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Home My WebLink About97-00103 II ~ It ~ ~~ ~I} -.....\:3 II ~ ::t ~ I I I :;! 1 , i i \.. \l Q.... "> ct. ~ ,,) ,I ~ ~I i . I , ~I I Ddendant Juniata, under a policy hy the tenns of whkh it providcd sccurity, including insurance Cllverage for damagc donc hy windstonns. a copy of which is an ached hereto and designated as Exhihit "A". 7, TIle Plaintiffs paid fair and adequate considcration for thc aforesaid insurance coverage, 8, On or about July 3D, 1996, Plaintiffs fann and place of residence, the property "insurcd" by Juniata. was damaged in a windstorm which resulted in severe damage to the buildings on thc property and many of the contents therein. 9, As a result of sa1d occurrence. the Plaintiffs have been madc to undergo severc financial and cmotional hardship in that they have lost use of a portion of their home and many of their personal belongings. and have had to either replace said items or to do without. 10, TIle Defendant, Juniata, has the duty to providc the Plaintiffs with insurance benefits in accordance with the aforesaid policy of insurance. 11, TIle Plaintiffs gave prompt. timely. and reasonable notice to the Defendant. Juniata, of their losses and/or claims and provided all required notices. applications. bills, report. forms, proofs. and verifications required by the Defendant pursuant to the aforesaid policy of insurance, and in fact subjected themselvcs to more than would seem necessary, to wit: a five hour "statement under oath" hy Defendant's attomcy. 12, Notwithstanding the Defendant. Juniata's duty to pay Plaintiffs windstorm loss hcnefits. and in spite of repeated demands upon the Defendant for payment of same. the Defendant has failed and/or refused to offer and/or pay a reasonable sum of money in S<ltisfaction of the Plaintiff's claims for benefits arising as a result of the aforesaid incident. 13, Further, the Defendant, Juniata, acting as aforesaid, has, in bad faith. maliciously, willfully. wantonly. intentionally, knowingly, recklessly. and/or negligently failed and/or refused to offer amI/or COUNT I GALEN & JEANNE1TE ASPER AND WADE ASPER v. JUNIATA IN TORT - IIAD FAITH , r ~ I pay a reasonable sum in sollisfactionof Plaintiffs' claims for benefits ali(I have engaged in such behavior in an effon to avoid and/or reduce their obligations 10 Plaintiffs under the aforesotid policy of insurance, 14, The Plaintiffs hereby incorporate by reference each and every allegalion contained in Plaintifrs claim for benefits arising frolll the aforesaid paragraphs 1-13 inclusive, of the foregoing Complaint as if the SOUlle were set fonh fully and length hereiu, 15, At all times relevant herein and material hereto. the Defendants were under a covenant and/or duty of good faith and fair dealing wilh the Plaintiffs regarding claims for windstonnloss benefils under the .Iforesaid policy of insurance, 16. TIle Defendant breached its covenant and/or duty of good faith and fair dealing with the Plaintiffs in that Ihe Defendant. acting as aforesaid, 1I11entionally, knowingly. recklessly, and/or negligently. and/or otherwise did: a, Fail and/or refuse to offer and/or pay the Plaintiffs a reasonable SUIIl of money in satisfaction of the windstonn; b, Unreasonably and without proper cause withhold payment of windstonu loss benefits due under the policy of insurance; c, Fail to properly and/or adequately state a reasonable cause for denial of Plaintit'rs claim based on Defendants pre-denial investigation; d, Force the Plaintiffs to incur nnnccessary expcnse in thl' hiring and paying of Icgal connseland in incnrring olher costs and expenscs in ordcr to obtain bcncfits to which they are rightfnlly cntitlcd uudcr thc policy of insufllnce; e, Intelllionally and/or ncgligcntly causc thc Plaintiffs severe emotiomll distrcss by and throngh the aforesaid outrageons acts; f. Otherwise breach the aforcsaid contract and policy of insurance; g. Otherwise act in bad failh and/or in an unreasonable manner in refusing and/or failing to pay a reasonable sum in satisfaction of Plaintiffs' claim; h, Commit such other acts of bad faith as may be disclosed through discovery and the trial of this case, 17. TIle aforesaid actions by the Defendalll were committed with the purpose and intention of avoiding and/or limiting Defendant's obligations under the aforesaid policy of insufllnce and with the purpose and imention of increasing Defendant's wealth, at the Plaintiffs detriment, 18, TIle aforesaid actions by the Defendalll were done willfully. wantonly. maliciously, and in bad faith, !lJ. Solely as a result of the Defendant's breach of its covenant and/or duty of good faith and fair dealing as aforesaid, the Plaintiffs suffered damages, including but uot limited to, failure to receive benefits rightfully due and owing under the said insurance policy, failure to receive a reasonable sum in satisfaction of their claim for windstorm loss, incurring of debts, litigation costs and attorney's fees, and incurriug severe emotional distress, 20. In an action arising under an insurance policy, the insured may make a claim against the insurer for damages for bad faith pursuant to 42P,S, Sec, 8371 (PA Regular Session, House Bill #121, print 3051. p, 21, I. 2-12), 21, TIle aforesaid statute provides for an award of interest on the amount of the claim for the date the claim was made by the insured in an amount equal to the prime rate of interest plus threc pcrcent (3%), and award of punitive damages against thc insurer. .md asscssmcnt of coun costs and attomey's fecs against the insurer, all of which Plaintiffs are entitled to under thc circumstances of this case, WHEREFORE, Plaintiffs demand judgment against the Defcndant. Juniata Mutual Insurance Company upon the first count as aforcsaid. in an amount in cxccss of Twenty TIlOusand Dollars ($20,000,00), together with cOlnpcl'satory damages, statutory interest, punitivc damages, costs and attomey's fecs. COUNT TWO GALEN & JEANNETTE AND WADE ASPER v. JUNIATA IN ASSUMPSIT - BREACH OF CONTRACT 22. Plaintiffs Galcn & Jeannctte Asper and Wadc Asper hercby incorporatc by rcference cach and cvcry allegation containcd in paragraphs I through 21, inclusive. of thc foregoing Complaint as If it were sct fonh fully at length hercm, 23, TIle Defendant, acting as aforesaid. maliciously, willfully, wantonly. in bad faith. intcntionally, knowingly, recklessly, and/or ncgligcntly, and/or otherwise breached its aforesaid contract and/or policy of insurance with the Plaintiffs, in that it did: a, Fail and/or rcfusc to offer and/or pay the Plaintiffs a reasonable sum of money in satisfaction of thc Plaintiffs ~. " claim for hcnclits arising from Ihc aforcsaid windstonll; b, Unreasonahly and without propcr causc wilhhold paymcnt of windstonu loss hcnclits duc undcr thc policy of insurance; c. Fail to properly and/or mlcquatcly statc a reasonahle cause for denial of Plaiutiffs claim hascd on Defcndant pre-denial invcsllgation; d, Force the Plaintiffs to iucur unnccessary expensc in the hiring and paying of legal counscl amI in incurring olhcr costs and expcnses in ordcr to ohtain benelits 10 which they arc rightfnlly cntitlcd undcr the policy of insurance; e. Intentionally and/or ncgligcntly cause the Plamtiffs severe emotional distress by and through Ihe aforesaid olltmgeous acts; 1', Otherwise breach the aforesaid contract and policy of insurance; g, Otherwise act in bad faith and/or in an unrcasonable manner in refusing and/or failing to pay a rcasonable sum in satisfaction of Plaintiffs claim; h, Commit such other acts of bad faith as may be disclosed through discovery and the trial of this case, 24, Solely as a result of the Defendant's hrcach of its covenant and/or duty of good faith and fair dealing as aforesaid. the Plaintiffs suffered damages, including hut not limited to failure to rcceivc Proll~ction Law, 73 !',S, Sec, 201,1 et seq., in the [)elcndalll, actlllg as at(uesaid, IIItl'lIlionally, knowingly, recklessly, and/or negligently and/or otherwise did: a, Represent th.1I goods or services have ingredients. benefits or quantities that they do not have: b, Advertise goods or services with intent not to sell them as advertised; c, Fail to comply with the tenns of written guarantees or warmnties given the buyer at. prior to or after the cOlllmct for the purchase of goods or services IS made; d, Eugage iu any other fraudulent conduct which creates a likelihood of confusiou or of misunderstanding; e, Engage in such other uufair methods of competition and/or commit such other uuti,ir or deceptive acts or pmctices as may be disclosed through discovery aud the course of trial. 29, Solely as a result of the Defendalll's breach of its covenant aud/or duty of good faith aud tilir deilliug as aforesaid, the !'Iaiutiffs suffered damages. including but not limited to , failure to rcceive bcncfits rightfully duc and owiug uuder thc said iusurance policy, tililure 10 receivc a reasouable sllln in smisfilction of their claim for windslonn loss. iucurring of debts, litigation costs aud ilttomey's fccs. aud iucurrlllg sevcr emotional distrcss, 30, Plaillliffs purchased good or services, being the policy of insumnce, primilrily for persoual, t:unily or household purposes and thereby suffered an ascertainable loss of money or personal property as a result of the IIse or cmployment by Defendaut of the aforesaid methods, acts or practices, which ~ ~ standards for the prompt investigation less thall the amounts due and ultimately of claims arising under the aforesllid insurance policy; 4, Refuse to pay claims withoutll reasonable cuuse for denial; 5, Not attempt in good faith to effectuate prompt. fair and equitable settlements of claims in which the company's liability under the policy had become reasonably clear; 6, Compel persons to institute litigution to recover amounts due under the aforesaid insurance policy by offering substlllllially recovered in an action brought by such persons; e. Commit such other unfair methods of competition and/or unfair or deceptive acts or practices as may be disclosed through discovery and the course of trial. 35, Solely as u result of the aforesllid action of the Defendant. Juniata, the Plaintiffs suffered damages, including but not limited to, failure to receive benefits rightfully due and owing under the said insurance policies. failure III receive a reasonahle sum in slltisfaction of their claim for windstonll loss benetits; incurring debts, litigation costs and attomey's fees, incurring severe emotional distress, providr Drfrndam with a sum of monry thrrdnrc. and was mmlr with thr intrnt Ihat Plaintiffs providr Drfrndant with a sum of moncy and/or prrmium paymrnt for comructrd for insurancr cowragr. alul would rrccivr thrrcforl' insurancr cowrugc, Irss than till' acmal valnc of Ihc moncy or prcminm paid Ihcn'forr, and was madc with thc imclll 10 avoid and/or Iimil its ohligations to Ihc PI,lillliffs undrr saill policy of insurancr hy comnnlling Ihr alnrrsaid actions and/or olhcrwisc allcmpting 10 thwan Plaintiffs' attainmcnt of a rrasonahlc sum in satisfaction of thcir claim undcr thc said policy of insurancc, 41 TIlc aforcsaid misreprcsclllationof thc valnc of "rid policy of insurancc and misrcprcsclllation Ihat I'laimiffs would hc dralt with rrasonahly and fairly and in good failh. would providc I'laillliffs with thr contruclcd l(lr insurancc covcrugr witholll attcmpting to avoid or limit thc Dcfcndant's ohligations, and would not allrmpt to tltwan Plaillliffs' claims for wmdstorrn loss hcncfits undcr the policy, was, in fact, aClrd upon hy Plaintiffs 10 thdr damagr and dctrimcnl. in that they providcd Dcfcndant wilh paymcnt of insurancr prrmilllns al\(l in rcturn n~cclwd from Dclcndalll Ihc aforcmcntloncd actions. had faith dcaling. untaimcss, uurcasonahlcnrss, allrmpts to avoid or Iimll its ohligations undcr thr policy 01 insurancr, and allcmpts to thwan Plaintiffs' windstonn loss hcncfils claims. thereby causing Plainliffs to suflcr a loss of monics paid for msurance prcmiums and/or causmg Plamtiffs to pay an unrrasonahlt. sum of 1II0ncy in insurancr prcmiums for insuruncc suhstanlially Icss than thc valuc Plaintiff paid thrrdorc. said loss hcing suffcrcd hy Plaillliffs as a dircct rcsult of thc aforesaid misrcprcsentations and Plaintiffs' rcliancc thcrcon, 44. In acting uponthc aforcsaid misreprescntations hy Dcfendanl. Plaillliffs wcre ignorunt of thcir falsity and of the actual valuc of thc policy of insurancc and rcasonahly hclieved Dcfcndant's rrprl'scmatillns tll hc tmc. 45, TIlc aforcmclllioncd actions of Defendalll, Juniata, wcrc perfonncd in had faith and eonstitutl' willful. wanton, and malicious conducl at law, GALEN S, ASPER, JEANNETTE A. ASPER AND WADE ASPER Plaintiffs : IN THE COURT or COMMON PLEAS or : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION. LAW : NO, 97, 103 CIVIL TERM JUNIATA MUTUAL INSURANCE COMPANY Defendant : INSURANCE. BAD FAITH : JURY TRIAL DEMANDED PRAECIPE FOR SETILEMENT AND DISCONTINUANCE TO THE PROTHONOTARY: Please mark the Plaintiff's claim filed in the above referenced matter as discontinued, settled and ended, Respectfully submitted. " Dated: July IS, 1998 , Jaine~'J. Kayqr, Esquire I .i 9, Denied, Defendant is without sufficient kfl(l\'Jledge or information to filrm a beliefas to the avennents containcd in this paragraph ofPlaintin:~' Complaint,lInd IIccordingly, strict proof thercof is demanded, 10, Denicd, It is specifically denicd that Dcfendant has the duty to providc Plaintiffs with insurance bencfits for reasons morc fully sct forth in Defendant's Ncw Maltcr which is incorporated herein, By way of further answer, thc policy of insurance is a writing which speaks for itself and therefore no response is necessary, J I, Denied, ] 2, Denied, ]3, Denied, It is specifically denied that Defendants acted maliciously, wilfully, wantonly, intentionally, knowingly, recklessly and in bad faith, By way of further answer, Defendant incorporates the within Ncw Malter as though fully set forth herein, COUNT I 14, Defendant incorporates hercin by reference paragraphs one (I) through thirteen (13) as if same were fully set forth at length, 15, Denied, This allegation is a conclusion of law to which on responsive pleading is required and strict proof thereof is demanded at time of trial. 16, Denied, This allegation is a conclusion of law to which no responsive pleading is required and strict proof thereof is dcmanded at trial. fly way of further answer, it is specifically dcnicd that Dcfendant: (a) Failed andlor refused to ofler and/or pay the Plaintiffs' a reasonable sum of money satisfaction of the Plaintifl's claim for bencfits arising from the aforesaid wind storm; (b) Unreasonably and wilh proper cause withheld payment ofwindstonn loss benefits due under the policy of insurance; WIIElmFORE, Defendant, Juniata Mutual Insurance Company, demand~ judgment in its favor and againstPlaintilTs. along with costs, expenses and attomey's fces incurred as a result of this sui!. COUNT II 22, Defendant incorpora:es hcrein by reference paragraphs one (I) through twenty- one (21) as if same were fully set forth at length. 23, Denied, It is specifically denied that Defendant acted in bad faith, breached any contract andlor policy of insurance with the Plaintiffs, By way of further answcr. Defendant specifically denied that: (a) Failed and/or refused to offer and/or pay the Plaintiffs' a reasonable sum of money satisfaction of the Plaintilrs claim for benefits arising from the aforesaid wind storm; (b) Unreasonably and with proper cause withheld payment of windstorm loss benefits due under the policy of insurance; (c) Failed to properly and/or adequately state a reasonable cause for denial of Plaintiffs' claim based on Defendant's pre,denial investigation; (d) Forced the Plaintiffs to incur unnecessary expense in the hiring and paying of legal counsel and in incurring other costs and expenses in order to obtain benefits to which they were rightfully entitled under the policy of insurance; (c) Intcntionally and/or negligently caused the Plaintiffs severe emotional distress by and through the aforesaid outrageous acts; (I) Otherwise breached the aforesaid contract and policy of insurance; (g) Otherwise acted in bad faith and/or in an unreasonable manner in refusing and/or failing to pay a reasonable sum in satisfaction of Plaintiffs' elaim; (h) Committed such other acts of bad faith as may be disclosed through discovery in the trial of this casc, Defendant incorporates the within New Maller as though fully set forth herein, (d) Engaged in any fraudulent eonduct which created a likelihood of confusion or of misunderstanding; (e) Engaged in such other unfair methods of competition and/or committed such other unfair or deceptive acts or practices as may be disclosed through discovery in the course of trial. 29, Denied, This allegation is a conclusion of law to which on responsive pleading is required and strict proof thereof is demanded at the time of trial. By way of further answer, it is specifically denied that Defendant breached its eonvenant and/or duty of good faith and fair dealing, 30, Denied, This allegation is a conclusion of law to which no responsive pleading is required and strict proof thereof is demanded at the time of trial. 31, Denied, To the extent of the avennent ofPlaintiOs' Complaint relate to a document in writing, such document speaks for itself and therefore no responsive pleading is necessary, 32, Denied, It is specifically denied that Defendant is liable to the Plaintiff for extra-contractual damages, WHEREFORE, Defendant, Juniata Mutual Insurance Company, demandsjudgmcnt in its favor and against Plaintills, along with costs, expenses and attorney's fees incurred lIS a result of this suit. COlJNTIV 33, Defendant incorporates herein by reference paragraphs one (I) through thirty-two (32) as if same were fully set forth herein at length. 34, Denied, It is specifically denied that Defendant violated the Unfair Insurance Practices Aetandlor the Unfair Claim Settlementl'ractices Act and any and all othcr laws of the Commonwealth, By way offurthcr answer, Defendant specifieally denies that it acted intentionally. knowingly, recklessly and/or negligently andlor otherwise did any of the avennents or allegations contained in subparagraphs (a) through (e) of this averment. 35, Denied, This allegation is a conclusion of law to which no responsive pleading is required and strict proof thereof is demanded at time of trial. 36, Denied, This allegation is a conclusion of law to which no responsive pleading is required and strict proof thereof is demanded at time of trial. WHEREFORE, Defendant, Juniata Mutual Insurance Company, demands judgment in its favor and against Plaintiffs, along with costs, expenses and attorney's fees incurred as a result of this suit. COllNT V 37, Defendant incorporates herein by refcrence paragraphs one (I) through thirty-six (36) as ifsame were fully set forth herein at length, 38, Admitted in part; denied in part, It is admitted that Defendant represented, and in fact. acted in good faith, Denied to the extent thmthe remainder of the avennents contained in this paragraph of Plaintiffs' Complaint relate to the obligations which are set forth in the policy of insurance which is a document in writing which speaks for itself and therefore no responsive pleading in neeessary, 39, Denied, This allegation is a conclusion of law to which no responsive pleading is required and strict proof thereof is demanded at time of trial. 40, Denied, This allegation is a conclusion of law to which no responsive pleading is required and strict proof thereof is demanded at time of trial. 41. Denied. This allegation is a conclusion of law to which no responsive pleading is required and strict proof thereof is demanded at time of trial. 42, Denied, This allegation is a conclusion of law to which no responsive pleading is making it impossible flJr a full and timely inspection of the prcmises to occur, WHEREFORE. Defendant. Juniata Mutual Insurance Company. demands judgment in its favor and against Plaintitls. along with costs. expcnses and attorncy's fees incurred as a result of this suit. COUNTERCLAIM 54, Defendant incorporates herein by reference paragraphs one (I) through fifty-three (53) as if same were fully sct forth herein at length, 55, Plaintiffs' made fraudulent statements and material misrepresentations to defendant in its investigation of plaintiffs' claim, 56, Plaintiffs', by virtue of their fraudulent actions, intentionally misrepresented the validity of their claim, caused defendant to justifiably rely upon their statements in investigating the claim with the intent that the defendant so rely and cause damages to defendant in the way of investigatory costs, whieh amount to an attempted fraud against defendant-insurer, 57, Plaintiffs' fraudulent actions requiring defendant to expend such sums and disbursements was wanton, malicious and with the intent to defraud defendant. 58, Plaintiffs' are liable to defendant for all ofthc funds expended during the course of all of the funds expending during the course of defendant's investigation into the aforesaid claim and in defense of this suit, together with punitive damages for wilful. oppressive. and malicious conduct. 59, Plaintiffs' actions as set forth in this Counterclaim violate the Pennsylvania Insurance Fraud Statute, -- ,.... i L"~ I c"~ I ~'.; I' ( \;- - , . . . .. ~, 1 C~ , ", . ; . , "j L- Co. ':.l.. L~ 'i " l"- e '" u 51. Admitted, 52, Admitted, 53, Denied, It is sp~cifically d~ni~d that the Plaintiffs failed to cooperate with Juniata Mutual Insurance Company to pellnit a full inspection of their premises, By way of further answer, the Plaintiffs allowed Juniata and its representatives to come to their premises on multiple occasions \0 inspect various portions of their personalty and realty, WHEREFORE, the Plaintiffs respectfully request a judgement in their favor and against Defendant, along with costs, expenses and attomey's fees incurred as a result of this, RESPONSE TO COUNTER.CLAIM 54. Plaintiffs incorporated herein by reference paragraphs I through 53 as if same were fully set forth herein at length, 55, Denied. It is specifically denied that the Plaintiffs made fraudulent statements and material misrepresentations to the Defendant in its investigation of the Plaintiffs' claim, 56, Denied. It is denied that the Plaintiffs attempted fraud against the Defendant - Insurer by intentionally misrepresenting the validity of their claim so as to cause the Defendant damages in the way of investigatory costs, 57, Denied, Defendant's avennent is a conclusion of law and therefore requires no response, 58, Denied, Defendant's avennent is a conclusion of law and therefore requires no response, 59, Denied, Defendant's avennent is a conclusion of law and therefore requires no response, WHEREFORE, Plaintiffs request this Honorable Coun to enter judgement in their favor and against the Defendant, along with costs, expenses and attorney's fees incurred as a result of this suit and for such other damages as perlllilled Iha\ Ihis Honorable Coull d,"'IIIS appropriale. Respectfully sublllilled, KA YER & BROWN Date: February 26, 1997 z ~ , ,~, - SHERIFF'S DEPARTMENT JUNIATA COUNTY, PENNSYLVANIA 3rd & Bridge Streets, Mlffllnlown, Pennsylvania 17059 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN COUHl t1UMIH II Pl"INllFF G,iLEN S. ASPER, JEANNE1"l'E A, A!a'ER and WADE ASPER 103-97 (Cumberland Co) DEF[NUArH 1 y..1. o~ WillI Oil UJ,,ol'l 1..tjl JUN lATA MU'l'UAL I NSURANCE COMPANY NO'l'ICE & COMPLAIN1' SERVE . AT IIH.l>l"'1I unu~u..1 bl'r.If.C COI'I'm 01 Pol ll~pul'le 0.,,,,, NAME OF INDIVIDUAL, COMPANY, CORPORATION, [Te . TO SERVICE Juniata Mutual Insurance Company ADDRESS IStrlllt III I1FU All~tlll"'"\' t~,; C+I~ U\.I'<' I",., ~tol'U <lnd ljP CI.lIl1tl Church Avenue, McAlistcrvillc, Juniata County, Penns Ivania SEND NOTICE OF SERVICE copy TO NAME AND ADORlSS OELQW I _________________________________________________1 KAYER & DROWN : James J. Kayer, Esquire I 4 East Liberty Avenue I Carlisle PA 17013 : I -, .------------------------------------------------ SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE " .") I ,) '~~ 'd () " ,"J SlgJlilull 01 Allorne~ 0' olher OflglJlilor rllQYIISllI1Q S('I.,UI uJl b1l1131! o! TELEPHor~f. UUMCEfl OAT( XPLAINHFF DEFENDANT 01/08/97 (717) 243-7922 SPACE BELOW FO USE.QF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE /' l,' L ,- all)(il~ri ,2rJ James J. Kayer, Esquire liClIJlOlHleoger.CIIPIOllh......fll orcomplllnlaSIJldlcat.d.bOwl ,."1 \...t....._.-..- (;""',,:, 'I.-,~'V DalIl11e,....e 01/09/97 E.,m;lllonOa'lI 02/06/97 I he"b~ COflll~ IJld III urn thai t ~ hjhQ perlOJlallt urwec:l, : : ha.llltlgalll.u.IIlJlce 0 rOICI IS lhO'llJlIJl " Rem.rl<S " h..we ttlOCull<J is sho"''' I" 'Relna,...s Ih~ "",1 0' compl.."'l dUtlltad on Ihe Indlwldual, compaJl~, corpor.llon, IIC, allhe ic:ltllU5 sho",.n abO~' or on Ihllndlwldual. compiln~ C(J,pol.llon, t'C" at Ihe ioJ,l,eu II1SllIllld bile... bt hol'\(]"I'\! ,j TRUE and ATTESTED COPY Iher.ol L' I hefeby cerllly Ind r,'urn a NOT FOUND tJec"usII I..m unabllllo lo~..I,~ 'he (nc:lI~ld\Ja1. company, eOlpOf,l"on, !'Ie namlrJ abo.1' ISle rema,k" bllOM p~em..ndlltleollndmduel'ClI."'(llnc' sho...nlbooel o A pefSorl 01 sUI1JlJie d'.l";lndd'Sl;rlll,on Ihen"s.d,"g'""H~delemJ...t"Irsusual plilUIOI,ItIOej" Barbara Vanalman, Secretary and person in Charge of Juniata Mutual at time of service Adlllul 01 "",h'I'lClr~.d lecmplel' Onlt II rJlllerlnllnilfl 5nOwll lbo_ell Srle" Qf RFD, A~"'IY"n' No, C"y, BOlO, T",~ Sr,,, ,nd [IPeod.' Oill00IS('",(e Tune 01/10/97 3:35 PM '"' P'" Same as above All.mpll Oil' $49,00 Dill Mil.. MU.. 1 1/10 20 ~Ql:!Xll REFUND Ser.lc.COSIS $19.00 $5.00 $26.00 Illm~I"" SO ANSWER AfFlR'-l(O Ind sub1Croti.d 10 ~Ior' nil! 11I'5 I~' ,L ifgt"lill"II1{\15/.t'(dl t1i1~ , , ~.'''''.)'- . o 't/XJ-- 01 ' 'I :,1 / I ' , i , "J il 51ilrrrr~IJunj'''Counl, {~/ , .' ....'.~ 1 /<~ ' .( CHARL01TE F, SURO _. ""II -r ,.. IIC~no""ledgl "Cllpl 01 tn. !helll", "('lurn S'gn.lure 01 AulnOflltld PrOlhonollft', Ciepult Tilt. Olllne(.lmerJ PROTHONOTARY O.plnl '- Lrl >~ lr~ Ll. " -c .. ';'1<( I'- co, - ~'"', .'~, ), . ,':'.? \tc a.. ,=3 9t .>. .:""--J '~'l ~. .1.:'-' ::.\- . -.. L': ,:,tll (Cl' U-' '.:1- I. L... '-'. r- .' C 0' 'J