PROCUREMENT OFFICER (IN BUDGET) �Roe�ucen.a✓tre�'c.el�, as )
f
a
Agawam tt
Office of the Mayor'
36 Main Street,Agawam, MA 01001
mayor@agawam.ma.us
Richard A Gahm Tel: 413-78&4S20
Mayor Fax:413-786-9927
18 May 2015
Dear Council:
I am providing you with this additional back-up information for the delegation n of a
Procurement Officer for the Town of Agawam. Per your suggestion, I have included funding for
compensation of these additional duties and responsibilities to the position occupied by the only
M.C. .P.O. certified Town employee-
I have reached an agreement with the relevant Union along with an agreed amount of
compensation as referenced in the attached Memorandum of Understanding.
Sincerely,
4ztll 44
Richard A.Cohen Mayor
a
MEMORANDUM OF UNDERSTANDING
BY AND BETWEEN THE TOWN OF AGAWAM
AND THE AGAWAM ADMINISTRATIVE ASSOCIATION
The Town of Agawam (hereinafter referred to as "Town") and the Agawam
Administrative Association (hereinafter referred to as"Association")hereby agree to the
following terms, conditions, and understandings.
1. The Town and Association are parties to a collective bargaining agreement,
1 The Town will designate an existing M,C.C.P.O. certified town employee to perform the
function of Chief Procurement Officer to be effective July 1, 2015.
1 The Town and Association agree that the function of Chief Procurement Officer shall be
covered by the parties' collective bargaining agreement.
4. The hourly rate while performing the function of Chief Procurement Officer shall be
based upon the Tier IV, Step I annual salary, which is currently $52,971.
S. The Community Preservation Act Administrator position shall be included in the
bargaining unit effective July 1, 2015. '
6. This Memorandum of Understanding is not precedent setting for any same or similar
circumstance in the future.
7. There are no other agreements, either verbal or written,between the parties to this
Memorandum of Understanding,
FOR THE TOWN OF AGAWAM FOR THE AGAWAM ADMINISTRATIVE
ASSOCIATION
Richard Cohen, Mayor Christopher . Golba, Vice President
S
Dated: Dated:
April 21, 201
To Agawam City Council
From.Councilor James Cichetti
Re; Procurement Officer Position
The Legislative Committee, after much discussion concerning this position and as suggested by Councilor
Robert Rossi and other councilors,have determined that the item should be funded in the fiscal 2015
2016 budget by the Mayor. The Council should consider this submission during budget deliberations.
While the Council cannot create a position via the budget the council can provide funding, This funding
would allow the Mayor to designate an employee to perform the functions of a Procurement Officer and
provide for the necessary funds to conduct negotiations with the appropriate bargaining unit for the
additional responsibilities the individual would perform. 'Therefore,as the Chair of the Committee l'
desire to remove TOR-2015-5 from the agenda and would like to see the Mayor include funding in the;
proposed FY 16 budget,
CHAPTER 2
Supply and Service Contracts: Getting Started
Chapter 30B establishes general procedures you must follow when awarding supply
and service contracts, Your own local jurisdiction is responsible for developing the
details of its own purchasing system by
deciding, for example, what forms must be Loddl rules may dictate more. rigbrous
44F 7
used, who has to approve purchases, and
exempt conifiew For .e' amplek,,,if,-Iyo'ur
who may make purchases. Also, your local
req'oW'4 fbrmaI'a�I --vdrt1sed de'M' on on,
w bylas or ordinances may establish Petri
co*(fts over $iO' A'00', You must comply
additional rules governing purchasing that tenth the local-rule If you have any,questions
abodt,-th'0�.ex1stqnq-- or..ap'
you must follow even where they are more
rules,' ,qon ac t t� your-.Grief.,
stringent than Chapter-30B. This chapter 'Ci gal 16 n".:.
, ,cqt� -
briefly considers topics relating to your local organization and then examines some first
steps to take in preparing for a procurement of supplies or services under Chapter 30B.
Chief Procurement Officer
A local jurisdiction that wishes to use Chapter 3013's request for proposals process to
procure supplies or services must appoint a Chief Procurement Officer (CPO) to
oversee the procurement of all supplies and services.
The CPO is responsible for all activities related to buying, leasing, renting or otherwise
acquiring supplies and services for all departments regardless of the contract value.28
This responsibility includes overseeing the solicitation; evaluating quotes, bids and
proposals, and awarding contracts. The CPO ensures that the local jurisdiction's
contracting practices are carried out in accordance with state law and local
requirements, Centralization of purchasing under a CPO can result in greater
efficiency, improved quality of supplies and services, and cost savings.
"' M.G.L. c. 30B, § 2.
29 Note, however, that the CPO may not have legal authority to exercise other powers,
such as final approval of budgets or contracts, that may be vested by statute or local
rules in other officials,
11 t- UU11q
2. TE-2015=4 Election of a member of the Community Preservation Act
Committee to a term expiring April 30,2018
The name of Raymond Moreau was placed into nomination by Councilor Bitzas and seconded by
Councilor 'Mineo' No other name was nominated. Councilor Rheault moved, to close
nominations which was seconded by Councilor Rossi.
The vote was 9 YES,0 NO, 2 ABSENT(Councilors Calabrese and Letellier) for Raymond'
Moreau.
Council President Johnson also thanked him for his continued service to the town'.
Item 9. Public Hearings
None.
Item 10. Old Business
1. TOR-2015-4 An Ordinance to Amend the Code of the Town of Agawam by
adding Chapter 178 Fingerprint-based Criminal Record Background Checks'
(Mayor)(2 of 2;readings)(Tabled 4/6115)(Referred to Legislative Committee)
Motion to remove the item from the table made by Councilor Cavallo and seconded by Councilor
Cichetti. Councilor Cichetti provided an updated report from the Legislative Committee stating
the Police Chief Gillis further explained the difference between CORI checks and fingerprint
checks widi respect to the National Database. 'Motion to approve the second and final reading of
this item was made by Councilor Rossi and seconded by Councilors Cichetti and Cavallo.
Discussion began with Councilor Rossi questioning the fee portion of this ordinance believing
$100 is way too high and should be reduced. Vendors need to be re-fingerprinted every year
because prints are not retained if there are no findings. Councilor Rossi made the Motion to
reduce the fee to$75 ($35 for the fingerprint fee and $45 for the General Reserve)and seconded
by Councilor Rheault. The vote was 9 YES,0 NO,2 ABSENT(Councilors Calabrese and
Letellier)passing the amended(six votes were required). Council'President stated that this item
was placed on the Agenda without supporting documentation. It shouldn't be up to the City
Council to have to pull information out of the Administration.
Motion to approve the second and final reading as amended was approved with a vote of 9 YES,
0 NO,2 ABSENT(Councilors Calabrese and Letellier)(eight votes were required)
2; TOR-2015-5 An Ordinance creating the position of Chief Procurement Officer
as required by Massachusetts General Law (Counciloms Cichetti, Suffriti, Mineo,
Bitzas and Cavallo)(l of 2.Readings)(Referred to Legislative Committee)
Motion to approve was made by Councilor Bitzas and seconded by Councilor Cichetti. Councilor
Cichetti as Chair provided a Legislative Committee report stating that his committee would like
to see this position do both the town and school side of the procurement;and he personally placed
this on the Agenda because he was trying to work with the Administration to do what's best for
the town. The Legislative Committee gave no recommendation on the item. Discussion started
with Councilor Rossi stating the draft was weak and extremely vague and hoped for more details
on the guidelines to follow. He was not opposed per se to this position but the administration
must get their ducks in a row first. Councilor Bitzas and Councilor Rheault said they'd like to see
the Mayor put it in the budget instead. Councilor Cichetti stated he was just trying to move;
things forward. He read the following letter into record;
3
The Legislative Committee,after much discussion concerning this position and as suggested by Councilor
Robert Rossi and other councilors,have determined that the item should be funded in the fiscal 2015-
2016 budget by the Mayor, The Council should consider this submission during budget deliberations.
While the Council cannot create a position via the budget the council can provide funding. This funding
would allow the Mayor to designate an employee to perform the functions of a Procurement Officer and
provide for the necessary funds to conduct negotiations with the appropriate bargaining unit for the
additional responsibilities the individual would perform. Therefore,as the Chair of the Committee I
desire to remove TOR-2015-5 from the agenda and would like to see the Mayor include funding in the
proposed FY 16 budget.
Motion to remove the item from the Agenda was made by Councilor Cichetti. He then withdrew
his motion so other councilors could speak. Councilor Rossi stated he has no problem with them
creating this position. Councilor Mineo, as a sponsor, thought it was a good idea and most cities
and towns have a procurement officer, Councilor Cavallo said it was unfortunate that this
discussion has gone on far too long and just put It in the budget. Council President Johnson
stepped from the Chair to say he thought it was a waste of time. If the Mayor wanted it, it should
go to the unions, set a salary and then come to the Council with a proposal. CPO only deals with
contracts $25,000 and up and there aren't many to his knowledge. If there isn't a CPO in town, it
is because the Mayor has not designated one. When Chris was mayor, he designated himself so
the town was in compliance. If they want this position, then the Mayor should get the
information and make his case. Councilor Rhexult asked why would we go forward with this,
The Department Heads are paid very well and should be doing this themselves. If the Mayor
wants this then he should have sponsored it himself. He fw1s, it's a big waste of money and is
building a bureaucracy. Councilor Bit thanked Councilor Cichetti for doing all of the work on
this item. He would second his Motion to withdraw and also mentioned that there is probably a
lot of money in the town that was lost because we do not have this position,
Motion to withdraw the it made by Councilor Cichetti and seconded by Councilor Bitzas, The
vote was 6 YES (Councilors Biwas, Cavallo, Cichetti, Minco, Perry and SulTriti), 3 NO
(Councilors Johnson, Rheault and Rossi) and 2 ABSENT (Councilors Calabrese and
Utelfier). The item was withdrawn.
Item If. Nov Business
1. TO-2015-16 - Budgetary Transfer from Building Maintenance Regular
Permanent(#11921-5 10 10)of$10,900.00 to BuildingMaintenance
Overtime(#1 192t-51030) for additional funds to cover unanticipated shortage due to
two unfilled positions.(Mayor)
Next Agenda; referred to Finance Committee.
2. TO-2015- 17 - An Order granting or renewing an Autornatic Amusement
PERMIT for Six Flags New England, 1623 Main Street,Agawam,MA. (Clerk)
Next Agenda; referred to Administrative Committee.
3. TO-2015-18 - Budgetary Transfer of$30,000.00 from Police Regular Permanent
Account(#12101-51010) to Police Overtime Account(#1210151030)(Mayor)
Next Agenda-,referred to Finance Committee.
4. TO-2015-19 - Budgetary Transfer of$30,000.00 from Police Court Time Account
(#1210151080)to Police Overtime Account(#12101-51030)(Mayor)
Next Agenda; referred to Finance Committee.
4
CRCAC AT'0"1 AND 1111�11 COINCII M11T11 go 5 (C�_�on t
6 T�R 6
ROLL CALL - 11 YES.
President Brindle - 11 yes , no nay's you have passed TR-90-56.
item 6.2 TR-90-57-Resolution-Pursuant to Massachusetts General Laws, Chapter 308, Section;
12(b) Authorizing the Chief Procurement Officer to Solicit and Award any and all
ipee. Contracts for Any Term Not to exceed Five (5) Years (Mayor) .
ray President Brindle What is the council 's pleasure?
is Councilor Bitzas Move to accept it.
tul d
President Brindle Moved to accept by Councilor Bitzas. Do I hear a second? Seconded
by Councilor Dziardziel . Any discussion?
Counc i'or &a Mr. Chairman, you alluded to the fact that we did receive an opinion
icitor
fmp the so icitor and again I am a little disappointed. Yes, we did in fact receive the
opinion. However, its very vague, its not precise enough for me to vote in favor of this
resolution tonight. In response to my inquiry about who the procurement officer was in
fact the solicitor responded by in paragraph 2 under the laws of the Commonwealth of Massa-
cbusetts, the mayor is designated as the chief procurement officer of the Town of Agawam.
If you have any further questions,. please contact me before the meeting at my office. I
q don't like to bother the solicitor at his private office. My job is such that I cannot get
in touch with trim at all times and I think that in his opinion he should cite the general
laws by Chapter and Sections as well . Because this is a fairly new situation, well its been
se in on the books for a long time but its been dressed up and I just want to know, looking
at some of the citations, all I have been able to find out is that the chief procurement
pfficer could be a purchasing agent. I don't know whether we have anything on file that is
ndicative of the fact that out mayor is the purchasing agent or not and therefore I would
like to hoid off action on this. Not only for that reason but I think when we are going
along, with the extension going from a three year contract to extending it to five years,
( think looking at the economy the way it is, it could come back and haunt us a little bit
ItAink. I think that 3 years is enough. Because we had a couple of situations here, well
t+e pumping station, I won't forget. I suggested that may be we ought to reject all of our
were bids and readvertise because of the slowness of the working situation with the labor forces
ked in the Commonwealth and I thought may be if we reject it we probably would have gotten a
I lower bid and by the same token I think if we go shut ourselves into a five year contract
hat w4th no reversion clause I think we might end up on the short end of the stick at some time.
her Mat's all I have to say and I would hope the council choses to at least table this until
we get something precise, you know under what general laws or what section of the charter
makes the mayor the procurement officer. Thank you.
Councilor Ennis Mr. Chairman, through the chair to Councilor Caba. Is that a motion?
Councilor Gaga Yes it is.
ands !
Councilor Ennis A tabling motion?
Councilor Caba, Yes.
Councilor Ennis Second.
President Brindle - Motion made to table TR-90-57 by Councilor Cab a, seconded by
iCouncilor Ennis. Any discussion? Hearing no discussion will the clerk call the roll please
On the tabling motion.
ROLL CALL - 6 YES, 5 NO (Coon. Bitzas, Brindle, Dziardziel , Fuller, Willis).
A
. TOWN OF AGAWAM
`4 Tel. 41 -r -04
E
TO EDWARD A . CABA, COUNCILLOR;
FROM LAW DEPARTMENT
RE . PROCUREMENT OFFICER
DATE JANUARY 17 , 1991
Massachusetts General Law, c . 30B , s . 2 defines the "Chief'
Procurement Officer" as follows
"Chief Procurement Officer" . the purchasing agent appointed
pursuant to section one hundred and three of chapter forty-one,
or as to any city or town which has not accepted said section.
an individual duly appointed in a city having a city manager,
by the city manager, in a town having a town manager, by the
torn manager, in any other town, by the selectmen, or in any
cit.y or town otherwise providing by charter or local k -law for
the appointment of a chief Rrocurement officer, in accordance
with such charter or local by-law, to procure all -supplies and.
services for the city or town and every governmental body
thereof; an individual duty appointed in a district by the
prudential committee, if any, otherwise the commissioners to
procure all supplies and services for the district: an
individual duly appointed in a regional school district by the
regional school district committee to procure all supplies and
services for the regional school district, an individual duly
appointed in a county having a county executive , by the county
executive, or in any other county, by the commission, to
procure all supplies and services for the county and every
governmental body thereof. "
A review of the state statute accepted or adopted by Agawam does
not indicate that Agawam accepted MGL, c. 41, s. 103, which such
acceptance would have established a purchasing department with a
purchasing agent. since Agawam does not have a purchasing agent as
set forth in c. 41 s. 103 one must look to the Charter for the
appointment or designation of a chief procurement officer. The
Charter, as amended, Section -2 states that "The executive powers of
the town shall be vested solely in the Mayor, and may be exercised by
him either personally or through the several, town agencies under ;his
general supervision and control . "
Edward A. Caba , Councillor January 17 , 1991
Page Two
The Mayor is vested with the executive: and administrative
affairs of the town . The executive or administrative affairs of the
town include the procurement and purchasing of all supplies and
services for the City of Agawam.
Respectfully submitted-,
S . Locke
Solicitor
CC; City Council
Mayor
L "'m
Chief Procurement Officer's Delegation
of Procurement Powers and Duties
(Type or print legibly)
Original Delegation Amendment Revocation
. Pursuant to the provisions of'M.G.L. c. 30B, § 19, I rC466
(print full narne)
am the CPO for and hereby delegate the
ruction)
procurement powers and duties set forth below to
Job Title/Position: _ C-21A.
Department: 60-07owme A 6`.s&" '(41
Current Employee;
Employee Email: 1`461ON IL141
E hereby delegate the following M.G.L.c.308 powers and duties to the procurements specified
herein
solicit Open Evaluate
Award Reject Cancel Exercise options;
® Increase quantities Maintain records D All of the above
Other(specify in an attachment)
4. This delegation pertains to procurements:
for the following department(s) ✓ Z
[� for the following contract(s):
Bather(specify in an attachment);
Pagel I CPO Delegation Form (May 2 1 )
Section 4 (Continued) This delegation pertains to procurements involving;
Supplies services Statute
M.G.L.c, 306,§4(c)(sound business practices;)
M.G.L.c, 30B, §4(a) (price quotations)
M.G.L.c.30B,§S using bids
M.G.L.c. 30B,§ 6 using proposals
Emergencies
Other(specify in attachment)
5. This delegation is conditioned upon compliance with M.G.L. c. 3013, all applicable statutes,
rubs, regulations, charters, ordinances or bylaws, and subject to the following additional
requirements;
Final approval of award b°Chief ProcurementOffic
Approval of all documents by Chief Procurement Officer prior to issuance
Designation as a Massachusetts Certified Public Purchasing Official (MCPPO):
Designation as an MCPPO for Supplies and Services
0 Designation as an MCPPO for Design and Construction
ED Other Designation Certification(specify in attachment)
Completion of the following MCPPO course(s):
Public Contracting Overview Bidding Basics&;Contract Administration
Q Supplies and Services Contracting Bidding for Better Results
F) Design&Construction Contracting Model IFB Course
❑, Construction Management at Risk 0 Advanced Topics Update
Other' (specify in an attachment)'
} Other requirements(specify in an attachment)
Page k2 CPO Delegation Farm (May 2015)
b. The CPO delegation is valid for the current employee only. The CPO Dele ation is for a.
limited, onetime procurement.The delegation shall expire on:
(expiration date
7. 1 certify, under wins and penalties of perjury, that the above information is true and that I
am the Chief Procurement Officer of: 6&jL6M MAZAC
" JF turisdiction)
Signed: hate, / ! &57
Name: Af
Jul �"lq ? r
Title (CPO)-
Department:
�
department,
Office Address A / /" 7 EC '
Office Address (2), A GA W d M PIMA Zip Code. C , 0 6
Office Telephone: y1a - PZA A
CPC Email;
CPO has MCPPO Resignation or Certification. D4 yes No
g. Send a copy of this form to
Office of the Inspector General
Attention. CPO Delegation
One Ashburton Place, Boom 111
Boston, MA 0 1 g-151
No delegation,amendment or revocation shall take effect until a copy of the form is received
by the Office of the Inspector General.
Page 13 CPO Delegation Form (May 2015
T1 ly CollilllollWealtl) of 1t1�6dr1)ll6ett5
ff re of On Inspector Otneral
John W. tulcormat«It
State Office Building
One Ashburton place
Room 1311
GLENN A.CUNHA Boston, MA 02106
Tel° (617)727.9140
INSPECTOR GENERAL Fax: (617)723- 334
September 23, 2014
Dear Ms.:Bonfi lio:
1 am pleased to inform you that you have successfully completed the Public Contracting Overview
seminar presented on September 9-11, 2014, Boston, AM, in the Massachusetts Certified Public
Purchasing Official (M PP program. Enclosed is your certificate.
The M PPO program has been designed to promote
• cost-effective, ethical, and modem purchasing practices;
4 dialogue and exchange of ideas and best practices among procurement officials;
a stewardship of resources in the,pubfies interest;and
• compliance with Massachusetts contracting laws.
Your participation in the program and success in meeting the requirements for certification
demonstrate your commitment to these objectives.
The MCPPCI seminars have been designed to meet national standards of recognition. Ile program is
registered with the National Association of State Boards of Accountancy as a,sponsor of continuing
professional education to offer CPI- credit. In addition, school business officials can qualify for
P°ro&ssional Development Points required under the state's Education Reform Act. As noted on your
certificate, you have earned 20 CPE credits and have qualified for 20 PDPs by completing the Public
Contracting Overview seminar. If you have taken*this course for re-certification credits or as a
refresher,you have earned 17 CPE credit_and have qualified for 17 PDPs
As you know, if you successfully complete an additional specialized certification seminar, you may
apply for an MCPP4 designation;
Congratulations on your achievement!
Sincerely;,
;�401 l&Vlni-1
Joyce McEntee Emmett
Director
iVlt PPOProgram
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d,.'<iwahii.da.a, and iia,i,.s'da,iia paai'a.iaaa„,'d ing p aa'�ti4.csw
d ialogn ie aaaaia exchaunge of id,s as andbest pni<a,aices aann4 nas
cail ijal:i incc alkali .aassaaa.aaaaaassS aiia aaiiaa.,aai ismµ, laws,
Your 3,ha i s aa,3 'ia aiai h in aaia aaa`a .aTa tll and sua<.a+aaadad aa;f' rneeung thte, requiur'na;"raaaa ,fio
demonstnate Iv,,oua.,'a taaaan aaa.;a ent ici t h aaa a ? ,vfives,
he MCPF"O a mdaiaaiia have c,,, desig
gned to maaa.a aiaaaadaii l standards, of aaaao a' a *d i i�dsis ;iahi'h'i hi"kaa�h k pia i asis
registered aa ith 'he Natiorial aadiaiiioa of Staaa aai&`a of aaiaa'aae aN as a �a�aiaasauaa aii a.".a,"aaiaaihaiiaa�`
aaaa amsk'naail education, to ai d"a i (IFI credit, .In, ziddition. as !'maaa bu ine's r a> a.ia`aaa caaia >quidif"a fi"I'r
Prof\ '"+siaiaasa„ DSaa"aw"laa'��"�amen xPoints aayspired unde'r al l'` i a e s Education Ra='atix is a' a, As armt d on yow
camaaifia aate, aaaiada lizave ayaamed 0 a,,a�a credits wad have tuof hi i i � 2�i a.�a,.)ii i >F m a" aa�aa al aaa ai ��. ,� i�aa �aa a;aai"taiaa'daia� i,a.a~. i�a„aaaLaa'
a i:aiaii.aa iron .,xverv"ia aar asau aaaiaiaai,. f you Inuih as taken, this course b r .,a:' a'"ai catia,aia?n aa'�a it �i8 li s is
a.efir ,.. her, y�diaa,a have av e(aa;a.iaaed 17 CPE' a,arexilia i:"iaaid have qualified aic a P )Ps
s you, i'has'ka aa` .,aou "si,i,,c .e s;srf'iaala C(:)T1,h.,�-a.ia,°ac ai., iddah 'a'oh'" E,i a`4.i'a4;.:a.,xas'd,?a`";aiu,.d ce.aa"ui ian..aaia x.. ia"i a', "ae�C'aat ias`d'a�,
?h ahh'iaaai>aaiaa� ;taaaa� ,.a"aa �a¢aaa a,as �taa'^a°�ih,a�a`i�'
Sincerely, '
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r..ammum(ty 3 rf,',sS rva icn a.t..aa'a"Ia1= yd,e gave At to sr,-t d Ms, Ba , r t o t#a;' 01a li..akt
and she is Certified d'ff„a`aa.s.t,4..a.'a=ena >frk-,d,"a"
x he t..,3krks, „'°52,9 1 .i alx,ary fc,,,r the M$,,.ui.'%Ymer;`.'{.. Ciifir<.ek t sh m !p 3, the Personnel es Page
of the ,rhtdminis aaa'Sass"e w. .3 k�la$d} a� }. gs . "n order o cwo 3c.e t ; 3an,' is to t
Of this, approximately � ris t ��y� 4 , a ,. . the Water
tt,`,,��yy e�Laod�.n,P C, k&t:� E„'+5., + ... dxk4lb.i`0.uM1��..�.� �a� a,3S< i. � and L,L�A,.3$�.9�L1.:A�..r DivK_Y1i.is 4q4:
k,'2 .,"0()t0 ,`e.jch)since the mx'1jo€'[ty of tiitt''rnajor;PLUch;'sses involv(,'� those two divisioto It is
,'t(aai dp a3:E.d that the Pip�,.c,�sff u��as�'`da E. dsffi app spend * t 3 s s
Officer�,: maz,� „s> t.. t� ".a�..y.I�._�aa..,aff�a.,�`ar 7256 of her We (25 Wa`s"
"�,s`.'=d..', t,rt..°4..'s...` an a>=aa.?s urti;;smerY: The rwnander of her We 11 0:War Was a„pdi %w ek) a''s'`H remain st s..inh,`'d.sd
y'ais= the *...s�,?aa'p7unity` epee', w',ithon .a'.s'srn aw, alas,",`
Tims Gk'' aFwaat; fu'3 f..H 2 s..r,,;"03a Of the a..;P0 Ux"xl'l not aaxa,ei.'i„'s e 1 of it id and should b4' `yiei§ b3sssa`1`at that,
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