101316-1

IN THE UNITED STATES DISTRICT COURT

 FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LOCAL UNION NO. 626, UNITED BROTHERHOOD : CIVIL ACTION

OF CARPENTERS AND JOINERS OF AMERICA :

PENSION FUND :

LOCAL UNION NO. 626, UNITED BROTHERHOOD :

OF CARPENTERS AND JOINERS OF AMERICA :

WELFARE TRUST FUND :

LOCAL UNION NO. 626, UNITED BROTHERHOOD :

OF CARPENTERS AND JOINERS OF AMERICA :

APPRENTICESHIP FUND and its subsidiary, t/a :

CARPENTERS LOCAL 626 JOINT :

APPRENTICESHIP TRAINING CENTER, INC., :

P.O. Box 740 :

Davis Road and Oakwood Lane :

Valley Forge, PA 19482 :

and :

:

UNITED BROTHERHOOD OF CARPENTERS AND :

JOINERS OF AMERICA, AFL-CIO LOCAL 626 OF :

DELAWARE, :

DELAWARE STATE REGIONAL :

COUNCIL OF CARPENTERS; :

INTERNATIONAL HEALTH & SAFETY TRAINING :

FUND/MARKETING FUND, :

CARPENTERS LOCAL 626 POLITICAL :

ACTION COMMITTEE, and :

JOSEPH DURHAM :

626 Wilmington Road :

New Castle, DE 19720 :

Plaintiffs :

:

v. :

:

MIDDLE STATES DRYWALL, INC. :

17 W. Miner Street :

West Chester, PA 19381 :

:

J.R. COLDIRON & SONS, INC. :

P.O. Box 460 :

Newport Gap Pike :

Avondale, PA 19311 :

:

:

COLDIRON ENTERPRISES, INC. :

Case 2:02-cv-02761-RBS Document 6 Filed 10/11/2002 Page 1 of 20
101316-1 2

17 West Miner Street :

P.O. Box 660 :

West Chester, PA 19381 :

:

COLDIRON BUILDING, INC. :

845 Waterway Road :

Oxford, PA 19363 :

:

ALN CONSTRUCTION :

P.O. Box 7717 :

Wilmington, DE 19803 :

:

JOHN D. COLDIRON :

845 Waterway Road :

Oxford, PA 19363 :

:

JOHN R. COLDIRON :

17 West Miner Street :

P.O. Box 660 :

West Chester, PA 19381 :

:

BRENDA PETERSON :

P.O. Box 7717 :

Wilmington, DE 19803 :

:

GREG PETERSON :

P.O. Box 7717 :

Wilmington, DE 19803 :

Defendants : Civil No. 02-2761

AMENDED COMPLAINT

Plaintiffs, by undersigned counsel, complain about Defendants as follows:

JURISDICTION

1. This Court has jurisdiction over the subject matter of this action under 29 U.S.C.

§§185(a), 1132 and 1145.

2. A copy of this Complaint has been served on the Secretary of Labor and the

Secretary of Treasury of the United States or their designated agents by certified mail.

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VENUE

3. Venue lies in the United States District Court for the Eastern District of

Pennsylvania under 29 U.S.C. §§185(a) or 1132(e)(2).

PARTIES

4. Plaintiffs Local No. 626, United Brotherhood of Carpenters and Joiners of

America Pension Fund, Local No. 626, United Brotherhood of Carpenters and Joiners of

America Welfare Fund and Local No. 626, United Brotherhood of Carpenters and Joiners of

America Apprenticeship Fund and its subsidiary t/a Carpenters Local 626 Joint Apprenticeship

Training Center, Inc. (respectively, “Pension Fund”, “Welfare Fund”, “Apprenticeship Fund”

and jointly “Funds”) are trust funds established under 29 U.S.C. §186(c)(5) and “multiemployer

plans” and “employee benefit plans” within the meaning of 29 U.S.C. §1102(37), (1), (2) and

(3). The Funds are administered within the Eastern District of Pennsylvania.

5. Plaintiffs, United Brotherhood of Carpenters and Joiners of America, AFL-CIO

Local 626 of Delaware (together with the Safety Fund and PAC, “Union”) and the Delaware

State Regional Council of Carpenters, its parent, are unincorporated associations, commonly

referred to as a labor union, and an employee organization that represents, for purposes of

collective bargaining, employees of Defendants, who are and/or were employed in an industry

affecting interstate commerce within the meaning of 29 U.S.C. §§152(5), (6) and (7) and

1002(4), (11) and (12).

6. Plaintiff Joseph Durham (“Durham” or jointly with the Funds and Union,

“Plaintiffs”) is the Union Chairman and a trustee and fiduciary with respect to the Funds within

the meaning of 29 U.S.C. §1002(21) with a business address as listed in the caption. He is

authorized to bring this action on behalf of all Trustees of the Funds. Durham is the Assistant

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Business Manager, Executive Secretary-Treasurer of the Union and is authorized to bring this

action on behalf of the Union and IAF.

7. Plaintiff International Health & Safety Training Fund/Marketing Fund (“Safety

Fund”) is/ are dues-financed trust funds established by the United Brotherhood of Carpenters and

Joiners of America for itself and its affiliates. Local 626 and Durham are authorized to sue in the

name and on behalf of the Safety Fund.

8. Plaintiff Carpenters Local 626 Political Action Committee (“PAC”) is an

unincorporated and separate fund established for the purpose of advancing the political interests

of the members of the union by lawfully influencing the selection, nomination, election and/or

appointment of individuals for political office. It is entitled to wage deduction and check-off,

pursuant to valid authorization by members of Local 626, from Defendants.

9. Plaintiff Industry Advancement Fund (“IAF”) is a fund established and

maintained by the Delaware Contractors Association, Inc., a non-profit business league, for the

purposes of fostering and advancing the interests of the carpentry industry in and around

Delaware.

10. Defendant Middle States Drywall, Inc. (“MSD”) is a corporation and an employer

in an industry effecting commerce within the meaning of 29 U.S.C. §§152(2), (6) and (7),

1002(5), (11) and (12) with a business office at the address listed in the caption.

11. Defendant J.R. Coldiron & Sons, Inc. (“Coldiron” and together with MSD,

“Coldiron Companies”) is a corporation and an employer in an industry effecting commerce

within the meaning of 29 U.S.C. §§152(2), (6) and (7), 1002(5), (11) and (12) with a business

office at the address listed in the caption.

12. Defendant Coldiron Enterprises, Inc. (“CEI” and together with MSD and

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Coldiron, “Coldiron Companies”) is a corporation and an employer in an industry effecting

commerce within the meaning of 29 U.S.C. §§152(2), (6) and (7), 1002(5), (11) and (12) with a

business office at the address listed in the caption.

13. Defendant Coldiron Building, Inc. (“CBI” and together with Coldiron Companies,

“Defendants”) is a corporation and an employer in an industry effecting commerce within the

meaning of 29 U.S.C. §§152(2), (6) and (7), 1002(5), (11) and (12) with a business office at the

address listed in the caption.

14. Defendant ALN Construction (“ALN” and together with Coldiron Companies and

CBI, “Defendants”) is a corporation and an employer in an industry effecting commerce within

the meaning of 29 U.S.C. §§152(2), (6) and (7), 1002(5), (11) and (12) with a business office at

the address listed in the caption.

15. Defendant John D. Coldiron (“J.D. Coldiron” and together with Coldiron

Companies, CBI and ALN, “Defendants”) is the president of CBI and CEI and Vice President of

Coldiron with a business address as listed in the caption.

16. Defendant John R. Coldiron (“J.R.Coldiron” and together with Coldiron

Companies, CBI, ALN and J.D. Coldiron, “Defendants”) is the president of Coldiron and MSD

with a business address as listed in the caption.

17. Defendant Brenda Peterson (“B. Peterson” and together with Coldiron

Companies, CBI, ALN, J.D. Coldiron and J.R. Coldiron, “Defendants”) directly or indirectly

controls the financial status of ALN with a business address as listed in the caption.

18. Defendant Greg Peterson (“G. Peterson” and together with Coldiron Companies,

CBI, ALN, J.D. Coldiron, J.R. Coldiron, B. Peterson, “Defendants”) husband of B. Peterson,

directly or indirectly controls the financial status of ALN with a business address as listed in the

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caption.

COMMON FACTS

19. At all times relevant to this action, MSD was party to a collective bargaining

agreement(s) with the Union (singly or jointly, “Labor Contract”).

20. MSD signed or agreed to abide by the terms of agreements and declarations of

trust of the Funds (“Trust Agreements”) made between certain employers and employee

representatives in an industry(ies) effecting interstate commerce to promote stable and peaceful

labor relations.

21. On information and belief;

1) The officers and management of MSD and CBI are the same;

2) MSD and CBI are engaged in the same business, serving the same or 

similar type of customers;

3) Labor relations for MSD and CBI are handled by the same person(s);

4) MSD and CBI employ the same employees, use the same equipment to 

serve the same or similar type of customers;

5) The ownership of MSD and CBI is or has been the same.

6) CBI was, at all times, fully aware of the amounts owed to Plaintiffs by 

MSD.

Based upon these facts and others, CBI is the alter ego of MSD and/or successor of MSD with

liability for its debts. Alternatively, MSD and CBI constitute a single employer or MSD and CBI

are operating as joint employer.

22. CBI separately executed the Labor Contract with Union and also agreed to abide

by the terms and provisions of the Trust Agreements.

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23. On October 9, 1996, Coldiron Companies entered into a Settlement Agreement

(“Agreement”) with the Funds for the payment of delinquent contributions and other amounts it

owes to Funds and for payment of its ongoing contributory obligations. A true and correct copy

of the Agreement is attached as Exhibit 1.

24. On October 9, 1996, Coldiron Companies executed a note (“Note”) which set

forth their obligations if the Agreement was violated. A true and correct copy of the Note is

attached as Exhibit 2.

25. On October 9, 1996, J.D. Coldiron, J.R. Coldiron and B. Peterson, agreed to be

bound by all provisions on this Settlement Agreement and Note. Exhibits 1 and 2.

26. Coldiron Companies, J.D. Coldiron, J.R. Coldiron and B. Peterson have defaulted

under the terms of the Settlement Agreement by failing to pay all installment payments due after

September 2000, totaling at least $27,496.08, and failing to cure the default after written notice.

27. Under the Labor Contract, Trust Agreements, and Agreement, Coldiron

Companies agreed;

a. To make full and timely payments on a weekly basis to the Funds and 

Union as required by the Labor Contract;

b. To file weekly remittance reports with the Funds detailing all employees 

or work for which contributions were required under the Labor Contract;

c. To produce, upon request by the Funds or Union, all books and records 

deemed necessary to conduct an audit of their records concerning their obligations 

to the Funds and Union and to pay the costs of such audit 

d. To pay liquidated damages, late charges, interest, audit costs, and all costs 

of litigation, including attorneys’ fees, expended by the Funds to collect any amounts due

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as a consequence of their failure to comply with their contractual obligations described in

subparagraphs a, b, and c.

28. On information and belief, the Coldiron Companies were at all relevant times

affiliated business enterprises engaged in the same business, with common ownership,

management and centralized control of labor relations, that use and have used identical

employees, equipment and other assets in such manner as to constitute a single integrated

business enterprise that is a single employer or alter ego for all purposes relevant to this action.

As a single employer or alter ego the Coldiron Companies are all bound to the terms and

conditions of the Labor Contract and Trust Agreements and Agreement including the obligation

to make fringe benefit contribution payments to the Funds and Union.

29. MSD documents in the possession of Defendants that were necessary for the

performance of an audit were destroyed prematurely and outside of accepted business practices.

COUNT I – AMOUNTS DUE UNDER CONTRACT - SUM CERTAIN

FUNDS

v.

CBI

30. The allegations of Paragraphs 1 through 29 are incorporated by reference as if

fully restated.

31. On information and belief, CBI has failed to pay amounts due under the Labor

Contract, Trust Agreement and Rules and Rules and Regulations from August 2001 to present in

at least the sum of $76,442.87 based upon information presently available to the Fund.

32. CBI has not paid the Funds as required by the Labor Contract, Trust Agreements,

and applicable law.

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WHEREFORE, the Funds ask that the Court:

(1) Enter judgment against CBI in favor of the Funds for at least the sum of

$76,442.87, plus any additional amounts which become due during the course of this litigation or

are revealed by an audit of CBI’s records together with liquidated damages, interest and costs,

including reasonable attorney’s fees incurred in this action or the collection or enforcement of

any judgment, as provided in the Labor Contract and Trust Agreement.

(2) Grant such other or further relief, legal or equitable, as may be just, necessary or

appropriate.

COUNT II –CONTRIBUTIONS UNDER ERISA - SUM CERTAIN

FUNDS

v.

COMPANY

33. The allegations of Paragraphs 1 through 29 are incorporated by reference as if

fully restated.

34. CBI has failed to pay at least the sum of $76,442.87 in contributions to the Funds

in violation of 29 U.S.C. §1145.

35. The Funds have been damaged by CBI’s violation of 29 U.S.C. §1145.

WHEREFORE, the Funds ask that the Court:

(1) Enter judgment against CBI in favor of the Funds for at least the sum of

$76,442.87, plus any additional amounts which are found to be due and owing during the course

of this litigation or are revealed by an audit of CBI’s records, together with interest at the rate

prescribed by 26 U.S.C. §6621, liquidated damages equal to the greater of the interest on the

unpaid contributions or liquidated damages provided by the documents governing the Funds or

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101316-1 10

statute and reasonable a reasonable attorney’s fees and costs incurred in this action or the

collection or enforcement of any judgment.

(2) Grant such other or further relief, legal or equitable, as may be just, necessary or

appropriate.

COUNT III –AMOUNTS DUE UNDER SETTLEMENT AGREEMENT

FUNDS

v.

COLDIRON COMPANIES

36. The allegations of Paragraphs 1 through 29 are incorporated by reference as if

fully restated.

37. Coldiron Companies are liable for all amounts owed to the Funds under the terms

of the Agreement and Note.

38. Coldiron Companies owe at least $27,496.08 under the Labor Contract,

Agreement and Note for the period of September 2000 to present based upon information

presently available to the Funds.

39. Despite Demand for payment, Coldiron Companies have not paid the amounts

owed.

WHEREFORE, the Funds ask that the Court:

(1) Enter judgment against Coldiron Companies in favor of the Funds, for at least the sum of

$27,496.08 plus such other amounts as may become due and owing during the pendency of this

lawsuit or as the result of an audit of the records of Defendants, together with liquidated

damages, interest and costs, including the costs of any audit, and reasonable attorney’s fees and

costs incurred in this action or the collection or enforcement of any judgment, as provided in the

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Labor Contract, Agreement and Note.

(2) Grant such other or further relief, legal or equitable, as may be just, necessary or

appropriate.

COUNT IV –AMOUNTS DUE UNDER SETTLEMENT AGREEMENT

FUNDS

v.

CBI

40. The allegations of Paragraphs 1 through 29, 36 through 39 are incorporated by

reference as if fully restated.

41. MSD is liable for all amounts owed to the Funds under the terms of the personal

guarantee and Note. As the alter ego of MSD, CBI is bound to the Settlement Agreement and

Note and liable for all debts and obligations of MSD, including amounts owed to the Funds.

 42. MSD owes at least $27,496.08 under the Labor Contract Agreement and Note for

the period of September 2000 to present based upon information presently available to the

Funds.

43. Despite demand for payment, MSD has not paid the amounts owed.

WHEREFORE, the Funds ask that the Court:

(1) Declare that CBI is the alter ego of MSD, is bound to the Settlement Agreement

and Note and liable for all amounts owed by MSD and all obligations of MSD.

(2) Enter judgment against CBI, and in favor of the Funds, for at least the sum of

$27,496.08 plus such other amounts as may become due and owing during the pendency of this

law suit or as the result of an audit of the records of the Defendants together with liquidated

damages, interest and costs, including the costs of any audit, and reasonable attorney’s fees and

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costs incurred in this action or the collection or enforcement of any judgment, as provided in the

Labor Contract, Agreement and Note.

(3) Grant such other or further relief, legal or equitable, as may be just, necessary or

appropriate.

COUNT V –DELAWARE FRAUDULENT CONVEYANCE

FUNDS

v.

ALN, B. PETERSON AND G. PETERSON

44. The allegations of Paragraphs 1 through 2, 36 through 43 are incorporated by

reference as if fully restated.

45. MSD became indebted to the Funds as a result of delinquent contributions and

other amounts owed to the Funds and the entry of an Agreement and Note executed on October

9, 1996. Exhibits 1 and 2. MSD subsequently ceased operations.

46. MSD desolved or distributed its assets after the demand for payment was made

and at a time when it was insolvent.

47. In connection with the dissolution and liquidation of MSD, MSD distributed the

available assets to ALN. ALN has refused to provide records concerning the affairs of MSD and

distribution of their assets. The Funds thus cannot plead the complete transfers which have been

concealed from them.

48. B. Peterson directly or indirectly controls the financial status of ALN and was

therefore an active participant in the distribution in the transfer of assets.

49. B. Peterson, who directly or indirectly controls the financial status of ALN and

was therefore an active participant in the distribution in the transfer of assets.

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50. The distributions were “transfers” of “assets” within the meaning of

6 Del C. §1301 or were transfers or conveyances to “insiders” within the meaning of 6 Del C.

§1301. At the time of any distributions, MSD, ALN, B. Peterson and G. Peterson had notice of

the “claim” of the Funds and their status of “creditors” within the meaning of 6 Del C. §1301.

51. On information and belief, the transfers were made with actual intent, under 6 Del

C. §1304(a)(1) to hinder, delay, or defraud the Funds in light of the following:

(a) The transfers were made to insiders

(b) The transfers consisted of all or substantially all available assets of MSD

(c) The transfers took place shortly before or after the amounts became due 

and payable, and

(d) On information and belief, the value of the consideration received for the 

transfers was not reasonably equivalent to the value of the assets transferred, and

(e) MSD was insolvent of became insolvent as a result of the transfer.

52. The transfers left MSD insolvent within the meaning of 6 Del C. §1302.

53. The transfers were made without fair consideration within the meaning of 6 Del

C. §1303.

54. The transfers were fraudulent to creditors, including the Funds, within the

meaning of 6 Del C. §1304, 1305.

55. The Funds will be irreparably injured in the event that ALN, B. Peterson and G.

Peterson are allowed to continue to create corporate shells and transfer entities at a speed which

is faster than the time to judgment so as to render any remedy at law of the Funds for future

transfers inadequate such that the balance of equities favors the Funds.

56. All conditions precedent to injunctive relief have been satisfied.

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WHEREFORE, the Funds ask that the Court:

(1) Declare that the transfers of assets of MSD to be fraudulent conveyances.

(2) Declare the transfers to be void.

(3) Enter judgment against ALN, G. Peterson and B. Peterson, individually and

jointly, for the amount of the proceeds they received directly, indirectly or beneficially from such

transfer and impress the proceeds, in whatever form and wherever traceable, with a constructive

trust in favor of the Funds.

(4) Enter judgment against ALN, B. Peterson and G. Peterson, and any other

organization under their control for damages occasioned to the Funds together with attorney’s

fees, costs and interest.

(5) Enjoin ALN, B. Peterson, G. Peterson, and any other organization under their

control, their officers, agents, servants, employees, attorneys and persons in active concert or

participation with them who receive actual notice of an order by personal service or otherwise

from transferring any of the property transferred to them (including the proceeds from the

transfers) or from transferring any real or personal property which they own or in which they

have a legal or equitable interest except to return it to creditors or its other rightful owner.

(6) Appoint a receiver to take charge of all property received by ALN, B. Peterson

and G. Peterson in these transfers (including the proceeds of such transfers) and their other

property with which it is commingled and held in trust for the benefit of creditors.

(7) Allow Funds to execute on property transferred to ALN, B. Peterson and G.

Peterson and on the proceeds received by them.

(8) Grant such other and further relief, legal or equitable, as may be just, necessary or

appropriate.

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101316-1 15

COUNT VI –CONSTRUCTIVE TRUST

FUNDS

v.

COLDIRON, CEI, CBI AND ALN

56. The allegations of Paragraphs 1 through 29, 36 through 56 are incorporated by

reference as if fully restated.

57. Coldiron, CEI, CBI and ALN hold assets received from MSD in trust for creditors

of MSD, including the Funds.

58. The amounts for which MSD is liable have not been paid.

WHEREFORE, the Funds ask that the Court:

(1) Declare a constructive trust and enter judgment against Coldiron, CEI, CBI, and

ALN, jointly and severally, and in favor of the Funds for the amount(s) they received from MSD

together with interest, earnings and any profits it has made from the use of the property or the

proceeds.

(2) Grant such other relief, legal or equitable as may be just, necessary or appropriate.

COUNT VII –CONVERSION

FUNDS

v.

COLDIRON, CEI, CBI AND ALN

59. The allegations of Paragraphs 1 through 2, 36 through 58 are incorporated by

reference as if fully restated.

60. Coldiron, CEI, CBI and ALN have intentionally and tortiously converted property

held in trust on behalf of creditors of MSD, including the Funds, without any lawful justification.

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61. Demand has been made on the Funds or their trustees for creditors for action for

recovery of the property without action or would be futile.

62. The Funds (and other creditors) have been damaged by the conversion of assets

held for them in trust.

WHEREFORE, the Funds ask that the Court:

(1) Award damages and make the Funds whole for any losses resulting from

Coldiron’s, CEI’s, CBI’s and ALN’s tortious conversion of property including the fair value of

such property, and actual proceeds, product, offspring, rents or profits of such property that at

any time came into their possession, custody or control;

(2) Restore any profits and the fair value of use or lost opportunity from the use of the

Funds, and;

(3) Grant such other relief, legal or equitable, as may be just, necessary or

appropriate.

COUNT VIII –AUDIT

FUNDS

v.

ALL DEFENDANTS

63. The allegations of Paragraphs 1 through 29, 36 through 62 are incorporated by

reference as if fully restated.

64. The amount of contributions Defendants are required to pay the Funds is based

upon hours worked and paid to employees performing work covered by the Labor Contract.

65. The Funds are without sufficient information or knowledge to plead the precise

nature, extent and amount of any additional delinquency beyond that reflected on the remittance

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101316-1 17

reports prepared by and submitted by Defendants and CBI because the books, records and

information necessary to determine this liability are in exclusive possession, custody, control or

knowledge of the Defendants.

66. A portion of the documents in possession of the Defendants which are necessary

for the performance of an audit were destroyed prematurely and outside of accepted business

practices.

67. Computation of the precise amount of an employers delinquency is normally

achieved by an audit of the employers book and records.

68. No audit of the books and records of Coldiron Companies, CBI or ALN has been

performed.

69. Defendants are required by the Labor Contract, Trust Agreements of the Funds,

the Settlement Agreement and applicable law to permit the Funds to audit their records and to

cooperate in determining the contributions due the Funds.

70. The Funds have no adequate remedy at law for the calculation of any damages

suffered as a result of the breach and require an audit.

71. All conditions precedent to equitable relief have been satisfied.

WHEREFORE, the Funds ask that the Court:

(1) Enjoin all Defendants their officers, agents, servants, employees, attorneys and all

others in active concert or participation with them to permit an audit of all records of Coldiron

Companies, CBI and ALN under their actual or constructive control and, in the absence of

records to cooperate in alternative methods for the determination of work for which contributions

are due, and

(2) Order Defendants to pay for an audit by a certified public accountant chosen by

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101316-1 18

the Funds.

(3) Grant such other or further relief, legal or equitable, as may be just, necessary or

appropriate.

Respectfully submitted,

JENNINGS SIGMOND

Dated: June 27, 2002 s\Marc L. Gelman 

KENT G. CPREK (ID NO 40806)

MARC L. GELMAN (ID NO. 78857)

510 Walnut Street, Suite 1600

Philadelphia, PA 19106

(215) 351-0615/23

Counsel for Plaintiffs

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101316-1

CERTIFICATE OF SERVICE

I state under penalty of perjury that I caused a copy of the foregoing Amended

Complaint to be deposited in the U.S. mail with postage for first class delivery, on the date and

to the parties below.

MIDDLE STATES DRYWALL, INC

17 West Miner Street

West Chester, PA 19381

J.R. COLDIRON & SONS, INC.

P.O. Box 460

Newport Gap Pike

Avondale, PA 19311

COLDIRON ENTERPRISES, INC.

17 West Miner Street

P.O. Box 660

West Chester, PA 19381

COLDIRON BUILDING, INC.

845 Waterway Road

Oxford, PA 19363

ALN CONSTRUCTION

25 Good Hope Rd.

Landenberg, PA 19350

JOHN D. COLDIRON

845 Waterway Road

Oxford, PA 19363

JOHN R. COLDIRON

17 West Miner Street

P.O. Box 660

West Chester, PA 19381

BRENDA PETERSON

25 Good Hope Rd.

Landenberg, PA 19350

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101316-1 2

GREG PETERSON

25 Good Hope Rd.

Landenberg, PA 19350

WALTER F. FLAMM, JR., ESQUIRE

925 Harvest Drive, Ste. 220

Blue Bell, PA 19422

s\Marc L. Gelman 

MARC L. GELMAN, ESQUIRE

DATE: June 27, 2002

Note: This document has been electronically filed.

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