HomeMy WebLinkAbout2008-4299
LYNNEA HALL, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : NO. 08-4299
:
DENNIS SEMANCIK, individually and :
d.b.a. S&S REAL ESTATE, : CIVIL ACTION
Defendant :
:
ANDREW SEMANCIK, individually :
and d.b.a. S&S REAL ESTATE, :
Defendant :
:
KEITH BOLASH, individually and :
d.b.a. APPRAISER-LINK, :
Defendant :
:
CODY FINANCIAL MORTGAGE :
SERVICES, INC., :
Defendant :
:
LAKESIDE ABSTRACT & :
SETTLEMENT, LLC, :
Defendant :
:
JOHN and JANE DOES 1-10 :
Defendants : JURY TRIAL DEMANDED
IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT CODY FINANCIAL
MORTGAGE SERVICES, INC.,
BEFORE BAYLEY, J. AND EBERT, J.
ORDER OF COURT
th
AND NOW
, this 10 day of July, 2009, upon consideration of the preliminary objections
of Defendant Cody Financial Mortgage Services, Inc., to Plaintiff’s complaint, the briefs filed by
the parties, and after argument;
IT IS HEREBY ORDERED AND DIRECTED
that:
1. As to Count 17, Defendant’s preliminary objection filed pursuant to Pa. R.C.P.
GRANTED in
1028(a)(4) (Demurrer - Legal Insufficiency of Plaintiff’s Complaint) is
part OVERRULED in part.
andWith regard to Plaintiff’s Complaint alleging a
1
violation of the Unfair Trade Practices Act and Consumer Protection Law under 73 P.S.
GRANTED
§201-2(4)(iii) is . With respect to the alleged violations of 73 P.S. § 201-
OVERRULED
2(4)(v)(vii) and (xxi) is .
2. As to Counts 18, 19, and 20, Defendant’s preliminary objections filed pursuant to
Pa.R.C.P. 1028(a) (Demurrer – Legal Insufficiency of Plaintiff’s Complaint) are
OVERRULED
.
3. Defendant’s preliminary objection filed pursuant to Pa.R.C.P. 1028(a)(2) (Failure of
OVERRULED
Pleading to Conform to Law or Rule of Court) is .
By the Court,
M. L. Ebert, Jr., J.
Laurence C. Kress, Esq.
Scaringi & Scaringi, P.C.
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 657-7770
Attorney for Plaintiff
James D. Hughes, Esq.
Laura Rebecca Ables, Esq.
Salzmann Hughes, P.C.
354 Alexander Spring Road
Carlisle, PA 17015
(717) 249-6333
Attorneys for Defendant Cody Financial
2
LYNNEA HALL, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : NO. 08-4299
:
DENNIS SEMANCIK, individually and :
d.b.a. S&S REAL ESTATE, : CIVIL ACTION
Defendant :
:
ANDREW SEMANCIK, individually :
and d.b.a. S&S REAL ESTATE, :
Defendant :
:
KEITH BOLASH, individually and :
d.b.a. APPRAISER-LINK, :
Defendant :
:
CODY FINANCIAL MORTGAGE :
SERVICES, INC., :
Defendant :
:
LAKESIDE ABSTRACT & :
SETTLEMENT, LLC, :
Defendant :
:
JOHN and JANE DOES 1-10 :
Defendants : JURY TRIAL DEMANDED
IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT CODY FINANCIAL
MORTGAGE SERVICES, INC.,
BEFORE BAYLEY, J. AND EBERT J.
OPINION and ORDER OF COURT
EBERT, J., July 10, 2009 -
STATEMENT OF FACTS
This action arises out of a transaction for the purchase of the property located at 329 Salt
Road, Enola, Cumberland County, Pennsylvania (the “property”). The property was purchased
by Plaintiff Lynnea Hall (“Hall”) from Defendants Dennis and Andrew Semancik (the
“Semanciks”), individually and doing business as S&S Real Estate, for a purchase price of
$177,000. The Agreement of Sale (the “Agreement”) for the purchase of the property was
3
entered into on June 20, 2006. The Agreement signed by both parties purports to be an “as-is”
sales agreement without any contingencies.
On or about June 2, 2006, Defendant Cody Financial Services, Inc. (“Cody Financial”)
pre-approved Plaintiff for purchase of the home at a sale price of $177,000. Hall engaged Cody
Financial to obtain financing for her purchase of the property. Hall provided Cody Financial
with all information necessary for securing a loan, including the Agreement of Sale. Cody
Financial hired a real estate appraiser, Keith Bolash (“Bolash”) to determine the value of the
property. On July 9, 2006, Bolash provided Cody Financial with his completed written appraisal
report. On or about July 11, 2006, Cody Financial informed Hall that a mortgage loan on her
behalf for $164,000 had been approved through Sovereign Bank. On July 17, 2006, Hall
proceeded to close on the property.
Shortly thereafter, Hall moved into the property. Hall allegedly discovered structural
defects on the premises some time after moving into the property. On July 17, 2008, Hall
initiated the instant action against the individuals and business from whom she purchased the
property, her mortgage broker, the mortgage broker’s real estate appraiser, and the title insurance
company as defendants. Hall stated four causes of action against Cody Financial in her
complaint: Count 17, Violation of the Unfair Trade Practices Act and Consumer Protection Law;
Count 18, Fraudulent Inducement; Count 19, Fraudulent Non-Disclosure, and Count 20,
Negligent Non-Disclosure. On August 11, 2008, Cody Financial filed preliminary objections
with this Court.
4
DISCUSSION
A. Standard of Review
A demurrer is an assertion that a complaint does not set forth a cause of action or a claim
on which relief can be granted. Lerner v. Lerner, 954 A.2d 1229, 1234-35 (Pa.Super. 2008),
citing Binswanger v. Levy, 457 A.2d 103, 104 (Pa.Super. 1983)). In ruling on a demurrer, the
court may consider only matters that arise out of the complaint itself; it cannot supply a fact
missing in the complaint. In evaluating a demurrer, all material facts set forth in the complaint
and all inferences reasonably deducible therefrom must be admitted as true. Hess v. Fox
Rothschild, LLP, 925 A.2d 798, 806 (Pa.Super. 2007). The question presented by a demurrer is
whether, based on the facts averred, the law says with certainty that the contested pleading is
legally insufficient and no recovery is possible. Schuylkill Navy v. Langbord, 728 A.2d 964, 968
(Pa.Super. 1999), citing Smith v. McDougall, 529 A.2d 20 (Pa.Super. 1987)). If there is any
doubt as to whether a demurrer should be sustained, the doubt should be resolved in favor of
overruling it. Lerner, 954 A.2d at 1234, citing Wawa Inc. v. Alexander J. Litwornia & Assocs.,
817 A.2d 543, 544 (Pa.Super. 2003)). Therefore, a preliminary objection in the nature of a
demurrer may be properly granted only where the contested pleading is legally insufficient.
Hess, 925 A.2d at 806.
B. Demurrer to Count 17, Violation of Unfair Trade Practices and Consumer Protection
Law.
Plaintiff’s first cause of action is for a violation of the Unfair Trade Practices and
Consumer Protection Law (“UTPCPL”), 73 P.S. §201-2. The general purpose of the UTPCPL is
to protect the public from fraud and unfair or deceptive practices. This statute is the
5
Commonwealth’s principal protection against such practices. Feeney v. Disston Manor Personal
.
Care Home, Inc, 849 A.2d 590, 597 (Pa.Super. 2004).
In order to state a claim under the UTPCPL, a plaintiff must allege one of the fraudulent,
unfair, or deceptive practices set forth in 73 P.S. § 201-2(4)(i)-(xxi). Id. The Plaintiff alleges
that Cody Financial violated 73 P.S. §201-2(4)(iii), (v), (vii) and (xxi). The Unfair Trade
Practices and Consumer Protection Law states as follow:
(4) “Unfair methods of competition” and “unfair or deceptive acts
or practices” mean any one or more of the following:
(iii) Causing likelihood of confusion or of misunderstanding as to
affiliation, connection or association with, or certification by another;
(v) Representing that goods or services have sponsorship, approval,
characteristics, ingredients, uses, benefits or quantities that they do not have
or that a person has a sponsorship, approval, status, affiliation or connection
that he does not have;
(vii) Representing that goods or services are of a particular standard,
quality or grade, or that goods are of a particular style or model, if they are
of another;
(xxi) Engaging in any other fraudulent or deception conduct which
creates a likelihood of confusion or of misunderstanding.
73 P.S. §201-2(4) (iii), (v), (vii), (xxi).
In 1996, the UTPCPL was amended to cover deceptive practices in addition to fraudulent
practices. After the 1996 amendments, the Superior Court continued to require that the elements
of common law fraud be met in order to establish a violation of the UTPCPL. Id. To prove
fraud, a plaintiff must demonstrate by clear and convincing evidence: (1) a representation; (2)
which is material to the transaction at hand; (3) made falsely, with knowledge of its falsity or
recklessness as to whether it is true or false; (4) with the intent of misleading another into relying
on it; (5) justifiable reliance on the misrepresentation; and (6) the resulting injury was
6
proximately caused by the reliance. Blumenstock v. Gibson, 811 A.2d 1029, 1034 (Pa.Super.
2002). However, the Federal Eastern District Court has ruled that following the enactment of the
amendments, the common law fraud elements need not be met. Jefferies v. Ameriquest Mortg.
,
Co. 543 F.Supp.2d 368, 389 (E.D.Pa. 2008). The Pennsylvania Supreme Court, in several cases
decided after enactment of the amendments, has required plaintiffs to at least prove the existence
of one of the common law fraud elements, justifiable reliance, to establish a UTPCPL violation.
Toy v. Metropolitan Life Ins. Co., 928 A.2d 186, 202-03 (Pa. 2007).
The only allegation making reference to 73 P.S. § 201-2(4)(iii) is paragraph 232 of the
complaint. In this paragraph, the Plaintiff avers, “Plaintiff believes, and therefore avers, that
Defendant Cody Financial and Defendant Lakeside Abstract are affiliated or associated with
each other. If true, this fact was not disclosed to Plaintiff.” It must be noted that on October 22,
2008, the Honorable Kevin Hess, granted Defendant Lakeside Abstract and Settlement, LLC’s
thth
Preliminary Objections and accordingly, the 15 and 16 counts, which were against Lakeside
Abstract and Settlement, LLC, were dismissed with prejudice thereby eliminating them as a
party to this litigation.
A fair reading of section 201-2(4)(iii) shows that the purpose of this section is to address
affirmative conduct or representations that someone is affiliated, connected, associated, or
certified by another entity. See Com. V. Parisi, 873 A.2d 3 (Pa. Commw. 2005). The Plaintiff’s
complaint does not allege that the Defendant made any affirmative misrepresentations as to any
association. Furthermore, given the overall nature of the Plaintiff’s complaint that the house she
purchased was defective and that the appraisal was overvalued does not in any way establish
how Plaintiff was “confused” regarding Defendant Cody’s affiliation, association, or connection
with any other entities. Accordingly, Defendant Cody’s Preliminary Objection with regard to a
7
violation of 73 P.S. § 201-2(4)(iii) is granted, and the claim arising under this section is
dismissed.
However, with regard to the claims under sections (4)(v)(vii) and (xxi), Hall set forth
numerous allegations that support her claim that Cody Financial has violated the UTPCPL. Hall
alleges that Cody Financial withheld the appraisal value from Hall, that they failed to inform
Hall of the requirement of a Seller’s Disclosure Statement, and that by allowing the closing to
proceed they represented to Hall that the property had a particular value that it did not have.
Accordingly, Defendant’s Preliminary Objections to the claims arising under these sections are
overruled.
C. Counts 18 and 19, Fraudulent Inducement and Fraudulent Non-disclosure
Plaintiff’s second cause of action (cause of action 18 of the Complaint) asserted against
Cody Financial is for fraudulent inducement. The elements of fraudulent inducement are: (1) a
representation; (2) which is material to the transaction at hand; (3) made falsely, with knowledge
of its falsity or recklessness as to whether it is true or false; (4) with the intent of misleading
another into relying on it; (5) justifiable reliance on the misrepresentation; and (6) the resulting
injury was proximately caused by the reliance. Eigen v. Textron Lycoming Reciprocating Engine
Div., 874 A.2d 1179, 1185 (Pa.Super. 2005), (citing Skurnowicz v. Lucci, 798 A.2d 788, 793
(Pa.Super. 2002), quoting Bortz v. Noon, 729 A.2d 555, 560 (Pa. 1999)).
Plaintiff’s third cause of action (cause of action 19 of the Complaint) asserted against
Defendant Cody Financial is for fraudulent non-disclosure. One is liable for fraudulent non-
disclosure if the party:
(1) has a duty to the other party to exercise reasonable care to disclose the matter
in question, and
8
(2) fails to disclose to another a fact that he knows may justifiably induce the
other to act or refrain from acting in a business transaction.
One party to a business transaction is under a duty to exercise reasonable care to
disclose to the other before the transaction is consummated:
(a) matters known to him that the other is entitled to know because of a
fiduciary or other similar relation of trust and confidence between them
(b) matters known to him that he knows to be necessary to prevent his
partial or ambiguous statement of the facts from being misleading
(c) subsequently acquired information that he knows will make untrue or
misleading a previous representation that when made was true or believed to be so
(d) the falsity of a representation not made with the expectation that it
would be acted upon, if he subsequently learns that the other is about to act in
reliance upon it in a transaction with him; and
(e) facts basic to the transaction, if he knows that the other is about to
enter into it under a mistake as to them, and that the other, because of the
relationship between them, the customs of the trade or other objective
circumstances, would reasonably expect a disclosure of those facts.
R(S)T § 551 (1977).
ESTATEMENT ECOND OF ORTS
Pursuant to this section, one may only be held liable for fraudulent nondisclosure if that
person is subject to one of the duties enumerated in subparagraphs (a) through (e). Youndt v.
First Nat. Bank of Port Allegany, 868 A.2d 539, 550 (Pa. Super. Ct. 2005). Defendant Cody
Financial argues that they had no fiduciary duty to Hall. It is established that in Pennsylvania, a
mortgage broker owes a fiduciary duty to its customers. McGlawn v. Pennsylvania Human
9
Relations Com'n, 891 A.2d 757, 769 (Pa.Cmwlth. 2006) (citing In re Barker, 251 B.R. 250
(Bankr.E.D.Pa.2000)).
Defendant argues that fraudulent inducement and fraudulent non-disclosure do not
constitute separate causes of action. However, the Pennsylvania Superior Court has specifically
recognized fraudulent non-disclosure as distinct from fraudulent inducement. In Youndt v. First
Nat. Bank of Port Allegany, 868 A.2d 539, 546 (Pa. Super. Ct. 2002), the court noted that for a
case of fraud in the inducement, a party makes affirmative fraudulent representations which
induce the other party to enter into an agreement. Youndt, 868 A.2d at 546 (citing Blumenstock
v. Gibson, 811 A.2d 1029, 1036 (Pa. Super. Ct. 2002)). The Pennsylvania Supreme Court has
stated that “[t]he deliberate nondisclosure of a material fact amounts to culpable
misrepresentation no less than does an intentional affirmation of a material falsity.” Neuman v.
Corn Exchange Nat. Bank & Trust Co. 51 A.2d 759, 764 (Pa. 1947). This clearly indicates that
Pennsylvania courts would consider an omission to be grounds for fraudulent non-disclosure,
while an affirmative representation fraudulently made would be grounds for a fraudulent
inducement claim. The Youndt Court further confirmed there are two separate torts that impose
liability for fraud upon a vendor of real estate in a commercial or residential transaction even
though the vendor made no affirmative misrepresentation: (1) Fraudulent Concealment; and (2)
Fraudulent Nondisclosure. Youndt, 868 A.2d at 549 (citing R(S)T
ESTATEMENT ECOND OF ORTS
§§ 550, 551 (1977)). Furthermore, the Pennsylvania Rules of Civil Procedure permit causes of
action to be pleaded in the alternative. Pa. R.C.P. No. 1020(c). Accordingly, Plaintiff is not
required to combine the counts of fraudulent inducement and fraudulent non-disclosure, and may
pursue them separately or as alternative pleadings.
10
Plaintiff has set forth facts in her complaint regarding her reliance on Cody Financial’s
services in purchasing the property. As is required for the purposes of evaluating a demurrer, the
facts set forth in the complaint are viewed as being true. Hall alleges that her reliance on Cody
Financial’s services and representations induced her to complete the purchase of the property
when, had she received accurate information that Cody Financial possessed prior to the closing,
she would not have bought the property.
Hall alleges that Cody Financial made false representations that it would handle all
aspects of the sale and closing, that it failed to inform Hall of the need for a Seller’s Disclosure
Statement, that it failed to inform Hall of the need for a home inspection, that it actively
discouraged Hall from retaining the services of an attorney or real estate agent, and that it did not
represent Hall at the closing. Hall alleges that Cody Financial withheld information from her
that was material to her decision to complete the purchase of the property. Specifically, Hall
alleges that Cody Financial inflated the sale price of the home and withheld the true value of the
home from Hall. Hall also alleges that Cody Financial did not notify Hall of the appraisal value,
and that had she reviewed the appraisal she would have seen the false/fraudulent entries and she
would not have proceeded with closing.
Defendant claims that the proximate cause required for the causes of action does not exist
because the damages claimed by Hall relate to the condition and value of the property and not at
all to the adequacy of the mortgage provided by Cody Financial. However, Hall claims that but
for the services provided and actions taken by Cody Financial she would not have proceeded
with closing on the property. Defendant did not review the Agreement of Sale, even though Hall
provided them with a copy, nor did they discuss with Hall the requirement of a Seller’s
Disclosure Statement or advise her to have a home inspection. Hall claims she was misinformed
11
about the accurate condition and value of the property because of her reliance on the information
and services provided by Cody Financial.
Hall has pleaded facts that, when accepted as true, could establish that Cody Financial
directly made representations or misrepresentations to her, that Cody Financial withheld material
information from Hall, that Cody Financial was aware that Hall would rely on their services for
the purchase of the property, and that Hall in fact relied upon the alleged representations by
Cody Financial. Hall alleges that she would not have purchased the property if not for the
financing obtained through direct services provided by Cody Financial, and would not have
completed the sale if she had known some of the information withheld by Cody Financial at the
time of closing. Because Hall has set forth allegations in her complaint that support fraudulent
non-disclosure and fraudulent inducement, Cody Financial’s preliminary objections to these
counts are overruled.
D. Count 20, Negligent Non-disclosure
Plaintiff’s fourth cause of action (cause of action 20 of the Complaint) asserted against
Defendant Cody Financial is for negligent non-disclosure. Defendant claims that negligent non-
disclosure is not a recognized cause of action in Pennsylvania and therefore the claim should be
dismissed or re-pleaded as negligent misrepresentation. There are no Pennsylvania Supreme
Court case rulings on negligent non-disclosure. The Pennsylvania Superior Court has reviewed
causes of action for negligent non-disclosure and has not ruled that such a cause of action does
not exist. See Baribault v. Peoples Bank of Oxford, 714 A.2d 1040, 1042 (Pa. Super. 1997).
A comment in the Restatement of Torts suggests that non-disclosure may be intentional
or negligent. The comment to subsection (2)(d) of section 551 states that “in the great majority
of cases the person owing the duty has so available an opportunity to make the required
12
or negligent
disclosure that it is rare that the failure to give it can be other than intentional .”
R(S)OT§ 551 cmt. on subsection 2 (emphasis added). In Destefano
ESTATEMENT ECOND F ORTS
& Associates, Inc. v. Cohen, the Philadelphia Court of Common Pleas distinguishes between
intentional non-disclosure and negligent non-disclosure. The court notes that unlike claims
based on intentional misrepresentation and concealment, claims for negligent misrepresentation
and negligent non-disclosure require an independent duty between parties. See Destefano &
Associates, Inc. v. Cohen, 2001 WL 1807790, *4 (Phila. Ct. Com. Pl. 2001). Given that a cause
of action for negligent non-disclosure has not been ruled nonexistent in Pennsylvania, and that
Hall has pleaded facts that support her allegations that she would not have completed the
purchase of the property but for the negligent non-disclosure of material facts by Cody Financial,
Defendant’s preliminary objection to this count is overruled.
E. Pa.R.C.P. 1028(a)(2) Requirement – Failure of Pleading to Conform to Law or Rule
of Court.
Defendant Cody Financial asserts that Plaintiff’s complaint fails to comply with
Pa.R.C.P. 1028(a)(2) because it fails to conform to Pa. R.C.P. 1019(i) – Claim Based Upon A
Writing. Defendant asserts that Plaintiff fails to meet this requirement because the causes of
action are based on writings which the Plaintiff failed to attach in their entirety. Specifically,
Defendant Cody Financial maintains Plaintiff did not attach a true, correct, and complete copy of
the Agreement of Sale to her complaint. Plaintiff’s complaint reveals that only page 4 of the
sales agreement was missing. Page 4 appears to have only contained the signatures of the
parties.
While the Plaintiff admittedly failed to attach a “complete” copy of the Agreement, the
Plaintiff did attach the material part of that writing. Plaintiff only omitted the signature page,
13
which was the fourth page of the four-page document. The substantive part of the Agreement
was contained on the first three pages, all of which were attached to the complaint. The specific
language of Pa.R.C.P. 1019(i) provides that:
(i) When any claim or defense is based upon a writing,
the pleader shall attach a copy of the writing, or the
material part thereof, but if the writing or copy is not
accessible to the pleader, it is sufficient so to state,
together with the reason, and to set forth the
substance in writing.
Additionally, Pa.R.C.P. 126 states:
The rules shall be liberally construed to secure the
just, speedy and inexpensive determination of every
action or proceeding to which they are applicable.
The court at every stage of any such action or
proceeding may disregard any error or defect of
procedure which does not affect the substantial
right of the parties.
This Court finds that Hall’s complaint has substantially complied with Pa.R.C.P. 1019(i)
and that any omissions from the writings attached to the complaint do not affect the substantial
rights of the parties, and therefore Plaintiff has complied with Pa. R.C.P. 1028(a)(2).
F. Conclusion.
The facts pled by Hall and reasonable inferences from those facts indicate that Hall’s
purchase of the property was dependent on Cody Financial’s services. This Court finds that
there is sufficient evidence required to preserve Hall’s claim that she relied on Cody Financial’s
services and trusted that they had reviewed and approved the relevant information such as the
appraisal, purchase price, and terms of the sale agreement. Cody Financial specifically
represented to Hall that they would handle all aspects of the sale and closing and actively
discouraged her from obtaining the services of an attorney or real estate agent. Upon review and
consideration of all material facts in the complaint, this Court finds that there is no doubt as to
14
the legal sufficiency of each of the four causes of action against Cody Financial. Therefore, this
Court concludes that Defendant Cody Financial’s preliminary objections are overruled, with the
exception of the claim under 73 P.S. § 201-2(4)(iii), which is granted.
Accordingly, the following order shall be entered:
ORDER OF COURT
th
AND NOW
, this 10 day of July, 2009, upon consideration of the preliminary objections
of Defendant Cody Financial Mortgage Services, Inc., to Plaintiff’s complaint, the briefs filed by
the parties, and after argument;
IT IS HEREBY ORDERED AND DIRECTED
that:
1. As to Count 17, Defendant’s preliminary objection filed pursuant to Pa. R.C.P.
GRANTED in
1028(a)(4) (Demurrer- Legal Insufficiency of Plaintiff’s Complaint) is
part OVERRULED in part.
andWith regard to Plaintiff’s Complaint alleging a
violation of the Unfair Trade Practices Act and Consumer Protection Law under 73 P.S.
GRANTED
§201-2(4)(iii) is . With respect to the alleged violations of 73 P.S. § 201-
OVERRULED
2(4)(v)(vii)(xxi) is .
2. As to Counts 18, 19, and 20, Defendant’s preliminary objections filed pursuant to
Pa.R.C.P. 1028(a) (Demurrer – Legal Insufficiency of Plaintiff’s Complaint) are
OVERRULED
.
3. Defendant’s preliminary objection filed pursuant to Pa.R.C.P. 1028(a)(2) (Failure of
OVERRULED
Pleading to Conform to Law or Rule of Court) is .
By the Court,
M. L. Ebert, Jr., J.
15
Laurence C. Kress, Esq.
Scaringi & Scaringi, P.C.
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
Attorney for Plaintiff
James D. Hughes, Esq.
Laura Rebecca Ables, Esq.
Salzmann Hughes, P.C.
354 Alexander Spring Road
Carlisle, PA 17015
Attorneys for Defendant Cody Financial
Mortgage Services, Inc.
16