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Home My WebLink About05-2146 Johnson. Duffie, Stewart & Weidner By: Michael J. Cassidy I.D. No. 82164 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mjc@jdsw.com Attomeys for Plaintiff KEYSTONE ACCEPTANCE CORPORATION, 2010 State Road, Camp Hill, PA 17011 Plaintiff IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNT PENNSYLVANIA NO. 0-5~~ ..)..1'10 v. GREGORY & SONS, INC., 154 Leaders Heights Road, York, PA 17403; and CIVIL ACTION - LAW JURY TRIAL DEMANDE CABOT R. GREGORY, 154 Leaders Heights Road, York, PA 17403 Defendants PRAECIPE FOR ENTRY OF CONFESSED JUDGMENT FOR MONEY TO THE PROTHONOTARY: Enter judgment in favor of the Plaintiff and against the Defendants Gregory & Sons Inc. and Cabot R. Gregory, jointly and severally, by confession on the attached demand judg ent note with provisions for costs of suit, and without stay of execution. Assess Plaintiffs damag as follows: Nature of Damaaes Amount Interest from April 4, 2005 (18% APR) $ 84,544.00 $ 375.24 $ 84,919.24 Amount of Note Total Amount Due: Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDN R By:[' C~ Michael J Cassidy, Esq. I. D. No. 82164 301 Market Street POBox 109 Lemoyne, PA 17043 (717) 761-4540 Attorney for Plaintiff AND NOW, this ,~Yday of April, 2005, judgment is entered in favor of the P aintiff and against the Defendants, Gregory & Sons, Inc. and Cabot R. Gregory, and damag s are assessed as above in the sum of $84,919.24. {, Prothonotary csj:249179 13333~1 r- 2 Johnson. Duffie, Stewart & Weidner By: Michael J. Cassidy I.D.No.82164 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mjc@jdsw.com Attorneys for Plaintiff KEYSTONE ACCEPTANCE CORPORATION, 2010 State Road, Camp Hill, PA 17011 IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNT PENNSYLVANIA Plaintiff v. GREGORY & SONS, INC., 154 Leaders Heights Road, York, PA 17403; and NO. CIVIL ACTION - LAW JURY TRIAL DEMANDE CABOT R. GREGORY, 154 Leaders Heights Road, York, PA 17403 Defendants CERT/F/CA TE OF RESIDENCE certify that Plaintiff, Keystone Acceptance Corporation, business located at 2010 State Road, Camp Hill, Cumberland County, Pennsylvania 17011 and that Defendants, Gregory & Sons, Inc. and Cabot R. Gregory, have a principal place of busi ess located at 154 Leaders Height Road, York, York County, Pennsylvania 17403. I unders and that false statements made in this certificate are sUbject to the penalties of 18 P.C.S.A. 94 04, relating to unsworn falsification to authorities. DATE: f. 2/.0'> JOHNSON, DUFFIE, STEWART & WEIDNER By: L-- c~ Michael . Cassidy, Esq. .. $84,544.00 Camp Hill, Pennsylv nia April 4, 2005 DEMAND JUDGMENT NOTE FOR VALUE RECEIVED, GREGORY & SONS, INC., a Pennsylvania Corporation, and CABOT R. GREGORY, an adult individual, (hereinafter collectively re rred to as "Maker") hereby promise to pay to the order of KEYSTONE ACCEPTANCE CORPO ("Payee") the principal sum of $84,544.00, together with interest accrued thereon from t e date hereof until the date of payment at a rate of eighteen percent (18%) per annum, imm diately upon demand on April 15, 2005 ("maturity"). If Maker fails to pay at maturity any portion of the principal and interest owing her under, then Maker shall be in default and interest shall commence to accrue thereon until aker's indebtedness to Payee is paid in full, including the period following entry of any judgment, at the continuing interest rate of eighteen (18%) per annum, together with 10% added for alto ney's fee for collection. and payment of the same may be enforced and recovered by the e ry of MAKER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY A TTO IN judgment on this Note and issuance of execution thereon. Time is of the essence of this N te. OR ATTORNEYS OR THE PROTHONOTARY OR CLERK OF ANY COURT OF RECO THE COMMONWEALTH OF PENNSYLVANIA OR ELSEWHERE, TO APPEAR FOR MA IN ANY SUCH COURT IN AN APPROPRIATE ACTION THERE BROUGHT OR TO BE BROUGHT AGAINST MAKER AT THE SUIT OF PAYEE ON THIS NOTE AND THEREI TO CONFESS JUDGMENT AGAINST MAKER FOR ALL SUMS DUE BY MAKER HER IN, TOGETHER WITH COSTS OF SUIT AND ATTORNEY'S FEE FOR COLLECTION AS AFORESAID; AND FOR SO DOING THIS NOTE OR A COPY HEREOF, VERIFIED BY AFFIDAVIT, SHALL BE A SUFFICIENT WARRANT. THIS WARRANT OF ATTORNEY SH LL BE EFFECTIVE ONLY AFTER MAKER'S DEFAULT. IIf" ..' The remedies of Payee provided herein or otherwise available to Payee at I w or in equity and the warrants of attorney herein contained shall be cumulative and concur nt and may be pursued singularly, successively, or together at the sole discretion of Payee, a d may be exercised as often as occasion therefore shall occur. The failure to exercise any su h right or remedy shall in no event be construed as a waiver or release of the same. Maker hereby releases Payee and said attorney or attorneys from all errors. defe ts, and imperfections whatsoever in entering judgment by confession hereon as aforesaid or in suing , , any process or instituting any proceedings relating thereto and hereby waives all bene it that might accrue to Maker by virtue of any present or future laws exempting any property, eal or personal, or any part of the proceeds arising from the sale of any such property, from attachment, levy or sale under execution, or providing for any stay of execution, exemptio from civil process or extension of time, and agrees that such property may be sold to satisf any judgment entered on this Note, in whole or in part and in any order as may be desired by P yee. Maker (and all endorsers, sureties and guarantors) waives presentment for pay ent, demand, notice of demand. notice of non~payment or dishonor, protest and notice of prot and shall not be affected in any manner by any indulgence, extension of time, renewal, w this Note, and all other notices in connection with the delivery, acceptance, perform nee, default, or enforcement of the payment of this Note. Liability hereunder shall be unconditi nal or modification granted or consented to by Payee. Maker shall pay the cost of any revenue, tax or other stamps now or hereafter requ red by law at any time to be affixed to this Note, and if Maker fails or refuses or is not leg lIy permitted to do so, Payee may, at its option, accelerate this Note to maturity as in the cas of default by Maker. The words "Payee" and "Maker", whenever occurring herein, shall be deemed d construed to include the respective heirs, personal representatives, successors and assigns of Payee and Maker. This instrument shall be construed according to and governed by the law of the Commonwealth of Pennsylvania. Notwithstanding any provision contained herein. Maker's liability for the pay ent of interest shall not exceed the limits now imposed by applicable usury law. If any provisio Note requires interest payments in excess of the highest rate permitted by law, the prev sion in question shall be deemed to require only the highest such payment permitted by la Any amounts theretofore received by Payee hereunder in excess of the maxil:num amo~nt of i terest so permitted to be collected by Payee shall be applied by Payee in reduction of the outst nding principal balance (in which event any applicable pre~payment prohibition or premium 5 all be waived with respect to the amount so pre-paid) or, if this Note shall have theretofore bee paid in full, the amount of such excess shall be promptly returned by Payee to the Maker. IN WITNESS WHEREOF, Maker has duly executed this Note the day and yea first above mentioned, and the undersigned hereby warrant that he is authorized to execut this Demand Judgment Note on behalf of Maker. Signed, sealed and delivered in the prese.,n"",~io~/ iL/ , ... SL l , ,.,. I 1-' . " i/ ; Witness:' ,0 . ~ I II tl MAKER: By: Witness: i ,? j{' ,,I , i f ~j{/ Title: ~. DISCLOSURE FOR CONFESSION OF JUDGMENT Being duly sworn according to law, the undersigned jointly and severally depo e and say that: 1. They jointly and severally are indebted to Keystone Acceptance Corpor tion in the amount of $84,544.00. 2. They are over twenty-one (21) years of age, not within the military service United States and its allies, nor otherwise within the civil relief provisions of the Soldier and Sailors Civil Relief Act of 1947. as amended. 3. They certify that they have annual income in excess of $10,000.00. 4. They are indebted to Keystone Acceptance Corporation (the "Lender") in the principal amount of $84,544.00 and to secure said obligation have delivered to the Lend r a Demand Judgment Note containing a Confession of Judgment. 5. They understand that a Confession of Judgment upon default allows for the e try of a judgment by confession against them without prior notice and that said judgm nt encumbers all real estate that they own. 6. They acknowledge that the debt incurred to Keystone Acceptance Corporation 'n the amount of $84,544.00 was incurred for the operation of a business and not for person I, family or household use. IN WITNESS WHEREOF and intending to induce the Lender to complete the transactio as provided, the undersigned have affixed their hands and seals this Y-<'9'-~ay of April, 2005. C Cabot R. Gregory ., - COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF On this, the if f'- day of ~ ' ' 2005, before me, a Notary Public, the undersigned officer, personally appeared CcJH'f /i', ~~ ' who acknowledg d himself to be the pj\ PA'4.f"u-if of GRE(30RY & SONS, IN ., a Pennsylvania corpo atlon (the "Corporation"), and that he as 7/'.f1-1A'p.nr , being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the nam of the Corporation by himself as 'fl, P # ld.u..j- . IN WITNESS WHEREOF, I have hereunto set my hand and official seal. - "a//~~A_ <-;0{/2{CA, Notary Publl Notarial Seal Sltetby A. Minich. Notary Public Camp Hil1 Boro. Cumberland County My Commission Expires Aug. 20, 2005 Member, Pennsytllanja AssociationofNotaries COMMONWEALTH OF PENNSYLVANIA COUNTYOF ~~ 55: ,... , On this the 1/ day of ~ ' 2005, before me, the undersigned personally appeared CABOT R. GREGORY, known to me (or satisfactorily proven) to be th person whose name is subscribed to the within instrument, and acknowledged that he exec ted the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. . L'h.d./<<<r '--1!u';'" ~L Notary Public Notarial Seal Shelby A. Mini<:h, Notary Publie Camp Hill Bora. Cumberland County My Commission Expires Aug. 20, 2005 ,..c;:i'?47~J:;R CERTIFICA TE OF SERVICE ,] ,YJ,vY- AND NOW, this ~day of April, 2005, the undersigned does hereby certify tha she did this date serve a copy of the foregoing documents upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at L moyne, Pennsylvania, addressed as follows: Cabot R. Gregory 154 Leaders Heights Road York, PA 17403 Gregory & Sons, Inc. 154 Leaders Heights Road York, PA 17403 By: ~ ~~, r. (\~~ -...... ...s;,. - ...... ~ \.i' €:' \1" \:\ ; '}.J' '1\\ IA t" L- \ o ~z~ -r} i~_f' \j-"i .\ :.-( - ,,: (.;] 2' ~~.-' ~'-'.i .":c' - ;yo (- ~ ..., c:? o:.;.~) co' :P" -:J ;;OJ N U1 ~..., ~ () ~n .-< :T:-n rT1.r:: _""jj"T1 ::j(::) ('\ \ j~.)\ ._, ."I} ';'_'~ (...) ,/,'}t"l ~A .",:~ .].) ~< s:- o _J - ~ Johnson, Duffie, Stewart & Weidner By: Michael J. Cassidy 1.0, No, 82164 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendant KEYSTONE ACCEPTANCE CORPORATION, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. Plaintiff NO. 05-2146 v. CIVil ACTION - LAW GREGORY & SONS, INC., CABOT R. GREGORY, JURY TRIAL DEMANDED Defendants PROOF OF SERVICE /)11, AND NOW, this ~ay of May, 2005, the undersigned does hereby certily that she did, on May 5, 2005, serve a copy 01 the Proof of Service of Notice of Defendant's Rights upon the other parties of record by causing same to be deposited in the United States Mail, first class, Certified Mail, Return Receipt Requested, Restricted Delivery, postage prepaid, at lemoyne, Pennsylvania, addressed as follows, as confirmed by the signed receipts attached hereto as Exhibit A: Cabot R. Gregory 154 leaders Heights Road York, PA 17403 Gregory & Sons, Inc. 154 leaders Heights Road York, PA 17403 osj:249999 13805-1 JOHNSON, DUFFIE, STEWART & WEIDNER ;J () .:/ By: L Ii{ V-<'t.-<. ~. ./ . fW/ Carleen S. Jensen ~.__// EXHIBIT "A" . Complete items 1. 2. and 3. Also complete item 4 If Restricted Delivery Is desired. . Print your name and address on the l'9Verse so that we can return the card to you. . Attach this card to the back of the mailpiece. or on the front n space pennils. 1. Article Addressed to: (~j:>&t 02 CI.t,;)", ff ," 151 ~rlUJ U'~/tf.5 /(.,.{L tik, Ole 11'-(63 3. SOrv)lo Type ID1:ertmed Mall 0 Express Mall o Registered 0 Retum R_pI for Men:handlse o Insured Mall 0 C.O.D. .. Restricted Delivety? (Extra Fee) ~ 2. ArtIcle Number (f1B1lSfor '""" ssrv/ce label) PS Form 3811. February 2004 7004 0750 0002 7283 1657 Domestic Return Receipt 102595-Q2-M-1540 . Complete ttems t, 2. and 3. Also complete ttem 4 n Restricted Delivery Is dsslred. . 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 maiiplece. or on thelront W space pennits. 1. ~Cle Addressed to: G rer'd' r Son', /nc " /C,,/ ~L~ U~ /(<-;/15 HJr~, ~ 17,/03 O. Is delivery address d\fferent from item 1 If YES, enter de\lV&lY address below: ;;7 I) 1("- 3. SOrv.Jl'e Type lIl"tertffied Mall 0 Exp.... Mall o Registered D Return Receipt for Merchandl6e o Insured Mall 0 C.O.D. .. Restricted DellvefY? (Extra Fee) ~ 2. Article Number (1"""'-,""" _label) PS Form 3811. February 2004 7004 0750 0002 7283 1640 Domestic Retum ReceIpt 102595-02-M-1540 ~ CERTIFICA TE OF SERVICE AND NOW, this ~day of May, 2005, the undersigned does hereby certify that she did this date serve a copy of the foregoing documents upon the other parties of record by causing sarne to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Cabot R. Gregory 154 leaders Heights Road York, PA 17403 Gregory & Sons, Inc. 154 leaders Heights Road York, PA 17403 JOHNSON, DUFFIE, STEWART & WEIDNER /1 /"l .. '~ ..' ,/ / ,. \ By: ~'>L/ 4 /~ Carl n S. Jensen l. / ," rOO) ~"' ,.--) (:_~ :) <::-il '-'h -:;} \\\ w ~"', ':} r<'; ...J.'-, _J "':, Johnson. Duffie, Stewart & Weidner By: Michael J. Cassidy I.D. No. 82164 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mjc@jdsw.com Attomeys for Plaintiff KEYSTONE ACCEPTANCE CORPORATION, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2146 CIVIL ACTION - LAW JURY TRIAL DEMANDED v. GREGORY & SONS, INC., and CABOT R. GREGORY, Defendants CERTIFICA TE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff hereby certifies thaI: 1) A Notice of Intent to serve the subpoena, with ia copy of the subpoena attached thereto, was mailed or delivered to each party at least 20 days prior to the date on which the subpoena was sought to be served; 2) A copy of the Notice of Intent, including the proposed subpoena, are attached to this certificate; 3) No objection to the subpoena has been received; and 4) The subpoena to be served is identical to the subpoena attached to the Notice of Intent. By: L.- - d (" -------. Michael J. Cassidy, Esquire Attorney 1.0. No. 82164 301 Market Street P.O. Box 10!~ lemoyne, Pi\ 17043-0109 Telephone (i'17) 761-4540 Attorneys for Plaintiff -- DATE: 71;j,~ Johnson. Duffie. Stewart & Weidner By: Michael J. Cassidy 1.0. No. 82164 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mjc@jdsw.com Attorneys for Plaintiff KEYSTONE ACCEPTANCE CORPORATION, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2146 CIVIL ACTION - LAW JURY TRIAL DEMANDED v. GREGORY & SONS, INC., and CABOT R. GREGORY, Defendants NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Gregory & Sons, Inc. and Cabot R. Gregory, Defendants 154 Leader Heights Road York, PA 17403 PLEASE TAKE NOTICE that Plaintiff intends to serve a subpoena identical to the one attached to this notice. You have 20 days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. JOHNSON, DUFFIE, STEWART & WEIDNER DATE: By: t.-:.- ('-=- Michae~:asSidY, Esquire Attorney I.D. No. 82164 301 Market Street P.O. Box 109 lemoyne, PA 17043-0109 Telephone (".717) 761-4540 Attorneys for Plaintiff COMMONWEALTH OF PENNSYl.v ANIA COUNTY OF CUMBERLAND KEYSTONE ACCEPTANCE CORPORA nON, Plaintiff vs. File No. 05-2146 GREGORY & SONS, INC., CABOT R. GREGORY, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Alex Lvon & Son Auctioneers ofHeavv C.onslruction Eauioment. P.O. Box 610. RD 2. Bridgeoort. NY 13030 (Name of Person or Bntity) Within twenty (20) days after service of this subpoena, you are ordered by the "ourt to produce the following documents or things: PLEASE SEE RECORDS DESCRIPTION ADDENDUM at Michael J. Cassidv. ESQuire. Johnson. Duffie. Stewart & Weidner. 301 Mark"t Street. Lemovne. PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You bave the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED A T THE REQUEST OF THE FOLLOWING l'ERSON: NAME: Michael J. Cassidv. Esouire.. Johnson. Duffie. Stewart & Weidner. P.C. ADDRESS: 30 I Market Street Lemovne. PA l7403 TELEPHONE: (717) 761-4540 SUPREME COURTID # 82164 ATTORNEY FOR: Plaintiff By the Court: DATE: Seal of the Court Prothonotary Deputy Johnson. Duffie, Stewart & Weidner By: Michael J. Cassidy 1.0. No. 82164 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 mjc@jdsw.com Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEYSTONE ACCEPTANCE CORPORATION, v. NO. 05-2146 GREGORY & SONS, INC., and CABOT R. GREGORY, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED RECORDS DESCRIPTION ADDEI'IDUM TO: Alex lyon & Son Auctioneers of Heavy Construction Equipment Explanation of Records: All documents related to the sale of one (1) Kobelco SK220lC Excavator (Serial No. llU2013 and one (1) Hypac C754B Roller (Serial No. 101650141491), (hereinafter collectively referred to as "the equipment") at an auction conducted in Harrisburg, Pennsylvania (Penn National Race Track, Grantville, PAl on or about October 4, 2003, including but not limited to, all documents related to: 1. Any agreement with or representation made by the Seller (believed to be either Gregory & Sons, Inc. or Cabot R. Gregory); 2. The identity, including the name and addres~; of the Purchaser(s) of the aforementioned equipment, together with copies .)f all sales contracts related to the purchase of the equipment; 3. Copies of auction records identifying the Purchaser(s) of the aforementioned equipment; and 4. Any other documents related to the sale or purchase of the aforementioned equipment which relates to any representations made by the Seller regarding ownership of the equipment, having free and clean title to the equipment or having authority to convey title to the equipment. . :253229 CERT/FICA TE OF SERVICE AND NOW, thi~1 ~ day of~U. ,2005, the undersigned does hereby certify that she did this date serve a copy of the foregoing appearance upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Cabot R. Gregory 154 Leader Heights Road York, PA 17403 JOHNSON, DUFFIE, STEWART & WEIDNER By ~~~~cf2 Eli eth l.. Zieg er CERT/FICA TE OF SERVICE AND NOIIV, this /1 ~ day of _::11 lid _ _, 2005, the undersigned does hereby certify that she did this date serve a copy of t~appearance upon the other parties of record by causing same to be deposited in the United States Mail. first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Cabot R. Gregory 154 leader Heights Road York, PA 17403 JOHNSON, DUFFIE, STEWART & WEIDNER ~&2 By: ,J.d:. E rzabeth L. z~ q <" (. ~~; :::+ -< ,..., C~ <-= "" (-- c: .. 'f\ -\ :T:""T'1 rnr:= -r1 ,11 :fo7 C)(") ;t~~~ '----'m ~ ~!:-.,. CoD :< N -0 _.~: w c:> 0:> Johnson, Duffie, Stewart & Weidner By: Michael J. Cassidy I.D. No. 82164 30 I Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 KEYSTONE ACCEPTANCE CORPORATION, Plaintiff v. GREGORY & SONS, INC., CABOT R. GREGORY, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. NO. 05-2146 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE TO THE PROTHONOTARY: Please mark the above-captioned matter settled and discontinued. cLncl sa+.'s.fy. Date: 12.l3'OS- ead:265500 JOHNSON, DUFFIE, STEWART & WEIDNER By: C '_\C ~ Michael? CaSSidy Attorney 1.0. No. 82164 301 Market Street P.O. Box 109 lemoyne, PA 17043-0109 (717) 761-4540 Attorneys for Plaintiff CERTIFICA TE OF SERVICE AND NOW, this J7J!day of Oec.........kr , 2~1he undersigned does hereby certify that he did this date serve a copy of the foregoing PRAECIPE upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Patrick Lauer, Jr., Esq. 2108 Market Street Camp Hill, PA 17011 ~~H~UF4~ WEIDNER C en S. Jense (~.., .-::; U'j "-0 ~') ':::"':> C-FI o .1 --j :r:." rnf':: (~; <:J p-: C) "" 0> -q 1'.'