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Home My WebLink About07-6930v Blatt, Hasenmiller, Leibsker & Moore, LLC Ron Z. Opher, Esquire Attorney for Plaintiff Attorney #57507 P.O. Box C3800 Southeastern, PA 19398 (610) 902-0644 ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK: c/o Blatt, Hasenmiller, Leibsker & Moore LLC IN THE COURT OF COMMON PLEAS P.O. Box C CUMBERLAND COUNTY, PA Southeastern, , P PA 19398 JOHN T GETZ GETZ, LUCILLE L Plaintiff V. 19 E MAIN ST SHIREMANSTOWN PA 17011 Defendant CIVIL ACTION - LAW COMPLAINT - CIVIL ACTION NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 "ISO Le han demando a usted en la corte. Si usted quiere defenderse de estas demandadas expuestas en las paginas siguentes, usted dente veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hace fafta asentar una comparencia escrita on en persona o con un abogado y entregar a la corte enforma escritas sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se defende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas del las provisiones de esta demanda. Usted puede perdes dinero o us propriedadedsu otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSIGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 1943114 ., Blatt, Hasenmiller, Leibsker & Moore, LLC Ron Z. Opher, Esquire Attorney for Plaintiff P.O. Box C3800 Southeastern, PA 19398 (610) 902-0644 ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK: c/o Blatt, Hasenmiller, Leibsker & Moore LLC IN THE COURT OF COMMON PLEAS P.O. Box C3800 CUMBERLAND COUNTY, PA Southeastern, PA 19398 Plaintiff V. JOHN T GETZ NO. GETZ, LUCILLE L 19 E MAIN ST SHIREMANSTOWN PA 17011 Defendant COMPLAINT - CIVIL ACTION COUNT ONE 1. The Plaintiff herein is ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK. 2. The Defendant herein is JOHN T GETZ, an adult individual located at 19 E MAIN ST SHIREMANSTOWN PA 17011. 3. The Defendant at all times relevant hereunder, knowingly requested the funds at issue, and knowingly and voluntarily accepted the benefits bestowed and the terms and conditions linked thereto. 4. After applying all known charges and payments to said account, the balance is $12735.55. A true and correct copy of an affidavit of account is attached hereto and marked as an Exhibit. 5. Plaintiff has in all respects fulfilled all conditions precedent to its obligations on the contract and for bringing this Complaint for damages. 6. Despite repeated demand by Plaintiff, Defendant has refused and continues in failure and refusal to pay Plaintiff. 1943114 PPTCDEAI WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of $12735.55, and costs of this action. COUNT TWO Plaintiff also claims alternatively on the basis of quantum meruit or Quasi Contract. 7. Paragraphs 1 through 6 above are incorporated herein by reference as though fully set forth. 8. Plaintiff was neither a volunteer nor an officious intermeddler. 9. Plaintiff is the owner of said credit account. 10. Plaintiff expected payment from the Defendant for said credit in the amount set forth above. 11. The amount claimed is the fair and reasonable market value for said credit. WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of $12735.55, and costs of this action. Dated: September 25, 2007 BY Ron Z. Opher, Esquire Attorney for Plaintiff r STATE OF ILLINOIS COUNTY OF COOK AFFIDAVIT OF INDEBTEDNESS The undersigned, being duly sworn, deposes and states that he/she is an employee/agent of: ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK and has knowledge of the account balance, and is duly authorized to make this affidavit. Affiant states that the amounts shown below are taken/calculated from the original books and records of the above named plaintiff, and based on information and belief, affiant states that the amount due to ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK by JOHN T GETZ GETZ, LUCILLE L for funds advanced to defendants(s) or paid to another at defendant(s) request, or for goods or services provided to defendant(s) or to another at defendant's request, is the following: on the following account(s) as of 06-21-07: CREDITOR/ACCOUNT NUMBER CURRENT BALANCE ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK 6034620218032375 $12735.55 Affiant states that the amount shown above is true and correct to the best of his/her knowledge. Further affiant sayeth not. Subscribed and Sworn to a me ?L± day of 0 V tz? 'n NPtary Pu "OFFICIAL SEAL"? My Commissl , P pi R DeLeon '?- as ois Commission Expires 1/3,2011 c Affiant Title Date of Service: 0 Reference #: 1943114 Forwarder ID#: Account #: 6034620218032375 BAFFAREG(11/02 )CF1 ARROW FINANCIAL SERVICES LLC VERIFICATION 1Ron Z. Opher, Attorney for Plaintiff, her 1 • I am the ebY state: Plaintiff is out of the attorney for the plaintiff in this action jurisdiction of the Commonwealth; I sign this Verification statin 2• °nwealth; I verif Y that the statements made 9 that of my knowledge, information and belief and fore nd foregoing Complaint are true and correct to the 3. 1 understand that the best Pa•C•S• Sec. statements in said complaint 4904 relating to ementn faaidati autre made subject to the penalties of 18 horities. DATED: l 21 6'7 By: Ron Z. Opher Attorney for Plaintiff PPTXVERI 70 d ? a {" G' C .5 rn W O SHERIFF'S RETURN - REGULAR CA&C NO: 2007-06930 P tCOMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS GETZ JOHN T ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GETZ JOHN T the DEFENDANT , at 1852:00 HOURS, on the 4th day of December-, 2007 at 21 E MAIN STREET SHIREMANSTOWN, PA 17011 by handing to JOHN GETZ a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge `u1 ?X Sworn and Subscibed to before me this of 18.00 12.48 .00 10.00 .00 40.48 day So Answers: R. Thomas Kline 12/05/2007 BLATT HA"T-NMIT T E T ETBSKE By: A. D. SHERIFF'S RETURN - REGULAR CASE; NO: 2007-06930 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ARROW FINANCIAL SERVICES LLC VS GETZ JOHN T ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GETZ LUCILLE L the DEFENDANT at 1852:00 HOURS, on the 4th day of December , 2007 at 21 E MAIN STREET SHIREMANSTOWN, PA 17011 JOHN GETZ, HUSBAND a true and attested copy of COMPLAINT & NOTICE by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharges f) So Answers: 6.00 .00 . 00 41 10.00 R. Thomas Kline .00 16.00 12/05/2007 BLATT HASENMILLER LEIBSKER Sworn and Subscibed to By: before me this day of A.D. w Blatt, Hasenmiller, Leibsker & Moore, LLC David C. Jenkins Attorney I.D. #85769 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 ext. 4151 Attorney for Plaintiff, Arrow Financial Services, LLC ARROW FINANCIAL SERVICES, LLC, Plaintiff, VS. JOHN T. GETZ and LUCILLE L. GETZ, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 07-6930 Defendants. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT JOHN T. GETZ in this matter in the amount of $12,735.55. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on December 28, 2007 by regular mail. A true and correct copy of each Notice is attached hereto along with the certificates of mailing. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: September 21, 2008 By: C?? David C. Je ins 4 v ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK: c/o Blatt, Hasenmiller, Leibsker & Moore LLC P.O. Box C3800 IN THE COURT OF COMMON PLEAS Southeastern, PA 19398 CUMBERLAND COUNTY, PA Plaintiff V. JOHN T GETZ CIVIL ACTION - LAW GETZ, LUCILLE L NO. 07 19 E MAIN ST SHIREMANSTOWN PA 17011 Defendant TO: JOHN T GET 19 E MAIN ST SHIREMANSTOWN PA 17011 DATED: December 28, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BY ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Gregory R. Dye Esquire Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff P.O. Box C3800 Southeastern, PA 19398 (610) 902-0644 1943114 PPTNLRSI U.S. POSTAL SERVICE CERTIFICATE OF MAILIP MAY BE ... _ FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDL. Rec:., Blatt, Hasenmiller, Leibsker & MOOre LLC P.O. Box C3800 Southeastern, PA 19398 One pies o rdinary mail addressed to: h 1/0 LOW PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING A.. wo0o cnoViA C31 -4 oto MAY BE USED - PROVIDE FOR Blatt Hasenmiller, leibsker& Received F Moore LLC P.O. Box C3800 N UN % 0IN Southeastern, PA 19398 4"n n One piece of ordin mail addressed to: uc?PIle- IQ, E_ M CO CO N O 0 La 0 craV1? Q M PS Form 3817, January 2001 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, David C. Jenkins Arrow Financial Services, LLC Attorney I.D. #85769 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 ext. 4151 ARROW FINANCIAL SERVICES, LLC, Plaintiff, vs. JOHN T. GETZ and LUCILLE L. GETZ, Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 07-6930 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CHESTER: I, David C. Jenkins, being duly sworn according to law, depose and say that I am the attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant JOHN T. GETZ is at least 18 years of age and not in the Military Service of the United States nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and any amendments thereto. I also hereby certify that the statements made in the foregoing Affidavit of Non-Military Service 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.A. § 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: September 21, 2008 By: ??? ?1_ David C. Jenkins Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, David C. Jenkins Arrow Financial Services, LLC Attorney I.D. #85769 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 ext. 4151 ARROW FINANCIAL SERVICES, LLC, Plaintiff, vs. JOHN T. GETZ and LUCILLE L. GETZ, Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 07-6930 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CHESTER: I, David C. Jenkins, being duly sworn according to law, depose and say that I am the BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: September 21, 2008 By: NkrNll? ____ David C. Je ns attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant LUCILLE L. GETZ is at least 18 years of age and not in the Military Service of the United States nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and any amendments thereto. I also hereby certify that the statements made in the foregoing Affidavit of Non-Military Service 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.A. § 4904 relating to unsworn falsification to authorities. f? b- ? s rr) ARROW FINANCIAL SERVICES, LLC, Plaintiff, VS. JOHN T. GETZ and LUCILLE L. GETZ, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 07-6930 Defendants. TO: JOHN T. GETZ NOTICE PURSUANT TO Pa.RC.P. 236 NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. Curtis R Long, Prothonotary Date: 7 By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC David C. Jenkins Attorney I.D. #85769 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 ext. 4151 Blatt, Hasenmiller, Leibsker & Moore, LLC David C. Jenkins Attorney I.D. #85769 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 ext. 4151 Attorney for Plaintiff, Arrow Financial Services, LLC ARROW FINANCIAL SERVICES, LLC, Plaintiff, VS. JOHN T. GETZ and LUCILLE L. GETZ, Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 07-6930 PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT LUCILLE L. GETZ in this matter in the amount of $12,735.55. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on December 28, 2007 by regular mail. A true and correct copy of each Notice is attached hereto along with the certificates of mailing. Respectfully submitted, Dated: September 21, 2008 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC -V r By: David C. Jenkin ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK: c o Blatt, Hasenmiller, Leibsker & Moore LLC P.O. Box C3800 IN THE COURT OF COMMON PLEAS Southeastern, PA 19398 CUMBERLAND COUNTY, PA Plaintiff V. JOHN T GETZ CIVIL ACTION - LAW GETZ, LUCILLE L NO. 07-6930 19 E MAIN ST SHIREMANSTOWN PA 17011 Defendant TO: =-mpqwGETZ, LUCILLE L 19 E MAIN ST SHIREMANSTOWN PA 17011 DATED: December 28, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BY ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Gregory R. ye Esquire Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff P.O. Box C3800 Southeastern, PA 19398 (610) 902-0644 1943114 PPTNLRSI U.S. POSTAL SERVICE CERTIFICATE OF MAILIP MAY 8E FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDL. Rec:., Blatt, Hasenmiller, Leibsker & Moore LLC P.O. Box C3800 Southeastern, PA 19398 One pie o rdinary mail addressed to: PS Form 3817, January 2001 $ O O D O As 7 . O A7" s M Q, .?. Wo???N ?ot71A cn v O a ' U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED PROVIDE FOR,v Received P Blatt, Hasenmiller, Leibsker & Moore LLC :N UN P.O. Box C3800 Southeastern, PA 19398 ? ° Ona piece of ordin mail addressed to: 9 f A 7 C? /?'!0 ,rT O N 000 ei m o, -.i t0 N 0 I cTOal e?l rn ? Q ? PS Form 3817, January 2001 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, David C. Jenkins ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BAN Attorney I.D. #85769 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE c/o Blatt, Hasenmiller, Leibsker & Moore, LLC P.O. Box C3800 Southeastern, PA 19398 Plaintiff, vs. JOHN T GETZ GETZ, LUCILLE L 19 E MAIN ST SHIREMANSTOWN PA 17011 Defendant(s). =Y BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 07-6930 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF ARROW FINANCIAL SERVICES, LLC AS ASSIGNEE OF GE MONEY BANK. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC P.O. Box C3800 Southeastern, PA 19398 Telephone Number: 1-800-850-1079 ext. 4151 Dated: September 21, 2008 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC By: Da id . Jenki s 1943114 PPTXPEAI t`) rv Q O ? ?. w ?"t t'+ i r" Q? Sti .. ?? 4 ,, ? ..) "`f . . ..a.-? ?;:?- ?J '?' ?V ..> . • ARROW FINANCIAL SERVICES, LLC, Plaintiff, VS. JOHN T. GETZ and LUCILLE L. GETZ, Defendants. TO: LUCILLE L. GETZ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 07-6930 NOTICE PURSUANT TO Pa.R.C.P. 236 NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. rtis R. g, Prothonotary Date: _ a *03 _ By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC David C. Jenkins Attorney I.D. #85769 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 ext. 4151