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L<\?41iS cl,AY AND MARY : IN I'I IF, C'OWRT OP COMMON I'IAQS OF
FRANCES CLAP. Husband and
\Vifc. I'laintit•fs : C'1)\IISI:RL:AND COUNTY. PENNSYLVANIA
c.
: NO. 99 - 6866 C'I\'Il.:\CIION - LAW
M:ARI:AN INSPIRATIONS. INC'
Defendant : coNPI?SSION Ob.ItjI)GE',\IFNI'
'Notice Under Rule 2958.1 of.ludgcmcnt
and F.Xecution 'Thereon
Notice oI' Detcndant'S Ri_hlS
'I'o: \•IARIAN INSPIRATIONS. INC.
A judgenunt in the amount of S 16.15180 As been entered against you and in liivor of
the plaintil'I'without any prior notice or hearing based on a confession ofjudgentenl contained in
a written agreement or other paper allegedly signed by you. Ile shcrin' may take your money or
other property to pay the judgement at any time alter thirty (30) days aaer the date on myhich this
notice is served on you.
You lnay have Icgal rights to defeat the judgement or to provcnt you anxtCy ot• property
Ifom being taken. YOU INIUST FIL1: A 1'1:'I'1'I'MIN 51:1•:KING IZELIEh FRO\1'1'1IE
JUDGEMENT AND I'RLSENT IT TO A JUDGE WITHIN TIIIIZTY (30) DAYS AFTER
I'Iil: UAI'F.ON \\'111011 1'1115 NO.1'ICL ISSI.I2VLD ON YOIi OR YOU MAY LOST.
YOUR RIG11"I :S.
1'OU SIIOULD TAKE THIS PAI'ER'I'O YOUR LA\\'YER AT ONCE. IF YOU
DO NOT IIAVE A LA\VYI:R OR CANNO'T' AFFORD ONE, GO "I'O OR 'I'Ii:LE1'?iON1'.
1'L1F, OPPICI's 81:'1' hOR'I'll 131:L0\\' "1'O iliiU OU"I' \\'III:RF. YOU CAN GET LGC:AI.
HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. Pennsylvania 17013
Telephone 17171 249- ', 166
AMERICANS WITH DISABILITIES ACTOP 1990
The Court of Common Pleas of Cumberland County is required by law to comph with
the Americans Nvith Disabilities Act of 1990. For inlitrnnttion about accessible facilities and
reasonable accommodations available to disabled individuals having business bcl'ore the court,
please contact our office. All arrangements must be made at least 73 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
.lamcs.l. Kayer. Esquire
Attorney 1'61. I'lahitiff
Liberty Loft
=4 East Liberty Avenue
Carlisle. PA 17013
(717) 243-7923
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JAMES CLAY AND MARY
FRANCES CLAY, Husband and
Wife, Plaintiffs
V.
MARIAN INSPIRA'T'IONS. INC
Defendant
IN TI IF COURT OP COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6866 CIVIL ACTION - LAW
CONFESSION OF JUDGEMENT
MOTION TO COMPEL ANSWERS TO INTERROGATORIES
AND PRODUCTION OF DOCUMENTS IN RESPONSE TO REQUEST
FOR PRODUCTION OF DOCUMENTS
COMES NOW, the Plaintiffs in the above matter, by their attorney, James J. Kayer, Esquire, and
request of this Honorable Court that it direct the Defendant to respond to the Interrogatories. In support
of this request, plaintiffs aver as follows:
1. On May 25, 2000, the Defendant was served with the attached interrogatories and
Request for Production of Documents, by U.S. Mail, through their attorney, James J. Kayer. Esq.
2. To date, there has been no response to this discovery.
3. Judgement was entered in favor of the Plaintiffs and against the defendant on November 12,
1999 and Defendant has made no attempt to satisfy this judgment or otherwise respond to Plaintiffs'
frequent attempts at contact.
WHEREFORE, Plaintiffs respectfully request of this Honorable Court that it enter a Rule
upon the Defendant to show cause why it should not be held in contempt for failing to respond to the
attached discovery request.
Respectfully submitted,
James J. Kayer Ls`t
Liberty Loft
4 Liberty AVcTe
Carlisle, PA Iq013
(717) 243-792
Date: i -I // 7 /CO
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing Motion to Compel Answers to
Interrogatories and Production of Documents in Response to Request for Production of
Documents was duly served upon the Defendant by First-class mail, postage prepaid, by
forwarding a true and correct copy unto:
Marian Industries, Inc
Andrew Fine, President
3876 Union Deposit Road
Harrisburg, PA 17019
Date Z?15 '
4 East Liberty ve
Liberty Loft!
Carlisle, PA 17013
(717)243-7922
I
VERIFICATION OF PLEADINGS
The f0mgonlg cloclhmclit is based l(Plll inf0rm.^ iOn Which has been gathered by in)- counsel
and myself in the Preparation of this action. Thu kmguage of the document may, in part, be the
language of in), counsel and not my oval. I lgtvc react the statements made in this document and to
the extent that it is basal upon information which I have given to my counsel, it is true and correct
to the best o! ill), knowledge, information and belief. To the extent that the contents of the
statements are that of counsel, I have mliecl upon counsel in nla :--zing this Verification. I understand
that false statenens herein are made subject to the penalties of ]E PA. C.S. § 4904, relating to
unsWorn falsification to authorities.
llatc: 17. I t ? ? fit, ° c?
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JAMES CLAY AND MARY : IN THE COURT OF COMMON PLEAS OF
FRANCES CLAY, Husband and
Wife. Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 99 - 6866 CIVIL ACTION - LAW
MARIAN INSPIRATIONS, INC
Defendant : CONFESSION OF JUDGEMEN"f
ORDER OF COURT
RULE TO SHOW CAUSE IN RE: MOTION TO COMPEL ANSWERS TO
INTERROGATORIES AND PRODUCTION OF DOCUMENTS IN RESPONSE TO
REQUEST FOR PRODUCTION OF DOCUMENTS
AND NOW, this 2 7' clay of'_?ec? 2000. a Rude is issued upon the
o,dw J
Defendant to show cause why he should not be n !uPTMT to Answer the
Interrogatories in aid of execution.
'this Rude is returnable as follows:
BY THE COURT,
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JAMES CLAY AND MARY
FRANCES CLAY, Husband and
wife, PlaintilTs
V.
MARIAN INSPIRATIONS, INC
Defendant
IN'ri-IL-• COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.99- (W& CIVIL ACTION-LAW
CONFESSION OF JUDGEMENT
PRACEPIE
COUNT I - CONFESSION FOR JUDGEMENT FOR MONEY
Dear Sir:
Pursuant to the authority contained in the warrant to the attorney, a copy of which is attached to
the complaint filed in this action. I appear as attorney I'or the Defendant and ConfcSS Judgement in favor
of the Plaintiffs and against Defendant as follows:
Principal Sum $10,350.00
Interest to and including Novwcmber 30, 1999 - 5.309.80
Attorney's Fees - 500.00
Total - $ 16.159.80
To: Lawrence E. Welker, Prothonotary
November , 1999
KAYER AND BROWN
By: G?
IanieJ. Kay Es tiro
Kaye and B own
4 En t Liberty Street
Car sle PA 17013
(717) 243-7932
ID# 50838
JAMES CLAY AND iNIARY : IN'I'I Ili COIJR'1. OP COMMON PLEAS OP
PRANCES CLAY, Husband and
Wile, Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
MARIAN NO. 99 - CIVIL ACTION - LAW
INSPIRATION S. WC'..
Defendant : CONFESSION OPJUDGENIENT
Creditors
Debtors
James and Mary Prances Clay
106 1-fill Lane Marian Inspirations. Inc.
Mechanicsburg PA 17055 Prcsidcnt Andrew F. Fine
3876 Union Deposit Road
Harrisburg PA 17019
KAYER AND BROWN
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By:
.lame- 's J• Kayci. I:s luire
Kaycr and Brown
4. East Liberty street
Carlisle PA 17013
(717) 243-7922
Date: November 1999 ID:: 508 38
i
JAMBS CLAY AND MARY : IN TI[E COURT' 01: CONI\ION PLEAS OF
FRANCES CLAY, Husband and
"Vito. Plaintiffs : Cl IN[B1 RLAN1) COUNTY, I'I:NNSYI-VANIA
V.
NO. 99 - CIVIL. ACTION - LAW
MARIAN INSPIRATIONS, INC.
Defendant : CONFESSION O1' JUDGEMENT
COMPLAINT IN CONFESSION OF- JUDGEMENT
AND NOW. comes the Plaintiffs .JAMES F. CLAY. SR. all(] MARY FRANCES CLAY, by their
attomey .lames ,I, payer. Esquire, and who makes the Rtllovving Complaint in Confession ot'Judgcmcnt:
Plaintify-s arc.IAiMES P. CLAY. SR.. and i\9ARY FRANC'I-S CLAY, husband and wife who
reside at 106 Hill Lane. Nfech atiesburg. PA. 17055.
2. Defendant. MARIAN INSPIRATIONS. INC.. is a Pensylvania Corporation doing business
at 3876 Union Deposit Road, Harrisburg. PA. 17109.
3. At all times relevant the president of \9ARIAN INSPIRATIONS. INC., is Andrew V. Fine.
4. A true and correct copy ol'two Promissory Notes between Plaintiffs and Defendant (fated
February 2, 1995, arc attached hereto, designated as Exhibit's '7\° and "13" and are incorporated herein by
reference thereto.
5. These instruments have not been assiened.
6. ,lodgement's ofthese instruments have not been previously entered in anyjurisdiction.
7. The third paragraph ol'each note states in pertinent part as follows:
The maker hereol'hereby authorizes any attorney - at - law to appear in any court of record
of the state of Pennsylvania or any other state in the United states at any time,
licr this becomes due.
whether by acceleration or otherwise. and to waive the issuing ofservice ol'process and exemptions
ant] confess ajudgentent in favor ol'the legal holder hercofagainst the maker for the amount of the
principal and interest then appearing clue ol'this note, u,gether with the costs of suit and to release
all errors and wave all right 0I'appea1 or exenyotioI I.
The \laker hercol'hereby waives presentment, demand notice ofdishonor. protest and notice
of nonpayment. The undersigned has executed this instrument in his capacity as chief operating
officer of the corporation.
S. The Defendant has delaulted in its obligations to repay oil these notes as f'ollows:
A. 'fhc maturity date of the f first note is August 2, 1997 at which time the Defendant was
required to repay the principal amount ol'S5.350.00, with interest from the initiation date at
the rate o1`8 'L,%o perauuuun. The Defendant failed to sotisk the note on the maturity date
and has flailed to make any payments due on the note at any time since the initiation date of
February 2. 1995.
13. 'fhc ntatUrity date ol'thc second note is August I. 1995 at which little the Defendant
Nvas required to repay the principal amount of'S5.000.00, with interest 1}om the initiation dale
at the rate of S'G,%, per annum. The Defendant failed to satisfy the note on the maturity date
and has lailed to make any payments due on the note at am 'time since the initiation date of
February 2. 1995.
9. On or about February 28. 1999, the Defendant acknowledged its obligation under both notes
and provided the Plaintill's with a calculation ol'interest and principle owed on the obligations. A true and
correct copy of this acknowledgement is attached hereto made a part hercol'and designated as Exhibit "C"
10. On or about \larch 20. 1999, the Notice of Defhult was delivered to the Defendant by
personal service. A true and correct copy ol'this notice is attached hereto, made part hereof and designated
as Exhibit "D".
11. On or about Ally, 9. 1999, Plaintiffs notified the Defendant ofthe default and Intent to Enter
Judgement and Commence a Statutory Action. Said notice was fiorwarded by first class mail and receipt of
said mail was acknowledged by the Dclcndant's president. Andrew Dine, on August 20. 1999. A true and
correct copy ol'the notice is attached hereto, designated as Iixhihit "I", and incorporated herein by relcrence.
12. I laintiff-s have not received any payment from the Defendant since the initiation of both
notes.
13. 'f'ile sums due and owing from the Delendanl to the Plaintiffs are as rollows:
A. Remaining balance ol'principle due and owing S 10.350.00
13. Accrued interest on the principle commencing on February 2. 199 and including
November 31, 1999.5309.50.
C. Attorney's lees - $500.00
D. Total Due - $16.159. 80
14. Plaintiff's demandjudgemcnt against the Defendant. as authorized by the warrant contained
in the attached instruments. Plaintiffs Fxhibifs "A" and "I3" in the total ofS16.159.80. together with the
Costs of suit, continuing interest al the rate of Sper annum on the unpaid principal balance.
WHEREFORE Plaintiffs demand judgement be entered against the Defendant, Marian
Inspriration's, Inc.. in the total Sum of S 16.159.50. together with costs of suit and continuing interest rate
of S 3/1%.
Respectfully Submitted.
Jantcs.1. Kayer. I?squire
4 East Libertv Street
Carlisle 11A 17013
Date 1999 IDit 5008
EXHIBIT A
A?l#YLA/iN ZNS'I?A)FZA"TZ?NS'? AYJC-
#49 Colonial Park Mnll
Harrlsburg, PA 17109
(717) 540-7244
:Sb, 3C;U.
Ih1I'fIATION DATE: !=EHRUARY , J.':J55
?.'J' 7
rv,TLJF,ITY DATE: AUGI.IF,l' :i,
INTEREST' RATE: 0.7.`.i% lfdivl!1'!
I-OR Vh;J.IE r:ECEIrJEr?, 1•IAF:iAty IPJS`.cF:P,TIDf.JS, INC., A
F'ENRISYLVA, I I R C:ORPOi•;! i7I ON, AGRELF TO Fri`f TO THE URDGF; CJ `r
JAI'iEB I IiAII:Y l-r:ANCES ?-:!_RY, ,ICIIPIT TCN:`:IJ'rS t:I'fFt
l'1•IE RIGHTS 0" SUF VIVO ;':HIP RESIDING IfJ l"IiE STATE OF
PENi4SYl_VAIJIA, 'fHE SUP., OF THUU`AND THREE HUivi)F:ED I-IF7Y
DAl'E
I)ULt_Rr:S C:,55Ct, j, TO?.E"rF!E: blITFi Ii:'rER='S7 FROt9 THE
Ff_i:[:UF AT THE RATE' OF CIG>'.'f Aim fiaFtCE 0UA2TLRS PEfb_ENl'
ALL F!C:CUMULATC*D If•J"fE,r.,r_gr 11 LL D'EE 1='Cl AT THE 1'h?TUf•;I1'Y DATE
STf-.TED ABOVE. 7f!E "F:IP!i:iPA.. (-MOUNT 0.- "fFII NOTE t•JII•L
AUTOHATICALF_Y RENEW F' 0rt A LIKE TERM AND L iKE Ii•!YERE iT Oo
PL^iYURITY DATE UNLESS U"iHER4JI .- idOTIFIED THiFrf`? DAYS r:IIJR TO
`1ATURITY DATE.
c^ IIEREOF i-!EPH Y AUTHORIZES ANY ATTOF:N Y - AT - LAW
1-0 !=TAIAP'F'EAr: IN RN ' C:OUF:"f Ol i ECOi OF T A- STATE OF
F'ciJF1°1'LVAiJIP. UF: A!`I Ul'i t=F: STO E IiJ THE UNITED STATES AT ANY
fU9-'RFTEI? THIS B=CU4=S t:Uc, l.1HEl'HL=R L'l' RCC:ELERATIr OR
w I V? TF-!G: ISSUif•!G OF SERVICE O PROCESS
O"I'FIER!•1IS?, ANT! T U
EXCt•iF'7I0^:a (if•JF? CUi? ESS :11 JUDi EPi?i•.i7 IN FAVOR Or THE LEGAL
0! i_r; I-IEREOF AGAINST THE ti:"-rKEf? FOR' TFIE AMOUNT OS NOTE
PRI1dCIf--A At •1D INTEREST THEN AF'P•cAi:ING DUE OF TIH-iS NOT,
'fO!3E'!'FiER L1I1 i-! "iF!E COSTS OF F..UIl Atli) TO RELEASE R!_L EF:F:GRS
'TI
Apr. •• t.J^.T'.VE ALL rtlCl-'.T OF F.PFEA._ Or; E):CDiF ON.
F.?tC vrr; HERE•^.. HEREI:,'?
0= DISHOt•!Oi, f-'R::TET FdJU
Utdl?EF;SIG!'d: U I•!:?-=• E: ECUI ED
C::11EF OPERFiTi.PG OFFICER
1RIVE:S PRESENISMENT, DEMAND NOTICE
NOTICE 0- NONPAYMENT. THE
TIdIS INSTRUMENT IN HIS CAPACIT`? AS
()!- CORPORA 7I ON-
is ?. iVr r t -•rc:,"
L __7 r,NlrcE!.j v. FIN=_
PI ES1DENT
.._......•........o,?.-?•s"?s_,e:rr^?zsM•-=>=?t.•a*,^^^c_ ?rs ...+.*.m?rgm+sr?a Ka
EXHIBIT B
A&AYZXAN INSPIRAx'IONS, INC_
#49 Colonial Park Mall
Harrisburg, PA 17109
(717) 540-7244
5s, 000.
INITIATION DATE: FEBRUARY 2, 1995
PIATURITY DATE: AUGUST 1, 1993
INTEREST RATE: 2.75% PER ANNUM
FOI' VALUE P;ECEIVED, MARIAN INSPIRATIONS, INC., A
PENNSYLVANIA CORPORATION, AGREES TO PAY TO THE ORDER OF
JAMES F. CLAY, SR. AND NARY FI A^IC:ES i L.A`/, JOINT TENANT'S WITH
!*HE RIG!-ITS" OF SUI-,*VI'VDRSHIP RESIDING IN THE STATE OF
PENi•lSYLVANIA, THE SUN OF FIVE THOUSAND DOLLARS (•. 5,000.),
TOGETHER WITH INTEREST FT;Orl THE DATE HEREOF AT THE RATE OF
EIGN'T AND THREE C!UAFdTEI S PERCENT (0.75%) PER ANNUM.
:iT_L ACCUNUL.ATED INTEREST WILL EG PAID AT THE MATUR'ITY DATE
STATED ABOVE. THE PRINCIPAL AMOUNT OF THIS NOTE WILL
-AUTOI•IATiCAt_LY RENEW FOR A LIFE TER'li AP:D LIKE INTEREST ON
mi'vr RiTY DATE UNLESS OTHERWISE NOTIFIED -THIRTY DAYS PRIOR TO
NATUI ITY DATE.
THE MAKER HEREOF- HEREE`i AUTHORIZES ANY ATTORNEY -- AT - LAW
TO AF'PEA.R 'It,! FiNY COURT OF- RECORD OF THE STATE OF
PENNSYLVANIA OR ATJY OTHE•, STATE: IN THE UNITED STATES AT ANY
TIME AFTER TF'IS BECOMES DUE, WHETHER BY ACCELERATION OF:
OTHERWISE, AND TO WAIVE THE ISSUING OF SERVICE OF PROCESS
AND EXEMPTIONS AND CONFESS A JUDGEMENT IN FAVOR OF THE LEGAL
HOLDER HEREOF AGAINST THE MAKER FOR '!-HE AMOUNT OF THE
PRINCIPAL AND INTEREST THEN APPEARING DUE OF THIS NOTE,
TOGETHER WITH THE COSTS OF SUIT AND TO RELEASE ALL ERRORS
AND WAIVE ALL RIGHT OF APPEAL OR EXEMPTION.
THE MAKER HEREOF HERESY NAIVES PRESENT'ENENT, DEMANU NOTICE
OF DISHONOR, P'ROTEST AND NOTICE OF NONPAYME-NT. THE
UNDERSIGNED HAS EXECUTED THIS INSTRUMENT IN HIS CAPACITY AS
C:IIIGI' OPERATING OFFICER OF THE CORPORi?TIOi•l.
iiARI'AN INSPIF•:A:IONS, .1N
ANDREW V. FINE
PRESIDENT
EXHIBIT C
Marian Inspirations, Inc.
3876 Union Dupusii Road
Harrisburg, Pa. 17109
voice phone: 717-540-7244
fax: 717-540-7243
MR AND MRS JAMES 1. CLAY
106 I1ILL LANE
ME•CIIANICSBURG, PA 17055
28 FEBRUARY, 1999
9'1--R.%1 I.O AN INI'I'IAT.I%ED: 02/24/94
PRINCIPAL ANIOUNT: $5,000.
NATURITY DATE:
INTEREST RATE: 7.00%
05/02/99
5.75°f?
INTEREST 02124/95
INTEREST 02/24/96
INTEREST 02/24/97
INTEREST 02/24/95
INTE•RESR 02/24/99
CURRENT VALUE:
350.00
•168.12
509.05
i53.63
602.05
$7,482.91
TERM LOAN INI'T'IALIZED: 02/02/95
PRINCIPAL AMOUNT: S 5,000.
MATURITY DATE:
IN E-REST RATE:
02/02/01
5.75%
INTEREST 02/02196
INTEREST 02102/97
INTEREST 02/02/95
INTEREST 02/02/99
BALANCE:
$ 437.50
475.75
517.41
562.65
56,993.37
TOTAL AMOUNT: S 14,476.28
EXHIBIT D
Marian Inspirations, 111C.
Union Deposit Road
Ilarrisburg, PA
March 20, 1999
Dear Mr. Fine:
This letter is to officially notify you of our desire to
withdraw the monies we have invested with Marian
Inspirations, ilic.
The initiation date of our first investment is Febl•Uary
2, 1995. This is in the amount of`` 350.00, with an
interest rate of S.75% per annum. The maturity date of this
investment is August 2, 1997.
Tllc second investment of $5,000-00 Nvas initiated on
February 2, 1995 with a matUl'ity date of August I, 1995.
This interest rate is also at the rate of 5.75% per annum.
We would like to withdraw this money plus all
interest accrued as soon as possible but no later than April
20, 1999.
Sineerel
James F. Clay, Sr. &
Mary Frances Clay
EXHIBIT E
Kayer and Brown
Attorneys At Law
A Professional Corporation
Liberty Left
4 E. Liberty Avenue
Carlisle, Pennsylvania 17013
U-mail: jP.ayerC'epix.net
Telephone: ;717) 2.13-7922 FAX: (717) 243-0946
July 9, 1999
Andrew V. Finc
Inspirations, Inc.
3576 Union Deposit Road
Harrisburg PA 17019
Deer Mr. Fine:
1 have been retained by Jtuncs and N4ary Prances Clay regarding two separate
tr arss+ctious they made with you, one elated January 24, 1994 the other detect February 2, 1995.
130th of these notes had maturity dates, which expired in 1997. Apparently, numerous telephone
conversations have occurred between you and Mr. Clay and Mr. Clay has also forwarded to you
it demand for payment, dated March 20, 1999, which was received by Stella Ann Fine on that
date.
I have advised Mr. and Mrs. Clay that the confession of judgement language within the
notes allows them to obtain a judgement against you, now that the notes have reached maturity
and have remained unpaid. Obviously, they would prefer not to have to rely upon obtaining a
judgement in order to be satisfied in this matter. However, the failure to repay this loan has
caused them to stiffer an undue financial burden. This situation cannot be allowed to continue.
Please contact me within two weeks of the date of this letter to advise me of your
specific intention to repay the sums owed to Mr. and Mrs. Clay. Should we not hear front you
prior to that date, I have been authorized to process these notes as confessed judgements by Mr.
and Mrs. Clay and will do so without further delay. As 1 am sure you are aware, the terms of the
notes would also require you to pay the cost of suite in addition to the principal and interest owed
uncr the note.
Mr. and Mrs. Clay have asked that ),on no longer contact them directly and that you deal
strictly through this office.
Vcry truly yours,
i •?
James J. Kayo
JJK/ j<g'
cc: Mr. and Mrs. Clay
,.,,,,a
VERIFICATION OF PLEADINGS
The foregoing document is leased upon information which has been gathered by my counsel
and myself in the preparation of this action. The language of the document may, in part, be the
language of my counsel and not my own. I have read the statements made in this document and to
the cxter.t that it is based upon information which I have given to my counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the contents of the
statements are that of counsel, I have relied upon counsel in staking this Verification. I understand
that false statements herein are made subject to the penalties of 1S PA. C.S. § 8904, relating to
unsworn falsification to authorities.
Date: /1c 6 1999
VERIFICATION OF PLEADINGS
The foregoing document is based upon information which has been gathered by my counsel
and myself in the preparation of this action. The language of the document may, in part, be the
language of my counsel and not my own. I have read the statements made in this document and to
the extent that it is based upon information which I have given to my counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the contents of the
statements are that of counsel, I have relied upon counsel in making this Verification. I understand
that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904, relating to
unsworn falsification to authorities.
Date: 1999
1