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HomeMy WebLinkAbout99-07554 .i i ?. oe, Civil Term No. 9f- 1 ? d VS. j .. 41 a + Court of Common Pleas ! Cunmb. Co. i PNC BANK, NATIONAL ASSOCIATION, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. (y 75.5t/ 77 t. GEORGE W. CUBBLER AND CAROLE CIVIL ACTION -LAW A. CUBBLER, Defendants CONFESSION OF JUDGMENT 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: Principal: Interest to December 14, 1999: Attorney's Commission: TOTAL $ 64,000.00 $ 10,759.99 $ 7.475.99 $ 82,235.98 Respectfully submitted, Date: Other authorized items: SAIDIS, SHUFF & MASLAND I Z I I'? 1 By: it ? J Karl M. Ledebo m, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Defendants 'w PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. GEORGE W. CUBBLER AND CAROLE : CIVIL ACTION -LAW A. CUBBLER, Defendants : CONFESSION OF JUDGMENT COMPLAINT FOR CONFESSION OF JUDGMENT UNDER RULE 2951 The name and address of the Plaintiff is PNC Bank, National Association, 4242 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The names and last known address of the Defendants are George W. Cubbler and Carole A. Cubbler, 280 Niel Road, Shippensburg, Cumberland County, Pennsylvania 17257-9415. 3. Defendants executed and delivered to Plaintiff a Promissory Note ("Note"), a true and correct photostatic reproduction of the original of which is attached hereto as Exhibit "A" and made a part hereof. 4. Defendants are in default of Defendants' obligations to make payment to Plaintiff as required in the Note, and Plaintiff has demanded payment in full of all outstanding amounts as provided in the Note. A copy of Plaintiffs demand is attached hereto as Exhibit "B" and made a part hereof. 5. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 6. There has not been any assignment of the Note. 7. Judgment has not been entered on the Note in any jurisdiction. 8. The amount due to Plaintiff as a result of Defendants' default is as follows: Principal $ 64,000.00 Interest to December 14, 1999 $ 10,759.99 Attorney's Commission $ 7.475.99 TOTAL $ 82,235.98 9. Interest continues to accrue at the default rate provided in the Note in the amount of Twenty Six and 661100 Dollars ($26.66) per day. WHEREFORE, Plaintiff demands judgment against Defendants, George W. Cubbler and Carole A. Cubbler, as authorized by the warrant of attorney contained in the Note for Eighty-Two Thousand Two Hundred Thirty-Five and 98/100 Dollars ($82,235.98), plus interest from and including the date of this Complaint and judgment entered hereon at the default rate provided in the Note, attorney's fees and costs of suit. Respectfully submitted, Date: lZ_11 LI/9/ SAIDIS, SHUFF & MASLAND By: I M. Ledebohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff PROMISSORY NOTE L S64 Principal 07-02 1997 L06-15-19981 Loan No ` Call j Collateral I ;Account Officer ani E 20113803369:, 00090 References in the shaded area are for Lender's use only and do not limit the aoolicabili of this document to any oarticular loan or Item Borrower: GEORGE W. CUBBLER (SSN: 198-26.8835) Lender: PNC BANK, NATIONAL ASSOCIATION CAROLE A. CUBBLER (SSN: 159-32-6848) 4242 CARLISLE PIKE 280 NEIL ROAD CAMP HILL, PA 17001-8874 SHIPPENSBURG, PA 17257 Principal Amount: $64,000.03 Initial Rate: 10.000% Date of Note: July 2, 1997 PROMISE TO PAY. GEORGE W. COBBLER and CAROLE A. CU13BLER ("Borrower") promise to pay to PNC BANK, NATIONAL ASSOCIATION ('tender"), or order, in lawful money of the United Slates of America, the principal amount of Sixty Four Thousand & 001100 Dollars ($64,000.00) or so much as may be outstanding, together with Interest on the unpaid outstanding principal balance of each advance. Interest shall be calculated from the date of each advance until repayment of each advance. PAYMENT. Borrower will pay this loan in accordance with the following payment schedule: Borrower will pay regular monthly payments of accrued Interest beginning August 15, 1997, and all subsequent Interest payments are due on the same day of each month after that. Borrower will pay this loan In one payment of all outstanding principal plus all accrued unpaid Interest on the Expiration Data. Borrower may borrow, repay and reborrow hereunder unlll the Expiration Date, subject to the terms and condlilons of this Note. The "Expiration Date" shall mean June 15, 1998, or such later date as may be designated by written notice from Lender to Borrower. Borrower acknowledges and agrees that In no event will Lender be under any obligation to extend or renew the loan or this Note beyond the Initial Expiration Date. In no event shall the aggregate unpaid principal amount of advances under this Note exceed the face amount of this Note. Interest on this Note is computed on a 365/360 simple interest basis; that is, by applying the ratio of the annual interest rate over a year of 360 days, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is outstanding. Borrower will pay Lender at lender's address shown above or at such other place as Lender may designate in writing. Unless otherwise agreed or required by applicable law, payments will be applied first to accrued unpaid Interest, then to principal, and any remaining amount to any unpaid collection costs and late charges. VARIABLE INTEREST RATE. The Interest rate on this Note is subject to change from time to time based on changes in an Index which is the Lender's prime rate (the "index'). The index is a rate per annum as publicly announced by Lender from time to time as Its prime rate. The prime rate is not tied to any external rate or Index and It does not necessarily reflect the lowest rate of interest actually charged by Lender to any particular class or category of customers. Lender will tell Borrower the current Index rate upon Borrower's request. Borrower understands that Lender may make loans based on other rates as well. The Interest rate change will not occur more often than each day. The Index currently Is a.5oo% per annum. The Interest rate to be applied to the unpaid principal balance of this Note will be at a rate of 1.500 percentage points over the Index, resulting In an Initial rate of 10.000% per annum. NOTICE: Under no circumstances will the interest rate on this Note be more than the maximum rate allowed by applicable law. PREPAYMENT. Borrower may pay without penalty all or a portion of the amount owed earlier than It is due. Early payments will not, unless agreed to by Lender in writing, relieve Borrower of Borrower's obligation to continue to make payments of accrued unpaid Interest. Rather, they will reduce the principal balance due. LATE CHARGE. It a payment is 15 days or more late, Borrower will be charged 5.000% of the unpaid portion of the regularly scheduled payment or $100,00, whichever Is less. DEFAULT. Borrower will be in default If any of the following happens: (a) Borrower fails to make any payment when due. (b) Bonower breaks any promise Borrower has made to Lender, or Borrower fails to comply with or to perform when due any other term, obligation, covenant, or condition contained in this Note or any agreement related to this Note, or in any other agreement or loan Borrower has with Lender. (c) Any represenlation•cr statement made or furnished to Lender by Borrower or on Borrower's behalf is false or misleading in any material respect either now or at the time made or furnished. (d) Borrower dies or becomes insolvent, a receiver is appointed for any part of Borrower's property, Borrower makes an assignment for the benefit of creditors, or any proceeding Is commenced either by Borrower or against Borrower under any bankruptcy or Insolvency laws. (e) Any creditor tries to lake any of Borrower's property on or In which Lender has a lien or security Interest. This Includes a garnishment of any of Borrower's accounts with Lender. (f) Any of the events described In this default section occurs with respect to any guarantor of this Note. (g) A material adverse change occurs in Borrowers financial condition, or Lender believes the prospect of payment or performance of the Indebtedness is impaired. LENDER'S RIGHTS. Upon default, Lender may, after giving such notices as required by applicable law, declare the entire unpaid principal balance an this Note and all accrued unpaid interest immediately due, and then Borrower will pay that amount. Upon default, including failure to pay upon final maturity, Lender, at its option, may also, if permitted under applicable law, increase the variable interest rate an this Note to 6.500 percentage points over the index. The interest rate will not exceed the maximum rate permitted by applicable law. Lender may hire or pay someone else to help collect this Note if Borrower does not pay. Borrower also will pay Lender that amount. This includes, subject to any limits under applicable law, Lenders attorneys' fees and Lender's legal expenses whether or not there is a lawsuit, including attorneys' lees and legal expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic slay or injunction), appeals, and any anticipated post-judgment collection services. If not prohibited by applicable law, Borrower also will pay any court costs, In addition to all other sums provided by law. If judgment is entered In connection with this Note, Interest will continue to accrue on this Note after judgment at the Interest rate applicable to this Note at the time judgment is entered. This Note has been delivered to Lender and accepted by Lender in the Commonwealth of Pennsylvania. If there Is a lawsuit, Borrower agrees upon Lender's request to submit to the jurisdiction of the courts of CUMBERLAND County, the Commonwealth of Pennsylvania. Lender and Borrower hereby waive the right to any jury trial In any action, proceeding, or counterclaim brought by elther Lender or Borrower against the other. This Note shall be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania. IGHT OF SETOFF. Borrower grants to Lender a contractual possessory security interest in, and hereby assigns, conveys, delivers, pledges, and ransfers to Lender all Borrowers right, title and interest in and to, Borrower's accounts with Lender (whether checking, savings, or some other ccount), Including without limitation all accounts held jointly with scmecra else and all accounts Borrower may open in the future, excluding however II IRA and Keogn accounts, and all trust accounts for which the grant of a security interest would be prohibited by taw. Borrower authorizes Lender, to he extent permitted by applicable law, to charge or setoff all sums owing on this Note against any and all such accounts. OLLATERAL. This Note is secured by a Mortgage dated July 2, 1997, to Lender on real property located in CUMBERLAND County, Commonwealth I Pennsylvania, all the terms and conditions of which are hereby incorporated and made a part of this Note. Exhibit "A" 1 ?? PROMISSORY NOTE Page 2 0 . 7-02-1997 Loan No o (Continued) Loan need not requiee r that l all oral tequests credit. he confirmed in under lAll ommunicatiions, instructions by Borrower or by an authorized ve. The advances under the ne Lender LINE 'F CREDIT. This Note evidences Lende direc are to shown ofhcredlit until Lender recei es fromtBorower atrLender's adda s bshown above written not ce of parties t of their authont . t GEORGE W. COBBLER authorized of an I accrdn with the agrees Lander. all Tsums either: he unpaid princpal be nce owingaon this Notel attany time may be evidenced by rson and CAROLit credited to CUBLER. igation Lender or (b) com or any guarantor Lender's iIs In default underctheltermslof this Note or ant- n agree ent thatlBohave no rrower or lany gue antorahas with Lender, nce thisNotef: endorsements e) Borrower Note or Including any agreement made in connection with the signing of this Note; (b) Borrower or any guarantor ceases doing business or is insolvent; (c) or revoke such antoes any guarantor Seeks, claims to lhilimit, moth r purposes olhe Ihanrthose authorime by Lhis Note or any other loan with Lender; or Note (d) Borrower has applied funds provided attempts to CLEANUP PROVISION. Borrower acknowledges and agrees that prior to the Expiration Date and annually thereafter if the Expiration Date Is extended, all amounts borrowed under the line of credit hereunder must be repaid in full so that there is no outstanding principal balance for a period of at least 30 consecutive days. and busin Borrow may request from Rtime to Otime,s Ouchas annual and interim financial statements (a)ll of wh cth srhall beep eparred to accordancenwith ge eerally atceepted accounting principles) and federal income tax returns. GENERAL PROVISIONS. Lender may delay or forgo enforcing any of its rights or remedies under this Note without losing them. Borrower and any and notice o other person who signs, guarantees or endorses this Note, to the extent allowed by law, waive presentment, demand who signs payment h is Note rwhe her as makerf dishonor. Upon any change In the terms of this Note, and unless otherwise expressly slated in writing, no party B s I guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lender may renew or extend (repeatedly and for any length of lime) this loan, or release any party or guarantor or collateral; or Impair, fall to realize upon or perfect Lender's security interest in the notce to by anyone e other without than the party with whomctheemoanyone. tl modification such made. The obligationshunder hi collateral; nloan without the consent of or necessary may modify this this Note are joint and several. If any portion of this Note is for any reason determined to be unenforceable. It will not affect the enforceability of any other provisions of this Note. APPEAR AT ANYTME FOR BORROWEROAFTER CONFESSION OF BORROWER HEREBY OR CLERK OF ANY COURTf IN THE COMMONWEALTH OFEP NNSYLVAN At,I ORI ELSEWHE E,, EMPOWERS AGAINST A DEFAULT UNDER THIS NOTE, AND WITH OR WITHOUT COMPLAINT FILED, AS F ANY TERM, CONFESS ENTER BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE. AL ACC UED INTEREST, LATE CHARG SRAND ANY AND ALL AMOU S EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL- SECURING THIS NOTE TOGETHER WITH INTEREST ON SUCH ' TOGETHER WH. COSTS OF SUIT, AND AN ATTORNEYS 13ALANCESAND ACCRUED INTEREST FOR COLLECTION. BUT IN ANY EVENT NOT COMMISSION LE S F THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS NOTE OR A COPY OF THIS NOTE VERIFIED BY SHALL BE SUFFICIENT WARRANT. THE AU`rHORrrY GRANTED IN NOTE TO CONFESS JUDGMENT AGAINST BORROWER HALL AFFIDAVITNOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORrrY, BUr SHALLHCONTI UE FROM TIME TO TIME AND MAY AND/OR ALL HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT, WAIVES ANY NOTICE R HEARING REQUIRED UNDER APPLICABLE LAW WITH RESPECT TO EXECUTION OF THE JUDGMENT, AND STATES THAT EITHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO BORROWER'S ATTENTION OR BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL. PRIOR TO SIGNING THIS NOTE, EACH BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE TERM OF THE NOTE AND ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF THHET OTEI.OW EACH BORROWER AGREES TO THE VARIABLE INTEREST RATE THIS NOTE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED. BORROWER: CAROLE A. COBBLER -? NOTICE TO COSIGNER You are being asked to you can afford to pay If you have to,his debt. that you i nano carefully accept bethis fore you do. It tlthe borrower doesn't pay the debt, you will have to. Be sure You may have to pay up to the full amount of the debt If the borrower does not pay. You may also have to pay late fees or collection costs. which Increase this amount. can u The lender can collect this debt from you without first trying to collect hborrower. waThel to if this debt Steven In a collect tion femethods et may against you that can be used against the borrower, such as suing you, garnishing Y 9e default, become a part of YOUR credit record. This notice Is not the contract that makes you liable for the debt. Willits Rale. Line of Cregn. LaSERPRO,Reg. U.S.Pat.&T.M.01r..Ver.a.g](c)lggl CFl PrgSarva:ee, Inc. allrlgntareesrvea.IPA-OgO CUBBLER.LN Cag.OVL. Law Offices SAIDIS, SHUFF & MASLAND John E. A PROFESSIONAL CORPORATION C. . Sai Saidis Robert 2109 Market Street • Post Office Box 737 Carlisle Office: Geoffrey S. Shuff Camp Hill, Pennsylvania 17001-0737 26 W. High Street Albert H. Nlasland Telephone: (717) 737-3405 • Facsimile: (717) 737-3407 Carlisle, PA 17013 Johnna J. Deily Richard P. Richard r t Email: sgsm@ezonline.com Telephone: (717) 243.6222 . E. eid, James Facsimile: (717) 243.6186 Scott D. Moore e o November 2, 1999 Karl M. Ledebohm Reply To Camp Hill Mark W. Allshouse VIA CERTIFIED AND REGULAR MAIL George W. Cubbler Carole A. Cubbler 280 Neil Road Shippensburg, PA 17257 RE: PNC Bank, National Association Line of Credit Obligor/Obligation No. 30923389-600705844 Promissory Note dated July 2, 1997 in the original Principal amount of $64,000.00 (the "Note") Dear George W. Cubbler: Dear Carole A. Cubbler: PNC Bank, National Association ("PNC") has referred the above-referenced account to our office for collection. The above account is currently past due and in default for, inter alia, failure to make payment of the amounts due to PNC under the Note in a timely manner and the Note having matured on August 15, 1998. As a result of such default, PNC hereby demands payment in full of all liabilities and obligations due to PNC under the Note, in the amount of $73,646.65 calculated as follows: 1. Principal -$ 64 000.00 2. Interest through November 2, 1999 9,646.65 3. Total due to PNC as of November 2, 1999 $ 73,646.65 4. Per diem: $17.33 Please send payment of $73,646.65 to me immediately. Checks must be made payable to Saidis, Shuff & Ivlasland and be in the form of a cashier's or certified check. Upon receipt of your payment, we will remit payment to PNC and advise PNC to close your account. If payment of the full outstanding balance of the debt is not received in our office within fifteen (15) days of this letter, the Bank has instructed this firm to Cernfied as a Civil Trial Advocate by the National Board of Trial Advocacy A Pennsylvania Supreme Court Accredited Agency Exhibit "B" proceed to exercise its rights and remedies against you to collect the debt with notice. If any such action is taken, your debt to out further as court costs and legal fees. the Bank could increase by such amounts . This letter shall be without prejudice to and shall not be deemed a waiver or Postponement of any rights or remedies available to PNC, including, without limitation, PNC's rights to accept partial Payments without waiving demand for payment in full of all obligations due under the above-referenced Note or reinstating Borrower's obligation. Neither this letter nor any subsequent discussion shall be deemed offers to extend the maturity of the loan or otherwise waive any defaults thereunder. In addition to the other rights and remedies available to PNC under the Note and at law or in equity, PNC hereby exercises its right under the Note to increase the applicable interest rate from the current rate of 9.75% to 16.25% per annum. The amounts due to PNC as set forth above will begin to accrue interest at the default rate as of the date of this letter. Thank you for your consideration in this matter. We look forward to receipt of payment in the immediate future. Very truly yours, SAID, SNUFF & MASLAND /Ka KML/cg M. Lede ohm cc: Andrew Rohmeyer LL? .S. POSTAL SERVI E ??^ - - +•?. -IC AND INM USED O o?y VBOE FOR IFOR D NCES POSTMASTEflNATIONAL MAIL. [TOES NOT Reeelved F,94idis, Shuff & Masland C uill PA 17011 ,:"-.. ._.. _. Ons piece of ordlnery mail addressed to: PS Form 3817, Mar- 1 Z 353 238 664 US Postal Service Receipt for Certified Mail No insurance coverage Provided. Certified Fee Spetlal Delivery Feo Res!dded Oefvary Fee N ? Relum Receipt Showir,l ww?,., x nau Oelivemf 0 I PNC BANK, NATIONAL ASSOCIATION Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. GEORGE W. CUBBLER AND CAROLE : CIVIL ACTION -LAW A. CUBBLER : CONFESSION OF JUDGMENT Defendants CERTIFICATE OF ADDRESSES I hereby certify that the precise address of Plaintiff, PNC Bank, National Association is 4242 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011; and that the last known address of the Defendants, George W. Cubbler and Carole A. Cubbler, is 280 Niel Road, Shippensburg, Cumberland County, Pennsylvania 17257-9415. Respectfully submitted, SAIDIS, SHUFF & MASLAND C ?- Date: By: Karl . Ledebohm, Esquire / 7 Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. GEORGE W. CUBBLER AND CAROLE CIVIL ACTION -LAW A. CUBIILER, ; Defendants CONFESSION OF JUDGMENT AFFIDAVIT OF NON-MILITARY SERVICE TO THE PROTHONOTARY: I do certify, to the best of my knowledge, that the Defendants, George W. Cubbler and Carole A. Cubbler, in the above-captioned action are not presently on active or nonactive military status. Respectfully submitted, SAIDIS, SHUFF & MASLAND 4jar1 M. Le bohm, Esquire Date: lZII 1 ! ! I By Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. GEORGE W. CUBBLER AND CAROLE A. CUBBLER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CONFESSION OF JUDGMENT VERIFI/C?ATION f1 r3 LLV-a-UQJer' V1Lz y'/l[Side.??? 1 Ammer, Assistant Goakier, for PNC Capital Recovery Corp., being authorized to do so on behalf of PNC Bank, National Association, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. PNC BANK, NATIONAL ASSOCIATION Date: t 2/ t 7 l `l By A L) 7i z( l Assistant C49M F if ?•e nESi? w?, PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. GEORGE W. CUBBLER AND CAROLE CIVIL ACTION - LAW A. CUBBLER, Defendants : CONFESSION OF JUDGMENT NOTICE TO: George W. Cubbler and Carole A. Cubbler Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY CONFESSION has been entered against you in the above proceeding and that enclosed herewith is a copy of all the documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: KARL M. LEDEBOHM, ESQUIRE TELEPHONE NUMBER: (717) 761-1881 Prothonotary PNC BANK, NATIONAL ASSOCIATION, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. GEORGE W. CUBBLER AND CAROLE CIVIL ACTION -LAW A. CUBBLER, Defendants : CONFESSION OF JUDGMENT ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of PNC Bank, National Association, Plaintiff in the above captioned matter. Respectfully submitted, SAIDIS, SHUFF & MASLAND C N? Date: "lTi/?Ul I ( By / K M. Ledebohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintlff i' i i ti ? A C7?= ? G- a a F 1- L. t:. <T 1 V ?