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Home My WebLink About06-2446IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. JUDITH ANN PATNO HARRISON WENDEL PATNO Defendants No: OL - aUgL, Otof-L k I COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05105794 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No U? - JUDITH ANN PATNO HARRISON WENDEL PATNO Defendants COMPLAINT AND NOTICE TO DEFEND 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 an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-31GG COMPLAINT 1. Plaintiff, is a corporation with offices at 3311 MILL MEADOW DR. HILLIARD , OH 43026 2. Defendants are adult individual(s) residing at the address listed below: JUDITH ANN PATNO 544 N ENOLA DR ENOLA, PA 17025 HARRISON WENDEL PATNO 544 N ENOLA DR ENOLA, PA 17025 3. Defendants applied for and received a credit card issued by Plaintiff bearing the account number 6011002920628534 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendants made use of said credit card and currently has a balance due and owing to Plaintiff, as of April 13, 2006 , in the amount of $9440.57 5. Defendants are in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendants will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $1500.00 8. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendants , JUDITH ANN PATNO AND HARRISON WENDEL PATNO ,JOINTLY AND SEVERALLY , in the amount of $9440.57 with interest at the legal rate of 6.000°s per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. + i - Jame C. V7armbrodt,42524 WEL'M N, WEINBERG & REIS CO., L.P.A. 43 S venth Avenue, Suite 2718 P'tts urgh, PA 15219 12 434-7955 S' AX' 412-338-7130 '05 5794 C A Pit WLG This law firm is a debt collector alt mpting to collect this debt for our client and any information obt ed will be used for that purpose '? newbalance minimum payment due account number 6011 0029 2062 $534 DISC r $743.00 enter amount enclosed below ` VER CARD payment due date $ March 9, 2006 1'1yi t_ 10 SDSN6A01 0001109 HARRISON PATNO JUDITH PATNO 544 N ENOLA DR ENOLA PA 17025-2120 Address or telephone change? Please print change in the space above, or go to Discovercard.com. Use your card with confidence--Discover Card ranked #1 in Fraud Protection Services among the largest card issuers by Javelin Strategy & Research in its 2005 report. PO BOX 15251 IIIulILnnl,IILn,IIIII WILMINGTON DE 19886-5251 ?I n???I?i I?u?Ilu?u"u1I I?u I?r?I?I?u u??I?I?uu???I?n? 000006011002920628534094405700000000074300 Discover Platinum Card Account Summary account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0029 2062 8534 March 9, 2006 $743.00 $9,000.00 $0.00 $4,600.00 $0.00 Cashback Bonus® Cashback Bonus® Anniversary Date: July 10 Average Daily Balances Closing Date: February 10, 2006 page 1 of 1 previous balance $9,440.57 payments and credits - 0.00 purchases + 0.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 0.00 new balance = $9,440.57 Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 Nominal ANNUAL Transaction Daily ANNUAL Periodic Fee Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Rates RATES RATES CHARGES CHARGES current billing period: 31 days VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to ?s unswarn falsifications to authorities, that he/she is y? yy? (Name) Accou ln, y?(LtZ oy- of Discover Financial Services LLC., plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR# 5105794 HARRISON WENDE PATNO 6011002920628534 D - .I14 11 vi b-Z D 12 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. HARRISON WENDEL PATNO and JUDITH ANN PATNO Defendants No. 06-2446 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05105794 Judgment Amount $ 10,940.57 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. HARRISON WENDEL PATNO and JUDITH ANN PATNO Defendants TO THE PROTHONOTARY Civil Action No. 06-2446 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendants, Harrison Wendel Patno and Judith Ann Patno, above named, in the default of an Answer, in the amount of $10,940.57 computed as follows: Amount claimed in Complaint $9,440.57 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $1,500.00 TOTAL $10,940.57 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A By:? I/ I/k/ James C. a mbrodt, Esquire PA I. D. #4 5 WELTM EINBERG & REIS CO., L.P.A. 2718 K pe Building 436 Se en Avenue Pittsb g PA 15219 (412) -7955 Plaintiff's address is: c/o Wellman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendants is: 544 N ENOLA DR ., ENOLA,PA 17025. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff HARRISON WENDEL PATNO Defendant(s) IMPORTANT NOTICE TO: HARRISON WENDEL PATNO 544 N ENOLA DR ENOLA,PA 17025 Date of Notice: _ Or/31106 WWR#: 05105794 Case # 06-.2,1116 Cav t rtRm YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 ` BY: / r v JAMVW BRODT, ESQUIRE PA 2524 WEL EINBERG & REIS CO., L.P.A. 271 RS BLDG, 436 7TH AVE. PIT I PA 15219 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case # 06 - 2qg6 GSvsz fE4m JUDITH ANN PATNO Defendant(s) IMPORTANT NOTICE TO: JUDITH ANN PATNO 544 N ENOLA DR ENOLA,PA 17025 Date of Notice: 05r131 101 WWR#: 05105794 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY : / I V/ ARMBRODT, ESQUIRE JAMJE PA #42524 WELWEINBERG & REIS CO., L.P.A. 6 7TH AVE. 271PPERS BLDG, 43 PIT RGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. HARRISON WENDEL PATNO and JUDITH ANN PATNO Defendants Case no: 06-2446 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, HARRISON WENDEL PATNO and JUDITH ANN PATNO is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, HARRISON WENDEL PATNO and JUDITH ANN PATNO is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SU RIBED in my presence this -t _l- day r M r 2o,$ta COMMON W EALTH OF PENNSY=201 VANIA Heiublic N T RY PUBLI ryOlyCounty _ My Com. 4, 2ppg Member, Pennsylvania Asaodation of Notaries This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center Military Status Report ' Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUN-14-2006 08:21:22 'K Last Name First/Middle Begin Date Active Duty Status Service/Agency PATNO HARRISON Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of thee Military. -% -o -j j_i?,'." Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense-Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/14/2006 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN. will cause an erroneous certificate to be provided. Report ID: GYSUGCCGEJ https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/14/2006 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUN-14-2006 08:21:52 < Last Name First/Middle Begin Date ActiveDuty Status Service/Agency PATNO JUDITH Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Mi?litary.? 1 Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209=2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense-Enrollment and Eligibility Deporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects' current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: httn://www.defenselink.mil/faa/pis/PC.09$LDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/14/2006 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: GYSYATWKDT https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/14/2006 J4. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-2446 CIVIL TERM HARRISON WENDEL PATNO and JUDITH ANN PATNO Defendants NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or J dg ent was entered against you on1 01 app(o (xx) Assumpsit Judgment in the amount of $10,940.57 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: e"ML PRO ONOT R DEPUTY) HARRISON WENDEL PATNO 544 N ENOLA DR ENOLA,PA 17025 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-2446 CIVIL TERM HARRISON WENDEL PATNO and JUDITH ANN PATNO Defendants NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or dgment was entered against you on Or 2Gb6 (xx) Assumpsit Judgment in the amount of $10,940.57 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PRO N TAR 1tDE TY) JUDITH ANN PATNO 544 N ENOIA DR ENOLA,PA 17025 V '% CASE NO: 2006-02446 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS PATNO JUDITH ANN ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PATNO JUDITH ANN the DEFENDANT , at 1741:00 HOURS, on the 3rd day of May , 2006 at 544 N ENOLA DRIVE ENOLA, PA 17025 JUDITH PATNO 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 18.00 Service 13.20 Postage .39 Surcharge 10.00 .00 vgyI06 41.59 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 05/04/2006 WELTMAN WEINBERG REIS By: J.* r,4 ?z, eputy Sheriff Prothonotary A CASE NO: 2006-02446 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS PATNO JUDITH ANN ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PATNO HARRISON WENDEL the DEFENDANT , at 1741:00 HOURS, on the 3rd day of May 2006 at 544 N ENOLA DRIVE ENOLA. PA 17025 JUDITH PATNO, 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 'I/"?/G f. 16.00 (?M Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 05/04/2006 WELTMAN WEINBERG REIS By. ?eA Deputy Sheriff Prothonotary r ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 06-2446-CIVIL TERM VS. PRAECIPE FOR SATISFACTION OF JUDGMENT HARRISON WENDEL PATNO JUDITH ANN PATNO Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I. D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5105794 f ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 06-2446-CIVIL TERM HARRISON WENDEL PATNO JUDITH ANN PATNO Defendants PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subscri ed before me this _U___ day of June 2008 NO RY PU C WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Mol an, Esquire PA. I . D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #5105794 rsr.a nc?tsVVrns. c a orr -- viovueis:i Sea! -.?-- W-3,;ne A notary ruUlc Gsty ?4 ?i;YsiSGSrc; ^+s ,g:^d? G?un?ty _,,yr'.t , , Sl 20" t?l?e? c. ar ,.. a c ^•,c?....les 00 V R' J -p r Qti „J D W of D em f . ?i ?J