HomeMy WebLinkAbout02-0146
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PAUL H. BOSWELL, JR.,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 200a - I~CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendant
NOTICE
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 attorney and
filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that 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 A LAWYER AT ONCE.
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU
LEGAL HELP.
IF YOU DO
TELEPHONE
CAN GET
Cumberland Count Lawyer Referral Service
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
PAUL H. BOSWELL, JR.,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2 0 O~ - NCr CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendant
COMPLAINT
AND NOW, comes the Plaintiff, Paul H. Boswell, Jr., and makes
the following Complaint:
1. The Plaintiff is Paul H. Boswell, Jr., an adult individual
residing at 908 Franklin Street, Carlisle, PA 17013.
2. The Defendant Banc One Consumer Discount Company
(hereafter "Banc One") is a business corporation doing business in
Pennsylvania, with its principal place of business at 8604
Allisonville Road, Indianapolis, IN 46250-1008.
3. The Defendant Associates Home Equity Consumer Discount
Company, Inc. (hereafter "Associates") is a business corporation,
doing business in Pennsylvania, with its principal place of
business at 250 East Carpenter Freeway, Irving, TX 75062.
4. On May 23, 1996 Paul H. Boswell, Jr. and his wife,
Linda K. Boswell executed and delivered a mortgage on the property
at 908 Franklin Street, Carlisle, Pennsylvania, to Banc One, as a
requirement for obtaining a Fifty Thousand Three Hundred Sixty-nine
and 59/100 ($50,369.59) Dollars loan, said mortgage being recorded
9. Plaintiff, by and through his undersigned attorney, by
letters dated November 6, 2001, requested both Defendants to
forward the Satisfaction piece to Plaintiff's Attorney or the
Recorder of Deeds within forty-five (45) days. Attached hereto,
made a part hereof and marked Exhibit "B" is a true and correct
copy of the Plaintiff's attorney's letter of November 6, 2001,
which meets the notification requirements of the Act of July 31,
1968 P.L. 866 No. 256, 21 P.S. 682.
10. Banc One and Associates both accepted service of their
certified mail letter on November 9, 2001. A true and correct copy
of the green return receipt card for each Defendant is attached
hereto, made a part hereof and marked Exhibit "C".
11. Nei ther Defendant has responded to the Plaintiff's
undersigned attorney in response to the letter of November 6, 2001.
12. As of the date of filing this Complaint the Defendants
have failed to forward a Satisfaction Piece necessary to satisfy
the mortgage of record to Plaintiff's undersigned attorney or to
the Recorder of Deeds in and for Cumberland County.
COUNT I
PAUL H. BOSWELL, JR. VS.
BANC ONE CONSUMER DISCOUNT COMPANY AND
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC.
13. The averments contained in Paragraphs 1 through 12 are
incorporated herein by reference.
14. Forty-five (45) days have elapsed since the date when
Paul H. Boswell, Jr. paid the mortgage in full.
-3-
15. More than forty-five (45) days have elapsed since the
date when Plaintiff gave Defendants written Notice and requested
Defendants to forward the Satisfaction Piece regarding said
mortgage.
WHEREFORE, Plaintiff, Paul H. Boswell, Jr., requests Your
Honorable Court to:
a. Order and Direct the Defendants, Banc One and
Associates, to satisfy said mortgage on the records of the
Cumberland County Recorder of Deeds; and
b. Grant such other and further relief as may be just
and proper.
COUNT II
PAUL H. BOSWELL, JR. VS.
BANC ONE CONSUMER DISCOUNT COMPANY, AND
ASSOCIATES HOME EQUITY DISCOUNT COMPANY, INC.
16. The averments contained in Paragraphs 1 through 15 above
are incorporated herein by reference thereto.
17. As a result of the Defendants' failure to satisfy the
said mortgage of record, Plaintiff has incurred damages and has
been precluded from obtaining a first mortgage and borrowing money
on the security of his property.
18. Pursuant to the Act of July 31, 1968, P.L. 866 No. 257,
Section 1, 21 P.S. 682, Plaintiff is entitled to statutory
liquidated damages in an amount not to exceed the original
principal sum of the mortgage.
-4-
in the Office of the Recorder of Deeds in and for Cumberland
County, Pennsylvania, in Mortgage Book 1322, Page 34.
5. On November 1, 1996, Mr. and Mrs. Boswell refinanced this
obligation and the loan was paid in full by Members 1st Check in
the amount of Fifty-one Thousand Eighty-six and 85/100 ($51,086.85)
Dollars, which payment included sufficient funds to satisfy the
aforesaid mortgage. Members 1st mailed the check, payable to Ford
Consumer Finance in accordance with instructions received from Banc
One. The funds were received by Banc One's Agent and the mortgage
paid in full. A true and correct coy of the Members 1st cancelled
check in the amount of Fifty-one Thousand Eighty-six and 85/100
($51,086.85) Dollars is attached hereto, made a part hereof and
marked Exhibit "A".
6. Linda K. Boswell died on December 24, 1997 vesting title
to the real estate in the Plaintiff, as surviving tenant by the
entirety. Paul H. Boswell, Jr. paid in full the balance of the
mortgage with Members 1st, which was then satisfied of record.
7. The Banc One mortgage, although paid in full, was
nevertheless assigned by Banc One to Associates on June 13, 2000.
This Assignment is recorded in Cumberland County Miscellaneous Book
647, Page 615.
8. Subsequently on or about August 2001, Plaintiff sought to
obtain a new first mortgage through Members 1st. He was then
advised by Members 1st Federal Credit Union that the mortgage to
Banc One had not been satisfied.
-2-
. ,
9. Plaintiff, by and through his undersigned attorney, by
letters dated November 6, 2001, requested both Defendants to
forward the Satisfaction Piece regarding the mortgage within forty-
five (45) days.
Attached hereto, made a part hereof and marked
Exhibit "B" is a true and correct copy of the Plaintiff's
attorney's letter of November 6, 2001, which meets the notification
requests of the Act of July 31, 1985, PoL. 866 No. 256, 21 P.S.
682.
10. Banc One and Associates both accepted service of their
certified mail letter on November 9, 2001. A true and correct copy
of the green return receipt card for each defendant is attached
hereto, made a part hereof and marked Exhibit "C".
11. Neither Defendant has responded to the Plaintiff's
undersigned attorney in response to the letter of November 6, 2001.
12. As of the date of filing this Complaint the Defendants
have failed to forward a Satisfaction Piece necessary to satisfy
the mortgage of record to Plaintiff's undersigned attorney or to
the Recorder of Deeds in and for Cumberland County.
COUNT I
PAUL H. BOSWELL, JR. VS.
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC.
13. The averments contained in Paragraphs 1 through 12 are
incorporated herein by reference.
14. Forty-five (45) days have elapsed since the date when
Paul H. Boswell, Jr. paid the mortgage in full.
-3-
15. More than forty (40) days have elapsed since the date
when Plaintiff gave Defendants written Notice and requested
Defendants to forward the Satisfaction Piece regarding said
mortgage.
WHEREFORE, Plaintiff, Paul H. Boswell, Jr., requests Your
Honorable Court to:
a. Order and Direct the Defendants, Banc One and
Associates, to satisfy said mortgage on the records of the
Cumberland County Recorder of Deeds; and
b. Grant such other and further relief as may be just
and proper.
COUNT II
PAUL H. BOSWELL, JR. VS.
BANC ONE CONSUMER DISCOUNT COMPANY, AND
ASSOCIATES HOME EQUITY DISCOUNT COMPANY, INC.
16. The averments contained in Paragraphs 1 through 15 above
are incorporated herein by reference thereto.
17. As a result of the Defendants' failure to satisfy the
said mortgage of record, Plaintiff has incurred damages and has
been precluded from obtaining a first mortgage and borrowing money
on the security of his property.
18. Pursuant to the Act of July 31, 1968, P.L. 866 No. 257,
Section 1, 21 P.S. 682, Plaintiff is entitled to statutory
liquidated damages in an amount not to exceed the original
principal sum of the mortgage.
-4-
WHEREFORE, Plaintiff, Paul H. Boswell, Jr. requests Your
Honorable Court to enter judgment in favor of Plaintiff and against
the Defendants, jointly and severally, in the amount of Fifty
Thousand Three Hundred Sixty-eight and 59/100 ($50,368.59) Dollars,
plus interest and cost of suit.
By:
Suite 203
VERIFICATION
Paul H. Boswell, Jr. hereby verifies that the facts set forth
in the foregoing Complaint are true and correct to the best of his
knowledge, information and belief, and understands that false
statements herein are made subject to the penalties of 18 Pa. CoSo
~4904 relating to unsworn falsifications.
~/JaI ~vJrfJlUJ/(A /
DATE:
January /~, 2002
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DALE F. SHUGHART, JR.
ATTORNEY AT LAW
35 EAST HIGH STREET
SUITE 203
CARLISLE, PENNSYLVANIA 17013
Telephone (7171 241 -43 11
Facsimile (7171 241-4021
OF COUNSEL
HAMILTON C. DAVIS
LEGAL ASSISTANT
BONNIE L. COYLE
November 6, 2001
Certified Mail #7099 3400 0018 5046 7340
Banc One Consumer
8604 Allisonville
Indianapolis, IN
Discount Company
Road
46250-1008
Certified Mail #7099 3400 0018 5046 7333
Associates Home Equity Consumer
Discount Company, Inc.
250 East Carpenter Freeway
Irving, TX 75062
RE: Mortgage of Linda K. Boswell and Paul H. Boswell, Jr.
her husband
Date of Mortgage: 5/24/96
Property address: 908 Franklin Street, Carlisle, PA
17013
Recording Data: cumberland County Mortgage Book 1322,
Page 3"4.
Gentlemen:
I am the attorney for Paul H. Boswell, Jr., Widower of Linda K.
Boswell who died on December 24, 1997. I have agreed to
represent Mr. Boswell in regard to the failure of Banc One
Consumer Discount Company and/or Associates Home Equity Consumer
Discount Company, Inc. to satisfy a mortgage of record. The
facts are as follows:
1. Mr. and Mrs. Boswell entered a mortgage with Banc One on
May 23, 1996 for the sum of $50,369.59. A copy of this mortgage
is enclosed.
2. On November 1, 1996, Mr. and Mrs. Boswell refinanced
this obligation and the loan was paid in full my Members 1st
check in the amount of $51,086.85 payable to Ford Consumer
Finance Company as directed. Copies of the HUD-l Settlement
Statement and cancelled check evidencing the payment in full of
~x-NI 0 r1
8 f/ I
DALE F. SHUGHART, JR.
November 6, 2001
Page 2
this obligation are enclosed.
3. Linda K. Boswell died on December 24, 1997.
4. The mortgage was assigned by Banc One Consumer Discount
Company to Associates Home Equity Consumer Discount Company on
June 13, 2000. This Assignment is recorded in Cumberland County
Mortgage Book 647, Page 615. A copy is enclosed.
Mr. Boswell has applied for a mortgage through Members 1st. His
mortgage application has not been approved because the above
captioned mortgage has not been satisfied of record. Mr. Boswell
is unable to secure first mortgage financing on his property
because the above captioned mortgage is not satisfied.
Therefore, pursuant to the Act of July 31, 1968, P.L. 866,
No. 259, Section I, as amended, 21 P.S. 681, 682, I am hereby
directing you to forward papers necessary to satisfy this
mortgage of record to the Recorder of Deeds or to me immediately.
If satisfaction papers are not received within forty-five (45)
days of your receipt of this Notice, legal proceedings will be
instituted as provided for in the aforementioned Statute.
Very truly yours,
Dale F. Shughart, Jr.
DFS,JR/bc
Enclosures
cc Paul H. Boswell, Jr.
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I also wish to receive the
following selVices (for an
extra fee):
1 . D Addressee's Address
2. D Restricted Delivery
Consult postmaster for fee.
4a. Article Number
70993400001850467340
SENDER:
. Complete items 1 and/or 2 lor addItional servIces.
. Complete Items 3, 48. and 4b.
. Print your name and address on the reverse of this form so that we can return this
card to you.
. Anach this form to the fronl of the mallplece. or on the back if space dOes nol
permit.
. Write "Return Receipt Requested- on the mailpiece below the anicle number.
. The Return ReceIpt Win show to w~om the anicle was delivered and the jate
delivered.
3. Article AddreSsed to:
Bane One Consumer Dis Co
8604 Allisonville Road
Indianapolis, IN 46250-1008
4b. SelVlce Type
D Registered
D Express Mail
~elurn <lecelpt lor Merchandise
7 Date of Delivery
- )-c I
8. Addressee's Address (Only if requested
and fee IS paid)
XQlI Ce rtified
D Insured
DCOD
,02595.ge.8.0229 Domestic Return Receipt
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U.S. Postal Service
CERTIFIED MAIL RECEIPT
(Domestic Mall Only; No Insurance Coverage Provided)
U.S. Postal Service .
CERTIFIED MAIL RECEIPT .
(DomestiC Mall Only; No Insurance Coverage ProVided)
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PS f-orm 3800 h'bruary 2000 .
IN
(Boswell )
I also wiSh to receive the
following selVices (for an
extra fee)'
1 . D Addressee's Address
2. D Restricted Delivery
Consult postmaster for fee.
4a. Article Number
70993~00001850467333
4b. SelVice Type
D Registered
D Express Mall
rn Return Receipt for Merchandise
7. Date of Deli~ery
II -y-fl\
8. Addressee's Address (Only if requested
and fee is paid)
". SENDER:
~ . Complete items 1 and/or 2 for additional serli~.~.
'Cij . Complete Items 3. 4a. and 4b. "'-.,
G) . Print your name and address on the reverse Of thiS form so that we can retum this
~ card to you
~ . Attach this form to the front of the mailplece Jr on the back if space does nol
! permit.
Q) . Write -Return Receipt Requested" on tne ms;ipiece below the article number.
J:_ . The Return Receipt will show to whom the article was delivered and the date
delivered.
a 3. Article Addressed to:
~Assoeiates Home Equity
tConsumer Dis Co., Inc.
g250 East Carpenter Freeway
"Irving, TX 7:5062
~ Certified
D Insured
D COD
5. Received By: (Print Name)
6. Signature: (Addressee or ~ent)
g X ""'bE1:i~ECt.
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J!! PS Form 3811, Decembe~-~
102595-98.8-0229 Domestic Return Receipt
IV: <f:;+O
I
46250-1008
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SHERIFF'S RETURN - U.S. CERTIFIED MAIL
CASE NO: 2002-00146 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BOSWELL PAUL H JR
VS.
BANC ONE CONSUMER DISCOUN ETAL
R. Thomas Kline
, Sheriff
of Cumberland
County, Pennsylvania, who being duly sworn according to law served the
within named DEFENDANT
,BANC ONE CONSUMER DISCOUNT
COMPANY
by United States Certified Mail postage
prepaid, on the 14th day of January ,2002 at 0000:00 HOURS, at
EXACT ADDRESS UNKNOWN
SEE COPY FROM POST OFFICE
FISHERS, IN 46038-1008
, a true
and attested copy of the attached COMPLAINT & NOTICE
Together
with
The returned
receipt card was signed by J.M.FARRELL
01/22/2002
on
Additional Comments:
Sheriff's Costs:
Docketing
Cert Mail
Affidavit
Surcharge
18.00
4.40
.00
10.00
.00
32.40
~o answ _ s /// ... .
--:;:;:::-- -~~ ---
..~. 'Th~~
Sheriff of Cumberland County
Paid by DALE F SHUGHART JR
on 02/22/2002 .
Sworn and subscribed to before me
this l~ day of ~
JOV:;L. A. D.
q~t~th~O{:;~'A_' ~'
SHERIFF'S RETURN - U.S. CERTIFIED MAIL
CASE NO: 2002-00146 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BOSWELL PAUL H JR
VS.
BANC ONE CONSUMER DISCOUN ETAL
R. Thomas Kline
, Sheriff
of Cumberland
County, Pennsylvania, who being duly sworn according to law served the
within named DEFENDANT
,ASSOCIATES HOME EQUITY
CONSUMER DISCOUNT COMPANY INC by United States Certified Mail postage
prepaid, on the 14th day of January ,2002 at 0000:00 HOURS, at
250 EAST CARPENTER FREEWAY
IRVING, TX 75062
, a true
and attested copy of the attached COMPLAINT & NOTICE
Together
with
The returned
receipt card was signed by SIGNATURE ILLEGIBLE
01/17/2002
on
Additional Comments:
Docketing
Cert Mail
Affidavit
Surcharge
6.00
4.40
.00
10.00
.00
20.40
Sheriff's Costs:
So
R. Thomas Kline
Sheriff of Cumberland County
Paid by DALE F SHUGHART JR
on 02/22/2002 .
Sworn and subscribed to before me
this i.A-1- day of ~
J...oo,L, A . D .
Q~.u () ~_J.h / J~
rothonotary ,
. Complete items 1. 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece.
or on the front if space permits.
,. Article Addressed to:
Associates Home EqUity Consumer
Discount canpany Inc.
250 East Carpenter Freeway
Irving. TX 75062
C. Signature
x
D. Is delivery address diff""",t fro
If YES. enter deiivery address
3. Service Type
~ertified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
02-146 civ
2. Article Number
(Transfer from service label) 7000 1670 0001 8790 3605
PS Form 3811 , March 2001 Domestic Return Receipt
102595-01-11-1424
UN"", S'^"l' ""''l'I """,,",' I'" II'" II' 111~11" tHl'" 11/'" I
::;:;';'34':.<8
First-Class ~lI.i'
Postage & Fees Paid
USPS
Permit No. G-10
· Sender: Please print your name, address, and ZIP+4 in this box.
. C' W7. V C! 'r:"'FF'S DEPARTMENT
CUMBERLAND C ',L," . ";.'"
up.....l,!nl tr:,.
ONE CO' ,'.[ "'''>',
CARLISLE PA I (0 I 3
/., .1//."11/",/1.1/,.1/././,, ,/,,1/, /" /"1,1/..,,.. 11/,/11/
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery Is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attacll" this card to the baCK Of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
c. Signature
x
0" Is delivery address different from item 1?
If YES, enter delivery address beloW:
D Agent
D Addressee
DYes
D No
Bane One Constnner Diseoun t
ccmpany
8604 Allisonville Road
Indianapolis, IN 46250-1008
3. Service Type
Certified Mail
D Registered
D Insured Mail
D Express Mail
D Return Receipt for Merchendlse
DC.O.D.
4. Restricted Delivery? (Extra Fee)
DYes
02-146 civ: ....
102i~1-M.14241
~...._-.....,----_...-
UNITED STATI;S POSTAL SERVICE
III/II
-._----~-~.
First-Clas~ail
Postage,,& Fees Paid
USPS ,
Per 0.-
· Sender: Please print your name, address, and ZIP+4 i
CUMBERLAND ce' ,.
ONE COU;-;,r": ::"
CARLISLE PA .7Gi3
('It
DEPARTMENT
-
"UIll,III1I,,"I1,,", "lI"i1/," ,"",1/ " rill
FEB-14-e2 e5:51 PM ~RRLI5LE.P05T.OFFI~E 717 245 59ge
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Item: 7000 1870 0001 87903Ggv
D..tlnatlon ZIP Code:
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State: IN
State:
Event
DELIVERED
Date TIme Location
D1/2212002 11:80 FISHERS IN 48031
Firm Name: BANK ONE
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0112212002 01:14 FISHERS IN 415038
0111812002 07:41 INDIANAPOLIS IN
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P.~2
Page 1 ofl
2/14/2002
PAUL H. BOSWELL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
MOTION TO SCHEDULE A HEARING
FOR ENTRY OF AN APPROPRIATE FINAL DECREE
BY THE COURT
AND NOW, comes the plaintiff, Paul H. Boswell, Jr., by his
attorney, Dale F. Shughart, Jr., Esquire and respectfully
represents as follows:
1. On November 1, 1996, Plaintiff and his wife, (who is now
deceased) paid in full an obligation to Banc One, which was secured
by a Mortgage filed of record in the Office of the Recorder of
Deeds in and for Cumberland County, Pennsylvania.
2. Banc One failed to satisfy the Mortgage and in fact on
July 13, 2000, assigned the mortgage to Defendant, Associates.
3. By certified mail letters dated November 6, 2001, the
undersigned demanded that the mortgage be satisfied and provided a
Statutory Notice pursuant to 21 P.S. 681 et seq.
4. Neither Defendant responded to the 45 day Notice.
5. On January 11, 2002, Plaintiff filed a Complaint in
Equity, requesting that the mortgage be satisfied and that the
Court fix damages pursuant to 21 P.S. 682.
6. The Complaint was served upon Defendant Banc One on
January 22, 2002 by the Cumberland County Sheriff.
7. The Complaint was served upon Defendant Associates on
January 22, 2002 by the Cumberland County Sheriff.
8. More than 20 days passed and neither Defendant entered an
appearance or filed a pleading in the case.
9. On February 18, 2002, the undersigned mailed each
Defendant a Notice of Intention to Enter Judgment by Default.
Neither Defendant responded to the Notice.
10. On March 11, 2002, the Prothonotary entered judgment
against both Defendants by default upon Praecipe of the Plaintiff.
11. The Plaintiff reasonably requires entry of an appropriate
final Decree by the Court to:
a. Direct Defendants or the Recorder of Deeds to satisfy
the mortgage;
b. Award appropriate damages under 21 P.S. 682.
WHEREFORE, pursuant to PA.R.C.P. 1511(b), Plaintiff prays Your
Honorable Court to schedule a hearing on the matter.
f
Dale F. Shughart,
Attorney I.D. #193
35 East High Street, Sui e 203
Carlisle, PA 17013
(717) 241-4311
Attorney for Plaintiff,
Paul H. Boswell, Jr.
-2-
PAUL H. BOSWELL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
CERTIFICATE OF SERVICE
AND NOW, this 11th day of March, 2002" I, Dale F. Shughart,
Jr., Esquire, attorney for Paul H. Boswell, Jr., Plaintiff, hereby
certify that I have served a copy of the Motion to Schedule a
Hearing for Entry of an Appropriate Final Decree by the Court, and
proposed Order of Court, by mailing a copy of the same by United
States mail, postage prepaid, addressed as follows:
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC.
250 East Carpenter Freeway, Irving, TX 75062.
BANC ONE CONSUMER DISCOUNT COMPANY
8604 Allisonville Road, Indianapolis, IN 46250-1008.
Dale F. Shughart, Jr.
Attorney I.D. #19373
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
Attorney for Plaintiff,
Paul H. Boswell, Jr.
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MAR 1 3 200ry
.
PAUL H. BOSWELL, JR.,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
ORDER OF COURT
AND NOW, this I "3Jd,. day of ~
, 2002, upon
Motion of the plaintiff, Paul H. Boswell, Jr., by his attorney,
Dale F. Shughart, Jr., Esquire, it appearing that Judgment by
Default has been entered against both Defendants and that the
Court is required to enter an appropriate Final Decree, which
may require testimony to assist the Court in framing its Decree,
a hearing in the above captioned matter is scheduled to be held at
7>, '-\ 5
0' clock CL .m.,
on
j~
, the
JGCA
~,
day of
~
2002, in
Courtroom No.
Cumberland County, Carlisle, Pennsylvania.
CC:
t6ale F. Shughart, Jr., Esquire
/Banc One Consumer Discount Company
/~ssociates Home Equity Consumer Discount Company, Inc.
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PAUL H. BOSWELL, JR.,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
MOTION TO SCHEDULE A HEARING
FOR ENTRY OF AN APPROPRIATE FINAL DECREE
BY THE COURT
AND NOW, comes the plaintiff, Paul H. Boswell, Jr., by his
attorney, Dale F. Shughart, Jr., Esquire and respectfully
represents as follows:
1. On November 1, 1996, Plaintiff and his wife, (who is now
deceased) paid in full an obligation to Banc One, which was secured
by a Mortgage filed of record in the Office of the Recorder of
Deeds in and for Cumberland County, pennsylvania.
2. Banc One failed to satisfy the Mortgage and in fact on
July 13, 2000, assigned the mortgage to Defendant, Associates.
3. By certified mail letters dated November 6, 2001, the
undersigned demanded that the mortgage be satisfied and provided a
Statutory Notice pursuant to 21 P.S. 681 et seq.
4. Neither Defendant responded to the 45 day Notice.
5. On January 11, 2002, Plaintiff filed a Complaint in
Equity, requesting that the mortgage be satisfied and that the
Court fix damages pursuant to 21 P.S. 682.
6. The Complaint was served upon Defendant Banc One on
January 22, 2002 by the Cumberland County Sheriff.
7. The Complaint was served upon Defendant Associates on
January 22, 2002 by the Cumberland County Sheriff.
8. More than 20 days passed and neither Defendant entered an
appearance or filed a pleading in the case.
9. On February 18, 2002, the undersigned mailed each
Defendant a Notice of Intention to Enter Judgment by Default.
Neither Defendant responded to the Notice.
10. On March 11, 2002, the Prothonotary entered judgment
against both Defendants by default upon praecipe of the Plaintiff.
11. The plaintiff reasonably requires entry of an appropriate
final Decree by the Court to:
a. Direct Defendants or the Recorder of Deeds to satisfy
the mortgage;
b. Award appropriate damages under 21 P.S. 682.
WHEREFORE, pursuant to PA.R.C.P. 1511 (b), Plaintiff prays Your
Honorable Court to schedule a hearing on the matter.
f
Dale F. Shughart,
Attorney I.D. #193
35 East High Street, Sui e 203
Carlisle, PA 17013
(717) 241-4311
Attorney for plaintiff,
Paul H. Boswell, Jr.
-2-
!" -' ' ..
PAUL H. BOSWELL, JR.,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
CERTIFICATE OF SERVICE
AND NOW, this 11th day of March, 2002" I, Dale F. Shughart,
Jr., Esquire, attorney for Paul H. Boswell, Jr., plaintiff, hereby
certify that I have served a copy of the Motion to Schedule a
Hearing for Entry of an Appropriate Final Decree by the Court, and
proposed Order of Court, by mailing a copy of the same by united
States mail, postage prepaid, addressed as follows:
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC_
250 East Carpenter Freeway, Irving, TX 75062.
BANC ONE CONSUMER DISCOUNT COMPANY
8604 Allisonville Road, Indianapolis, IN 46250-1008.
Dale F. Shughart, Jr.
Attorney I.D. #19373
35 East High Street, suite 203
Carlisle, PA 17013
(717) 241-4311
Attorney for plaintiff,
Paul H. Boswell, Jr.
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PAUL H. BOSWELL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
PRAECIPE TO ENTER A DEFAULT JUDGMENT
PURSUANT TO PA.R.C.P. 1511(a)
Dear Sir:
The Defendants having failed to appear or file a pleading in
the case, and having failed to respond to a Notice of Intention to
Enter Default Judgment, mailed to them on February 18 (attached
hereto together with Certification of Service). Please enter
judgment in favor of Plaintiff, Paul H. Boswell, Jr., and against
Defendants Banc One Consumer Discount Company and Associates Home
Equity Consumer Discount Company, Inc.
To: Curtis R. Long, Prothonotary
March 11, 2002
rlJ
Attorney for Plaintiff,
Paul H. Boswell, Jr.
PAUL H. BOSWELL, JR.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 2002-146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
NOTICE OF INTENTION TO ENTER JUDGMENT BY DEFAULT
TO: BANC ONE CONSUMER DISCOUNT COMPANY
8604 Allisonville Road, Indianapolis, IN 46250-1008.
(Defendant)
DATE OF NOTICE: February 18, 2002
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
By:
le F. Shu
Attorneys for
35 East High 203
Carlisle, PA 1701
(717) 241-4311
Attorney for Plaintiff
PAUL H. BOSWELL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
CERTIFICATION OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
The undersigned, Dale F. Shughart, Jr., Esquire, being duly
sworn according to law, hereby certifies that on February 18, 2002,
he mailed the attached Notice of Intention to Enter Judgment by
Default by first class mail, postage prepaid, to:
BANC ONE CONSUMER
8604 Allisonville
Suite 203
Attorney for Plaintiff,
Paul H. Boswell
sworna~subscribed before me,
this ~day of March, 2002.
~/}&dP :7f~
NOTAIlIAL UAI.
BONNie L. cova... NOTARY PUBLIC
BORO 0' CAAUlLE, CUMlIERLAND COUNTY
MY CO....1S8ION IXI'lREB OCTOBER 17 2002
DALE F. SHUGHART, JR.
ATTORNEY AT LAW
35 EAST HIGH STREET
SUITE 203
CARLISLE. PENNSYLVANIA 17013
Telephone 1717) 241-4311
Facsimile (717) 241-4021
OF COUNSEL
HAMILTON C. DAVIS
LEGAL ASSISTANT
BONNIE L. COYLE
February 18, 2002
Banc One Consumer Discount Company
8604 Allisonville Road
Indianapolis, IN 46250-1008
RE: Paul H. Boswell, Jr. vs. Banc One Consumer Discount
Company, Inc. and Associates Home Equity Consumer
Discount Company, Inc.
No. 2002-146 CIVIL TERM - EQUITY
Ladies and Gentlemen:
Please find enclosed a Notice of Intention to Enter Judgment By
Default in the above referenced matter.
Very truly yours,
Dale F. Shughart, Jr.
DFS,JR/bc
Enclosure
cc Paul H. BOswell, Jr.
PAUL H. BOSWELL, JR.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVNAIA
vs.
NO. 2002-146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
NOTICE OF INTENTION TO ENTER JUDGMENT BY DEFENDANT
TO: ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC.
250 East Carpenter Freeway, Irving, TX 75062.
(Defendant)
DATE OF NOTICE: February 18, 2002
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Lawyer Referral
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Service
n
By:
203
PAUL H. BOSWELL, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 2002 - 146 CIVIL TERM - EQUITY
BANC ONE CONSUMER DISCOUNT
COMPANY AND ASSOCIATES
HOME EQUITY CONSUMER DISCOUNT
COMPANY, INC.,
Defendants
CERTIFICATION OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
The undersigned, Dale F. Shughart, Jr., Esquire, being duly
sworn according to law, hereby certifies that on February 18, 2002,
he mailed the attached Notice of Intention to Enter Judgment by
Default by first class mail, postage prepaid, to:
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC.
250 East Carpenter Freeway, Irving, TX 750
Dale F. Shughart, Jr.
Attorney I.D. #19373
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
Attorney for Plaintiff,
Paul H. Boswell, Jr.
Sworn a~~subscribed before me,
this ~~ay of March, 2002.
~X~~
NOTAIlIAL UAI.
BONNie L. cova... NOTARY PUBLIC
BORO ~ CAR' ... .
MY CO..M1I81oN'".:::.... CUllIlERLAND COUNTY
-,"E. OCTOBER 172002
.
DALE F. SHUGHART, JR.
ATTORNEY AT LAW
35 EAST HIGH STREET
SUITE 203
CARLISLE, PENNSYLVANIA 17013
Telephone (717) 241 -4311
Facsimile (7171241-4021
OF COUNSEL
HAMILTON C, DAVIS
LEGAL ASSISTANT
BONNIE L. COYLE
February 18, 2002
Associates Home Equity Consumer Discount Company, Inc.
250 East Carpenter Freeway
Irving, TX 75062
RE: Paul H. Boswell, Jr. vs. Banc One Consumer Discount
Company, Inc. and Associates Home Equity Consumer
Discount Company, Inc.
No. 2002-146 CIVIL TERM - EQUITY
Ladies and Gentlemen:
Please find enclosed a Notice of Intention to Enter Judgment by
Default in the above referenced matter.
Very truly yours,
Dale F. Shughart, Jr.
DFS,JR/bc
Enclosure
cc Paul H. Boswell, Jr.
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RECEIVED JUL 0 5 2005~
Michele J. Thorp, Esquire
Attorney I.D, No, 71117
THOMAS, THOMAS & HAFER, LLP
305 North Front Street
Post Office Box 999
Harrisburg, PA 17108-0999
(717) 237-7153
E-Mail: rnthorp@ttf1law.com
Attorneys for Defendants
LISA MABIUS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v,
NO, 02-126 CIVIL TERM
LONG JOHN SILVERS, INC., and
SHIRLEY POLONSKY 'Jd/b/a LONG
JOHN SILVERS SEAFOOD SHOPPE,
STORE NO. 3683,
Defendants
JURY TRIAL DEMANDED
ORDER
AND NOW, this
jZ'" day of
1wr,
, 2005, upon consideration
of the Uncontested Motion for Extension of Deadlines, it is hereiby ORDERED that said Motion
is GRANTED and:
(1) Discovery will be completed no later than sixty (60) days from the date of this
Order;
(2) Any and all expert reports will be produced no Ilater than ninety (90) days from
the date of this Order;
(3) At any time after October 31,2005, either party may praecipe to list this case for
either arbitration or trial.
BY THE COURT
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