HomeMy WebLinkAbout12-26-91
IN RE: ESTATE OF ROBERT M.
MUMMA, LATE OF
CUMBERLAND COUNTY,
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS'COURT DIVISION
NO. 21-86-398
CITATION
WE COMMAND, you that laying aside all business and excuses
whatsoever, you be and appear in your proper person before
the Honorable Judges of the Common pleas Court, Orphans'
Court Division at a session of the said Court there to be held,
for the County of Cumberland to show cause, if any there be why
the appointment of a temporary fiduciary should not be granted
with regard to the administration of the above-referenced estate's
interest in the Pennsylvania corporation known as Lebanon Rock,Inc.
The time and place of hearing are fixed for 1:30 o'clock P.M.
on the 17th day of January, 1992, in Courtroom No.1, Carlisle,
Courthouse, Cumberland County, Pennsylvania.
This citation is returnable sec. leg.
witness my hand and official seal of office at Carlisle,
pennsylvania this 27th day of December, 1991
'inaLuJ- c.. ~~ ,of. jJ tC~
Mary (t.Lew1s .
Clerk of Orphans' Sourt D1vision
Cumberland County
Carlisle,Penna.
1.296
)(
, PJP.~ C1
J D"'-< ~A
IN RE:
ESTATE OF ROBERT M.
MUMMA, late of
Cumberland County,
Pennsylvania
: IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 21-86-398
ORPHANS' COURT DIVISION
RULE TO SHOW CAUSE
'-I/,
AND NOW, this ~ day of?<1cOA}Lt\Lj'l-/
, 1991,
upon consideration of the annexed PETITION FOR THE APPOINTMENT OF
A TEMPORARY FIDUCIARY, it is hereby decreed that citations be
awarded, directed to Barbara McK. Mumma and Lisa M. Morgan,
Executrices under the will of Robert M. Mumma, to show cause, if
any there be, why the appointment of a temporary fiduciary should
not be granted with regard to the administration of the above-
referenced estate's interest in the Pennsylvania corporation
known as Lebanon Rock, Inc.
The
time and place of hearing are fixed
/'7 'Ii /]
on the I day of "JiJ-I(..vJ.A;r
1, Carlisle courth~e, Cumberland
for /,' 3Z)
, 199/ in
o'clock f.m.
Courtroom No.
County,
Pennsylvania.
This citation is returnable sec. leg.
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1'-'0101
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IN RE:
ESTATE OF
ROBERT M. MUMMA,
Late of Cumberland
County, Pennsylvania
:
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
No. 21-86-398
: ORPHANS' COURT DIVISION
PETITION FOR THE APPOINTMENT OF
A TEMPORARY FIDUCIARY PURSUANT TO
CHAPTER 43 OF THE PROBATE, ESTATES AND
FIDUCIARIES CODE (20 Pa. C.S.A. S 4301 et sea.)
Robert M. Mumma, II, individually, and Robert M.
Mumma, II and Gary M. Gilbert, Co-Guardians of the Estates of
Susan Mann Mumma and Marguerite Mann Mumma, by their attorneys,
Charles E. Shields, III of Mechanicsburg, and William C.
Costopoulos, of Lemoyne, file the following Petition for the
Appointment of a Temporary Fiduciary:
1. Robert M. Mumma, II is an adult individual
currently residing in Bowmansdale, York County (Box 58),
Pennsylvania, and he is a beneficiary under the will of his
father, Robert M. Mumma, the Decedent herein.
2. Robert M. Mumma, II and Gary M. Gilbert are the
court-appointed guardians of the Estates of Susan Mann Mumma and
Marguerite Mann Mumma pursuant to the Order of the Honorable
John T. Miller, of the Court of Common Pleas of York County,
Pennsylvania, Orphans' Court Division, dated October 4, 1991.
The said Susan Mann Mumma and Marguerite Mann Mumma are holders
1299
of shifting executory devises under the duly probated will of
their grandfather, Robert M. Mumma, and are also interested
parties in the administration of his estate.
3. Robert M. Mumma, the Decedent herein, died testate
on April 12, 1986, a resident of Cumberland County, Pennsylvania.
4. The said Robert M. Mumma's will, dated May 19,
1982, and the codicil thereto, dated October 12, 1984, were duly
probated by the Register of Wills for Cumberland County,
Pennsylvania, and letters testamentary thereon were granted to
Barbara McK. Mumma and Lisa M. Morgan, the executrices named
therein.
5. At the time of the Decedent's death, he owned a
fifty percent (50%) interest in a Pennsylvania corporation known
as Lebanon Rock, Inc. ("Lebanon Rock"). This ownership interest
was represented by 5,000 shares of common stock of such
corporation, and it was valued for federal and state death tax
purposes by the executrices of the Decedent's estate at
$50,000.00. The remaining 5,000 shares of common stock of the
said corporation are owned by Robert M. Mumma, II, one of your
Petitioners herein.
6. In addition to his ownership interest in Lebanon
Rock, the Decedent also owned at the time of his death 700 shares
of the outstanding common stock of a Pennsylvania corporation
known as Pennsylvania Supply Company. By reason of such shares,
the Decedent held a 98.31461% ownership interest in Pennsylvania
-2-
1300
Supply Company, which ownership interest was valued for federal
and state death tax purposes by the executrices of the Decedent's
estate at $9,144,473.00. The remaining shares of such
corporation were owned, in equal portions, by the Decedent's four
children, Linda M. Roth, Barbara M. McClure, Lisa M. Morgan (one
of the executrices of the Decedent's estate), and Robert M.
Mumma, II, a Petitioner herein. Attached hereto, made a part
hereof and marked as Exhibit "A" is a chart which depicts the
ownership structure of the Decedent's family enterprises at the
time of his death.
7. Pennsylvania Supply Company was essentially the
hOlding corporation for a number of subsidiary corporations and,
in order to take advantage of certain favorable tax provisions
which were due to expire at the end of 1986, this corporation,
and one of its subsidiary corporations, was liquidated by the
executrices of the Decedent's estate. The executrices have
represented in their First and Partial Account filed herein that
such liquidation occurred on December 19, 1986. By reason of
such liquidation, the Decedent's estate received, in addition to
various other assets, 709.4238 shares of the outstanding common
stock of a Pennsylvania corporation known as Nine Ninety-Nine,
Inc. ("Nine Ninety-Nine"), as well as 900.0761 shares of the 10%
preferred stock of such corporation. These shares represented
33.511% of the outstanding common stock of Nine Ninety-Nine and
81.825% of the outstanding 10% preferred stock of such
-3-
:130:1
corporation. The remaining common and 10% preferred shares of
Nine Ninety-Nine were held as follows:
Shareholder
Common
10% Preferred
Barbara McK. Mumma
Lisa M. Morgan
Barbara M. McClure
Linda M. Roth
Robert M. Mumma II
.5001%
16.472%
16.472%
16.472%
16.572%
1.22119%
4.23556%
4.23556%
4.23556%
4.24703%
8. Since the receipt of the aforementioned common and
preferred stock, the executrices of the Decedent's estate have
transferred the same to themselves, in their capacities as
trustees of the marital trust created under Article Seven of the
Decedent's will. Following this transfer, Barbara McK. Mumma and
Lisa M. Morgan have used a substantial portion of the aforesaid
shares to fund a withdrawal right granted under the Decedent's
will to Barbara McK. Mumma. As set forth in the First and
Partial Account filed by Barbara McK. Mumma and Lisa M. Morgan as
Trustees of the Marital Trust, Barbara McK. Mumma has received,
pursuant to her withdrawal right, 195.842 shares of common stock
of Nine Ninety-Nine, and 118.268 shares of its 10% preferred
stock. In addition, the trustees have paid to Barbara McK.
Mumma, in her capacity as the income beneficiary of the marital
trust, income distributions consisting of 55.58368 shares of
common stock of Nine Ninety-Nine and 70.8421 shares of its 10%
preferred stock. By reason of these aforesaid distributions,
Barbara McK. Mumma has received from the Decedent's marital trust
-4-
1302
251.6788 shares of common stock of Nine Ninety-Nine and 189.1101
shares of its 10% preferred stock.
9. Following the aforesaid distributions from the
Decedent's marital trust, the ownership structure of Nine Ninety-
Nine is now as follows:
Shareholder
Common 10% Preferred
21. 62234% 64.63327%
12.3886% 18.41302%
16.472% 4.23556%
16.472% 4.23556%
16.472% 4.23556%
16.572% 4.24703%
Barbara McK. Mumma and
Lisa M. Morgan, Trustees
Barbara McK. Mumma,
Individually
Lisa M. Morgan,
Individually
Barbara M. McClure
Linda M. Roth
Robert M. Mumma II
Accordingly, Barbara McK. Mumma and Lisa M. Morgan now own in
their individual names 28.8606% of the common stock of Nine
Ninety-Nine, and they vote as Trustees 21.62234% thereof, giving
them more than 50% control of said corporation.
10. The Petitioners herein have filed objections to the
distribution of the aforesaid shares to Barbara McK. Mumma, which
objections are based, in part, upon your Petitioners' belief that
Barbara McK. Mumma and Lisa M. Morgan intend to use Mrs. Mumma's
withdrawal right over the Marital Trust to gain control over the
Decedent's family enterprises in contravention of the Decedent's
testamentary intent. Your Petitioners further believe that
Barbara McK. Mumma ultimately intends to either transfer such
shares by will or gift to her daughter, Lisa M. Morgan, so that
-5-
1303
her daughter will eventually own a majority interest in such
family enterprises, or Barbara McK. Mumma intends to exercise her
controlling vote in order to cause the family business interests
to be sold to third parties, further in contravention of
decedent's testamentary intent.
11. As indicated by the attached Exhibit "A", Nine
Ninety-Nine is the sole owner of a Pennsylvania corporation known
as pennsy supply, Inc., which in turn is the sole owner of a
sUbsidiary corporation known as Elco Concrete Products, Inc.
During the past three years Elco Concrete Products, Inc. ("Elco
Concrete") has been involved in extensive litigation with Lebanon
Rock which, as noted heretofore, is a corporation owned equally
by the Estate of Robert M. Mumma and your petitioner, Robert M.
Mumma, II. Given, as indicated above, the present ownership of
Elco Concrete's parent corporation (Nine Ninety-Nine), the
litigation represents a suit by one corporation (Elco Concrete)
controlled by Barbara McK. Mumma and Lisa M. Morgan, both
individually and as fiduciaries, and another corporation (Lebanon
Rock) owned equally by the Decedent's estate and Robert M. Mumma,
II.
12. The litigation between the aforesaid corporations
is embodied in four separate actions in Dauphin county,
Pennsylvania, and recently was the subject of litigation before
the Pennsylvania Superior Court. Among the principal issues
involved in such litigation is the right of Elco Concrete to mine
-6-
130,1
dolomite in a quarry owned by Lebanon Rock under terms and
conditions economically adverse to Lebanon Rock.
~3. Barbara McK. Mumma and Lisa M. Morgan, although
executrices of the Decedent's estate, have consistently exercised
their controlling interest in Elco in a manner designed to
enhance its profits and value, while undermining the
profitability of Lebanon Rock. This action constitutes a breach
of their fiduciary duty to preserve and protect the value of the
assets of the estate. The executrices have taken such action
(i) because of their deep-seated personal animosity against
Robert M. Mumma, II and the challenges he has raised whenever the
executrices have failed to administer the Decedent's estate in
accordance with the Decedent's testamentary intent, and (ii) in
order to enhance their own individual financial interests in Elco
Concrete even though such interests are directly in conflict with
their fiduciary duties to Lebanon Rock as executrices of the
Decedent's estate. Such financial interests include, but are not
limited to, the 28.860% individual stock interest of Barbara McK.
Mumma and Lisa M. Morgan in the parent corporation of Elco
Concrete, and also the substantial salaries and other benefits
that they have voted to themselves as officers and directors of
Elco Concrete, Nine Ninety-Nine and its affiliated corporations.
~4. Lisa M. Morgan and Barbara McR. Mumma, in their
capacities as executrices of the Estate of Robert M. Mumma, have
further exercised estate's ownership interest in Lebanon Rock so
-7-
1305
as to create a deadlock with regard to the management and
operation of such corporation, thereby fostering their plan to
undermine the value of this estate asset. This plan of the
executrices, which is a matter of public record in the Dauphin
County and Superior Court actions, has been, in sum, to seek the
award of favorable mining rights to Elco Concrete of mineral
deposits owned by and located on land of Lebanon Rock, all to the
detriment and exclusion of Lebanon Rock. The executrices have
also resisted all attempts by your Petitioner, Robert M. Mumma,
II, to acquire the estate's interest in Lebanon Rock and thereby
resolve the current deadlock, even though the acquisition price
offered by your Petitioner is substantially in excess of the
estate's carrying value for such stock.
15. The great lengths to which Lisa M. Morgan and
Barbara McK. Mumma will go to undermine the profitability of
Lebanon Rock and to create a deadlock with regard to its
management and operation is evidenced by the petition they filed
in the Court of Common Pleas of Dauphin County on October 1,
1991, requesting that Lebanon Rock be prohibited from mining
dolomite in its own quarry and selling it to third parties.
Lisa M. Morgan and Barbara McK. Mumma, as
executrices of the Estate, which owns 50% of Lebanon Rock, have
refused to attend any Board of Directors' meetings for Lebanon
Rock or to engage in any dialogue as to whether such mining
activity is likely to be profitable for Lebanon Rock and its
-8-
~306
shareholders, and yet they maintain in their petition that the
mining and selling of dolomite by Lebanon Rock would jeopardize
the continuing viability of Lebanon Rock. On the contrary, the
mining and selling of dolomite by Lebanon Rock has been shown to
be very profitable for Lebanon Rock, and if the executrices would
have attended any Directors' meeting, they would have clearly
seen that to be the case. Instead, however, Lisa M. Morgan and
Barbara McK. Mumma have deadlocked the management and operation
of Lebanon Rock by refusing to attend Board of Directors'
meetings and have sought to undermine the profitability of
Lebanon Rock by filing a petition to prohibit Lebanon Rock from
engaging in a very profitable business venture.
This has been done not out of any concern for the
profitability of Lebanon Rock, as the executrices maintain in
their petition of October 1, but rather to advance the interests
of Elco Concrete, which claims the right to mine dolomite in the
quarry owned by Lebanon Rock. The Superior Court has ruled that
no evidence has been shown of the existence of such a right, and
has remanded the case to the trial court for hearings on that
issue. The advancement of Elco Concrete's interests at the
expense of those of Lebanon Rock represents a conflict of
interest for Lisa M. Morgan and Barbara McK. Mumma as executrices
of the Estate.
16. section 4301 of the Probate, Estates and
Fiduciaries Code empowers the orphans' Court Division of the
-9-
1307
Court of Common Pleas to appoint a temporary fiduciary whenever
the existing fiduciary is "in a position of conflicting interest
or in any situation where his functioning as a fiduciary for a
temporary period may not be in the best interests of the estate."
Given the present litigation between Elco Concrete and Lebanon
Rock, the fact that Lisa M. Morgan and Barbara McK. Mumma, as
fiduciaries, hold substantial ownership interests in both
litigants is a clear case of conflicting interests. Furthermore,
the conflict is all the more egregious in the present instance
since Lisa M. Morgan and Barbara McK. Mumma have used their
fiduciary interest in Lebanon Rock to undermine such corporation
and to enhance their own 28.8606% individual interest in Elco
Concrete.
17. In accordance with the provisions of Chapter 43 of
the pennsylvania Probate, Estates and Fiduciaries Code, your
Petitioners respectfully request that, during the pendency of the
litigation between Elco Concrete and Lebanon Rock, a temporary
fiduciary be appointed in place of Barbara McK. Mumma and Lisa M.
Morgan with respect to the 5,000 shares of Lebanon Rock held by
the Decedent's estate. This temporary fiduciary should be vested
with the same fiduciary powers that Barbara McK. Mumma and
Lisa M. Morgan now hold with respect to such stock, including the
power to sell the same at a price that is fair to the estate and
that reflects the current fair market value of such stock.
-10-
1308
18. Your Petitioners respectfully request that
Barbara M. McClure and Dauphin Deposit Bank and Trust Company,
the substitute fiduciaries under the Decedent's will, be
appointed as the temporary fiduciaries of the Decedent's interest
in Lebanon Rock. In the event that such parties are unwilling to
serve, your Petitioners request this Honorable Court to appoint
such persons or corporations as this Court may deem appropriate.
WHEREFORE, your Petitioners respectfully request this
Honorable Court to issue a citation against Lisa M. Morgan and
Barbara McK. Mumma, the executrices of the Estate of Robert M.
Mumma, to show cause why, in accordance with Chapter 43 of the
Probate, Estates and Fiduciaries Code, temporary fiduciaries
should not be appointed in their place with regard to the
administration of the Decedent's interest in Lebanon Rock.
Respectfully submitted,
/!!!;~ f.~
Charles E. Shields, III
Commonwealth National
Bank Building
2 West Main Street
Mechanicsburg, PA 17055
(717) 766-0209
1.D. #38513
William C. Costopoulos
831 Market street
Lemoyne, PA 17043
(717) 761-2121
Attorneys for Petitioner,
Robert M. Mumma, II
-11-
1309
IN RE:
ESTATE OF ROBERT M.
MUMMA, late of
Cumberland County,
Pennsylvania
: IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 21-86-398
ORPHANS' COURT DIVISION
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Jja II jJ ~;,n,
SS.
Before me, the undersigned authority, personally
appeared ROBERT M. MUMMA, II, who, being first duly sworn
according to law, deposes and says that all of the averments set
forth in the foregoing Petition are true and correct according to
the best of his knowledge or as he is informed and believes.
~~1Vt
Robert M. Mumma, II
Sworn to and subscribed
before me this ~ day
of () OM>elL-- , 1991.
IOTARIAL SEAL
KIMBER~ I A. CROSTLEY, No!&,V' Public
City oi Harrisburg. Dauphin Co.
My Commlssien Expires Jan. 4. 1993
1310
IN RE:
ESTATE OF ROBERT M.
MUMMA, late of
Cumberland County,
Pennsylvania
: IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 21-86-398
ORPHANS' COURT DIVISION
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF D{lJAf'~J:".
)
) 55.
)
Before me, the undersigned authority, personally
appeared ROBERT M. MUMMA, II, aHa GARY M. CILBERT, Co-Guardians
of the Estates of Susan Mann Mumma and Marguerite Mann Mumma,
who, being first duly sworn according to law, depose and say that
all of the averments set forth in the foregoing Petition are true
and correct according to the best of their knowledge or as they
are informed and believe.
1MM.~
Robert M. umma, II, Guard~an
xxxxxxxxxxxxxxxxxxxxxxxxx
~yr}Qllxxa~~J<:~U~~
Sworn to and subscribed
before me this ~" day
of b C'ipitl A... , 1991.
~ m1~~tPpu~{;)iP€u-
NOTARIAL SEAc
KIMBERLY A. CROSTLEY. Notdlv f)ubffc
City of Harrisburg, Dauphin Co.
My Commission Expires Jan. 4. 1993
:1311
IN RE:
ESTATE OF ROBERT M.
MUMMA, late of
Cumberland County,
Pennsylvania
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 21-86-398
ORPHANS' COURT DIVISION
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF (jORK..-
)
) SS.
)
Before me, the undersigned authority, personally
appeared GARY M. GILBERT, Co-Guardian of the Estates of Susan
Mann Mumma and Marguerite Mann Mumma, who, being first duly sworn
according to law, depose and say that all of the averments set
forth in the foregoing Petition are true and correct according to
the best of his knowledge or as he is informed and believes.
~~ ilIA Cif. 02x. 9-
G Y M.\Gilbert, Guardian
NOTARIAL SEAL
LORI A PODGERS, Notary Public
City of YJik. York County
~.Y.9q!'0T:!_~~LQ.r.:...f:::Qi:.-~~~J.O, 1994
1312
CERTIFICATE OF SERVICE
I, Charles E. Shield$ III, certify that a copy of the
attached PETITION FOR THE APPOINTMENT OF A TEMPORARY FIDUCIARY
upon the
was served by first class mail on
following:
Richard w. stevenson, Esquire
McNees, Wallace & Nurick
P.O. Box 1166
Harrisburg, PA 17108-1166, for
Barbara M. McClure
129 S. Lewisberry Road
Mechanicsburg, PA 17055
John Hardin Young, Esquire
Porter, Wright, Morris & Arthur
1233 20th Street, N.W.
Washington, D.C. 20036-2395, for
Linda M. Roth
5104 Wessling Lane
Bethesda, MD 20814
Attorney General
Commonwealth of Pennsylvania
Strawberry Square
Harrisburg, PA 17120
Thomas M. Kittredge, Esquire
Morgan, Lewis & Beckius
2000 One Logan Square
Philadelphia, PA 19103-6993, for
Barbara McK. Mumma and
Lisa M. Morgan
William F. Martson, Esquire
Martson, Deardorff, Williams & otto
10 East High Street
Carlisle, PA 17013, for
Barbara McK. Mumma and
Lisa M. Morgan
(Courtesy Copy)
Robert M. Frey, Esquire
5 South Hanover Street
Carlisle, PA 17013
Charles E. Shields, III
j.313
Donr,<::vjv~ni~ :;r1nnlv ~ilmn;:'l"\/ ~.........
AS portrayec bv figures from
P A I nher tax rewrn filed
7/20/87
(::igures as existing on
d.o.d. 4/12/86)
(Fiegship of the Mumme Family Enterorlses)
Rente I , Reel Estate (Inc. 6/21/21 - PAl
Total 712 Shares
700 est Robt Mumme
3 eeen child
1--------------------1-------------**
I
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-----t---------------------------------------t---------------------------- I
I
I
I
k:"tr" r.,...,
Cp"tpl C..I I'~~ (I~~ R f"S 1"'7 - DA \
Tote! 8,680 Sheres
PA Supply Co
RMM, II
Sisters, ea.
Widow
7,241 (83%)
334 !--
333
106
RMM, II
Vice President
Director
*
llnif"llj
,,.,...,...;~ (\1"1'" '7/?/F-,1 _ OA'
000 In!"" (lr'1r'
I liS/SF< - DA \ I4nlMiM r:~
Quar ry, er-ushed stone
Total 100 Shares Kim Co, SO
Hempt Trustes SO
Total Com. 2,117
Kim Co, 867
RMM, II 314
Bar-bare 312
8% pJ.
267
10% p.L
x
x
103
*( OPERATING COMPANIES)
Linda
Lisa
312
312
61
103
Do
Blog materials, concrete, asphalt
Total 2,500 Shares 999 2,500 (100%)
1'1
im
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- DA \
Mfg, concrete blocks, ready-mix concrete
Total 5,000 Shares
Pennsy Supply 5,000 ( I OO~)
Renta I, equipt, rea J estate
Total 500 Shares
Pennsy Supply 500 ( 100%)
1,100
l,100
x
x
RMM, II
!-- Vice PreSident
DIrector
M'
c C~"'k Inr-
(I
Rental, real estate oevelooment
Total 700,COO Shares
Pennsylvanie SupOly Co.
Each eh ild
100.000 Shares
150,000
( These two were later
merged. )
R . ;:l1; rnr."" (Ihr 7,1Q;f:.C - PAl
Land oevelopment and rental
T ota I 1 0 Shares
Middle Park Inc. 10 ( 100%)
x
x
**( RE.t.,L ESiATE COMPANIES)
According to Robt Mllmma's will--
eact, child was to receive an MIISl
~ share of Penna SUDDlv and
~,1 shares in the real estate
,...t M M m
?Qj7C _ OA)
Rental, PUC hauling (RMM. II - V.P.)
Total I .000 Shares
Pennsy Supply 1,000 ( 100%)
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