J-S14006-17

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*Retired Senior Judge assigned to the Superior Court.

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

WELLS FARGO BANK, N.A. 

SUCCESSOR BY MERGER TO 

WACHOVIA BANK, N.A.

v.

PATRICK F. COSTANTINO, A/K/A 

PASQUALE F. COSTANTINO, A/K/A 

PATRICK COSTANTINO, KAREN E. 

COSTANTINO, A/K/A KAREN ANN 

KARBOSKI AND THE UNITED STATES 

OF AMERICA

APPEAL OF: PATRICK F. 

COSTANTINO, A/K/A PASQUALE F. 

COSTANTINO, A/K/A PATRICK 

COSTANTINO

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 IN THE SUPERIOR COURT OF

 PENNSYLVANIA

No. 607 MDA 2016

Appeal from the Order Entered March 14, 2016

In the Court of Common Pleas of Luzerne County

Civil Division at No(s): 2014-06640

BEFORE: GANTMAN, P.J., SHOGAN, J., and STRASSBURGER, J.*

MEMORANDUM BY GANTMAN, P.J.: FILED MARCH 28, 2017

Appellant, Patrick F. Constantino a/k/a Pasquale F. Constantino a/k/a 

Patrick Constantino, appeals from the order of the Luzerne County Court of 

Common Pleas, which entered summary judgment in favor of Appellee, Wells 

Fargo Bank, N.A., in this mortgage foreclosure action. We affirm.

In its opinion, the trial court fully and correctly set forth the relevant 

facts and procedural history of this case. Therefore, we have no reason to 
J-S14006-17

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restate them.1

Appellant raises two issues for our review:

DID THE [TRIAL] COURT...ERR AS A MATTER OF LAW IN 

DISMISSING [APPELLANT]’S NEW MATTER ASSERTING 

THAT [APPELLEE]’S MORTGAGE WAS UNLAWFUL AND IN 

CONTRAVENTION OF BANKING REGULATIONS?

DID THE [TRIAL] COURT ERR AS A MATTER OF LAW IN 

GRANTING [APPELLEE]’S MOTION FOR SUMMARY 

JUDGMENT?

(Appellant’s Brief at 4).

With respect to Appellant’s first argument challenging “the dismissal of 

his new matter,” we observe that appellate briefs must conform in all 

material respects to the briefing requirements set forth in the Pennsylvania 

Rules of Appellate Procedure. Rosselli v. Rosselli, 750 A.2d 355 

(Pa.Super. 2000), appeal denied, 564 Pa. 696, 764 A.2d 50 (2000) (citing 

Pa.R.A.P. 2101). See also Pa.R.A.P. 2114-2119 (addressing specific 

requirements of each subsection of brief on appeal). Regarding the 

argument section of an appellate brief, Rule 2119(a) provides:

Rule 2119. Argument 

(a)General rule. The argument shall be divided into as 

many parts as there are questions to be argued; and shall 

____________________________________________

1 We make the following additions to the trial court’s Rule 1925(a)(1) 

opinion: Appellant and then-wife, Karen Constantino a/k/a Karen Ann 

Karboski, executed the residential mortgage and promissory note in favor of 

Wachovia Bank, N.A. on May 5, 2007. Appellant has not made a single 

payment since he defaulted on the mortgage on January 26, 2012, and the 

last payment he made was on December 28, 2011. 
J-S14006-17

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have at the head of each part―in distinctive type or in 

type distinctively displayed―the particular point treated 

therein, followed by such discussion and citation of 

authorities as are deemed pertinent. 

Pa.R.A.P. 2119(a). Importantly: 

The argument portion of an appellate brief must include a 

pertinent discussion of the particular point raised along 

with discussion and citation of pertinent authorities. This 

Court will not consider the merits of an argument which 

fails to cite relevant case or statutory authority. Failure to 

cite relevant legal authority constitutes waiver of the claim 

on appeal. 

In re Estate of Whitley, 50 A.3d 203, 209 (Pa.Super. 2012), appeal 

denied, 620 Pa. 724, 69 A.3d 603 (2013) (internal citations and quotation 

marks omitted). See also Lackner v. Glosser, 892 A.2d 21 (Pa.Super. 

2006) (explaining appellant’s arguments must adhere to rules of appellate 

procedure, and arguments which are not appropriately developed are waived 

on appeal; arguments not appropriately developed include those where 

party has failed to cite any authority in support of contention); Estate of 

Haiko v. McGinley, 799 A.2d 155 (Pa.Super. 2002) (stating rules of 

appellate procedure make clear appellant must support each question raised 

by discussion and analysis of pertinent authority; absent reasoned 

discussion of law in appellate brief, this Court’s ability to provide appellate 

review is hampered, necessitating waiver of issue on appeal). 

Instantly, Appellant fails to cite relevant legal authority to support his 

argument that the mortgage was unlawful. Instead, he merely cites the 

legal standard for summary judgment. Appellant baldly states that the 
J-S14006-17

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mortgage was unlawful and violated banking regulations because “the crosscollateralization of the loan with the loan of...Appellant’s former wife was 

done after the parties were divorced.” Appellant’s argument is incoherent 

and unsupported by relevant legal authority. Appellant’s failure to develop 

his claim on appeal precludes meaningful review and arguably constitutes 

waiver of his first issue on appeal. See Pa.R.A.P. 2119(a); Pa.R.A.P. 2101; 

Whitley, supra; Lackner, supra; Haiko, supra. 

Moreover, with respect to both issues on appeal, after a thorough 

review of the record, the briefs of the parties, the applicable law, and the 

well-reasoned opinion of the Honorable Lesa S. Gelb, we agree Appellant’s 

issues merit no relief. The trial court opinion comprehensively discusses and 

properly disposes of the questions presented. (See Trial Court Opinion, filed 

June 3, 2016 at 7-16) (finding: preliminarily, Appellant filed 14-issue Rule 

1925(b) statement; this case is straightforward mortgage foreclosure action 

where all relevant facts were presented to court; case does not factually or 

procedurally justify identification of 14 issues for appellate review; 

Appellant’s Rule 1925(b) statement includes issues, which are entirely 

misplaced and not intended to be addressed with Superior Court; Appellant’s 

Rule 1925(b) statement is nothing more than attempt to delay final 

determination in this matter; Appellant waived all issues on appeal for filing 

unnecessarily complex, incoherent, and lengthy Rule 1925(b) statement; 

moreover, (1) Appellant’s new matter did not raise any material issues of 
J-S14006-17

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fact but merely stated conclusions of law irrelevant to this foreclosure 

action; in Appellant’s response to Appellee’s summary judgment motion, 

Appellant failed to identify relevant facts in dispute or point to contradictions 

in record; specifically, Appellant failed to: (a) attach to his response 

supporting documents; (b) make factual allegations related to other loans 

and guaranties; and (c) properly identify any cross-collateralization 

provision; information related to other loans and guaranties are not in 

record; Appellant failed to identify issue of material fact related to crosscollateralization clause; (2) Appellant baldly denied in his answer to 

Appellee’s complaint that he is in default under mortgage and amount due 

and owing on mortgage; Appellant failed to identify in his answer those 

payments he claims he made under mortgage; information on Appellant’s 

payments not stated in complaint was within Appellant’s control; therefore, 

Appellant’s denial of default is deemed admission of default and amount due 

and owing under mortgage; Appellant’s response to motion for summary 

judgment rested completely on pleadings; Appellant failed to attach 

supporting documents to demonstrate genuine issue of material fact). 

Therefore, we affirm on the basis of the trial court’s opinion. 

Order affirmed. 
J-S14006-17

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Judgment Entered.

Joseph D. Seletyn, Esq.

Prothonotary

Date: 3/28/2017
In the Complaint, Appellee alleged that Appellant defaulted 

Recorder of Deeds, Book 3007, Page 161163 (the II Mortgage"). 

mortgage to Wachovia was recorded at the Luzerne County 

Appellee is the successor by merger to Wachovia. The 

("Wachovia") in the original principal amount of $240, 141.50. 

mortgage to Wachovia Bank, National Association 

Complaint, Appellee alleged that Appellant executed a 

Foreclosure against Appellant (the "Comptolnt"}. In the 

On May 28, 2014, Appellee filed a Complaint in Mortgage 

Background 

OPINION 

No. 6640 of 2014 

Patrick F. Constantino, 

Appellant 

Patrick F. Constantino, a/k/a 

Pasquale F. Constantino, and 

Koren Constantino a/k/a 

Karen Ann Karboski 

VS. 

Appel lee 

Wells Fargo Bank, N.A. s/b/m : In the Court of Common Pleas 

Wachovia Bank, National of Luzerne County 

Association 

Circulated 03/03/2017 09:49 AM
2 

necessary the averment that the Act 6 and Act 91 Notices 

conclusions of fact and law to which no responsive pleading is 

owing on the Mortgage. Further, Appellant denied as 

generally denied the amounts alleged to remain due and 

listing any payment dates or amounts. Appellant likewise 

alleging a default under the terms of the Mortgage, without 

Answer, Appellant generally denied Appellee's averment 

New Matter (the "Answer") in response to the Complaint. In the 

On December 10, 2014, Appellant filed his Answer and 

Appellant for the amount of $278,678.91. 

sought an in rem judgment in mortgage foreclosure against 

accruing thereafter. At the close of the Complaint, Appellee 

$278,678.91 with per diem interest in the amount of $44.44281 

by Appellant on the Mortgage through May 8, 2014 was 

According to Appellee, the total amount due and owing 

Appellant. 

that, due to the default, Act 6 and Act 91 Notices were sent to 

interest due on January 26, 2012. Appellee further explained 

on the Mortgage for failure to pay installments of principal and 
3 

and 11 of the Complaint amount to admissions to the event of 

Appellee claimed that Appellant's answers to averments l O 

admissions to the allegations in the Complaint. Specifically, 

that Appellant's responses in his Answer effectively operated as 

Further, Appellee argued in the Motion for Summary Judgment 

combined Act 6 and Act 91 Notice with proof of mailing. 

and owing; Appellant's loan history; and, a copy of the 

default under the Mortgage and the amounts remaining due 

Mortgage and Promissory Note; an Affidavit confirming the 

following documents to the Motion for Summary Judgment: the 

pursuant to the Mortgage. Specifically, Appellee attached the 

supportive documents to demonstrate Appellant's liability 

issues of material fact remaining and attached various 

-- · · for Summary Judgment, Appellee osserted trrcrf"there·were-nn -- 

Judgment (the "Motion for Summary Judgment"). In the Motion 

On February 3, 2016, Appellee filed its Motion for Summary 

-------------------- ------~-- --------------- 

Appellee filed its Reply to New Matter on December 31, 2014. 

issues that fail to amount to defenses in the instant matter. 

were sent. In his New Matter, Appellant raised various irrelevant 
4 

throughout his seven (7) page Response, Appellant completely 

its own allegations and deemed admissions by Appellant. Still, 

that summary judgment is improper because Appellee relies on 

foreclosure action. Finally, Appellant argued in his Response 

states various conclusions of law irrelevant to this mortgage 

Matter does not address any issues of fact, rather, it merely 

unresolved issues of material fact. Notably, Appellant's New 

judgment by arguing that the averments in his New Matter raise 

2014. Next, Appellant attempted to overcome summary 

Appellee filed a timely Reply to New Matter on December 31, 

because Appellee failed to answer his New Matter. Indeed, 

incorrectly stated that summary judgment is inappropriate 

Motion for Summary Judgment. First, in his Response, Appellant 

.. ·····- ... -· ·-- ··-. ···-··- 

On March-2; 20T6, Appellant filed his Respc,nse to ··the 

as defenses in a mortgage foreclosure action . 

conclusions of law, unsupported by facts, which do not serve 

the argument that Appellant's New Matter consisted only of 

Appellee concluded the Motion for Summary Judgment with 

default and the amounts due and owing under the Mortgage. 
5 

1 The other Defendant in this case, Karen Constantino a/k/a Karen Ann 

Karboski, had a default judgment entered against her on January 21, 

2015, and is not involved in the current appeal. 

Appellant's Concise Statement. 

matters for review. Appellee did not file a response to 

Complained of on Appeal, raising fourteen (14) different 

2016, Appellant filed his Concise Statement of Errors 

of Matters Complained of on Appeal within 21 days. On May 3, 

2016, this Court instructed Appellant to file a Concise Statement 

to the Pennsylvania Superior Court. 1 By Order dated April 15, 

property. On April 13, 2016, Appellant filed a Notice of Appeal 

the Mortgage for foreclosure and sale of the mortgaged 

January 15, 2016 and other costs and charges collectible under 

Appellee in the amount of $322,327.95 plus interest from 

Accordingly, this Court entered an in rem judgment in favor of 

Appellee was entitled to summary judgment as a matter of law. 

By Order dated March 14, 2016, this Court held that 

remain in dispute, or point to any contradictions in the record. 

fails to raise any facts relevant to the instant matter which 
6 

Standard of Review 

Upon review of a motion for summary judgment, a court 

must view the record in the light most favorable to the nonmoving party, and resolve all doubts as to the existence of a 

genuine issue of material fact against the moving party. Fine v. 

Checcio, 582 Pa. 253, 265, 870 A.2d 850, 857 (citing Jones v. 

SEPTA, 565 Pa. 211, 772 A.2d 435, 438 (Pa. 2001)). The 

Pennsylvania Rules of Civil Procedure governing summary 

judgment instruct, in relevant part, that the court shall enter 

judgment whenever there is no genuine issue of any material 

fact as to a necessary element of the cause of action or 

defense that could be established by additional discovery. 

Pa.R.C.P ., Rule l 035.2(1) (2015}. Pursuant to the Rules of Civil 

Procedure, a motion for summary judgment is based upon an 

evidentiary record that entitles the moving party to judgment 

as a matter of law. Note to Pa.R.C.P., Rule 1035.2 (2015}. The 

court 11 ... may grant summary judgment only where the right to 

such a judgment is clear and free from doubt." Checcio, 582 
7 

Pa. 253, 265, 870 A.2d 850, 857 (citing Marks v. Tasman, 527 Pa. 

132, 589 A.2d 205, 206 (Pa. 1991)). 

Law and Discussion 

First and foremost, Appellant waived all issues for appeal 

because he failed to concisely and coherently identify his 

matters complained of, as ordered to do so by this Court. 

According to the Pennsylvania Superior Court, the mere filing of 

a timely response to the trial court's Pa.R.A.P. l 925(b) order 

does not automatically equate to issue preservation. Jiricko v. 

Geico Insurance Company, 947 A.2d 206, 210 (Pa. Super. 2008). 

The statement is a crucial step in the process because it permits 

the trial court to focus on those issues an appellant intends to 

raise. _!st (internal citations omitted). Accordingly, any issues not 

properly raised will be deemed waived. kt (internal citations 

omitted). 

Pennsylvania Courts have repeatedly held that an 

appellant waives all matters for review where he/she identifies 

an outrageous number of issues in the concise statement. See 

Jones v. Jones, 878 A.2d 86 (Pa. Super. 2005) (seven page, 
8 

Additionally, the Pennsylvania Superior Court has 

explained that an appellant's failure to state his/her issues to be 

raised on appeal in a concise manner impedes a trial court's 

twenty-nine issue statement resulting in waiver); Signora v. 

Liberty Travel, Inc., 886 A.2d 284 (Pa. Super. 2005) (appellants 

admonished for eight page, 25 issue statement and eight 

page, forty-six issue statement, but court declined to find 

waiver due to trial court opinion); Kanter v. Epstein, 866 A.2d 

394 {Pa. Super. 2004) {fifteen page, fifty-five issue statement 

resulting in waiver). However, " ... the number of issues raised in 

a Rule 1925(b) statement does not, without more, provide a 

basis upon which to deny appellate review where an appeal 

otherwise complies with the mandates of appellate practice." 

Eiser v. Brown & Williamson Tobacco Corp., 595 Pa. 366, 385, 

938 A.2d 417, 427-428 (Pa. 2007). The Pennsylvania Supreme 

Court has identified the complexity of the matter under review 

as a consideration for courts to make prior to finding waiver 

based on sheer volume of the concise statement. kt at 383, 

427. 
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that factually or procedurally justifies the identification of 

genuine issues of material fact to be resolved. This is not a case 

judgment granted in favor of Appellee because there were no 

documents were presented to this Court and summary 

straight forward mortgage foreclosure where all relevant 

must consider the complexity of this matter. This case involves a 

the statement may not appear excessive at first glance, one 

fourteen issue concise statement. Although the sheer length of 

In the instant matter, Appellant filed a three page, 

review. See Jones, 878 A.2d 86; Kt at 402. 

cumbersome statements in an effort to preclude meaningful 

breach their duty of fair dealing with the court by filing 

certain circumstances, our courts have held that appellants 

meaning and purpose of Rule 1925(b). Id. Indeed, under 

appeal, an appellant may deliberately circumvent the 

by identifying issues which he/she never intends to raise on 

Specifically, by raising an outrageous number of issues and/or 

-------·-- ··--·········-·------------- 

impedes proper appellate review. Kanter, 866 A.2d at 401. 

ability to prepare an opinion explaining its ruling and, thus, 
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agree with this Court's finding of waiver, this Court has 

Second, in the event that the reviewing court does not 

nor coherent and thwarts meaningful review. 

for appellate review by filing a Statement that is neither concise 

that, for the reasons stated above, Appellant waived all issues 

final determination in this matter. Accordingly, this Court holds 

Concise Statement is nothing more than an attempt to delay a 

paragraphs to do so. It is evident to this Court that Appellant's 

raises two issues for review, but uses eleven numbered 

misrepresentations, as described below, Appellant arguably 

disposed of at summary judgment. Aside from these 

of the evidence when there was no trial and the case was 

Appellant claims that this Court's ruling was against the weight 

filed in the matter currently before this Court. In another issue, 

related to counterclaims when no counterclaims have been 

the Superior Court. For example, Appellant identifies two issues 

misplaced and which Appellant never intends to address with 

Concise Statement clearly includes issues which are entirely 

fourteen issues for review by our appellate courts. Appellant's 
11 

2002)). 

Commonwealth v. Heggins, 809 A.2d 908, 911 (Pa. Super. 

Kanter v. Epstein, 866 A.2d 394, 400 (Pa. Super. 2004) (citing 

opinion pursuant to that supposition the issues are still wclved." 

guesses the issues Appellants raise on appeal and writes an 

review, it is worth noting that "[e]ven if the trial court correctly 

However, despite this Court's attempts to identify issues for 

clause rendered the Mortgage unlawful? 

Motion for Summary Judgment where a cross-collateralization 

(2) Whether the trial court erred by granting Appellee's 

material fact exist? 

Motion for Summary Judgment where genuine issues of 

(1) Whether the trial court erred by granting Appellee's 

following issues for review: 

procedural posture of this matter, this Court has identified the 

this Court, due to the lack of complexity of the substance and 

Appellcnt' s Concise Statement inhibits meaningful review by 

··•·"-··-··-··-··-··---·-·----------- 

matters which may be appropriate for review. Although 

attempted to distill from Appellant's Concise Statement any 
12 

appropriate. First Wisconsin v. Strausser, 653 A.2d 688 {Pa. Super. 

admission and tha.t summary judgment is therefore 

owing the bank, the general denial must be considered an 

that, when a defendant generally denies the amount due and 

an admission." 19.:_ In First Wisconsin v. Strausser, the Court held 

general denial or a demand for proof ... shall have the effect of 

necessary implication." Pa.R.C.P ., Rule 1029(b) {2015). "A 

required are admitted when not denied specifically or by 

"[a]verments in a pleading to which a responsive pleading is 

Pennsylvania Rule of Civil Procedure 1029(b) states 

In an action for mortgage foreclosure, the 

_________ .entrv of surnmory ludqmentIs __ proper.il.the.. _ 

mortgagors admit that the mortgage is in 

default, that they have failed to pay 

interest on the obligation, and that the 

recorded mortgage is in the specified 

amount. This is so even if the mortgagors 

have not admitted the total amount of 

the indebtedness in their 

pleadings. Cunningham v. McWilliams, 

714 A.2d 1054, 1056-1057 (Pa. Super. 1998) 

{internal citations omitted); Washington 

Federal Savings and Loan Assoc. v. Stein, 

515 A.2d 980, 981 (Pa. Super. 1986). 

The Superior Court has explained as follows: 
13 

1995). The First Wisconsin Court applied the rationale that a 

defendant/ debtor, apart from the plaintiff I lender, is the only 

party who would have sufficient knowledge of which to base a 

specific denial. Id. 

Applying the law to the facts of this case, it is clear that 

the entry of summary judgment in favor of Appellee was 

proper. In the Answer, Appellant purports to deny the 

allegations in averment 10 of the Complaint that he is in default 

under the terms of the Mortgage for failure to pay installments 

due on January 26, 2012. Such denial is not specific because it 

fails to allege payments made under the Mortgage and not 

otherwise stated in the Complaint. Because such information 

would be within the control of Appellant, his response to 

averment 10 must be deemed an admission to the event of 

default on January 26, 2012. Likewise, Appellant included in the 

Answer a specific denial to the amounts due and owing on the 

Mortgage through May 8, 2014, while, again, failing to allege 

any payments he made that were unaccounted for in the 

Complaint. Appellant's response to averment 11 of the 
14 

pleadings, while arguing that the entry of summary judgment 

Response. Instead, Appellant continues to rest on the 

Appellant has failed to attach even one document to his 

including the Mortgage and Note, affidavits, and a loan history, 

documents in support of the Motion for Summary Judgment, 

material dispute of fact. While Appellee attached multiple 

supportive materials to his Response that demonstrate a 

identify a remaining issue of fact is his failure to attach any 

allowed to proceed to trial. Related to Appellant's failure to 

such that summary judgment should be denied, and the case 

failed to identify any genuine issue which remains in dispute, 

depositions. kt In the instant matter, Appellant has completely 

affidavits, admissions, answers to interrogatories, and/or 

judgment must demonstrate a genuine issue for trial by utilizing 

Rather, a party attempting to avoid the entry of summary 

judgment may not rest on the pleadings. Stein, 515 A.2d at 289. 

Further, a party seeking to avoid the entry of summary 

-------------------------------------------- 

remaining due and owing under the Mortgage. 

Complaint must be deemed an admission to the amounts 
15 · 

properly identify any cross-collateralization provision. Neither 

allegations related to the other loans and guaranty, and to 

Summary Judgment, but he has failed to make any factual 

attach any such materials to his Response to the Motion for 

depositions. Stein, 515 A.2d at 289. Not only did Appellant fail to 

use of affidavits, admissions, answers to interrogatories, and/or 

demonstrate that relevant factual issues remain through the 

attempting to avoid the entry of summary judgment must 

allegedly executed by Appellant. As discussed above, a party 

Statement, Appellant mentions a guaranty and two other loans 

of the banking regulations. Also, for the first time, in his Concise 

that this rendered the Mortgage unlawful and in contravention 

their divorce was finalized. Appellant alleged in his New Matter 

former wife, Defendant Karen Karboski, was completed after 

cross-collateralization of his loan with a loan provided to his 

deny Appellee's Motion for Summary Judgment because a 

Finally, Appellant indicates that this Court was required to 

-------···-··--·-······- ----------- 

law in this Commonwealth. See Stein, 515 A.2d at 289. 

was improper. This argument is simply against the state of the 
16 

(END OF OPINION) 

merit and must fail as a matter of law. 

collateralization clause, Appellant's vague argument is without 

failure to identify any issue of material fact related to the cross 

themselves have been made of record in this case. Due to his 

no information related to said documents or the documents 

irrelevant to the instant mortgage foreclosure matter. As such, 

include copies of such documents which appear wholly 

·-------------------··-·-····-···-··-····-----·-···-------·-- ----------- 

Summary Judgment provide any identifyi"ng information or 

Appellant's New Matter, nor his Response to the Motion for 
17 

-, _. Lesa S. Gelb, J 

/ 

i 

Superior Court of Pennsylvania Docket No. 607 MDA 2016. 

the Appellants and Appellee as well furnish a copy to the 

notice of the attached Opinion pursuant to Pa. R.C.P. 236 to 

Judicial Records/Prothonotary is hereby directed to serve 

ORDER 

AND NOW, this£day of June, 2016, the Clerk of 

No. 6640 of 2014 

MORTGAGE FORECLOSURE 

: In the Court of Common Pleas 

of Luzerne County 

Patrick F. Constantino, 

Appellant 

Patrick F. Constantino, a/k/a 

Pasquale F. Constantino, and 

Karen Constantino a/k/a 

Karen Ann Karboski 

vs. 

Appel lee 

Wells Fargo Bank, N.A. s/b/m 

Wachovia Bank, National 

Association 
18 

Andrew Katsock, Esquire 

15 Sunrise Drive 

Wilkes-Barre, PA 18705 

cc: 

Mario J. Hanyon, Esquire 

Phelan Hallinan Diamond & Jones, LLP 

1617 J.F.K. Blvd., Suite 1400 

One Penn Center Plaza 

Philadelphia, PA 19103