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HomeMy WebLinkAbout00-08675 ~ - J - , .~, /" vVRIT OF POSSESSIO~-Ejecrment Proceedings PRep 3160 - 3165 erc,) KEYSTONE FINANCIAL BANK, -N:A. .. -------------------------------------------- D THE COCRT OF cm.{:,rQ); ?L.E.-\.S OF Cl..,,{BERL-\.c.u COl..""TY, ?E..,");S'I"'L V.-\...''-r..-\. S/I/I FIANCIAL TRUST COMPANY -----~------------------------------------~ )io, 00-8675 -------------------------------- T= 20______ :-;0 -------------------------------- T = 20______ ''''- COSt, VASILIKI T. PHILLIPY OR OCCUPANTS .-\.::':" _______________________________ s___.l.Ql.:1l_4__ ------_____________________________________4 P!'~f ;'. _____________________________ ~___________ ?cor~v. ______________________________ s______~~33__ CO~o'IO~"WE.._\.LTH OF ?E......"SYLV.-\......'A; cac)'"TY OF CC),[SE.RL-\.......u: Tu:ne She:-ifi oi __________:~.::~.:.~~~~~___________ Coun",,-, P",n3.. ( 1', To n:tisiv :he iudpe:'l:: :0:' iJ~on in :.~e .loa '...~ :n:LC":e:" '.-ou. :lre ,~::e<::~d. :0 .:.e~,h'e:" ~se:sion cf. :one foi:l~~~ desc...-:bed ProPe~l .~: ". . KEYSTONE FINANCIAL BANK, N.A., S/I/I FINANCIAL TRUST COMPANY -------------------~----------------- --------------------------------------------------------------~ ------------------------------------------------------------------------------------------ ?!.:1i:u:ff i bei:1g: I.P:-=i= 3S loaaws;: 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, ,PA 17065 /' l1: TlJ ~-I:t:~ .:.oSts ~:.i...~c ~e~e!e:ncUnt .:s!, you JI~ d.i~ed to :e'..,~: ~?On J.:~y ?t"O?!':'::/ or d.:lnt ,i,; .l.C<i ie:l::;.3 n;:" ,or ::'"1'C:' :r..c_...,;).. ~'1er~::1. x.e cc:::,e-::,.. Dac. ..May__4,~_G.9.9J.____________ .. -------- ,SE.u.) , eu~tis R. 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B~ v1rt:re \)f ,h..;" ..".:i.t. on :.~e _____________________d:a~. ,){ _..._..._______________________________. ~ , " " ? ? ,0 ,0 " ,00 '''' '-.../ \.11 ...; Q - N N 0 0 :('1 ----------------------------------------------------~--------------------. :?~----~ ~:J.used :he wi thin :lamed . .. -.... ~.J " ,t., , i-m.';~ pO'S.3es.rion or ~hf' ?rl"'!:llse!. d.~or."'J, '.'il::~l ':....~ .J.??Ur':~:1.:ln_ce"t, 'J.:'lc. _______~_____~____..._______~~___________ NO ACTION TAKEN AS PER ATTY, _P13O!'~~_!;;_YA<;;@.J__WJS_}'lli1T_m______________________________, --------------------------------- - - IS RETURNED STAVED. --------------------------~_._--~----_. --------------------------------------------------------------- SHERIFF"S, COSTS, ADVANClLQ2S'I'S_nS_lSfWl.O_______ ____n_____~________ - --- h_ __h__________________________ ..-n--n--SHERIFF' S COSTS 38.86, DOCKETING $ 18.00 , __m_n____!!!_.}_~~___ e~Q'I'A~Y--------l.D~--..---------------------,-----------_____________ ~ ~. E 9.10 REFUND 'IO ATTY ON 7/19/~ S 'GE 10.00 \::::::V GE --:76- @3 @ 38.86 -0. .\..i~'.H::~. tt;' . " 3L .L ~......)rt"...l..'1 -:,:~n~c:'~~'Cl:.J ::C'=;}r~ :::''.c: :!US __ ~:____'~_...__ '1~'. ,>( _ _n___________n__n.____n. /f!}_~_~.. n. /) VI.;' _4!'!.-r._...____. ..v-------..-~--tc6.-.I~~-l '~F':/ P:'Clthonoc;J:ry . -------_._---_._-~ ~hc;r:t"~ -:.. - '. ~ ~ . - - " ,'~. ---------~----------~----~-----~--------------- iJe'?U.:y 1,..-0 cJ<.. 33V7(P I ;~ fl'i 9'i{" I,. .', '" ~ ... FEDERMAN AND PHELAN 'BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 Suite 1400/0ne Penn Center at Suburban Station 1617 Jo1m F, Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAlNTWF KEYSTONE FINANCIAL BANK, N.A. SIIII FINANCIAL TRUST COMPANY COURT OF COMMON PLEAS CIVIL DIVISION vs V ASILIKI T. PHILLIPY OR OCCUPANTS 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17065 No. 00-8675 CUMBERLAND County PR A F.CTPF. FOR .rrmfiMFNT TN F..TF.CTMFNT TO THE PROTHONOTARY: Kindly enter Judgment in Ejectment in favor of the Plaintiff, KEYSTONE FINANCIAL BANK, N.A. S/III FINANCIAL TRUST COMPANY and against the Defendant(s) VASILIKl T. PHILLIPY and OR OCCUPANTS for possession of premises 21 CHESTNUT STREET, MOUNT HOLLY SPRINGS, PA 17065 pursuant to the attached court order dated April18, 2001. -=t-~ +~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Default Judgment entered as indicated above, DATE , J "". , , ..;.;1-," ~ ... KEYSTONE FINANCIAL BANK, N.A. IN THE COURT OF COMMON PLEAS OF SIIII FINANCIAL TRUST COMPANY : CUMBERLAND COUNTY,PENNSYLVANIA 2270 Erin Court Lancaster, PA 17604 : NO. 00-8675 CIVIL TERM VASILlKI T. PHILLlPY or occupants 21 Chestnut Street Mount Holly Springs, PA 17065 IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT ORDER OF COURT AND NOW, April 18, 2001, the Court has determined that Plaintiff is entitled to Summary Judgment as a matter of law, and therefore: Orders and Decrees that judgment is entered in favor of Plaintiff and against Defendant(s) Vasiliki T. Phillipy or occupants, for immediate possession of the premises located at 21 Chestnut Street, Mount Holly Springs, PA 17065. B the Court, Kathleen B. Mazzafro, Esquire Federman and Phelan One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 For the Plaintiff P.J. Vasiliki T. f1hillipy or occupants 21 Chestnut Street Mount Holly Springs, PA 17065 ~ "I .....'" h~( .. FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO, 12248 Suite 1400/0ne Peml Center at Suburban Station 1617 John F, Kelmedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FORPLAlNTIFF KEYSTONE FINANClAL BANK, N.A. SllII FINANCIAL TRUST COMPANY COURT OF COMMON PLEAS CIVIL DIVISION vs V ASILIKl T. PHILLIPY OR OCCUPANTS 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 No. 00-8675 CUMBERLAND County VF,RTFTc.A nON OF NON-MH.IT ARV SF,RVTC'R FRANK FEDERMAN, ESQUIRE, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) That the defendant(s) islare 'not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant V ASILIKI T. PHILLIPY Or occupants, is over 18 years of age, and resides at 21 CHESTNUT STREET, MOUNT HOLLY SPRINGS, P A 17065. This statement is made subject to the penalties of 18 P A. C.S.S 4904 relating to unsworn falsification to authorities. II~ -=t-~~~, FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .' ~~ ,. " - ~" , " " ~:... , '~&' ~ PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND KEYSTONE FINANCIAL BANK, NA S/IlI FINANCIAL TRUST COMPANY COURT OF COMMON PLEAS CIVIL DIVISION vs V ASILIKI T, PHILLIPY OR OCCUPANTS 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 No. 00-8675 CUMBERLAND County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARy: Issue Writ of Possession in the above matter for possession of: 21 CHESTNUT STREET, MOUNT HOLLY SPRINGS, P A 17065 **PLEASE SEE THE ATTACHED LEGAL DESCRIPTION*** Being Known as No. 21 CHESTNUT STREET =+-~~t~~ FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF ,~~6i1iF.~+-,"d",:;,;i~;Hiii~-,-oi\~~'&.'li""""""",",<:;"",~;,j4"~',,,,~,,-mi,'&"JI'i>1.Nj!..",;(jil~."'lif,,!iil"l!IlfI!ii:frill>111il't__~_~~!iIOO~(lil1~lil;liIIt_liililIll =~.' ~ ~"~il < , - ~"~.....~~ t? ("0 ~~ 7- ~ lS9 .... o - . "Q <..t ~ ~ " "'.; ~ N "<l ~ :--. & f) , ~, .,. , I, .--- ~~ " ~.~ b ~ 8 d lAv 0 I ~ () ::: r~ ~ ;:- .:- ~ ~ ~ - ... o ~ -Off;' ~q:i 7-" 0S ~;;::> :;::::8 ):> :z:0 j;;O c: ~ If Ci c--' -, ..,.. -~ ::;c..! I .C' ''''1-....,. ...1:: ',:. (~i '~':::;/~ g~ ;::-j 1] -< -0 -,,,,. ~ ::> .", ~ ~ '" . I" ""' ,.~ .. ~ ARACOR Search and Abstract Services, Inc. One Penn Center, 1617 J.F.K. Boulevard, Suite 305 Philadelphia, Pennsylvania 19103 (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE Effective Date: 6/23/2000 Order Number: Client Number: A42440 Premises: 21 CHESTNUT STREET, BOROUGH OF MOUNT HOLLY SPRINGS CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth. This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the Northeastern corner of Chestnut Street at a limestone adjoining Lot No, 3; thence South along Chestnut Street, Eighty (80) feet to a limestone; thence West along land formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), now or formerly of Rose C. Wolf, One Hundred Eighty-five (185) feet to a limestone; thence North along said land now or formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), Eighty (80) feet to a limestone; thence along Lot No.3, on the Plan mentioned below (185) feet to a limestone, the place of beginning. BEING Lots Nos. 4 and 5 of the Mathew Moore Plot of the Town Lots having a width on Chestnut Street of Eighty (80) feet and a depth along Lot No, 3 of One Hundred Eighty-five (185) feet, and being improved with a two and one-half story frame dwelling house known as a numbered 21 Chestnut Street. T AX PARCEL NUMBER: 23-32-2336-202 '~'-ir " ".', -~ -- 1-- ._',; ,0 "_'" 'or', ;-,' "~1(f i KEYSTONE FINANCIAL BANK, N.A. : IN THE COURT OF COMMON PLEAS OF SIIII FINANCIAL TRUST COMPANY : CUMBERLAND COUNTY,PENNSYLVANIA 2270 Erin Court Lancaster, PA 17604 , " d Ii [1 I! n , r\ i,i : NO. 00-8675 CIVIL TERM i.-i l ~ " !' VASILlKI T. PHILLlPY or occupants 21 Chestnut Street Mount Holly Springs, PA 17065 ,r" 1'1 (~ IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT ORDER OF COURT , .;:i " "j :~ :j " .! ,I AND NOW, April 18, 2001, the Court has determined that Plaintiff is d Orders and Decrees that judgment is entered in favor of Plaintiff and , it [1 n' :1 ,i is i~ entitled to Summary Judgment as a matter of law, and therefore: against Defendant(s) Vasiliki T. Phillipy or occupants, for immediate possession of the premises located at 21 Chestnut Street, Mount Holly Springs, PA 17065. B the Court, Kathleen B. Mazzafro, Esquire Federman and Phelan One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 For the Plaintiff . offe~ A ,,\9J>f\ 0\ L..C'( o~.~S P.J. Vasiliki T. Phillipy or occupants 21 Chestnut Street Mount Holly Springs, PA 17065 j)J ~,"" ,~. ',,,.,~.. '" "'." ~ ," j'"' iU Clji\f:r,:'~ --, " l' p;:i", i':.,-;(I'-./L\ !,', 1'/, ~ ,",I\U I I','~'';\i 'I -1'- ,~ " ""-'<" ~ ",-,," ''C'" ,,~---~~~,,-= ,", ,=_. '~, " '. if( ..!~,' I , .,'_~.~,,"'''''''''~__, "'~~=~,I\~,o:r"'- ~,~1.~'Tf,1Wi~~f,f.'W'n'Ai'!ffi[~J~~~F!I~f~1i~,,.,'""'" 'T,~;~,,-n~ ,,"_....~--~~ '". ,', -' ~-" ,j . t,. " -.i "'tl"I~ FEDERMAN AND PHELAN By: KATHLEEN B. MAZZAFRO, ESQUIRE Identification No. 80990 One Penn Center at Suburban Station 1617 John F. Kennedy Bol11evard Suite 1400 Philadelphia, PA 19103-1814 (9.1 ~) 1)0;\-7000 Keystone Financial Bank, N.A. S/I/l Financial Trust Company 2270 Erin Court Lancaster, PA 17604 Attorney for Plaintiff Court of Common Pleas vs, Civil Division Vasiliki T. Phillipy or occupants 21 Chestnut Street Mount Holly Springs, P A 17065 Cumberland County No. 00-8675 PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COllECTOR ATI'EMTINGTO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATI'EMPTTO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST THE PROPERlY, MOTION FOR STTMM A RY JTTOr..MF,NT Plaintifi; Keystone FInancial Bank, N.A. S/I/I Financial Trust Company (hereinafter "Plaintiff"), by its attomey, Kathleen B. Mazzafro, Esquire, respeclfully requests that this Honorable Court enter an Order granting Summary Judgment in the above-captioned matter for the following reasons: 1. As the successfUl bidder at a Sheriffs Sale, Plaintiff became the owner of the premises located at 21 Chestnut Street, Mount Holly Springs, PA 17065, by a Deed from the Sheriff of Cumberland County. A true and correct copy of the Deed is attached hereto as Exhibit A. 2, Pfaintiff notified the occupants to vacate the premises, but, to date, they have remained in the property. A true and correct copy of Plaintiff's notice to vacate is attached hereto as Exhibit B. 3. Because the occupants have refused to vacate the property on their own, Plaintiff fIled an ejectment action on December 18, 2000. A true and correct copy of the Complaint is attached hereto as Exhibit C. 4. An Answer to the Complaint has been filed, A true and correct copy of the Answer is .- ~ " - "jf -~, l' ,~ )'! ..', ..... ,'L' ~ "" -- _ -.l;~ ."'-', ~. 'j~k'ii I I I I , '., attached hereto as Exhibit D, 5. Plaintiff respectfully submits that it has established its right to irrunediate, exclusive possession of the premises, and there are no material issues of fact in this case for a fact-fmder. 6. Plaintiff incorporates herein it<; Brief in support of its Motion for Summary Judgment. WHEREFORE, Plaintiff respectfully requests that Judgment for possession be entered as prayed for in the Complaint. Respectfully submitted, ~~ Attorney for Plaintiff 2 -~~ '.'it-'" .., . ~, '" _~l.__, FEDERMAN AND PHELAN By: KATHLEEN B. MAZZAFRO, ESQUIRE Identification No. 80990 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (51.1~) t;1i~-7000 KeyslDne Financial Bank, N.A. S/III Financial Trust Company 2270 Erin Court Lancaster, PA 17604 Attorney for Plaintiff Court of Common Pleas vs. Civil Division Vasiliki T. Phillipy or occupants 21 Chestnut Street Mount Holly Springs, P A 17065 : Cumberland County : No. 00-8675 r:FRTTFTr:ATION OF SFRVTr:F. I hereby certifY true and correct copies of the foregoing Plaintiff's Motion for Summary Judgment and supporting Brief were served by regular mail on Defendant(s) at the address and on the date listed below: Vasiliki Phillipy, Pro Se 21 Chestnut Street Mount Holly Springs, P A 17065 DATE: c9//;J/oj , I ~~ Kathleen B. Mazzafr e Attorney for Plaintiff ~ ,~".. ~~, --.1!Mililtl€..__WJ~~~*.tJj~"'li1L'\O~Jm~",~l>';-1i,,,~,-~~'l~ll1:W""" " ..=~=, ~~'~lilk__t" ';;""e. ~~" ,'"'"" , ",""'.'" ,," 'J ~ ," 0 0 0 C .'rl ~, .." --~ -oCJ rfl ,--- mf--~l ::0 ~J 2:U :';-'j z: 3 ;', ':;:J <::Q UJ c;' r, r-' C) u / V '''!'. :::> -'-'j c -- '~,~ ;:-"'~ ~ (5 " )> ,- -;-,-::;c::; I 11 c: ~, Z ,:=> ~ --j :n ~, C;:J -< Jl; ", ",', ' r'~ PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE (entire caption must be stated in full) Keystone Financial Bank, N.A. S/i/i Financial Trust Company 2270 Erin Court Lancaster, PA 17604 (Plaintiff) vs. Vasiliki 1', Phillipy Or Occupants 21 Chestnut Street Mount Holly Springs, P A 17065 (Defendant) No. on-Rh7~ Civil Tprm 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Plaintiffs Motion for Summary Judgment 2. Identify counsel who will argue case: (a) for plaintiff: Address: Kathleen B. Mazzafro, Esquire One Penn Center at Suburban Station Suite 1400 1617 J.F,K. Blvd. Philadelphia, PA 19103-1814 (b) for defendant: Address: Vasiliki Phillippy, pro se 21 Chestnut Street Mount Holly Springs, P A 17065 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: Date: 2//2/0 { ~~ Attorney for PIa ti ~ ll~ I, ~ ~ I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEYSTONE FINANCIAL BANK, NA, Plaintiff v. No. 00-8675 CIVIL TERM V ASILIKl 1. PHILLIPPY Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER TO COMPLAINT AND NOW, this 8th day of January, 2001, comes Plaintiff and Answers Complaint as follows: I.) Admitted. 2.) Admitted. 3.) After reasonable investigation Defendant is unable to ascertain the truth or falsity of these statements; therefore, specific proof is demanded. 4.) After reasonable investigation Defendant is unable to ascertain the truth or falsity of these statements; therefore, specific proof is demanded. 5,) After reasonable investigation Defendant is unable to ascertain the truth or falsi1y of these statements; therefore, specific proof is demanded, 6.) Specifically denied. Plaintiff has never contacted Defendant as to the Sheriff s sale or to its rights or desires that Defendant vacate 1 ".~" ~, . the property. Plaintiff has continually failed to notify or contact Defendant as to many ofthe matters surrounding the property. WHEREFORE, Defendant requests that this Court dismiss the present action. tiJh /A ASILIKI T. ILLIPPY, Pro 21 Chestnut Street Mount Holly Springs, P A 17065 ~" .. - I~, ~'lli' ~,...~ " "".., I, , -~, ,~ .l VERIFICATION The undersigned, Vasiliki T. Phillippy, hereby certifies that the statements made in the foregoing Answers to the Interrogatories posed by Defendant are true and correct to the best of her knowledge, information and belief. It is understood that statements made herein are subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities. Date: 0:1' ,< ~ ". ~ .~- ~. >' l\li.Liij~:'~ , . I, Vasiliki T. Phillippy, do hereby certify that I am this day serving a copy of1he foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirement of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class postage prepaid as follows: Frank Federman, Esquire Felderman & Phelan, LLP One Penn Center At Suburban Station 1617 JFKBlvd, Suite 1400 Philadelphia, PA 19103-1814 D,~ ~if1 D j(jd I , ., ~'~irn:~,iiiI!l.o"jI;;,:!L,.,;;',,;,,j'i~:,;;,j,;;1~,?"",'ifil*~--"I,14"'-oi~',f&116,,,,,. ,~"d:,~,,,,,"&,,,s'- .cg,-ii<' -;"Jf;""",""f"Kc~';;'li!~"~'i&~4i;,'j>'-.di!ll';~~41"";;;:1!>~,,.;;;;j"""[j - ~, ........ ,~,-:~k" L.~:""r:lm.U~<~_, ..,~ ,~ ,'~ ~~~ _ , ,~_ ~_ ,qe' '-,~,'~' ~I",-..-~..~ C) c; .' -r; j--:-,) Cl}C; ~.--' ti;!:-': r::::.., ',-" "-', ;:'~~ ?; -< C::J ._- ~~~'" w_~ . '-,,," " , , -~, '-- '~::; (.::::J ,"7'1 '~~) --c~ -i(,} ,. " ;~f~ ;;;; ::< "" \0 1m ""-, ,.. ~~ I.. I, ,l" ,-L-' 'J;', .. . DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND, PETITION AND NEW MAnER, Keystone Financial Bank, N.A. S/I/I Financial Trust Company 2270 Erin Court Lancaster, PA 17604 vs. No. 00-8675 Civil Term Vasiliki T, Phillipy or occupants 21 Chestnut Street Mount Holly Springs, PA 17065 RESPONSE TO PLAINTIFF'S MOTION FOR SUMMARY JUDGEMENT: 1.) AND NOW, this 5th day of March, 2001, comes,,Defendant, Vasiliki T. Phillipy, and responds to Motion for Summary JUdgment as filed by Plaintiff: Defendant, as attested in the Answer To Complaint bearing the date of the 8th day of January, 2001, has labored and struggled without adequate communications from Plaintiff as to the condition of the situation under which Defendant finds herself. Defendant attempted on many occasions to properly determine, from Plaintiff, answers to procedural questions and practical considerations in order to cooperate with proceedings and requirements of Plaintiff. Said attempts of Defendant were repeatedly met with incomplete and untimely responses or with no information or response ~orthcoming from Plaintiff. These difficulties have created an extreme burden for Defendant in understanding and participating in decision making regarding the development of events and circumstances which effect the outcome of these actions. 2.) DefeMant has suffered throughout the preceding and current term of these actions, with a perpetually deteriorating state of mental health related to depressive illness. Defendant has been, and remains currently, on medications and under the care of a physician for these conditions. Treatments and responsiveness to these modalities has had varying degrees of effectiveness for Defendant, and at many times Defendant has had to live as a seriously impaired individual. These circumstances have created substantial difficulty for Defendant to adequately grasp the severity of her situation and to ta~e remedial action to alter the course of events. This has been exponentially exacerbated by the difficulty in receiving proper notifications and responses from Plaintiff. 3.) Defendant respectfully submits that circumstances surrounding the referenced conduct of Plaintiff and the medical conditions outlined herein have had a material impact on Plaintiffs ability to position for the Motion For Summary JUdgment, and that such circumstances should be given due consideration in finding a solution for the problems averred by Plaintiff. NEW MATTER AND PETITION 4.) Defendant recognizes a responsibility to cooperate and to provide assistance for the Plaintiff in the event this honorable court should issue an order or decision favorable to the position held by Plaintiff. In this regard, it would be most beneficial for all parties concemed if the Defendant was to be granted an extension of 30 days from the docketed date for argument of this issue to vacate the referenced premises. 1 I. " ~ ,~ ,I" "'''; , 5.) Defendant has, as of the filing of this Response, notified concemed family members of the plight in which she finds herself and has engaged their assistance for examining the options available to her. Prior mental health difficulties prevented Defendant from making these most essential contacts which will assist and enable Defendant to make more reasonable choices about those few resources which have been retained as worldly possessions necessary for Defendant to establish and maintain an independent household. 6.) The premises subject to the outcome of these proceedings represent the family homestead which was occupied by the immediate and extended family of the Defendant for over 40 years. Defendant acquired this property after the death of her father. Defendant's mother predeceased the father by 20 years. Consequent to this extensive family history of occupancy, the premises is fully stacked with family memorabilia and artifacts. Although this large amount of material has little residual value, it represents the Defendant's family history for many generations and it is deservil19 of proper distribution to surviving siblings and extended family members. It is planned for these important keepsakes to be removed from storage, reviewed and distributed appropriately. The volume of material in question makes the task at hand extended and difficult requiring out-of-state travel for relatives in other parts of the country to visit and assist in this process. WHEREFORE, Defendant requests that this honorable court, if findil19 for the Plaintiff in this malter, grant a 30- day extension of time from the docketed date of argument, for Defendant to fully execute the plans as outlined in this Petition. tJ~ () fXlI1J' VAS/UKI T, PHILUPY, Pro Se 21 Chestnut Street Mount Holly Springs, PA 17065 3/:)/6/ 2 ... . VERIFICATION The undersigned, Vasiliki T. Phillipy, hereby certifies that the statements made in the foregoing Response To Plaintiff's Motion For Summary Judgment And, Petition And New Matter are true and correct to the best of her knowledge, information and belief, It is understood that statements made herein are subject to the penalties of 18 pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: 3/0 )6/ { , , i , , 1 ~ - . "'--..l. " "',' --L'~ ,- 'J " < ' . PROOF OF SERVICE I, Vasiliki T. Phillipy, do hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirement of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class postage prepaid as follows: Frank Federman, Esquire Kathleen B. Mazzafro, Esquire Felderman & Phelan, LLP One Penn Center At Suburban Station 1617 JFK Blvd, Suite 1400 Philadelphia, PA 19103-1814 5/s ft/ Date: 1 i~~'I!.iI"IM'-_ij~;!;~,,;;di'MjjiliMllf&~~"iItm'\)liruji,,","ii-,j:JfI"'-'d~>t;~b''''1JL..;,l~,,'1i;~iS~~~i>iI!.~~h~~:Br ~~~' 0 'I.'j ,", _, ~"""'" ' "_M ~~ Ll ~,-- ";", . 0 C' 0 C -q ;;:: 3: --,f ~ro "'" :J: _~ Tn "'" z:U 1'1'1"":-.' ,- we I ""~':',f('n -.J .,:-'0 -<.2: i':> L ~CJ .." ':_.iC) ~o I~Ti :x . " 00 )>0 Zr- C 0" ~ UI ~ (J:) -< wq r"'"'" ~=~ '"^C' ~"'~_~. ~ L .<'~"l' SHERIFF'S RETURN - REGULAR CASE NO: 2000-08675 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KEYSTONE FINANCIAL BANK N A VS PHILLIPY VASILIKI T RICAHRD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon PHILLIPY VASILIKI T the DEFENDANT , at 0013:22 HOURS, on the 27th day of December, 2000 at 21 CHESTNUT ST MOUNT HOLLY SPRINGS, PA 17065 by handing to VASILKI T. PHILLIPY a true and attested copy of COMPLAINT - EJECTMENT together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.34 .00 10.00 .00 32.34 ~~~~<~f R. Thomas Kline 12/28/2000 FEDERMAN & Sworn and Subscribed to before By: eriff me this 3~ day of ~AAI d.o-r} I A.D. ~ (l , - L._ YvuP t..v ~ Prothonotary , ", I, "' FEDERMAN AND PHELAN, L.L.P. One Penn Center Plaza at Suburban Station Suite 1400 Philadelphia, P A 19103-1814 (215) 563-7000 Fax: (215) 563-4491 Email: michcle.bradrord(a)rc<lphc-pa.com Michele M. Bradford, Esquire Litigation Department Representing Lenders in Pennsylvania and New Jersey' Apr1l9,2001 Office of Lhe Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Re: Keystone Financial Bank, N.A., 5/1/1 Financial Trust Company vs. Phillipy Cumberland County, No, 00-8675 Dear Sir or Madam: Enclosed for filing with the Court please find Plaintiff's Affidavit and Certification of Service. Please return a time-stamped copy of the first page of the Motion, Praecipe and Certification in the enclosed self-addressed stamped envelope. Thank you for your cooperation, cc:' Vasihki Phillippy, Pro Se Robert Lieberman, Esquire Honorable George E. Hoffer, President Judge """ - .;L _ ~ " '.o.~"'- " FEDERMAN AND PHELAN, L.L.P. By: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center at Snburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (21 <;) <;63-7000 Attorney for Plaintiff Keystone Financial Bank, N.A., 81I1I Financial Trnst Company 2270 Erin Court Lancaster, P A 17604 Court of Common Pleas Plaintiff Civil Division Cumberland County vs. : No. 00-8675 Vasiliki T. Phillipy Or Occupants 21 Chestnut Street Mount Holly Springs, P A 17065 Defendants CFRTTFTCATTON OF SF,RVTCF, I hereby certity a true and correct copy of the foregoing Plaintiffs Affidavit in Support of its Motion for Summary Judgment and Certification of Service was served by regular mail on Defendant on the date listed below: Vasiliki T, Phillipy 21 Chestnut Street Mount Holly Springs, P A 17065 L DA TE:------iliLtl iche M. Bradfora, Esquire Attorney for Plaintiff - ~ " J, -,' ,~ . '0; < ~,<- r FEDERMAN AND PHELAN, L.L.P. By: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center at Suburban Statiou 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 : Attorney for Plaintiff Keystone Financial Bank, N.A., SII/I Financial Trust Company 2270 Erin Court Lancaster, PA 17604 : Court of Common Pleas Plaintiff : Civil Division : Cumberland County vs. : No. 00-8675 VasiIiki T. PhilIipy Or Occupants 21 Chestnut Street Mount HoUy Springs, P A 17065 Defendants PLAINTIFF'S AFFIDAVIT IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT Michele M. Bradford, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of Partner at the law firm of Federman and Phelan, LLP. 2. In said capacity, I am familiar with the Motion for Summary Judgment filed in the above captioned case, 3, This affidavit is given at the request of the panel of judges at the March 28, 2001 oral argument on Plaintiff s Motion for Summary Judgment. 4. By letter dated February 12, 2001, Plaintiff filed its Motion for Summary Judgment, Brief in Support thereof, exhibits, proposed order, and Praecipe for listing case for argument. 5. Plaintiff sent a copy of this package to the Defendant, Vasiliki T. Phillippy by regular mail on that date and filed a Certification of Service to that ~"" .L f' OL~ , effect with the Court. This certification of Service was also part of Plaintiff's Motion for Summary Judgment package. 6. Subsequently Plaintiff received a post card from the Office of the Prothonotary of Cumberland County dated March 8, 2001 informing the Plaintiff that the case had been scheduled for argument on March 28, 2001, The post card states, "Cumberland County Argument Court Rules 210-1 through 210-14 shall be strictly enforced." 7, Cumberland County Rule 210-4 states that it is the responsibility of the Prothonotary to notify all attorneys and unrepresented parties of the Argument Court listing by regular mail. Plaintiff did not contact Defendant in any manner with respect to notifying him of the March 28,2001 argument date, as it was not Plaintiff's responsibility to do so. 8, Plaintiff's counsel relied upon the Cumberland County rules to the effect that the Court would notify the opposition of the argument date, as is the practice in all counties in the state of Pennsylvania except Westm SWORN TO AND SUB~IBED BEFORE ME THIS DAY! OF il,2001. NOTARY PUBLIC NOTARIAl 0'0', E~NA L. HOUS""O:-! ",:,'_,1 '- City of Phil~'dG!"'J '':'ublic -M.Y..QQm[n;:;s:~(',") .~ "nly ----, , __,,_., 2001 ,\~~~~ij~g~~~~~J;~;~~l I ~~ ~I, - ." ,~ ilMIIl~ , I.,: " 1'1 ji I'l ! !.i 1;-1 FEDERMAN AND PHELAN L.L.P. By: Frank Federman, Esquire Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, 1400 Philadelphia, PA 19103-1814 (215) 563-7000 , i:i ,-! Attorney for Plaintiff KEYSTONE FlNANCIAL BANK, N.A., S/I/I FlNANCIAL TRUST COMPANY 2270 ERIN COURT LANCASTER,PA 17604 Court of Common Pleas Civil Division I.,; I" !;~ i: 'J v. CUMBERLAND County Term V ASILIKl T. PHILLTI>Y OR OCCUPANTS 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 No. 00- Pt.7S Qu~l 't~ CTVTT, ACTION - lUF.CTMFNT - l020 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for and other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ~. ~~.~ ,1'_ ) , , 1. Plaintiff is KEYSTONE FINANCIAL BANK, N.A., SIIIII FINANCIAL TRUST COMPANY. 2. Defendant is V ASILIKI T. PHILLIPY OR OCCUPANTS, 3, Plaintiff is the owner of premises located at 21 CHESTNUT STREET, MOUNT HOLLY SPlUNGS, P A 17065, a legal description of which is attached. (i 4, Plaintiff became owner of said premises by a Deed from the Sheriff of CUMBERLAND County, which Deed was lodged and settlement made with the Sheriff (Abstract of Title). 5, Plaintiff, by virtue of the above, is the owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim of title, I,:'! ,c.; 6, Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. i;J , ;I Ii I:-i I WHEREFORE, plaintiff seeks to recover possession of said premises, ': ;, "j ;~ F PEDE ttomey for Plain 'ff ~~~ ~ - 1 '... .. ,I -w . 4 ~ ARACOR Search and Abstract Services, Inc. One Penn Center, 1617 J.F.K. Boulevard, Suite 305 Philadelphia, Pennsylvania 19103 (215) 496-0900 FAX (215) 496-0904 RECORD OWNER AND LIEN CERTIFICATE Effective Date: 6/23/2000 Order Number: Client Number: A42440 Premises: 21 CHESTNUT STREET, BOROUGH OF MOUNT HOLLY SPRINGS CUMBERLAND COUNTY PENNSYLVANIA Based upon the examination of evidence in the appropriate public records, Company certifies that the premises endorsed hereon are subject to the liens, encumbrances and exceptions to title hereinafter set forth, This Certificate does not constitute title insurance; liability hereunder is assumed by the Company solely in its capacity as an abstractor for its negligence, mistakes or omissions in a sum not to exceed Two Thousand Dollars. DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the Northeastern corner of Chestnut Street at a limestone adjoining Lot No.3; thence South along Chestnut Street, Eighty (80) feet to a limestone; thence West along land formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), now or formerly of Rose C. Wolf, One Hundred Eighty-five (185) feet to a limestone; thence North along said land now or formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), Eighty (80) feet to a limestone; thence along Lot No.3, on the Plan mentioned below (185) feet to a limestone, the place of beginning, BEING Lots Nos. 4 and 5 of the Mathew Moore Plot of the Town Lots having a width on Chestnut Street of Eighty (80) feet and a depth along Lot No.3 of One Hundred Eighty-five (185) feet, and being improved with a two and one-half story frame dwelling house known as a numbered 21 Chestnut Street. TAX PARCEL NUMBER: 23-32-2336-202 ~~~ ~" . ) " h., I'J""" "M'. . VERIFICA nON Frank Federman, Esquire hereby states that he is the Attorney for the Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Ejectment are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~ Fr Federman, Es ire ttorney for PlamtI f Date: J~/11 / tlJ 1!iilliildm~m.'WJ""',"",~:,-;:y~:,,,,,,.,:~""i'ii\ili1~~~Yfi,;~,""~',"li1R'-';~',j,"~;,;;",S";;;;;i;,"M'I!hb,j,:i:r<iG:blB-~'1;,"'~~I1If~m.~~~~~ .~ " r"""'" . "N ~ ~ ~ (") 0 r:< jt ~ C C> '1 '& s: c::> ,!i h ""UaJ p1 ..---;; nip.... CJ ...:~;~ B f9 . 2::0 "- ~ ~ Zf--. i t:"~J (n~":'~ ill ---.. j "'- '-<,,~ :..J').,.J. 1-J e:;Ci .:)~j f "'0 ~~ . ~c> ~ ~J -,'- L--~ ~ j7(d t,,) L, --I Z 'J'l '> :;! .,...j ~ -'..' - ~.i.,: .." '" ... FEDERMAN AND PHELAN, L.L.P. By: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center at Snburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 56J.7000 Attorney for Plaintiff Keystone Financial Bank, N.A., S/I/I Financial Trust Company 2270 Erin Court Lancaster, PA 17604 Court of Common Pleas Plaintiff Civil Division : Cumberland County vs. : No. 00-8675 VasiIiki T. PhiIIipy Or Occupants 21 Chestnnt Street Mount Holly Springs, P A 17065 Defendants C.FRTIFTC A nON OF SFRVTCF, I hereby certify a true and correct copy of the foregoing Plaintiffs Affidavit in Support of its Motion for Summary Judgment and Certification of Service was served by regular mail on Defendant on the date listed below: VasiIiki T. Phillipy 2 I Chestnut Street Mount Holly Springs, PA 17065 L. DATE:~ iche M. Bradforo, Esquire Attomey for Plaintiff 0' I ,~ - ", J FEDERMAN AND PHELAN, L.L.P. By: MICHELE M. BRADFORD, ESQUIRE Identification No. 69849 One Penn Center at Snburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 : Attorney for Plaintiff Keystone Financial Bank, N.A., S/I/I Financial Trust Company 2270 Erin Court Lancaster, PA 17604 : Court of Common Pleas Plaintiff : Civil Division : Cumberland County vs. : No. 00-8675 Vasiliki T. PhiUipy Or Occupants 21 Chestnut Street Mount HoUy Springs, P A 17065 Defendants PLAINTIFF'S AFFIDAVIT IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT 'I I ,I :1 :i , !,i II I , I I :1 , I I I II ,I ~ II " I 'I i I Michele M. Bradford, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of Partner at the law firm of Federman and Phelan, LLP. 2. In said capacity, I am familiar with the Motion for Summary Judgment filed in the above captioned case. 3. This affidavit is given at the request of the panel of judges at the March 28, 2001 oral argument on Plaintiff's Motion for Summary Judgment. 4. By letter dated February 12, 2001, Plaintiff filed its Motion for Summary Judgment, Brief in Support thereof, exhibits, proposed order, and Praecipe for listing case for argument. 5. Plaintiff sent a copy of this package to the Defendant, Vasiliki T. Phillippy by regular mail on that date and filed a Certification of Service to that ,'I' ,I:' _ ~, " ."'~ ~-~ > ., ~ effect with the Court. This certification of Service was also part of Plaintiff's Motion for Summary Judgment package. 6. Subsequently Plaintiff received a post card from the Office of the Prothonotary of Cumberland County dated March 8, 2001 informing the Plaintiff that the case had been scheduled for argument on March 28,2001. The post card states, "Cumberland County Argument Court Rules 210-1 through 210-14 shall be strictly enforced." 7. Cumberland County Rule 210-4 states that it is the responsibility of the Prothonotary to notify all attorneys and umepresented parties of the Argument Court listing by regular mail. Plaintiff did not contact Defendant in any manner with respect to notifying him of the March 28, 2001 argument date, as it was not Plaintiff's responsibility to do so. 8. Plaintiff's counsel relied upon the Cumberland County rules to the effect that the Court would notify the opposition of the argument date, as is the practice in all counties in the state of Pennsylvania except WestIn eland County. ... SWORN TO AND SUBS<;:RIBED BEFORE ME THIS i:t-- D OF iI, 2001. NOTARIAL SEAl EDNA L HOUSTON-- City of Phi1adeJDhi;.' ,;.~j,; -';\,' Public )i..ssion ,~": <' ", ' iunty '--' "':;:--'-_.. __ -- :,2001 NOTARIAL SEAL EDNA L, HOUSTON, Notary Publie -M City e/ Phl~~delphia, Phila, County --,-,l(.,~,~~&OB"es Dee, 4, 2001 """~"~:l"liMl~!!!~!~.:iWiil.~--"""~~'wkt'~~'~!~,",I.h..;j~~*";W;;;;,l\,,t<l:~~l1;;tIitilt;l;-I"ii1Jil;ta1f~ .~,tWlJ~ ~1i~rlti ~"-~-" -,'- N_,"~, ~ ~- ""'--",,~,,-, ,",. ""'~"""~"-="'~'" ,~_ ~.J .' j ....,! ;. C) c, c: :;:2'" T~ V [~; -::> rn - " Z z L [j~ ~.-.; ~~ ,- '- :~~ , , . 5, ~,' 1',' '. .- :~) -< \ 0 "