Court File and Parties

Court Files: CV-13-480099 and CV-13-480001 MOTION HEARD: 2019-02-06 REASONS RELEASED: 2019-05-02 SUPERIOR COURT OF JUSTICE – ONTARIO

BETWEEN:

CAITLYN ALEXANDRA PRICE Plaintiff

and

MIROSLAY DELAC, SINISA FILIPOVIC, AVISCAR INC. Defendants

and

CERTAS DIRECT INSURANCE COMPANY (a subsidiary of DESJARDINS GENERAL INSURANCE GROUP INC.) Third Party

BEFORE: MASTER D. E. SHORT

COUNSEL: Brigette Morrison, for the defendant, Aviscar Inc. Shanti Barclay, for the defendant Filipovic

RELEASED: May 2, 2019

Reasons for Decision re costs following Offer to Settle

49.02 (1) A party to a proceeding may serve on any other party an offer to settle any one or more of the claims in the proceeding on the terms specified in the offer to settle (Form 49A).

I. Overview

[1] Miroslav Delac, came to Toronto from Bulgaria for a visit in the summer of 2011. On May 7, 2011 he went with his brother-in-law Sinisa Filipovic to rent a car from the moving party, Aviscar Inc. That rental ultimately gave rise to a series of legal problems that were only recently resolved.

[2] On May 7, 2011, Filipovic entered into a contract with Aviscar. He signed and paid for a two day rental of a Grey Chevrolet Malibu with his own personal credit card. At the rental counter, he was advised that his brother-in-law, Miroslav Delac, could not rent the vehicle because he did not have a valid credit card. As a consequence the vehicle was rented by Filipovic but Delac was identified as an authorized driver on the contract. The rental was for "personal" rather than "business" purposes.

[3] The present matter involves a dispute between various automobile insurers with respect to the Bill 18 priority of insurance responsibility, pursuant to section 277(1.1) of the Insurance Act, as well as the entitlement to costs of the various proceedings and motions as between the rental company, Aviscar, the renter/lessee, Sinisa Filipovic, and his insurer, Certas Direct Insurance Company ("Certas Direct").

[4] At all material times, Filipovic was a named insured on a valid motor vehicle liability policy (relating to the vehicle he personally owned) through Certas Direct. That policy had third party liability limits of $2,000,000.00, with there has been no indication throughout this litigation of any coverage issues vis-a-vis Mr. Filipovic.

II. The Accident

[5] Contrary to the terms of the rental contract, the Grey Chevrolet Malibu was not returned to Aviscar by May 9, 2011. Then on May 10, 2011, Miroslav Delac was operating the rental vehicle in the westbound lanes of the Gardiner Expressway near Kipling Avenue, when he caused a serious multi-car collision.

[6] Miroslav Delac was convicted of dangerous operation of a motor vehicle causing bodily harm pursuant to the Criminal Code. That conviction was upheld on appeal and Miroslav Delac was subsequently deported. (Her Majesty The Queen v. Miroslav Delac, 2014 ONSC 6619)

[7] Two tort actions were commenced as a result of this accident in May, 2013. One action on behalf of Caitlyn Price (the "Price action") and one on behalf of Lara Totayo ("the Totayo action"). The original Statement of Claim in the Price action included a liability claim against the renter, Sinisa Filipovic, and such was added by way of amendment to the Totayo action on February 25, 2014. These reasons impact the Totayo action which has file number and will therefore also be filed in action CV-13-480001.

[8] With regard to the appropriate insurer that ought to respond to these claims Aviscar’s factum asserts:

Aviscar submits that it was solely due to Certas Direct's improper and ongoing refusal to accept priority for the Plaintiffs' claims in accordance with section 267.12 and 277(1.1) of the Insurance Act, section 3.3.5 of the OAP1, as well as the leading case on priority, Intact Insurance Co. of Canada v. American Home, as well as Certas Direct's insistence in keeping Aviscar in this action based on duplicative and meritless claims of misrepresentation and breach of contract (as outlined below), that Aviscar had to incur significant costs over the past 5 years litigating Crossclaims and Third Party Claims in the two tort proceedings, as well as a 2 ½ year trial in Small Claims Court between February 3, 2016 to August 15, 2018. [sic -my emphasis]]

[9] Aviscar submits that:

In accordance with the Supplementary Reasons in [Smith v. Smith 2012 ONSC 5872 and 7152]…given the non-exposure of Aviscar and its insurer throughout this litigation, Aviscar is entitled to its costs of all of the tort proceedings against Certas Direct and/or Sinisa Filipovic, as well as its costs of the within motions and the abandoned motion by Sinisa Filipovic to reinstate his duplicative Crossclaim in the Price action (including the contested adjournment hearing before Master Short on November 19, 2018).

[10] Although there were administrative dismissals that appeared to have been inappropriate along the way, I am satisfied that the fact that the Registrar dismissed both tort actions, with deemed dismissals of the Crossclaims and Third Party Claims, should not relieve Certas Direct and/or. Sinisa Filipovic of any obligations to pay Aviscar's costs in these proceedings, particularly given Sinisa Filipovic's consent to the reinstatement of the Totayo action and the submissions on behalf of Sinisa Filipovic in support of his· abandoned motion to reinstate his Crossclaim in the Price action.

III. Relief sought

[11] When the motion before me was launched there were a number of outstanding issues. Most of those have been resolved and what remains is a determination of the entitlement to costs and the quantum thereof by virtue of an offer to settle made by Aviscar at a very early stage.

[12] Accordingly, I must address the following items claimed by Aviscar which continue to be outstanding. Aviscar seeks the following relief on the pending motions:

i) An Order that all claims and Crossclaims in the Price action and Totayo action (to the extent reinstated) be dismissed against Aviscar with costs of these proceedings fixed on a partial indemnity basis from February 20, 2014 to June 4, 2014, and on a substantial indemnity basis from June 4, 2014. to present, and made payable by Certas Direct and/or Sinisa Filiopovic to "Aviscar Inc." on a forthwith basis;

ii) An Order that the costs of the Price and Totayo Third Party Claims be fixed on a· partial indemnity basis from February 20, 2014, and on a substantial indemnity basis from June 4, 2014 to present, and made payable by Certas Direct to "Aviscar Inc." on a forthwith basis;

iii.) An Order that the costs of Sinisa Filipovic's abandoned motion seeking to reinstate his Crossclaim in the Price action (including the contested adjournment hearing before Master Short on November 19, 2018) be fixed on a substantial indemnity basis, and made payable by Certas Direct and/or Sinisa Filipovic to "Aviscar Inc." on a forthwith basis; ·

iv) An Order that the costs of the pending Aviscar's motions be fixed (in part on a substantial basis with respect to issues which should have been settled or agreed upon), and made payable by Certas Direct and/or Sinisa Filipovic to "Aviscar Inc." on a forthwith basis.

[13] The procedural elements having been resolved, I now must address issues of entitlement and quantum.

IV. Case History

[14] On or about July 19, 2013, Certas Direct was first advised of the priority issue in this matter, by copy of correspondence from Brigette Morrison to Plaintiff's counsel in the Price and Totayo actions, advising that

"These actions are governed by the Bill 18 priorities set out in section 277(1.1) of the Insurance Act. At the time of this loss, the renter, Sinisa Filipovic was insured pursuant to Certas Direct Insurance Policy No. D1729304. Accordingly such policy is primary to respond to all claims arising from the subject motor vehicle accident on May 10, 2011”

[15] Accordingly, counsel was advised that Sinisa Filipovic needed to be added as a Defendant to the Totayo action, and the Statements of Claim should also be amended to properly refer to the rental company as “Aviscar Inc.”.

[16] David Zarek (counsel appointed by Certas Direct) was confirmed as counsel for Sinisa Filipovic on February 12, 2014. Pursuant to subsequent e-mails exchanged between counsel at that time, Mr. Zarek's office sought to raise doubt as to whether Sinisa Filipovic on the basis that he provided “funding only” for the rental vehicle and would not be driving the vehicle. They also sought to rely upon apparent representations made by the Aviscar employee to Sinisa Filipovic at the time of the transaction. Aviscar’s counsel provided a copy of the Rental Agreement confirming that it was signed and paid. for by Sinisa Filipovic,· as well as a copy of the leading case on priority, Intact Insurance Co. of Canada v. American Home, 2013 ONSC 2372; 2013 CarswellOnt 4991 stating, in part,

“... I understand that your intention is to try to argue that Sinisa Filipovic was not the "de facto" lessee of the rental vehicle in question. As noted in Intact Insurance Co. · of. Canada v. American Home Assurance... specifically paragraphs 17 and 18 of that decision, the court rejected the introduction of the concept of "de facto lessee" into the s.277(1.1) analysis. Sinisa Filipovic signed the Rental Agreement, not the operator, Miroslay Oelac, The privity of contract is between Aviscar Inc.MITH Car Rental ULC and Sinisa Filipovic, and therefore Sinisa Filipovic is the "lessee" for the purpose of the Bill 18· priorities. According to Intact, the court will not go into a detailed factual analysis as to the circumstances surrounding the rental or the manner [of] payment of same, For your information, I have provided further copies of the rental documentation, confirming the contractual relationship between our client and Sinise Filipovic as "lessee".

Though irrelevant to the issue of priority, as previously indicated, Sinisa Filipovic only accepted LOW which is not insurance .... Of course, this is all irrelevant as a party cannot "contract" out of its statutory obligations.

We look forward to your confirmation that Sinisa Filipovic's automobile policy is primary to respond to all claims arising from this accident in accordance with section 277(1.1) of the Insurance Act with respect to the liability arising from section 192(6) of the Highway Traffic Act with confirmation as to the third party liability limits available under such policy.

If our client is kept unnecessarily in this action, I anticipate that I will likely be instructed to bring a summary judgment motion, and seek costs in that regard from any party which makes such steps necessary .” [my emphasis]

[17] On March 21, 2014 and April 10, 2014, as there was no further response from Zarek's office, all parties were served with Demands for Particulars, Requests to Admit and Offers to Settle on behalf of Aviscar, which contemplated a dismissal of all claims or Crossclaims against Aviscar on a "without costs" basis for 30 days, "with costs" to be agreed upon or assessed thereafter.

[18] I am satisfied that there is absolutely no indication of any mechanical defect in the rental vehicle which caused or contributed to the subject motor vehicle accident. I accept as well the submission on behalf of Aviscar that, given the statutory cap for rental companies pursuant to section 267.12 of the Insurance Act, there will be no recourse to the automobile policy issued to Aviscar and therefore the ongoing involvement of said Defendant is not necessary or proportionate.

[19] There was no response to the Demand for Particulars with respect to the allegations of mechanical defect. With respect to priority, David Zarek's office provided formal admissions that Sinisa Filipovic had a standard OAP1 with $2,000,000.00 in third party liability limits at the time of this loss, but refused to admit there will be no recourse to the motor vehicle liability policy issued to Aviscar Inc. beyond the coverage available to Sinisa Filipovic through the Certas Direct policy, Accordingly, counsel communicated the position of Aviscar by correspondence dated May 13, 2014 that if Certas Direct did not accept priority for this loss by that date, her office would proceed to defend both actions and commence a Third Party Claim against Certas · Direct, with increased costs being sought with respect to the failure or refusal to admit facts that ought to have been admitted pursuant to the Requests to Admit.

[20] I note as well the content of further correspondence from Ms. Morrison dated September 9, 2014 to David Zarek's office:

“We are in the process of gathering documentation related to the collections proceeding and the Small Claims Court proceeding commenced in terms of the property damage .... You have chosen (inappropriately) to raise and "import" the issues from those proceedings into a Bill 18 priority dispute in a tort claim (contrary to the decision in Intact Insurance Co. of Canada v. American Home Assurance Co. of Canada ... , and you have chosen to rely upon numerous "contested issues of fact". By doing so, you have unnecessarily complicated this proceeding. Given the overlap of issues and fact, I expect that the Small Claims Court proceeding will have to be transferred to Ontario Superior Court of Justice, and amendments to pleadings will be required with respect to the property damage claim.”

V. The Small Claims Court Action

[21] Counsel for Aviscar asserts that after initially agreeing that the misrepresentation and breach of contract issues ought to be decided as part of these tort proceedings in January, 2015, David Zarek's clients then refused to stay the Small Claims Court trial at the mandatory settlement conference on June 4, 2015 and insisted on a trial date. In reliance upon David Zarek's correspondence dated June 29, 2015 stating, in part, "We do not intend to re-litigate any issues properly decided by the Small Claims Court", and based on the estimate that the Small Claims Court trial would only take 1 to 1. ½ days, no motion was brought on behalf of Avis Budget Group Inc. to stay the Small Claims Court proceeding.

[22] They further asserted that contrary to the above, the Small Claims Court trial took 2 ½ years to complete · between February 3, 2016 and August 15, 2018, with the trial decision rendered December 18, 2018, and received by the parties on January 2, 2019. Certas Direct would not accept priority for the tort claims pending the disposition of the Small Claims Court trial (despite these issues being irrelevant to the determination of priority), and has still not accepted priority despite the findings in the Small Claims Court trial decision that all allegations of misrepresentation and breach of contract were unfounded.

[23] The moving parties factum further asserts:

There was never any attempt on behalf of Certas Direct/Sinisa Filipovic to settle or narrow the issues in these proceedings vis-a-vis Aviscar or Avis Budget Group Inc. In correspondence from David Zarek dated November 21, 2016 stated that he would "recommend" that all actions and Crossclaims against Sinisa Filipovic/ Certas Direct be dismissed with costs payable by Aviscar, in exchange for Aviscar paying · the full amount of the Price settlement, dismissing its Small · Claims Court action and agreeing to take over the entire defence of the Totayo action. By contrast, Aviscar made a time-limited "offer" on December 6, 2017 which was never responded to. That offer contemplated the withdrawal of all claims in the Small Claims Court proceeding without costs, as well as the waiver of all costs in the tort proceedings in exchange for Certas Direct accepting priority for the Plaintiffs' claims in the Price and Totayo actions

[24] The Moving Party further asserts:

34 Despite the fact that the status of the Totayo action was still being determined, and despite· repeated indications by Aviscar's counsel that a) the Small. Claims Court trial decision was required before any motion to reinstate the Crossclaims ·· could be determined (given the issues of res judicata, issue estoppel and abuse of process); b) that Aviscar would not rely upon any delay with respect to the hearing of the motion (following the Rule 48.14 deadline) in opposing any relief sought by the other parties; c) that the Price Crossclaim was only one of the five proceedings that would have to be reinstated; and d) that a long motion hearing would therefore be required, David Zarek's office proceeded to unilaterally schedule a 1 hour motion before a Master on November 19, 2018 in an attempt to reinstate the Price Crossclaim only in the absence of the Small Claims Court trial decision. Thereafter, they refused any reasonable request for . an adjournment of the November 19, 2018 date despite knowing that counsel for Aviscar was unavailable and would have to delay discoveries and inconvenience counsel in an entirely separate matter in order to speak to the contested adjournment request on November 19, 2018, which was granted by Master Short, with costs reserved.

[25] Their submissions continue with this outline of more recent developments:

35 After refusing to wait for the Small Claims Court trial decision to bring their motion to reinstate the Crossclaim in the Price action, David Zarek's office refused to accept Aviscar's offer to settle all of the reinstatement motions by way of Consent Orders on November 1, 2018. Such proposed Orders would have allowed Sinisa Filipovic to reinstate the Crossclaims in both actions on consent with the understanding that the Crossclaims would be stayed pending the release of the Small Claims Court trial decision (and/or the disposition of any appeal), that the only remaining issues to be tried would be priority and costs, and that the parties would be bound by the evidence and determinations from the Small Claims Court trial. In refusing the proposed terms, David Zarek's associate, … stated, “We have no idea what the SCC decision will say or which issues will be addressed and I am not prepared to guess. ” They then proceeded to abandon their motion entirely once the Small Claims Court trial decision was provided, resulting in significant costs thrown away.”

VI. Relevant Legislation

[26] As the subject motor vehicle involved a rental vehicle, the Bill 18 Amendments to sections 2.2.4 and 3.3:5 of the Standard Ontario Automobile Policy (OAP1), section 192 of the Insurance Act, and sections 267.12 and 277(1.1) of the Insurance Act, effective March 1, 2006, applied to these proceedings. The purpose of these amendments was to "make renters liable for damages sustained by reason of negligence in the operation of a rented vehicle, and to relieve the insurer of the owner of a rented vehicle from being the first loss.

[27] This clarification removes much uncertainty with respect to the rental car insurance industry. By establishing an order of priority of responsibility a somewhat no-fault regime is imposed were various insurers from time to time will be in a position of responsibility, while at other times they will be protected by these provisions.

[28] It is clearly within the rights of a party to seek to find a “work around” by virtue of creative arguments. If those arguments succeed, the insurer is in a much better position. But if they elect to roll the dice, they may end up with a significantly more onerous exposure that would otherwise have been the case.

[29] Any other litigant who would be prejudiced if the law were interpreted in a different way in a particular case, has the entitlement under the rules to increase the stakes in any such gamble.

[30] Rule 49.10 addresses the consequences of a failure to accept a plaintiff’s offer to settle. In this case I treat the position of a co-defendant as comparable to that of a plaintiff.

[31] The sub rule provides:

49.10 (1) Where an offer to settle,

(a) is made by a plaintiff at least seven days before the commencement of the hearing;

(b) is not withdrawn and does not expire before the commencement of the hearing; and

(c) is not accepted by the defendant,

and the plaintiff obtains a judgment as favourable as or more favourable than the terms of the offer to settle, the plaintiff is entitled to partial indemnity costs to the date the offer to settle was served and substantial indemnity costs from that date, unless the court orders otherwise. (1).

[32] I note that the rule also addresses what is referred to as a “Defendant’s Offer”

(2) Where an offer to settle,

(a) is made by a defendant at least seven days before the commencement of the hearing;

(b) is not withdrawn and does not expire before the commencement of the hearing; and

(c) is not accepted by the plaintiff,

and the plaintiff obtains a judgment as favourable as or less favourable than the terms of the offer to settle, the plaintiff is entitled to partial indemnity costs to the date the offer was served and the defendant is entitled to partial indemnity costs from that date, unless the court orders otherwise.

[33] I interpret this provision as being applicable any case where the defendant is addressing an offer to settle for the plaintiff and making a counteroffer. The present case is quite different in that it is between two defendants and I feel therefore that there is an entitlement to substantial indemnity costs in such a circumstance.

[34] Coming to that determination, I make note that sub rules 49.13 and 49.14 provides:

DISCRETION OF COURT

49.13 Despite rules 49.03, 49.10 and 49.11, the court, in exercising its discretion with respect to costs, may take into account any offer to settle made in writing, the date the offer was made and the terms of the offer.

49.14 Rules 49.01 to 49.13 apply, with necessary modifications, to counterclaims, crossclaims and third party claims.

(2) Subrule (1) and rules 49.03 to 49.14 also apply to motions, with necessary modifications

[35] The foregoing partial synopsis of the numerous steps between these parties in an action that ultimately resulted in awards to the two plaintiffs relatively insignificant amounts.

[36] While I was inclined to indicate that in cases such as this the most appropriate approach would be for the insurers to work through an arbitrator and not tie up substantial court resources on an issue which could have been resolved by way of a an application at an early stage. An application to the court for interpretation of the documentation at an early stage. However these are sophisticated litigators with substantial exposure to all the elements of the litigation process and the potential high cost of “playing hardball”.

[37] In the result I have determined to apply some degree of proportionality but to allow a significant proportion a significant portion of the amount sought in each of four cost outlined placed before me

[38] I am satisfied that the offer set out in what was marked as book SF-4 within the complete motion record was clearly directed to the issues before me and that the June 3, 2014 and that the date of June 3, 2014 is the trigger date for awards on a substantial indemnity basis.

VII. Quanta Meruit

[39] The foregoing partial synopsis of the numerous steps between these parties in an action that ultimately resulted in awards to the two plaintiffs of relatively insignificant amounts.

[40] While I was inclined to indicate that in cases such as this the most appropriate approach would be for the insurers to work through an arbitrator and not tie up substantial court resources on an issue which could have been resolved by way of an Application to the court for interpretation of the documentation at an early stage. However these are sophisticated participants with substantial exposure to all the elements of the litigation process and are keenly aware of the potential high cost of “playing hardball”.

[41] In the result I have determined to apply some degree of proportionality but to allow a significant proportion a significant portion of the amounts sought in each of four cost outlines placed before me by Aviscar’s counsel

[42] I am satisfied that the offer to settle was clearly directed to the issues before me and that June 3, 2014 is the trigger date for awards on a substantial indemnity basis.

[43] As well I have considered the extensive submissions made on behalf of Sinisa Filipovic with respect to the costs sought made by Aviscar.

[44] In support of the moving party’s cost claims they rely upon, inter alia the following elements which I have considered in coming to the conclusions that follow:

Rule 57.01(1)(e). The conduct of any party that tended to shorten or lengthen unnecessarily the duration of the proceeding;

Rule 57.01(1)(f) Whether any step in the proceeding was improper, unnecessary or taken through negligence, mistake or excessive caution;

Rule 57.01(1)(g) A party's denial of or refusal to admit anything that should have been admitted

Rule 57.01(1)(i) Any other matter relevant to costs (merit/unfounded allegations of· misrepresentation or other misconduct)

[45] The first Costs Claim relates to the following elements with respect to the “Price” action:

The Defendant, Aviscar Inc., seeks costs of within action, Crossclaim and Third Party Claim against the Defendant, Sinisa Filipovic, and/or the Third Party, Certas Direct Insurance Company on the following basis:

All Fees and Disbursements Waived from July 18, 2013 to February 19, 2014

Fees on a Partial Indemnity Basis from February 20, 2014 until June 3, 2014: $705.12

Fees on a Substantial Indemnity Basis from June 3, 2014 onwards: $20,397.63

Disbursements from February 20, 2014 onwards: $822.83

TOTAL FEES & DISBURSEMENTS: $21,925.58.

[46] I am satisfied that there is an entitlement to the substantial basis sought but applying proportionality I am satisfied the hourly rates are reasonable but that an appropriate award for this item would be $18,000 inclusive of the costs of this motion and HST.

[47] The second Costs Claim relates to the following elements with respect to the “Totayo” action:

The Defendant, Aviscar Inc., seeks costs of within action, Crossclaim and Third Party Claim against the Defendant, Sinisa Filipovic, and/or the Third Party, Certas Direct Insurance Company on the following basis:

All Fees and Disbursements Waived from July 18, 2013 to February 19, 2014

Fees on a Partial Indemnity Basis from February 20, 2014 until June 3, 2014: $1,956.03

Fees on a Substantial Indemnity Basis from June 3, 2014 onwards: $16,381.61

Disbursements from February 20, 2014 onwards: $613.28

TOTAL FEES & DISBURSEMENTS: $18.950.92

[48] Again I am satisfied that there is an entitlement to the substantial basis sought but applying proportionality while I am satisfied the hourly rates are reasonable, I have determined that an appropriate award for this item would be $16,000 inclusive of the costs of this motion and HST.

[49] The third Costs Claim relates to the following elements re Filipovic's Abandoned Motion:

The Defendant, Aviscar Inc., seeks substantial indemnity costs against the Defendant, Sinisa Filipovic, with respect to said Defendant's abandoned motion to reinstate its Crossclaim and set aside the dismissal Order in this action, including all costs with respect to the contested adjournment of the 1 hour Master motion returnable November 19, 2018 before Master Short.

Partial Indemnity

Fees $6,696.27

Counsel fee $ 145.77

Disbursements $ 564.88

Total $7.406.92

[50] The Substantial Indemnity amount sought was $8,928.36. Inasmuch as the motion did not proceed I am awarding $6000 as an appropriate amount for these claims.

[51] Lastly claims for fees relating to a number of other elements are addressed

COST OUTLINE OF THE DEFENDANT, AVISCAR INC. (Re: Aviscar's Motions for Reinstatement, Priority & Costs)

The Defendant, Aviscar Inc., seeks substantial indemnity costs against the Defendant, Sinisa · Filipovic and/or Certas Direct, with respect to its four motions for reinstatement, priority and .costs in the above proceedings, on the following basis:

Fees {as detailed below) $11,104.96

Estimated Counsel Fee for Appearance (4.0 hrs) $ 583.08

Disbursements (as detailed below) $ 1,291.93

TOTAL: Partial Indemnity $12.979.97

[52] Substantial Indemnity basis costs of $16.875.98 are also proposed.

[53] Taking the entirety of this matter into account I have determined that $9500 inclusive of HST is the appropriate amount to be awarded on these claims.

VIII. Conclusion

[54] It is not very satisfying to award $49,500 on what devolved into a small claims action where the moving party, it would seem, did not belong “at the table” from the outset.

[55] Nevertheless a party is entitled to its day in court. The need to pay in court mandates for a more prompt consideration of a litigant’s position.

[56] The parties found liable shall have 60 days to pay the amounts awarded.

R. 271/DS

Master D.E. Short