Documents submitted by Iran after the Closure of the Written Proceedings: Comments of an Expert of Iran on the Expert Report of the United States of America

JAN 18 '03 16:17 P.2

.1

BEFORE THE INTERNATIONALCOURT OF JUSTICE

ISLAMlC"REPUBLICOF IRAN

v.

UNITEDSTATESOF AMERICA

OIL PLATFORMSCASE

COMMENTSOF

MOHAMMAD YOUSSEF!

17JANUARY2003JAN 18 '03 16:18 P.3

~ 1~

COMMENTS OF MOHAMMAD YOUSSEFI

1. The undersigned, Mohammad Youssefi, has been requestbythe Govemment of the

IslamicRepublicof Iran to revieand comment on theReport dated18 November
2002ofMs. Deborah Martin (th"DM Report''),filebythe UnitedStateof America

asExhibitNo. 262intheOil PlatformCasebefore the InternatioCourtof Justice.

2. Iam familiar witthe subjectmatterof theDM Reportand havealreadysubmitteda

Statement filed on 10 March 1999 in this case (see the Islamic Republic of Iran's

Reply and Defenceto the Counterclaim, Annex VI, "Youssefi Statement"). I further
confirmthatIam familiarwithaerialandsatelliteimageanalysiand haveregularly

anaiysed aerial and satellite imageries since 1986, including those relating to areas

shawn in the attachments to the DM Report.

3. Below aremy comments on the DM Report and its attachments. I will follow the same

arder as thDM Report.

4. Attachment A is an image showing the intersection of the Kuwaiti, Iraqi and Iranian

terrestrial and maritime borders in the extrerne north-westsian Gulf. In the

left side the image one may see the Kuwaiti islands of Warbah and Bubiyan, and

the vioinlty of the Iraqi port of Umm-ol-Qasr. Khur Abdullah and the Faw peninsula in
the southern part of Iraq as well as the Arvan(Shatt~Al m~yAbe sbn)in

the middlepartof the image.The extreme south~ owIraststerritory, south of JAN 18 '03 16=18 P.4

~2-
1

Abadan oity and the vicinity of the city of Arvand-Kenar c1n be seen in the right side

of the image.

S. Attachment B is an enlargement of the central part of Attachment A. The Faw

peninsula may be seen on the left side, the Arvand River (Shatt Al-Arab) in the middle

and,the extreme south-west of Iranian territory, south of Abadan and Arvand-Kenar, is

visible on the right side.

6. Attachment C is an enlargementof part of AttachrnentB marked as "map inset 2".

7. I have no specifie comment on the above Attachmems.

1
8. Attachment Dis said to be an enlargement of part ofthe area shawn in 'inset2" on 16

October 1987. However,

1. considerh1g the quality ofAttachment C, it is not possible to confirm

that AttachmentD shows an area in Iran or the same area as the one

marked as "Graphie 1"on Attachment C;

11. it is not possible, based on that image, to confirm whether that image

bas been actually taken on 16 October 1987or on any other date.

9. Furthermore 1 thereare insufficient elements to supporthe affirmation that Attaclunent

D represents "HY-2 Cruise Missile Vehicles" as indicated on the top of the image. Of

course, a num.berofvehicles may be distin&lUisheo dn the image. However, the quality
and resolution of the image does not allow me to determine their exact type. It can,

however, be confirmed with certainty that, in any event, the said vehicles do not

constitutecomponents of an HY -2 missile system.Myspecifie comments in these

respects are as follows:JAN 18 '03 16=19 P.S

- 3-

(i) In paxagraph 9 of the DM Report it is affumed that: "the IDP in

Attachment D shows equipment used in launching HY-2 cruise

missiles: a transporterth a canvas-covering ofthe kind typically used

to protecta missile;atransporterwithouta missi twloet~uckstowing
two HY-2 missilelaW1chersa ;ndother supporttrucks."

However, the image submitted as Att.achment D does not support the

affirmationmade asto theexistenceof "atransporterwithouta missile"
on the right side of the upper part of the small raad visible in the center

of the image. Indeed, there isnothing on the image to allow us to

distinguishthe shapeof a vehiclein the locationmarkedwith anarrow

to that effect. Moreover, evenassuming that one is able tadetect a

"transporter" of the kind described in the DM Report in connection
with this Attachment, i.e.l 5 meters long (see the DM Report at §10), at

the place indicated by the arrow on that image, it would be

presumptuous to affinn that such a transporter was used with respect to

HY-2 missiles. Indeed, the transporter of the type described in the DM

Report is not avehtcle exclusively used for transporting missiles, but
rathera multipurpose transporter conunonly used for various military

tasks including transportof differenttypes of heavy equipment and

material, and sometimes even for transport of troops. Hundreds of such

transporters were used on the southern front.

As to the shadows described as "a transporter with a canvas-covering of

the kind typically used to protect a missile", the best one can confirm is

that these shadows would represent one or severa! vehicles. Jt is

however not possible,based on the quality of the image provided, to

state which type of vehicle. However, as mentioned above, even
assuming that one would interpret those shadows as a "transportof"JAN 18 '03 16:20 P.6

-4 ~

the kind described in the DM Report in connection with this

Attachment, i.e. 15 meters long (see the DM Report at §10), it would

again be entirely speculative to affirm that such a transporter was used

with respect ta HY-2 missiles. As I have already mentioned above, the

transporter of the type described in the DM Report is not a vehicle

exclusively used for transporting missiles, but rather a multipurpose

transporter commonly used for various military tasks. Moreover, the

use of a canvas caver is in no way exceptional. Canvas covers were

commonly used by ail kinds of transportees, in particular to protect

items from the harsh sunshine. Indeed, one may note that the trucks

stationed on the opposite side of the raad are also covered by canvas.

However, itis not suggested in the DM Report that these latter trucks

transport missiles.Neither could the presence of "four rib frameworks"

be an indication thata particular transporteis used for HY-2 missiles.

Indeed, these frameworks are necessarily used every time that the

transporters are covered by a canvas, irrespective of what is

transported. Finally, I did not find any support in the image for

affinning that a vehicle, which is said to be covered with a canvas, is

indeed transporting a missile. The only basis for that affirmation seems

to be the presence of a canvas caver. If this is the case, then the

affirmation made in the DM Report is unfounded.

As to the vehicles visible on the left side of the small road in the central

part of the image, labeled as "two trucks towing two HY-2 missile

launchers", I would agree that indeed two trucks are visible on the

image. lt can also be said that each of these trucks is towing one or two

trailersIf there are two trailers then the trailer directly attached to the

first truck would have s length equal to half of that of the first truck,

i.e., approximately 3.5 meters. Thus, in such a case the trailer is

certain!y not an HY ~2launcher, which should be substantially longer

than a truck. In the second event, i.e., the space between the first and

the second truck is occupied by only one traiter, despite the presence ofJAN 18 '03 16:20 P.7

- 5-

a dark area on the image betv..reenthe two trucks, then it would be

sufflcient to note that the trailer attached to the truck stationed upfront

has a size substantially different from the trailer which is tobydthe
second truck. The second trailer seems to be around one meter longer

than thefirsttrailer.

11. Attachment D is said ta showan a rea close to the front (aroun2 km

from Arvand River), south-west of the cities of Abadan and Arvand­

Kenar. The said area had an extremely high military importance,

particularly once the IraniaArmed Forces crossed Arvand River and

entered into the Faw Peninsula. Indeed, that area was the unique

possible way for providing logistical support to Iranian forces in Faw.

Thus, the area was under uninterrupted bombing by Iraqi forces.

Bambing was carried out using three different means: heavy ground

artillery located on the western bank of Arvand River, ground-to­

ground missiles and air raids. The area was thus particularly insecure.

especially atthe time the image is said to have been taken. For this

reason, lranian forces wereusing cancrete-made shelters to ladge bath

troopsas well asvalua bleand sophisticated equipment. Thesheltersfor
the troops were generally made of three or four, and sometimes more,

reinforced semi-circular concreteblacks lîned upto form a tunnel.For

the heavy equipment, square concrete blacks with a greater height and

width were used. Similarly,and depending on the need, they were also

linedup to form tunnels 10 to 30 meters long. These shelters were big

enough to lodge heavy military trucks, and indeed, were commonly

used -especiallyin the sauthernpart of Abadan in the marshlands area

~fo tre storage of ali operational and valuable equipment and material.

Furthermorel no anti-aircraft defence system can be seen in the image.

It would have been very dangerous and unusua\ to park sophisticated

military equipment such as missiles withoutn air defence system or at

!east one or two 20 mm machine guns.J~N . lB '03 16:21 P.8

- 6-

Even more curiously, one may also note the absence of the single most

rudimentary passive defence, i.e. a camouflage net ta protect valuable

equipment.

Given the above, it is completely unrealistic to assume that sensitive

equipment such as missiles, launchers or auxiliary deviees would have

been set up, unprotected, in the manner described in the DM Report, in

the south of Abadan at such a shortdistance from the front.

Thus, assuming that the given location and date of the image are
accurate, the vehicles shawn are in fact more likely to be heavy trucks

commonly used in the area for various purposes including transport of

troops or militaryequipment such as anillery pieces, heavy cranes or

concrete blooks used forconstructionof shelters.

m. In any event, there is no doubt that the vehicles shawn on the image do
not constitute an HY-2 missile system. lndeed, as listed in Annex C to

my earlier Statement (see Youssefi Statement 10 March 1999, Annex

C, pp. 4-8), an HY-2 missile system comprises the following

equiprnent:

1. Antenna truck of tracking radar;
2. Displaytruck oftracking radar;

3. Firecontrol truck;

4. Pre-launchingohecktruck;

5. Launcher tractortruck;

6. Transporter-loader;
7. Cabletransportingtruck 1;

8. Cable transportingtruck 2;

9. Movable power station (forpre-launch check);

10. Movable power station(for fue control); -----,---------· -----------
P.9
• J~N 18 '03 16:22

~7 -

11. Movable power station (for tracking radar);

12. Movable power station (for integrated testing truck);

13. Integrated testing truck;

14. Air sourcetruck;

15. Air charging truck;

16. Oxidant charging truck;
17. Oxidant rransporting truck;

18. Fuel chargingtruck;

19. Fuel transportingtruck;

20. Neutralizing and blow washing truck;

21. Neutralizing and washingtruck;

22. Lift truck;
23. Missile transportingtruck;

24. Oil chargingtruck;

25. Accessoriestruck.

An HY-2 system missile site capable of launching one missile is,

therefore, constituted of25 trucks.Thus, even considering thatmost of

the eq1.tipme;nltisted above may be used in cornmon by two or more
launching systems, tlle two HY-2 launching systems which the DM

Report alleges at §§ 9-12 to be visible, must comprise at least

28trucks.

However, at best one can detect 5 trucks on the image annexed as

Attachment D. The conclusion is that Attachment D canin no way be
interpretedas representingan HY-2missile system arrangement.

10. Attachment E, is said to depict "HY-2 Missile Crates". The image is stated to have

been taken on 16October 1987.There is, however,noth1ngto confirm the alleged date

ofthe image.Theimageseems to show a warehouse and four tentsor containers along

a river.The locationof the tents/containersclearly îndicates that they are either empty

or used for general storage purposes only, not the storage of any sensitive equipmentJ~ 18 '83 16=23 P.H3

- 8-

such as missiles. As stated above, sensitive equipment is usually protected both

through passive and active defence systems. Here, no passive defence (such as a

camouflage net), nor active defence (such as anti-aircraft guns) can be seen. Indeed, it

would have been completely unbelievable that four missiles be left unprotected in the

way-suggested in the DM Report in an area which is said to be only a few kilometers

away from the front and subject to daily bombings.

ln any event itis certain that:

1. no missile can be seen in this image;

u. no other component of an HY·2 missile system can be seen in the
image;

iii. the four abjects positioned along the river are probably tents or

containers;

iv. the four tents or containers are used only for general storage purposes

and are not designed to contain sensitive or valuable military

equipment;
v. no passive oractivedefence system can be seen in the image.

11. Attachment Fis said to show "HY-2 Cruise Missile Vehicles''. 1l1e image is stated to

have been taken on 9 September 1987. There is, however, no indication in the image

that would allow one to confirm the date of the image. On the image one may
distinguish a truck attached to a trailer. It is affi.rmed that the traHY-2 ismissile

lallilcherHowever, an overhead image of an HY ~2 launcher should show the two

parallel rails alongwhich the missile is propelled. No such rails can be seen on the

image. Finally, considering the quality and the resolution of the image, it would be

purely speculative to affirm that thelauncher is covered by a "flat canvas" or that the

gray area along the trailer is a "stabilizing jack housing".JAN 18 '03 16:23 P.11

-9-

I may conclude that inany event it is certain that:

1. no missile can be seen in this image;

11. there isno sufficient indication to show that the trailer towed is an HY-

2launcher;

111. no other vehicle used in a standard HY-2 missile system can be seen on
this image;

lV. theabsence of any passiveor activedefence system inthe image me:ans

that the vehicles shawn are either damaged, non sensitive or non­

valuable equipment.

12. Attachment G is said ta be an enlargement of part of the area shov.m in Attachment C

marked as "map inset 2'', taken on 9 September 1987. lt seems that the image shows

the same area as that appearing oAttachr Di.1repeat the reservations made in § 8

abave as to the alleged location of the area shawn and the alieged date of the image. I

also refer generally to comrnents and reservations made with respect to Attachment D

in§9(i) ta 9(iii) abov1.have ta add that it seems that the two vehicles described as
"transporters" do not have the same length. Moreover, the length of the vehides

described as "launchers" is Jessthan half of that of the "transporters". Considering that

the length of the "transporter" is 15 rneters (see the DM Report §10), the vehicles

described as launchers would have an approximate length of 7 meters. But, the length

of an HY-2 launcher is substantially more, i.e. about 8.5 meters. My conclusion is that

th.ere isnot sufficient support for the affirmation made in the DM Report that

Attachment G depicts HY-2 cruise missile vehicles. In any event, there is no doubt

that Attachment G cannat be interpreted as representing an operational HY·2 missile

system.

13. Attachment H is said to show "HY-2 Missile Crates". The image is stated to have been

taken on 9 September 1987. There is, however, no indication in the imagethat would

allow confirmation of this. The area shawn is the same as the one shown in

Attachment E. 1therefore refer tomy comments in § 10 above. J wonld only add that,J~N 18 '03 16:24 P.12

- 10-

considering the quality and the resolution of the image, the so-called "protrusion"

referredto inpara. 19mayweilbe infact anair-conditioneror simplyabox.

Myconclusion on this image, similarly ta Attachment E, is as follows:

1. no missile can be seen in thiimage;

11. no componentof anHY-2missilesystemcan beseen inthe image;

m. the two abjects positioned along the river are most probably tents or

possibly containers;
iv. the two tents or containers are used only for general storage purposes

and are not designed ta contain sensitive or valuable military

equipment;

v. no passive oractive defence system can be seen in the image.

14. Attachment I is, similar ta Attachment A, an image showing the intersection of the
Kuwaiti, Iraqi and Iranian terrestrial and maritime bordersin the extreme north-west

of the PersianGulf. On the left sideof the image, one may see the Kuwaiti islands of

Warbah and Bubiyan. and the vicinity of the Iraqi port of Umrn-ol-Qasr. Khur

Abdullah and the Faw peninsula in the southern part of Iraq and Arvand River {Shatt­

Al-Arab} may be seen in the middle part ofthe image, and the extreme south-west of

the Iranian terrtory,south of Abadan city,is visible onthe right sde. This image is
stated ta have been taken in 1989 by SPOT. 1 have no particula.r corrunents on this

image, save to statethat it imisleading to labelthe areashawn as the "Al-Faw Area".

The area shawn covers a much larger area of the extreme north-western coastof the

Persian Gulf.

15. Attachment J similar ta Attachment B, is an enlargement of the central part of
Attachment I.The Faw Peninsula may be seen on the left side,the Arvand River

{ShattAl-Arab) inthemiddle, and theext!eme south-west oflranian tenitory, south of

Abadan city, is visible on the right side. This image isstatedta have been taken in

1989by SPOT. 1 have no particular comment on this image, save ta repeat that it is

misleading to label the area shawn as the "Al Faw Area". The area shawn covers aJAN 18 '03 15:25 P.13

- 11 -

much larger area, including both the Iraqi side of the Arvand River (Al-Faw) and the

Iranian side of that river (Aravand-Kenar). Asto the annotations "HY-2 Staging Area''

and "Nahr-e Owyeh'', 1 respectively refer to other comments made above and also

below.

ii. Attachment K is an image showing the Iraqi HY-2 missile site No. 3. It

is stated to have bee n taken on 5 Septem ber 1987. The re is no

indication in the image that would allow confumation of this.

17. Attachrnent L is an enlargement of the upper part of the right side of Attaclunent K,

marked as "Graphie 2". One may see on that image the launch positions used by Iraqi

forces and the shape of a standard HY-2 missile site.

18. Attachment Mis an enlargement of the upper part of the right side of Attachment K,

marked as "Graphie 8". The image is stated ta have been taken on 16 October 1987. I

would have the same comment as above regarding the asserted date of the image. 1

would also mention that the description of the vehicles highlighted with arrows in the

images marked "Jnset A" and "lnset B" as "support trucks" may be misleading. I

would underline that the vehicles shawn are not ail trucks. lndeed, itseems that one of

the vehicles is a command car (fourth arrow from the left side of the image marked

"lnset A''),and that two others are light transporters such as Toyota Land Cruisers

(first and second arrows from the left side of the image marked "lnset A"). Two dump

trucks may also be seen on the image ma:rkedas "Inset A''(third and fifth arrows from

the left side of the image). These trucks were generally used for the construction of

ernbankments on the front line. The truck shown in the image marked as "Inset B" is

probably a water transport tanker. Thus, none of the vehicles highlighted with arrows

are of the type specifically designed ta support missile systems. The east-west coastal

communication raad in the Al-Faw peninsula was indeed used every day by a great

number of vehicles to provide logistical support to the forces stationed along the

contact lne on the western side of the Salt Factory, In any event no deployment of any

missile or of any missile system can be seen on that image.JAN 18 'B3 16=26 P.14

- 12-

19. Attachment N is an image showing Nahr-e~O aryaeihthe extreme south-west of

Iran. It is stated to have been taken on 16 Oetaber 1987. However, there is no

indicationin the image that would allow confirmation ofthis.

20. Attachment 0 isan enlargement of the area shown in Attachment N. It is affirmed that

this image h.asbeen taken on 16 October 1987.It is further affirmed that this image

would represent a "Launch Site"..However, there is not the slightest indication on this

image tosupport that affirmation. In fact, th.ereis neianyrmissile equipment nor

any missile relatedconstruction thatwould suggest that the area was a missile

launching site. Moreover, no active defence system can be seen on the image. It is

inconceivable that a missile launohite, even a temporary one, would be without anti­
aircraft defence protection.

21. The area was in fact a srnalfishingpoint before and aisduring the major part of the

war, although with reduced activity. Indeed, a number of tocal inhabitants had

remained in the area despite the war and were continuing to fish for theîr own

coq.sumption. The reversed "T" jettywhich was used by fishermen is visible at the

extrernity of the raad on the right side of the image. The jetty was also sometimes used
duringthe warby sma11patrol boats.

22. This point alsohad a military significance and was used as an observation station

controllingthe estuary of the Arvand River. Indeed, to enter the Arvand River, Iraqi

boats would have had to pass in front of that point. The shadows highlighted by

arrows and marked "Support Tents" are therefore probably nothing more than9 to 12

persan tents usedby the observationbattalionpresent at that location during the war.
The suggestion that the tents would in fact bouse support equipment for HY-2 missiles

seems ta me totally unfounded. Indeed,asmentioned above, the necessary equipment

for launching HY-2 missiles is mounted on trucks. The length of sorne of these trucks,

which may vary from 6 to 15 rneters, is referred ta in the DM Report. These

dimensions are inconsistent with the dimensionof a standard tent. None of the tents

shown have a Iengthexceeding 6 meters. Moreover, the trucks have a height of around

4.50 meters which cannat be housed under a tent of the dimensions which can be seenJAN 18 '03 16=26 P.15

- 13~

on the image. Indeed 1he shadows cast by the tents clearly indicate that they have a

standard height of around 2 meters.

23. Moreover, as ta the alleged "run·up aprons", and "Launch Position l" and "2" it has to

be mentioned that contrary to fixed missile sites such as the lraqi sites (see
Attachments M, R and S of the DM Report), mobile missile launchers may fire in

virtually any direction. Indeed, a mobile launchermay be positioned at the desired

location and orientedinany direction. And even once stabilized on its jack, a Jauncher

may still wheel round 85 degrees to the right and 85 degrees to the left. Therefore, the

indications "HY ~2Launch Position 1. 243° Launch Azimuth" and indications "HY·2

Launch Position 2, 200° Launch Azimuth" are misleading and totally unsupported.

24. Furthermore, due ta the rather limited width of the track which can bee seen on that

image, the fact that it is not tarred but is a simple dirt track and also bitwould

be difficult to stabilize theail in the marshlands, the area shawn in the image is

inappropriate forbeing used asa missile b.unching site.

25. Finally,given that that pointis at sea leve!, even if a missile antenna were placed at 5

meters abave that lev el, based on the capabilities of the HY·2 system, and as

explained in the manufacturer's booklet and in my previous statement (see Youssefi
Statement, 10 March 1999, Annex C pp. 4~19), a missile launched from that point

would have a maximum radar range of only 38 kilometers for a target50 meters bigh

(such as a big vessel).A missilelaunched from that point, therefore, could not have

targeted the Sea Isle City, which was both far outside its maximum radar range, and

also outside its maximum effective and maximumpowered range.

i. Attachment P is an enlarged image of the same area as the one shown
in Attachment 0. Tt is said that that image has been taken on 14

December 1987.. 1 have the same comments on this image as those

mentioned above with respect to Attachment O. 1would also add that:JAN 18 '03 16=27 P.16

- 14-

ii. Considering the resolution of the image it cannat be confirmed that the

abject described as "HY-2 Missile at Launch Position 1" is in fact a

missile.The best one can see there is à vehicle;

m. The fact that no other vehicles can be seen on the image supports the

above. Indeed, as already indicated above) an actual HY-2 launch site

needs the support of at !east 25 trucks.

m. Compared to the size of the tents and the width of the raad, the alleged

"launcher" would have a length of approximately 6 meters which is

substantially less than the length of an HY-2 launcher, i.e. 8.50 meters;

iv. Finally, it is said in the DM Report at §26 that "the high vertical

stabilizer or tailf the missile can be seen in the shadow of the missile

on the ground". I do not agree v.ritthat Interpretation of the image.

Indeed, even assuming that the described abject is a missile, given the

direction of thesunshine and the fact that the nase of amissile loaded

on a launcher is higherby 11 degrees than itstail, the shadow cast on

the ground should be larger to the front. But, on the image, the shadow

of the front part is srnaller than the shadow of the rcar part of the

"Iauncher". Thus, if the abject is a launcher, then one should conclude
11
that the missile" is actually painting inland!

27. Attachment 0 is an image showing part of Al-Faw and) in particular, the Iraqi HY-2

missile sites No. 1 and No. 2, as weil as a salt factory and the line of contact between

Iranian and Iraqi forces in 1987. The image is stated to have been taken on 13

November 1987. However, there is no indication in the image that would allow

confirmation of this. Consequently, the assertion that no 4th Iraqi HY -2 site existed in

October 1987 at the location alleged by Iran) is not demonstrated. .. JAN 18 '03 16=28 P.17

J - 15-

28. Attachment Ris an eiùargement of part of Attachment Q. It shows, in particular, the

IraqiHY-2 missilesiteNo. 1.Theimageis statedto have been taken on 13 November

1987. Once again, there is no indicatiointhe image that would a.llow confirmation of
this.

29. Attachment S is an enlargement of a different part of Attachment Q. lt shows, in

particular, theaq.\ HY-2 missile site No. 2. The image is stated to have been taken on

13 November 1987. However, there is no indication in the imagethatwou1d allow us
toconfrrm this.

30. AttachmentT is an enlargementofpart ofAttachment Q. It showsin particularanarea

in Al-Faw, west of theline ofcontact between Iranian and Iraqi forces i1987. The

image is stated to have been taken on 13 November 1987. However, there is no
indication in the image that would allow us to confirrn the date of the image.

Consequently, the assertionthatno 4thIraqiHY·2 site existed in Oeta b1987 at the

location alleged by Iran, is not demonstrated.

31. Attaohment U is an image sho..ving part Al-Faw peninsula and in particular the Iraqi
HY-2 Site No. 2 and a new HY-2 Site allegedly built in 1989. The image is stated to

have been taken on 15 October 1994. However, there is no indication in the image that

would allowone ta confirm the datof the image. Since the dates of Attachments Q, R

and U are not proven, itis impossible to ascertain when this new Iraqi HY-2 site was
bui1t.

Moharrunad Yousse fi

yorA'Pf .f L