Fitzgerald v. Congleton

Annotate this Case
 NOTICE:  This opinion is subject to motions for reargument under V.R.A.P.
40 as well as formal revision before publication in the Vermont Reports.
Readers are requested to notify the Reporter of Decisions, Vermont Supreme
Court, 111 State Street, Montpelier, Vermont 05602 of any errors in order
that corrections may be made before this opinion goes to press.



                                No. 86-558


Judy W. Fitzgerald                           Supreme Court

     v.                                      On Appeal from
                                             Chittenden Superior Court

William G. Congleton                         May Term, 1988


Hilton H. Dier, Jr., J.

Jane Watson, Burlington, for plaintiff-appellant

Paradis, Coombs & Fitzpatrick, Essex Junction, for defendant-appellee


PRESENT:  Allen, C.J., Peck, Gibson, Dooley, JJ., and Barney, C.J. (Ret.),
          Specially Assigned


     GIBSON, J.   Plaintiff, Judy W. Fitzgerald, appeals from a decision of
the trial court that her claim for legal malpractice was barred by 12 V.S.A.
{ 512(4).  We hold that plaintiff's claim is not barred in its entirety,
and, accordingly, reverse.
                                    I.
     On September 28, 1981, attorney William G. Congleton, defendant, was
paid a retainer to represent plaintiff and her husband in a juvenile pro-
ceeding in which the State alleged that their son was a child in need of
care and supervision.  The proceeding was held that same date, and on behalf
of his clients, defendant admitted certain allegations of the petition at
the hearing.  Plaintiff asserts that those admissions resulted in the loss
of custody of her son.  On October 1, 1981, plaintiff and her husband
discharged defendant as their attorney.  They retained new counsel, who
succeeded in having the juvenile proceeding dismissed in March of 1982.
     In January of 1984, plaintiff and her husband retained yet another
attorney to represent them in various claims arising from the juvenile
proceeding.  This attorney corresponded with defendant regarding a potential
legal malpractice claim against defendant.  On September 20, 1984, defendant
agreed to toll the statute of limitations for sixty days in order to attempt
a resolution of the dispute prior to the filing of a formal complaint.  The
waiver, however, only addressed claims by plaintiff's husband against
defendant; it did not include a waiver of the statute of limitations
regarding any claim by plaintiff.(FN1)  On November 18, 1984, plaintiff and her
husband initiated a lawsuit against defendant, alleging legal malpractice.
The complaint claimed a "breach of contract, negligence and violation of the
Code of Professional Responsibility."  Plaintiff and her husband sought
damages for "emotional distress, . . . personal humiliation and lost
custody of their son."  They also set out a claim for punitive damages.
     Defendant moved to dismiss on the basis that the cause of action was
barred by the three-year statute of limitations, 12 V.S.A. { 512(4). (FN2)
Plaintiff and her husband argued that the statute had been tolled by
defendant's agreement to extend the limitations period by sixty days, and
that, in any event, the applicable statute of limitations was not 12 V.S.A.
{ 512(4), but rather, the six-year statute of limitations, 12 V.S.A. { 511.(FN3)
The trial court initially denied defendant's motion to dismiss on the basis
that the statute of limitations had been waived, and declined to decide
which statute applied to the facts of the instant case.
     Defendant filed a motion for reconsideration, asserting that the waiver
of the statute applied only to plaintiff's husband and not to plaintiff.
The court granted defendant's motion for reconsideration, elected to treat
the motion to dismiss as one for summary judgment, and entered summary
judgment against plaintiff, finding that her claim was barred by { 512(4).(FN4)
Plaintiff, however, had been given no notice of the motion for reconsid-
eration.  Upon being informed of the entry of summary judgment against her,
plaintiff immediately objected, and the trial court allowed her additional
time in which to respond to defendant's motion.  After plaintiff's response,
which included her affidavit, several other documents and a brief on the
issue, the court reaffirmed its decision to grant summary judgment to
defendant, and severed plaintiff's claim from her husband's claim so that an
appeal of the order could be taken to this Court.
     Plaintiff raises four issues on appeal: (1) the trial court erred when
it failed to apply the six-year statute of limitations, { 511; (2) the court
erred in granting summary judgment without notice or hearing on the
question; (3) there exist genuine issues of material fact which make the
grant of summary judgment improper; and (4) the application of { 512(4) to
her case violates plaintiff's rights to an open court and a remedy at law as
guaranteed by the Vermont Constitution.  We hold that the trial court erred
in failing to apply the six-year statute of limitations to those claims that
were for other than personal injuries.
                                    II.
     While this Court has not previously considered which statute of
limitations should apply to attorney malpractice claims, it is not the first
time the Court has grappled with the differences between { 512(4) and the
more general provisions of { 511.  Section 512 enumerates five types of
actions covered by the three-year statute -- assault and battery, false
imprisonment, slander and libel, injury to the person, and damage to
personal property -- whereas { 511 is a catchall statute that applies to
civil actions generally, "except as otherwise provided."  Because { 511
applies to both tort and contract causes of action, it is not possible to
decide which limitations period to apply to a malpractice action solely on
the basis of whether the action sounds in tort or contract.  See, e.g.,
Union School Dist. No. 20 v. Lench, 134 Vt. 424, 425, 365 A.2d 508, 509
(1976) (in action against architect for negligent design of roof, Court
agreed with parties that "whether the action sounds in tort or contract,"
the applicable statute of limitations was 12 V.S.A. { 511, the general
statute).
     Other jurisdictions have taken a variety of approaches to this issue.
See generally Koffler, Legal Malpractice Statutes of Limitations: A Critical
Analysis of a Burgeoning Crisis, 20 Akron L. Rev. 209, 229-36 (1986)
(analyzing various states' approaches to determining the applicable statutes
 of limitations in attorney malpractice actions).  Some states have adopted
a statute of limitations specifically limited to actions for attorney
malpractice, see, e.g., Cal. Civ. Proc. Code { 340.6 (1982), while other
states have adopted broad professional malpractice statutes of limitations
that includes attorney malpractice actions.  See, e.g., Fla. Stat. Ann. {
95.11(4)(a) (1982).
     In states having no statute governing malpractice actions, as such, the
jurisdictions are split as to whether their tort, contract or general
statute of limitations should apply.  Compare, e.g., Long v. Buckley, 129
Ariz. 141, 143, 629 P.2d 557, 559 (Ariz. Ct. App. 1981) (attorney malprac-
tice actions are governed by tort, not contract, statute of limitations) and
Hillhouse v. McDowell, 219 Tenn. 362, 371-72, 410 S.W.2d 162, 166 (1966)
(client's action against attorney for failure to prosecute personal injury
suit within statute of limitations was not governed by one-year, personal-
injury statute of limitations, but rather by six-year statute relating to
contracts) with, e.g., Dolce v. Gamerdino, 60 Ill. App. 3d 124, 126, 376 N.E.2d 273, 275 (1978) (attorney malpractice actions come under the general
statute of limitations).  In such jurisdictions, most courts permit a
plaintiff to elect between the contract and tort limitations periods
depending on how the complaint is framed.  See Note, Attorney Malpractice,
63 Colum. L. Rev. 1292, 1308-09 (1963).  We find these categorizations are
not helpful, given our precedent of looking to the nature of the harm
suffered rather than the theory alleged by complainant and the fact that our
general statute of limitations applies to both tort and contract causes of
action.
     This Court recently reiterated the principle, long followed in this
jurisdiction, that the "nature of the harm done is the determining factor in
construing the two limitations provisions [{{ 511 and 512], rather than the
[party's] characterization of the action." (FN5) Stevers v. E.T. & H.K. Ide Co.,
148 Vt. 12, 13, 527 A.2d 658, 659 (1987).  Stevers, an action for damages to
personal property (livestock) under { 512(5), relied on Kinney v. Goodyear
Tire & Rubber Co., 134 Vt. 571, 367 A.2d 677 (1976), which discussed the
concept in more detail and observed that "since at least 1915, the applica-
bility of [12 V.S.A. { 512] has been predicated upon the nature of the harm
for which recovery is sought and not upon the nature of the action brought."
Id. at 575, 367 A.2d  at 680.  In Kinney, the plaintiff had received personal
injuries caused by the bursting of a new tire that he was mounting, and the
issue was whether { 512(4) applied to a products liability action for per-
sonal injury damages even though the complaint labeled the action as one
for breach of warranty.  The Court held that the determination of which
limitation period applied did not depend upon whether the action sounded in
contract or tort since the nature of the harm -- there, injury to the person
-- was the same under either theory.  Id.
     The "nature of the harm" was not difficult to determine in Kinney,
where the plaintiff had suffered bodily injuries, and the decision clearly
showed the governing principle behind the Court's holding: the three-year
statute of limitations would apply "[w]here the injury is personal." Id. at
576, 367 A.2d  at 680.  The term is more difficult to apply to a case like
the one now before the Court, where the complaint contains a mixture of
allegations that do not fit neatly into one pigeonhole.

                                   III.
     In the instant case, plaintiff alleges that, as a result of defendant's
"breach of contract, negligence, and a violation of the Code of Professional
Responsibility," she suffered emotional distress, personal humiliation, and
the loss of custody of her son for a period in excess of five months.  She
seeks both compensatory and punitive damages.  She contends that she "did
not get what she bargained/contracted for, that is, effective legal repre-
sentation."  She further maintains that her interests "are largely intangi-
ble, not physical or bodily injury and not injury to personal property," and
that { 511, the six-year statute of limitations, is therefore controlling.
Plaintiff also argues that the loss of legal custody of her child makes this
case similar to those cases where a plaintiff has lost legal rights, such as
the loss of a chose in action.  See Higa v. Mirikitani, 55 Haw. 167, 170,
517 P.2d 1, 4 (1973) ("virtually all claims for legal malpractice [concern]
a non-physical injury to an intangible interest of the plaintiff") (emphasis
in original); Neel v. Magana, Olney, Levy, Cathcart & Gelfand, 6 Cal. 3d 176, 182, 491 P.2d 421, 424, 98 Cal. Rptr. 837, 840 (1971) (legal mal-
practice "usually causes damage to intangible property interests").  She
asserts that one might suffer stress and trauma as a result of the loss of
any legal right, but that that does not make the nature of the harm alleged
into an action for bodily hurt or personal injury.
     Defendant contends that the underlying nature of plaintiff's cause of
action is an "injury to the person" and that it therefore comes under the
three-year statute of limitations, { 512(4).  He argues that plaintiff's
claims are not "intangible," since in order to recover for negligently
caused emotional distress when there has been no physical impact, a claimant
must ordinarily suffer substantial bodily injury or sickness.  See
Vaillancourt v. Medical Center Hosp. of Vt., 139 Vt. 138, 143, 425 A.2d 92,
95 (1980).  In support of his contention that the loss to plaintiff is
purely personal, defendant points to the case of Bland v. Smith, 197 Tenn.
683, 277 S.W.2d 377 (1955).  In Bland, plaintiff sued an attorney for
negligence in the handling of his divorce action, alleging that he not only
sustained the loss of his property, but also suffered great annoyance,
aggravation, embarrassment, humiliation and mental anguish.  In looking to
determine "the real purpose or the gravamen of the action," id. at 686, 277 S.W.2d  at 379, the Tennessee Supreme Court concluded that the plaintiff
based his cause of action on "injuries to his person" and therefore the one-
year statute in suits "for personal injuries" applied rather than the six-
year statute for contract actions.  Id. at 689-90, 277 S.W.2d  at 380-81.
     The line that delineates the underlying nature of a cause of action is
not always a clearly defined one, particularly in a legal malpractice
action.  See Pancake House, Inc. v. Redmond, 239 Kan. 83, 85, 716 P.2d 575,
578 (1986) (legal malpractice may constitute both a tort and a breach of
contract).  We conclude that the nature of the harm alleged to have been
done to plaintiff herein is mixed -- some of her alleged injuries are
personal injuries within the meaning of { 512(4), while some are not.  A
single complaint may contain multiple causes of action, some of which are
time-barred and some not.  See Bevins v. King, 147 Vt. 203, 204, 514 A.2d 1044, 1045 (1986).  Plaintiff's complaint falls into this category.
     We hold that plaintiff's claims for damages resulting from her mental
anguish, emotional distress, and personal humiliation are time-barred
because they constitute injuries "to the person" within the meaning of {
512(4).  See, e.g., Reed v. Real Detective Pub. Co., 63 Ariz. 294, 306, 162 P.2d 133, 139 (1945) ("It seems to us that the mind of an individual, his
feelings and mental processes, are as much a part of his person as his
observable physical members.  An injury, therefore, which affects the
sensibilities is equally an injury to the person as an injury to the body
would be."); see also Black's Law Dictionary 707 (5th ed. 1979) (term
"personal injury" "may include such injuries to the person as . . . mental
suffering").  We recognize that "the phrase 'injury to the person' has
consistently been applied in its legal sense to cover situations involving
bodily hurt, and not to cover all actions that allege harm that is somehow
personal to the plaintiff." (FN6) Alpstetten Ass'n v. Kelly, 137 Vt. 508, 512,
408 A.2d 644, 646 (1979).  Accordingly, in Alpstetten, this Court applied
the six-year rather than the three-year statute of limitations where the
defendant counterclaimed that he was inconvenienced, harassed and embar-
rassed as a result of the plaintiff's decision to shut off the water supply
to the defendant's vacation home complex.  Id. at 512-13, 408 A.2d  at 646.
The Court held that { 511 applied since the alleged harm centered on an
interference with the use and enjoyment of defendant's property rather than
a bodily injury.  Id.
     Here, the harm for which plaintiff seeks damages is, in part, the
emotional distress that she suffered as a result of defendant's alleged
negligent representation of her interests.  Absent physical contact, one may
recover for negligently caused emotional distress only when the distress is
"accompanied by substantial bodily injury or sickness."  Vaillancourt, 139
Vt. at 143, 425 A.2d  at 95.  Accordingly, one must show some physical effect
of any claimed emotional injury -- some bodily hurt -- in order to prevail.(FN7)
     We note that some courts have permitted plaintiffs to recover for
emotional distress under insurance policies providing coverage for "bodily
injury."  See California Mut. Ins. Co. v. Robertson, ___ Cal. App. 3d ___,
___, 262 Cal. Rptr. 173, 178 (1989) ("bodily injury," as term is used in
insurance policies, can result from emotional distress); Bloodworth v.
Carroll, 455 So. 2d 1197, 1205 (La. App. 1984) ("definition of bodily
injury includes mental anguish, fright, distress and humiliation"); cf.
State Farm Fire & Cas. Co. v. Westchester Inv. Co., 721 F. Supp. 1165, 1167
(C.D. Cal. 1989) (physical manifestations of emotional distress -- dry
throat, knot in stomach, rise in body temperature -- constitute bodily
injury; therefore, insurer is potentially liable for renter's claim of
emotional distress resulting from discrimination); but see Aetna Cas. &
Sur. Co. v. First Sec. Bank of Bozeman, 662 F. Supp. 1126, 1128 (D. Mont.
1987) (allegations of emotional distress do not fall within definition of
"bodily injury" in insurance policy); St. Paul Fire & Marine Ins. v.
Campbell County School, 612 F. Supp. 285, 287 (D. Wyo. 1985) (same).  The
rationale for including emotional distress within the term "bodily injury"
is that it is often difficult, even for doctors, to distinguish between
mental and physical injuries, since emotional disturbances have physical
aspects and physical disturbances have emotional aspects.  Abellon v.
Hartford Ins. Co., 167 Cal. App. 3d 21, 27, 212 Cal. Rptr. 852, 855 (1985);
see also W. Keeton, Prosser and Keeton on Torts { 12 at 56 and { 54 at 361
(5th ed. 1984) (mental injuries have physical symptoms capable of objective
proof).  According to these courts, the physical effects of emotional dis-
tress are sufficient to satisfy the "bodily injury" requirement.  Abellon,
167 Cal. App. 3d  at 27, 212 Cal. Rptr.  at 856.
     Based on the foregoing considerations, we conclude that, for purposes
of limitations on actions, a claim for damages resulting from emotional
distress is an "injury to the person" and must be commenced within three
years after the cause of action accrues.  Whether the physical effects of
an alleged emotional injury are severe enough to warrant an award of com-
pensatory damages is a question of fact for the jury, see id. at 27, 212 Cal. Rptr.  at 855; determining the appropriate statute of limitations does
not depend upon resolution of this question.  Accordingly, plaintiff's claim
for damages resulting from emotional distress and personal humiliation are
barred by { 512(4).
     Some of the damages sought by plaintiff, however, are for economic
losses that do not constitute personal injuries.  These claims involve the
costs incurred by her to secure the return of her child, including such
expenses as her attorney's fees.  Not being claims for personal injury,
they fall under the limitations provisions of { 511.  Since plaintiff was
precluded from pursuing such claims by the court's ruling, this matter must
be remanded for further proceedings on those issues.
                                    IV.
     Plaintiff contends that the trial court erred in granting summary
judgment to defendant without notice or a hearing on defendant's motion.
While the procedure followed in this matter was not exemplary, the remedial
measures taken by the court after discovering the lack of notice to
plaintiff were sufficient to cure the defect.  The court converted
defendant's motion to dismiss into a motion for summary judgment by
examining matters outside of the pleadings.  See V.R.C.P. 12(c).  Upon
converting a motion to dismiss to one for summary judgment, the court must
notify the parties as to the changed status of the motion, and give them a
reasonable opportunity to submit extra-pleading materials as permitted by
V.R.C.P. 56(e).  Bennett v. Travelers Ins. Co., 138 Vt. 189, 191, 413 A.2d 1208, 1209 (1980).  See generally 5 C. Wright & A. Miller, Federal Practice
and Procedure, Civil { 1366 (1969) (analysis of virtually identical federal
rule).  While the court originally did not notify plaintiff as to the change
in status of the motion, the court did allow her a reasonable opportunity to
respond to defendant's motion after becoming aware of the error.  Plaintiff
thereafter presented an affidavit and certain documentary evidence, together
with a brief.  A hearing on the motion was not required.  V.R.C.P. 78(b)(2);
see Reporter's Notes 1984 Amendment to V.R.C.P. 56(c).  The procedural
defect having been cured, there was no reversible error.
                                    V.
     Plaintiff also asserts that genuine issues of material fact existed
which should have precluded the grant of summary judgment.  Summary judgment
is appropriate only when the material properly before the court clearly
shows that there is no genuine issue as to any material fact.  Miller v.
Merchants Bank, 138 Vt. 235, 237, 415 A.2d 196, 198 (1980).  The moving
party has the burden of proving, both before the trial court and on appeal,
that no disputed issues of material fact exist.  Sykas v. Kearns, 135 Vt.
610, 612, 383 A.2d 621, 623 (1978).  All reasonable doubts and inferences
are to be resolved in favor of the nonmoving party in determining whether a
genuine issue exists as to any material fact.  Pierce v. Riggs, 149 Vt. 136,
139, 540 A.2d 655, 657 (1987).  A defendant moving for summary judgment
satisfies his legal burden when he presents at least one legally sufficient
defense that would bar plaintiff's claim as a matter of law, and shows that
the case involves no genuine issues of material fact.  See Smith v. Day, 148
Vt. 595, 596-97, 538 A.2d 157, 158 (1987).
     Plaintiff asserts that the question as to the applicability of { 512(4)
is a genuine issue of a material fact.  While this question was certainly at
issue, the applicability of a statute of limitations is a matter of law for
the court to decide.  Where, as here, the underlying facts are not in dis-
pute, a controversy over what law applies would not preclude a grant of
summary judgment.  Tierney v. Tierney, 131 Vt. 48, 51-52, 300 A.2d 544, 547
(1978).
     Three other factual issues advanced by plaintiff -- whether the joinder
of plaintiff's claim with her husband's claim for malpractice amounted to a
pro se motion to join a party under V.R.C.P. 15(c), whether plaintiff's
husband was plaintiff's agent for purposes of defendant's waiver, and the
date of the accrual of the cause of action against defendant -- were not
raised before the trial court, and thus will not be considered on appeal.
See Liberles v. County of Cook, 709 F.2d 1122, 1126 (7th Cir. 1983) (well-
settled rule is that party opposing summary judgment motion must inform
trial court of reasons, legal and factual, why summary judgment should not
be entered, and if it does not do so, and loses the motion, it cannot raise
such reasons on appeal); Lanphere v. Beede, 141 Vt. 126, 129, 446 A.2d 340, 341 (1982) (contentions not raised or fairly presented to trial court are
not preserved for appeal).
     Plaintiff's claim of fraudulent concealment does not create a genuine
issue of material fact, even resolving all reasonable doubts and inferences
in plaintiff's favor.  This contention is not supported by the record and
was not supported by the evidence plaintiff submitted to the trial court.
     There were thus no genuine issues of material fact before the trial
court, and defendant has asserted a valid defense -- the three-year statute
of limitations -- which would entitle him to summary judgment as a matter of
law on plaintiff's claims for personal injury.  The court did not err in
entering summary judgment against plaintiff on such claims.
                                    VI.
     Finally, plaintiff argues that to apply the three-year statute of
limitations to her, so as to bar her suit, would violate her rights under
the Vermont Constitution.  Plaintiff claims a violation of her constitu-
tional right to a remedy at law, Vt. Const. ch. I, art. 4, and her right to
an open court, Vt. Const. ch. II, { 28, yet plaintiff fails clearly to
delineate how her rights under these provisions have been violated.  We have
often stated that we will not consider state constitutional issues which
have been inadequately briefed.  See, e.g., State v. Gabaree, 149 Vt. 229,
231 n.2, 542 A.2d 272, 273 n.2 (1988).  The merits of the issue herein have
not been made sufficiently apparent to warrant further briefing or the
further attention of this Court.  See State v. Jewett, 146 Vt. 221, 225, 500 A.2d 233, 236 (1985).  Accordingly, we do not consider the state constitu-
tional question. (FN8)
     Reversed and remanded.




                                        FOR THE COURT:


                                        _________________________________
                                        Associate Justice




FN1.    A copy of the complaint that was submitted to defendant with the
request for waiver contained only the name of Daniel Fitzgerald as
plaintiff.

FN2.   12 V.S.A. { 512 provides: "Actions for the following causes shall be
commenced within three years after the cause of action accrues, and not
after: . . . (4) Injury to the person suffered by the act or default of
another, except as otherwise provided in this chapter . . . ."

FN3.   12 V.S.A. { 511 provides: "A civil action, except one brought upon
the judgment or decree of a court of record of the United States or of this
or some other state, and except as otherwise provided, shall be commenced
within six years after the cause of action accrues and not thereafter."

FN4.   The trial court initially stated that { 511, not { 512(4), applied,
but this obvious error was corrected upon motion by the parties.

FN5.   This approach is analogous to that taken in some other jurisdictions.
See, e.g., Giffin v. United Transp. Union, 190 Cal. App. 3d 1359, 1362, 236 Cal. Rptr. 6, 7 (1987) (applicable statute of limitations is determined by
substance or gravamen of the action, rather than by the form of the
pleading); Serrano v. Flight Motel, Inc., 95 Misc. 2d 669, ___, 408 N.Y.S.2d 198, 201 (N.Y. Sup. Ct. 1978) (in determining which statute of limitations
governs an action, court will look to the reality and essence of the action
and not to its name).

FN6.    Prior to the 1947 revision of the Vermont Statutes, the predecessor
statute to 12 V.S.A. { 512(4) mandated a three-year statute of limitations
for "recovery of damages for bodily hurt or injury to personal property
suffered by a person."  P.L. { 1649 (emphasis added).  Because the change in
language was accomplished during a general revision of the statutes rather
than by direct amendatory action by the Legislature, one could argue that
the change in language from "bodily hurt" to "injury to the person" was not
intended to change the meaning of the statute.  See Town of Cambridge v.
Town of Underhill, 124 Vt. 237, 240, 204 A.2d 155, 157 (1964) ("When changes
come about only as a result of a revision, caution is required in deter-
mining whether or not any substantive change in the law was intended.").  In
light of our determination herein, we need not consider whether the change
in language effected a substantive change in the statute.

FN7.    By this statement, we do not necessarily foreclose the possibility
of allowing for emotional-distress damages absent physical manifestations
under special circumstances where the nature of the tortious act guarantees
the genuineness of the claim.  See W. Keeton, Prosser and Keeton on Torts {
54 at 362 (5th ed. 1984) (discusses actions for negligent transmission of a
message, especially one announcing death, and negligent mishandling of
corpses).

FN8.   We note, without deciding, that states which have a constitutional
provision similar to that set forth in chapter I, article 4 of the Vermont
Constitution have found no violation of this provision for statutes of
limitations that bar lawsuits after a reasonable length of time has elapsed
following discovery of a cause of action.  See, e.g., Overland Construction
Co. v. Sirmons, 369 So. 2d 572, 574-75 (Fla. 1979).

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.