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Valley of Lakes RICO Class Action against PNCBANK, et. al

(K) SCHEME OF FIRST EASTERN BANK AND DEFENDANTS TO CONCEAL RACKETEERING ACTIVITY PRIOR TO ITS MERGER WITH P.N.C. BANK AND TO CONTINUE PATTERN OF RACKETEERING INDEFINITELY

233. Commencing on or about May 23, 1993, FIRST EASTERN BANK, CBG, FRANK CEDRONE, and other defendants, did knowingly and willfully devise a scheme and artifice to continue to conceal the pattern of racketeering, and to continue the extortion and fraudulent schemes, even after the Consent Decree of October 22, 1992 had expired. In furtherance of this scheme, FIRST EASTERN BANK purposely secured the assignment of the promissory note of J.L Wolgin so that it, FIRST EASTERN BANK, would have complete control of when to foreclose on CBG's property. (See Exhibits 199 and 200).

  • Second, FIRST EASTERN BANK then used this newly acquired power to continuously delay the foreclosure of the property since on or about May [22 ], 1993 until the present day--even though CBG's lack of compliance with the Chapter 11 proceeding caused the U.S. Trustee to file a motion, as early as July 2, 1993, to liquidate CBG and its affiliates pursuant to Chapter 7 of the Bankruptcy Code.

  • Third, FIRST EASTERN BANK and CBG permitted MLA to continue to manage and operate the essential functions of the subdivision, after the CONSENT DECREE of October 22, 1992 had expired, to the present day.

  • Fourth, FIRST EASTERN BANK through MLA continued the extortionate collection practices for services and maintenance that were not provided.

  • Fifth, FRANK CEDRONE with the knowledge and assistance of FIRST EASTERN BANK continues to tout the imminent resumption of the development plan through mass mailings sent throughout the U.S.

  • Sixth, FRANK CEDRONE and CBG have created a pseudo-property owners association intended to ensure that his control of the "Valley of Lakes" will continue even after the property is foreclosed by enforcing CBG's fraudulent covenant and restrictions. The specific and particular details of this scheme are provided infra.

234. A copy of three pages of "United States Trustee's Motion to Convert to Chapter 7," in the United States Bankruptcy Court for the Middle District of Pennsylvania, IN RE C.B.G. Limited, et al., filed July 2, 1993, is annexed hereto and made a part of this complaint, and marked Exhibit 186-1 to 186-3.

235. A copy of a newspaper article titled "Trustee: Pull bankruptcy protection for resorts," by Tony Greco, Staff Writer, published on or about August 17, 1993, in the Hazleton Standard-Speaker of Hazleton, Pennsylvania is annexed hereto and made a part of this complaint, and marked Exhibit 187.

236. In furtherance of this scheme, FIRST EASTERN BANK through MLA continued the policy of CBG and FRANK CEDRONE of denying access to the common areas to property owners, "in good standing", who wished to associate as part of VOLCA. Demonstrating FRANK CEDRONE's policy is a copy of a letter, dated July 25, 1991, from Wayne F. Guidotti, Director of Operations, on "Valley of Lakes and Eagle Rock Resort" letterhead, addressed to Helen Phillips, P.O. Box 133, Nuremberg, PA 18241, is annexed hereto and made a part of this complaint, and marked Exhibit 188-1 to 188-2. The following are examples of letters placed in the U.S. Postal Service by MLA for purposes of carrying out this scheme:

    a. A copy of a letter dated July 15, 1993, from Raymond F. Stanford, Managing Agent, "Per C.B.G., Limited," to M/M Frank Rachubinski, P.O. Box 137, Oneida, PA 18242, regarding Application for Pig Roast, on "C.B.G., Limited, Valley Utilities Co., Oneida Water Co., P.O. Box 673, Nuremberg, PA 18241" letterhead is annexed hereto and made a part of this complaint, and marked Exhibit 188A.

    b. A copy of a letter dated July 30, 1993, from Gilbert C. Werner, Managing Agent, to Mr. Frank Rachubinski, P.O. Box 137, Oneida, PA 18242, on "C.B.G., Limited, Valley Utilities Co., Oneida Water Co., P.O. Box 673, Nuremberg, PA 18241" letterhead is annexed hereto and made a part of this complaint, and marked Exhibit 189.

237. A copy of a letter dated August 2, 1993, to Gil Werner, Managing Agent, from Frank Rachubinski, regarding VOLCA Pig Roast Application is annexed hereto and made a part of this complaint, and marked Exhibit 190.

238. In furtherance of this scheme, FRANK CEDRONE, CBG, mailed numerous letters throughout the U.S. making fraudulent representations and pretenses regarding imminent financing, and continuing the promotion of the development plan. A copy of a group mailing dated July 28, 1993, from Frank M. Cedrone - Managing General Partner, C.B.G. Limited, addressed to "All Property Owners - Valley of Lakes & Eagle Rock Resort,", RE: Current Status Report, is annexed hereto and made a part of this complaint, and marked Exhibit 191-1 to 191-5.

239. Commencing on or about May 23, 1993 and continuing to the present, In order to continue the pattern of racketeering, the defendants FRANK CEDRONE, CBG, MLA, and other defendants, intensified their extortionate campaign against the property owners by denying them access to the common areas as punishment for expression of their opinions in letters and advertisements, and as punishment for property owners associating as a property owners association. In addition, the defendants continued to stress the need to rely on CBG's development plan. A copy of a group mailing titled "Notice to all Valley of Lakes Property Owners," mailed to all Property Owners in the "Valley of Lakes" subdivision, circa August, 1993, from "Valley of Lakes and Eagle Rock Resort" is annexed hereto and made a part of this complaint, and marked Exhibit 192-1 to 192-3.

240. FRANK CEDRONE with the knowledge of FIRST EASTERN BANK continued to make numerous fraudulent representations and pretenses to the press in order to create the false impression that CBG would secure new financing and resume the development plan, and thereby avoid foreclosure by FIRST EASTERN BANK. A copy of a newspaper article titled "Refinancing will avert sheriff's sale of resort," published on or about August 4, 1993, in the Hazleton Standard Speaker of Hazleton, Pennsylvania is annexed hereto and made a part of this complaint, and marked Exhibit 193.

241. Commencing on or about August 5, 1993, FRANK CEDRONE, with the support of MLA, levied fines against officers of VOLCA, totaling approximately $1,500.00 per individual, and revoked their right to use the common areas, a property interest, for exercising their free speech rights by advertising a gathering of VOLCA, and other fraudulent charges. The following are copies of a number of the citation letters, which were placed in the U.S. Postal Service:

    a. A copy of a letter dated August 5, 1993, from Frank M. Cedrone, Managing General Partner, to Mr. Frank Rachubinski, RE: "Violations - Lot No. A-043" is annexed hereto and made a part of this complaint, and marked Exhibit 194-1 to 194-2.

    b. A copy of a letter dated August 5, 1993, from Frank M. Cedrone, Managing General Partner, to Ms. Bette J. Jones, RE: "Violations - Lot No. I-018" is annexed hereto and made a part of this complaint, and marked Exhibit 195.

    c. A copy of a letter dated August 5, 1993, from Frank M. Cedrone, Managing General Partner, to Ms. Senta Sheridan, RE: "Violations - Lot No. CW-081" is annexed hereto and made a part of this complaint, and marked Exhibit 196-1 to 196-2.

    d. A copy of a letter dated August 25, 1993, from Frank M. Cedrone, Managing General Partner, to Ms. Senta Sheridan, is annexed hereto and made a part of this complaint, and marked Exhibit 197-1 to 197-2.

242. A copy of a letter dated, September 8, 1993, from Board of Directors of Valley of Lakes Civic Association, to Mr. Frank M. Cedrone, is annexed hereto and made a part of this complaint, and marked Exhibit 198-1 to 198-2.

243. Although FIRST EASTERN BANK had the right to foreclose on the mortgages encumbering the property owned by CBG in the "Valley of Lakes" subdivision on or about May [22], 1993, FIRST EASTERN BANK did not even schedule a Sheriff's Sale until September 3, 1993, which it then postponed.

    a. Copy of a Writ of Execution (Mortgage Foreclosure), filed by First Eastern Bank, N.A., assignee of J. L. Wolgin against C.B.G. Limited in the Court of Common Pleas of Luzerne County, dated June 25, 1993, is annexed hereto and made a part of this complaint, and marked Exhibit 199-1 to 199-6

    b. Copy of a Notice of Sheriff's Sale to be held on September 3, 1993, by First Eastern Bank, N.A., assignee of J. L. Wolgin against C.B.G. Limited in the Court of Common Pleas of Luzerne County, is annexed hereto and made a part of this complaint, and marked Exhibit 200-1 to 200-2.

    c. A copy of a newspaper article titled "Resort set for auction on Sept. 3," by Katrina Veeder, published on or about August 14, 1993, in the Potsville Republican, Pottsville, Pennsylvania is annexed hereto and made a part of this complaint, and marked Exhibit 201.

244. On or about September 3, 1993, FIRST EASTERN BANK postponed the Sheriff's sale in order to conceal the pattern of racketeering activity prior to its merger with PNC. This permitted CBG to continue its fraudulent press and mass mailing campaign claiming that resumption of the development plan was imminent, to wit:

    a. A copy of a newspaper article titled "Valley of Lakes sheriff's sale is postponed," published on or about September 4, 1993, in the Hazleton Standard-Speaker of Hazleton, Pennsylvania is annexed hereto and made a part of this complaint, and marked Exhibit 202.

    b. A copy of a newspaper article titled "CBG hopes to escape foreclosure," by Jeff Cox, Staff Writer of the Standard-Speaker, published on or about Fall, 1993, in the Hazleton Standard Speaker of Hazleton, Pennsylvania is annexed hereto and made a part of this complaint, and marked Exhibit 203.

245. In early December 1993, FIRST EASTERN BANK postponed the second scheduled Sheriff's Sale in order to conceal the pattern of racketeering until its merger with PNC was complete, and to permit the pattern of racketeering to continue. To this day, FIRST EASTERN BANK has refused to foreclose on the property, and has continued to operate and manage the property through a pattern of racketeering in which hardly any maintenance is provided, the sewage collection system is allowed to flood property and contractor's repairing the system are forced to place lien's on the property of property owners because VALLEY UTILITIES CO. INC. refuses to pay for the maintenance, the water system is not adequately maintained, the road system is not adequately maintained, many recreational facilities remained closed and the others are not adequately maintained, and FRANK CEDRONE continues to allege that new financing and full resumption of the development is imminent, to wit:

    a. A copy of a newspaper article titled "Anguish grows as lot owners see Valley of Lakes dream go dry," by Lisa Sheid, Staff Writer of Times Leader, published on or about December 5, 1993, in the Times Leader of Wilkes-Barre, Pennsylvania is annexed hereto and made a part of this complaint, and marked Exhibit 204-1 to 204-2.

    b. A copy of a group mailing dated December 13, 1993, from Frank M. Cedrone, Managing General Partner, addressed to "All Property Owners,", RE: Current Status Report, is annexed hereto and made a part of this complaint, and marked Exhibit 205-1 to 205-2.

    c. A copy of a letter dated April 8, 1994, from R. Dongelewicz, President, VOLCA, to Renardo Hicks, Bureau of Consumer Protection, 1425 Strawberry Square, Harrisburg, PA 17120, is annexed hereto and made a part of this complaint, and marked Exhibit 206-1 to 206-2.

    d. See Exhibits infra of complaints regarding sewer, water, and maintenance services.

    e. To this day, BILLBOARD ADVERTISING continues on the property. Such as:

      (1) A copy of a photograph showing a billboard reading, "FUTURE SITE OF EAGLE ROCK GOLF CLUB, 18 HOLD CHAMPIONSHIP GOLF COURSE, Planning & Design .. PALMER COURSE DESIGN COMPANY, Operation .. ARNOLD PALMER MGT. CO., Construction GOLF COURSE CONSULTANTS, Developed by .. C.B.G., Financing by .. FIRST EASTERN BANK," is annexed hereto and made a part of this complaint, and marked Exhibit 207.

      (2) A copy of a photograph showing a billboard reading, "5 UNIQUE MODELS, 'The Town Houses' At ARAPAHOE WEST, Ten Year Buyer Warranty, UNDER CONSTRUCTION, 'Valley of Lakes,'" is annexed hereto and made a part of this complaint, and marked Exhibit 208.

      (3) A copy of a photograph showing a billboard reading, "ED SHEMANSKY, CUSTOM BUILT HOMES, Contact 'Valley of Lakes' Housing Dept.," is annexed hereto and made a part of this complaint, and marked Exhibit 209.

    f. A copy of a group mailing circa Fall, 1993, from Frederick A. Deal, President and Chief Executive Officer, First Eastern Bank, addressed to "Dear Customer," is annexed hereto and made a part of this complaint, and marked Exhibit 210.

    g. A copy of a newspaper article, published on or about May 17, 1994, titled, "CBG bankruptcy hearing reset to July 21," by Tony Greco, Staff Writer, in the Hazleton Standard-Speaker of Hazelton, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 210A.

246. As a result of the refusal of MLA, FIRST EASTERN BANK, or CBG to pay for the maintenance of the sewer collection system as promised, in the Spring of 1993, raw sewage flooded the homes of property owners, who were then forced to pay for the repair to sewer collection system. See Exhibit 204.

247. Commencing on or about May 24, 1994, FRANK CEDRONE, CBG, and THE PROPERTY OWNERS ASSOCIATION OF THE VALLEY OF LAKES, an unincorporated associate knowingly and wilfully devised a scheme to continue to use the fraudulent covenants and restrictions recorded by CBG (E.g., Exhibit 10) for the purpose of continuing the patter of racketeering. FRANK CEDRONE made a mass mailing, on or about July 10, 1994, announcing the formation of a "property owners association" authorized to control the subdivision until he, FRANK CEDRONE, is "able to resume full operations...." This "property owner's association" was named "THE PROPERTY OWNERS ASSOCIATION OF THE VALLEY OF LAKES." The members of the board of the "PROPERTY OWNERS ASSOCIATION OF THE VALLEY OF LAKES" who have been encharged by CBG and FRANK CEDRONE with operating and managing the "Valley of Lakes" subdivision are: GEORGE DENKE, RON KICHLINE, DIANNE FRENCH, and TOM PIERSON.

248. In furtherance of this scheme, on or about June 10, 1994, the following letter, in the name of FRANK CEDRONE, was mailed as a group mailing to all of the property owners: a copy of a group mailing dated May 24, 1994, from Frank M. Cedrone, addressed "To All Valley of Lakes Property Owners," on "Valley of Lakes and Eagle Rock Resort" letterhead is annexed hereto and made a part of this complaint, and marked Exhibit 211.

249. In furtherance of this scheme, the unincorporated association, 'THE PROPERTY OWNERS ASSOCIATION OF THE VALLEY OF LAKES" mailed the following group mailing to all property owners, on or about June 10, 1994: A copy of a group mailing dated May 24, 1994, from George Denke, Diane French, Ron Kichline and Tom Pierson, addressed "To Our Fellow Property Owners," and mailed to all Property Owners in the "Valley of Lakes" subdivision, on letterhead reading "The Property Owners Association of the Valley of Lakes, P.O. Box 686, Nuremberg, PA 18241" is annexed hereto and made a part of this complaint, and marked Exhibit 212- 1 to 212-4.

250. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Henry E. Anuskiewicz (age over 60) of P.O. Box 643, Nuremberg, Luzerne, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about August, 1989, is annexed hereto and made a part of this complaint, and marked Exhibit 213-1 to 213-2.

251. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Randy Boldosser and Nancy Boldosser of 2 Meadow Lane, Annandale, New Jersey, owners of real property located in the area known as "Valley of Lakes," purchased on or about March, 1990, is annexed hereto and made a part of this complaint, and marked Exhibit 214-1 to 214-2.

252. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Frank Bott (age over 60) and Theresa Bott (age over 60) of P.O. Box 126, Nuremberg, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 215-1 to 215-2.

253. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Arthur W. Chafey (age over 60) and Anitah Chafey (age over 60) of 140 Valley Greene Circle, Wyomissing Hihhs, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," and financed by First Eastern Bank, N.A., Emerson, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 216-1 to 216-2.

254. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/27/94, filed by Michael Chaudrue and Geraldine Chaudrue of 7221 Ditman Street, Philadelphia, Pennsylvania, owners of real property located at Lot EA107 in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 217-1 to 217-2.

255. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by John Delgozzo and Toni Delgozzo of Rd. 4 Box 24A, Lionville Station Rd., Chester Springs, Chester, Pennsylvania, owners of real property located at Lot JA169 in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 218-1 to 218-2.

256. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Joanne E. Dumene (age over 60) of Box 177, Nuremburg, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about 1990, is annexed hereto and made a part of this complaint, and marked Exhibit 219-1 to 219-2.

257. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by George W. Hussinnetter (age over 60) and Dorothea Hussinnetter (age over 60) of 49 Brookhill Road, Sugarloaf, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," purchased on or about October 12, 1990, is annexed hereto and made a part of this complaint, and marked Exhibit 220-1 to 220-2.

258. A copy of a Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., dated 5/29/94, filed by Helen Ilkowski & Oman of address, owners of real property located in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 221-1 to 221-2.

259. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Robert Jacobe and Linda Jacobe of 693 Barrington Rd., Collegeville, Montgomery, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," purchased on or about 1989, is annexed hereto and made a part of this complaint, and marked Exhibit 222-1 to 222-2.

260. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Betty Jones (age over 60) of I18 Valley of Lakes, Box 214, Nuremberg, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about March 19, 1991, and financed by Citicorp Mort. Inc., is annexed hereto and made a part of this complaint, and marked Exhibit 223-1 to 223-2.

261. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by James Keim and Marion Keim of 4037 Main Street, Voorhees, New Jersey, owners of real property located in the area known as "Valley of Lakes," purchased on or about September, 1989, is annexed hereto and made a part of this complaint, and marked Exhibit 224-1 to 224-2.

262. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Justin A. Kershaw, Jr., (age over 60) of 23 Frog Hollow Rd., Chruchville, Bucks, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about February, 1986, is annexed hereto and made a part of this complaint, and marked Exhibit 225-1 to 225-2.

263. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Robert J. Knapp of 1064 Sterling Road, Union, New Jersey, owner of real property located in the area known as "Valley of Lakes," purchased on or about March, 1988, is annexed hereto and made a part of this complaint, and marked Exhibit 226-1 to 226-2.

264. A copy of a Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by William Krieger (age over 60) and Lee Krieger (age over 60) of 26 Cheyney, owners of real property located in the area known as "Valley of Lakes," purchased on or about September 22, 1989, and financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 227-1 to 227-2.

265. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/27/94, filed by John Kuhn of P.O. Box 631, Nuremberg, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about October, 1987, is annexed hereto and made a part of this complaint, and marked Exhibit 228-1 to 228-2.

266. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Dr. William Mannella and Mrs.Pamela M. Mannella of 98 Fox Valley Lane, Glen Mills, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 229-1 to 229-2.

267. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Gerald McNeill and Carol McNeill of 1680 Magnolia La., Norristown, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," purchased on or about May, 1989, and financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 230-1 to 230-2.

268. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Paul F. Morrow of P.O. Box 290, Nuremberg, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about August, 1990, is annexed hereto and made a part of this complaint, and marked Exhibit 231-1 to 231-2.

269. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Aimee Penko of 3812 Dartmouth Place, Philadelphia, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about March, 1990, and financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 232-1 to 232-2.

270. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Jack Pitts and Barbara Pitts of 2025 Wilson Ave., Bristol, Pennsylvania, owners of real property located at Lot C-2 in the area known as "Valley of Lakes," purchased on or about January 15, 1993, is annexed hereto and made a part of this complaint, and marked Exhibit 233-1 to 323-2.

271. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Gail M. Reese of 239 Muskegon Ci, P.O. Box 672, Nuremberg, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 234-1 to 234-2.

272. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Gail M. Reese and David A. Reese of P.O. Box 672, Nuremberg, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," purchased on or about 1992, and financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 235-1 to 235-2.

273. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by John Reinecker of 8648 Belfy Dr., Philadelphia, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 236-1 to 236-2.

274. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Kathleen Reinecker of 8648 Belfry Dr., Philadelphia, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about January, 1990, is annexed hereto and made a part of this complaint, and marked Exhibit 237-1 to 237-2.

275. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/27/94, filed by Florence Rodgers of 114 S. Main St., Dublin, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 238-1 to 238-2.

276. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Vittorio Rossi of 1030 Pinetown Rd., Ft. Washington, Pennsylvania, owner of real property located at Lot E14 in the area known as "Valley of Lakes," purchased on or about September, 1990, and financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 239-1 to 239-2.

277. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by James P. Rowan of P.O. Box 611, owner of real property located in the area known as "Valley of Lakes," purchased on or about August 15, 1987, and financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 240-1 to 240-2.

278. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Parvin Sawhney of 397 Pleasantview Dr., Bloomsburg, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about March, 1989, and financed by First Federal Savings Bank of Hazleton, is annexed hereto and made a part of this complaint, and marked Exhibit 241-1 to 241-2.

279. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Senta M. Sheridan (age over 60) of P.O. Box 697, Nuremberg, Pennsylvania, owner of real property located in the area known as "Valley of Lakes," purchased on or about October, 1988, and financed by First Eastern Bank, N.A., is annexed hereto and made a part of this complaint, and marked Exhibit 242-1 to 242-2.

280. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Waclaw Szczesniak (age over 60) and Danuta Szczesniak (age over 60) of B-56 Lake Valley Drive, Valley of Lakes, P.O. Box 147, Oneida, Pennsylvania, owners of real property located at Lot B-56 in the area known as "Valley of Lakes," purchased on or about September, 1988, is annexed hereto and made a part of this complaint, and marked Exhibit 243-1 to 243-2.

281. A copy of a Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Charles L. Tarone (age over 60) of 215 Shingle Mill Dr., Drums, Pennsylvania, owner of real property located at Lot E-49 Shenango Dr., in the area known as "Valley of Lakes," purchased on or about December, 1988, is annexed hereto and made a part of this complaint, and marked Exhibit 244-1 to 244-2.

282. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Marlene Thomas of P.O. Box 698, Nuremberg, Pennsylvania, owner of real property located at Lots H-62 and H-61, Huron Cir., in the area known as "Valley of Lakes," purchased on or about November 5, 1990, and Lot N-A1 in the area known as "Valley of Lakes," purchased on or about February, 1991, is annexed hereto and made a part of this complaint, and marked Exhibit 245-1 to 245-2.

283. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against Valley Utilities, Oneida Water, and CBG Ltd., dated 5/28/94, filed by Dan Tripodi of 1 Burlingnoff La., Lebanon, New Jersey, owner of real property located in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 246-1 to 246-2.

284. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by James J. Williams of 6 Francis Rd., East Brunswick, New Jersey, owner of real property located in the area known as "Valley of Lakes," is annexed hereto and made a part of this complaint, and marked Exhibit 247-1 to 247-2.

285. A copy of a Sworn Complaint filed with the Office of Attorney General, Commonwealth of Pennsylvania, against CBG Ltd., d/b/a Valley of Lakes, dated 5/28/94, filed by Paul M. Yosko and Patricia L. Yosko of 135 Country Club Rd., Coatesville, Pennsylvania, owners of real property located in the area known as "Valley of Lakes," purchased on or about 1989, and financed by Coatesville Saving Company, is annexed hereto and made a part of this complaint, and marked Exhibit 248-1 to 248-2.

286. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Henry E. Anuskiewicz of P.O. Box 643, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 249-1 to 249-2.

287. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Randy Boldosser and Nancy Boldosser of 2 Meadow Lane, Annandale, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 250-1 to 250-2.

288. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Frank V. Bott and Theresa Bott of P.O. Box 126, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 251-1 to 251-2.

289. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Arthur W. Chafey and Anita L. Chafey of 140 Valley Green Circle, Wyomissing Hills, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 252-1 to 252-2.

290. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Michael Chaudrue and Geraldine of 7221 ditman St., Philadelphia, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 253-1 to 253-2.

291. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by John Conahan and Linda Conahan of 11 Market View Dr., Ephrata, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 254-1 to 254-2.

292. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by John A. Delgozzo and Toni Delgozzo of Rd. 4, Box 24A, Lionville Station Road, Chester Springs, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 255-1 to 255-2.

293. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Jan T. Drayer of 160 Bertrand Drive, Princeton, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 256-1 to 256-2.

294. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Joanne E. Dumene of 5902 Mt. Eagle Dr. #318, Alexandria, Virginia (Lot D-06, Valley of Lakes), is annexed hereto and made a part of this complaint, and marked Exhibit 257-1 to 257-2.

295. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Amy Goodman of 7909 Heather Rd., Elkins Park, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 258-1 to 258-2.

296. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Frank F. Huppe of 1401 Clive Circle, Wilmington,Delaware, is annexed hereto and made a part of this complaint, and marked Exhibit 259-1 to 259-2.

297. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by George W. Hussinetter of 49 Brookhill Rd., Sugarloaf, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 260-1 to 260-2.

298. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Helen Ilkowski and Oman of 305 Debbie Lane, Phoeinixville, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 261-1 to 261-2.

299. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Robert Jacobe of 693 Barrington Rd., Collegeville, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 262-1 to 262-2.

300. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Betty Jones of Box 214, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 263-1 to 263-2.

301. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Alvin Johnston of P.O. Box 121, Nuremberg, Pennsylvania (I-65 Valley of Lakes), is annexed hereto and made a part of this complaint, and marked Exhibit 264-1 to 264-2.

302. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Mildred Johnston of P.O. Box 121, Nuremberg, Pennsylvania (J-66, Valley of Lakes), is annexed hereto and made a part of this complaint, and marked Exhibit 265-1 to 265-2.

303. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/29/94, filed by Walter Kawa of 2555 Burning Tree, Pennsauken, New Jersey (I-62 Valley of Lakes), is annexed hereto and made a part of this complaint, and marked Exhibit 266-1 to 266-2.

304. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by James Keim and Marion Keim of 4037 Main St., Voorhees, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 267- 1 to 267-2.

305. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Justin A. Kershaw, Jr., of 23 Frog Hollow Rd., Churchville, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 268-1 to 268-2.

306. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Nancy T. Kershaw of 23 Frog Hollow Road, Churchville, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 269-1 to 269-2.

307. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by R. Knapp of 1064 Sterling Road, Union, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 270-1 to 270-2.

308. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by William J. Krieger of 76 Cheyney, P.O. Box 294, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 271-1 to 271-2.

309. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by John M. Kuhn and Elayne Kalstein Kuhn of P.O. Box 631, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 272-1 to 272-2.

310. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Edwin M. Leiby, Jr., of 2675 Terwood Hill Dr., Willow Grove, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 273-1 to 273-2.

311. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Chester C. Lukas and Ann Marie Lukas of 1116 Cambridge Lane, Bridgewater, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 274-1 to 274-2.

312. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., CBG Ltd., and Kleppinger Trust, dated 5/28/94, filed by John A. Maloney and Catherine K. Maloney of 7610 Cheltenham Ave., Wyndmoor, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 275-1 to 275-2.

313. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Dr. William Mannella and Mrs. Pamella M. Mannella of 98 Fox Valley Lane, Glen Mills, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 276-1 to 276-2.

314. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Sheldon May and Margaret May of 55 Countrywood Dr., Wilkes- Barre, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 277-1 to 277-2.

315. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Gerald McNeill and Carol McNeill of 1680 Magnolia La., Norristown, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 278-1 to 278-2.

316. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Paul F. Morrow of P.O. Box 290, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 279-1 to 279-2.

317. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Jeffrey Natale of P.O. Box 54, Oneida, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 280-1 to 280-2.

318. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Woodnow C. Neff of 328 Tamanack Drive, Allentown, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 281-1 to 281-2.

319. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by William John Perez of (JA-247, Musitegon Circle, Valley of Lakes), P.O. Box 83, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 282-1 to 282-2.

320. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Aimee Penko of 3812 Dartmouth Place, Philadelphia, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 283-1 to 283-2.

321. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Jack A. Pitts of 2025 Wilson Ave., Bristol, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 284-1 to 284-2.

322. A copy of a Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Frank Rachubinski and Helen Rachubinski of P.O. Box 137, Oneida, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 285-1 to 285-2.

323. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by David Reese and Gail M. Reese of P.O. Box 672, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 286-1 to 286-2.

324. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by John Reinecker and Kathleen Reinecker of 8648 Belfry Drive, Philadelphia, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 287-1 to 287-2.

325. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by George M. Roberts of JA-150 Tuskarora Dr., Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 288-1 to 288-2.

326. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Florence Rodgers and Russell Rodgers of 114 S. Main St., Dublin, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 289-1 to 289-2.

327. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Vittorio Rossi of 1030 Pinetown Rd., Ft, Washington, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 290-1 to 290-2.

328. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by James P. Rowan of P.O. Box 611, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 291-1 to 291-2.

329. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Parvin Shawhney of 397 Pleasantview Dr., Bloomsburg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 292-1 to 292-2.

330. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Senta M. Sheridan of P.O. Box 697, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 293-1 to 293-2.

331. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Harold L. Smith and Emma J. Smith of P.O. Box 87, Oneida, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 294-1 to 294-2.

332. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by William E. Spotts of 250 Center St., Milton, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 295-1 to 295-2.

333. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Fred G. Stahl of P.O. Box, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 296-1 to 296-2.

334. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Waclaw Szczesniak and Danuta Szczesniak of (Lake Valley Drive Lot B-56), P.O. Box 147, Oneida, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 297-1 to 297-2.

335. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Charles L. Tarone of 215 Shingle Mill Dr., Drums, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 298-1 to 298-2.

336. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Marlene D. Thomas of (H-62 Huron Cir of Valley of Lakes), P.O. Box 698, Nuremberg, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 299-1 to 299-2.

337. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Dan Tripodi of 1 Burlingnoff La., Lebanon, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 300-1 to 300-2.

338. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by James Williams and Frances Williams of 6 Francis Road, East Brunswick, New Jersey, is annexed hereto and made a part of this complaint, and marked Exhibit 301-1 to 301-2.

339. A copy of a Sworn Formal Complaint filed with the Pennsylvania Public Utility Commission, against Valley Utilities, Oneida Water Co., and CBG Ltd., dated 5/28/94, filed by Paul Yosko and Patricia Yosko of 135 Country Club Rd., Coatesville, Pennsylvania, is annexed hereto and made a part of this complaint, and marked Exhibit 302-1 to 302-2.

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Valley of Lakes RICO Class Action against PNCBANK, et. al

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