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HomeMy WebLinkAbout04-62362013118 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. G'ORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CHASE MANHATTAN BANK 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. LARRY DARON 3166 RITNER HWY NEWVILLE PA 17241 DOCKET NO. : OU --(o ff Clio.1.?,z__ 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 JUDGEMENT 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. At all times relevant hereto, the defendant (s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant (s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. Defendant (s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 3. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 4. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $4,086.16. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $4,086.16 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendant(s) the sum of $4,086.16 at the rate of 24% from the date of December 15, 2000, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: BERG, ESQUIRE PAUL M. S ELD, JR., ESQUIRE FR ?ERIC OorPlaintiff Attorney P01h VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff (s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I./WEIWBERG, ESQUIRE EXHIBIT "A" 829 Balance as of: Payment Due Minimum Payment Account Number 07/28/2004 Date Payment Enclosed 1 5260311330000477 $7979.50 Past Due { $7979.50 1 $ Make checks payable to: Unifund UNIFUND STATEMENT Larry Daron 3166 Ritner Hwy Newville PA 17241-9569 MESSAGE FROM UNIFUND Your account is past due $7979.50. The past due amount is included in the minimum payment. Please remit immediately. If you have already sent payment for the above amount, thank you. This account is currently bein serviced by: Gordon & Weinberg P.C. 21 S. 21st St Philadelphia PA 19103 TRANSACTIONS: 1 Date {{ Transaction II Balance 11 Due II Payments II New II Balance 07128/2004 Unifund Purchased The $7979.50 $7979.50 $0 $7979.50 Above Referenced account from CHASE MANHATTAN BANK Prompt crediting of payments. To receive credit for payments as of the date of receipt, we must receive your check or money order at: Unifund 10625 Techwoods Circle Cincinnati, OH 45242 Payments received at the above address in the manner specified after that time will be credited to your account as of our next business day. The crediting to your account of payments received at any location other than the above address may be delayed up to 5 days of receipt This communication is from a debt collector. Federal law requires us to inform you that this is an attempt to collect a debt and any information obtained will be used for that purpose. Unless you notify this office within 30 days after receiving this notice that you dispute the validity of this debt or any portion thereof, this office will assume this debt is valid. If you notify this office in writing within 30 days from receiving this notice that the debt or any portion thereof is disputed, we will obtain verification of the debt or a copy of a udgment and we will mail you a copy of such verification or judgmen to you. If you request this office in writing within 30 days after receiving this notice, this office will provide you with the name and address of the original creditor, if different from the current creditor. D j I GJ - r, 'T ff l-I P ..' ? ? fra e:..?Tl % SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-06236 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS DARON LARRY R. Thomas Kline Sheriff who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: DARON LARRY unable to locate Him in his bailiwick COMPLAINT & NOTICE but was He therefore returns the the within named DEFENDANT DARON LARRY NOT SERVED , as to 3166 RITNER HIGHWAY NEWVILLE, PA 17241 DEFENDANT FILED BANKRUPTCY. 1:03-BK-07381-MDF ATTORNEY JAMES JONES. Sheriff's Costs: So answers: _ -- Docketing 18.00 Service 8.14 Affidavit .00 R. Thomas ine Surcharge 10.00 Sheriff of Cumberland County .00 36.14 GORDON & WEINBERG 01/05/2005 Sworn and subscribed to before me this )Y day of , Jay A. D. Prothonotary 2013118 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 UNIFUND CCR PARTNERS ASSIGNEE OF CHASE MANHATTAN BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. LARRY DARON 3166 RITNER HWY NEWVILLE PA 17241 DOCKET NO. : 04-6236 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Plaintiffs' Complaint in Civil Action in the above-captioned matter for an additional thirty (30) days. GORDON & WEINBERG, P.C. BY: FREDERIC I. IN ERG, ESQUIRE JOEL M. FLINK, QUIRE Attorney for Plaintiff(s) 2013118 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CHASE MANHATTAN BANK 10625 Techwoods Circle Cincinnati, OH 45242 VS. LARRY DARON 3166 RITNER HWY NEWVILLE PA 17241 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : Oq NOTICE C ".?- 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 JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLATAT Oj;,,FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOS$--.,MON 0P PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. - .7- YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO"NOT QTE rn LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOAtH BETQpy7 T FIND OUT WHERE YOU CAN GET LEGAL HELP. rn CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET - n3 CARLISLE, PA 17013 (717) 249-3166 COMP I I& CZYM-ACTION 1. At all times relevant hereto, the defendant (s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. Defendant (s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 3. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $4,086.16. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $4,086.16 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. II WHEREFORE, plaintiff claims of bhe defendant(s) the sum of $4,086.16 at the rate of 24% from the date of December 15, 2000, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE ERG, ESQUIRE PAUL M. S H ELD, JR., ESQUIRE Attorney or Plaintiff P01h M Balathco its of, Pay nef t Due Minimum Payment Account Number 07/28/2004 Date Payment Enclosed Melee cheeks payable 10; UnNund UNIFUND STATEMENT Larry Daron 3166 Ritner Hwy Newville PA 17241-9559 MESSAGE FROM UNIFUND Your account is past due $7979.50. The past due amount is Included in the minimum payment. Please remit immediately. If you have already sent payment for the above amount, thank you. This account is current )yy beingA?serviced by: Gordon & Weinberg P.C. 21 S. 21st 5t Philadelphia PA 19103 Date ransa on a ence ue aymen s 1 -1 Balance 07/26/2004 Unifund Purchased The $7979.50 $7979.50 $0 $7979.50 Above Referenced account from CHASE MANHATTAN BANK Prompt crediting of payments. To receive credit for payments as of the date of receipt, we must receive your check or money order at: Unifund 10625 Techwoods Circle Cincinnati, OH 45242 Payments recelved at the above address in the manner specified after that time will be credited to your account as of our next business day. The crediting to your account of payments received at any location other than the above address may be delayed up to 5 days of receipt This communication is from a debt collector. Federal law requires us to inform you that this Is an attempt to collect a debt and any Information obtained will be used for that purpose. Unless you notify this office within 30 days after receiving this notice that you dispute the validity of this debt or any portion thereof this office will assume this debt is valid. If ou notify this office In writing within 30 days from receiving this notice that the debt or any portion thereof is disputed, we will obtain verification of the debt or a copy of a udgment and we will mail you a copy of such verification or judgmej to you, If you request this office in writing within 30 days after receiving this notice, this office will provide you ith the name and address of the original creditor, if different from the current creditor. RECEIPT FOR PAYMENT Cumberland Countyy Prothonotary's Office Carlisle, Pa 17013 Receipt Date 12/13/2004 Receipt Time 14:34:43 Receipt No. 158298 UNIFUND CCR PARTNERS (VS) DARON LARRY Case Received of 200PD OGORDON & WEINBER IM Total Non-Cash..... + 55.50 Check# Total Cash. + .00 6492 Change ............. - .00 Receipt total...... = 55.50 ------------------------- Distribution Of Payment ---------------------------- Transaction Description Payment Amount COMPLAINT 35.00 CUMBERLAND CO GENERAL FUND TAX ON CMPLT .50 BUREAU OF RECEIPTS AND CONTROL SETTLEMENT 5.00 CUMBERLAND CO GENERAL FUND AUTOMATION 5.00 CUMBERLAND CO AUTOMATION FUND JCP FEE 10.00 BUREAU OF RECEIPTS AND CONTROL 55.50 AFFIDAVIT OF INDEBTEDNESS State of Ohio) County of Hamilton) ss. l 1 Jessica Bergholz being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that she is authorized to make the statements and representations herein. The defendant is not in any branch of the military. There is due and payable from Lary Daron, Account Number 5260311330000477, the amount of $7979.50 (principal balance in the amount of $4086.16 plus interest up through 07/28/2004 in the amount of $3893.34). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid dale at the rate of 24.00 percent per annum. This balance reflects any payments, credits or offsets made since the account was charged off. This account was originated with CHASE MANHATTAN BANK. Unifund CCR Partners purchased this account from CHASE MANHATTAN BANK. Said account has been assigned, transferred and set over unto, Gordon & Weinberg P.C. with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim, on behalf of Unifund CCR Partners. DATED this July 28 2004 UNWUND ARTNERS y a Beraholz Media Supervisor 10625 Techwoods Circle Cincinnati OH 45242 Address Subscribed and sworn to before me this 28 day of July 2004 Year Notary Public My commission Expires Client # 829 `„111 U 1 f rrr)' c3 CIfRT,S'pTNA M. aLLE 1h JiRri Notaryp,,b,. N fnr the state of Ohia, „li. r'rlrnmiS???? ?'xPrrkk9 8 Fn - 1 ?", .. .. rO .-yy OD&)RCE hr? vs Case No. l.J` , `? ?, ?? M 0a (Z-71 Statement of Intention to Proceed To the ttCoou t: L L?A 1 1 1 t ?-I intends to proceed with the above captioned matter. e/? Print Name 1 re w 1 O h n Name Date: VD Attorney for 112 n Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. 1. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated irrmsponse to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. 11 Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a show in to the courvthat the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. r-.> c =' C n a :: r,, SHERIFF'S RETURN - REGULAR CASE NO: 2004-06236 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS DARON LARRY 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 DARON LARRY the DEFENDANT , at 1853:00 HOURS, on the 17th day of October , 2008 at 3166 RITNER HIGHWAY NEWVILLE, PA 17241 by handing to PATTY DARON, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge !v/a-2/UP So Answers: 18.00 ?--? 11.00 00 10.00 R. Thomas Kline .00 39.00 10/20/2008 GORDON & WEINBERG Sworn and Subscibed to before me this of By: day De y 1herif C / A. D. 2013118 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 UNIFUND CCR PARTNERS ASSIGNEE OF CHASE MANHATTAN BANK VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 04-6236 LARRY DARON TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff nd against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the com laint, as follows: Principal $4,0866 Less: Payments on Account ( $10) Total: $4,086.X6 Understanding the false statements made herein are subje t to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification o Authorities, I verify that: 1. The last known addresses of the parties are: IFUND CCR PARTNERS ASSIGNEEOF CHASE MANHATTAN BANK and that the last known address of defendant, LARRY DARON, 3166 RITNER HWY, NE ILLE PA 17241. 2. The annexed notice(s) of intention to file thi praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the mili ary service of the United States or otherwise within the cov rage of the Soldiers and Sailors Civil Relief Act and is (are) o er 18 years of age. AND NOW, this 10 44 day of "June , 2009 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $12,534.36 as per the above ertificat' Prot notary GOR BY: 2013118 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 UNIFUND CCR PARTNERS ASSIGNEE OF CHASE MANHATTAN BANK VS. LARRY DARON COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 04-6236 NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA LARRY DARON 3166 RITNER HWY NEWVILLE PA 17241 DATE OF NOTICE/FECHA DEL AVISO: May 20, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITT PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT Y OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAI: WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTA YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU D, LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFIC. YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE A] PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL ; ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: P10D-2 FREDERI?J I V WEINBERG, ESQUIRE JOEL M /FLINK, ESQUIRE APPEARANCE DEFENSES THIN TEN YOU RIGHTS. NOT HAVE A CAN PROVIDE LE TO ERVICES TO OF THE PP, QT Y 2009 JUN 10 PM 1- 02 CUME ?' ryV ?''i ??4^1f?l? l i :? 14.oo PA ATTq Cy-* &M87 P-To as (0'50'9 Nom GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2013118 UNIFUND CCR PARTNERS ASSIGNEE OF CHASE MANHATTAN BANK VS. LARRY DARON 3166 RITNER HWY NEWVILLE PA 17241 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 04-6236 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Penn: you are hereby notified that a judgment has been entered you in the above proceeding as indicated below. /XL Judgment by Default $4,086.16 Money Judgment $ ?L Judgment on Award of Arbitra- LL Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT TELEPHONE NUMBER: 484/351-0500 _ PR !,polo 9 cylvania, against THIS