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HomeMy WebLinkAbout87-0028COb~MONWE~IT'E OF PENNSYLVANIA In the Court of Common Pleas of COUN?f OF CUM~E.RJ.A~ND Cumberland County, Pennsylvania No.. 28 Civil 1987 Complaint and Notice Rolling Green Memorial Gardens Inc VS Ronald A. Curran and Kathryn Curran Michael E. Barrick X~or Depu:y Sheriff of Cumberland County, Bennsylvania, who being duly sworn according ~o law, says, ~hat he served ~he within Complaint and Notice Curran Ronald A. Curran and Kathryn :he defendant, a: 2:19 o'c!ockP ~pon , EST /X~ on :he 13th day of January , 19 87., 207 RenO Street, New Cumberland ,C.~mberiand County, (s:ree: number) (ci:y or :own) Pennsylvania, by handing ~o Kathryn Curran for both a ~z-ae and a::es:ed copy of ~he Complaint and Notice her an~ at :he same :imm directing a~en~ion ~o ~he con~en~-~ ~hereof and :he ".Md:ice ~o Plead" endorsed ~hereon. Sherlf£'s Costs: So answers_ _ ~'~- -: ~ Docke ting 18.00 ///,~~ Service 9.43 .~fidavi~ WILLL~M K. BECK, Sheriff Surcharge 4.00 $ 31.43 pd. by Sworn and subscribed before me atty 1-13-87 b~v ~, - ' Depu ~f Sherif; ROLLING GREEN MEMORIAL : IN THE COURT OF COMMON PLEAS GARDENS, INC. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : : CIVIL ACTION - LAW V. : KATHRYN CURRAN : 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 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 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. COURT ADMINISTRATOR, THIRD FLOOR CUMBERLAND COUNTY COURTHOUSE CALRISLE, PA 17013 (717) 249-1133 ART~ P.O. Box 11585 3905 North Front Street Harrisburg, PA 17108 (717) 233-7649 Supreme Court No. 07207 ATTORNEY FOR PLAINTIFF ROLLING GREEN MEMORIAL : IN THE COURT OF COMMON PLEAS GARDENS, INC. :CUMBERLAN~OUNTY, PENNSYLVANIA Plaintiff, : : CIVIL ACTION - LAW v. : RONALD A. CURRAN AND : NO. KATHRYN CURRAN : : Defendant. : NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL: COURT ADMINISTRATOR, THIRD FLOOR CUMBELAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-1133 P.O. Box 11585 3905 North Front Street Harrisburg, PA 17108 (717) 233-7649 Supreme Court No. 07207 ATTORNEY FOR PLAINTIFF ROLLING GREEN MEMORIAL : IN THE COURT OF COMMON PLEAS GARDENS, INC. : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF : : V. : NO. RONALD A. CURRAN AND : CIVIL ACTION- LAW KATHRYN CURRAN, : DEFENDANTS : COMPLAINT AND NOW, comes Plaintiff, by its attorney, ARTHUR A. KUSIC, ESQUIRE, and makes its complaint as follows: 1. Plaintiff, ROLLING GREEN MEMORIAL GARDENS, INC. is a cemetary association with offices at 1811 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant RONALD A. CURRAN and KATHRYN CURRAN, are adult individuals residing at 207 Reno Street, New Cumberland, Cumberland County, Pennsylvania. 3. On or about July 15, 1985, Defendants entered into a Retail Installment Contract and Security Agreement with Plaintiff in order to purchase from Plaintiff items subject to security agreement shown on Exhibit "A". 4. Defendants agreed to make consecutive monthly installment payments each and every month until the debt was paid in full, said installments to be in the amount of $25.73. 5. The installment payments were to be due on the same day of each and every succeeding month as per a true and correct copy of the Retail Installment Contract and Security Agreement attached hereto, made a part hereof and marked Exhibit "A". The first installment being due on August 28, 1985. 6. Defendants have not complied with the terms and conditions of said Contract and are now in default in the amount of $2,224.80. 7. The prices charged for such goods and services were fair and reasonable, and were the usual charges made in the trade, and were charges agreed to by the Defendants. 8. Demand has been made by Plaintiff of Defendants for payment of the amount due, but all demands remain unheeded. WHEREFORE, Plaintiff prays your Honorable Court to enter judgment in its favor and against Defendants in the amount of $2,224.80 along with interest and costs of this suit. Respectfu~ AR~IC ,~ E S~O~ffE - ~---~ 3905 North Front Street P.O. Box 11585 Harrisburg, Penna. 17108 (717) 233-7649 ATTORNEY FOR PLAINTIFF Supreme Court No. 07207 ROLLING GRRE~ ME~OAIAL GARDENS, INC, verify t~at the statements made in this Complaint in assumpsit are true and correct and that I am authorized to made this verification on behalf of ROLLING GREEN MEMORIAL GARDENS, INC. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. R~N?REEN MEMORIAL GARDENS, INC. q ROLLING GREEN MEMORIAL GARDENS, INC. oetween Rolling Greef~ Memorial ,Ga/den~, [n~.' v~it~--oHices.- EY ;S~-~ '~arlisle ~os~,:Cam~-iiii,'-~ennsylvania,-'.hemi'n~fte~: called ...... qL. ................... hereinafter called "PURCHASER." WITNESSETH THAT: The Purchaser agrees to buy and the Company agrees to obtain for the benefit of and sell to the Purchaser, subject t~3 the terms and conditions set forth on the front and back ct this Retail Installment Contract and Security Agreement, hereinafter called "Agreement," the merchandise, interment space for the exclusive right of interment of members of the human race. and services itemized below, for which the Purchaser agrees to pay the Company as set forth in this Agreement, including the Finance Charge and other charges set forth in the Federal disclosure Statement. The Purcl3e~s~ grits to Lh.e C(~ean~a s~cur, i,tyinte, re~t In the items specified below as security for the payments due under.this Agreement.:! " ~/[ ~ ~//C'//~1- /1 Or ~¥~.{~//-__ ~ . . PURCH~</E~D~AND SU THE ITEMS B.~ECT 1.-~..Adult I~termentlEnto~bment space (Does not include openings& closing), i l~.~i...I"C ~'._~_,./.':'.~ . ,.~,pr ce $ __/3 '~__ 2. Bronze Mem. o!:iDlization (including cost of installation and deposit to Care Fund) ................/ --Price $ 3. ~, Adult Size Burial Vaults ~. ............................................................... Price $ ....... 4. ' 'Granite'Bases ........................................................................ Price $ ...... -- ' ~ ' .................................................... --_ Price $ 6. __ Document and Processing Fee. ................................ : .............. ' .......... $ 25.00 OF AMOUNT FINANCED: 7._ Cash Sale'PH'ce of ,ter~' Purchased Illems I through 6, ............ : .... , ............ , ...... Price, ___/____~_~_ _'-~' ..... ITEMIZATION _ Down Pa menf'By PurchaserCo sisting Of: Cash ' -- Plus Yrad~:ln 'of "_ .... ::" ..... : ............ $ ~,_~ (~,~ Down Payment) $ _ 9. Amount Finan cqt;I. ~ (Description) $ .,, DISCLOSURES BY ROLLING GREEN MEMORIAL GARDENS, INC. REQUIRED BY FEDERAL LAW ,. AMOUNT FINANCE TOTAL OF TOTAL SALE ANNUAL FINANCED : , "' '" CHARGE PAYM,'"-NTS PRICE PERCENTAGE · 't The amount Of :~ *'; *~ The dollar The amount You The total cost of RATE · ~' ~ ~ credlt*provlded: · amount the will have paint your purchase : The cost of J to you or on .~ credit'will after you have credit your credit as yo ~J al '~ ' COSt~[b~ ~ on ~_~b~?~)~.~ made all including your a ye, arJy rate,.~ :i':, $ $__~/ O" '''~ ~ payments as downpayer~er~.t,c~L, S C h e,d,l, qe. gL.. ~ :~.~ /y~~ I se,e. gabov '" o Your payment schedule will be: Number of Payments" ' Amount of Pa_yments When Paymen_ts Are due' : Late Charge: If a payment is r...~ .. ~t.-~-~, .~r~ ,~ ~ ~, (~.~... ~, ~.)... ' more than 10 days late, you ~ . . will be charged 5% of the · ' "; ' ' ~['~'!,~ . i'~ · ,';~'~-;' 2'~.:~ i-..~'~[,~J~ D (,/'"J'~ payment or $5.00, whichever ........ , .... ' .... '~ ' - · is less, but not 13ss than , - $1.00, SECURITY:. You are giving a security interest in the goods or property being purchased. PREPAYMENT: If~ YOU pay off early, you will not have to pay a penalty and you may be entitled to a-refund of part. of the finance charge. * See other sections of 'the Agreement for any additional information about nonpayment, default, any required payment in full '"before the ~(:heduled~dates,'and prepayment refu, nds. ACCELERATED PAYMENT: The Company shall have the option to require full payment of any Items purchased herein before their use. The Purchaser shall have;the right tO prepay the amount,due herein without penalty. Rebate of unearned finance charges sha be computed under the Ruleof 78's. " * .. . DEFAULT: Time is of the essence of this Agreement, and should the Purchaser default for more than sixty (60) days in any of the payments due herein the Company may, at its option, declare this Agreement null and void and retain all payments made by the Purchaser as liquidated damages, or the Company may, at its option, declare the outstanding balance due and payable upon demand, and the Purchaser agrees to pay on demand all aclual arid reasonable attorney fees, court costs, and other collection costs connected thereto. ASSIGNMENT: Purchaser shall have the right at any time unless in default hereunder to sell or hansfer his tmerest In this Agreement. A transfer must first be recorded upon the books of the Company before it shal become effective, The Company agrees to furnish, upon request, approved transfer forms. ENTIRE AGREEMENT; ~ANGES: This Agreement shall become effectiv~ when signed by an authorized representative of the Company and, together'with the rules and regulations of the Company, contains all of the'covenants and promises between the parties. No agent or representative of the Company'has authority to modify, add to or change any of the lerms and conditions herein set forth, except by a written agreement signed by an officer of the Company : . , . BENEFIT: This Agreement shall apply to aha bind and inure to the benefit of the Company, its successors and assi ns, and to the heir , . mlnlstrators eXecutor~ and asslOrm of tt~e Purchaser and whenever the Purch . . g . s ad ' ' ' .... ' ' , ' astir Is ment oned herein,'lt aha Include the heirs and assigns of the Purchaser es' I1' they were specifically set out ' ~ , PR CE ADJU~TM ENT I~O1~1 MERCHANDISE AND DELIVERY COSTS: If, when the Corn party orders any merchandise purchased herein the cost of such merchandise or its delivery to the Company Is lower than at the date of this Agreement, the Company agrees to refund to the Pur- chaser the decrease in such cost or to credit such decrease against any amounts owed by the Purchaser to the Company. If, when the Company orders any merchandise purchased herein, the cost of such merchandise or Its delivery to the Company Is hlgher than at the date of this Agree- ment. the Purchaser agcees to pay the Company the increase in such cost before the order is placed. For exampled, if the merchandise cost to Rolling Green Memorial Gardens, Inc. Increases $50.00 when ordered, the Purchaser would have to make an additional payment of $50.00 at that time.- -- HEADINGS: The headings.are for convenience only and do not affect the meaning of the provisions of the Agreement. The service charge herein contained does not exceed the equivalent of eighteen (18%) sim pie interest per an. num on the unpaid balance, except that a minimum service charge of seventy cents (70~ per month may be made. ' NOTICE TO THE'BUYER: (1) Do not sign the Agreement before you read it or if it contains any blank space. (2) Youare entitled to a completely filled.in copy of this Agreement. (3) Under the law, you have the right to pay off in advance the. full amount due and under certain conditions to obtain a partial refund of the service charge. ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED THE AMOUNT PAID BY THE DEBTOR HEREUNDER. Purchaser hereby acknowledges receipt of a completely filled in copy of this Instrument and right of rescis- sion form. NOTICE: Intending to be legally bound hereby, the undersigned has signed Ihis Agreement the date first writ. ten above. / ~ccepted b .,,,~~)~~/~ ,,.._/B' ~t~'- Purchaser ~' ' . (Seal) , ~"~ -'~Represen[adve, ~) ~:]~ ~'"~~ /~,/~ Birthdate Co-Purchaser (Seal) You may cancel this transaction at any time prior to midnight of the third business day after tl'~e date above. See the accompanying notice of cancellation form explaining this right. See reverse side for additional terms and conditions. EXHIBIT A · .~ . . . AD?ITIO~IAL TERM~ AND CONDiTiONS '~ The Purchaser and Company agree that at'ar~y time after receipt of all the payments pro¥ided in this A r .quest'of the PurChaSer','.hlS heirs or aSsl ns t e ee enum~erat,,e,.d,.a..n..d_.d.e.s, lgnated as purchased,gsu'b~ ;t tCo°tr~?a,n_.y.'wl!I de. liver to the Purchase~, 'his '-heirs Aor ~; ~-m--en!Lu-P.°.n re- · . I-EIII-,I-/ . {HU lOllOWln terms an . slu,,~, [ne items UAL CARE. It is distinctly un~r;tood that a sum gre~, ,* r~l.d,c~°~n,-d!.t.i-°n-.s'-2 ~ . '.~ .~ ' · ~uire,, ,,/,.,= ,aw~ ut ~ennsylVanla will De set aside with other similar sums, by COmpany in a general Perpetual Care Trust Fund. This amount Is to be paid Into the Trust Fund from the last one or more Installments orat the time of the sale, in the event of a cash sale, before delivery of a deed can be made. The payment into the general Perpetual Care Trust Fund is made only on the original sale of burial lots. The Income from this Fund is to be used for the general care and preservation of the Cemetery's grounds, and for the maintenance, repair, renewal and replacement of all Improvements, buildings and property of said Cemetery,"!ncluding administrative overhead applicable to such care. .-. . . 2. ASSIGNMENT OF SPACE: The Company reserves the right to assign the specific Section and grave numbers of the in- terment spaces purchased hereunder or in the event of a mausoleum purchase, the specific crypt number, and the records of the Company shall be considered 'sufficient and proper evidence of said designation If, for an rea .' contracted for Is not satisfactory to Purchaser within a period of I year from the ·date o~ this A r y son, the ocation hereby and exchange It for any other locatiOn of e ............. . ..... g eement, Purchaser may select · qum mzu uno value anywhere aVallaDle In HOIllng Green Memorial Gardens, Inc. 3, DEVELOPMENT OF SITES: It is understood and agreed that no interment shall be made in a burial Site until the development and Improvement of the section shall have progressed sufficiently to permit burials therein, otherwise transfer · shall be made to a site of similar size in a developed section of Rolling Green Memorial Gardens, Inc. In the case of a mausoleum purchase, if the need for entombment arises before the crypt is available, due to the death of one or more of the Purchasers, the Company may furnish al its expense temporary entombment space, to the extent of the number of entomb. ment spaces purchased herein; provided, however, that each entombment space for which temporary entombment is provided Is fully paid.. Upon availability of the designated crypts, the Company will then transfer the remains that have been placed in temporary entombment into the designated crypt without charge or, at the option of the Company, It may transfer the remains to a crypt of equal value in a completed mausoleum and t 4. CASKETS FOR MAUSOLEUM CRYP ...... ' .... h.e. Purc.hase. r he. ruby consents to such tr .r~es_.p.o.n. slbll.ity'.to use a casket that fit ,,,,r.,..~_o;~t~ls. ?.stlnca.y unoerstood that the P rch~-~, '-,- ~_n,s_fer. . ~ S ~.~,~H U ~_~a_~ ~[ De .0r t pe "so that no ev m_u ~ e olmenslons of the maus --......;_nm nmr8 .or assigns, has the ,,nd that 'it L~[~Y'~I, .... ,,,,..~,n. oev!.dence of dlssul~jtr~e~ may esca,,,,' ......... ~o. leu_m crypts purchased unaer this ,,,~, ,,=o w~m att-~tc'able.laws and re,~ul,.,,'---- -'-~"~ "=- =~? ~Unn in i~ennsylvanla Code 'nH. ,,o .~:'ff'--:'~ .... , 5. OPENING AND CLOSING COSTS: This Agreement does not Include the charges for the opening and closing of u o.,~,.~ as may De In effect now or In the futur~-~'''~"0 4:o,.~..~napmr 1-22B, graves, crypts or niches· Opening and closings shall be done by the Company upon payment according to a schedule of charges available for Inspection at the office of the Company. 6. LETTERING: Unless specifically set forth herein, this Agreement does not Include the charges for lettering of crypts or niches. To establish and maintain a uniformity of lettering and/or inscribing, It is required that all mausoleums and creme. tion niches be inscribed and/or lettered and that any and all such lettering and/or Inscribing shall be done by upon payment therefore according to a schedule of char 7, CONVEYANCE: Upon fulfillment of ,......~,fln~es_.a.v~llable for Inspection at the Corn an's off the Company the ,.,,,,u, ..... a Ol' this Anraa,,,..-, __2 ........ P Y ice. pany agrees and' binds itselfto con~,ey'to the Purcha ,, ......., a.u receipt ct all required payr~ents, purposes only/the afore 8er, by its cemete dee the Com- ado t ' said, site s.u, bjeqt'to all rules and, r ry d in the usual form, for Interment _ p ed for. the governln of the M,,-".--i'-,·',-,-'--. _ ~ :egu. lations,...of the Company ....... , .....: .... or e. ntombment ~ompanv-s off ,~ ' g . . ........... ,=, ~=aroens. salo.rules and i'enUlat ~,,,o",7.~' ..... ,=~,aung or wnlcn, may hereafter be . lc.. . ,. i ....... y be seen.upon, request, ,~t the Cemetery . 8. INDIVIDUAL MEMORIALS: The Company agrees t~) Install upon~requ%t of the Purchaser hi ' ' ' subject to the'rules and regulations of the Corn a ~ ' Individual memorJ r p ny, Individual memori ~ ' e heirs or assl nS and als shall consist of.a bronz · als, Jf,,enumerated and de I 'x g ' and shall bear the nemean .... , _= ,:,.;L z.e .P~a!.e a.fflxed to a cast stone ba , ,.,.h .... s gn.ated as purchased. Said dx,==,= u~ u,rm aha cleath of the individual, and. s?, ...... = re_commonly sold b_y the Compan '--~ ....... Gardens,Jnc._. .... g. C.oMpAN[~N M~3:he.(~:..Z.: ........ , Installation shall be made in ,oiling ereen MemorlaY~ ,-puny agrees to ................................ : ' -"~'~ ....... install; UpOn request of the PurChaser, his heirs or assigns, and subject to thb rules and regulations of the Company, a companion memorial with vase, If enumerated and designated as pur- chased. Said memorial to be placed only after an interment of one of the Purchasers has been made. Said companion memorial shall consist of a bronze Plate affixed to a cast stone base, such as Is commonly sold by the Company. Said memorial shall bear the family name, christian names, and years, of birth and death of the Interred, and Installation shall be made in Rolling Green Memorial Gardens, .Inc,-~ ' 10; .'GRANITE BASESfThe COmpany agrees to Install, upon request of the Purchaser;'his heirs or assigns, and subject to the rules and regulations of the Company, granite'bases If enumerated and designated as purchased. Said Installation shall be made In Rolling Green Memorial Gardens, Inc .. 11. BURIAL VAULTS: Upon order of the Purchaser, his heirs or assigns, If enumerated and designated as purchased, the Company shall Provide and Install for Interment in Rolling Green Memorial Gardens, Inc., burial vaults of adult size. Said burial vaults shall be made of reinforced concrete with a do 12. GUARANTEE OF PERFORMANCE. In or-~ .... _mud lid:_ ~ . . u,=, ~u assure rrm performance of the delivery Of the merchandise and services covered by this Agreement, the COmpany agrees that it will set aside and place in a trust fund, separate and apart from all other funds, sufficient money based upOn,its costs and its present wholesale costs With reliable manufacturers, to [: ay for said mer. chandise and services when delivered' The amounts placed Into said trust fund shall remain Intact In the said trust fund for the · express purpose of payment for t.h_e merchandise and services and be sub ect to °:~: therefrom tO"b· Ui~ed.fd~!fle~est !l~terests. oFt ..~ _;. _..~ J .... , ~the:termeof: heTruM ,, _ he Company, ur its nominees '~is': .... ~1~. ;. ,A~[qff~er;.,~the,!ncom~, , It~ BO~a~c~ of Directors ~a~ determine. The ' amount of money to be placed in said fund as herein provided shall be determined by the Company's costs in accordance with Its present day costs and cOntracts with reliable manufacturers, copies of which are on file with the Trustees, Trust Agreement. The amount of money to be lace the ti.m_ e_o.f, the sale,' In the event'Of a Cash saPl ~, d In the Trust Fund Is t,o be paid from the last one named In the ~1. rIMEOFOBT .eL.: _ ' ; ...... ~.~. ~: .~ ? °rm0. m.!,~tallments orat. at AINING MERCHANDISE [ne r, Jompany shall have the option to order and obtain before 'need and's the Company,S expense all merchandise items urc 14. IMPOSSIBILITY OF PERFORMA c.~, .~uaP~-,c-.h.a-s-e-d herein, tore N ..... O/l/U~E MERCHANDISE: Company agrees that it will endeavor to the best of its ability; with all of the facllitle~ under Ifa nonfrol to perform in the fur,are a< h=rel~ agreed, but in the even* of war, riot, in- surraction, Acts Of God or for Other causes beyond the control of the CompanY,'lt should be impossible to deliver the exact merchandise described herein because necessary materials are not available; the Purchaser,his heirs, or assigns, will merchandise which, to the best of the Corn an's quality as Possible with m ,,,,,,.,. _.n_~_~_y,, .a. blllty; w. ill be a substitute therefore s n ' _ .accept aterlals _,,,,.. mu avanaDle ana at a cost to the Combe .... n, =aJ,.._ea~.rly ~..ompara. bl.e In character and merchandise as of. the date of this Agreement. If said .... x ..... ,,eeo~ng the cost ct such unavailable substitute merchandise shall be lower in cost to the Co~pany than that of the unavailable merchandise at the date of this Agreement, then the Company agrees to refund to the Purchaser the dif. ferance In said costs. If ~thls ,'Agreement provides for::the purchases of bronze individual grave markers or a companion mum°rial,the Purchaser; his heirs or'aa, signs, has. the Option and right not to accept substitute delivery when bronze Is ·made available, subjeCt to the price adjustment provision herein, merchandise, but to accept · /~ssign No. L/~ Cou__p_on Book "~ ~ ' ' ,, '::'~ Volume Book' ..::.'.:: .,Cml Cert. · : Reco~'o,~ [o, C,,,'d~._ '~.: f"'~';'y P,'~,t. .~_.~iI : ~ O~d Account ZC~rd . "x ' v'; i..h "~-,t .... ---~-T'- ............ ::J: '.Z .~ Fil.- PENN~ No. ROLLING GREEN MEMORIAL GARDENS, INC., Plaintiff RONALD A. CURRAN AND KATHRYN CURRAN, Defendants COMPLAINT ~.I beF,?Y?~'rtlfY ~hat the w~t, hirL ~t~ ~ ,~,iT~,~:l fil.c~ i,, this action~ ~t~ ;'¥ :J [ ..~t ia 20 days 9.f ~,' ' [' ;.~Jgment may ~~ A. KUSIC