered the Notice to ConsumerorEmployee and Objection as follows: (1) Name of person served: (3) Date served: (2) Mdress where served: (4) Time served: b. [J Mail. I deposited the Notice to ConsumerorEmployee and Objection In the United States mail, in a sealed envelope with postage fully prepaid. The envelope was addressed as follows: (1) Name of person served: See List (3) Date of mailing: 12/5/2023 (2) Address: See List (4) Place of mailing (city and state): (5) I am a resident of or employed in the county where the Notice to Consumer or Employee and Objecfion was mailed. c. My residence or business address is (specify): Written Deposition Service, LLC, 21021 Ventura B}vd., Ste 410, Woodland Hills, CA 91364 d. My phone number is (specify): (800) 346-4405 I declare under penalty of perjury under the laws of the Stale of California that the foregoing is true and correct. Date: I2/5/2023 RobertGlucroft ? % (Type or Print Name of Person Who Served) (Slgnature ofPerson Who served) PROOF OF SERVICE OF OBJECTION TO PRODUCTION OF RECORDS (Code Clv. Proc. § § 1985,3, 1 985.8) Personal Service Mail 1. At the time of service I was at least 18 years of age and not a party to this legal action. 2. I served a copy of the Objectlon to Production of Records as follows (cornplete either a orb).' a. ON THE REQUESTING PARTY (1) 0 Personalservice.IpersonallydeliveredtheObject/onfoProduct/onofRecomsasfollows: (i) Name of person served: (iii) Date served: (ii) Address where served: (iv) Time served: (2) 0 Mait. I deposited the Objectlon to Production of Records in the United States mail, In a sealed envelope with postage fully prepaid. The envelope was addressed as follows: (i) Name of person served: (iii) Date of mailing: (li) Address: (v) I am a resident of or employed in the county where the Objection to Pr'o2icPtiaocneo'ffr';rcao:'d's Eajf", manadilesda, fe" b. ON THE WITNESS (1 ) g Personal service. I personally delivered the Objection to Production of Records as follows: (i) Name of person served: (iii) Date served: (ii) Address where served: (iv) Time served: (2) Mail.ldeposltedtheObject;onfo/:'roducffonofRet.ordsin(heUnitedStatesmall,Inasealedenvelopewlthposiage fully prepaid. The envelope was addressed as follows: (i) Name of person served:(iii) Date of mailing: (ii) Address: (v) I am a resident of or employed In the county where the Objection to Pro('dv;jc'ffoanceofoRf %aor'J !caisfym&asilfead.'a) 3. My residence or business address Is (specify): 4. My phone number is (specify): I declare under penalty of pedury under the laws of the State of California that the foregoing is true and correct. Date: (TYPE OR PRINT NAME OF PERSON WHO 8ERVED (SIGNATURE OF PERSON WHO SERVED) SUB1'4)!I IRIII. litllll!ty 1, 200ii NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION (Code Clv. Proc I 985.3 1986.6 (lvrlr-v *l'HsAKl l Grace Schmidt andAnthony 8chmidt & Arkema, Inc., et at Court: 23STCV18513 Order#: 76461 ATTORNEYS OF RECORD Edward R Hugo Hugo Parker, LLP 240 Stockton st., sth Floor San Francisco, CA 94108 415-808-0300;Fax:415-80 8-0333 Attorney For: Defendant Farah S Nicol Polsinelli, LLP 2049 Cenhiry Park East, Ste 2900 Los Angeles, CA 90067 310-556-1801; Fax: 310-556-1802 Attorney For: Defendant Gabriel A Jackson Goldberg Segalla LLP 611 Gateway Blvd., Ste. 120 Soutli San Francisco, CA 94080 415-432-6600; Fax: Attorney For: Defendant leffrey M Goldman Troutman Pepper Hamilton Sanders ALP Two California P]aza 350 South Grand Avenue, Suite 3400 Los Angeles, CA 90071 213-928-9800; Fax: Attoriiey For: Defendant Jeremy D. Milbrodt PrindIe, Goetz, Bames & Reinholtz, LLP One World Trade Center Suite 1100 Long Beach, CA 9083 I 562-436-3946; Fax: 562-495-0564 Attorney For: Defendant Kelley S Olah Bames & Thoi'nburg LLP 2029 Century Park East, Suite 300 Los Angeles, CA 90067 310-284-3880; Fax: 310-284-3894 Attoiney For: Defendant Kendra E Bray WFBM,LLP I9900 MacArthur Blvd. Suite 1150 Irvine, CA 92612 714-634-2522; Fax: 714-634-0686 Attorney For: Defendant 76461 Kimberly L Rivera Foley & Mansfield, P.L.L.P. 187 W Huntington Drive, Suite 2]0 Monrovia, CA 91016 213-283-2100; Fax: 213-283-2101 Attorney For: Defendant Lindsay Weiss Maruiing Gross + Massenburg LLP 444 S Flower Street, Ste 4100 Los Angeles, CA 90071 213-622-7300; Fax: 213-622-7313 Attorney For: Defendant Michael L Fox Duane Morris LLP One Market Plaza Spear Tower, Ste. 2200 San Francisco, CA 94105-1127 ; Fax: Attorney For: Defendant Nicolas P. Martin Wilson, Elser, Moskowitz, Edelman & Dicker, LLP 655 Market st., Ste. 900 San Francisco, CA 94105 415-433-0990; Fax: 415-434-1370 Attorney For: Defendant RObert A Rich Gordon & Rees Scully Mansukhani, LLP 633 West Fifth Street, 52nd Floor Los Angeles, CA 90071 2]3-576-5000;Fax:2]3-680-4470 Attorney For: Defendant Ryan B Cosgrove Nelson Mullins Riley & Scarborough LLP 19191 S. Vermont Ave, Ste. 900 Tonance, CA 90502 424-221-7400; Fax: 424-221-7499 Attorney For: Defendant Shawn M Ridley Ridley Master 19000 Cj Farrell Street, Suite 280 San Mateo, CA 94403 650-365-7715; Fax: 650-364-5297 Attorney For: Defendant Tina Van Darn Manning Gross + Massenburg L.LP 400 Spectium Center Drive, Suite 1450 Irvine, CA 92618 949-892-4700; Fax: 949-892-4701 Attorney For: Defendant 76461 William L Coggshall Gordon Rees Scully Mansuk)iani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 619-696-6700; Fax: 619-696-7124 Attorney For: Defendant 76461 J ti i% I I ' COUNT\ PROCESS SERVJCE, INC. 27772 . I, 31 East Julian St. ' " SaitJose,CA95112 ' 90-78/1211 ' ' DATE "/'./ " 7 "Ph.-408-297-6070 ' @gl;l,F,C_y,g@pi i I --- :-'- -- =' o I IPAY . , I J()oRr'FhFl=nF C""l" '"i I$lr-""aa i t =--= I : ' < - 2- ' " " ' ' :pmbi' I I -= )'t > 'r . , - ..,., . . .. . . .. ' = 'DOIIARS",,. -' :>l t : . . " " , ' ." . ' " " - = ' " =: ' :-T--i' ' BANKAWEST " " ' . ' 51, 0 " . II a ' " " " ' "' =. . i BNP PARIBAS . .' "' : l " - '-.- " o _" . 'f' ".1 !l' R)E'l" " ' " ' " - "" ": ' -___' _ _' __ ' "" ': : ' a' "' ' =Q ..'l i 1,ii'.O??":??iii i:'k?kk0[J'?8?i: €.i35.lig5??iii = l' "'