2016-01-12 complaint (case no cv-16-857117)

7/23/2019 2016-01-12 Complaint (Case No CV-16-857117)

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IL H BYRD

CUY HOG COU TY

CUERK

OF

COURTS

1200OntarioStreet

Cleveland,Ohio44113

urtof mm n Pleas

ewCaseElectronicallyFiled:

January

12 ,

2016

09:44

By:SU ODH HANDRA0069233

onfirmationNbr.

639910

LU ILLEDUMAS V16

857117

vs

MADELINE HAPPELL, ETAL.

Judge:

PETER

J ORRIGAN

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IN

THE

OURT

OF OMMON

LEAS

UYAHOGA

OUNTY,

OHIO

LU ILLE

DUMA

15634

Kipling

Avenue,

Apt.2

leveland,

Ohio

44110

Plaintiff,

vs .

MADELINE

HA ELL

In

bothher

official

and

personal

capacities

26241

Lakeshore

Boulevard #1953

Euclid,

Ohio

44132

and

UYAHOGA

OUNTY

1215

West

3rd

Street

leveland,Ohio 44113

Defendants.

C

plaint

with

ury

e and

ase No.

Judg

e

_ _

ature f

the

cti n

1. Thisis a

civil-rights

actionbrought under

42U.S. .

1983

and

1985(3).It alsoasserts

state-lawcauses

of

action.

Plaintiff

LucilleDumas

alleges

that

uyahoga ounty

orrections

Officer

Madeline

happell

violated

the

Fourth

and

Fourteenth

Amendments

of

the

United

States onstitution by usingexcessive

forceagainst

her

without

just

causeandcausingher

physicalandemotionalinjuriesand distress.

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2. WhileDefendant

happellwas actingin

thesc pe f

her

empl ymentwith

the

uyah ga

unty

Sherif

f

s

Department

and

under

color

f

state

law,

sheunlawfully

attacked

Ms.

Dumas, wh

was

being

b ked

n

January14,

2015at

the

Euclid

ity Jail.

This

unreas nable

seizuredirectly

and

pr ximatelycaused

Ms.

D as

sinjuries.The

uyah ga

untyPr secut rsOfficeindictedMs. happell ncharges f kidnapping(R. .2905.10(A)(3)),

tamperingwithrecords(R. .2913.42(A)(1)and

2921.12(A)(1)),

assault(R. .

2903.13(A),and

unlawfulrestraint(2905.03(A)).

happell

pled

guiltytotheassaultcharge n December 9,2015,

and

as

part

f

her

plea

agreement,

she

resigned

her

empl yment

as

a

corrections

officer

and

agreedthatshew uldn tseekfurtherempl ymentinlawenf rcement.

3.

uyah ga

unty,

thr ughit s

Sheriff

sDepartment,

knew

thatDefendant

happell

was

unfitfordutyas

a

corrections

officer

andwasnegligent

and

reckless

insupervising,disciplining,

staffing,and

retaining

happellas

an

empl yee.Thisnegligence

and

recklessness

was

a

direct

andpr ximatecause

f D as

s

injuries.

rt es

4.

Plaintiff

LucilleDumasresidesin leveland,Ohi .

5. Defendant

Madeline happell

wasa orrectionsOfficer

rp ral

for

the uyah ga

unty

Sherif

f s

Department.At

al l

times

relevantto

this

mplaint

s allegations,

she

was

acting

in

her

capacity

as

a

rrecti nsOfficer

empl yed

by

the uyah ga

untySheriff

s

Department

and

was

acting

under

color

f

state

law.

6.

Defendant

uyah ga

unty is

responsible

for happell

s

actions

as

alleged

inthis

mplaint,and

is responsible

for

the negligentand

reckless

supervision,

discipline,

staffing,and

retention f

Ms.

happellasa

rrecti ns

Officer.

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.

Jur sd ct n

and

Venue

7.

This

urt

has

pers nal

jurisdiction

ver

Defendants

under

R. .

2305.01

and

venue

is

pr per

in

this urtunder

iv.

R.

3(B)(3)becausetheeventsgiving

rise

toPlaintiffs

claimst k

place

in

uyah ga

unty,

Ohi .

V .

actua

ackgr und

. happellsattack on

umas

8.

r

ab ut

January

14,

2015,

Lucille

Dumas

was

arrested

in

c nnecti n

with

a

traffic

stop

and

br ught

to

the uyah ga

unty

Jail

Annex fthe

Euclid

ity Jail

for

b king.Then-

rp ral happell was

n

duty

at

theb king

desk

at

the

time.

9.

Acc rding

toa

written

report

by Detective

Phil

R bins n

f

the uyah ga unty

Sheriffs Department,wh reviewed jailsurveillancevide andinterviewed severaleyewitnesses,

happells attack nDumas ccurredasfollows:

10. Duringthe b kingprocess, happelland

Dumas

became engagedinaverbal

exchangethatbegantoget animated. happellthenranar undthe deskand punched

Inmate

Dumas

in

her

face

with

her

righthand...

Acc rdingto

unty

rrecti ns

Officer

Macarthur

Williams,

an

eyewitnessto

the incident,

when

rp ral

happell

slammed

[a ]b k

d wn

n

thedeskandg[o]t

up

andbeg[a]n

to

c me

ar und

the

desk[,]

that

s

when Ms.

Dumas

stood

up

and

t k

a

defensive

stance

to

protect

herself.

11.

Acc rdingtoDetectiveR bins n s

report,

after

the[first]punchby rp ral happell,

OfficerM tt disengagedfr mh lding

InmateDumasand rp ral happellgrabbedinmate

Dumas and

began

to

wrestle

with

her

and eventually

threwher

to

the gr und. The

[surveillance]

vide alsosh ws rp ral happelladministering [oleoresincapsicum]

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pepper

sprayto

the

faceof InmateDumas with

several

otherofficers

affectedby thedeployment

of

the

spray.

Accordingto

Dumas,

she

was

kicked

by

orporal happell

while

on

the

ground.

12. Detective

Robinson

s

report

furtherstatesthat, thecorrections

staffwas

able

tohandcuff

Inmate

Dumas

and

secure

her

inacorrections

approvedrestraintchair...

Whileattempting

to

moveInmateDumasfromthe

floor

totherestraintchair,the videoshows orporal happell

liftingInmateDumas[,who washandcuffedatthe time,]off thefloorbyherhairthenslamming

her

intotherestraintchair.

happell

then,

along

with orrectionsOfficerDelonteBrown and

Officer

Williams,

strap[ped]

Inmate

Dumas

to

the

restraint

chair.

13. AfterDumas wassecuredtotherestraintchair,happelladjustedherhair,looked

around,

then

struck

inmateDumas

with

her

left

hand.Officer

Brown reported

that

happell

struckMs.

Dumas3

timesin

the

face

and while

being

punched

Ms.Dumas was

defenseless

and

wasnotable

toprotect

herself.

Officer

Williams

reported

that,

while

[Ms.

Dumaswas]inthe

restraintchair

he

saw

orporal

happellpunchMs.

Dumas3

timeswith

aclosed

fist to

her

face

and

that

it

was

full

blown

strikes

.. .[t ]

theeye

and

cheek.

14.

Detective

Robinson

sreport

furtherstates

that

happell

wheel[ed

Ms.

Dumas

in

the]

restraint

chair

towards

the backof

theroom

...

butOfficerBrown intervenedand

tookcontrolof

the

restraint

chair

and

pushed

Inmate

Dumas

in

tothe back

room out

of

cameraview.

The video

shows...

orporal

happell

entering

andexitingthe room with

aTupperwarestylecontainer

handling

it

as

if

it

was

filled

up

with

water

and

repeating

the

process

no

less

than

two

(2 )

times.

15.

Officer

Mott

reportedthat happellthenunnecessarily

drenched

[Ms.Dumas]with

waterin

an

aggressive

manner,andthen

str[uck]Ms.Dumas

inthefacewith

[the]

Tupperwarecontainercausingit tobreak.According toOfficerBrown, happelltookthe

[Tupperware]bowl and

hit

[Dumas]

in

the

face

with

it

breaking

thebowl

and

splitting

it

down

themiddle.

According

to

Officer

Williams,

happell

took

the

bucket

and

slapped

Dumas

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upside

the head with

a

back

hand

slappingmotion[.][T]his

cracked

the

bucket

down

the

middle[.]Ms.

Dumas

was

in

restraints

in

the

restraint

chair

at

this

time.

16.

Officer

Brown

further

reported

that,

orporal happellordered

Officer

Brown

to

throw

that

particular

bowl

away

and

repeated

the

order

twice[.] orporal happell

placed

thebowl

in

thetrashcart...withthe TupperwareBowl nevertobe seenagain.

17.

According toOfficer

Mott:

Allemployees working

that

eveningwererequiredto

completeawrittenor

typedaccountoftheassaultincident. orporal happellreadOfficer

Mott

s

statement

and

replied,

oh

hell

no

you

re

doing

too

much.

orporal

happell

then

erased

anddeletedOfficerMott s typedstatementwhichwas approximately onehalf pagelongand

very

detailed

and

typed

in

a

one

line

simple

statementthat

depicted

untruth

and

minimized

the

whole

incidentbetweenMs.

Dumas

and

orporal

happell.OfficerMottwas

thenordered

to

sign

the statementthatwas not

authorized

by her.

18. According to

Officer

Williams,

when

Sheriff

sDeputiesarrived

to

transportMs.

Dumas

to

the

uyahoga

ounty

Jail

...

a

female

deputy

asked,didI

missanything?

and

Ms.

Dumas

replied, yes,shetried

tokillme,

then orporal happell

replied,

you

refuckingright

I

tried

to

killyou.

19. All

of

these

statements

containedin

Detective

Robinson

sreport,

as

set

forth

in

paragraphs10

18

above,aretrue.

20.

happell

s

attack

on

Dumas

caused

Dumas

to

be

terrified

and

fearful.

happell

s

attack

onDumas was

not

provoked

by

any

threat

of

physical

forcefrom Dumas.

21.

Dumas

filed

a

formal

grievance

with

uyahoga

ountyabouttheabove-described

conduct bymailon July17,2015,accordingtothe uyahoga ounty orrections enters

inmate handbook.

Dumas

receiveda

writtenreply

to

her

grievancefrom uyahoga

ounty

Assistant

Prosecuting

Attorney

Barbara

R.

Marburger

in

whichMs.

Marburger

stated

that

the

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inmate grievance

process

...is n tapplicable to[Ms.

Dumas]

andthat

uyah ga

unty

officials

are

aware

f

theincident

at

the

Euclid

Jail

n

January

14,

2015.

The ounty

s

negligent

and

reckless

retention

of efendant happell

22.

uyah ga

unty,

thr ughit s

Sheriff

sDepartment,hadapatternand

practice

and

a

cust mand policy f negligentlyandrecklessly

hiring

officersn tsuitablefortheirpositions,

failingtopr perlytrainandsuperviseofficers,andretainingofficersunfitfortheirpositions.

23. TheSheriffsDepartment negligentlyand recklesslyhired,staffed,and retained

Defendant

happell

as

a

rrecti ns

Officer

rp ral,

despite

the

fact

that

she

was

clearly

unfit

for

her

duties.

24.

In

December

2013,

the

Sheriffs

Department

suspended

happell

for

fourseparate

incidents

in

Oct berand

N vember 2013,

including

tw incidents

f

displaying

unprofessional,

disrespectful,

threatening

and

pr fane

language

t ward

inmates,

andtw incidents

f

unprofessional behavi r

t ward

subordinates.Ina

letter

to happelldated

December 22,

2013,

uyah ga

unty

H man

Res urcesDirector

Elise

Hara

stated

that,y ur

c ntinued

failure

to

c nduct

yourself

in

aprofessional

manner

am untstoadeliberatedefianceofprotocol,policy

andappropriatebehavi rinthew rk place.

25. Thisfollowedan incident nly

m nthsbeforethat

caused

theSheriff s

Department

to

issued

happell

awritten

reprimand

to

happellstatingthat:

On

March25,2013,

while

y u

were

c nducting

a

raid

and

strip

search

y u

ann unced

to

the

entire

p d

f

inmates

to

squat

d wn

and

actlike

y uare

riding

a

dick.

26.

In an

investigatory

interview

c nductedby uyah ga

unty

Sherif

f

sSergeant

Patrick

Leahy

n

N vember

6,

2013,

Leahy

stated

to happell:H w

many

times

have

I

had

to

have

y u

relievedfr man

incident

because

f

y ur

screaming

and

swearing,inciting

theinmate,

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instead

f de-escalating the

situations?

...Have I

n thady urelievedfr m

an

incidentseveral

timesin

the

past?

27.

Leahy

wr tein

his

report

f

theinterview

that:

During

the

questioning

pl

happell

had

to

be

told

several

times

to

stop

talking

sol ud

and

to

keep

n

the

subject

athand.

pl

happellc ntinuedtog off natangent,arguingab utirrelevanttopics. pl happell had

been calledtothe

office

for herallegedunprofessionalismindealingwiththe inmatesandshe

was

c mpletelyunprofessional during

theinterview,talking

loudly

andarguingduringthe entire

interview.

28.

Since

2005,theSheriff sDepartment hassuspended happellatleast21timesfor

absenteeism

and

otherunprofessional

conduct.

Plaintiff

s

d m g s

29.

Since

having

beenattacked

by

happell,

D as

sability

to

perf rm

and

enj y

her

usual

activities

has

beenimpaired.

She

hassuffered

severe

em ti naldistress,includingdepression,

sleeplessness,

and

relatedem ti nalanxietyasaresult fhermistreatment.If

sheseesapolice

officer,shehas

particulartroublesleeping

thatnight.Her mentaland

em ti nal

injuriesaredue

tobeing

terrorized

by

theattack

thatDefendant happellperpetratedandthe unty

failedto

prevent.

30.

As a

direct

and

pr ximate

result

f

Defendants

intentional

and

recklessacts,Dumas

sustained

severe

mental

and

physical

pain

and

suffering

and

injury

in

an

am unt

to

be

determined

at

trial.

31.

Dumas

is

entitled

toc mpensat rydamages

for

the

harmsinflicted

up n

her.

And

sheis

entitled

to

punitivedamages

for

the

unc nsci nable

c nduct

she

was

forcedto

endureat

the

hands

f

happell,as

well

asattorneys

feesandcosts.

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V

ai s

laim

Excessive

use

of forceunder

the

FourthandFourteenth

mendments

and

U S 1983

(against all efendants)

32.

Plaintiffincorporates

al l

previous

allegationsby

reference.

33. Defendant

happell

used

excessiveforce gainst

Dumas

to

terrorizeher. reasonable

officerw uld

n t

haveinitiatedthe seizure r

used

the

kindof

force

that

happell

usedagainst

Dumas. happellattacked

Dumaswith ut

pr bable

cause

or

reasonable

need

tod so.She

used

a

grosslyunnecessary

am unt

f

force

to

detain

Dumas,

which

was

sh cking

to

a

pers n f

rdinary

conscience

and

unjustifiable

under the

circumstances.

The

am unt

f

force

used

to

acc mplishthe detentionwasclearly

excessiveandobjectively

unreas nable

underthe

F urth

Amendment. All

f

theseactions

caused

damagetoDumas.

34.

happell

acted

under

color

f

law

in

her

official

capacity

to

deprive

Dumas

f

her

right

to

freed mfr m

illegal

seizure f

her

person.This

rightis

securedto

her

by the

F urth

and

F urteenth

Amendments and

was

clearlyestablished

as

fJanuary 4, 015.

35.

The

unty

knew

that

it snegligentand

recklesstraining,

upervision,

iscipline,

taffing,

andretention f

happell

w uld

lead

to

this

civil-rights violation.

36.

In

retaining

happell,

and

failing

to

adequately

train,

iscipline,

and

superviseher

despite

her

kn wn

history f violence

t ward

inmates

and

colleagues,the

unty

was

deliberatelyindifferent

tothe

likelihood

that

the

civil-rights

violationsagainst

Dumas w uld

occur.Thisfailuream unts toan unconstitutionalcust m,policy, rpractice f permittingthe

use fexcessiveforceagainst

inmates.

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37. As a

directand pr ximateresult

f

Defendants

unlawful

conduct,

which

was

intentional

and

sh wed

a

spirit

f

ill-will,hatred,and

want n disregard

f

D as

srights,

Dumas

suffered

and

will

c ntinue

to

sufferec n micand

n n-ec n mic damages

for

which

happelland

the

unty

are

liable,

including,but

n t

limitedto,

mental,emotional,

and

physical

pain

and

suffering.

38. Dumas

is

entitled

topunitivedamagesbased nDefendants unlawfulconduct.

laim

2

enial

f

equal

protection under

the14th me dme tand

4 U S 1983

(against

happell)

39.

Plaintiffincorporates

the

previous

allegations

by

reference.

40. With purp se

r

intent

to

discriminate,

acting

under

color

f

state

law,

Defendant

happelldiscriminated

againstDumas

illegallyand

based

n

her

race.

In

attacking

Dumas

as

describedab ve, happell,wh is aucasian,treatedDumas differentlyandaslessthanhuman

because

Dumas

is

black.

41.

happellsattack nDumas wasm tivatedby D assrace. happelldid

n tattack

similarlysituated aucasianinmates,wh ,likeDumas, presentedn reasonable threatof

physical

force

to

her,

in

the

way

that

sheattacked

Dumas.

42.

happell

s

attack

n

Dumas

led

to

the

deprivation

f D as

sfederally

protected

rightto

equal

protection.

43.

As

a

direct

and

pr ximate

result

f

the

unconstitutional

denial

f

equal

protection,

Dumas

hassuffereddamages

forwhich happell

is

liable.

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44. Asa


f

Defendants

unlawful

conduct,

which

was

intentional

and

sh wed

a

spirit

f

ill-will,hatred,and

want n disregard

f

D as

srights,

Dumas

suffered

and

will

c ntinue

to

suffer

ec n micand

n n-ec n mic

damages

for

which

happell

is liable,

including,

butn t

limitedto,

mental,

emotional,

and

physical

pain

andsuffering.

45.

Dumas

is entitledtopunitivedamagesbased n

Defendants

unlawfulconduct.

laim

3

attery

(againstChappell)

46. Plaintiffincorporates

the

previous

allegations

by

reference.

47.

Defendant

happellengaged

in

the

ab ve-describedactions

intending

to

cause

the

harmful

contactand

the harmful

contact

resulted.

happell

intended

to

strike

Dumas

in

her

face

repeatedly,withher

closed

fist

and

witha

plastic

container,

and

didsowhile

Dumas was

c mpletelyrestrainedand defenseless.Theseoffensivet uchingswereunlawfulandunwanted.

48.

As

a

direct

and

pr ximate

result

f

happell

s

unlawful

conduct,

which

was

intentional

andsh wedaspirit f

ill-will,hatred,andwant n disregard f D assrights,Dumassuffered

andwillc ntinuetosufferec n micandn n-ec n mic damagesfor which happellis liable,

including,

butn t

limitedto,

mental,

emotional,andphysicalpain

and

suffering.

49.

Dumas

is

entitledtopunitivedamages

based

n

happell

s unlawful

conduct.

laim4

ntentional

infliction

of

emotio al

distress

(against

Chappell)

50.

Plaintiff

incorporates thepreviousallegationsby reference.

51.

Defendant

happellsattack n

Dumas wasextremeand utrage usand

constituted

behavi r

that

is

intolerable

in

acivilized

c mmunity.

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52.

happell

s

attack nDumas

was

undertakenkn wingly

and

intentionally,

withmalice,

with

a

conscious

disregard

f D as

s

rights

and

interests,

and

with

certainty f

inflicting

severe

harmanddamage n

Dumas.

53.

Defendant

happell

sattack

nDumas

was

intentional,

was

intended

to

cause,

anddid

directlyandpr ximatelycauseDumas tosuffersevereanddebilitatingem ti nalharm and

damage,includinganxiety,depression, paranoia,andsleeplessness.

54.

The mentalanguishsuffered

by Dumas asadirectandpr ximateresult f happells

c nduct

is

serious

and

f

a

nature

that

n

reasonable

pers n

c uld

be

expected

to

endure

i .

55. happellknewor sh uldhavekn wn thatDumas w uldsuffersevereharm anddamage

asaresult

f

her

conduct.

56.

Dumas

is entitledtopunitivedamages

based

n

happell

s

unlawful

conduct.

Claim5

M l c ous

attemptto

influence

public officials

(intimidation)under

C 2921.03( )and

(C)

(against

Chappell)

57.

Plaintiff

incorporates thepreviousallegationsby reference.

58.

By deleting

and

replacing

OfficerM tt

swrittenacc unt

f

her

attack n

Dumaswith

a

false

acc unt

f

theevent,

Defendant

happell

kn wingly

attemptedtouseamateriallyfalseand

fraudulent

writingwithmaliciouspurpose,in

badfaith,andin

a

w nt n

and

recklessmanner,

in

an

attempt

to

influence

and

hinder

unty

officials

r

Prosecutors

in

the

discharge

f

their

duties.

59.

As

adirect

and pr ximateresult f happelsunlawful

conduct,

prosecutorswere

hampered

in

theirability

to

fully

prosecute

and

h ld

happellacc untable

for

her

crimes,and

accepteda

lesserpleaand

sentence

than

was

warranted.

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60. Asa


f happel

s

unlawful

conduct,

whichwas

intentional

and

sh wed

a

spirit

f

ill-will,hatred,and

want n disregard

f

D as

srights,

Dumas

suffered

and

will

c ntinue

to

sufferec n micand

n n-ec n mic damages

for

which

happell

is

liable,

including,

butn t

limitedto,

mental,

emotional,

and

physical

pain

andsuffering.

61. Defendant uyah ga unty,as happelsempl yer,is responsiblefor

her

wr ngd ing

underthedoctrine f resp ndeatsuperior.

62.

happellsactions

violateR. .

2921.03(A)andsubject happellandthe

unty

tocivil

liability,

including

for

attorneys

fees,

costs,

and

expenses

under

R. .

2921.03( ).

laim

6

egligent a d

reckless

training,supervision,

discipline,

staffing,a dretention

(against

uyahoga

ou ty)

63. Plaintiffincorporates thepreviousallegationsby reference.

64. Defendant uyah ga unty failedtoexerciseduecareand

acted

inawillful,want n,

andreckless

manner

intraining,supervising,disciplining,staffing,and

retaining

Defendant

happellasa orrectionsOfficer orporal.

65. uyah ga

unty

knew

that

happell

was unfit

for

her

position

and

duties,

yet tolerated

her

empl yment.

66. uyah ga

unty

s

negligent,

reckless,

want n,andwillful

c nduct

inthis

regard

directly

and

pr ximately

caused

D as

s

injuries

alleged

in

this

mplaint.

V .

r yer

f r

e ef

F r

the reasons

stated

ab ve,Plaintiffrespectfully

requests

the

following

relieffr mthe ourt:

A. DeclarethatDefendants actsandc nductconstituteviolations f theF urthand

F urteenth

Amendments

ftheU.S. onstitution

under

42

U.S. .1983.

B. Judgment in

Plaintiff sfavorastoal l

claimsfor

relief.

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.

Specialand

generaldamages

in

excess

f$25,000

to

c mpensatefor

theinjuries

Ms.

Dumas

sustained

dueto

Defendants c nduct

including

ec n mic

and

n n

ec n mic

damages

for

medical

costs,

pain,

suffering,

humiliation,

and

em ti nal

distress.

D.

Punitiveand

exemplary

damages,

pre-judgment interest,

p st-judgmentinterest,

costs,and

otherreasonable

expenses incurred

in

maintaining

thisaction,and

the

reasonableattorneys feesandcostsincurredinmaintainingthisaction.

E. Allother

relief

inlawor equitytowhichPlaintiffis

entitled

andthatthe

urt

deemsequitable,just, rproper.

V

ury

e nd

Plaintiff

demands a

trial

by jury

n

al l

issues

within

this

mplaint.

Respectfully

submitted,

THE

HANDRALAW

FIRM,

ubodh

Chandra_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Sub dh

handra

(0069233)

Peter

Pattakos

(0082884)

Ashlie

ase

Sletvold

(0079477)

1265

W.

6thSt.,Suite400

leveland, H44113-1326

216.578.1700Ph ne

216.578.1800Fax

Sub dh. handra@ handraLaw.c m

Peter.Pattak s@ handraLaw.c m

Ashlie.Sletv ld@ handra.Law.c m

and

[Per

con ent

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

hrist pher

Th mari s

(0076637)

820W.

Superi r

Ave.,Suite840

leveland,Ohi 44113

216.696.8217Ph ne

216.696.9292Fax

christ [email protected] m

Attorney for

Plaintiff

Lucille

Duma

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2016-01-12 complaint (case no cv-16-857117)

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