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Home My WebLink About99-02950f ORIGINAL: HAYT, HAYT & LANDAU BY. ARTHUR LASHIN IDENTIFICATION NO 23425 SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106.2509 (215) 928.1400 ATTORNEY FOR PLAINTIFF FIRST RESOLUTION INVESTMENT CORPORATION CUMBERLAND COUNTY 639 IsteXI Road COURT OF COMMON PLEAS Suite 390 CIVIL DIVISION Reno, Nevada 89509 va. k TERM, ALICE R. MOUNTZ 899 Emily Drive Mechanicsburg, PA 17055 No. yy-1??50 CIVIL ACTION "NOTICE "You nave Ufen 5ufa .h coult 11 Y'n: niln In rlrlena aY1rntl The uarml 11, IO,In .n !toe h)n0ning bayrs. ,nU "'U" ,,, .11hm IY•enI1 1201 aAli aver In.110 malt' tot ano'O1.,. Ue 111 yea. by ent"'no a `1111" sob Nlanc" pils i"Ittl 0. 01 al Ion., ana lerny w v •rt.ng .,In the c0u11 you, aHerges ,, "n,qtluins I, line Claims set "It. saarnll YOU YOU all walla Thal f you 4.110 oP so IMP CaK may o•Ocero Y•Ilnuu, fall ana a n.agnvnl MAY be to ilea "'o,st you by The court .., .rain U"h" III, an, 'non !Y Cla.mea in the Cnmblaml Or I0r Any Other Cain 01 rl.el larplell fa by Ine 0 4ml,lr. You may 1011 money Of pr0pnly o, 0111rn rights . mpOllant to you "VOII SHOtJLD IAKC T111 PAP(, It III Y(i UI, LAWYI R AT ONCE. if YOU DO NOT LAVE A LAVVY 1 14 011 C ANNOT At I'Ca0 ONE. GO TO OR TFLLPI,ONt Ills no s ua %I.1 I OR T14 eLLOV, TO FIND OUT iiii YOU CAN lit, I.L( OAT, 111, LP Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 "AVISO i --t-. I,rn ill n.naaan a .%ora nn IJ cooe. So ustea otilve .)rrr^ar 11 0:.1 11H ae mijnaH e.purybl en tat p391M{ slqurentes. uUea I,.n. vnle I: U) rL H. of plaro al Penn, ae 4 tecna ae la arnunna V la nntn¢ac.Tn, .tore Alto efenter Una Compafencu HI ,,Is n An prllona a ran on abog,ao Y entregar a la Corte ea r91n`a not 0,14 .In aerensn I, us JOlec.ann a 4s aemanaaa en tonne ae lot plnwne. Sea avnaaa ooe so ustea no 1e penenpe, Is ells Inn"AS ea'an v sues. COnbnun la aemanaa en canto ury. un "'-u alto" n notdiuc.l n. Aa.mes. 'a Corte co.ce let. a.r a 4.OI oil 0emanaanll Y ,eou,ere Our ustea Cumpla Con I"an'n 0111..s.019% ae sits aamanaa. Usle.1 pue0e pelaer ells n I'll 011Ip10aaa.l u buns arl"Chos Importantes Cara Uflea. "1. L( !I I. SIA fit MANDA A UN AOOGAOO I N1.al DIYVI AMT. NT(.. 51 NO TIENE AAOGAOO O 51 NO 111111. L L DIN(' RO SUF ICIENTE DE PPG R TAL S('.RVICIO, VA V A I N Its R10NA U LLAML PUR TEL iCNO A LA (..I ll'INA CU.A DIRLC(IIIIN 51. LNC(JCNTRA ESCRITA PlCill') PA RA AVS WGUP.A DONOE $E PUEDE CONSEOVIR A•J :11. `A :1A LI. ;AL. CIVIL ACTION 1. Plaintiff, First Resolution Investment corporation, is a corporation organized and existing under the laws of the State of Nevada authorized to do business in the Commonwealth of Pennsylvania with offices located at 639 Iste'll Road, Suite 390, Reno, Nevada 89509. 2. The Defendant (s) Alice R. Mountz is/are individual (s) residing at the address(es) contained in the caption of this case. 3. Through accident and without any fault or negligence on the part of Plaintiff, the original contract in this matter was inadvertently lost or destroyed, a true and correct copy of the Affidavit of Indebtedness being attached hereto, made a part hereof, and marked Plaintiff's Exhibit "A". 4. Though diligent search and inquiry have been made, Plaintiff cannot ascertain the current whereabouts of the original contract. 5. Pursuant to the Affidavit of Indebtedness there is presently an outstanding balance as outlined below: Unpaid Balance: $4,728.94 Interest due: 3,113.04 Attorney's fees at 25%: 11960.50 Total due: $9,802.48 6. Despite repeated demand by Plaintiff, Defendant(s) has/have failed and refused to pay the aforesaid sum. WHEREFORE, Plaintiff demands that judgment be entered against Defendant(s) in favor of Plaintiff in the amount of $9,802.48 together with interest and costs. HAY By: Attorney for Plaintiff First Resolution Investment Corporation P.O. Box 34000 Seattle, WA 98124-1000 ALICE R MOUNTZ 899 Emily Drive Mechanicsburg, PA 17055 Account Number: Original Creditor: Original Account #: Current Statement Date Principal Last Payment Date Interest Q 2% per month Collection Costs TOTAL AMOUNT DUE Statement of Account 2293 CHASE MANHATTAN BANK 5465988610505698 07/08/98 $4,328.94 01/23/1996 $2,553.24 $400.00 $7,282.18 This communication is from a debt collector and is an attempt to collect a debt. Any Information obtained will be used for that purpose. A "gem This Is ExhtbiY to in the aMovit of C. T hn RodwgKM R. DEAN SIMPSON sworn before me et Bum y, BC A NOTARY PUBLIC IN AND FOR THE thls day of 19y PROVINCE OF BRITISH COLUMBIA .r r ,:d.** FYN''? ?eoZweau.h cavmel. SWORN AFFIDAVIT OF INDEBTEDNESS CITY OF Burnaby PROVINCE OF British Columbia (CANADA) Before me, a Notary Public of the Province and City aforementioned, personally appeared C. Tim Rodenbush with whom I am personally acquainted (or proved to me upon the basis of satisfactory evidence), and who, upon oath, acknowledged himself to be President of First Resolution Investment Corporation, and that as such President, makes the following affidavit: 1. I am the custodian of the books and records of said business; 2. An account exists against: ALICE R MOUNTZ, Debtor, Social Security Number: 012-30-4636, which is just and correct within the knowledge of Affiant. A copy of the Debtors Statement of Account Is attached hereto and marked Exhibit "A" to this Affidavit, which is justly due and remains unpaid; 3. The said account, which originated with CHASE MANHATTAN BANK (USA), was, on the 17th day of March, 1998, by MKM Acquisitions LLC, sold, transferred and set over unto First Resolution Investment Corporation with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of the said claim and said account and further, Affiant states that to the best of Affiants knowledge, information and belief there were no uncredited payments. 4. The services and goods thereon stated and composing the said account were prepaid for said Debtor at this special instance and request. 5. The name, address, and/or work address on the summons is the last known for the defendant; 6. Credit has been duly given for all payments and just and lawful effects to which said account is entitled as thereon stated; -2- 7. The Total Debt balance thereof, amounting to the sum of $7,282.18, is justly due and remains unpaid. 8. That to the best of Affiant's knowledge and belief the defendant is employed in civilian life and by reason thereof is not engaged in the military service of the United States and is a resident of the State and of the County in which this action has been filed. 9. If this debt is based upon a written contract and there is a provision within said contract for the defaulting to pay the plaintiffs reasonable attorney fees then; a. The plaintiff has contracted with its attorney of record to pay an attorney fee of 25% contingent upon recovery of debt from the defendant; b. The plaintiff contracts with many Attorneys across the nation to collect similar debts, in the states where attorney fees are allowed, the attorney fees agreed to be paid are compatible with those paid in the other states; C. If there is an attorney fee amount listed in 9(a) then the debt is based upon written contract with a provision for the debtor to pay plaintiffs reasonable attorney fee. Signature of Contact Person C. Tim Rodenbush. President Print Name & Title of Contact Witness my hand and seal; at office in Burnaby, BC, Canada, this the emu' Day of V 11998 `J R. Dean mph n A NotarP c in and for the Province of British Columbia My commission expires: Permanent Commission ctft `?tr :P" ac?i'N? P CB OF BRITISH COLUMBIA SS CIT/ eGVK Y OF BURNABY AFFIDAVIT J C. Tim Rodenbush, being duly sworn according to law, deposes and says that he is President of First Resolution Investment Corporation, and that he is duly authorized to take this Affidavit on behalf of First Resolution Investment Corporation, and that the facts contained in the attached pleading are true and correct to the best of his information, knowledge and belief. --------- C. Tim Ro President Sworn to and subscribed before me this 756' day of (dov£wn rte- /, 19.90 R. DEAq SI P, 0. A NOTARY PURL A FOR THE PROVINCE OF BRITISH COLUMBIA U ?_ ?? ('`? C %? J ti:? i?=> ?`? (a '-? i ?_.._ ? ? ?1 :? T i:. :I ?. .. rr? Ci . _.J U ? ? . ???? Q? ? ? V ? O \ ? ` \_ W (? SHERIFF'S RETURN - REGULAR CASE NO: 1999-02950 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST RESOLUTION INVESTMENT VS. MOUNTZ ALICE HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon MOUNTZ ALICE R the defendant, at 9:30 HOURS, on the 2nd day of June 1999 at 899 EMILY DRIVE MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to ALICE R. MOUNTZ a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 5.58 ?? 2 Affidavit .00 Surcharge 8.00 omas Kline, 3 eri 6/03/ 999 & LANDAU by pu Sworn a/nIDdD subscribed to before me this day of 19 CG A. D1. O MAARTSON DEARDORFF WILLIAMS K OTTO :Iw?rFUm+x•Am?u?•Aimxmx ? •. TrWEAST ('11011 STREET ' CARLISLE; PENNSYLVANIA 17013 v FIRST RESOLUTION INVESTMENT CORPORATION, Plaintiff V. ALICE R. MOUNTZ, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2950 CIVIL ACTION-LAW Defendant : JURY TRIAL OF TWELVE DEMANDED TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. Defendant hereby demands a twelve jurorjury trial in the above captioned action. MARTSON DE O FF WILLIAMS &OTTO BY? / George B. Faller, Jr., PI Lire I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: June 23, 1999 CERTIFICATE OF 4FRVIC E I, Nichole L. Myers, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Arthur Lashin, Esquire HAYT, HAYT & LANDAU Sixth Floor 400 Market Street Philadelphia, PA 19106-2509 MARTSON DEARDORFF WILLIAMS & OTTO BY-jV{(" Ul AG L a,- Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: June 23, 1999 r., U) ?5. .1 ?... I? ?_ C ref:. ._.. ? ?i : -;' i .J ii.? ..?'.. ?...' ??1' CJ ' .. ? ? J F'J'ILESVIATAFI I.Ii`GEN000"9 549251 PO I W m Orcned UN21N9 12 x0.29 PM Revised O&W/W 1211.15 PM $49251 FIRST RESOLUTION INVESTMENT CORPORATION, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2950 CIVIL ACTION-LAW ALICE R. MOUNTZ, Defendant : JURY TRIAL OF TWELVE DEMANDED DEFENDANT'S PRELIMINARY OB IECTiONS TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant, Alice R. Mountz., by and through her attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and propounds these preliminary objections, and avers as follows: I. Plaintiff's Complaint was filed on or about May 14, 1999. (A copy of that Complaint is hereby attached as Exhibit "A"). 2. The Complaint alleges in paragraph 3 that the cause of action is on a written contract. 3. The Complaint fails to attach a copy of the written Complaint and in fact states that the original contract has been lost or destroyed. 4. The Complaint fails to allege the date the original contract was entered or the dates in which the indebtedness was incurred. 5. The Complaint makes a claim for attorneys fees of 25% and there is no basis for a claim for attorneys fees in the absence of a written agreement to the contrary. 6. The Complaint makes a claim for interest due of 2% per month when there is no basis for such a claim unless there is a written agreement to the contrary. WHEREFORE, Defendant requests that this Court grant a demur to Plaintiff's Complaint and since Plaintiffs are unable to produce any written agreement signed by the Defendant. MARTSON DEA`RDORFF?WILLIAMS & OTTO By g Ge B. Faller, Jr., Es i I.D. Number 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 (/ t r; Attorneys for Defendant I l Date: ?C C ( ?) , LEGAL SERVICES. INC. 2438026 P.02 TRUE 400py III To y wtWM HAYTt HAYT & LANDAU BY: ARTHUR LASRIN IDENTIFICATION N0 23425 SIXTH FLOOR 400 MARKET STREET Pi-KADELPMA, WA 181015.21500 12191926.1400 ATTORNEY FOR PLAINTIFF FIRST RESOLUTION INVESTMENT COR90RATION 639 Ista= Road Suite 590 Reno, Nevada 89509 Va. ALICE R. MOONT2 899 miry Drive Mechanicsburg, PA 17055 "NOTICE •, YOY naYa ONn fup rn aQYI:, it YpW wnh 10 QtIM against tneclalmap[ """'A the ""o mg bago, p r YCY M.61 ,aril action bYtentelNn ntY ISOI e[Yf alto, Ihla cope m A., ti"". vt ter.ea, "llpg In W,tmg/W uh In, coin, Y ou•reetlengt or 001ct?Oni to lee tla,mi tot IOnn 1gltn11 You. VOW ,, pa-1111M tnlt .1 You fart to Cc to in' Cap may Grace" W.f,nWt Ymo an0 a tuormfni T,, 0. an- If,aO 101", YOU by the tour, W IthOYI 'With,, policy 10, any Moro to I as bCIO." i. y en[ eIUM Jf,OYOUam?Y rap Of any monoother :I6-M or rtfal N,~. IMO011 ant tQ you. Y po' urOmVly or tine/ right, "vCU SHOULD TA"[ THIS VAPCR TO YOUR LA" R AT ONCE. la'YOU OO NOT "Ave A LAWYER OR CANN E T R A FORD ONE. GO TO OR TELEFHON[ THE Crop OT TO /INO Guy WH[R[ YOU CAN OET #rE SET T LEGAL HEFORTH LP. Cumberland COunty.Bar Association 2 Liberty Avenue Carlislea•Penn6ylvania 17013 (717) 249-3166 MM R I, I here unto fat my Iwo CM31 Ca111sle, pav BE A VRA I oERTIFY THE WITi-L lik ! °• COPY OF TIIE OP, F THIS CASE. Ahd;my sr ? mtt! - - •.u CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION TERM. 9?t ? a9s v (d ?? No. CIVIL ACTION "AV ISO "Le pan pereanoaa0 a ugeo M It torte, A wN0 OuNw Qe1;ea.1fa as carat tlem++Maa eA0ug11t to let I?Pitl vourln!H. uf1eO dens YPnfo 1201 rfiaa, at Plaac al Palbr do 081 IoCnl do to tidelands v le not'.frcfc,bn. "ace falls 6enfar un$ co mOUertcu [ILllta 0 [n maf 10 na a Con We aeop0a or enll[ear a"Carl* an IOlma *scrota I., cefth Mt a WI Qb^,0p0 a ralpNNnpM an Contra Qa w "hale. Sea aYllaeo Pus w uPtO 00 'a get,M Qa.'a COR* IYrharf matl10" Y eucv, c ntfnYar to coma"Ca an taRN IVYa tin OreYIC Ante- -011f."NSn. Ap[tmty a corb Ru[Qy tleclOU a #AYO, 0, 04RYFOante Y gaina" aA Willa cumela ion IOtla, fat Orwmonea Oa tlta 06nan0a. uNHO QutOt Oy,Qe1 OtntrO o Wt Drooi[tlaOM u OIrOO aefeen0l l,ngGfbnt" Oars "INC, "LLEV [ ESTA OC MANOR A UN AROGAOO iHMIOIATAM[NT[. Sl NO TICNC AOOOADO O SI No TICNC EL OINCRO SUr•ICI[NT0 00 PAO/l??R TAL SEgvlC,O VAYA EN PERSONA 0 LLAMC WOR TELeMO A I.A OFICINA CUYA DIRECC,CFN SC CNCUCNrAA ESCRITA AeAJO.0^RA AVCRIq UAR OONOE Sr FUCOt CDNSCGwat ASr5T[NCIA LEGAL, Exhibit "A" .' LEGAL SERVICES, INC. 2430026 i• 7laiatiff, Sirat Its Nevada authorixed to corporation orgaained and existing under the leas of the State Of Investment Corporation, is s Pennsylvania with olficesd la business 63B 2ata11 Road, aSuitoh390, 114110, Nevada' 89509. 2. The Defendant (a) Alice it. Mounts is/are individual (a) residing at the addrees(es) contained in the caption of this cage, 3• Through accident and without any fault or nonligenca on the Part of Plaintiff, the original contract in this :natter was inadvertently lost or destrooyid, a true and correct copy of th ag attached hereto the Affidavit of Xu de plc ?t ?f,_ , made a hereof, and marke +sxhibit °A¦, part 4• Though diligent acarch and inquiry have been made, Plaintiff o annot ascertain the current whereabouta of the original contract. S- Pursuant to an out standing balanceAffidavit of there is Presently ailpaid Balances $4,748.94 Interest dues: 3,113.04 Attorney•a fees at 2,5%. 1-292-JA Total dues 6• Despite repaatsd $9,802.48 failed and refused to demand by Plaintiff, Defendant(s) has/have PAY the aforesaid num. DMRBPORE, Plaintiff demands that Defendant(s) in favor of Plaintiff iss??t be entered against together With interest and costs. the amount of (9,804.48 BAYT, HAYT & By s P.03 i i Attorney for Plaintiff LEGAL SERVICES, INC. 2400026 P.04 r First R63oludon Investment Corporation P.O. Box $4000 Seattle, WA 9812441000 ALICE R MOUNTZ 899 Emily Drive Mechanicsburg, PA 17055 Account Number. Original Creditor. Original Account P Current Statement Date Principal Last Payment Date Interest ® 2016 per month Collection Costs TOTAL AMOUNT DUE Statement of Account 2293 CHASE MANHATTAN BANK 5485988810505098 07/08/98 $4,328.94 01/23/1998 $2,553.24 $400.00 $7,282.18 This Fommunication is from a debt collector and is an attempt to collect a debt. Any information obtained Wit be used for that purpose. "rafarrod to in ttw Nedwk of C. Tkn Radaft ah R. DEAN SIMPSON % K • ac A NOTARY PUBLIC IN AND FOR THE PROVINCEOF BRITISH COLUMBIA I;V1-.-jT AC LEGAL SERVICES. INC. 2439026 P.03 618MN AFFIQAVIT OR I QEBTEQNESS CITY OF Burnaby PROVINCE OF British Columbia (CANADA) Before me, a Notary Public of the Province and City aforementioned, personally appeared C. Tim Rodenbush with whom I am personally acquaimed (or proved to me upon the basis of satisfactory evidence), and who, upon oath, acknowledged himself to be President of First Resolution Investment Corporation, and that as such President makes the following affidavit: 1. I am the custodian of the books and records of said business; 2. An account exists against: ALICE R MOUNTZ, Debtor, Solo) Security Number. 012-30-4636, which is just and correct within the knowledge of Affiant. A copy of the Debtor's Statement of Account Is attached hereto and marked Exhibit "A" to this Affidavit which Is justly due and remains unpaid; 3. The said account, which originated with CHASE MANHATTAN BANK (USA), was, on the 17th day of March, 1998, by MKM Acquisitions LLC, sold, transferred and sat over unto First Resolution Investment Corporation with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment compromise or satisfaction of the sold claim and said account and further, ABlant states that to the best of Affiant's knowledge, information and belief there were no uncradlted payments. 4. The services and goods thereon stated and composing the said account were prepaid for said Debtor at this special instance and request. 6, ' The name, address, and/or work address on the summons Is the last known for the defendant; 6. Credit has been duly given for all payments and just and lawful effects to which said account is entitled as thereon stated: &YN *.IT 't " LEGRL SERVICES, INC. ' 2436026 '2- 7. The Total Debt balance thereof, amounting to the sum of $7,282.18, Is Justly due and remains unpaid. a. That to the best of Affiant's knowledge and belief the defendant is employed In civilian life and by reason thereof is not engaged in the military service of the United Stales and is a resident of the State and of the County in which this action has been filed. 9. If this debt is based upon a written contract and there is a provision within said contract for the defaulting to pay the plaInWs reasonable attorney fees then; a. The plaintiff has contracted with its aftomey of record to pay an attorney fee of 25% contingent upon recovery of debt from the defendant; b • The plaintiff contracts with many Attorneys across the nation to collect similar debts, In the states where attorney fees are allowed, the attorney fees agreed to be paid are compatible with those paid In the other states; C. If there is an attorney tea amount listed in 9(a) then the debt is based upon written contract with a provision for the debtor to pay plaintiffs reasonable attorney fee. \J Signature of Contact Person G. Tim Rodenh?? ti a Print Name $ Title of Contact Witness my hand and seal, at office in 1998 Burnaby, BC, Canada, this the ,9u_ Day of R. Dean ;Vjn A Nita and for the Province of British Columbia IVY commission expires: P-2EMenent Commission P.06 • ? r LEGAL SERVICES. INC. 2430026 P.O p of IRITZM Coam®am C.r My; so GQWMT or BDRW?sa Anmmm C. Tim Modembueh, being duly sworn according to law, deposal and says that he is President of pi.rst Resolution =nvostmeut Corporation, and that he in duly authorized to take this Affidavit on behalf of 81st Reaolut3ou savestMnt Corporation, and that the tacta contained in the attached pleading are true and correct to "a best of his intormation, knowledge and belief. C. Tim no President sworn to and subscribed before me this '250- day, of r4wEwntr&• - , L• 19.5x6 R. DEAN SI Pik A NOTARY PURL AM FOM THE PROVINCE OF SRms H COLUMBLA i I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Defendant's Preliminary Objections to Plaintiff s Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Arthur Lashin, Esquire HAYT, HAYT & LANDAU Sixth Floor 400 Market Street Philadelphia, PA 19106-2509 MARTSON DEARDORFF WILLIAMS & OTTO By Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: JUV ?(?/ 1099 I r'! rl r f. r Ci r( ow .? 1 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and sutmitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within natter for the next Argument Court. CAPTION OF CASE (entire caption must be stated in full) FIRST RESOLUTION INVESTMENT (Plaintiff) VS. ALICE R. MOUNTZ (Defendant) No, 99-2950 Civil Action-Law 19 99 1. State matter to be argued (i.e., Plaintiff's motion for new trial, defendant's dam=-er to canplaint, etc.): Defendant's Preliminary objections to Plaintiff's Complaint 2. Identify counsel who will argue case: (a) for plaintiff: Arthur Lashin, Esquire Address: HAYT, HAYT & LANDAU, Sixth Floor 400 Market Street Philadelphia, PA 19106-2509 (b) for defendant: George B. Faller, Jr., Esquire Address: MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 3. I will notify all parties in writing within two days that this case has been listed for argumst. 4. Argument Court Date: October 13, CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Arthur Lashin, Esquire HAYT, HAYT & LANDAU Sixth Floor 400 Market Street Philadelphia, PA 19106-2509 MARTSON DEARDORFF WILLIAMS & OTTO By . IChc6 -l. / , u ?A/? Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 24, 1999 C: 7?t?? V.t :?? • C-D 11/l yl ]2 IL rn j Cil V "'(WA1A& HAY; HAYT & LANDAU BY: ARTHUR LASHIN, ESQUIRE IDENTIFICATION NO, 23425 ATTORNEY FOR PLAINTIFF SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106.2509 (215) 928-1400 , FIRST RESOLUTION INVESTMENT CORPORATION VS. ALICE R. MOUNTZ CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DI VISION TERM, No. 99-2950 PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROT11ONfARY: Kindly discontinue the above captioned matter without prejudice. HAYT, HAYT & LAND By: Attorney for Plaintiff -' Atli C' 1 L1 L " :?? cn J