98-003521 Division Of Real Estate vs. Judy K. Palmer Status: Closed Recommended Order on Thursday, December 17, 1998.

Summary: Respondent told seller deposit was being returned to buyer but told buyer deposit was being forfeited to seller. Some escrow charges didn`t apply because transactions didn`t involve real estate.

STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

DEPARTMENT OF BUSINESS AND )

PROFESSIONAL REGULATION, DIVISION )

OF REAL ESTATE, )

)

Petitioner, )

)

vs. ) Case No. 98-3521

)

JUDY K. PALMER, )

)

Respondent. )

___________________________________)

)

DEPARTMENT OF BUSINESS AND )

PROFESSIONAL REGULATION, DIVISION )

OF REAL ESTATE, )

)

Petitioner, )

)

vs. ) Case No. 98-3522

)

JUDY K. PALMER and ERA SOLUTIONS )

IN REAL ESTATE, INC., )

)

Respondents. )

___________________________________)

RECOMMENDED ORDER

On October 13, 1998, a formal administrative hearing was

held in these cases in Lakeland, Florida, before J. Lawrence

Johnston, Administrative Law Judge, Division of Administrative

Hearings.

APPEARANCES

For Petitioner: Steven W. Johnson, Senior Attorney

Department of Business and

Professional Regulation

Division of Real Estate

Suite N-308A

400 West Robinson Street

Orlando, Florida 32801

For Respondent: Judy K. Palmer

Post Office Box 24734

Lakeland, Florida 33802

STATEMENT OF THE ISSUES

The issues in these cases are whether the Florida Real

Estate Commission should discipline Judy K. Palmer (Palmer) and

her real estate brokerage, ERA Solutions in Real Estate, Inc.

(ERA Solutions in Real Estate), for alleged violations of Chapter

475, Florida Statutes (1997).

PRELIMINARY STATEMENT

On May 20, 1998, the Florida Department of Business and

Professional Regulation, Division of Real Estate (the Petitioner

or Division) filed an Administrative Complaint against Palmer,

FDBPR Case Nos. 97-84801 and 97-85465. On July 13, 1998, the

Petitioner filed an Administrative Complaint against Palmer and

ERA Solutions in Real Estate, FDBPR Case Nos. 97-80764, 98-80700,

and 97-82812. Palmer and ERA Solutions in Real Estate requested

formal administrative proceedings, and the cases were referred to

the Division of Administrative Hearings (DOAH), where they first

were given DOAH Case Nos. 98-3521 and 98-3522 and then were

consolidated. Final hearing was scheduled for October 13, 1998.

At final hearing, the Petitioner called eleven witnesses and

had Petitioner's Exhibits 1 through 12 admitted in evidence.

Palmer testified on behalf of herself and ERA Solutions in Real

Estate. The Petitioner ordered the preparation of a transcript

of the final hearing, and the parties were given ten days from

the filing of the transcript to file proposed recommended orders.

The transcript was filed on November 12, 1998. Only the

Petitioner filed a Proposed Recommended Order.

FINDINGS OF FACT

1. The charges alleged violations arising out of four

factual settings. At all times material to the charges, the

Respondent, Judy K. Palmer (Palmer), was a licensed Florida real

estate broker under license number 0574496.

2. Palmer was the qualifying broker for Palmer Realty of

Central Florida, Inc. (Palmer Realty), from January 1996 until

Palmer Realty was deactivated. Although the evidence is not

clear, it appears that Palmer Realty was deactivated in June

1996. Palmer claims that she did not intend to deactivate Palmer

Realty in June 1996 but only had her office inquire as to

deactivation procedures.

3. In late 1996 (Palmer testified to late 1997, but she

must have misspoken), Palmer entered into negotiations to

purchase an ERA franchise. Complications arose, and the

transaction was not completed until March 1997. Although it is

alleged in the Administrative Complaint against Palmer that

Palmer applied for licensure of the Respondent, ERA Solutions in

Real Estate, Inc. (ERA Solutions in Real Estate), in March 1997,

it appears from the evidence that Palmer actually applied on

June 13, 1997. The application was approved, and it appears from

the evidence that Palmer became the qualifying broker for ERA

Solutions in Real Estate effective on June 13, 1997.

4. At the same time, Palmer conducted business as a

principal and officer of a brokerage of mobile homes on leased

property, an activity that does not require licensure as a real

estate broker or salesperson. Initially, Palmer conducted her

business through an entity called Affordable Lifestyle Homes,

Inc. (Affordable Lifestyle). At approximately the time she began

to conduct her real estate business through ERA Solutions in Real

Estate in March 1997, Palmer began to conduct her mobile homes

sales business through ERA Solutions, Inc. (ERA Solutions).

5. Palmer testified without contradiction that she was not

a broker in the mobile homes sales business. However, because

her real estate brokerage was conducted in the same building as

her mobile home sales business, customers sometimes confused the

two businesses, and mobile home customers sometimes believed that

they were doing business with the real estate brokerage and that

Palmer also was a broker for the sale of mobile homes on leased

property.

The Hinkles and Conklin

6. The Administrative Complaint against Palmer alleged

violations arising out of the handling of a $1,000 deposit on the

purchase of real property in Lakeland, Florida. A ctually, no

real property was involved. It also was alleged that the deposit

was placed in the Affordable Lifestyles escrow account.

Actually, the money was placed into an ERA Solutions account; it

is not clear from the evidence whether it was an escrow account.

It also was alleged that the deposit eventually was returned to

the buyer; actually, it eventually was returned to the seller.

7. In early 1997, Joanne Conklin went to the offices of

Affordable Lifestyle and Palmer Realty to list and sell a mobile

home on leased property that had belonged to Conklin's recently

deceased father. The evidence indicated that Conklin dealt with

an individual named Bruce Shefler, but it did not seem to be

clear to Conklin whether Shefler worked for Affordable Lifestyle

or Palmer Realty, or both, or whether there was a difference

between the two. Conklin did, however, understand that not all

realtors sold mobile homes on leased property and that her

choices were limited. Starting approximately March 1997, Conklin

began to receive documentation bearing the name of ERA Solutions.

8. Disillusioned with the services she was getting, Conklin

complained to Palmer, who tried to satisfy Conklin by switching

her property to another mobile home salesperson named Sandi

Stone. Still confused as to the relationship between the realty

and the mobile homes sales entity, Conklin appears to have

assumed incorrectly that Shefler and Stone were realtors.

9. On or about July 15, 1997, Don and Janet Hinkle made an

offer to purchase Conklin's mobile home at close to the asking

price, with a $1,000 deposit and a September 1, 1997, closing

date. Conklin considered this to be the first "major offer," and

she was inclined to accept. However, Conklin did not think the

deposit was enough to take the property off the market for the

September closing date.

10. It is not clear from the evidence what happened at that

point. Conklin thought the closing date was being changed to

August 16, 1997, to allay her concerns. The face of the contract

itself also indicates such a change of the closing date; however,

it is not clear whether the change was made before or after the

Hinkles signed the contract, or if the change ever was presented

to them. Stone accepted the Hinkles' deposit by check made

payable to ERA Solutions and placed the money in an ERA Solutions

bank account. It was not clear if it was an escrow account.

11. Shortly before August 16, 1997, Stone telephoned

Conklin and told her that the Hinkles' financing had been delayed

and that closing would have to be delayed until September 1,

1997, after all. Conklin was upset and telephoned the Hinkles

directly to inform them that she would require an additional

deposit to hold the property off the market until September 1,

1997. The Hinkles in turn became upset because they professed

not to have any knowledge of a closing prior to September 1,

1997. They also did not like the way the transaction was

proceeding and decided they no longer wanted to buy Conklin's

mobile home.

12. When told that the Hinkles would not close the

contract, Conklin asked Palmer for the $1,000 deposit. Palmer

told Conklin that that the property would go back on the market

and that the deposit would be returned to the Hinkles.

13. When the Hinkles asked for the $1,000 deposit, Palmer

told them that the deposit would be paid to Conklin and that the

Hinkles might also have to pay for the mobile home. Based on

this advice, the Hinkles felt that they were at the mercy of

Conklin as to the return of the deposit.

14. Palmer did not report to the Florida Department of

Business and Professional Regulation, Division of Real Estate

(the Division), that the demands had been made for the return of

the deposit.

15. The Hinkles complained to the Division that their

deposit had not been returned. During the investigation of the

Hinkles' complaint, Palmer returned the deposit to them on

December 11, 1997. Conklin did not object to the return of the

deposit but would have objected to Palmer, ERA Solutions in Real

Estate, ERA Solutions or Affordable Lifestyle keeping it.

The Snow Contract

16. The Administrative Complaint against Palmer alleged

that Palmer continued to conduct business as Palmer Real Estate

after it was deactivated by entering into a listing contract with

the Snows between November 1996 and March 1997. But the

Administrative Complaint alleged in two places that deactivation

occurred on June 20, 1997. Palmer Real Estate actually appears

to have been deactivated in June 1996, perhaps accidentally. See

Finding 2, supra .

17. Palmer and Palmer Real Estate performed the Snow

listing contract without any problems and to the satisfaction of

the Snows.

The Karolishyn Contract

18. The Administrative Complaint against Palmer alleged

that Palmer conducted business as ERA Solutions in Real Estate

before it was licensed.

19. On or about March 13, 1997, Palmer, on behalf of ERA

Solutions in Real Estate, entered into a listing contract with

Beatrice Karolishyn.

20. Palmer and ERA Solutions in Real Estate performed the

Karolishyn listing contract without any problems and to the

satisfaction of Karolishyn.

Alleged Misappropriation of Escrow Funds

21. In addition to the allegations against Palmer arising

out of the Conklin/ Hinkles transactions, the Administrative

Complaint against Palmer and ERA Solutions in Real Estate alleged

specific as well as wholesale misappropriation of escrow funds.

22. The Administrative Complaint against Palmer and ERA

Solutions in Real Estate alleged that, on or about December 31,

1997, Donald J. (Jack) Miller, a salesperson employed by the

Respondents, accepted a $100 deposit from Geneva McCoy on the

purchase of a mobile home on leased property. It further alleged

that, prior to closing, the Respondents converted the $100 to

their own use and that the sellers were unable to fund the

purchase of tags and title.

23. The evidence was that, after the McCoy deposit, the

sale of Palmer's ERA franchise to another broker was initiated,

and there was confusion as to whom McCoy was supposed to write

her check for the balance of the purchase. In addition, McCoy

wanted title to the mobile home to be taken in the names of both

her and her son; title was delayed while information required by

the Department of Highway Safety and Motor Vehicles was obtained

from her son. There was no evidence that the $100 deposit had

anything to do with the delay in obtaining title to the mobile

home.

24. On or about February 4, 1998, Palmer's ERA franchise

was transferred to another broker. Miller was permitted to, and

chose to, join the successor franchisee. At the McCoy closing,

Miller discovered that McCoy was $100 short because the deposit

had not been made available for the closing. Miller paid the

$100 out of his own pocket.

25. The Administrative Complaint against Palmer and ERA

Solutions in Real Estate also alleged that, on or about

February 10, 1998, Miller accepted a $1,000 deposit from Maxine

Reed on the purchase of real property from Barbara L. McCarty.

In fact, as reflected in the sales contract and deposit check

attached to the Administrative Complaint, and confirmed by the

evidence presented at the hearing, the deposit was accepted on or

about January 17, 1998.

26. When the McCarty/Reed transaction closed on

February 20, 1998, Mille r participated in the closing in his new

capacity as salesperson for the successor broker. As with the

McCoy deal, the deposit was not made available for the closing.

In order to proceed with the closing, Miller had to charge back

the $1,000 against the broker's sales commission.

27. The evidence was that, after agreeing to sell her ERA

franchise to another broker, Palmer attempted to renege and

rescind the sale. She took the position that, at the time of the

agreement, she was not thinking clearly because she was on

medication for continuing emotional difficulties from the sudden

and tragic death of her daughter in a car accident in 1994.

Palmer sought to rescind the sale and viewed the transaction as a

hostile takeover against her will.

28. The evidence did not prove why the McCoy and Reed down

payments were not available for their closings. The money

apparently remained in the ERA Solutions in Real Estate escrow

account. On or about March 18, 1998, after both the sale of the

ERA franchise and the closings, Palmer withdrew all funds from

her ERA brokerage accounts (including the ERA Solutions in Real

Estate and ERA Solutions escrow accounts) and closed the

accounts. She used the funds in the account for her own

purposes. These funds included the McCoy and Reed deposits.

29. It was Palmer's position that the successor broker was

responsible for making the funds available for the closings and

that the money in the ERA brokerage accounts rightfully belonged

to her. There was no evidence as to the terms of the sale of the

ERA franchises or the contemplated handling of the escrow funds.

There also was no evidence that either Miller or the successor

broker made a claim to the funds.

30. There also were general allegations in the

Administrative Complaint against Palmer and ERA Solutions in Real

Estate that the Respondents wrote payroll checks out of the ERA

Solutions in Real Estate escrow account at Barnett Bank between

August 1997 and January 1998. However, those allegations were

not proven.

31. There also were general allegations in the

Administrative Complaint against Palmer and ERA Solutions in Real

Estate that the Respondents "obtained deposits and

misappropriated the deposits by improperly disbursing them to the

operating account at Barnett Bank and/or by directly converting

them to the use of the Respondent Judy K. Palmer." The only

evidence of such a direct conversion of escrow funds was that

Palmer once wrote a $200 to $400 check out of the escrow account

for a personal health insurance premium. However, another broker

brought this to Palmer's attention, and Palmer replaced the

money, saying she accidentally had picked up the wrong check

book. The evidence was that this occurred in December 1996,

before Palmer began operating as ERA Solutions in Real Estate.

32. There also were general allegations in the

Administrative Complaint against Palmer and ERA Solutions in Real

Estate that the Respondents "converted approximately $14,200 in

trust funds to the Respondents' general account and/or to

Respondent Judy K. Palmer's own use." As reflected in the bank

statement attached to the Administrative Complaint, the evidence

proved that $14,200 was transferred out of the ERA Solutions in

Real Estate escrow account during July 1997, but the evidence did

not prove who transferred the funds, where the funds were

transferred, or what they were used for.

33. The Administrative Complaint against Palmer and ERA

Solutions in Real Estate also alleged that, on or about

January 28, 1998, First Union Bank froze all of the Respondents'

accounts, including escrow accounts, because of checks (including

payroll checks) returned by reason of insufficient funds. The

evidence proved that there was not much activity in the escrow

account but that there was a substantial problem with deposits in

the general accounts and that they were overdrawn by almost

$6,500 at the end of January 1998. There also was evidence that,

as before, vendors were not being paid and were dunning the

brokerage for payment and that checks on the general account were

bouncing, including payroll checks.

CONCLUSIONS OF LAW

34. The burden is on the Division to proved its charges by

clear and convincing evidence. Ferris v. Turlington , 510 So. 2d

292 (Fla. 1987). Moreover, the Division legally cannot find

licensees guilty of violations not charged, making it important

that administrative complaints be accurate and complete. See

Ghani v. Dept. of Health , 714 So. 2d 1113 (Fla. 1st DCA 1998);

Sternberg v. Dept. of Prof. Reg., Bd. of Med. Exam'rs , 465 So. 2d

1324 (Fla. 1st DCA 1985).

The Hinkles and Conklin

35. The charges alleged that Palmer committed the following

violations in connection with the Hinkles/ Conklin transaction:

Count I - Failure to account or deliver

funds, in violation of Section 475.25(1)(d)1,

Florida Statutes (1997);

Count II - Failure to institute one of the

settlement procedures set forth in Section

475.25(1)(d)1, Florida Statutes (1997),

within 30 days after the last demand, in

violation of Florida Administrative Code Rule

61J2-10.032(1) and therefore Section

475.25(1)(e), Florida Statutes (1997);

Count III - Culpable negligence or breach of

trust in any business transaction, in

violation of Section 475.25(1)(b), Florida

Statutes (1997); and

Count IV - Failure to maintain trust funds in

the real estate brokerage escrow bank account

or some other proper depository until

disbursement was properly authorized, in

violation of Section 475.25(1)(k), Florida

Statutes (1997).

36. The evidence is clear that the Hinkles/ Conklin

transaction did not involve real estate but rather a mobile home

on leased property. The requirements for handling real estate

escrow accounts applied to the transaction. See White v. Dept.

of Bus. and Prof. Reg. , 715 So. 2d 1130 (Fla. 5th DCA 1998);

LaRossa v. Dept. Prof. Reg. , 474 So. 2d 322 (Fla. 3d DCA 1985).

37. The evidence proved, however, that Palmer's handling of

the requests from both the Hinkles and Conklin for the return of

the deposit proved at least culpable negligence and breach of

trust in a business transaction, in violation of Section

475.25(1)(b), Florida Statutes (1997). The evidence proved that

Palmer told the Hinkles that they had lost their deposit and told

Conklin that the deposit was being returned to the Hinkles.

Meanwhile, unbeknownst to either, Palmer kept the deposit and did

not return it until the Division investigated the Hinkles'

complaint.

The Snow and Karolishyn Contracts

38. The charges alleged that Palmer committed the following

violations in connection with the Snow and Karolishyn contracts:

Count IV [sic] - Fraud, misrepresentation,

concealment, false promises, false pretenses,

dishonest dealing by trick, scheme or devise,

culpable negligence, or breach of trust in

any business transaction, in violation of

Section 475.25(1)(b), Florida Statutes

(1997); and

Count V [sic] - Operating as a broker under

the name of a corporation or as an officer or

manager thereof, without the corporation

being the holder of a valid current

registration in violation of Section

475.42(1)(k), and therefore in violation of

Section 475.25(1)(e), Florida Statutes

(1997).

39. The evidence as to the Snow contract proved that Palmer

conducted business as Palmer Realty after the deactivation of

that license. The evidence as to the Karolishyn contract proved

that Palmer and ERA Solutions in Real Estate conducted business

as the latter entity before it was licensed. These were both

violations of Section 475.42(1)(k), Florida Statutes (1997).

40. As to both the Snow and Karolishyn contracts, there was

evidence of confusion on the part of Palmer as to the actual date

of deactivation of Palmer Realty, if not also the licensure of

ERA Solutions in Real Estate. Palmer Realty may have been

deactivated accidentally, and Palmer seemed to think application

for licensure of ERA Solutions in Real Estate occurred in March

1998. In any event, the evidence as to these matters did not

prove fraud, misrepresentation, concealment, false promises,

false pretenses, dishonest dealing by trick, scheme or devise,

culpable negligence, or breach of trust in a business

transaction, in violation of Section 475.25(1)(b), Florida

Statutes (1997).

Alleged Misappropriation of Escrow Funds

41. The charges alleged that Palmer and Real Estate ERA

Solutions committed the following violations in connection with

the handling of escrow funds (other than the Hinkles/ Conklin

transaction):

Counts I, II, VII, and VIII - Fraud,

misrepresentation, concealment, false

promises, false pretenses, dishonest dealing

by trick, scheme or devise, culpable

negligence, or breach of trust in any

business transaction, in violation of Section

475.25(1)(b), Florida Statutes (1997);

Counts III, IV, IX, and X - Failure to

maintain trust funds in the real estate

brokerage escrow bank account or some other

proper depository until disbursement was

properly authorized, in violation of Section

475.25(1)(k), Florida Statutes (1997); and

Counts V, VI, XI, and XII - Failure to

account or deliver funds, in violation of

Section 475.25(1)(d)1, Florida Statutes

(1997).

Based on the findings, it is concluded that the evidence may have

proven improper maintenance of trust funds; but the evidence did

not prove either failure to account and deliver, or fraud,

misrepresentation, concealment, false promises, false pretenses,

dishonest dealing by trick, scheme or devise, culpable

negligence, or breach of trust in a business transaction, in

connection with the trust funds.

42. As found, there was confusion as to the status of

Palmer and ERA Solutions in Real Estate around the time of the

McCoy and Reed escrow deposits. After the deposits were made,

Palmer's ERA franchise was sold to another broker; however,

Palmer sought to rescind the sale and viewed the transactions as

a hostile takeover against her will. After the sale of the

franchise, the McCoy and Reed contracts closed. Their down

payments were not available for the closing, but the evidence did

not prove why not. The money apparently remained in the ERA

Solutions in Real Estate escrow account. Long after the

closings, Palmer withdrew the funds and closed the account.

There was no evidence as to the terms of the sale of the ERA

franchise or the contemplated handling of the escrow funds.

There also was no evidence that either Miller or the successor

broker made a claim to the funds.

43. As found, the evidence did not prove that the

Respondents wrote payroll checks out of the ERA Solutions in Real

Estate escrow account at Barnett Bank between August 1997 and

January 1998. The evidence also did not prove who transferred

the $14,200 out of the ERA Solutions in Real Estate escrow

account during July 1997, where the funds were transferred, or

what they were used for. The evidence proved that Palmer once

accidentally wrote a $200 to $400 check out of the escrow account

for a personal health insurance premium, but she replaced the

money when another broker brought the error to her attention.

(Also, this occurred in December 1996, before Palmer began

operating as ERA Solutions in Real Estate.)

44. Finally, as to the chronic nonpayment of vendors and

substantial overdrafts in the general accounts, the evidence did

not prove fraud, misrepresentation, concealment, false promises,

false pretenses, or dishonest dealing by trick, scheme or devise.

However, it was proven that Palmer allowed the business and

finances of ERA Solutions in Real Estate to fall into complete

dissarray. This evidence was sufficient to prove culpable

negligence and breach of trust in business transactions, in

violation of Section 475.25(1)(b), Florida Statutes (1997).

Penalty Guidelines

45. Under Florida Administrative Code Rule 61J2-

24.001(3)(c), the usual penalty for violating Section

475.25(1)(b), Florida Statutes, by fraud, misrepresentation, or

dishonest dealing is revocation; for culpable negligence or

breach of trust, the usual penalty is in the range from an

administrative fine of $1,000 to a one-year suspension.

46. Under Florida Administrative Code Rule 61J2-

24.001(3)(l), the minimum penalty for violating Section

475.25(1)(k), Florida Statutes, is a 90-day suspension and $1,000

administrative fine; the penalty can range up to revocation.

47. Under Florida Administrative Code Rule 61J2-

24.001(3)( dd), the usual penalty for violating Section

475.42(1)(k), Florida Statutes, is in the range from an

administrative fine of $1,000 to a six-month suspension.

48. Under Florida Administrative Code Rule 61J2-

24.001(4)(a), deviation from the usual penalties is permitted if

there are aggravating or mitigating circumstances. Under Florida

Administrative Code Rule 61J2-24.001(4)(b), aggravating or

mitigating circumstances can include, but are not limited to:

1. The severity of the offense.

2. The degree of harm to the consumer or

public.

3. The number of counts in the Administrative

Complaint.

4. The number of times the offenses

previously have been committed by the

licensee.

5. The disciplinary history of the licensee.

6. The status of the licensee at the time the

offense was committed.

7. The degree of financial hardship incurred

by a licensee as a result of the imposition

of a fine or suspension of the license.

8. Violation of the provision of Chapter 475,

Florida Statutes, where in [sic] a letter of

guidance as provided in s. 455.225(3),

Florida Statutes, previously has been issued

to the licensee.

49. The facts in this case, taken as a whole, do not

warrant a departure from the Florida Real Estate Commission's

usual penalties.

RECOMMENDATION

Based upon the foregoing Findings of Fact and Conclusions of

Law, it is

RECOMMENDED that the Florida Real Estate Commission enter a

final order revoking the licenses of Judy K. Palmer and ERA

Solutions in Real Estate, Inc.

DONE AND ENTERED this 17th day of December, 1998, in

Tallahassee, Leon County, Florida.

___________________________________

J. LAWRENCE JOHNSTON

Administrative Law Judge

Division of Administrative Hearings

The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399-3060

[phone] SUNCOM 278-9675

Fax Filing (850) 921-6 847

Filed with the Clerk of the

Division of Administrative Hearings

this 17th day of December, 1998.

COPIES FURNISHED:

Steven W. Johnson, Senior Attorney

Department of Business and

Professional Regulation

Division of Real Estate

Suite N-308A

400 West Robinson Street

Orlando, Florida 32801

Judy Palmer

Post Office Box 24734

Lakeland, Florida 33802

Lynda L. Goodgame, General Counsel

Department of Business and

Professional Regulation

1940 North Monroe Street

Tallahassee, Florida 32399-0792

James Kimbler, Acting Division Director

Division of Real Estate

Department of Business and

Professional Regulation

Post Office Box 1900

Orlando, Florida 32802-1900

NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

All parties have the right to submit written exceptions within 15

days from the date of this Recommended Order. Any exceptions to

this Recommended Order should be filed with the agency that will

issue the final order in this case.