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Home My WebLink About06-1086 SILVERMAN BERNHEIM & VOGEL BY: Daniel S. Bernheim, 3d, Esquire Lauren R. Berschler, Esquire Idcntilication Nos.: 32736 & 88209 Two Penn Center Plaza, Suite 910 Philadelphia, PA 19102 (215) 569-0000 CITTZENS BANK OF PEN1"SYLV ANIA 801 Market Street Philadelphia, PA 19106 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff v. NO.OG ..IOPL C;u',lls hi FRANK ALBANO, III 36 Weatherburn Road Enola, P A 17025 Defendant NOTICE TO DEFEND You have been sued in court. Ilyou wish to defend against the claims set lorth in the lollowing 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 tiling in writing with the court your defenses or objections to the claims set I(lrth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice t(lr any money claimed in the complaint or ](lr any other claim or relief requested by the plaintitf You may lose money or property or other rights tmportant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE orFICr: SET FORTI I BELOW. TIHS OFFICE CAN PROVIDE YOU WITIIINFORMATION ABOUT HIRING A LA WYFR. IF YOU CANNOT AFFORD TO I IlRI:: A LA WYER.THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEI'. COURT ADMINISTRATOR 4TH Floor, Cumberland Couuty Courthouse Carlisle. PA /7013 (717) 240-6200 I:\\il'(' 'T'J)()( Sc1-01l5(1'Alhano-lh"('ol1lplainI.lJ2::'] 06, \\pd II SILVERMAN BERNHEIM & VOGEL BY: Daniel S. Bernheim, 3d, Esquire Lauren R. Berschler, Esquire Identitication Nos.: 32736 & 88209 Two Penn Center Plaza. Suite 910 Phi ladelphia, P A 19102 (215) 569-0000 CITIZENS BANK OF PENNSYLVANIA SO I Market Street Philadelphia, PA 19106 COURT OF COMMON PLEAS CUMBERI AND COUNTY Plaintiff v. No.O~-IC>f!c, CiuL~, FRANK ALBANO. III 36 Weatherburn Road Enola. P A 17025 Defendant COMPLAINT - CIVIL ACTION Plaintiff. Citizens Bank or Pennsylvania. by and through its counsel. Silverman Bcrnheim and Vogel, respectfully tiles this Civil Action Complaint against Defendant. Frank Albano. 1[1. and in support thereor avers as follows: I. Plaintitl Citizens Bank or Pennsyfvania ('"Citizcns"). is a state chartcd banking institution with a registered place of business at SO I Market Street. Philadelphia. PA [9 [06. 7 Detendant, Frank Albano. ('"Albano"). is an individual who is believcd to rcside at 36 Weatherburn Road. Enola.PA 17025. COUNT I BREACH OF CONTRACT 3. Citizcns incorporates by rcterence paragraphs I through 2 inclusive as irset I()rth in their entirety. \\VI'I.' In, )t'S"A\l(l'iO"'Albano-l f/Colllphlln(()::':211)!l\\pd I " YERlFICATION I, Michael Hecht, being duly sworn a<:cordiug to law., depose and say that I am a legal specialist with Citizens Bank of Pennsylvania and say that the facts set forth h1 CitizOlls Bank's Civil Action Complai.ut ar.e true and correct to the best of my knowl edge, information and belief, I understand that the statements therein are made subject to the penalties of 18 Pa.C.S.A. S 4904 relating to unsworn falsification to authorities, wL..; MICHAELHECBT Dated: diu-ill I, , ".WPC ;l\nOCSIl1664IR.1It",,,.l341C<>,,,ploinLOSl405. ",pO ;;-.. r_ . \v (2.~ IS: 1!12 S" ~"OH CITIZENS ; '~lV" 91aelil~J;57l5 GlEIl31 "PQE.6l!I1'ElIllI NO,475 : ,~ .- i 'l:T4nJ ~.. .IJ. -::""'nllliY:1?~. ." '~JJ""S (/}7it77) Sf- 'r7!7i1~.rn Pa..-. $.. l"1'CB'r l.l""""-_'" ~_... , ~~'1:1? CjJ/L{~~. /(,IJ-~~=~_.".... ~'~~__-1//~... ~. 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EXHIBIT "B" ~~ Citizens Bank PO BOX 9665 PROVIDENCE, RI 02940-9665 Account Number 4798153200011737 Payment Due Date SEP 17. 2005 Amount Due 1II",.,I,II,I",I"II!",I,I",ll",II",I,I,II,.,ll",I,I"J * PO BOX 9665 PROVIDENCE, RI 02940-9665 New Balance $539.10 $9,027.81 Amount Enclosed 1$ ROBER TO 'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA IlIII For proper credit. pleClsemLlilpaymentsto::Jddressatleft P<lymentsrecelvedalanyotherloc<Jtionmaydel<:lycmdiling YOUf L1ccounl Lip to fivedLlYS 000000 4798153200011737 000053910 000902781 Please detach and relurn with your paymenl ~~ Citizens Bank Account Summary For: ROBERTO'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 Account Information: Account Number: 4798 1532 0001 1737 Total Credit line: $10,000 Available Credit: $972 Days In Billing Cycle: 31 Billing Information: Statement Date: Payment Due date; Amount Due: Past Due Amount: Disputed amount: AUG 23, 2005 SEP 17,2005 $539.10 $358.54 $0.00 To report card lost or stolen, call 1-877-593-3878 For 24-hour customer service, call1-800-B62-6200 Send billing inquiries to: COMMERCIAL CARD PO BOX 9665 PROVIDENCE, RI 02940"9665 CORPORATE ACCOUNT SUMMARY . Previous Purchases Cash Balance + & Other Debits + Advances + Finance Charges + Fees Credits $9,127.58 $0.00 $0,00 $82.78 $0.00 $0,00 Payments $182.55CR New Balance $9,027.81 FINANCE CHARGE SUMMARY Average Daily Monthly Corresponding Annual Periodic Balance Periodic Rate Percentage Rate Finance Charge PURCHASES $8,830.06 0.9375% 11.25% $82.78 CASH $0,00 0.9375% 11.25% $0.00 FEES $0,00 0.0000% 0.00% $0.00 PERIODIC RATE MAY VARY PLEASE REFER TO YOUR CARDHOLDER AGREEMENT IMPORTANT INFORMATION FOR OUR VALUED CUSTOMER IF YOUR CARD IS LOST OR STOLEN, PLEASE CALL 1-877-593-3878. OUTSIDE THE U.S., PLEASE CALL COLLECT 706-649-2331 IN JANUARY 2005, OUR TELEPHONE NUMBERS FOR REPORTING LOST OR STOLEN CARDS CHANGED. IF YOUR CARD WAS ISSUED BEFORE THIS DATE, LOST I STOLEN NUMBERS ON THE BACK OF YOUR CARD ARE NO LONGER VALID. PLEASE SAVE THIS CHANGE IN YOUR CARD RECORDS. CORPORATE ACCOUNT ACTIVITY ROBERTO'S 479815320001 1737 TOTAL CORPORATE ACTIVITY $99,77CR Post Tran Date Dale Reference Number 07-29 07-29 000000000 08-23 08-23 Transaction Description Amount ONLINE PMT - THANK YOU r'URCl-iASE "FINANCE CHARGE" 182.55 CR 82.78 Member FDIC Paue 1 of2 Important information About Your Account And Your Responslbilliies Reviewing your Citizens Bank Business Card Statement When you receive your Citizens Bank Business Card Statement, you should confirm the following items: 1) Review that all transactions are recognized. 2) Make sure all transactions are accurate. 3) Verify Ihat the productsls8IVices were or are scheduled 10 be received. 4) Make sure that any anticipated credits have been received. 5) Confirm the total amount of Ihe transaction. Note: The merchant name that appears on your slatement may not always match the nome by which you know the establishmenVvendor. This may be caused by the merchant's point-of-sale terminal being registered under a different nsme, (e,g. its formal corporate name). If this happens, check the amount of the charge, date, and time of the transaction; if these fields match the ones on your receipt, the charge is correct Reporting Lost or Stolen Cards If your card is lost or stolen, you are responsible for notifying Citizens Bank immediately in order to limit both your and our potential liability for unauthorized use. (See your Business Card Agreement for details.) To do so, call Citizens Bank as soon as possible Elt 1-877-593-3878 . We will cancel the lost or stolen card and you will receive a replacement card within 7 10 10 business days. If you need to replace your card immediEltely, call Citizens Bank's 24-hour customer service number: 1-800-862-6200 RlJsolving Disputes If you find that an item is mistakenly posted to your statement, you are responsible for contacting the merchant 10 correct the charge. Sleps to Take: 1) Identify the item, dollar amount, and dale of charge to provide to the merchsnt If the problem can be resolved, no further action is necessary, 2) If the merchant can not resolve the issue to your satisfaction, document your dispute in writing including merchant name, date, and amount of the transaction and forward it to the Billing Inquiry Address located on the first page of your statement. When Citizens Bank receives your merchant dispute, we will issue a temporary credit for the amount or provide a reason why the charge is valid. The most common stalement error is double billing (two or more charges of the same transaction). If this occurs. contact Citizens Bank directly. Citizens Bank will issue a temporary credit and contact the merchant on your behalf to provide appropriste credit(s). Very Important Point About Timing... Paying attention to liming is important with disputes because your 'time period' for reporting a dispute can expire. Disputes need to be reported in writing to Citizens Bank no later than 60 days after we sent you the first bill onwhkh the error or problem appeared. Discrepancies should be reported as soon as you suspect that they can not be resolved immediately with the merchant. Disputes have a better chance of being resolved the sooner you get Citizens Bank involved. How We Compute The Balance Upon Which Periodic FINANCE CHARGES Are Assessed: The clnlOunt of the periodic finance charge will be figured by multiplying the average daily balance of your accounl by the monlhly periodic filte. We ciJlculate a sepmate average daily balance for each of your purchase, cash advarlce, special advsnce, and special purchase bBlances. To get the averilge daily balance for each bal8nce, we take the beginning bal<lIlce eilch day (which does not include 8ny unpaid finance charges or fees), add ,lilY new cash or Ilew purchases, or speci;)1 advances, or special purchas8s as of the dsle of those trans<lclions and subtract any pilyments or credits. This gives liS the daily balance for each type of balance. We tllen <Jdd alllhe daily balances for each type 01 balance for lhe billing cycle togelher and divide the total by the number of days in billing cycle. This gives us the average daily balance for each type of balance on your account. The average daily balance on your purcllase balance will be deemed zero for any cycle if the payments and credits reflected on YOllr statement equal the previous balance shown on the statement for th<lt cycle GRACE PERIOD You milY avoid incurring a periodic finance chsrge on your purchase balance only if the entire amount sllown ilS the new balance on this statement is pBid within 25 dsys of the statement closing date. Payment must be received atlhe address noted all reverse side of this statement in order to meetlhis requirement. Cash <ldvances and special adv,lIlces are subject 10 periodic finarlce charges from the dBte of tl1e Irclrlsaclions unlilthe dClle they are paid in full. Citizens Bank Contact Numbers: Lost or Stolcn Cards: \n the U.S., 1-877-593-3878 Outside the U.S., call collect 1-706-649.2331 24.hour Customer Service Phone Center: 1-800-862-6200 P8ge 20f2 ~~ Citizens Bank PO BOX 9665 PROVIDENCE, RI 02940-9665 Account Number 479815320001 1737 Payment Due Date OCT 18. 2005 Amount Due $72189 111..",1.11,1."1.,111..,1,1."11.,11,"1.),11,,,11,,,1.1,,1 New Balance 519,139.59 * PO BOX 9665 PROVIDENCE, RI 02940-9665 Amount Enclosed 1$ ROBERTO'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 For proper credit, please mail pnymentsto <lddrE>SS alle!1 PElymenls receivedalanyolherloc<llionmClydelaycrediling your <lccQunl up 10 live days 000000 4798153200011737 000072189 000913959 Pleasedetachilndreturnwilhyourpaymenl ~~ Citizens Bank Account Summary For: ROBERTO'S FRANK P ALBANO lit PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 Account Information: Account Number: Total Credit Line: Available Credit: Days In Billing Cycle: 479815320001 1737 $10,000 $860 31 Billing Information: Statement Date: Payment Due date: Amount Due: Past Due Amount: Disputed amount SEP 23, 2005 OCT 18, 2005 $721.89 $539.10 $0.00 To report card lost or stolen, call 1-877 -593-3878 For 24.hour customer service, call 1-800-862-6200 Send billing inquiries 10: COMMERCIAL CARD PO BOX 9665 PROVIDENCE, RI 02940-9665 . CORPORATE ACCOUNT SUMMARY. Previous Purchases Cash Balance + & Other Debits + Advances + Finance Charges + Fees Credits Payments New Balance $9,027.81 $0.00 $0.00 $82.78 $29,00 $0.00 $0.00 $9,139.59 FINANCE CHARGE SUMMARY PURCHASES CASH FEES Average Daily Monthiy Corresponding Annual Periodic B81ance Periodic Rate Percentage Rate Finance Charge $8,830.06 0.9375% 11.25% $82.78 $0.00 0.9375% 11,25% $0.00 $0,00 0.0000% 0.00% $0.00 PERIODIC RATE MAY VARY PLEASE REFER TO YOUR CARDHOLDER AGREEMENT IMPORTANT INFORMATION FOR OUR VALUED CUSTOMER IF YOUR CARO IS LOST OR STOLEN. PLEASE CALL 1-817-593-3878. OUTSIDE THE U.S., PLEASE CALL COLLECT 706-649-2331. IN JANUARY 2005, OUR TELEPHONE NUMBERS FOR REPORTING LOST OR STOLEN CARDS CHANGED. IF YOUR CARD WAS ISSUED BEFORE THIS DATE. LOST I STOLEN NUMBERS ON THE BACK OF YOUR CARD ARE NO LONGER VAllO. PLEASE SAVE THIS CHANGE IN YOUR CARD RECORDS CORPORATE ACCOUNT ACTIVITY ROBERTO'S 1\798153200011737 TOTAL CORPORATE ACTIVITY $111.78 Post Tran Dilte Dale Reference Number Transaction Description Amount 09-20 09-20 09-23 09-23 LATE FEE PURCHASE "FINANCE CHARGE' 29.00 82,78 Member FDIC Page 1 of 2 Important information About Your Account And Your Responsibilities Reviewing your Citizens Bank Business Card Statement When you receive your Citizens Bank Business Card Statement, you should confirm the following items: 1) Review that ali transactions are recognized. 2) Make sure all transactions are accurate, 3) Verify that the products/services were or are scheduled to be received. 4) Make sure that any anticipated credits have been received. 5) Confirm the total amount of the transaction. Note: The merchant name that appears on your statement may not always match the name by which you know the establishment/vendor. This may be caused by the merchant's point-of-sale terminal being registered under a different name, (e,g, its formal corporate name), If this happens, check the amount of the charge, date, and lime 01 the transaction; if these fields match the ones on your receipt, the charge is correct. Reporting Lost or Stolen Cards If your card is lost or stolen, you are responsible for notifying Citizens Bank immediately in order to limit both your and our potential ilability for unauthorized use. (See your Business Card Agreement for details.) To do so, call Citizens Bank as soon as possible at 1-877 -593-3878 . We will cancel the lost or stolen card and you will receive a replacement card within 7 to 10 business days. If you need to replace your card immediately, call Citizens Bank's 24-hour customer service number: 1-800-862-6200 . Resolving Disputes If you find that an item is mistakenly posted to your statement, you are responsible for contacting the merchant to correct the charge. Steps to Take: 1) Identify the item, dollar amount, and date of charge to provide to the merchant. If the problem can be resolved, no further action is necessary. 2) If the merchant cem not resolve the issue to your satisfaction, document your dispute in writing including merchant name, date, elnd amount of the transaction and forward it to the Billing Inquiry Address located on the first page of your statement. When Citizens Bank receives your merchant dispute, we will issue a temporary credit for the amount or provide a reason why the charge Is valid. The most common statement error is double billing (two or more charges of the same transaction). If this occurs, contact Citizens Bank directly. Citizens Bank will issue a temporary credit and conlactthe merchant on your behalf to provide appropriate credit(s). Very Important Point About Timing._ Paying attention 10 timing is important with disputes because your 'time period' for reporting a dispute can expire. Disputes need to be reported in writing to Citi.z:ens Bank no later than 60 days <lfler we sent you the first bill on which the error or problem Clppeared. DiscropClndes should be reported as soon as you suspect that they can not be resolved immediately with the merch,mt. Disputes have a better chance of being resolved the sooner you get Citizens Bank involved. How We Compute The Balance Upon Which Periodic FINANCE CHARGES Are Assessed: The amount of the periodic finance chmge will be figured by multiplying the averClge daily balance of your ilccount by the monthly periodic wte. We c8lculate a sep,nate avemge daily balance for each of your purchase, cash 8dvnnce, special advance, and special purchase b8lances. To get the <lVerage daily balance for each balance, we lake the beginning balance each day (which does not include <"-my unpaid finance charges or fees), add any new cash or new purchases, or special adv<lnces, or special purchases as of the date of lhose transactions clOd subtract any p,Jyments or credits. This gives us the daily b~lance for cacll lype 01 balance. We lhen add all the daily balances for each lype of balance for the billing cycle together and divide lhe tolal by the number of dClYs in billing cycle, This gives us the average daily balance for each type of balance on your account. The average daily balance Oil your purchase balance will be deemed zero for any cycle if the p<1yments and credits reflected on your st31emenl equallhe previous bal,lOce shown on the statement for that cycle GRACE PERIOD You may avoid incurring a periodic finance charge on your purchase balance only if the entire <1mollnt shown as the new bal,mce on this st"tement is paid within 25 days of the statement closing date. Payment must be received at the address noted on reverse side of this statemenl in ordl;Jr 10 meet this requirement C<lsh adv,mccs and special adv<lnces are subject \0 periodic finance chmges flOm the d<lte of the lrans<ldions un Iii the date they ore relid in full. Citi.z:ens Bank Contact Numbers; Lost or Stolen Cards: In the U.S., 1.877-593-3878 Outside the U.S., call collect 1"706.649-2331 24.hollr Customer Service Phone Center: 1-800-862-6200 Page 2 of 2 ~~ Citizens Bank PO BOX 9665 PROVIDENCE, RI 02940-9665 AccoLlnt Number 479815320001 1737 Payment Due D-ate NOV 17, 2005 111"",1,11,1,,,1,,111,,,1,1,"11,,,11,,,1,1,11,.,11,,,1,],,I New Balance $906.95 $9,253.21 Amount Due * PO BOX 9665 PROVIDENCE, RI 02940-9665 Amount Enclosed 1 $ ROBERTO'S fRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 Forpropercredit.ple::Jscm21ilpiOlymentstnaddressalldt Pnyments received al <lny otller location m<JydelOlycredlllng YOl\[3cc.G\m\\.Jp\oli\>edClY:; 000000 4798153200011737 000090695 000925321 Please detach arid relurn with your payment ~~ Citizens Bank Account Summary For: ROBERTO'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA n111 Account Information: Account Number: 479815320001 1737 rolal Credit Line: $10,000 Available Credit: $747 Days In Billing Cycle: 30 Billing Information: Statement Date: Payment Due date: Amount Due: Past Due Amount: Disputed amount: OCT23,2005 NOV 17, 2005 $906.95 $721.89 $0.00 To report card lost or stolen, call 1-877-593-3878 For 24-hour customer service, call1-800-B62-6200 Send billing inquiries to: COMMERCIAL CARD PO BOX 9665 PROVIDENCE, RI 02940-9665 , CORPORATE ACCOUNT SUMMARY Previous Purchases Cash Finance New Balance + & Other Debits + Advances Charges + Fees Credits Payments Balal'lce $9,139.59 $0.00 $0.00 $84.62 $29.00 $0,00 $0.00 $9,253.21 -- FINANCE CHARGE SUMMARY PURCHASES CASH FEES Average Daily Monthly Corresponding Annual Periodic Balance Periodic Rate Percenlage Rale Finance ChiHge $8,830.06 0,9583% 11.50% $84.62 $0.00 0.9583% 11.50% $0.00 $0.00 0,0000% 0.00% $0.00 PERIODIC RATE MAY VARY PLEASE REFER TO YOUR CARDHOLDER AGREEMENT IMPORTANT INFOI'<MATION FOR OUR VALUED CUSTOMER IF YOUR CARD IS LOST OR STOLEN, PLEASE CAI.L 1-877-593-3878. OUTSIDE THE US. PLEASE CALL COLLECT 706-649-2331. IN JANUARY 2005, OUR TELEPHONE NUMBERS FOR REPORTING LOST OR STOLEN CARDS CHANGED. IF YOUR CARD WAS ISSUED BEFORE THIS DATE. LOST I STOLEN NUMBERS ON THE BACK OF YOUR CARD ARE NO LONGER VALID. PLEASE SAVE THIS CHANGE IN YOUR CARD RECORDS. CORPORATE ACCOUNT ACTIVITY ROBERTO'S 479815320001 1/37 TOTAL CORPORATE ACTIVlTY $113,62 Post Tr,ln Dale Date Reference Number Transaction Description Amount 10-21 10-21 10-21 10-21 U\TE fEE PURCHASE 'FINANCE CI lARGE" 29,00 84.62 Member FDIC PClge 1 of2 Important information About Your Account And Your Responsibilities Reviewing your Citizens Bank Business Card Statement When you receive your Citizens Bank Business Card Statement, you should confirm the following items: 1) Review thai ali transactions are recog.nized. 2) Make sure alllransaclions are accurate. 3) Verify that the products/services were or are scheduied to be received. 4) Make sure thai any anticipated credits have been received. 5) Confirm the lotal amount of the transaction. Note: The merchclnt name that appearS on your statement may not always mCllch the name by which you know the establishment/vendor. This may be caused by the merchant's point-of-sale terminal being registered under a dif{erenlllame, (e.g. its formal corporate name). Iftnls happens, cneck 1ne amount of the charge, date, and time of the transaction; if these fields match the ones on your receipt, the charge is correct. Reporting Lost or Stolen Cards If your card is lost or stolen, you are responsible for notifying Citizens Bank immediately In order to limit both your and our potential liability for unauthorized use. (See your Busill8SS Card Agreemell\ for details.) To do so, call Citizens Bank as soon as possible aI1-877-593-3878 , We wiil cancel the lost or stolen card and you will receive a replacement card within 7 to 10 business days. If you need to replace your card immediately, call Citizens Bank's 24-hour customer service number: 1-800-862-6200. Resolv.m9 Disputes If you find that an item is mistakenly posted to your slatement, you are responsible for contacting the merchant 10 correcl the charge. Steps to Take: 1) Identify the item, dollar amount, and date of charge to provide to the merchant. If the problem can be resolved, no further aelion is necessary. 2) If the merchant can not resolve the issue to your satisfaction, document your dispute in writing including merchanl name, date, and amour\t o~ the Iransaclion and forward il to the Billing Inquiry Address located on the first page of your slalemenl. When Citizens Bank receives your merchant dispute, we will issue a temporary credit for the amount or provide a reason why lhe charge is valid. The most common slatement error is double billing (two or more chalges 01 the same \Tz,nsaction). If this occurs, contact Citizens Bank d.lreclly. Citizens Bcmk will Issue a temporary credit <lnd contaclthe merchclnt on your behalf to provide appropriate credil(s). Very Important Point About Timing.. P<lying attention to timing is important with disputes because your 'time period' for reporting ;'I dispute can expire. Disputes need to be reported in writing to Citizens Bank no later than 60 days after we sent you the first bill on which the error or problem appeared. Discrepancies should be reported as soon as you suspect that they can not be resolved immediately with the merchant. Disputes have a beller chance of being resolved the sooner you get Citiz.ens Bank irY."lol'l~d. How We Compute The Balance Upon Which Periodic FINANCE CHARGES Are Assessed: The amount of the periodic finance charge will be figured by multiplying HIe average d8ily balance of your <lccount by Ihe monthly periodic rate We calculate a sep<lrate average daily balance for e8ch of your purchase, cash ildvClnce, speci<ll advance, and speci<ll purchase balances, To getlhe aVer8ge daily ba\cmce for eacn bElIElnce, we \elke Ihe beginning balance eElch day (which does not include any unpaid finance charges or fees), add any new cash or new purchases, or special advances, or special purchases <IS of the date of lIlose transactions and subtract "lilY payments or credits. This gives us the daily baiance for each type of balance. We tllcn add alt the daily balallces for eO\ct~ Iype 0\ balance for the billing cycle together <lnd divide the lolal by the number of days in billing cycle. This gives us Ihe average daily b81ance for each type of balance on YOllr account. The average daily bul,mce on your fHJrch<lse balance will be deemed zero for any cycle if tile payments ;;Ind credils reflected on your sl"temcnt equal the previous bal8nce shown on the slalemcnl lor that cycle. GRACE PERIOD You may avoid incurring a periodic finance charge on your purch<lse balance only if the entire <Jmounl shown as the new bal<lllce on this statement is paid within ;;5 days of the statement closing delte_ Payment must be received <Jt the address noted on reverse side o( tl~is statement in order to meet this rS'1uirement. C8sh advances cmd special adv<Jnces are subject to periodic filliJnce cl13rges frolll the date of lhe tr<lnsaclions untillhe diJte they are pilid in lulL Citizens Bank Cont'lct Numbers: Lost or Stolen Cards: 111 the U.S., 1-877-593-3878 Oulside the U.S., c'lll collect 1-706-649-2331 24-hotlr C~15t{}mer Servic.e Phone Center: 1-800-862-6200 Page 2 of 2 ~:€ Citizens Bank PO BOX 9665 PROVIDENCE, RI 02940-9665 Account Number 479815320001 1737 Payment Due Date DEC 18. 2005 $1. 094 32 Amount Due 111"",1,11,1,,,1,,111,,,1,1,,,11,,,11,,,1,1,11.,,11,.,1,1,,1 New Balance $9,368.67 * PO BOX 9665 PROVIDENCE, RI 02940-9665 Amount Enclosed 1$ ROBERTO'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 For proper credit. ple'-1semoilpElyment~to i:lddress at left P"'yments received at any other IOCEllion may delBY crediling your <Jccount up lolived:JYs 000000 4798153200011737 000109432 000936867 Pleasedelach and relurn with YOLJrp<lymenl ~:€ Citizens Bank Account Summary For; ROBERTO'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 Account Information: Account Number: 479815320001 1737 Total Credit LIne: $10,000 Available Credit: $631 Days In Billing Cycle: 31 Billing Information: Statement Date: Payment Due date: Amount Due: Past Due Amount: Disputed amount: NOV 23, 2005 DEC 18, 2005 $1,094.32 $906.95 $0,00 To report card lost or stolen, call 1-877-593-3878 For 24-hour customer service, call 1-800-862-6200 Send billing inquiries to: COMMERCIAL CARD PO BOX 9665 PROVIDENCE, RI 02940.9665 CORPORATE ACCOUNT SUMMARY Previous Purchases Cash Balance + & Other Debits + Advances + Finance Charges + Fees Credits Payments New Balance $9,253,21 $0.00 $0.00 $86.46 $29,00 $0.00 SO,OO $9,368.67 FINANCE CHARGE SUMMARY Average D<lily Monthly Corresponding Annual Periodic Balclnce Periodic Rate Percentage Rate Finance Charge PURCHASES $8,830.06 0,9792% 11.75% $86.46 CASH $0.00 0.9792% 11.75% $0,00 FEES $0,00 0.0000% 0,00% $0.00 PERIODIC RATE MAY VARY PLEASE REFER TO YOUR CARDHOLDER AGREEMENT IMPORTANT INFORMATION FOR OUR VALUED CUSTOMER IF YOUR CARD IS LOST OR STOLEN, PLEASE CALL 1-877-593-3878. OUTSIDE THE US., PLEASE CALL COLLECT 706649-2331. IN JANUARY 2005. OUR TELEPHONE NUMBERS FOR REPORTING LOST OR STOLEN CARDS CHANGED. IF YOUR CARD WAS ISSUED BEFORE THIS DATE, LOST I STOLEN NUMBERS ON THE BACK OF YOur, CARD ARE NO LONGER VALID. PLEASE SAVE THIS CHANGE IN YOUR CARD RECORDS. CORPORATE ACCOUNT ACTIVITY ROBERTO'S 4798153200011737 TOTAL CORPORATE ACTIVITY $115.46 Post Tran Date Date Reference Number Transaction Description Amount 11-2111-21 11-23 11-23 LATE FEE PURCI-tASE 'FiNANCE CHARGE' 29,00 86.46 Mernl.Jrcr FDIC PcJge 1 of 2 Impodant information About Your Account And Your ResponsIbilities Reviewing your Citizens Bank Business Card Statement When you receive your Citizens Bank Business Card Statement, you shouJd confirm the following items: 1) Review that all transactions am recognized. 2) Make sure all transactions are accurate. 3) Verify that the products/services were or are scheduled to be received. 4) Make sure that any anticipated credits have been received. 5) Confirm the total amount of the transaction, Note: The merchant name that appears on your statement may not always miltch the name by which you know the estClblishmentlvendor. This may be caused by the merchant's point-of-sClie terminal being registered under a different name, {e.g, its formal cmporate name}. If this happens, check Ihs amount of the charge, date, and lime of the transaction; if these fields match the ones on your receipt, the charge is corred. Reporting lost or Stolen Cards If your card is lost or stolen, you are responsible for notifying Citizens Bank immediately in order to iimit both your and our potential liability for unauthori.zed use, {See your Business Card Agreement for details.} To do so, call Citizens Bank as soon as possible at 1-877-593-3878. We will cancel the lost or stolen card and you will receive a replacement card within 7 to 10 business days. If you need to replace your card immedialely, call Citizens Bank's 24-hour customer service number: 1-800"862-6200, Rc,sol'ling Disputes If you find that an item is mistakeniy posted to your stalement, you are responsible for contacting the merchanl to correct the charge. Steps to Take: 1) Identify the item, dollar amount, and date of charge to provide to the merchant. If the problem can be resolved, no IUliher adion is necessary. 2) If the merchant am not resolve the issue to your satisfaction, document your dispute in writing including merchant name, date, and amount of the transaction and forward it to the Billing Inquiry Address located on the first page of your statement. When Citizens Bank receives your merchcmt dispute, we will issue a temporary credit for the amounl or provide a reason why the charge is valid, The most common statement error is double billing (lwo or more charges of the same transaction). If this occurs, contact Citizens B<.mk directly. C'lllzens Bank wm issue a temporary credil8nd contact the ml,rch<.mt on your behalf 10 provide appropriate credit(s). Very Important Point ,About Timing... Paying attention to timing is important with disputes because your 'time period' for reporting a dispute can expire. Disputes need to be reported in writIng to C1tizens Bank no taier than 60 days afler we sent you the first bill on which the error or problem appeared. Discrepilncies snould be reported as soon;'ls you suspect tnat they can not b{! resolved immediately with the merchanl. Disputes have;) better chance of being resolved Ihe sooner you get Citiz.en.s Ban.\<. invol"ed. How We Compute The Balance Upon Which Periodic FINANCE CHARGES Are Assessed: The amount oj tile periodic finomce chmge will be figured by mulliplying the average d<lily balance of your account by the ll10nthly periodic ralc We cCliculale Cl sepamte averClgc daily bCli<.lOce for ench of your purchase, c::Jsh Cldvance, special advance, olOd speci<ll purchClse balances. To gel the average I:bily bal<.:1nce lor each bal<1nce, we IClxe the begllln'lng balance each day (which does not include any unpaid finClnce charges or t<1<15), Cldd ,lny new cash or new purchases, or special advilnces, or speciol purchases as of the date of those tranS;lctions and sublroct any pDyments 01 credits. This gives us the daily bdlance for oacl1lype of balClnce. We then add all the ddily balances for e2.ch type 0\ balance fOf \l1e billing cycle \ogctller Clnd divide the lotal by the nllmber of days ill billing cycle. This gives us Ihe 8verClge daily balance for each type of balance on your dcwunt. The i1verage daiiy bdlance on your pllrchase balance will be dcellled zero for any cycle jJ Ihe paymcnts dnd credits reflected all your sl,-llement equal tile previous balance shown on Ihe sta\emenllor thai ~ycle. GRACE PERIOD You mClY avoid incurring n periodic fillance charge on your purchdse bal;:mce only if the entire amount shown os the new b.llvnce olllhis statement is paid wilhin 25 days of the statement closing ddte. P8yrnen\ must be received dt the addl.ess noted on reverse side of this slatement in order to mee\ this requirement. Cash ddvsnces and special advances are subject to periodic finnnce charges from the date of the tmnsactions until [he r:i8te lhey me pClid in fuil. Citizens Bilnk Contact Numbers: Lost or Stolen Cilrds: In the U.S., 1_877_593_3878 Outside the U.S., call collecI1-706-549-2331 24.hOllr Customer Service Phone Center: 1-800-862-6200 Page 2 of2 ~~ Citizens Bank PO BOX 9665 PROVIDENCE/ RI 02940-9665 Account Number 479815320001 1737 Payment Due Date JAN 17.2006 $1.28342 Amount Due 111"",1,11,1,,,1,,111,,,1,1,,,11,,,11,,,1,1,11,,,11,,,1,1,,I New Balance $9,455.13 * PO BOX 9665 PROVIDENCE, RI 02940-9665 Amount Enclosed 1$ ROBERTO'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 For proper credil. pleClsem3il pLlyments to Clddressatleft PiJymefltsreceived Dtanyolherlocalion mflydel::1ycrediling YOUf::lCCount up to five dQYs 000000 <\798153200011737 0001283<\2 0009<\5513 Please detach and return wilh your payment ~~ Citizens Bank Account Summary For: ROBERTO'S FRANK P ALBANO III PAGLIARO'S 6301 GRAYSON RD HARRISBURG PA 17111 Account Information: Account Number: Total Credit line: Available Credit: Days In Billing Cycle: 479815320001 1737 $10,000 $545 3D Billing Information: Statement Date: Payment Due date: Amount Due: Past Due Amount: Disputed amount: DEC 23, 2005 JAN 17, 2006 $1,283,42 $1,094.32 $0,00 To report card lost or stolen, call 1-877-593-3878 For 24-hour customer service, call 1-800-862-6200 Send billing inquiries to: COMMERCIAL CARD PO BOX 9665 PROVIDENCE, RI 02940-9665 CORPORATE ACCOUNT SUMMARY Previous Purchases Cash Finance Balance + & Other Debits + Advances + Charges Fees Credits Payments New Balance $9,368.67 $0,00 $0.00 $86.46 $0.00 $0.00 $0.00 $9,455.13 FINANCE CHARGE SUMMARY PURCHASES CASH FEES Average Daily Monthly Corresponding Annual Periodic Balance PeriodicRClle Percentage RClte Finance Charge $8,830.06 0.9792% 11.75% $86.46 $0,00 0.9792% 11.75% $0.00 $0.00 0.0000% 0.00% $0.00 PERIODIC RATE MAY VARY PLEASE REFER TO YOUR CARDHOLDER AGREEMENT IMPORTANT INFORMATION FOR OUR VALUED CUSTOMER IF YOUR CARD IS LOST OR STOLEN, PLEASE CALL 1-877-593-3878. OUTSIDE THE US. PI_EASE CALL COLLECT 706-649-2331. IN JANUARY 2005. OUR TELEPHONE NUMBERS FOR REPORTING LOST DR STOLEN CARDS CHANGED. IF YOUR CARD WAS ISSUED BEFORE THIS DATE, LOST I STOLEN NUMBERS ON THE BACK OF YOUR CARD ARE NO LONGER VALID. PLEASE SAVE THIS CHANGE IN YOUR CARD RECORDS. CORPORATE ACCOUNT ACTIVITY ROBERTO'S 479815320001 173'1 TOTAL CORPORATE ACTIVITY $86.46 Post Tran Date Dale Reference Number Transaction Description Amount 17.-2312-23 PURCHASE 'FINANCE CHARGE' 86.46 Member FDIC PClgC 1 of 2 Important information About Your Account And Your ResponsibIlities Reviewing your Citizens Bank Business Card Statement When you receive your Citizens Bank Business Card Statement, you should contkm the (ollowing items: 1) Review that all trar.sacliOlls ale recognized, 2) Make sure all transactions are accurate. 3) Verify that the products/services were or are scheduled to be received. 4) Make sure that any anticipated credits have been received. 5) Confirm the total amount of the transaction. Note: The merchant name that appears on your statement may not always mCltch the name by which you know the establishment/venn or. This may be caused by the merchant's poir.t-01-sale lerminal being regis\eretll.lnder a differen't name, (e.g. ils formal corporale name). If this happens. check the amount of the charge, date, and time of the transaction; if these fields match the ones on your receipt, the charge is correct. Reporting lost or Stolen Cards If your card is lost or stolen, you are responsible for notifying Citizens Bank immediately in order to limit both your and our potential liability for unauthorized use_ (See your Business Card Agreement lor delails.) To do so, call Citizens Bank as soon as possible a11-877 -593-3878 . We will cancel Ihe lost or stolen card and you will receive a replacement card within 7 to 10 business days. If you need 10 replace your card immediately, call Citizens Bank's 24-hour cuslomer service number: '-800-862"6200. Resolving Disputes If you find that an item is mistakenly posted to your statemenl, you are responsible for conlacting the merchant to correct the charge. steps to Take: 1) Identify the item, dollar amount, and date of charge to provide to the merchant. II Ihe problem can be resolved, no further action is necessary. 2) If the merchant can not resolve the issue 10 your satisfaction, documer.t your dispute If\ writir.g induding merchant name, date, and amount of the transaclion and forward it to the Billing Inquiry Address located on Ihe first page of your statement. When Citizens Bank receives your merch,mt dispute, we will issue a temporary credit for Ihe amount or provide a reason why the charge is valid. The most common statement error is double billing (two or more charges 01 the same transaction). II this occurs, contact Citizens Bank directly. Citizens Bank will issue Cltemporary credit and conlClctthe merchant on your behalf to provide appropriate credit(s). Very Import;mt Point About Timing.. Paying attention to timing is important with disputes because your 'time period' for reporting a dispute can expire. Disputes need to be reported in writing to Citizens Bank no later than 60 days after we sent you the first bill on which the error or problem appeared. Discrepancies should be reported as soon as you suspect that they can not be resolved Immediately with the merchant. Disputes have a better chance of being resolved the sooner you get Citizens Bank involved. How We Compute The B<llance Upon Which Periodic FINANCE CHARGES Are Asse.ssed: The OlIllOLlIlt of the periodic finance chOlrgc will be figured by muilipfying the average diJily bellelnce of your account by the rnonthly periodic rate We calculate EI separate average daily balance for cacll of your purchase, cash OldvClnce. speciElI advance, and special purchase balances. To get the elvcrage rJOljly balance lor eOlcll balance, we takcthe beginning balance each day (which does not include any uIlp8id finance charges or lees), add any new cosh or new purchases, or special advcll1ces, or special purchases ,1S of the d<:1te of those tr,'lrlsClcliolls and sublract any payments or credils. Tllis gives liS the dally baiance lor e,lch type 0\ balance. We then aod al\ the daily balances for each Iype of balance lor the billing cycle together and rJivlde the total by the number of days in billing cycle. This gives us the average daily balance for each type of bCllance on your account The average daily balance on your purcllClse bo"ll<Jllce will be deemed zero for any cycle if the payments and credits l-elleclerJ on your sl3terncnt equal the preVious bal;:l1',ce shown 01l the statcmellt for tllatcyde. GRACE PERIOD You IT13Y avoid incurring a periodic finance chmge on your purchase b<ll,mce only it the entire amount shown 8S the Ilew balance on this statement is paid withill 25 rlClYS of tile slatcment closing date. Payment musl be \Ccellfed at the ;:Iddles$ \lo\ed on relferse side '0\ Ihis statement ill order t'0 meel \h'ls requirement C<lsh advances and special advances are subjeclto periodic finance charges from lhe U<lte of the tranSOlctions untillhe dale they are paid in full. CitizenS Bank Contact Numbers: Lost or Stolen Cards: tn the U.S., 1_877_593_3878 Outside the U.S., call collect 1-706"649-2331 24-hour Customer Service Phone Center: 1_800_862_6200 P8ge 7. 012 EXHIBIT "C" / -'.... - .~. SILVERMAN BERNHEIM & VOGEL LALJ1{I3N It BERSCrrLER DlRECT DIAL. (4\2) 255-3767 e-mail: Ibcr~:chler(ii.~~ibvlalV.com OF COUNSEL JONATHAN A. Si\lDEL MARY B. STEIN Two Penn Center Pima Suite 910 Philadelphia, PA 19102 p, 215.569.0000 F, 215.6363999 Sentry Office Plaza 216 Haddon Avenue Suite 602 Westmonc, NJ 08108 p, 856.858.9499 F 856.858.4606 One Oxford Centre SUlte 4300 Pitt$burgb, PA 15219 1', 412.2553767 F, 412.2553701 wIVw.:;bvlaw.CUIJ1 Attorneys at Law November 18, 2005 VIA CERTIFIED AND REGULAR MAIL Frank Albano, III 36 Wetherburn Road Eno1a, P A 17025 Roberto's 23 S. Union Street Middletown, P A 17057 Roberto's Pagliaro's and Frank Albano, III 6301 Grayson Road Harrisburg, P A 17111 Re: Visa Account No. 4798153200011737 Overdraft sum: $9,139.59 Dear Mr. Albano: Please be advised that this office represents Citizens Bank of Pennsylvania ("Citizens"), in connection with the above-referenced Business Visa Account issued to Roberto's. As you are aware, on or about November 5, 2003, you executed the Business Credit Application and Agreement in your capacity as Owner of the business, as well as in your individual capacity. Accordingly, you as well as Roberto's are jointly and severally responsible for all amounts due and owing on this account Since, as you have failed to make monthly payments are required by the Agreement, please note that the amollnt due and owing to Citizens currently totals the sum of $9, ] 39.59. Please forward your payment, made payable to "Cltizens Bank of Pennsylvania" to my attention at Silverman Bernheim & Vogel, Two Penn Center, Suite 910, Philadelphia, P A 19102, within twenty (20) days of date of this letter. Please note, such payment must be made by certified check, cashier's check, or money order. Neither a personal check nor a business check will be accepted. F:\WPCNE'l\DOCS\40050\Albnl1o-1 (,\demand.111 S05.wpd . SILVERMAN BERNHEIM & VOGEL Additionally, please note, if payment in the amount 01'$9,139.59, is not received on or before December 8, 2005, then Citizens may initiate further legal proceedings. If such legal proceedings are commenced, you will thereafter become responsible for any and all additional interest, late charges, and attorneys fees and costs, as provided for in the Business Credit Application and Agreement. We are hopeful this matter will be resolved by payment and trust that YOLl will give this your immediate attention. Sincerely, SILVERMAN, BERNHEIM & VOGEL By:cl~l ^ 1 m ~ ~wch LAUREN R. ERSCHLER LRBI cc: Citizens Bank of Pennsylvania (via fax) F:\WI'CNET\DOCS\40050\^lhano-16\dcllland.1 I 1805.wpd ~ !'=' 6' ~ ~ 3 11." U). .~- ~ OJ ~ 3 ~:3-g . m ~ ~ i 0- g j ~. '" = o I< l? -,J 3 D l& D o. In :lJ i!t D " W 0 !' :lJ ..Jl !l D :D l& E D o. D ~ D IT" 0 "- ". D ~ D W i ru D, l -,J. -'" '" ~ 0 ~ ~ ~ . ~ U; ~ '" o 01!(i~, . if JJ ~ s:'" ~ c ~ ~ n " - 3; . c.~3..:2 Afil.;:~ = ~ o };to Pil'.g' P~<i p 3 ~ :D H -S- if ~ g. ~ '" "/ij" . I I I I'" ,rr1 I'- 'Cl ! C"\ ::s <::7 ~ ? ru rrI Cl Cl ..1]. [j! D D Return Receipt Fee (Endorsement Required) d Restricted Delivery Fee 0- (Endorsement Required) rrI Cl u1 D D I'- .-." ::- 0"~" ... S- -=:; ~..,Sl~~;!'3itb' ("=- . ~);;g _-~ g: 3. 3 ~ ;f'lfun :6 <5 R i'lc;~!!li[-~ c:::::; p ~g:3a.o,!\) - -:s m(l)...."'9!.p, -.;;:;. Co c-:::rQ.-":;:I --' _ ~fl)CDC.iic. 30Qiil-<o> &:' R iifaa.~ iD'~ ~ . :fo~g.~ CD '< :J"'!a. 0 30CD(;I0 DlF~a.3 ~ <' 'Q. ffi. m !a 1l III Gl :::I c= >-" <3' I" P o DO ~ S 'if " a .~ U.S. Postal Service"" CERTIFIED MAIL" RECEIPT (Domestic ~Mai1 Only; No Insurance Coverage Provided) OFFICIAL , 1 '~.30 \,10 Postage $ USE ...----....~ './~'" \9102 P{iJ;~ .c<;~s~ i "~~!:~;2oov/f;; \ -,-, \ 14 "-.....,!i,s.r..~__ CertlfiedFee Tolar Postage & Fees :L <0 =r I'- Cl U.S. Postal Service", CERTIFIED MAIL". RECEIPT (Domestic Mail Only; No Insurance Coverage PrOVided) ru rr1 Cl o ..1] Cl Cl. 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'~~\ i3i~ ,".," (U U'~\",':"'Ii6'~o" 'i'>; .L.>- rrr~: "; "" . .""C,..,.,,.,.,"/l&. I~,. 'if] ....>t........... U.S. Postal Service"" CERTIFIED MAil", RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) OFFICIAL 1 '30 .-p;j ::r ru r'- Cl ru n1 Cl Cl Postage $ .J] Cl d Return Recelpl Fee r:l (Endorsement RequIred) CerUfied FeEl Cl ReStricted Delivery Fee IT' (Endorsemem fl;eqiJlred) fT1 d Total Postage & Fees '},.. u1 o o r'- USE ;::J 0 ~ 8 \ 7' en ~. :Il en .. ..() V; - ( , ~ ,'-', (-) i (J( " ..~A --. _-eo'! , '" q ~ E) , \ r-- \) b 1-.' tj.) 1- -"-L-., .\ SHERIFF'S RETURN - REGULAR CASE NO: 2006-01086 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIZENS BANK OF PENNSYLVANIA VS ALBANO FRANK III ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ALBANO FRANK III the DEFENDANT , at 1745:00 HOURS, on the 27th day of February, 2006 at 36 WEATHERBURN ROAD ENOLA, PA 17025 JAMIE ALBANO, WIFE by handing to 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 18.00 13 .20 .00 10.00 .00 41. 20 Sworn and Subscribed to before me this 0'/4 day of ~~AD dh {Prot. no ary So Answers: "1P"/;~rf'~.c ./~ R. Thomas Kline 02/28/2006 SILVERMAN BERNHEIM VOGEL B~ ~~'^ Deputy Sheriff SIL VERMAN BERNHEIM & VOGEL BY: Daniel S. Bernheim, 3d, Esquire Lauren R. Berschler, Esquire Identification Nos.: 32736 & 88209 Two Penn Center Plaza, Suite 910 Philadelphia, P A 19102 (215) 569-0000 CITIZENS BANK OF PENNSYLVANIA Plaintiff v. FRANK ALBANO, III Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 06-1086 PRAECIPE TO SETTLE. DISCONTINUE AND END To the Prothonotary: Please mark the above-captioned action settled, discontinued and ended. Dated: September 26, 2006 F.IWPCNE IDOCSI40050IAlbano-16\Praecipe.SOE.092606 wpd Respectfully submitted, SILVERMAN BERNHEIM & VOGEL BY Q t:.~ ~$-;' :-=~ .-<, r--') <::::> = cro if) rr; u o -n ::r! it rnF' -nG : ;)~ C-:? -" .. ;:; ~ "'.;: