# Petition for Writ of Certiorari — Atlas Van Lines, Inc. v. Lewis (No. 08-901)

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Petition for Writ of Certiorari
- **Published:** January 1, 2008

## Text

mfp ae TT vs WA.
2

&) No. 08-_____- 0. 8-9! 17 = 2009

OFFICE JF THE CLERK

In The
Supreme Court of the Anited States

2

ATLAS VAN LINES, INC.,

Petitioners,

RICHARD J. LEWIS AND PATRICIA L. LEWIS,

Respondents.

On Petition For Writ Of Certiorari
To The United States Court Of Appeals
For The Third Circuit

PETITION FOR WRIT OF CERTIORARI

@

JAMES A. WESCOE
RAWLE & HENDERSON
The Widener Building
One South Penn Square
Philadelphia, PA 19107
(215) 575-4200
Counsel for Petitioners

(OOK LAW RRIEP PRINTING ©) (S001 229-6964
OK CALL COLLECT 12) 542-2831

QUESTION PRESENTED FOR REVIEW

Did the United States Court of Appeals for the
Third Circuit err in ruling that the respondents’
October 26, 2004 letter to Atlas Van Lines, Inc., an
interstate motor carrier, in which respondents failed
to assert any dollar amount or estimated dollar
amount or range of dollar amounts for their damages,
nonetheless satisfied the federal claim-filing re-
quirements of 49 U.S.C. §14706 and 49 C.F.R.
§ 370.3(d)(3), and, as a consequence, undermine the
intent and purpose of the Carmack Amendment by
establishing a new, third standard for determining
the sufficiency of interstate cargo claims that further
defeats and contradicts the goal of uniform and cost-
effective claim settlement practices for shippers and
carriers throughout the United States?

i
PARTIES TO THE PROCEEDINGS

Pursuant to Supreme Court Rule 14.1, petitioner
states that all parties to the proceedings in the court
whose judgment is sought to be reviewed are listed in
the caption.

RULE 29.6 STATEMENT

The parent company of petitioner Atlas Van
Lines, Inc. is Atlas World Group, Inc., which is not a
public company. No publicly held company owns more
than 10% of petitioner’s stock.

ili

TABLE OF CONTENTS

Page

Question Presented for Review .......................0068 1
SMPLION CO CMO PLOCROGIIAGN 6..co. oececccsisevizcncasdacsveavess i
De re OG niss ssccge cede sens nessacesvapeencineasenes ii
IIE stein sec itrantncs sorcarriiectcesaeean Vv
IS PMI osu ieinve-cknssueTcnpsavepinieszenemeabbesbriaees 1
IIE 65 dass soxietcenindiekbutcvacensicanemeanadenaoeke 2
Statutes and Regulations Involved ..................... 2
BIA MOAt Of MS CANS ..0..cccscccssrccciscsesccscscvansseseces 3
Reasons Why the Writ for Certiorari Should Be

IE sinssccsnticis eccxascismmnesssen dats eel 10
Io Siitihiisinkelcctisacaveeeans saan 32
Appendix
Opinion of the United States Court of Appeals

for the Third Circuit dated September 9,

2008 vacating the Order of the District Court

and remanding for further proceedings con-

membernt WICH CHO COPIOP 5.5 .ccccscnsasscenccscressnssossenes App. 1

Opinion of the United States District Court for
the Middle District of Pennsylvania, dated
EM DO OE iNisxnicinisnstiicinurcetinvsakeseliebsbleess App. 23

Opinion of the United States Court of Appeals
for the Third Circuit dated October 9, 2008
denying the Petition for Rehearing and/or
PCO TE THY eiincstiessisceiciiocnsecdcaverteacoueee App. 38

Statutes and Regulations Involved................... App. 40
Complaint with Attached Exhibits ................... App. 50

TABLE OF CONTENTS — Continued

Page
I ii el catiedixvaterincessievindaaviareeulens App. 87
COOCOROE BS, BOE Lt oe ccsicceccssscccsccssevsseccesees App. 123
November 4, 2004 Letter.................cceeeese eens App. 126

November §, 2005 Latter. ...........00.0..cccssshroceesses App. 128

TABLE OF AUTHORITIES

Page
CASES
Adams Express Co. v. Croninger, 226 U.S. 491
= ES SE AAO teeter PEED OR Pe SEMIS 12, 13, 14
Atchinson T:. & S.F. Ry. v. Harold, 241 U.S. 371
SERIA ee ROR RB eo SCE deere RO ey Ieee 14
Charleston & Western Carolina Ry. Co. v.
Varnville Furniture Co., 237 U.S. 597 (1915)......... 14
Cleveland v. Beltman North American Van
Lines Co., Inc., 30 F.3d 379 (2d Cir. 1994) ............. 15

Coughlin v. United Van Lines, LLC, 362
¥. Supp. 2d 1166 (C.D. Cal. BO0S)...cccccccsccccsccssccseecs 15

Culver v. Boat Transit, Inc., 782 F.2d 1467 (9th

Rn CAIN «bc cac'a 3 sicshcaabavasdad (ea doaadasaaeacedsthnbstabetanaeiakesee 21
Ford Moior Co. v. Transport Indem. Co., 795

Be OO CO CAE, WG on ovcvincvcniciescsivicescccssosvesescovens 17
Fulton v. Chicago, Rock Island & P.R. Co., 481

Brae Ge I RNS. BIFFY Spas ccc cee Rckce hecticicgssceanncndons 15
Georgia, Florida & Alabama Ry. Co. v. Blish

Milling Co., 241 U.S. 190 (1916)......... ieieuccrxat 13, 14
Hoskins v. Bekins Van Lines, 343 F.3d 769 (5th

RN NEY 9234 chiemcsicdacsgs cadakecacidsstemunteicen take ae ta daokinanes 15

Hughes v. United Van Lines, 829 F.2d 1407 (7th
es EO a cviddstestasienticssastideeitoNana serie reuedeviadi esa 16

Hughes Aircraft v. North American Van Lines,
970 F.2d 609 (9th Cir. 1992)

TABLE OF AUTHORITIES — Continued

Page
Ins. Co. of N. Am. v. G.I. Trucking Co., 1 F.3d
903 (9th Cir. 1993), cert. denied, 510 U.S.
tie iso csdusetiatcnaapinedcdigniepeshssbanleikeshvas neste: 21
Intech, Inc. v. Consolidated Freightways, Inc..,
ee Be SI CEBE CAG, LOGT) vcccscsessesscscesscesssecesscescees 15
Kvaerner E&C Metals v. Yellow Freight Sys.,
Inc., 180 Fed.Appx. 172 (9th Cir. 20085) ................. 21
Louisville & Nashville R. Co. v. Rice, 247 U.S.
NE rns cos Saco tanassncgvereseuardsbseausuvadsedsndqueheieasses 14
McLaughlin Transportation Systems, Inc. v.
Rubinstein, 2005 U.S. District LEXIS 19932
IN I oreo dg sce colnsiecadaceusnchvaceveaiaes oineuarks sea 22
Missouri Pacific Ry. Co. v. Elmore & Stahl, 375
AN I 0 as cied iva 25 didn iaadsus nave veaeaeherecsdasaian 15
Moffit v. Bekins Van Lines Co, 6 F.3d 305 (5th
als te tone siauecs gobaguauiaelceniauneainasins 15
Myrick v. Michigan Central R.R., 107 U.S. 102
SNE Pasta cet thd csacse dei duacdicaeyeeedansiane Giacsbaiasaciarsbin’ 14
Nedlloyd Lines B.V. Corp. v. Harris Transport
Co., 922 F.2d 905 (ist Cir, 1991)...............ccsc0es. 22, 26
New York, N.H. & H.R. Co. v. Nothnagle, 346
ee

BROKER: JackGaughen | SALES ASSOCIATE: Ingrid M. Lochte __ =

Acting as: (x) Seller’s Agent ( ) Transaction Licensee ( ) Dual Agent ©
( ) Designated Agent for Buyer with Broker as Dual Agent of Seller and Buyer

THIS AGREEMENT is made this 14 — day of March , 2005

1, PARTIES: Between Lewis
hereinafter called Seller, and Charles E & Constance B. Patterson
(residing at XXX XXX XXX XXX PA xxx Zip ) hereinafter called Buyer r.

bo

PROPERTY: Seller hereby agrees to sell and convey to Buyer, who hereby agrees to
purchase: ALL THAT CERTAIN tract of ground with improvements thereon, if any, known as
XXX XXX XXX XXK

Municipality XXX ,County xxx, State PA Zip
Identification: (Tax ID#; Parcel #; Deed Book/Page)

3. ZONING: The ZONING CLASSIFICATION of the property is Resid _. Failure of this
Agrcement to contain the zoning classification (except in cases where the property and each
parcel thereof, if subdividable, is zoned fully or primarily to permit single family dwellings)
shall render this Agreement voidable at the option of the buyer, and, if voided, any deposit
tendered by the Buyer shall be returned to the Buyer without any requirement for court

action.
4. PURCHASE PRICE: The purchase price is $ 280,000 |/s/ CEP 3/31/05 /s/ CP 3/31/05
/s/ RJL/PAL] ( Two Hundred Stxty Righty [/s/ ¢ !CEP 3/31/05 /s/ CP 3/31/05
/s/ RJL/PAL| Thousand — 00/00 Dollars to be | paid in n cash or “equivalent : at Lime of
seltlement

5. DEPOSITS: Security for the purchase is to be as follows:
a) Cashvcheck at signing of this Agreement. $

b;} Cash/check on or before Mareh-26 [April 3), 2005. = $ 1,000.00
/si CEP 3/31/05 /s/ CP 3/31/05 /s’ RJL/PAL 2/31/05]

ci Noteother(specifyy = ; x re
6. FINANCING CONTINGENCY: This sale is contingent upon the following financing for

Buyer:

a) The amount of financing $ 235,700 _ is for a term of 15 years. The type of financing

8010/10 (Fixed/Adjustable/Insured: Interest rate of 0 %; however, Buyer agrees te

accept the interest rate as may be committed by the mortgage lender, not to exceed a
maximum interest rate of 6 %.

i o)

b)

c}

d)

e)

f)

The Seller agrees to pay Buyer's closing costs, including prepaid expenses in the
maximum amount of 0)

The maximum financing placement, origination, or loan discount fees, or similar charges,
to be paid by BUYER shall not exceed — 0% of loan amount.

Unless otherwise agreed by Seller, Buyer's financing shall not be contingent upon sale
or settlement of any real estate owned by Buyer.

Buyer shall make a completed application including payment for appraisal and credit report to
a responsible lending institution on or before 3-20-06 [4-3-05] .

(/si CEP 3/31/05 /s/ CP 3/31/05 /s/ RJL/PAL 3/31/05] Should the Buyer fail to make
such completed application within the specified time, it shall be the option of the
Seller to declare this Agreement of Sale null and void at which time all deposit monies
paid on account shall be forfeited to the Seller as liquidated damages and all copies
of this Agreement shall be returned to the Seller's agent for cancellation. Financing
terms as stated above cannot be changed without written agreement of all parties.

oot ‘ddy

A written mortgage commitment must be obtained by 4-30-05. Ifa written commitment
is not received by the above date, Buyer and Seller agree to extend the commitment date
until Seller terminates this Agreement in writing; and in such event, any deposit shall
be returned to Buyer.

ADDITIONAL TERMS AND CONTINGENCIES ARE:

a)

b)
¢)
da)

e)

f)

Written acceptance of all parties must be obtained on or before: 3-46-06 [4-1-05]
/s/ CEP 3/31/05 /s/ CP 3/31/05 /s/ RJL/PAL 3/31/05]

Settlement is to be made on or before 5-15-05

Possession is to be delivered: settlement

Payment of transfer taxes will be divided equally between Buyer and Seller.

All income and expenses, including but not limited to real estate taxes, rents, water, sewer
and refuse charges, condo fees, homeowners’ association fees and similar charges, public or
private, shall be prorated to date of (settlement/possession) on a fiscal year basis.

(see addendum A & B}

FIXTURES, TREES, SHRUBBERY, ETC.: All plumbing, heating, air conditioning and
electrical systems and fixtures and systems appurtenant thereto and forming a part thereof,
antennas, masts and rotor systems; screens, storm windows and/or doors, shades, awnings,
blinds, drapery and curtain rods and hardware; radiator covers, kitchen cabinets, built-in
appliances and wall-to-wall carpet, all trees, shrubbery, and plantings now on property, garage
door openers, storage sheds, remaining heating and cooking fuels, excluding propane, stored on
the property al time of settlement, all items included in the Seller Disclosure Statement, and

None of the above-mentioned included items shall be removed by Seller from premises after
the date of this Agreement. Seller hereby warrants that Seiler will deliver good title to all
the articles deseribed in this paragraph, and any other fixtures or items of personality
specifically scheduled to be included in this sale.

oO
9
—
S
—

App. 102

10. ASSESSMENTS AND NOTICES: As of the
acceptance date of this Agreement, Seller repre-
sents the following:

a)

b)

c)

d)

e)

f)

No public assessment or notice of a future
public assessment for any matter including
water, sewer, sidewalk or curbs, has been
made against the property.

Buyer acknowledges that taxes may increase
due to change of assessment or millage rates.

No condominium or homeowners’ association
assessments, if any, remain unpaid.

Seller has no knowledge of any notice by any
governmental or public authority relating to
violations of zoning, housing, building, safety
or fire ordinances or codes.

Buyer is advised that access to a public road
may require issuance of a highway occu-
pancy permit from the Department of Trans-
portation.

Sellers of property enrolled in the Clean and
Green program shall, as required by law,
give the county assessor 30 days notice of the
pending sale.

Buyer acknowledges that building codes,
zoning ordinances, suddivision ordinances
and restrictive covenants may control any
addition to or modification of the property as
well as restrict the use of the property.

If prior to settlement Seller receives any assess-
ments or notices, as previously stated, then
Seller shall immediately give notice to Buyers.

11.

12.

App. 103

Unless otherwise prohibited by law, Buyer will be
responsible for any written notice served upon
Seller after execution of this Agreement and for
the payment thereafter of any public improve-
ment and condominium or homeowners’ associa-
tion assessments.

RIGHT-TO-FARM LAW 3 P.S. SECTION 951-
957: The property you are buying may be located
in an area where agricultural operations take
place. Pennsylvania protects agricultural re-
sources for the production of food and agricul-
tural products. The law limits circumstances
where normal agricultural operations may be
subject to nuisance lawsuits or restrictive ordi-
nances.

TITLE AND COSTS:

a) The Premises are to be conveyed free and
clear of all liens, encumbrances and ease-
ments, EXCEPTING HOWEVER: Existing
building restrictions, ordinances, easements
of roads, easements visible upon the ground,
privileges or rights of public service compa-
nies, if any; otherwise the title to the above-
described real estate shall be good and mar-
ketable and such as will be insured by a
reputable Title Insurance Company at the
regular rates.

b) If the Seller cannot give a good and market-
able title, such as will be insured by a repu-
table Title Insurance Company at regular
rates, then the Buyer has the option of tak-
ing such title as the Seller can give without

abatement of prove or of being repaid all

c)

d)

App. 104

monies paid by Buyer to Seller on account of
the purchase and the Seller will reimburse
the Buyer for any costs incurred by the
Buyer for inspections specified in paragraph
#9 and #12(c) items (1), (2), (3), and in para-
graph #*2(d); and in the latter event there
shall be no further liability or obligation on
either of the parties hereto and this Agree-
ment shall become NULL AND VOID and all
copies will be returned to Seller’s agent for
cancellation.

The Buyer will pay for the following:

1) The premium for title insurance and/or
title search, or fee for cancellation of
same, if any.

2) The premiums for flood insurance and/or
fire insurance with extended coverage,
insurance binder charges or cancellation
fee, if any.

3) Appraisal fees and charges paid in ad-
vance to mortgagee, if any.

4) Buyer’s normal settlement costs.

Any survey or surveys which may be re-
quired by the Title Insurance Company or
the abstracting attorney, for the preparation
of an adequate legal description of the prem-
ises (or the correction thereof), shall be se-
cured and paid for by the Seller. However,
any survey or surveys desired by the Buyer
or required by his/her mortgagee shall be se-
cured and paid for by the Buyer.

13.

14.

15.

App. 105

DOMESTIC RELATIONS LIEN: Pennsylvania
law requires county Domestic Relations Offices to
impose property lens for overdue child support.
If applicable, Buyer and Seller shall advise their
agent/licensee so verification of lien status can be
promptly determined.

DEPOSIT AND RECOVERY FUND: Deposits
or hand monies shall be paid to Listing Broker,
who shall retain the same until consummation or
termination of this Agreement in conformity with
all applicable laws and regulations. Listing Bro-
ker may hold any uncashed check tendered as
deposit pending the acceptance of this other. In
the event of dispute for the return of deposit
monies, Listing Broker will distribute the monies
pursuant to a final order of court or the written
agreement of the parties. A real estate recovery
fund exists to reimburse persons who have suf-
fered monetary loss and have obtained an uncol-
lectible judgment due to fraud, misrepresentation
or deceit in a real estate transaction by a Penn-
sylvania licensee. For complete details, call 717-
783-3658.

TENDER AND POSSESSION:

a) Title shall be tendered by way of warranty
deed and possession is to be delivered by
keys to a vacant building (Gf any) broom
clean, free of debris or by deed and assign-
ment of existing lease(s) at time of settle-
ment if premises are tenant-occupied at the
signing of this Avgreement, unless otherwise
specified herein.

16.

b)

d)

App. L06

Seller will not enter into any new leases,
written extension of existing leases, if any, of
the premises without expressed written con-
sent of the Buyer.

Formal tender of an executed deed and pur-
chase money is hereby waived.

Buyer reserves the right to make a pre-
settlement inspection of the subject prem-
ises.

MAINTENANCE AND RISK OF LOSS

a)

b)

C)

Seller shall maintain the property (including
all items mentioned in paragraph #8 herein)
and any personal property specifically sched-
uled herein in its present condition, normal
wear and tear excepted.

Seller shall bear risk of loss from fire, or
other casualties until time of settlement. In
the event of damage to any property included
in this sale by fire or by other casualties, not
repaired or replaced prior to settlement,
Buyer should have the option of rescinding
this Agreement and receiving all monies paid
on account or of accepting the property in its
then condition together with the proceeds of
any insurance recovery obtainable by Seller.
Buyer is hereby notified that he may insure
his equitable interest in this property as of
the time of the acceptance of this Agreement.

Buyer agrees, if necessary, to apply to not
less than three insurance companies in order
to secure basic Homeowners insurance cov

erage.

17.

18.

19.

App. 107

RECORDING: This Agreement shall not be
recorded in the Office for the Recording of Deeds
or in any other office or place of public record.

ASSIGNMENT: This Agreement shall be bind-
ing upon the parties, their respective heirs, per-
sonal representatives, guardians and successors,
and to the extent assignable, on the assigns of
the parties hereto, it being expressly understood,
however, that the Buyer shall not transfer or as-
sign this Agreement without the written consent
of the Seller.

DEFAULT: Time shall be of the essence with
respect to performance of any obligation arising
under this Agreement. Compliance therefore
must be made by the specified date(s) or Seller
may, at Seller’s sole election, hold Buyer in
breach of this agreement. Should the Buyer: 1)
fail to make any additional payments, as speci-
fied in paragraph #5, or 2) furnish false or in-
complete information to the Seller, Seller’s Agent
or the mortgage lender concerning the Buyers le-
gal or financial status, or fail to cooperate in the
processing of the mortgage loan application,
which acts would result in the failure to obtain
the approval of mortgage loan commitment, or 3)
violate or fail to fulfill and perform any of the
terms or conditions of this Agreement. The Seller
may, at Seller’s option, elect:

a) to declare the agreement of sale null and
void; and

b) to proceed against the buyer for Seller’s ac-
tual damages; or

20.

App. 108

c) to retain all deposit money paid on account
as liquidated damages which amount the
parties agree|is a reasonable sum and not in
the nature of a penalty.

Should the Seller violate or fail to fulfill and
perform any of the terms and conditions of this
Agreement, Buyer may elect:

a) to pursue Buyer’s remedy for specific per-
formance of the Agreement or

b) proceed against the Seller for Buyer’s actual
damages; or

c) receive a return of the deposit money and
also be entitled to receive an additional sum
equal to the deposit money paid on the ac-
count as liquidated damages which amount
the parties agree is a reasonable sum and
not in the nature of a penalty.

REPRESENTATIONS: Seller represents that
Seller has informed Buyer of any hidden or latent
defects of which Seller has knowledge. It is un-
derstood that the Buyer has inspected the prop-
erty and any personal property to be included in
the sale or hereby waives the right to do so and
has agreed to purchase it as a result of such in-
spection and not because of_or in reliance upon
any representations which were not included in
this agreement whether made by any broker,
transaction licensee or any of their respective
sales people, employees, officers and/or partners.

Buyer agrees that any and all statements,
claims, advertisements, marketing, promotional
exhibits, building and subdivision plans made

2

nN
wo

1.

App. 109

or presented by Seller, brokers, their licensees,
employees, officers. or partners are not incorpo-
rated in this agreement of sale unless expressly
so stated to be made a part thereof. The Buyer
has agreed to purchase the property in its pre-
sent condition unless otherwise specified herein.
It is further understood that this Agreement con-
tains the whole Agreement between the Seller
and the Buyer and there are no other terms, obli-
gations, covenants, representations, statements
or conditions, oral or otherwise, of any kind
whatsoever concerning this sale. Furthermore,
this Agreement shall not be altered, amended,
changed or modified except in writing executed
by the parties.

RELEASE: Buyer hereby releases, quit-claims
and forever discharges all real estate licensees,
employees and any officer or partner of any one
of them and any other person, firm or corporation
who may be liable by or through them from any
and all claims, losses or demands, in law or eq-
uity, including but not limited to personal inju-
ries, property damage and any and all of the
consequences thereof, whether now known or not,
which may arise from the presence of mold, all
wood-boring insects, radon, lead-based paint
hazards, environmental hazards, any defects or
deficiencies in the onlot sewage disposal system
and/or on-site water service system, or any de-
fects or conditions on the property. This release
shall survive settlement.

MEDIATION: The Buyers, Sellers and Brokers
agree that disputes relating to this Agreement
SHALL be submitted to mediation in accordance

23.

App. 110

with the rules and procedures of the dispute reso-
lution system established by the REALTORS®
Association of York and Adams Counties, Inc.,
and that if any agreement is reached by the Buy-
ers, Sellers and Brokers pursuant to a mediation
conference, it shall be binding upon them. Costs
of mediation to be shared equally by Buyers,
Sellers and Brokers named in the dispute. This
duty to mediate disputes shall survive final set-
tlement.

EXECUTION: This Agreement and any amend-
ments thereto, maybe executed by the parties by
way of transmission through a Facsimile (FAX)
machine; such a copy shall have the same legal
enforceability and binding effect upon the parties
as though it were signed by all parties in original
form.

APPROVAL BY BUYER: The Buyers hereto, intend-
ing to be legally bound hereby, have hereunder set
their hands and seals the day and year first above

written.
WITNESS BUYER
/s/ [Illegible | 7 /s/ Charles E. Patterson
(SEAL)

WITNESS
/s/ (Hlegible] BUYER

~/s/ Constance B. Patterson _
WITNESS (SEAT)

aes ___ BUYER

(SEAL)

App. 111

APPROVAL BY SELLER: Seller hereby accepts/
counteroffers the above proposal this __lst_ day of

April _—_, 2005.

The effective date of this Agreement shall be the date
on which the offer or any counteroffer is accepted as
evidenced by the dated signature or dated initials.

WITNESS SELLER
/s/ [illegible] /s/ Richard J. Lewis
(SEAL)
WITNESS SELLER
/s/ Patricia A. Lewis
WITNESS (SEAL)
__ SELLER

(SEAL)

App. 112

DISCLOSURES AND INSPECTION ADDENDUM
Form approved by REALTORS® Association of York and Adams Counties, Ine.

DATE 3-14-05

RE: PROPERTY XXX s ae tae
SELLER: Lewis Ds 2 ae eae PE Oe ene es eae
BUYER: Charles E & Constance B. Patterson PL RD a

It is understood and agreed that the above Agreement of Sale shall be endorsed as follows:

Seller and Buyer include the initialed paragraph(s) as supplemented by the applicable provisions on THE REVERSE SIDE OF
THIS DOCUMENT , as part of the above-captioned Agreement.

IN THE EVENT THE INSPECTIONS, TESTS AND/OR CERTIFICATIONS, INCLUDING WRITTEN RESULTS FURNISHED
TO SELLER, ARE NOT COMPLETED WITHIN TIE PRESCRIBED TIME PERIOD STATED BELOW, THEN ALI PARTIES
ACKNOWLEDGE THAT BUYER’S RIGHT TO CONDUCT SAID INSPECTIONS SHALL BE WAIVED UNLESS PRESCRIBED
BY THE MORTGAGE LENDER, from whom buyer is securing a loan, in accordance with the mortgage contingency clause in the
above-captioned Agreement.

/ / 1. Condominium or Planned Community
Seller Buyer Public offering statement or resale certificate and related documents as applicable for condomiuniturn or

Planned Community to be received on/or before
These documents cannot be waived.

/ CEP /CP_ 2. Wood Destroying Pest Inspection Completed on/or before : 4-17-45
Seller Buyer (15 days after ratified contract
[/s/ PAL/RJIL CEP/CP 3/31/05]

—— s CEP /CP_ 3. On-Lot Waste Water Treatment System Completed on/or before 4-17-05
Seller Buyer Inspection (15 days after ratified contract
[/s/PAL/RJIL CP/CEP 3/31/05]
/ CEP /CP 4. Water Test: —— Coliform Bacteria (Potability)
Selier Buyer ¥_FHA/VA
___Other:

Completed on/or betore

App. 113

— a CEP / CP 5. Other Inspection(s):
Seller Buyer
__ Air Conditioning Completed on/or before :
_____ Roof/Flashing Completed on/or before
____ Plumbing Completed on/or before
Heating Completed on/or before _
Electrical Completed on/or before 2
Structural Completed on/or before
ELFS (synthetic stucco) Completed on/or before apy:
_¥_ Other: Check Motor Radon System Completed on/or before 4-17-05
(15 days after ratified contract)
[/s/ RJL/PAL CP/CEP 3/31/05]
15 days after
f CEP /CP 6. Whole House Inspection Completed on/or before _ -atified contract
Seller Buyer [/s/ CP/CEP PAL/RJL 3/31/05]

If Buyer elects to have a whole house inspection, unless specifically agreed by Buyer and Seller
to the contrary, such inspection shall be performed in accordance with all of the provisions of the
Pennsylvania Home Inspection Law. (See Pennsylvania Home Inspection Law notice on Reverse)

= ff es 7. Radon Test Completed on/or before
Seller Buyer
f / 8. Mold Inspection/Test Completed on/or before

Seller Buyer

App. 114

WAIVER OF INSPECTIONS: Unless otherwise
requested in paragraphs 1 through 8 by Buyer, or
unless required by Buyer’s mortgage lender, Buyer
hereby acknowledges and agrees that Buyer uncondi-
tionally waives any and all rights to any pre-
settlement tests, inspections or certifications concern-
ing the condition of the subject property whatsoever.
This waiver applies regardless of whether Buyer has
acquired equitable interest in the property under the
provisions of this Agreement of Sale.

All the inspections or re-inspections called for above
are the Buyer’s responsibility, and shall be Buyer’s
expense, unless otherwise prescribed by law or gov-
ernment regulation. Buyer agrees to pay for any
indicated inspections whether or not settlement
occurs. Provided, however, the cost of the On-Lot
Waste Water Treatment System Inspections shall be
allocated between the Buyers and Sellers as follows:
Locating, Uncovering & Recovering Septic to be paid
by __—C, Pumping Septic to be paid by __
Inspection to be paid by __

es, |

Upon the execution of this agreement, authority is
hereby given to Buyers to select said inspection
companies.

Buyer hereby states that he/she understands that
he/she is not obligated to use any individual firra
recommended or suggested by any Broker/salesperson
involved in this transaction. However, if authority
has been given such Broker/salesperson to order any

App. 115

tests or inspections, as evidenced by the preceding
paragraph, Buyer hereby releases Broker/salesperson
from any claim arising out of their selection of any
individual or firm.

Seller is hereby notified that all utilities must pe
connected and operational for a whole house inspec-
tion or specific component inspection and it is Seller’s
responsibility to have utilities on and available for
inspector. Should utilities not be connected and re-
inspection is required, cost shall be paid by Seller.

All other terms and conditions of the said Agreement
shall remain unchanged and in full force and effect.

DEFINITIONS AND NOTICES

1. CONDOMINIUM OR PLANNED COMMU-
NITY:

A prospective Buyer of a condominium unit or a
property within a Uniform Planned Community
has the option of canceling the Agreement of Sale
with the return of all deposit monies, until a re-
sale certificate has been provided to the prospec-
tive Buyer and for 5 days thereafter or until
conveyance of the property, whichever first occurs.

WOOD DESTROYING PEST INSPECTION:

to

A wood destroying pest infestation and damage
report from a licensed exterminator. Such certifi-
cation is to provide that an inspection of the
readily accessible areas of the existing building(s)
and other vulnerable improvements on the sub-
ject property has been made satisfactory to and

App. 116

in compliance with all applicable laws and the
requirements of any mortgage or lending institu-
tion or any agency providing federal insurance or
guarantees. Seller may receive notice from the
exterminator that there exists either active infes-
tation(s) or evidence of previous infestation(s)
and/or resultant damage, which has not been cor-
rected.

ON-LOT WASTE WATER TREATMENT
SYSTEM INSPECTION:

A written report from a qualified inspector that
the sewage system is functioning properly. A
proper test may include locating and uncovering
septic system, pumping of tank and inspection of
components existing in system. Vacant property
may require additional testing which may in-
clude a hydraulic load test.

(NOTICE: Some municipalities may require
outdated and malfunctioning on-lot systems to be
replaced. )

WATER TEST:

Water test(s) from a certified laboratory accord-
ing to standards established by the Environ-
mental Protection Agency (EPA).

OTHER INSPECTIONS:

Written report(s) from qualified inspector(s) that
at the time of inspection the indicated system(s)
are in good working order and structurally sound
(if structural inspection requested). With regard
to plumbing, heating, roofing and flashing, age
and normal wear and tear are not deficiencies.

D

App. 117

Exterior Insulation and Finish Systems (syn-
thetic stucco) are multi-layer materials applied to
the exterior of some buildings. Improper installa-
tion of synthetic stucco may result in moisture
penetrating the surface of the walls which may
cause damage to the building.

WHOLE HOUSE INSPECTION: (68 Pa. C.S.A.
§7501, et. seq., effective December 20, 2001)

a)

b)

Cc)

d)

The Home Inspection Law applies to residen-
tial real estate transfers of not less than one
and not more than four residential dwelling
units.

A home inspection under this law is a nonin-
vasive, visual inspection of some combination
of the mechanical, electrical or plumbing
systems or the structural and essential
components of a residential dwelling de-
signed to identify material -}efects in those
systems and components.

A home inspection under this law does not
include an examination of a single system or
component of a residential dwelling such as
electrical or plumbing systems or its roof. It
also does not include inspections that are
limited to one or more of the following: wood
destroying insects, wells, septic systems, air
and air quality, and environmental hazards.

A material defect, if identified by a home in-
spection, is any problem with the property or
any portion of it that would have a signifi-
cant adverse impact on the value of the
property or that involves unreasonable risk

e)

f)

App. 118

to people on the property. The law further
states that a structural element or system
that is near or beyond the end of its normal
useful life is not by itself a material defect.

A material defect, therefore, does not gener-
ally include maintenance and .osmetic items
unless they meet the definition above stated.

A home inspector is defined to be an individ-
ual who performs home inspections and is a
member of a national home inspection asso-
ciation. The law requires that home inspec-
tors provide customers with verifications
that they are a member of such an organiza-
tion.

RADON TEST:

A radon test from a qualified testing service
indicating that radon gas, if present, is within
limits deemed acceptable by the United States
Environmental Protection Agency (EPA).

NOTICE TO SELLER/BUYER REGARDING
RADON GAS:

a)

Radon is a radioactive gas produced natu-
rally in the ground by a normal decay of
uranium and radium. Uranium and radium
are widely distributed in trace amounts in
the earth’s crust. Descendants of radon gas
are called radon daughters or radon progeny.
Several radon daughters emit alpha radia-
tion, which has high energy but short ranve.

8.

b)

¢)

e)

App. 119

Studies indicate the result of extended expo-
sure to high levels of radon gas/radon daugh-
ters is an increased risk of lung cancer.

Radon gas originates in soil and rocks. It dif-
fuses, as does any gas, and flows along the
path of least resistance to the surface of the
ground, and then to the atmosphere. Being a
gas, radon can also move into any air space,
such as basements or crawl spaces, and per-
meate throughout the home.

If a house has a radon problem, it can usu-
ally be cured by (a) increased ventilation,
and/or (b) preventing radon entry.

The EPA advises corrective action if the AN-
NUAL average exposure to radon is at or
above 4pCl/L. Further information can be se-
cured from the DEP, Bureau of Radiation
Protection, PO Box 8469, Harrisburg PA
17105-8469, 1-800-23RADON or (717) 783-
3594.

MOLD INSPECTION/TEST:

Buyer is hereby advised that mold and/or other
microscopic organisms (commonly referred to as
“Mold”) may exist in, on or around the Property
and such Mold may have the potential to cause
health effects including, but not limited to, physi-
cal injuries, allergic and/or respiratory reactions
or other problems, particularly in persons with
immune system problems, young children and/or
elderly persons.

App. 120

Real estate Brokers/salespersons are not
qualified to inspect property for mold or
make recommendations or determinations
concerning possible treatment of mold or
its health or safety issues. The purpose of
this disclosure is to put buyers on notice to
conduct their own inspection/test regarding
this matter, prior to closing, using appro-
priate, qualified experts.

SELLER, LISTING AGENT AND SELLING
AGENT SHALL HAVE THE RIGHT TO A COPY
OF ANY OF THE ABOVE REPORTS.

IMPORTANT NOTICE

IF ANY OF THE ABOVE REPORTS INDICATES A
SUBSTANTIAL DEFECT EXISTS,* BUYER SHALL
HAVE SEVEN (7) CALENDAR DAYS TO GIVE
SELLER WRITTEN REPORT AND WRITTEN
NOTIFICATION OF THESE CONDITIONS. If Buyer
does not provide the Seller with said written report
and written notification of defects within this 7
calendar day period then the Buyer waives the right
to any indicated repairs. (*SUBSTANTIAL DE-
FECT: A single, non-cosmetic defect for which
correction will exceed a cost of $300.00; or
any defect which may adversely affect the
health or safety of the occupants. The $300.00
value cited is non-cumulative and is not based
on an accumulation of defects. If any discov-
ered defect is not substantial as defined herein,
Buyer agrees that Buyer shall have no right to

App. 121

demand correction of such defect and no right
to void or cancel this Agreement.

UPON RECEIPT BY SELLER OF NOTIFICATION
FROM BUYER OR LENDER THAT SUBSTANTIAL
DEFECTS EXIST WHICH MUST BE CORRECTED
PRIOR TO FINAL SETTLEMENT, IN THAT EVENT,
Seller shall have the right, unless prohibited by law
or gover.mental regulation, to cure such substantial
defect, and shall within seven (7) calendar days of
such notice, advise Buyer, in writing, whether or not
the substantial defect shall be so corrected. If Seller
agrees to pay for the correction of all such substantial
defect this agreernent shall remain in force and effect
and shall survive final settlement. In such event,
Buyer shall have NO right to void or cancel this
agreement because of any such substantial defect.

If Seller does not respond or elects not to correct the
substantial defect, the Buyer shall then have the
option of (a) accepting the property with the substan-
tial defect as revealed by any inspection without
abatement of price, or (b) of being refunded all ear-
nest monies paid thus far by Buyer toward the pur-
chase price. In the event the second option is
exercised, there shall be no further liability or obliga-
tion of either Buyer or Seller, and this Agreement
shall become NULL and VOID. However, in order to
invoke this contingency, Buyer shall notify Seller, in
writing, of his election within seven (7) calendar days
after Buyer receives Seller’s decision not to correct
the substantial defect; otherwise, Buyer waives
his/her right to exercise this option, and this agree-
ment shall remain in full force and effect.

App. 122

All other terms and conditions of the said Agreement
shall remain unchanged and in full force and effect.

WITNESS

WITNESS
/s/ (Illegible| _

BUYER

_____/s/ Charles E. Patterson

BUYER

_ /s/ Constance B. Patterson.

WITNESS

WITNESS
/s/

WITNESS
/s/ {Negible|

WITNESS

BUYER

SELLER
__/s/ Richard J. Lewis _

SELLER

_/s/ Patricia A. Lewis

SELLER

App. 123

DOUGLAS H. GENT
ATTORNEY & COUNSELOR AT LAW

Wills & Trusts * Estate Administration ¢
Business/Corporate * Real Estate ¢ Litigation *
Elder Law *¢ Title Insuranc

[Address And Phone Numbers Omitted In Printing]

Douglas H. Gent, Esq. Eric R. Dutcher, Esq.
dgent@gentlaw.com edutcher@gentlaw.com

October 26, 2004

Mr. Jeffrey Warner
Warners Moving & Storage
PO Box 269

West Country Club Road
Red Lien, PA 17356

RE: Richard J. and Patricia A. Lewis

Dear Sir:

Mr. and Mrs. Lewis have retained this office to
represent them with respect to losses they have
incurred arising out of your negligence in performing
your contractual obligations to move Mr. and Mrs.
Lewis’ belongings on August 27, 2004, to their new
home in New York. As a result of your failure to
perform your contractual obligation, Mr. and Mrs.
Lewis were unable to meet the terms of the sale of
their house, closing of which was scheduled at 4:00
p.m. on August 27, 2004. Since they were not able to
close, they lost that sale and have not been able to
resell their house.

App. 124

Mr. and Mrs. Lewis’ losses include, but are not
limited to, loss of profit on the sale of their residence,
additional mortgage payments that Mr. and Mrs.
Lewis have had to pay on two mortgages on their
Pennsylvania residence which otherwise would have
been paid off at closing, and various other miscella-
neous expenses they would not have otherwise in-
curred.

Needless to say, this entire situation has been
very emotionally distressful for Mr. and Mrs. Lewis
particularly since their move to New York State is a
part of Mr. Lewis retiring and having reduced finan-
cial obligations.

The primary purpose of this letter is to notify you
of our representation of Mr. and Mrs. Lewis’ claim,
and to request that you immediately notify your
insurance carrier in the event your insurance carrier
would provide coverage for this type of claim. I an-
ticipate being in touch with you within the next 30 to
60 days with the exact amounts of their claim; how-
ever, until they are actually able to sell their Penn-
sylvania residence, it will be difficult to =: vide an

f
exact number.

Please do not hesitate to contact this office if you
have any questions.
Sincerely,

/s/ Douglas H. Gent, [illegible]
Douglas H. Gent

App. 125

DHG/rec
Ce: Atlas Van Lines, Inc.
PO Box 509

1212 St. George Road
Evansville, IN 47703-0509

App. 126

[LOGO]
BLAKEY, YOST, BUPP & RAUSCH, LLP
Attorneys at Law

Albert G. Blakey
David Wm. Bupp

Doaald B. Hoyt of counsel
Charles A. Rausch ee
Bradley J. Leber Donald H. Yost

Stacey R. MacNeal
Penny V. Ayers

John J. Baranski, Jr.
Michael C. Anderson,
Wanda L. Snader

[Address And Phone Numbers Omitted In Printing]
November 4, 2004

Douglas H. Gent, Esquire
1157 Eichelberger Street
Suite 4

Hanover, PA 17331

Re: Richard J. and Patrica A. Lewis v.
Warners Moving & Storage

Dear Doug:

Please be advised that this office represents
Warners Moving & Storage. Reference is made to
your letter of October 26, 2004. In response to your
letter, there is no insurance for this claim. In order to
evaluate the circumstances, I would appreciate your
providing me more details about this transaction.
Please send me a copy of the Sales Agreement be-
tween your clients and the purchasers, any Ictters of
counsel or other documentation, including letters

App. 127

about the cancellation of the settlement, realtors’
letters, etc. Upon receipt of everything, we will see if
we are in a position to respond to your letter.

Thank you.
Very truly yours,
/s/ Donald B. Hoyt
Donald B. Hoyt
BLAKEY, YOST,
BUPP & RAUSCH, LLP
DBH/isk

cc. Mr. Jeffrey Warner

App. 128

THE LAW OFFICES OF DOUGLAS H. GENT
ATTORNEYS & COUNSELORS AT LAW

Wills & Trusts * Estate Administration *
Business/Corporate * Real Estate ¢ Litigation *
Elder Law *¢ Title Insurance

[Address And Phone Numbers Omitted In Printing]

Douglas H. Gent, Esq. Eric R. Dutcher, Esq.
dgent@gentlaw.com edutcher@gentlaw.com

November 9, 2005

Attorney Donald B. Hoyt Atlas Van Lines, Inc.

Blakey, Yost, ATTN: Claims Department
Bupp & Rausch, LLP P.O. Box 509

17 East Market Street 1212 St. George Road

York, PA 17401 Evansville, IN 47703-0509

RE: Richard J. & Patricia A. Lewis v. Warner’s
Moving & Storage

Dear Attorney Hoyt and To Whom it May Concern at
Atlas Van Lines, Ine:

This is a follow up to Attorney Hoyt’s letter of
November 4, 2004, on the above-captioned matter.
Our response has been delayed because we have been
waiting for Mr. & Mrs. Lewis to re-sell their former
residence located at xxx xxx xxx xxx, Glen Rock,
Pennsylvania, and to gather other information with
respect to their damages. The purpose of this letter is
to outline in detail Mr. & Mrs. Lewis’s claim against
Warner’s Moving & Storage.

The first thing [ want to bring to your attention
is that it appears that at the time of this incident

App. 129

Warner’s Moving & Storage was an agent for Atlas
Van Lines, Inc. I have enclosed a copy of the estimate
prepared for the cost of moving along with a copy of a
brochure that was provided to Mr. & Mrs. Lewis by
Warners. In the event a lawsuit would be commenced,
we would include not only Warner’s Moving & Stor-
age as a defendant but also Atlas Van Lines, Inc.

Mr. & Mrs. Lewis entered into a contract on July
19, 2004, for the sale of their residence to Bruce D. &
Crystal L. Gibbons in the amount of $315,000.00.
Settlement was to occur on or before August 27, 2004.
A copy of the Agreement of Sale is enclosed herewith.
Mr. & Mrs. Gibbons obtained their financing com-
mitment, all required inspections and other matters
were completed, and settlement was scheduled for
4:00 p.m. on August 27, 2004. In late July, 2004, Mr.
& Mrs. Lewis entered into a contract with Warner’s
Moving & Storage to have their household effects
moved to their new residence that was being built at
xxx xxx xxx, Alpine, New York. Enclosed is a copy of a
letter executed by Joe Allen, relocation consultant for
Warner’s Moving & Storage confirming the terms of
the contract. Please note that the letter identifies
Warners as an interstate agent for Atlas.

This letter confirms the terms agrecd upon as far
as the dates and times for completing the move. The
letter confirms that representatives of Warners would
appear at my clients residence on August 23 and 24 to
box up household belongings and that the loading of
my chents possessions into a moving truck(s) would
occur on August 25 and August 26. Delivery at my

App. 130

client’s new residence in New York was scheduled for
August 31 or September 1.

My client indicates that packers appeared on
August 23 and 24 to box up household belongings. A
moving van appeared at my client’s residence on
August 25, 2004, at approximately 12:00 noon and
stayed only until 5:00 p.m. At that time your client
advised Mr. Lewis that the moving van would be-
taken back to your client’s place of business because
the tractor and the crew were needed to handle a
move to North Carolina beginning the next day. Your
client failed to appear on August 26 to continue to
perform its contractual obligations with Mr. and Mrs.
Lewis. During the day Mr. Lewis attempted to contact
your client and apparently spoke with an individual
named Joe Kilgore who did not provide any satisfac-
tory response.

No one appeared on August 27, 2004 to load the
van with Mr. & Mrs. Lewis’s household effects. Mr.
Lewis again contacted your client and spoke with Jeff
Warner at approximately 12:00 noon. Mr. Warner
advised my client that he had no licersed driver avail-
able to load up Mr. & Mrs. Lewis’s household effects.

When my clients, Mr. & Mrs. Gibbons and the
reali estate agents met at approximately 4:00 p.m. on
August 27, 2004, to discuss the situation and to close,
Mr. and Mrs. Lewis contacted Mr. Kilgore who prom-
ised that your client would have all of Mr. and Mrs.
Lewis’ belongings packed and moved out of the house
by 1:00 p.m. on Saturday. Unfortunately, this was

App. 131

unacceptable to the buyers. At that point Mr. & Mrs.
Gibbons terminated the transaction and left settlement.

Apparently representatives of Warners showed
up at Mr. & Mrs. Lewis’s residence at 9:00 a.m. on
August 28, 2004, and worked until approximately
9:00 p.m., at which time they advised Mr. & Mrs.
Lewis that a second truck would be needed. Your
client provided a second truck on Sunday, August 29,
2004, and completed loading Mr. & Mrs. Lewis’
household effects sometime on that date. Unfortu-
nately, the sale had been lost.

Mr. & Mrs. Lewis immediately put their house on
the market using the same real estate agent. On
March 14, 2005, Mr. & Mrs. Lewis entered into a
subsequent contract with a Charles E. & Constance
E. Patterson for the sale of my client’s residence for
the sum of $280,000.00. Settlement was to occur on or
before May 18, 2005. Settlement was subsequently
extended to June 3, 2005. A copy of that contract is
enclosed along with a copy of the settlement state-
ment evidencing the completion of the sale.

It is clear that your client breached its contrac-
tual obligations with my clients by failing to provide a
truck and personnel to load the truck on August 25
and August 26, 2004, so that my clients could vacate
the premises in a timely fashion pursuant to the
terms of their agrcement of sale with Mr. & Mrs.
Gibbons. My clients paid your client $10,477.00
for the move. All of the essential facts are easily

verifiable. We would be presenting as witnesses, in

App. 132

addition to my clients, the real estate agents involved
are Ingrid Locte and Mary Anne Panicho. Further, I
would anticipate that your client’s requirea logs and
other business records will verify the above facts.

As a result of your client’s breach of its contrac-
tual obligations, my clients have incurred damages in
the amount of $72,462.96. Their damages consist of
the following:

1 Loss in sale price $35,000.00
2 Additional interest paid on their first

mortgage with GMAC $7,772.28
3 Additional interest paid on their home

equity line of credit $1,070.78
4 Additional electric utility bills $435.00
5 ‘Telephone bills $249.20
6 ADT security system charges $206.55
7 Additional home-owners insurance

premium $339.03
8 Additional gas utility $371.70
9 Additional county and borough real

estate taxes $570.69
10 Additional school tax $2,549.97
11 Federal income taxes paid on with-

drawal from 401(k) plan $19,328.27
12 New York income taxes paid $5,825.93
13 Credit for savings on reduced real estate

commission & realty transfer tax ($1,050.00)

14 Total Loss $72,462.96

App. 133

With respect to the income taxes paid on the
withdrawal from Mr. Lewis’s 401(k) identified above,
because of the loss of this sale on August 27, 2004,
Mr. & Mrs. Lewis did not have the net proceeds
available to pay off their construction mortgage for
their house in New York. As a result, Mr. Lewis had
to withdraw $87,946.48 from his 401(k) retirement
plan through his place of employment. Enclosed is a
copy of the withdrawal confirmation statement for
Mr. Lewis’s withdrawal from his 401(k). My client has
his bills and checks to verify all of the other expenses
set forth above. Enclosed is a copy of a spreadsheet
prepared by Mr. Lewis setting forth those expendi-
tures on a monthly basis.

A copy of this letter is being sent to the claims
department for Atlas Van Lines, Inc. to put them on
notice of the claim.

At this time, my clients are seeking payment of
$72,462.96 to settle their claim against your client
and Atlas Van Lines, Inc. This offer of settlement will
be open for 30 days from the date of this letter after
which it will be withdrawn. If no response is received
or this matter is not resolved to the satisfaction of my
clients within said time limit, Mr. & Mrs. Lewis have

App. 134

authorized me to proceed with the filing of a lawsuit
against both your client and Atlas Van Lines, Inc.

Sincerely,

/s/ Douglas H. Gent [illegible]
Douglas H. Gent

DHG/abk

Enclosures

Montt Sep-04 Oct-04 Nov-04 ) Jan-0F > Mar s Ml
PAYEF
GMAC Mortgage ‘Interest $871.42 $869.47 $867.62 $865.65 $863.66 $861.67 $859.6 $457 64 $H55 Bf. 742 39
Home Equity Line ‘Interest $77.02 $78.45 $85 89 $86 15 SSE e1 $137 S156 } ¢ 12 : =") 72
Electric Bill $130.01 $36.01 $33.00 % 400.000) D355 .{ >4 mt ange $435

Telephone Bi $70.48 $22.34 $22.34 $22.34 $22.34 $2 i : ‘ : ; $22 34 ‘

ADT Security 922.99 $22 95 $22.9 $22 95 $29 $29 9 7 } : ; . ; 6 55
Home Insurance $37.67 $37.67 $37.67 $37. $37. $37 6 $37.64 B54 .Gs $559
Gas (Heat) 33% :
Real Estate fax $63.41 363.4 363.41 363.41 963.41 i ia , il $57 ‘
7 < < ~ ~ . ~ . | i,

School Tax $283.33 $283.33 $283 $283.33 $28 $

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386017_0057%3A1. Public record. Not legal advice.