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HomeMy WebLinkAbout01-111 FX : SHERIFF'S RETURN - OUT OF COUNTY " i.i. -'t..: ~ C~S~ NO: 2001-00111 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PAYNE SUSAN L ET AL VS UGI UTILITIES INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: AMERI GAS INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of MONTGOMERY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 5th, 2001 , this office was in receipt of the attached return from MONTGOMERY Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 02/05/2001 COZEN & O'CONNER S - - :;o/~~ R. Thomas Kline .- Sheriff of Cumberland County Sworn and subscribed to before me this '7~ day of ::t_jLu~) :Mro I A.D. C) 'I' . Cot'?:6:tt7:rv 4jn~ In The Court of Common Pleas ofCumberlallld County, Pennsylvania ,1;:..... .' P t 1 . ...Susan L.. ayne, e .. a. .. VS. -_". ;':1 UGI. .Ut.ilitie..s,. I.n.c. ..~.'. et. al. L_---.J. .. -::'\_~__~_.. Serve:- Ameri Gal>, Inc. No. 2001-111 Civi4A8TDAYFOR S~RTTi0;iP:.':/7'OT,~'"; LjIoO'1\~1\ --= tSL/o0 cKn-&01~~ pw Now, 1117/01 , 200~, I, SHERIFF OF CUMBERLA.ND COUNTY, PA, do - . hereby deputize the Sheriff or Montaomerv ,,,'" ,,,,~ County to execute this Writ,_this deputation being made at the request and risk of the Plaintiff. " ' ~~-~~~~ Sheriff ofCumberl",d County, PA Affidavit o>f Service Now, ddAJ7)c::0,';1 A r1J'1v"vAIH // within /18<;'-1-"----,- , 20~_L_, at /u y") o'dack ;.4- ~ o 0 ;z: (...... ~-i :::::=- -"""r") M= c::,a~ . . ~I1l~~~L~ ::: =r. 0i::?; ~ 4'"1;;C:":": (.nA-C -0 CJ-:~ -.:: r '6' N.. --0 - ~z U1 --< "" -< at 4eu 0-C , f1r[J CJV-'- upon by handing to /f/lC//. {. &- 6 au /-1,,"'--<::-1)1 copy of the original a and made lmown to t'?QJ--- the contents "G. So answers, '7--Pf &. ~~~r~~-- Il NOladai S':)CiJ . j , Helene FrJ6dfIl2l.n.. Notar'.! PubHc ! Norr~tovm, 8~"'r0- klo~igomi;y COfJrH-:/ ,j 'I My I...OlTI(c'SSlur\ 2.X(1IF~:3 Aor ~ )(;hl t . , ' . -~-,-l 7A-1o-.1~ County, PA Sworn and subscr:i me thi~ day 0 COSTS SERv1CE Ml"LEAGE A:FFIDA'vlT $ Xo~l& $ SHERIFF'S RETUffi" - OUT OF COUNTY ",,,,- .,""- ~SE NO: 2001-00111 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PAYNE SUSAN L ET AL VS UGI UTILITIES INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT I to wit: UGI CORPORATION but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of MONTGOMERY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 5th, 2001 , this office was in receipt of the attached return from MONTGOMERY Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 02/05/2001 COZEN & O'CONNER S~~/ ~~.~ R. Thomas Kline : Sheriff of Cumberland County Sworn and subscribed to before me this '7 e- day of :J..t.L"~"7 J..i,-o i A . D . ~A'-> G. fu -ii,,,, ~t:ti' Prothonotc(r In The Court of Common Pleas 0 ~.., ...-....... -~Sus~n L. Payne, .et. a1. UGI Utilities, V:~c., et.,~l. :..jJ:.,TD;r'lli'ORSERv7c2.'....,.-:'ll:~ serve:-~tb ~~rp~'f::~A)1.::> No. \ Civi] . ~~c1~).&-' ,~a; li\~Oh , Now, 1/17/0.1 ,20 () iP, I, SHERIFF &R, CUiv.lBERLAND COUN1Y, PA, do \ \ \_ County to execute this Writ, this berland County, Pennsylvania " , deputation being made at the request and risk of the Plaintiff. \ . ~~~~# Sheriff,ofCumberland Coumy, PA Montgomerv '" ,'" " J hereby deputize the Sheriff of Now, ,%7"') '8':))' -r;.lIh'r{>-( flf3ol./~ ')0 . I ,_ ~,at /0' S o':lock , \ 4 "7 sa <- {f)""'" ~ :::::: ~:e ';j ~~ ~ ~t;::;:C-) \"C.) .-'lSJ:J f.,."1-<.:""''::: M..., ""ct~ .1 .... ~rv~6...e , N' v-c: '" ... --Iz -.,\ "', - -l ';,[I, .-< o Affidavit of Sei'V:ice within upon (f v '"'-- / , " \. at '" -,J-'<.- , \.. by handing to ..1/1(' /1, te..- -- COD" of the original - . - a and made Imown to #iSvv-"--- the contents t..~ereof. so'~~~e:~ Get:? 0~/c,(L ~~.~_ Sherin of Coulli'Y, P A <7 I ;"..~(~.~~i 1 I ,l-i;;-;;;;"1r1 rrjeG1!iar;, l\iCtz-rJ Public '. I ~~;'..;-?~[".vn. 801':1, IVlontomn{,;'i ClJunr! .1 j ,,{.~ GCilTlin,bslorr Exoir53 Ai-.,-'1 --:.,"0" I l.....-.: -',~ . ., c.. ..,. 'I COSTS SERVICE MILEAGE }\FFIDA VIT $ Swam and subscri' me MD day $ X O~1 r . SHERIFF'S RETURN - OUT OF COUNTY - ' CASE NO: 2001-00111 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PAYNE SUSAN L ET AL VS UGI UTILITIES INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within'named DEFENDANT , to wit: UGI UTILITIES INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of MONTGOMERY serve the within COMPLAINT & NOTICE County, Pennsylvania, to On February 5th, 2001 , this office was in receipt of the attached return from MONTGOMERY Sheriff's Costs: Docketing Out of County Surcharge DEP. MONTGOMERY 18.00 9.00 10.00 65.00 .00 102.00 02/05/2001 COZEN & O'CONNER CO So an~s~?': ~~ :::-- R! Thomas Kline ~ Sheriff of Cumberland County Sworn and subscribed to before me day of :/4"''''7 this 1 '=:: d.o-o( A.D. g'fh go~~t~ta;1A~ UGI Utilities, Inc~., et. a Serve: UGT Uti~.'ieslJ'.~d. '-IuD' / f. 'flp '?V-' 'KvrMfof ~, q<lo6 1/17 101 . , 20 () t) , I, SHERIFF-OF COMBERLAND COlJNTY, P A, do ..... of Cumbedal11ld County, Penusylvania . In The Court of Common -;Susa.n L.Payne" et. al. vs. . . . BE /?-7~Cl'/ . . LASTDllYFOR SERVI(Zf.:;'c<- - Cl VJ] ---- ~ - _ _ ____ Now, hereby deputize the Sheriff of Mon taomerv County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . . ",,' ~/,.,/ .,.,. ~,f . ~~ 1': ...~-r~ , Sherin of Cumberland County, PA Affidavit of Service upon NoviI, d3#Q~"6 :;I J/;1V<.wrt-( within 4e<i~ -"- ptfS .." --'--- ; r1.0 hl-'L . , 20-EL., at /G'C/,\ o'clock ,4- M. served the by handulg to IJu:J/o {e- , . Otic I;-/./o~<:"// - / / at a -- copy of me original ------ o No1arlal Seal Helene Friedman, Notary PubliC i .~9rrjstown ~ B~fO, ~o~tgomery ~ C~~nty , , -.'IY ComlTllSSlon :::xplres ApI', '. .::v04 : SO~~d EJr _.--h . :;f!~ Sheriff of ' ~ ~ <- (,.t?....... :J;::;;a ..."...--i .,:;e: ~€?=o the contents ~reoJ!."";;'" \.0 5Ar~ ....... -, [...!''):::(.< o rq rr"OO -dO c: -' 0"\ -< --u-r~''''''4 coun.ty ~ P A and made Imown to ~ . v-<- COSTS SERVICE MILEAGE ~AFFIDA VIT $ Swom and subscri ed before me thi.6~ day? . 2rf$1 $ Xo~r , COZEN AND O'CONNOR BY: KEVIN J. HUGHES Attorney ill # 50238 The Atrium- 3m Floor 1900 Market Street Philadelphia, PA 19103 (215) 665-2739 SUSAN L. PAYNE 2204 Menimac Lane Mechanicsburg, Pennsylvania, 17055 and ENCOMPASS INSURANCE COMPANY a/s/o Susan L. Payne P.O. Box 908 Monmouth Junction, NJ 08852 Plaintiffs, v. UGI UTILITIES, INC. 460 North Gulph Road, King of Prussia, PA 19406, Al\1ERI GAS, INe. 460 North Gulph Road, King of Prussia, PA 19406, UGI CORPORATION 460 North Gulph Road, King of Prussia, PA 19406 Defendants. Counsel for Plaintiff COURT OF COM:M:ON PLEAS OF CUMBERLAND COUNTY CNIL ACTION - LAW NO. t) J- II} {tu JURY TRIAL DEMANDED - /v.-- '. 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 any 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 ONECE. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 A VISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientas, usted tiene veinte (20) dias de plazo al partir de la fecha de 1a demanda y la notificaci6n. Hace falta asentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones a 1as demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificaci6n. A demas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO lNMEDIATAi\1ENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TALSERVICIO. VAYAENPERSONA o LLA\\1E POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRlT A ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. c. COMPLAINT COMES NOW Plaintiffs, Susan L. Payne and Encompass Insurance Company, as subrogee of Susan L. Payne, by and through its counsel, Kevin J. Hughes, and complaining of the Defendants, UGI Utilities, Inc., Ameri Gas, Inc. and UGI Corporation, alleges and says: PARTIES 1. Plaintiff Susan L. Payne is an adult individual and citizen of the State of Pennsylvania, (hereinafter "Payne") who, at all times material hereto, owned a residential dwelling located at 2204 Merrimac Lane, in Mechanicsburg, Pennsylvania, 17055. (Hereinafter "Payne Home"). 2. Plaintiff Encompass Insurance Company, ("Encompass") formerly known as CNA Personal Insurance Company, is foreign corporation duly authorized by the Commonwealth of Pennsylvania to engage in the business of, inter alia, issuing and providing insurance policies in this Commonwealth. 3. Defendant, UGI Utilities, Inc. is, upon information and belief, a Pennsylvania corporation having a principal place of business located at 460 North Gu1ph Road, King of Prussia, Pennsylvania 19406 and a business address at 2121 City Line Road, Lehigh Valley, Pennsylvania, 18002-5148 (Hereinafter "UGI"). At all times material hereto, UGI was engaged in the business of, inter alia, selling and distributing propane gas to the general public. 4. Defendant, Ameri Gas, Inc. is, upon information and belief, a Pennsylvania corporation having a principal place of business located at 460 North Gu1ph Road, King of Prussia, Pennsylvania 19406 and a business address located at 5400 Paxton Street, Harrisburg, Pennsylvania, 17105. (Hereinafter "AmeriGas"). At all times material hereto, AmeriGas was engaged in the business of selling and distributing propane gas to the general public. 5. Upon information and belief, UGr Corporation is a Pennsylvania corporation having a principal place of business located at 460 North Gulph Road, King of Prussia, Pennsylvania 19406. At all times material hereto, UGr Corporation was engaged in the business of. inter alia, selling and distributing propane gas to the general public. 6. Upon information and belief, UGI and AmeriGas are sister companies and/or subsidiaries ofUGI Corporation. JURISDICTION AND VENUE 7. Jurisdiction and Venue properly lie with this Court as the events leading up to and causing the complained of damages occurred in Cumberland County and the defendants, by contract and/or by their respective actions, have placed themselves under the jurisdiction of this Court. FACTS SURROUNDING CAUSE OF ACTION 8. Prior to January 9,1999, Encompass, by and through its former subsidiary, Continental Insurance Company, issued to Payne an insurance policy affording certain protections for the Payne Home (hereinafter "Insurance Policy"). 9. The Payne Home is located in a residential neighborhood/development known as Creek Stone Manor. 10. Upon information and belief, prior to January 9, 1999, UGI and/or UGr Corporation (hereinafter collectively referred to as "UGr Defendants") entered into a contractual relationship with Payne whereby, in return for certain consideration, UGr Defendants agreed to monitor, service, fill, and maintain the propane tank for the Payne Home (hereinafter "Payne Contract"). The Payne Contract is, upon information and belief, in the custody and control ofUGr Defendants. 11. Upon information and belief, prior to January 9, 1999, UGr Defendants entered into contracts similar to that of the Payne Contract with other residents in Creek Stone Manor. 12. Upon information and belief, UGr Defendants entered into a written contract and/or oral agreement with AmeriGas whereby, in return for certain consideration, AmeriGas agreed to monitor and fill propane tanks of houses located in Creek Stone Manor, including that propane tank that supplied fuel to the Payne Home. (Hereinafter UGLlAmeriGas Contract"). 13. Upon information and belief, on or about January 3, 1999, propane tanks providing fuel to homes in Creek Stone Manor began to and/or did run out of propane gas. 14. The pilot light of a home furnace fueled by propane gas will go out, i.e., be extinguished, once its fuel tank runs out of propane gas. As a result, in order to render a furnace operable once it is deprived of propane fuel, it becomes necessary to not only refill the fuel tank with propane gas, but to relight the furnace's pilot light. 15. On or about January 3, 1999, residents of houses that neighbored the Payne Home advised UGr Defendants employees responding to their complaints of fuel outages of the fact the Payne Home was unoccupied and was, like their homes, most probably out of propane fuel. 16. In response to the concerns expressed by the Payne Home neighbors, UGr Defendants emp10yee(s) assured them that UGI Defendants would refill the Payne Home propane tank and relight the dwelling's furnace pilot light. 17. Upon information and belief, UGr Defendants had in their possession Payne's work and home telephone numbers as well as that ofthe Payne's real estate agent. 18. On January 9, 1999, Payne discovered that a water pipe in the Payne Home had frozen, thawed, and subsequently ruptured, causing severe damage to the dwelling (hereinafter "Water Damage"). 19. The subject water pipe froze due to the fact the fuel tank that provided gas to the Payne Home furnace had run out of propane, the tank had not been refueled, and the Payne Home furnace pilot light had not been relit, thereby depriving the Payne Home of heat. 20. Pursuant to the Insurance Policy, Payne subsequently submitted a claim to Encompass or its predecessor company for, inter alia, the Water Damage. 21. Encompass and/or its predecessor company paid to Payne monies in excess of $10,000.00 nnder the Insurance Policy for the Water Damage. Encompass is now legally and equitably subrogated to the rights of its insured to the extent of those payments. COUNT I PLAINTIFFS V. UGI DEFENDANTS 22. Plaintiffs incorporate by reference paragraphs 1-21 as fully as if set forth at length herein. 23. By agreeing to monitor, maintain, supply, and refill the Payne Home propane tank and by subsequently nndertaking to perform those services, UGr Defendants became legally obligated to perform their services in a prudent, proper, and workmanlike manner. 24. UOI Defendants negligently and carelessly breached its duties owed Payne in that they: a. failed to properly monitor the propane tank providing fuel to the Payne Home (Hereinafter "Payne Propane Tank") to ensure that it contained appropriate levels of propane gas; b. failed to properly supply the Payne Propane Tank with propane gas on a timely basis; c. failed to refill the Payne Propane Tank with propane gas on a timely basis; d. failed to relight the pilot light to Payne Home furnace; e. failed to promptly notify Payne and/or her real estate agent that the Payne Propane Tank had run out of propane gas; f. failed to promptly notify Payne and/or her real estate agent that the Payne Home furnace pilot light had been extinguished, depriving the Payne Home of heat; and g. failed to ensure that Defendant AmeriOas had properly monitored the Payne Propane Tank and had supplied and/or refilled said tank with propane gas in a timely and appropriate manner. 25. In failing to properly discharge its duties in a good, prudent, and non- negligent manner, UOI Defendants proximately caused and/or permitted the Payne Home to be deprived of heat during a period of ambient freezing temperatures. 26. UOI Defendants knew or should have known that, if left without heat, the water pipes in the Payne Home would be subjected to freezing temperatures and thus could freeze and subsequently rupture, causing severe water damage to the dwelling. 27. The negligent acts and omissions by UOI Defendants, as hereinbefore averred, was the direct and proximate cause of the Water Damage. WHEREFORE, Plaintiffs request that judgment be entered in their favor and against Defendants UOI Utilities, Inc. and UOI Corporation, and that they be awarded their compensatory damages for the Water Damage and related losses in an amount in excess of$10,000.00, together with prejudgment interest and the costs associated with this action. COUNT II PLAINTIFFS V. AMERIGAS 28. Plaintiffs incorporate by reference paragraphs 1-21 as fully as if set forth at length herein. 29. Upon information and belief, by agreeing to monitor, maintain, supply, and refill the Payne Home propane tank, and by undertaking to perform those services, AmeriGas became legally obligated to perform its services in a prudent, proper, and workmanlike marmer. 30. Upon information and belief, AmeriGas negligently breached its duties owed Payne in that they: a. failed to properly monitor the propane tank providing fuel to the Payne Home (Hereinafter "Payne Propane Tank") to ensure that it contained appropriate levels of propane gas; b. failed to properly supply the Payne Propane Tank with propane gas on a timely basis; c. failed to refill the Payne Propane Tank with propane gas on a timely basis; d. failed to relight the pilot light to Payne Home furnace; e. failed to promptly notify Payne and/or her real estate agent that the Payne Propane Tank had run out of propane gas; and f. failed to promptly notif'y Payne and/or her real estate agent that the Payne Home furnace pilot light had been extinguished, depriving the Payne Home of heat. 31. In failing to properly discharge its duties owed Payne in a good, prudent, and non-negligent marmer, AmeriGas proximately caused and/or permitted the Payne Home to be deprived of heat during a period of ambient freezing temperatures. 32. AmeriGas knew or should have known that, ifIeft without heat, the water pipes in the Payne Home would be subjected to freezing temperatures and thus could freeze and subsequently rupture, causing severe water damage to the dwelling. 33. The negligent acts and omissions by AmeriGas, as hereinbefore averred, was the direct and proximate cause of the Water Damage. WHEREFORE, Plaintiffs request that judgment be entered in their favor and against Defendant AmeriGas and that they be awarded their compensatory damages for the Water Damage and related losses in an amount in excess of $10,000.00, together with prejudgment interest and the costs associated with this action. COUNT III BREACH OF CONTRACT PLAINTIFFS V. UGI DEFENDANTS 34. Plaintiffs incorporate by reference paragraphs 1-21 as fully as if set forth at length herein. 35. UGr Defendants breached their contractual duties and obligations owed to Payne under the Payne Contract in that they: a. failed to properly supply the Payne Propane Tank with propane gas on a timely basis; b. failed to properly monitor Payne Propane Tank to ensure that it contained appropriate levels of propane gas; c. failed to refiJ1 the Payne Propane Tank with propane gas on a timely basis; and d. failed to relight the pilot light to Payne Home furnace. 36. The breach by UGr Defendants of the Payne Contract caused the Water Damage. 37. The Water Damage is the type of damage that would necessarily be expected to flow from a breach of the Payne Contract during periods of freezing temperatures. 38. Upon discovery of the breach of the Payne Contract, UGr Defendants were given prompt and reasonable notice ofthe Water Damage. WHEREFORE, Plaintiffs request that judgment be entered in their favor and against Defendants UGr Utilities, Inc. and UGr Corporation, and that they be awarded their compensatory damages for the Water Damage and related losses in an amount in excess of $10,000.00, together with prejudgment interest and the costs associated with this action. COUNT IV BREACH OF CONTRt\.CT PLAINTIFFS V. AMERIGAS 39. Plaintiffs incorporate by reference paragraphs 1-21 as fully as if set forth at length herein. 40. Payne was and would have been a third party beneficiary of the UGIIAmeriGas Contract. 41. Defendant AmeriGas breached its contractual duties and/or obligations owed to Payne under the UGII AmeriGas Contract in that they: a. failed to properly supply the Payne Propane Tank with propane gas on a timely basis; b. failed to properly monitor Payne Propane Tank to ensure that it contained appropriate levels of propane gas; c. failed to refill the Payne Propane Tank with propane gas on a timely basis; and d. failed to relight the pilot ligl1t to Payne Home furnace. 42. The breach by AmeriGas of the UGIIAmeriGas Contract directly and proximately caused the Water Damage. 43. The Water Damage is the type of dan1age that would flow from a breach of the UGIIAmeriGas Contract during periods of freezing temperatures. 44. Upon discovery ofthe breach of the UGI/AmeriGas Contract, AmeriGas was given prompt and reasonable notice ofthe Water Damage. WHEREFORE, Plaintiffs request that judgment be entered in their favor and against Defendant AmeriGas and that they be awarded their compensatory damages for the Water Damage and related losses in an amount in excess of $10,000.00, together with prejudgment interest and the costs associated with this action. COZEN AND O'CONNOR BY ~ KEV J. HUGHES, ESQUIRE ~ OF COUNSEL: T. DAVID HIGGINS, JR., ESQ. HIGGINS MINSKER, P.L.L.C. 1208 South Tryon Street Charlotte, NC 28203 (704) 370-7700 JAN. 5.2001' 12:47PM CNA INSURANCE CO NO. 393 P.2 " . ,~ VERIFICATION Susan Taibbi, of Encompass Insurance Company, averS that the allegations contained in the foregoing Complaint are true and correct to the best of her knowledge, information and belief; and that the statements in the said Complaint are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsifications to authorities. ~~~. SUSAN TAlBBI Verified this sCfL day ofJanuary, 2001. 215 665 2013 JAN,05'2001 12:47 RECEIVED FROM: #6340-002 J Cj e, 3 o \ii ::r .. g c:t . ., f> J) ~\.1 17- !e >- ~ ~;' y~< (-. 'i~C-'J .-..,,"- 17 i:.._ __. !=--: u, C ~~ ~ ~ :r- .... - sJ c5] @) '" (<,,=' 0' >- '- 7 ~:sr: ;_-~ -;7 ,-..:~ ! ;-.::1 ,.<0 Jj~ :::. u ..-.:.:;: co ...::;: ~ c::'