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Home My WebLink About11-5083.A BARLEY SNYDER LLC Donald R. Geiter, Esquire Court I.D. No. 202629 126 East King Street Lancaster, PA 17602 717.299.5201 FiLED-QFFICE OF The PPOTIjONOTAPY 21113UN 2a PM 2- U8 CUMS NNSYLVAN A T'? PE Attorney for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. MICHAEL P. McCAULEY, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. I l- So 3 0o ( Defendant CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney in the Note executed by Defendant in favor of Plaintiff, a true and correct copy of which is attached to the Complaint filed in this action as Exhibit "A" and which is incorporated herein by reference, I hereby appear for Defendant, Michael P. McCauley, confess judgment for money damages in favor of Plaintiff and against Defendant as follows: Principal ...................................................................... $ 200,000.00 Interest through 3/3/2011 at a rate of $23.63 per diem ..................................................... 3,990.28 10% Attorneys' Fees .................................................... 20,399.03 Late Fees ...................................................................... 540.74 Total ............................................................................. $ 224,930.05 plus continuing interest after March 3, 2011 at a rate of $23.63 per diem, plus continuing late charges and costs of suit. BARLEY SNYDER LLC Date: b i ?'?tI 3231151.1 By: Donald R. Geiter, Esquire Attorneys for Defendant Court I.D. No. 202629 126 East King Street Lancaster, PA 17602-2893 717.299.5201 ctLt?ya-7 Nvfica FILED-OFFICE OF THE PROTHONOTARY BARLEY SNYDER LLC Donald R. Geiter, Esquire Court I.D. No. 202629 126 East King Street Lancaster, PA 17602 717.299.5201 Attorney for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. MICHAEL P. McCAULEY, 2011 JON 20 PM 2: 08 CUMBERLAND COUNTY PENNSYLVANIA Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. I I - SOS -9 Cl V COMPLAINT FOR CONFESSION OF JUDGMENT Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank, files this Complaint pursuant to Pa. R.C.P. §2951 for judgment by confession and avers the following: 1. Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank ("Fulton"), is a national banking association with a principal location of One Penn Square, PO Box 4887, Lancaster, Pennsylvania 17604. 2. Defendant, Michael P. McCauley, is an adult individual with a last known address of 1442 Wellgate Lane, Mechanicsburg, Pennsylvania 17055. 3. Defendant, in connection with a business loan, executed and delivered to the Bank a Promissory Note dated April 12, 2006 (the "Note") in the original principal sum of $200,000.00. A true and correct copy of the Note is attached hereto as Exhibit "A" and incorporated herein by reference. 3231151.1 4. The interest rate on the Note is subject to change from time to time based on changes in an index which is the Fulton Bank Prime Rate (the "Index" as defined in the Note) and shall be a rate equal to one percentage point over the Index. 5. The Note requires Defendant to make monthly payments of all accrued unpaid interest due as of each payment date, beginning May 15, 2006, and all subsequent interest payments to be due on the same day of each month thereafter. 6. The Note requires Defendant to pay a late charge of five percent (5%) of the unpaid portion of the regularly scheduled payment when Fulton does not receive Defendant's monthly payment within fifteen (15) days of the date that the payment is due. 7. Defendant defaulted under the Note by failing to make monthly payments that were due on October 15, 2010 and each month thereafter, as required by the Note. 8. Pursuant to the Note, if Defendant fails to make payments required under the Note, Fulton may, and hereby does, declare the entire balance of principal and interest under the Note to be due and payable immediately. 9. The Note authorizes confession of judgment against Defendant for all amounts due under the Note plus continuing interest, continuing late charges and attorneys' commission of ten (10%) percent of the unpaid principal balance plus accrued interest for collection, but in any event, not less than five hundred dollars ($500), plus the cost of any legal proceedings. 10. As of March 3, 2011, the amount due on the Note is as follows: Principal ...................................................................... $ 200,000.00 Interest through 3/3/2011 at a rate of $23.63 per diem ..................................................... 3,990.28 10% Attorneys' Fees .................................................... 20,399.03 Late Fees ...................................................................... 540.74 Total ............................................................................. $ 224,930.05 3231151.1 2 plus continuing interest after March 3, 2011 at a rate of $23.63 per diem, plus continuing late charges and costs of suit. 11. The Note has not been assigned. 12. No Prior Judgment has been entered on the Note in any jurisdiction. 13. Judgment is not being entered by Confession against a natural person in connection with a consumer credit transaction. WHEREFORE, Plaintiff, Fulton Bank, N.A., formerly known as Fulton Bank, demands judgment against Defendant, Michael P. McCauley, in the total amount of $224,930.05, consisting of a principal amount of $200,000.00, interest through March 3, 2011 in the amount of $3,990.28, attorneys' fees in the amount of $20,399.023 late fees in the amount of $540.74, plus continuing interest after March 3, 2011 at a rate of $23.63 per diem, plus continuing late charges and costs of suit. Date: (' f I 1 BARLEY SNYDER LLC By: a ??" Donald R. Geiter, Esquire Attorneys for Plaintiff Court I.D. No. 202629 126 East King Street Lancaster, PA 17602-2893 717.299.5201 3231151.1 VERIFICATION [Fulton Bank v. McCauley] I, JEFFREY W. VALENTINE, Vice President, of Fulton Bank, N.A., hereby verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments in the foregoing document are based upon the understanding or application of law, I have relied upon counsel in making this Verification. This Verification is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: ?fl7hl / effrey W. Valentine 3231151.1 EXHIBIT A Borrower; a6duel P. Mccadey Lender: Fulton so* S 205 Fairway Drive Hummalstown Office Mechanicsburg, PA 17055 Corporate Address One Penn Square ( La icaste+, PA 17602 Principal Amount: $200,000.00 Date of Note: April 12, 2006 PROMISE TO PAY. Michael P. McCauley ("Borrower") promises to pay to Fulton Bank ("Lender"), or order, In (awful money of the United States of America, on demand, the pr(neipel amount of Two Hundred Thousand & 001100 Dollars ($200,000.00) 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 full immediately upon Lender's demand. Borrower will pay regular monthly payments of all accrued unpaid Interest duo as of each payment data, beginning May 15, 2006, with all subsequent interest payments to be duo on the some day of each month after that. Unless otherwise agreed or required by amicable taw, payments will be applied first to any accrued unpaid interest; then to principal; than to any lots charges; and they to say unpaid collection costs. The annual interest rate for this Note Is computed on a 3651360 basis; that is, by applying the ratio of the annual interest rate awn a year of 360 days, multiplied by the outstanding principal balance, multiplied by the, actual number of days the principal balones is outstanding. Borrower will pay Lender at tender's address shown above or at such other place as Lender may designate in wilting.. VARIABLE INTEREST RATE. The interest rate on this Note is subject to change from time to time based on charges in an index which is the Fulton Bank Prime Rate (the 'Index"). The Index is not necessarily the lowest rate charged by Lender on its loans and is set by Lender in its sole discretion, if the Index becomes unavailable during the term of this loan, Lender may designers a substitute index after notifying Borrower. Lender will tell Borrower the current Index rato upon Borrower's request. The Interest rate change will not occur more often than each day. Borrower understands that Lender may make loans based on other rates as well. The interest rate to be applied to the unpaid principal balance of this Note wig beat a rate of 1.000 percentage pant over the Index. NOTICE: Under no circumstances will the interest rate an this Note be more than the maximum rate allowad'by applicable law, PREPAYMENT. Borrower agrees that all ban lose aril other prepaid finance charges are earned gully as of the date of the loan and will not be subject to refund upon early payment (whether voluntary, or as aresult of default), except as otherwise required by law. Except for the foregoing, Borrower may pay without penalty all or a portion of the amount owed eerier 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, early payments will reduce the principal balance duo. Borrower agrees not to send Lender payments marked `paid in tuts", "without. recourse% or similar language. If Borrower sends such a payment, Lender may accept h without losing. any of Larder's rights under Oils Note, and Borrower wig remain obligated to pay any further amount owed to Lender. AD written communications concerning disputed amounts, including any. check or other payment instrument that indioetes that the payment constitutes 'payment in fug' of the amount owed or that is tendered with other conditions at limitations or as full satisfaction of a disputed amount most be mailed or delivered to: Fulton Bank, Hummslstown Office, Corporate Address. One Penn Square, Lancaster, PA 17602. LATE. CHARGE. If a regularly scheduled interest payment is 15 days or mac late, Borrower will be charged 5.000% of the unpaid portion of The regularly scheduled payment, If Lender demands payment of this loan, and Borrower does not pay the loan in full within 15 days after Lender's damrand, Borrower also will be charged 5.000% of the unpaid pardon of the sum of ttu unpaid principal plus accrued unpaid Interest. INTEREST AFTER DEFAULT. Upon. default. including 'faika'o to pay upon final maturity. Lender, at its option, may, if permitted under applicable law, increase the variable interest rate on Otis Note to 6.000 percentage points over the Index. The interest rate will riot exceed to maximum rate permitted by applicable law, If judgment is entered in connection with this Note, interest wid continue to accrue on this Note attar judgment at the interest rate applicable to this Note at the time judgment is entered. LENDER'S RIGHTS. Upon Lender's demand, Lender may, after giving such notices as required by applicable low, declare the entire unpaid principal balance on this Note and all accrued unpaid interest immediately due,. and then Borrower will pay that amount. ATTORNEYS' FEES; EXPENSES. Lender may hire or pay someone else to help collect this Note if Borrower does not pay, Borrower will pay Lender that amount. This includes, subject to any. limits under applicable law, Lender's attorneys' fees and Lender's Legal expenses, whether or not there is a lewsdt, including attorneys' fees, expanses for bankruptcy proceedings finctudbg efforts to modify or vacate any automatic stay or irjunctiord, and appeals. If not prohibited by applicable taw, Borrower also will pay any court casts, in addition to sil other sums provided by law. JURY WAIVER. Lander and Borrower hereby wive the right to any jury trial In any action, proceeding, or counterclaim brought by either Lender or Borrower against the other, GOVERNING LAW. This Note will be governed by federal law applicable to Lender and, to the extent not preempted by federal law, the laws of the Commonwealth of Pennsylvania without regard to itsconflicts of law provisions. This Note has been accepted by Lender In the Commonwealth of Pennsylvania. RIGHT OF SETOFF, To the extent permitted by applicable law, Lender reserves a right of setoff in all Borrower's. accounts with Lender (whether chocking, savings, or some other account). This includes all accounts Borrower holds jointly with someone also and aft accounts Borrower may open In tare future. However, this does not Include any IRA or Keogh accounts, or any trust accounts for which aatoN would be prohibited by law. Borrower authoorizes Lender, to the extent permitted by applicable law, to charge or setoff all ens owing on the debt against any and all such accounts, and, at Lender's option, to administratively freeze all such accounts to allow Lender to protect Lender's charge and setoff tights provided in thus paragraph. COLLATERAL. This ban is unsecured. LINE OF CREDIT, This Noto evidences a revolving loo of credit. Advances under this Note may be requested orally by Borrower or as provided in this paragraph. All oral requests shall be confirmed in writing on the day of the request. All communications, instructions, or directions by talephona or otherwise to Lender are to be directed to Lenders office shown above. The fdbwlp person currently is authorized, except. as provided in this paragraph, to request advances and authorize payments under the tins of credit until Lender receives from Borrower, at Lender's address shown above., written notice of revocation of his or her authority: Michael P. McCauley. Any and all advances under the Una of Credit strap be deposited into Borrower's checking account 13623-12139 with Lender. Borrower agrees to be gable for all sums either: LAI advanced in accordance with the instructions of an authorized person or IS) credited to any of Borrower's accounts with Lender. The unpaid principal balance owing on this Note at any time may be evidenced by endorsements on this Note or by Lenders internal records, including daily computer prim-ows. CROSS DEFAULT, Any event of default under any loan our and owing to Lender by Borrower, at any time, shag constitute an event of default under all loans due and owing to Lender by Borrower. SUCCESSOR INTERESTS, The terms of this Note shag be binding upon Borrower, and upon Borrower's heirs, personal representatives, successors and assigns, and shall inure to the benefit of Lender end its successors and assigns. GENERAL PROVISIONS. it any part of this Note cannot be enforced, this fact will not affect the rest of the Note. Lender may delay or forgo enforcing any of its rights or remasits under this Note without losing them. Borrower and any other person who signs, guarantees or endorses this Note, to the extent allowed by low, waive presentment, demand for payment, and notice of dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated in writing, no party who signs this Note, whether as maker, guarantor, accommodation make or endorser, shag be released from liability. All such parties agree that Lender may renew or extend !repeatedly and for any length of tine) this loan or raises* any party or guarantor or collateral; or impair, fail to realize upon or perfect Lender's secularity interest in the collateral; and take any other action deemed necessary by Lander without the content of or notice to anyone. AD such parties also agree that Lender may modity, this loan without the consent of or notice to anyone other than the party with whom the modification is made. The obligations under this Note are joint and several, if any portion of this Note is for any reason. determined to be unenforceable, it wig not affect the enforceability of any other provisions Of this Note. CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES ANO EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER A DEFAULT UNDER THIS NOTE AND WITH OR WITHOUT COMPLAINT FILED, CONFESS OR ENTER JUDGMENT Loan No: 0001-9707942-0101 PROMISSORY NOTE (Continued) Page 2 AGAINST BORROWER FOR THE ENTIRE PRINCIPAL BALANCE OF THIS NOTE AND ALL ACCRUED INTEREST, LATE CHARGES AND ANY AND ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THIS NOTE, TOGETHER WITH COSTS OF SUIT. AND AN ATTORNEY'S COMMISSION OF TEN PERCENT 110911 OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS 1$5001 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 AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS NOTE TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS NOTE. BORROWER HEREBY WAIVES ANY RIGHT BORROWER MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF 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 SIGNtMG THIS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE, INCLUDING THE VARIABLE INTEREST RATE PROVI"S. BORROWER AGREES TO THE TE RFAS OF THE NOTE. BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF THIS PROMISSORY NOTE. THIS NOTE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS NOTE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW_ BORROWER "'- x tseal) y KNwal P. M.C. Signed, acknowkdged and denvared In I pfsss a of: X - Wm X Wimaas ..-?^ aASGMWL??.v..,AgN. tw,r .br1/+T..??.a.r?NalMl. fOw NIfIwlY.wb. aR{lWpf4?C,RYa!p04 M,pY •00001-9707942.010100230031057• DISCLOSURE FOR CONFESSION OF JUDGMENT Declarant: M1chow P. Mccowsy Lender: Fuhon Bank 205 Fairway Drive Hummektown OHlce Mechanicsburg, PA 17055 Corpams Address One Perm Square Lancoater, PA 17602 ?y? DISCLOSURE FOR CONFESSION OF JUDGMENT 1 AM EXECUTING, THIS II/?(ADAY OF 2/L , 2010-6-A PROMISSORY NOTE FOR $200,000.00 OBLIGATING ME TO REPAY THAT AMOUNT. A. 1 UNDERSTAND THAT THE NOTE CONTAINS A CONFESSION OF JUDGMENT PROVISION THAT WOULD PERMIT LENDER TO ENTER JUDGMENT AGAINST ME IN COURT, AFTER A DEFAULT ON THE NOTE, WITHOUT ADVANCE NOTICE TO ME AND WITHOUT OFFERING ME AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT. IN EXECUTING THE NOTE, BEING FULLY AWARE OF MY RIGHTS TO ADVANCE NOTICE AND TO A HEARING TO CONTEST THE VALIDITY OF ANY JUDGMENT OR OTHER CLAIMS THAT LENDER MAY ASSERT AGAINST ME UNDER THE NOTE, 1 AM KNOWINGLY, INTELLIGENTLY, AND VOLUNTARILY WAIVING THESE RIGHTS, INCLUDING ANY RIGHT TO ADVANCE NOTICE OF THE ENTRY OF JUDGMENT, AND I EXPRESSLY AGREE AND CONSENT TO LENDER'S ENTERING JUDGMENT AGAINST ME BY CONFESSION AS PROVIDED FOR IN THE CONFESSION OF JUDGMENT PROVISION. 0. 1 FURTHER UNDERSTAND THAT IN ADDITION TO GIVING LENDER THE RIGHT TO ENTER JUDGMENT AGAINST ME WITHOUT ADVANCE NOTICE OR A HEARING, THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE ALSO CONTAINS LANGUAGE THAT WOULD PERMIT LENDER, AFTER ENTRY OF JUDGMENT, AGAIN WITHOUT ETHER ADVANCE NOTICE OR A HEARING, TO EXECUTE ON THE JUDGMENT BY FORECLOSING UPON, ATTACHING, LEVYING ON, TAKING POSSESSION OF OR OTHERWISE SEIZING MY PROPERTY, IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. IN EXECUTING THE NOTE. BEING FULLY AWARE OF MY RIGHTS TO ADVANCE NOTICE AND A HEARING AFTER JUDGMENT IS ENTERED AND BEFORE EXECUTION ON THE JUDGMENT, I AM KNOWINGLY, INTELLIGENTLY AND VOLUNTARILY WANING THESE RIGHTS, AND I EXPRESSLY AGREE AND CONSENT TO LENDER'S IMMEDIATELY EXECUTING ON THE JUDGMENT IN ANY MANNER PERMITTED BY APPLICABLE STATE AND FEDERAL LAW, WITHOUT GIVING ME ANY ADVANCE NOTICE. C. AFTER HAVING READ AND DETERMINED WHICH OF THE FOLLOWING STATEMENTS ARE APPLICABLE, BY INITIALING EACH STATEMENT THAT APPLIES, 1 REPRESENT THAT: INITIALS 1. 1 WAS REPRESENTED BY MY OWN INDEPENDENT LEGAL COUNSEL IN CONNECTION WITH THE NOTE. N y 2. A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE TO MY ATTENTION. 0. 1 CERTIFY THAT MY ANNUAL INCOME EXCEEDS 010,000; THAT THE BLANKS IN THIS DISCLOSURE WERE FILLED IN WHEN I INITIALED AND SIGNED IT; AND THAT I RECEIVED A COPY AT THE TIME OF SIGNING. THIS DISCLOSURE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS DISCLOSURE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A SEALED INSTRUMENT. ACCORDING TO LAW. DECLA T x ` fSeall Mkhael P. Mc u y Sgned, acknowkd d and deAvmad M UIe presmn:e of: X sa x Witness NWI11101?,f,a Y.. RI0.MIM Cw. MMwI,ti?Y,µiy 41Mf, it M If?Y IY?yL . M RYIIKAI,CrMrtY1AR 1MIA] FILED-OFFICE OF THE PROTHONOTAR 1' 2011 JUN 20 PM 2: 08 BARLEY SNYDER LLC Donald R. Geiter, Esquire Court I.D. No. 202629 126 East King Street Lancaster, PA 17602 717.299.5201 CUMBERLAND COUNTY PENNSYLVANIA Attorney far Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. MICHAEL P. McCAULEY, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. Defendant CERTIFICATE OF RESIDENCE I, Donald R. Geiter, Attorney for Plaintiff, hereby certify to the best of my knowledge, information and belief that the name and current address of each party is as follows: 1. The precise address of Plaintiff, Fulton Bank, N.A., is One Penn Square, PO Box 4887, Lancaster, Pennsylvania 17604. 2. The last known address for Defendant, Michael P. McCauley, is 1442 Wellgate Lane, Mechanicsburg, Pennsylvania 17055. Date: 6-t tt BARLEY SNYD?E-R LLLC By: Donald R. Geiter, Esquire Attorneys for Plaintiff Court I.D. No. 202629 126 East King Street Lancaster, PA 17602-2893 717.299.5201 3231151.1 _- Or THE PROTNNOTAR'i 2011 JUN 20 PM I: 5t, CUMBERLAND COUNTY PENNSYLVANIA BARLEY SNYDER LLC Donald R. Geiter, Esquire Court I.D. No. 202629 126 East King Street Lancaster, PA 17602 717.299.5201 Attorney for Plaintiff Fulton Bank, N.A., formerly known as Fulton Bank FULTON BANK, N.A., FORMERLY KNOWN AS FULTON BANK, Plaintiff V. MICHAEL P. McCAULEY, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. I (' sas clyl-I ENTRY OF APPEARANCE Kindly enter the appearance of Donald R. Geiter, Esquire, Barley Snyder LLC on behalf of Plaintiff, Fulton Bank, NA., formerly known as Fulton Bank, in the above-captioned matter. Serve all papers at 126 East King Street, Lancaster, Pennsylvania 17602-2893. BARLEY SNYDER LLC Date: b ? (t By: Donald R. Geiter, Esquire Attorneys for Plaintiff Court I.D. No. 202629 126 East King Street Lancaster, PA 17602-2893 717.299.5201 3231151.1