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THE PEOPLES STATE BANK,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
v.
RANDY L. LAWRENCE and
SHARON A. LAWRENCE,
Defendants
CIVIL ACTION - LAW
No. 01-3000
COMPLAINT IN CONFESSION OF JUDGMENT
1. Plaimtiff, The Peoples State Bank, is a Pennsylvania banking corporation
organized and existing under the laws of the Commonwealth of Pennsylvania, having an office
at 100 East King Street, East Berlin, Pennsylvania 17316.
2. Defendants, Randy L. Lawrence and Sharon A. Lawrence, are adult individuals
whose last known address is 234 Fox Drive, Mechanicsburg, Pennsylvania 17055.
3. Plaintiff made a term loan to Defendants in the original principal amount of
$245,000.00 as evidenced by a certain Promissory Note of Randy L. Lawrence and Sharon A.
Lawrence to The Peoples State Bank dated May 7, 1998. A true and correct copy of the
Promissory Note is attached hereto as Exhibit "A" and incorporated herein. On June 1, 1999,
Plaintiff and Defendants entered into a Note Modification Agreement whereby the repayment
terms were amended. A copy of the Note Modification Agreement is attached hereto as
Exhibit "B" and incorporated herein. On January 11, 2000, Plaintiff and Defendants entered
into a Second Note Modification Agreement whereby the repayment terms were amended. A
copy of the Second Note Modification Agreement is attached hereto as Exhibit "c" and
incorporated herein.
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4. Under the terms of the Promissory Note, Note Modification Agreement, and
Second Note Modification Agreement, Defendants were to make monthly payments of
principal and interest at a variable interest rate. Defendants have not made the monthly
payments of $2,617.62 each for February 7, March 7, April 7, and May 7,2001.
5. Exhibit "A" contains a Confession of Judgment clause in favor of the Plaintiff
and against the Defendants. Furthermore, said document contains the right of the Plaintiff to
collect reasonable attorney's fees in the amount of 15% of the principal balance together with
costs of suit. Said terms were reaffirmed in the Note Modification Agreement and Second
Note Modification Agreement.
6, There has been no assignment of Exhibit "A", "B", and "C".
7. No judgment has been entered on Exhibit "A", "B", and "C".
8. The terms of the Promissory Note, as reaffirmed in the Note Modification
Agreement and Second Note Modification Agreement, provide that upon the occurrence of a
default by the Defendants, the Plaintiff may accelerate and demand immediate payment of all
sums secured by the Promissory Note.
9. All conditions precedent to confession of judgment have been performed or have
occurred.
10. Judgment is not being entered by confession against a natural person in
connection with a consumer credit transaction.
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11. The sums presently due and payable to Plaintiff by Defendants and secured by
the Promissory Note are computed as follows:
A.
Unpaid Principal
$239,052.93
B.
Unpaid Interest through 5/15/01
$ 5,487.61
C.
Late Fees as of 5/15/01
$ 785.28
D.
Attorney's commission of 15%
of Principal
$ 35,857.94
TOTAL
$281,183,76
WHEREFORE, Plaintiff, The Peoples State Bank, by and through its attorneys, CGA
Law Firm (Countess Gilbert Andrews, P.C.), hereby confesses judgment in favor of the
Plaintiff, The Peoples State Bank and against the Defendants, Randy L. Lawrence and
Sharon A. Lawrence, and simultaneously herewith requests the Prothonotary to enter judgment
against Defendants in favor of the Plaintiff in the amount of $281,183.76, together with
interest from May 16, 2001 at the per diem rate of $52.40, and costs of suit.
CGA Law Firm
Countess Gilbert Andrews, P.C.
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VERIFICATION
I, the undersigned,
Georgia A.'Bear
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Vice President of Collections
for Plaintiff, The Peoples State Bank, hereby affirm that the facts contained in the foregoing
Complaint in Confession of Judgment are true and correct to the best of my knowledge,
information and belief. This statement is made subject to the penalties of 18 Pa.C.S. Section
4904 relating to unsworn falsification to authorities.
THE PEOPLES STATE BANK
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By: P
Georgia A. Bear
Vice President/Collections
Dated: May~, 2001
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PROMISSORY NOTE
, 5002896":8
$245,000.00
~7
, 1998
FOR VALUE RECEIVED, and intending to be legally bound hereby, RANDY L. LAWRENCE and
SHARON A. LAWRENCE, jointly and severally (hereinafter collectively referred to as "Maker"),
promises to pay to the order of THE PEOPLES STATE BANK, a Pennsylvania banking institution
("Bank"), or any subsequent holder hereof, Ihe principal amount of TWO HUNDRED FORTY-FIVE
11HOUSAND DOLLARS ($245,000.00), in lawful money ofIhe United States, togeIher wiIh interest
at Ihe rate as hereinafter provided and any additional charges or funds advanced hereunder, at Ihe offices
of Ihe Bank or such oIher address as the Bank may designate by written notice to Ihe Maker.
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INTEREST-The unpaid principal balance shall bear interest at Ihe following rate per annum:
(a) From Ihe date hereof until m~ 1 , 1999, fixed at 8.50% per annUm.
, (b) From m Co ij 1 , 1999 and continuously Ihereafter until all indebtedness
hereunder is paid in full, Ihe Adjustable Rate per annum. The "Adjustable Rate" shall be Ihe Index
on the Change Date plus 3.50%. rounded up to Ihe nearest 0.125%. The "Index" shall be the weekly
average yield on United States Treasury securities adjusted to a constant maturity of one (I) year, as
made available by the Federal Reserve Board. The Change Date shall be on m Cu , 7
I999 and on Ihe same date of each year thereafter. ~
Interest shall be calculated on an actual days basis. Accrued interest shall be payable as provided herein.
Accrued interest shall also be payable when the entire principal balance of Ihis Note becomes due and
payable (wheIher by stated maturity, demand or acceleration) or, if earlier, when such principal balance
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is actually paid to Bank. Interest shall accrue on each disbursement hereunder from Ihe date such
disbursement Is made by Bank. Interest shall accrue on Ihe unpaid balance hereof at Ihe rate provided
for in this Note until the entire unpaid balance has been paid in full, notwiIhstanding Ihe entry of any
judgment against Maker.
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REPAYMENT-The principal sum and interest shall be paid by Maker to Bank as follows:
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~a) Payment of interest only, computed on the unpaid principal balance outstanding, duy on
Ihe.1t:..- day of each month, beginning on ,"1.)". , 1998. through ~-\- "-*<I bQ.;r I,
1998; tllereafter, '
(b) Repayment to be made in 180 monthly installments of principal and interest in Ihe amount
of $2,412.61 each, the first such payment being due and payable on Ihe ~ day of 0 C) C \).v ,
1998 and on Ihe same day of each consecutive month thereafter, except that the finaI installment shall be
equal to the balance of principal and interest remaining unpaid hereunder. Changes in the rate of interest
will require corresponding changes in the amount, but not Ihe number, of monIhly installments.
PREPAYMENT-Maker may prepay all or any portion of the principal balance hereunder at any time
wiIhout premium or penalty. Partial prepayments shall be applied to monIhly installments in the inverse
order of Iheir maturity. Maker shall pay a prepayment penalty equal to 1 % of Ihe amount prepaid if
prepaid by a third party.
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COLLATERAL-As security for all indebtedness to Bank now or hereafter incurred by Maker, under this
Note or otherwise, Maker grants Bank a lien upon and security interest In any personal property of Maker
now or hereafter in Bank's possession and in any deposit balances now or hereafter held by Bank for
Maker's account. Such liens and security interests shall be Independent of Bank's right of setoff.
Additionally, to secure the performance of this and all other obligations to Bank of Maker or any other
parties to this Note, whether now existing or hereafter incurred, Maker grants to Bank a security interest
in the collateral described below, complete with all present and future attachments, accessories and
replacements of all or any parts thereof and all additions thereto or substitutions therefor, and in any
insurance policies thereon, and dividends, distributions and other rights on or with respect to, and the
proceeds thereof (all of which is referred as "Collateral") with authority to collect, sell, transfer and
rehypothecate. In case the market value of the Collateral or any part thereof shall suffer any decline,
Maker agrees upon demand of the Bank to deliver to and pledge with the Bank additional collateral as
the Bank shall in its discretion require. Description of Collateral: 1) First priority mortgage lien on real
estate and improvements located at 675 Williams Grove Road, Mechanicsburg, Pennsylvania; 2)
Assignment of leases; 3) Assignment of all agreements affecting real estate; 4) Assignment of
construction contract.
LATE CHARGE-If any payment hereunder is not paid when due, and continues unpaid for a period of
ten (10) days thereafter, Maker agrees to pay to Bank as a late charge an amount computed at a rate of
five percent (5 %) of such past due amount. The late charge shall be in addition to any interest due.
Notwithstanding the foregoing, in no event shall any late charge be less than ten dollars ($10).
REPRESENTATIONS BY MAKER-Maker warrants and represents that this Note has been validly
executed and is enforceahle in accordance with its terms, that the execution, delivery and performance
by Maker hereunder are not In contravention of law and do not conflict with any Indenture, agreement
or undertaking to which Maker is a party or is otherwise bound, and that no consent or approval of any
governmental authority or any third party is required in connection with the execution, delivery and
performance under this Note. Maker warrants that no advance hereunder or portion thereof shall be
used other than for business purposes.
SUBSEQUENT HOLDERS-In the event that any holder of this Note transfers this Note for value and
in good faith, the Maker agrees that no subsequent holder of this Note shall be subject to any claims or
defenses which the Maker may have against a prior holder, all of which are waived as to the subsequent
holder, and that all subsequent holders shall have all of the rights of a holder in due course with respect
to the Maker even though the subsequent holder may not qualify, under applicable law, absent this
paragraph, as a holder in due course.
DEFAULT-Each of the following shall be an Event of Default hereunder:
a. If any payment of principal or interest under this Note is not paid when due, or within
ten (10) days thereafter; or
b. If Maker or any endorser, surety or guarantor of this Note defaults in the payment or
performance of this Note or any other obligation to Bank or to any other holder hereof
or fails to perform or comply with any agreement with Bank or any other holder hereof;
or
c. If Maker or any endorser, guarantor or surety is unable to pay its debts as they mature;
becomes insolvent; voluntarily suspends transaction of its business or operations; makes
an assignment for the benefit of creditors; files a voluntary petition to reorganize or to
effect a plan or other arrangement with creditors; or has an involuntary petition filed
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against it pursuant to the Bankruptcy Code or any amendments thereto; or applies for
?r ~onsent.s t? th.e apP?intme.nt of a receiver or trustee of all or part of its property;
mstltutes liqUIdation, dIssolution, merger or consolidation proceedings; or
d. If there is entered against Maker a judgment, levy, or lien of a material nature or if a
writ or warrant of attachment, execution, garnishment, distraint, possession, or any
similar process of a material nature shall be issued by any court against all or a part of
the property of Maker; or
e. If Maker or any endorser, surety or guarantor dies or is judicially declared incompetent;
or
f. If there is a taking of possession of a substantial part of the property of Maker at the
instance of any governmental authority; or
g. If Maker fails to pay any income, excise, or other taxes of any nature whatsoever when
due and payable or fails to remit when due to the appropriate governmental agency or
authorized depository any amount collected or withheld from any employee of Maker
for payroll taxes, Social Security payments or similar payroll deductions; or
h. If the Maker or any endorser, surety or guarantor fails to provide the bank with required
financial information; or
i. If a material adverse chauge in the financial condition of the Maker, or any endorser,
surety or guarantor of this Note has occurred since the date of this Note.
REMEDIES UPON DEFAULT-Upon the occurrence of one or more Events of Default, at the Bank's
option, the entire unpaid balance of this Note and all accrued interest shall be immediately due and
payable without notice or demand, and Bank may, inunediately or any time thereafter, exercise any or
all of its rights under any agreement or otherwise under applicable law against Maker, against any person
liable, either absolutely or contingently, for payment of any indebtedness evidenced hereby, and In any
collateral without regard to any marshalling requirements, and such rights may be exercised in any order
and shall not be prejudiced by any delay in Bank's exercise thereof. The Bank may set off against all
other obligations of Maker to Bank all money owed by the Bank in any capacity to Maker. In addition
to the principal and interest and other sums payable hereunder, Maker agrees to pay Bank on demand,
all costs and expenses which are incurred by Bank in the collection of this Note or the enforcement of
Bank's rights and remedies hereunder, including attorneys' fees of fifteen percent (15%) of the unpaid
balance. Upon any default, Maker and any endorser hereby authorize and empower the Prothonotary or
any attorney of any court of record of Pennsylvania or within the United States to appear for the Bank
and confess judgment against such Maker or endorser for such unpaid balance and costs, with release of
all errors and without stay of execution. All rights and remedies of Bank are cumulative and concurrent
and no single or partial exercise of any power or privilege shall preclude any other or further exercise
of any right, power or privilege. This Note is the unconditional obligation of Maker and each additional
person, if any, obligated for repayment of the indebtedness evidenced hereby agrees that Bank shall not
be required to exercIse any of its rights or remedies against any collateral in which it holds a lien or
security interest, or against which it has right of setoff, or against any particular obligor.
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MISCELLANEOUS-Any demand for payment or any notice required to be given by Bank under the
provisions of this Note shall be effective as to each Maker when addressed to Maker and deposited in the
mail, postage prepaid, for delivery by first class mail at Maker's billing address as it appears on Bank's
records. Maker and any endorsers, sureties and guarantors waive presentment, dishonor, notice of
dishonor, protest, notice of protest, and notice of any renewal, extensions, modification or change of
time, manner, place or terms of payment. Maker, and any endorsers, sureties and guarantors hereby
waive any right to trial by jury of any issues of fact in any action relating to any rights or
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obligations under this promissory note or other documents relating to this transaction. Neither the
failure nor any delay on the parI of Bank to exercise any right, remedy, power or privilege hereunder
shall operate as a waiver or modification thereof. No consent, waiver or modification of the terms of
this Note shall be effective unless set forth in a writing signed by Bank. All payments due under this
Note are to be made in immediately available funds. If Bank accepts payment in any other form. such
payment shall not be deemed to have been made until the funds comprising such payment have actually
been received by or made available to Bank. All representations, warranties and agreements herein are
made jointly and severally by each Maker. If any provision of this Note shall be held invalid or
unenforceable, such invalidity or unenforceability shall not affect any other provision hereof. This Note
has been delivered in and shall be governed by and construed in accordance with the laws of the
Commonwealth of Pennsylvania without regard to the law of conflicts. This Note shall be binding upon
each Maker and each additional endorser, guarantor, or surety and upon thelt personal representatives,
heirs, successors and assigns, and shall benefit Bank and its successors and assigns.
IN WITNESS WHEREOF. Maker has executed and delivered this Note under seal as of the day and year
rlIst above written.
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(Type Name)
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(Type Name)
Sharon A. Lawrence
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EXIHIIT 81
NOTE MODIFICATION AGREEMENT
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TE MODIFICATION AGREEMENT ("Agreement") is made this 1st' day of
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-0 , 1999 by and between RANDY L. LAWRENCE and SHARON A.
LAWRENCE! r mafter collectively referred to as "Bbrrower") and THE PEOPLES ST ATE BANK,
a Pennsylvania bing institution, ("Bank").
THIS
WHEREAS, the Borrower is indebted to the Bank pursuant to a ce]tain promissory note (the
"Note") executed by Borrower on May 7, 1998 in the original principal amount of Two Hundred Forty-
Five Thousand Dollars ($245,000.00), and
WHEREAS, Borrower has requested the Bank-'fii make certain modifications to the terms of the
Note,
WHEREAS, the Bank has agreed to such modifications upon the terms and conditions herein
contained,
NOW THEREFORE, and in consideration of the mutual covenants herein, and for other good
and valuable consideration, the receipt and sufficiency of which is hereby aclmowledged, the parties agree
as follows:
1. From the date hereof the Repayment Section of the Note shall be amended to read as follows:
(a) Payment of interest only, computed on the unpaid principal balance outstanding,
due on the 7th day of each month, beginning on June 7, 1999, through September 7, 1999;
thereafter,
(b) Repayment to be made in 172 monthly installments of principal and interest in
the amount of $1,841.30 each, the first such payment being due and payable on the 7th day of
October, 1999 and on the same day of each consecutive month thereafter, except that the final
installment shall be equal to the balance of principal and interest remaining unpaid hereunder.
Changes in the rate of interest will require corresponding changes in the amount, but not the
number, of monthly installments.
2. Except as expressly provided herein, alllerms and conditions of the Note, and each additional
document securing payment thereof shall remain in full force and effect.
3. This Agreement shall be binding upon and inure to the benefit of the parties hereto, their
respective successors, heirs and assigns. '
IN WITNESS WHEREOF, the parties have set their hands and seals.
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SECOND NOTE MODIFICATION AGREEMENT
560-;J g'l(.,-l)
THIS SECOND NOTE MODIFICATION AGREEMENT ("Agreement") is made this 11 th
day of T:mll"ry , 2000 by and between RANDY L. LAWRENCE and
SHARON A. LAWRENCE (hereinafter callectively referred to. as "Barrower") and THE PEOPLES
STATE BANK, a Pennsylvania banking institutian, ("Bank").
WHEREAS, the Barrower is indebted to the Bank pursuant to a certain promissory note (the
"Nate") executed by Barrawer an May 7, 1998 in the ariginal principal amount of Two. Hundred Farty-
Five Thausand Dollars ($245,000.00), and
WHEREAS, Borrower has requested the Bank to make certain modifications to the terms of the
Note,
WHEREAS, the Bank has agreed to such madificatians upon the terms and conditians herein
cantained,
NOW THEREFORE, and in cansideratian af the mutual cavenants herein, and far ather good
and valuable consideratian, the receipt and sufficiency af which is hereby acknaw1edged, the parties agree
as fallaws:
1. From the date hereof the Repayment Sectian afthe Nate shall be amended to. read as follows:
(a) Payment of interest anly, computed an the unpaid principal balance outstanding,
due an the 7th day af each month,' beginning on January 7, 1999 through February 7, 2000;
thereafter,
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(b) Repayment to. be made in 163 monthly installments af principal and interest in
the amount af $2,503.90 each, the first such payment being due and payable an the 7th day af
March, 2000 and an the saine day af each cansecutive manth thereafter, except that the final
installment shall be equal to:the balance af principal and interest remaining unpaid hereunder.
Changes in the rate of interest will require carresponding changes in the amaunt, but not the
number, af monthly installments.
2. Except as expressly pravided herein, all terms and canditians of the Note, and each additional
dacument securing payment thereof shall remain in full force and effect.
3. This Agreement shall be binding upan and inure to. the benefit af the parties hereto., their
respective successars, ,heirs and assigns.
IN WITNESS WHEREOF, the parties have set their hands and seals.
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THE PEOPLES STATE BANK,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
RANDY L. LAWRENCE and
SHARON A. LAWRENCE,
Defendants
CIVIL ACTION - LAW '--r-
No. 01 - ~(..C) CU'I..( I~
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the Warrant of Attorney, the original or a copy of
which is attached to the Complaint filed in this action, I appear for the Defendants and confess
judgment in favor of the Plaintiff and against Defendants as follows:
A.
Unpaid Principal
$239,052.93
B.
Unpaid Interest through 5/15101
$ 5,487.61
C.
Late Fees as of 5/15101
$
785.28
D.
Attorney's commission of 15%
of Principal
$ 35,857.94
TOTAL
$281,183.76
Plus interest from May 16, 2001, at the per diem rate of $52.40, together with costs of suit.
CGA Law Firm
Countess Gilbert Andrews, P. C.
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Supreme Court No. 32111
29 North Duke Street
York, PA 17401
(717) 848-4900
Attorneys for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
THE PEOPLES STATE BANK,
Plaintiff
CIVIL ACTION - LAW
v.
No. Dl - dcx.o
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RANDY 1. LAWRENCE and
SHARON A LAWRENCE,
Defendants
NOTICE OF FILING JUDGMENT
(X) Notice is hereby given that a Judgment in the above-captioned matter has been
entered against you in the amount of$28l,183.76 plus interest and costs on
May J2.., 200 I.
(X) A copy of all documents filed with the Prothonotary in support of the within
judgment is/are enclosed.
__by: ~o-..I' P.7J;~
If you have any questions regarding this Notice, please contact the filing party:
NAME: Sharon E. Myers, Esquire
ADDRESS: 29 North Duke Street
York,PA 17401
TELEPHONE NO: (717) 848-4900
(This Notice is given in accordance with PAR.C.P. 236.)
Notice sent to: NAME Randv L. Lawrence
Sharon A Lawrence
ADDRESS 234 Fox Drive
Mechanicsburl!. P A 17055
i&i~!if;tll,h;j$.$iiilg~ij~'J:{~;;''''::Si''';;JU,!.:."",,':#;'''liF.i!il1l4''!if:l!ttilli'"~-'&ii''^"Ukjt"."""",,,;,;,,;-;~,',,,v""':i>,,;@;,af,,,,,:(;/!.-"'iiilillWl&.~~m 1 jj ~ I illillIJ.' I!i' I
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CIVIL ACTION - LAW
THE PEOPLES STATE BANK,
Plaintiff
v.
No. 2001-3060
RANDY L. AND SHARON A. LAWRENCE,
Defendant
PRAECIPE TO REMOVE
TO THE PROTHONOTARY:
Please mark the above-captioned action discontinued, satisfied and ended.
Respectfully submitted,
CGA LAW FIRM
By L~~
PA # 21009
29 North Duke Street
York, PA 17401
717-848-4900
Attorneys for Plaintiff
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CERTIFICATE OF SERVICE
I hereby certify that on this 9th day of September 2004, a true and correct copy of the
foregoing Praecipe to Remove has been served, via fIrst-class mail, postage prepaid, upon the
following:
Dorothy L. Mott, Esquire
125 State Street
Harrisburg, P A 171 0 I
CGA LAW FIRM
By: ~~~
PA # 21009
29 North Duke Street
York, PA 17401
717-848-4900
Attorneys for Plaintiff
{OO129377/1}
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