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huu:ki\cund\ugi-kark.con.1 OJ:! 119M
IN TilE COllin OF COMMON I'LEAS OF
CUi\lIIEIU.ANIl CO\lNTY.I'ENNSYLVANIA
CIVIL ACTION - LAW
IN RE: CONIlEMNATION OF
EASEMENT ANI) RIG 11'1' OF WAY
ACROSS LANIlS OF EVANGELICAL
LUTIIERAN CIIlJRCII
BY UGI UTILITIES, INC.
FOR PUBLIC PURPOSES
('Y(~ L-.Lf (1
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NOTICE OF INTENT TO PRESENT
CONI>EMNATION PETITION ANIl BONIl
To: Evangelical Lutheran Church
('()2 McLund Road
Mount I-Iol\y. I'A 17065
I'ursuuntto and in uccorduncc with thc l'cnnsylvuniu Busincss Corporation Law of 1988,
Act of Decembcr 21, 19M8 (I'.L. 1444 No. 177(g)(2)(ii)). YOU ARE HEREBY NOTIFIED
THAT the alluehcd Petition has been tiled with thc CUll1berlund County l'rothonotary. and that if
you do not file an Answer or Objections thereto, WITHIN TEN (10) DAYS AFTER SERVICE
OF Tl.I\S PETITION UPON YOU. UOI Utilities, Inc., by und through its counsel, will tile a
Motion with the Cumberland County l'rothonotury, and present it to the Coun for approval,
seeking entry of an Order in the form attached as Exhibit "C" to UOI's Petition, directing the
tiling of UOl's original Bond.
~~~
Allorney for UOI Utilities. Inc.
h.lll:kl',cond\ugi.kark l"ln.llI'~ I ,")X
IN TilE C'OIlln OF C'O:\1:\IO:"O I'I.EAS OF
('J1:\lIIEIU,ANIl C'OliNTY, I'ENNSH\'.\:"OIA
1'1 \'11. AC'T1O:"O . 1.;\ \\
IN 1m: CONIlEMNATION OF
EASEMENT ANIlIUC;IIT OF \VA Y
AClmss "ANIlS OF EVANla:I.I(',\"
Ll'TIIEI~AN ClIlIlKII
BY UGI UTILITIES. INC.
FOR PUBLIC I'URI'OSES
'to<. '(J - (,.'1 'I' l:." ~,~ '-r,.-
I'ETITION FOR AI'I'ROVA"
ANIl OIUlER FOI{ FILING CONI>EMNATION BONI>
AND NOW. comcs thc Pctitioncr. UGIUTlLlTIES. INC.. by and through its attorney.
Kcvin T. Fogcrty. Esq.. and rcspcctfully petitions this Ilonorable Coun as 1()lIows:
I. The Petitioner. UGlUTILlTIES INC. ("UGI"). is a corporation organized and
existing under the laws of the Commonweallh of Pennsylvania. and is principally cngaged in the
business of producing. purchasing, storing. transporting and distributing natural gas. The
Petitioner maintains its principal office and place ofbusincss in Valley Forgc. Montgomcry
County. Pennsylvania. and has as its mailing addrcss 1'.0. Box 858. Valley Forge.PA 19482.
2, The Petitioner, a public utility, by virtue of thc powcr of eminent domain as
provided in the Pennsylvania Busincss Corporation Law of 1988, 15 P.S. Scction 1511, and by
resolution duly adopted by the ExecutivelNominating Committce of its Board of Dircctors on
Octobcr 27, 1998. as evidcnccd by the Sccretary's Ccrtilicatc attachcd hereto and marked as
Exhibit "A," has determincd and concludcd to entcr upon. take and appropriate for a public
purpose, an cascmcnt and right of way over and upon certain parcels of land located in South
Middletown Township. Cumbcrland County, PA. by routc survcycd and located for thc purposcs
hao:kl\eond\ugi.kmk,eon.llI'21I'1X
of constructing. operating. maintaininl!. replaeinl! and ehanginl! a pipeline li.r the transponatinn.
transmission and distrihntion of naturall!as \\ith the ril!ht in said company. its successors and
assigns to enter UP'lII such casement and/or ril!ht of way al such times as may he lit and
necessary li,r said purposes.
3. Petitioner helieves allll avers that the only person or enlity having an ownership
interest in the property being condemned is Evangelicall.utheran Church. being lhe sole legal
and equitable titlcholder (hereafter "the OwnerOO). Petitioncr believes and avers that said Owner
holds sole legal and equitablc litle to this propeny, by virtue of Dccds recorded at the
Cumberland County Recorder of Deeds Oflicc. at Dced Book Volume A3 I. Page 5 I 7 (dated
Novcmbcr 15. 1984). and at Deed Book Volume T23, Pagc 123 (dated August 5. 1970).
4. Sincc in or about Septcmbcr. 1998. thc Petitioncr. through its agents and
cmployees. has attcmptcd 10 sccurc an agrccment for a pipelinc cascmcnt and right of way ovcr
and through thc subjcct parccl of land Irom thc Owncr rcfcrcnced in Paragraph 3 hereinabove. In
that respect, thc Pctitioner has attcmpted to contact thc Owncr to try and agrce as to lhe damages
properly payable, but to datc has bcen unablc to do so for the purpose of entering into an
agreement! contract for such eascment and right of way; hence, thc Pctitioncr and the Owner
havc not agreed upon reasonable compensation to be paid therefor and to affix the amount of
damages, if any, which would be occasioncd by the taking of said casemcnt and said right of way
and thc construction of said pipelinc.
- 2-
ha",kl\~'ond\ul'i.kark \'I'n-' O/~ I /llH
5, ,\ wpy of Ih.: lIond oflh.: 1'.:lilion.:r wilh Salcw Insunlnc.: ('olllpan)' of Alllcrk<l.
<I surdy <lulhori/cd III do husincss in Ih<' ('ollllllllnl,,'allh of Pcnnsylvania. which is .:ondilioncd
iiII' Ih.: p<lYIII.:nl 01'<111 dam<lg.:s <lrising Irllllllh.: <lpproprialilln Ill' said ':<lscm.:nl allll righl ofw<lY
<lnd Ih.: IlIc<ltilln <l1ll1 conslru.:lion oflh.: pipdin.: on lhc <lIi'r,:s;lid p<lr.:d or I<lnd orlh.: ()wn.:r
rdcr.:nc.:d in P<lnlgraph 3 h.:r.:in<lhol'.:. Ih.: origin<ll or whidt is 10 h.: pr.:s.:nlcd 10 this Courl. is
auach.:d h.:rclo as Exhibit "B." It is pursuanl to this Bond thaI titl.: to Ih.: <llilrcsaid ':<ls':lII.:nt and
righl of wa)' will pass 10 Ih.: 1'.:lilion.:r. wilh th.: au.:ndanl right of poss.:ssion lilr purposes of its
.:asem.:nl. right of W<l)' and installalion of ils pipdin.:.
6. This l'':lilion <lnd Ih.: propos.:d Ord.:r seeking approv<ll and dir,:cling lh.: filing of
th.: rel<lted Bond. will b.: pr.:sented lor approv<lIIO Ihe Cumberland Counly Courl of Common
I'I.:as upon .:xpiration of Ih.: t.:n-day respons.: p.:riod sd forth in 15 I'a. C.S.^- Section
151 1 (g)(2)(ii),
WHEREFORE. UOI UTILITIES. INC., respectfully requ.:sts this Honorable Court enter
an Order approving the form and substane.: of the Bond attached hereto as Exhibit "8," and
ordering that said Bond be filed with the Cumberland County Prothonotary.
By:
evin T. Foge
Attorney lor Petitioner
UGI Utilities. Inc.
1620 Pond Road - Suite 301
Allentown. I' A 18104
(610) 366-0950
PA Supreme Cl. No. 36667
- 3 -
1
VERIFICATION
I, ROBERT J. CHANEY, hereby state and verify that I am the Vice I'resklcnl and
Gcnera! Manager - Gas Utility of UOI Utilities, Inc., that I am authorizcd to takc this
Verification on bchalf of said Petitioner, and that the facts set forth in thc forcgoing Pctition
are true and correct to the best of my knowledge, information and bclief.
I understand that falsc statements herein arc made subject to the penalties of 18 Pa.
C.S.A. Section 4904 relating to unsworn falsification to authorities.
Vice President,'and Gene
UOI Utilifu:!. Inc.
anager - Gas Utility
Date: October 30 , 1998
bao:ld\concl\uc:i-k4zk.cOII-10121/98
INSURANCE COMPANY OF AMERICA, SlIlcty, and cllch oftbem bind themselves, their
successors and llSSicns, fumly by these presents.
Witness the cOl]lol'l1tc seal ofUOI UTILITIES, INC., by the hand of its Senior Vice
President, attested by its Secretary, and the corporate seal of SAFE CO INSURANCE
COMPANY OF AMERICA, Surety, by thc hlll1d afits Attorney-in-Fact on this.JIll day of
~rI998.
WHEREAS, UOI UTILITIES, INC., under lawfulllUthority is about to enter Upon land in
which the Owner/Obligee bas ownership interests and/or rights, to construct a pipeline, together
with such related equipmelltand strumJres as may be required for the transmission of natural gas
over and upon said cc:tain land of the Owner/Obligee, situated in South Middletown Township,
Cumberland County, PA (with said parcel ofland hereinafter being :referred to as "the
Premises"), and with the subject casement and right ofway being herein taken and condemned
being as depicted on the plan drawings attached hereto as Exhibit "A." The casement herein
condemned by the Condernnor/Principal sha11 not intcrf= with said Owner/Obligee's use and
enjoyment of said Premises except for the pUlposes of said pipeline, except that no buildings or
pennanent non-movablc structures shall be placed or erected by the Owner/Obligee or any othcr
persons on or above the surface of the land encompassed by this easement and right of way.
NOW, THE CONDITION OF THtS OBLIGATION IS SUCH, that if the above-bound
UGI UTILITIES, INC., its successors or assigns, or the said SAFECO INSURANCE
COMPANY OF AMERICA, Surety, its successors or assigns, or either oCthem, do and shall
well and truly pay, or cause to bc paid unto the said Owner/Obligee, its attorneys, successor or
-2-
hao:kl\.:onJ\u~i.k'llk.':(lIl.1 ni~ 1/1JN
IN TilE cOIJln OF COMMON PLEAS OF
ClIMIlEIU.ANU COUNTY. PENNSYLVANIA
('IVII. ACTION -LAW
IN RE: CONUEMNATION OF
EASEMENT ANU IUGIIT OF \VA Y
ACROSS LANUS OF EVANGELICAL
LUTHERAN CIIURCH
BY UGI UTILITIES. INC.
FOR PUBLIC !'URPOSES
ORDER
AND NOW. this _ Jay or
. 19<JN.upon .:onsid.:ration ofUGI
UTILITIES. INC.'s P.:tition for Approval and Ord.:r lor filing Bond. th.: Court heing satisfied
that the Cond.:mn... Evangelkal Luth.:ran Church. has h..n giwn prop.:r noti.. of UGl's
intention to pres.:nt the subject Petition to this Co un. and after anording the parties an
opportunity to he heard.
IT IS ORDERED that UGI UTILITIES. INC. is hereby authorized and directed to file the
referenced Bond with the Cumberland County Prothonotary. and that the amount of security
provided in and by that Bond is hereby approved by this Court.
BY THE COURT:
J.
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ha,,:kl\c"Il,I\ugi.kmk,~'''n.1 0/21 19H
IN TilE COllin OF COMMON "LEAS OF
('l1i\lIlEIU.ANf) COIINTY,I'ENNSYLVANIA
(,(VII. ,\(TION - LAW
IN RE: CONUEMNATION OF
EASEMENT ANU IUGIIT OF \VA Y
ACROSS L.ANUS OF EVANGELICAL
L.lJTIIERAN ClIlJRCII
BY UGI UTILITIES, INC.
FOR PUBLIC I'URPOSES
NO. I)H-(,~1)7
OIWER
AND NOW. this _ day of
. 199H. upon consideration ofUGI
UTILITIES. INC.'s Pctition for Approval and Ordcr for filing Bond. the Court being satisficd
that the Condemnce. Evangelical Lutheran Church, has been given proper notice of UGI's
intention to present the subject Petition to this Court. and alier affording the parties an
opportunity to bc heard.
IT IS ORDERED that UGI UTILITIES. INC. is hercby authorized and directed to file the
referenced Bond with the Cumberland County Prothonotary. and that the amount of security
provided in and by that Bond is hereby approved by this Court.
BY THE COURT:
J.
, ,.JIb
.'
hao:kl\condlugi.k;u",con.1 012 Ii'JS
IN TilE counT OF COMMON PLEAS OF
CUMlllmLANI> COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
IN nE: CONI>EMNATION OF
EASEMENT ANI> RIGIIT OF WAY
ACROSS LANDS OF EVANGELICAL
LUTHERAN CHURCH
BY UGI UTILITIES, INC.
Fon PUBLIC PURPOSES
NO. 98-6497
NOTICE OF INTENT TO PRESENT
CONDEMNATION PETITION AND nOND
To: Evangclical Luthcran Church
602 McLand Road
MountHolly,PA 17065
Pursuant to and in accordance with the Pennsylvania Business COl]loration Law of 1988,
Act ofDecembcr 21, 1988 (poL. 1444 No. I 77(g)(2)(ii)), YOU ARE HEREBY NOTIFIED
THAT the attachcd Petition has becn filed with the Cumberland County Prothonotary, and that if
you do not file an Answer or Objections thercto, WITHIN TEN (10) DAYS AFTER SERVICE
OF THIS PETITION UPON YOU, UOI Utilities, Inc., by and through its counsel, will file a
Motion with thc Cumbcrland County Prothonotary, and prcsent it to the Court for approval,
seeking cntry of an Order in the form attachcd as Exhibit "e" to UOI's Pctition, directing the
filing ofUGI's original Bond.
~~
Attorney for VOl Utilities, Inc.
hall:kl\condlugi.kmk,clln.( 0/21/98
of constructing, operating, maintaining, rcplacing and changing a pipeline for thc transponation.
lransmission llnd distrihution of nalural gas with thc ri~hl in said company, its succcssors and
assigns to entcr upon such eascmcnt and/or right of WilY at such timcs as may hc fit and
ncccssary for said purposcs.
3. Petitioncr bclicvcs and avcrs thatthc only pcrson or entily having an owncrship
intercst in the propcrty bcing condcmned is Evangelical Luthcran Church. bcing thc sole legal
and cquitablc titleholder (hcrcaftcr "thc Owncr"). Pctitioncr bclievcs and avcrs that said Owncr
holds solc legal and cquitablc title to this property, by vinuc ofOceds rccorded at the
Cumberland County Recorder of Deeds Office, at Dccd Book Volume A31, Page 517 (dated
November 15, 1984), and at Deed Book Volume 123, Page 123 (dated August 5,1970).
4. Since in or about September, 1998, the Petitioner, through its agents and
employees, has attempted to secure an agreement for a pipeline easement and right of way ovcr
and through the subject parcel of land from the Owner rcferenced in Paragraph 3 hereinabovc. In
that respect, the Pctitioner has attempted to contact thc Owner to try and agree as to the damages
properly payable, but to date has been unable to do so for the purpose of cntering into an
agreement! contract for such easement and right of way; hencc, thc Petitioner and the Owner
have not agreed upon rcasonablc compensation to be paid thcrcfor and to affix the amount of
damagcs, if any, which would bc occasioncd by thc taking of said casemcnt and said right of way
and thc construclion of said pipclinc.
-2-
, '. bao:Jd\cond\uei-k:uk.con.1012II11!
INSURANCE COMPANY OF AMERICA, Surcty,lUld eacb of them bind themselves, their
successors and Ilssicns, finniy by these presents.
Witness the cOl]lOr.1le 5e~1 of UOI UTILITIES, INC., by the hnnd of its Senior Vice
President, attcsted by its SccrclaQ', and the corporate se:d of SAFE CO INSURANCE
COMPANY OF AMERICA, Surety, by the hand ofits Attorney-in-Fact on this..3Ll1 day of
~rI998.
WHEREAS, UGI UTILITIES, INC., under lawfUl nuthority is about to enter upon land in
which the Owner/Obljzee has ownership interests and/onights, to constructa pipeline, together
with suc:h related equipment and structures as may be required for the transmission of natural gas
over and upon said eertain land of the Owner/Obligee, situated in South Middletown Township,
Cumberland County, PA(with sa!a parcel of land hcrcin~er being :referred to as "the
Premises.), and with the subject casement and right of way being herein t8kcn and condemned
being as depicted on the plan drawings A~t'I1..d hc:rcto as BxIu'bit .. A." The casement herein
.eondemned by the Condemnor/Principal shall not intcrfc:rc with said Owner/Obligee's use end
enjoyment of said Premises exeept for the purposes of said pipeline, except that no buildings or
pCIIIlanent non-movable s1Iucturcs shall be placed or erected by the Owner/Obligee or any other
persons on or above the surface of the land encompassed by this easement and right of way.
NOW, THE CONDITION OF THIS OBLIGATION IS SUCH, that if the above-bound
UOl UTILITIES, INC., its successors or assigns, or the said SAFECO INSURANCE
COMPANY OF AMERICA, Surety, its successors or assigns, or either of them, do and shall
well and trUly pay, or eause to be paid unto the said Owner/Obligee, its attorneys, suece~sor or
-2-
bDo:ld\c:ond\ugj.k:ark.con.1 012 11')8
N$iCns, the dam:lges it may sustain by I~oa of the appropriation of the pipeline richt-of-woty
and easemcot and the collStrw:tion oftha pipeline over !be property herein described, when
datn.1gcs sball be agn:ed upon by the parties, or shall have been lecal1y awarded to said
Owner/Obligee, wilh inlerest and costs, if any may be due, for which sald Principal is liable, then
this obligation is to be void; otherwise, to be and remain in full force and effect.
ATIEST: '-'//
#II;:c<.'I
A.!..:.~S
n.>...,'..u, cc"wy
Robert Krick
(CorpolUte Seal)
U~~Il1E);T', n
~~r
Brendan P. Bovaird
Treasurer
In the pxoscnce of:
SAFECO INSURANCE COMPANY OF
k2t4%d/~
Darel1a R. Vhttp
Attorney-in-Fact
'Wil:sio s;/' "~ :LA":)
Irma I. Torres
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SArEccfD
POWER
OF ATTORNEY
=Af[CO IN~uA^r<<:( C()f.APAHV OF AM(IlCA
en.OAt IN~UIlANCC C()t.A'ANV 01 AJA:IUCA
lOA: O"IC[: SAf[CO PLA'.
S(ArtL[. WAStllHOT~ ""~
No. 6014
KNOW AU IV THUE PRESENTS:
Till. CAFECO IN~unANCt COMPANY OF AMERICA ond OtNtRAL INSURANCE COMPANV OF AMeRICA, e",h 0 w.sNngton
torpor.llon. dOoS l,JCh horoW appoint
.....OARELLA [, WHlf[j DONALD J. OAIL[Yl OMOU OCUOCSKY, Phlladolphla. Ponnsylvanla............
I1s true and law'''' .1Iorncr.<s)-ln"fJct. with ful IV1hOrlly 10 exocute on Its bohalf fldolilY and slSOly bonds or Uldor1lklngs a'\d other
dOct.monls of I s.iTli1,)l" ch3rICtor Issuod In tho courso of Us bu~noss. and 10 bind tho rospective canp.1tly IhOroby.
IN WITNESS WHEREOF, SAFECO INSURANCE COMPANY OF AMERICA and OENERAL INSURANCE COMPANY OF AMERICA h.1vo uch
Ixocutod and Ittoslod IhOso prosents
'hiS
22nd
d>i of
March
. 19.!!2-.
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CERTIRCA TE
ElC1rac1 frcim lho By-Lows of sArceo INSURANCE COMPANY OF AMERleA
ond of OENERAL INSURANeE COMPANY pF AMERICA:
'Arllclo V, Section 13. - FIJEl.ITY AND SUlETY Il(NJS . . . tho President. In( Vlc. President. tho secretary. IlIld .., AssIst'"" VIce
Pr.sldent appointed for tl\at _so by lho olllc.. In charge of ......ty oper.tlons. shall .ach h.1v. IUlhorlty to appoint Incfvlduals as
. oUom&y$-ln-foct or lnl.. other __oprl.te tltI.s wI.h IUthorlty 10 ,xecu1. on behalf of lho c~.., fld.llty and u.lY bonds and
other docunents of smIl11' character ISSUOd by tho c~.., In tho Cau's. of lis business . ; . On .., Instrunent making or evidencing
SUCh eppoin.....nt. tho signat....s <n:1f be olllxed by facsl'rile. On 3T>/ Instrunent conf.rrlng such authority or on In( bond or ~aklng
of tho ~. tho s.... or a focsmll. ther.of. """ be ~ess.d or olllxed or In In( other manner reproduced: prOYiOOd, however.
that lho soal shall not be necessary to tho validity of ont such Instrunent or undertaking.'
ElC1ract from 0 Resolution of lho Board of Directors of sArceo INSURANeE COMPANY OF AMERICA
one! of GENERAL INSURANCE eOMPANV OF AMERleA adopted JUy 2B. t970.
-an "'" cerllfici!te exocuted by tho Secretary or an assistant secretary of the Ca"npaN{ setting out.
(0 Tho prOYislons of Arllcl. V. Secllon 13 of tho By-Lows. and
(II) A copt of the power-or-attorney appointmGnt. executed ptrsuant thereto. and
(III) Certifying lhat said power-of-allorney appointment Is In f<./I force and .rroct.
the signatc..re of the certifying officer fT'l<fi be bv facsimile. and the soal of tho Canpany may be a facsimile lhereof,-
L R. A. Pierson. SecrOlary of SAFECO INSURANCE COMPANY OF AMERICA and or OENERAL INSURANCE COMPANY OF AMERICA,
do hereby certify that the foregoing extracts of tho By-laws and of a Resofution of tho Board of Directors of those corporalions. and
of a Powor of Attorney Issued pc..rsuant thorota. ars true and correct. and that both tho By-Laws. the ReSOlution and the Power of
AlIornoy ara still In full (orce and effect.
IN WITNESS WHEREOF, I have herOlS\to sot m{ hand and affixed tho facsimilo soal of said corporation
lhis
3rd
. 19 J1.lL.
November
d~ of
S.O'WEP 1/03
@ RegislereCl trademark of SAFE CO Corporation.
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UGI UTILITIES INC.
GAS UTILITY DIVISION - HARRISBURG AREA
F'l.AN5 "To M(c"'PIlIJ'I ftC.I-eIEIIIIZ'/JT
~E1wEl?'/-) ~I \J-r1L-1T1e.5,I/-!c. AJUP
eVrt/JGE/-lcI\L l.U"{liE:R N C+l\;;a.CH
cove>2-{1J1. ,lie" 11oJ$1'A-l..l.I\"'(Iol!I of,'
C>tJc: 'l.r <;1'\:> MAlI\) $llvA'T~P ttJ
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/..1./-)1) C'<>vl-'"(Y PII., _,
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~f'r~ 1..1\lJe: TO L-lt:: I l"OHti
'of !'Vot.,H CVI,Q...~ 1-1.....1: e.F
,^^c.LA-tv'Cl; .nE' ~fi1frl/J'1::>~ra. of"
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IN TilE COI I 1rI' OF CO:\li\ION PLEAS OF
CIIMIIEIU.ANU COUNTY, PENNSYLV,\NIA
('IVIL i\CnON - LAW
IN IU:: CONIlEMNATION OF
EASEMENT ANI) IU(;IIT OF WAY
ACIWSS LANUS OF EVANGELICAL
LUTIIERAN CIIUllCII
BY UGI UTILITIES, INC.
FOR PUBLIC I'URI'OSES
NO. 9H-(,497
ORl>lm
AND NOW, this _ day of
. 1998. upon consideration of UOl
UT[LlTIES. INC.'s Petition for Approval and Order for filing Bond. the Court being satisfied
that the Condemnee. Evangelical' Lutheran Church, has been given proper notice ofUGl's
intention to present the subject Petition to this Court, and after affording the parties an
opportunity to be heard,
[T [S ORDERED that UOl UTILITIES, [NC. is hereby authorized and directed to file the
referenced Bond with the Cumberland County Prothonotary, and that the amount of security
provided in and by that Bond is hereby approved by this COUll.
BY THE COURT:
J.
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LAW OFT ICES
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KEVIN T. FOGERTY
1620 J'>ONO ROAD, SUITt. 30'
ALLENTOWH, PENNSYLVANI/'" IBI04
EVANGELICAl. LUTllFRAN C1IURCII
602 McLAND ROAD
MOUNT [-lOLLY PA 17065
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KEVIN T. FOGERTY
1620 "ONO ROAD, SUITE 30'
ALLe:NTOW~-l. PENNSYLVANIA /8104
LA W OFFICES OF KEVIN T FOGERTY
1620 POND ROAD
SUITE 301
ALLENTOWN PA 18104
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