REPUBLIC OF LIBERIA) IN THE CIVIL LAW COURT, SIXTH JUDICIAL CIRCUIT, MONTSERRADO COUNTY ) MONTSERRADO COUNTY, SITTING IN ITS MARCH TERM, A. D.

Transcription

1 REPUBLIC OF LIBERIA IN THE CIVIL LAW COURT, SIXTH JUDICIAL CIRCUIT, MONTSERRADO COUNTY MONTSERRADO COUNTY, SITTING IN ITS MARCH TERM, A. D BEFORE HIS HONOR:...YUSSIF D. KABA... RESIDENT CIRCUIT JUDGE City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant Plaintiff=s Complaint ACTION OF DAMAGES FOR WRONG Plaintiff, in the above entitled cause of action, complains of Defendant in form and manner, as follows, to wit: 1. Plaintiff says he is a citizen of the Republic of Liberia; while Defendant is a corporation duly organized, registered and engaged in the Airline Business in Liberia. 2. Plaintiff says that in August 2009, he purchased a round trip ticket from the Defendant to travel to Washington, through Brussels, and back to Roberts International Airport. Copy of the Ticket is hereto attached and marked Plaintiff=s EXHIBIT AP/1". 3. Plaintiff says that he departed Liberia on August 28, 2009 on SN Brussels Flight SN 245 and arrived at Washington Dulles, DC on August 29, 2009, on a United Airlines Flight, UA 951, Plaintiff having been placed on United Airlines by the Defendant in Brussels on the morning of August 29, Further to count three (3 herein above, Plaintiff says on the 15 th day of October, A. D. 2009, he proceeded to Washington Dulles Airport to depart for Liberia, as his Ticket read Monrovia ROB Liberia/Brussels, Belgium/Washington, Dulles/Brussels, Belgium/Monrovia ROB Liberia. Copy of Plaintiff=s Itinerary is hereto attached and marked Plaintiff=s EXHIBIT AP/2". 5. Further to count four (4 herein above, Plaintiff says when he went to the United Airlines Counter to check in, he was presented with a boarding pass and a luggage tag which read Washington, Dulles Brussels, Belgium. 6. Further to count five (5 herein above, Plaintiff says that upon information to the United Airlines= Supervisor, Mr. Clark, that Plaintiff=s journey terminated in Monrovia; and inquiry as to why he was given a boarding pass and luggage tags for Brussels, Belgium, he was informed by the said Mr. Clark that it was Defendant=s Policy to present passengers with boarding passes and luggage tags for Brussels, Belgium; and that upon arrival in Brussels, Belgium, they are then issued new boarding passes and luggage tags since they are, in fact, transit passengers. 7. Further to count six (6 herein above, Plaintiff says he was charged United States Dollars Two Hundred Fifty (US$ for his excess baggage and he paid same. Copy of the Receipt is hereto attached and marked Plaintiff=s EXHIBIT AP/3". 8. Further to count seven (7 herein above, Plaintiff says that upon his arrival in Brussels, Belgium, he was asked by the Attendant at Defendant=s Transit Counter to exit the terminal and recheck himself and his luggage in. Page 2 of 3

2 9. Further to count eight (8 herein above, Plaintiff says that he refused to exit the terminal, arguing that he was a transit passenger; that Defendant knew that Plaintiff did not have a visa for Brussels and that Plaintiff=s Returned Ticket read Washington Dulles/Brussels, Belgium/Monrovia ROB Liberia 10. Further to count nine (9 herein above, following heated argument and exchanges between Plaintiff and the Attendant at Defendant=s Transit Counter, during which exchanges Plaintiff was subjected to the utmost humiliation, embarrassment and inconvenience, with the Attendant at Defendant=s Transit Counter threatening to forcefully evict Plaintiff from the service line, the Attendant at Defendant=s Transit Counter abandoned her demands for Plaintiff to exist the airport terminal and re-check himself in; but finally demanded that Plaintiff pay another three hundred (300 euros for his excess baggage. 11. Further to count ten (10 herein above, Plaintiff says he refused to pay the three hundred (300 euros for his excess baggage, he having paid United States Dollars Two Hundred Fifty (US$ at Washington Dulles Airport, and as a transit passenger, could not be subjected to double payment(s. 12. Further to count eleven (11 herein above, Plaintiff says the Attendant at Defendant=s Transit Counter refused to place Plaintiff on the flight, demanding that Plaintiff pay the three hundred (300 euros for his excess baggage; whereupon, against Plaintiff=s vehement protest, he was compelled to pay the amount of three hundred (300 euros before Defendant agreed to place Plaintiff on the flight. Copy of the Receipt is hereto attached and marked Plaintiff=s EXHIBIT AP/4". 13. Further to count twelve (12 herein above, Plaintiff says that upon his arrival in Monrovia, he wrote Defendant a letter, demanding the return of his three hundred (300 euros; but Defendant elected to treat the entire matter with levity, frivolity; Defendant ignored Plaintiff, and refused to address Plaintiff=s request. Copy of Plaintiff=s letter is hereto attached and marked Plaintiff=s EXHIBIT AP/5". 14. Further to count thirteen (13 herein above, Plaintiff says Defendant=s refusal to address Plaintiff=s request for refund is characteristic and typical of the racist way and manner in which Defendant has elected to treat Liberians and Africans in general; it having been observed that Defendant has created and reserved a remote terminal for Africans at its Brussels, Belgium Airport, which is now labeled the African Terminal. Copy of the information, culled from Defendant=s Brochure, is hereto attached and marked Plaintiff=s EXHIBIT AP/6". 15. Further to count fourteen (14 herein above, Plaintiff says upon arrival at Defendant=s Brussels, Belgium Airport, passengers traveling to Africa, overwhelmingly Africans, are required to board a bus for the remote terminal where they are required to be confined up to boarding time. 16. Plaintiff further says the information contained in the brochure, from which Plaintiff Exhibit AP/6" is extracted, is most untrue; there is no lounge, there are no bars, restaurants and shops; in fact, to buy water and other beverages, the passengers from the African Terminal have to board a bus and return to the main termial Further to count sixteen (16 herein above, Plaintiff says Defendant is in the habit of spraying its flights after passengers have boarded at the Roberts International Airport, something that is never done on its European Flights. Page 3 of 3

3 18. Plaintiff says the act of Defendant in demanding that Plaintiff leave the Airport and recheck himself and his luggage in; that the act of Defendant in threatening to evict Plaintiff from the Service Line; that the wrongful act of the Defendant in demanding that Plaintiff pay the sum of three hundred euros before he could be allowed to board the flight in Brussels caused him great inconvenience, humiliation, embarrassment and demeaned Plaintiff in the eyes of on looking passengers at Defendant=s Brussel/Belgium Airport, for which damages will lie. WHEREFORE, and in view of the foregoing, Plaintiff prays for verdict and judgment against the Defendant, as follows: (i (ii (iii (iv in the amount of Three Hundred Euros as special damages, representing the amount spent for excess baggage, though Plaintiff had paid for his excess baggage prior to boarding the United Airlines Flight in Dulles, Washington, and arrived in Brussels as a transit passengers; such amount as shall be determined by the Jury to be sufficient as general damages for the wrong, embarrassment, inconvenience, humiliation, disgrace and mental anguish experienced at the hands of Defendant=s Attendant at its Brussels, Belgium Airport, but not less than United States Dollars Seven Hundred Thousand (US$700, 000; interest of six percent (6% per annum on the entire judgment (both special and general damages commencing from the day of the judgment, until settlement of the judgment is eventually made, as provided by law; rule all costs against the Defendant; and grant unto Plaintiff any other and further relief as in such cases is made and provided by law. Respectfully submitted, The above named Plaintiff, by and through his Counsel: DEAN & ASSOCIATES, INC. Necular Y. Edwards F. Musah Dean, Jr., Pro se DATED THIS 27 th DAY OF JANUARY, A. D $5.00 Revenue Stamp Affixed on the Original. REPUBLIC OF LIBERIA IN THE OFFICE OF THE JUSTICE OF THE PEACE FOR MONTSERRADO COUNTY AND IN MONTSERRADO COUNTY, CITY OF

4 MONROVIA, LIBERIA City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant ACTION OF DAMAGES FOR WRONG PLAINTIFF=S AFFIDAVIT PERSONALLY APPEARED BEFORE ME, a duly qualified and commissioned Justice of the Peace, for and in Montserrado County, at my Office, in the City of Monrovia, Necular Y. Edwards, Counsellor-At-Law, and one of Counsel for Plaintiff, in the above-entitled cause of action, and made Oath according to law that all and singular the allegations of both law and facts, as set forth and contained in the annexed and foregoing PLAINTIFF=S COMPLAINT are true and correct to the best of his knowledge and belief; and as to those matters of information, he verily believes them to be true and correct. Sworn and Subscribed to before me, this 27 TH day of January, A. D Justice of the Peace for Montserrado County, R.L. Necular Y. Edwards AND ONE OF COUNSEL FOR PLAINTIFF/DEPONENT $3.00 REVENUE STAMP AFFIXED ON THE ORIGINAL REPUBLIC OF MONTSERRADO LIBERIA IN THE CIVIL LAW COURT, SIXTH JUDICIAL CIRCUIT, COUNTY MONTSERRADO COUNTY, SITTING IN ITS MARCH

5 TERM, A. D BEFORE HIS HONOR:...YUSSIF D. KABA... RESIDENT CIRCUIT JUDGE City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant ACTION OF DAMAGES FOR WRONG The Clerk Civil Law Court Temple of Justice Monrovia, Liberia WRITTEN DIRECTIONS Madam Clerk: Upon the receipt of these our Written Directions, Plaintiff=s Complaint and Affidavit, you are hereby ordered to immediately docket the said cause in the Civil Law Court, Sixth Judicial Circuit, Montserrado County, sitting in its March Term, A. D You will issue a Writ of Summons, directed to the Sheriff for Montserrado County, commanding him to summons SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs, or any Authorized Officer, of the City of Monrovia, Republic of Liberia, Defendant in the above-entitled cause of action, to appear before the Civil Law Court, Sixth Judicial Circuit, Montserrado County, on the 15 TH day of March, A. D. 2010, at the hour of ten o=clock in the morning, same being the formal opening day of the March, A. D Term, to answer Plaintiff=s Complaint, in an action of Damages for Wrong. You will further insert a clause in the said Writ of Summons, notifying said Defendant to file its Answer or Formal Appearance in your Office on or before the 6 th day of February, A. D.2010; and that upon its failure to so appear, judgment will be rendered against it by default. In the meantime, you will command the Sheriff to make his Official Returns, endorsed on the back of the original Writ of Summons, to your Office on or before the said 6 th day of February, A. D. 2010, as to the manner of its service. AND FOR SO DOING, THIS SHALL CONSTITUTE YOUR LEGAL AND SUFFICIENT AUTHORITY, AND THESE OUR WRITTEN DIRECTIONS. Respectfully submitted, THE ABOVE NAMED PLAINTIFF; By and through His Counsel: DEAN & ASSOCIATES, INC. DATED THIS 27 th DAY OF JANUARY, A. D Frank Musah Dean, Jr., Pro se REPUBLIC OF MONTSERRADO LIBERIA IN THE CIVIL LAW COURT, SIXTH JUDICIAL CIRCUIT, COUNTY MONTSERRADO COUNTY, SITTING IN ITS MARCH

6 TERM, A. D BEFORE HIS HONOR:...YUSSIF D. KABA... RESIDENT CIRCUIT JUDGE City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant WRIT OF SUMMONS ACTION OF DAMAGES FOR WRONG REPUBLIC OF LIBERIA, TO: MAJOR CLARA N. KPAINGBAI, ESQ. SHERIFF, MONTSERRADO COUNTY, OR HER DEPUTY, G R E E T I N G S: YOU ARE HEREBY COMMANDED to summons SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs, or any Authorized Officer, of the City of Monrovia, Republic of Liberia, Defendant in the above entitled cause, to appear before the Civil Law Court, Sixth Judicial Circuit, Montserrado County, sitting in its March Term, A. D. 2010, at the Temple of Justice Building, to convene on the 15 th day of March, A. D. 2010, at the hour of ten o=clock in the morning, to answer the Complaint of the above-named Plaintiff; that upon its failure to appear, judgment by default will be rendered against it. YOU ARE FURTHER COMMANDED to notify the said Defendant to file its Formal Appearance and/or Answer in my office on or before the 6 th day of February, A. D Meanwhile, you will make your official returns endorsed on the back of the Writ of Summons, as to the manner of its service, on or before the said 6 th day of February, A. D AND HAVE YOU THERE THIS WRIT OF SUMMONS. Given under my Hand and Seal of Court, this 27 th day of January, A. D S E A L: Ellen Hall CLERK, CIVIL LAW COURT, MO. CO. R. L. $5.00 REVENUE STAMP AFFIXED ON THE ORIGINAL. REPUBLIC OF LIBERIA IN THE CIVIL LAW COURT, SIXTH JUDICIAL CIRCUIT, MONTSERRADO COUNTY MONTSERRADO COUNTY, SITTING IN ITS MARCH TERM, A. D BEFORE HIS HONOR:...YUSSIF D. KABA... RESIDENT CIRCUIT JUDGE

7 SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...APPLICANT SPECIAL APPEARANCE City of Monrovia, Liberia...RESPONDENT GROWING OUT OF THE CASE: SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...MOVANT City of Monrovia, Liberia...RESPONDENT GROWING OUT OF THE CASE City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant RESPONDENT=S RESISTANCE MOTI0N FOR THE ENLARGEMENT OF TIME ACTION OF DAMAGES FOR WRONG Respondent, in the above-entitled proceedings, denies the legal and factual sufficiency of Movant=s Motion/Application for Special Appearance, and prays Your Honor to deny, overrule and dismiss said Motion for Special Appearance, for legal and factual reasons, showeth the following, to wit: 1. That as to the entire Motion, Respondent says that same is a fit and proper subject for dismissal as the Applicant was properly summoned and is under the jurisdiction of this Court. 2. That as to counts one (1 through four (4 of the Motion/Application, Respondent says that same is a restatement of the law and raise no traversable issue. 3. That as to counts five (5 and six (6 of the Motion/Application, Respondent says that the Writ of Summons was served on Defendant=s Agent/Employee on January 27, 2010, upon the instructions of the Country Manager Awho authorized his Sales Agent to sign for and receive the Writ of Summons@. Copy of the Writ of Summons, with the Sheriff=s Returns at the back, is hereto attached and marked Respondent=s Exhibit AR/1". Page 2 of 2 4. Further to count three (3 of this Resistance, Respondent says that in a long line of cases, our Supreme Court has held that the Returns of the Sheriff/Ministerial Officer will be deemed

8 authentic, in the absence of any proof to the contrary, and mere assertion is not sufficient to rebut such presumption. Perry vs. Ammons, 16LLR 268 (1956, Jeto Liberian Clothing vs. Breckwoldt and Company (Liberia, Ltd. 20LLR 509 ( Further to count four (4 of this Resistance, Respondent says that the Movant/Applicant, having been duly served, is under the jurisdiction of the Court and, therefore, the Application for Special Appearance should be denied and dismissed. 6. Respondent denies all and singular the averments of fact and law contained in Movant/Applicant=s Motion and which may not have been specifically traversed in this Resistance. WHEREFORE, and in view of the foregoing laws, facts and circumstances, Respondent prays this Honourabele Court and Your Honour to overrule, set aside and quash Movant=s Motion/Application for Special Appearance, and grant unto Respondent such other and further relief as to this Court may seem just and equitable Respectfully submitted, The above named Respondent, by and through Himself and His Counsel: DEAN & ASSOCIATES, INC. Necular Y. Edwards F. Musah Dean, Jr.. Pro-se Bindu E. Clark ATTORNEY-AT-LAW DATED THIS 22nd DAY OF MARCH, A.. D $5.00 Revenue Stamp Affixed on the Original. REPUBLIC OF LIBERIA IN THE OFFICE OF THE JUSTICE OF THE PEACE FOR MONTSERRADO COUNTY AND IN MONTSERRADO COUNTY, CITY OF MONROVIA, LIBERIA SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...APPLICANT

9 SPECIAL APPEARANCE City of Monrovia, Liberia...RESPONDENT GROWING OUT OF THE CASE: SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...MOVANT City of Monrovia, Liberia...RESPONDENT GROWING OUT OF THE CASE City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant RESPONDENT=S AFFIDAVIT MOTI0N FOR THE ENLARGEMENT OF TIME ACTION OF DAMAGES FOR WRONG PERSONALLY APPEARED BEFORE ME, a duly qualified and commissioned Justice of the Peace, for and in Montserrado County, at my Office, in the City of Monrovia, Necular Y. Edwards, Counsellor-At-Law, and one of counsel for Respondent in the above-entitled cause of action, and made Oath according to law that all and singular the allegations of both law and facts, as set forth and contained in the annexed and foregoing RESPONDENTS= RESISTANCE are true and correct to the best of his knowledge and belief; and as to those matters of information, he verily believes them to be true and correct. Sworn and Subscribed to before me, this 22 ND day of March, A. D Justice of the Peace for Montserrado County, R.L. Necular Y. Edwards AND ONE OF COUNSEL FOR RESPONDENTS/ DEPONENT $4.00 REVENUE STAMP AFFIXED ON THE ORIGINAL. REPUBLIC OF LIBERIA IN THE CIVIL LAW COURT, SIXTH JUDICIAL CIRCUIT, MONTSERRADO COUNTY MONTSERRADO COUNTY, SITTING IN ITS MARCH TERM, A. D BEFORE HIS HONOR:...YUSSIF D. KABA... RESIDENT CIRCUIT JUDGE SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or

10 any Authorized Officer, also of the City of Monrovia, Liberia...MOVANT MOTION FOR THE ENLARGEMENT OF TIME City of Monrovia, Liberia...RESPONDENT GROWING OUT OF THE CASE City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant RESPONDENT=S RESISTANCE ACTION OF DAMAGES FOR WRONG Respondent, in the above-entitled proceedings, denies the legal and factual sufficiency of Movant=s Motion, and prays Your Honor to deny, overrule and dismiss said Motion for Enlargement of Time, for legal and factual reasons, showeth the following, to wit: 1. That as to the entire Motion, Respondent says that he has filed a verified Resistance to the Motion/Application for Special Appearance and respectfully requests Court to take judicial notice of same. 2. Further to count one (1 of ths Resistance, Respondent says the entire Motion is a fit and proper subject for dismissal as our law clearly stipulates that Awhen under this title or by a notice given thereunder or by order of court an act is required or allowed to be done at or within a specified time, the court for cause shown may, except as otherwise provided by law, at any time in its discretion: (a order the period enlarged if application is made before the expiration of the period originally prescribed or as extended by previous order, or (b upon motion made after the expiration of the prescribed period permit the act to be done when the failure to act was the result of excusable neglect@. Civil Procedure Law, 1 L.C.L. Rev., tit. 1, section 1.7(2 ( That as to counts one (1 through eight (8 of the Motion, Respondent says that same should be denied and dismissed because Movant=s Application is not made before the expiration of the period originally prescribed or as extended by previous order; and Movant=s explanation does not qualify it to be placed within the exception of excusable neglect. 4. Further to count three (3 herein above, Respondent says ignorance of the law is no excuse; and that Movant=s explanation avers and confirms that it did not have a lawyer and waited for a date close to March 15, 2010, the formal opening day of Court, to contact and retain the services of a lawyer. Page 2 of 2 5. Further to count four (4 of this Resistance, Respondent says that Movant, who was duly served on the 27 th day of January, 2010, should have filed its Answer on or before the 6 th day of February, A. D. 2010, as stipulated in the Writ of Summons; but up to and including the 8th day of February, A. D. 2010, had failed and refused to file Answer. Copy of the Writ of Summons, with the Returns indicated on the back of same and Clerk=s Certificate in verification of the averment herein

11 contained, are hereto attached in bulk and marked Respondent=s Exhibit AR/1". 6. Further to count five (5 herein above, Respondent says that in a long line of cases, our Supreme Court has held that the Returns of the Sheriff/Ministerial Officer will be deemed authentic, in the absence of any proof to the contrary, and mere assertion is not sufficient to rebut such presumption. Perry vs. Ammons, 16LLR 268 (1956, Jeto Liberian Clothing vs. Breckwoldt and Company (Liberia, Ltd. 20LLR 509 ( Further to count six (6 of this Resistance, Respondent says that the Movant, having been duly served, is under the jurisdiction of the Court and, therefore, its refusal to file an answer places it on bare denial. 8. Respondent says Movant is not entitled to an enlargement of time and it Motion for the Enlargement of Time should be denied. 9. Respondent denies all and singular the averments of fact and law contained in Movant=s Motion and which may not have been specifically traversed in this Resistance. WHEREFORE, and in view of the foregoing laws, facts and circumstances, Respondent prays this Honourabele Court and Your Honour to overrule, set aside and quash Movant=s Motion, and grant unto Respondent such other and further relief as to this Court may seem just and equitable Respectfully submitted, The above named Respondent, by and through Himself and His Counsel: DEAN & ASSOCIATES, INC. Necular Y. Edwards F. Musah Dean, Jr.. Pro-se Bindu E. Clark ATTORNEY-AT-LAW DATED THIS 22nd DAY OF MARCH, A.. D $5.00 Revenue Stamp Affixed on the Original. REPUBLIC OF LIBERIA IN THE OFFICE OF THE JUSTICE OF THE PEACE FOR MONTSERRADO COUNTY AND IN MONTSERRADO COUNTY, CITY OF MONROVIA, LIBERIA SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...MOVANT

12 MOTI0N FOR THE ENLARGEMENT OF TIME City of Monrovia, Liberia...RESPONDENT GROWING OUT OF THE CASE City of Monrovia, Liberia...Plaintiff SN Brussels Airlines, by and thru its Country Manager, Frederic Vloeberghs or any Authorized Officer, also of the City of Monrovia, Liberia...Defendant RESPONDENT=S AFFIDAVIT ACTION OF DAMAGES FOR WRONG PERSONALLY APPEARED BEFORE ME, a duly qualified and commissioned Justice of the Peace, for and in Montserrado County, at my Office, in the City of Monrovia, Necular Y. Edwards, Counsellor-At-Law, and one of counsel for Respondent in the above-entitled cause of action, and made Oath according to law that all and singular the allegations of both law and facts, as set forth and contained in the annexed and foregoing RESPONDENTS= RESISTANCE are true and correct to the best of his knowledge and belief; and as to those matters of information, he verily believes them to be true and correct. Sworn and Subscribed to before me, this 22 ND day of March, A. D Justice of the Peace for Montserrado County, R.L. Necular Y. Edwards AND ONE OF COUNSEL FOR RESPONDENTS/ DEPONENT $4.00 REVENUE STAMP AFFIXED ON THE ORIGINAL.