The folowing lawsuit was filed on August 1, 2008:
________________________________________________________________
IN THE COURT OF COMMON PLEAS OF _______ COUNTY, PENNSYLVANIA
CIVIL DIVISION
International Association of Certified
Home inspectors
1750 30th Street
Suite 301
Boulder, CO 80301
Plaintiff
CIVIL ACTION NO. __________
v.
Joe Kelly JURY TRIAL DEMANDED
Box 156 Chapel Drive
Virginville, PA 19564
and
Pennsylvania Home Inspectors’
Coalition, Inc.
197 Marlboro Road
Yardley, PA 19067
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served, by entering a written appearance personally or
by Attorney and filing in writing with the Court your defenses or objections to
the claims set forth against you. You are warned that if you fail to do so the
case may proceed without you and a Judgment may be entered against you by the
court without further notice for any money claimed in the Complaint or for any
other claim or relief requested by the Plaintiff. You may lose money or property
or other rights important to you.
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135 East State Street
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IN THE COURT OF COMMON PLEAS OF BUCKS COUNTY, PENNSYLVANIA
CIVIL DIVISION
International Association of Certified
Home inspectors
1750 30th Street
Suite 301
Boulder, CO 80301
Plaintiff
CIVIL ACTION NO. __________
v.
Joe Kelly JURY TRIAL DEMANDED
Box 156 Chapel Drive
Virginville, PA 19564
and
Pennsylvania Home Inspectors’
Coalition, Inc.
197 Marlboro Road
Yardley, PA 19067
COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES
PARTIES
1. Plaintiff, International Association of Certified Home Inspectors (“INTERNACHI”)
is a Colorado Nonprofit Corporation and is also a tax exempt trade association
under Section 501(C)(6) of the Internal Revenue Code. Plaintiff’s address is
1750 30th Street, Ste. 301, Boulder, Colorado 80301.
2. Defendant Joe Kelly (“Kelly”) is a home inspector who resides in Pennsylvania
and has a business address of Box 156 Chapel Drive, Virginville, PA 19564. According
to his website Kelly does business in Berks, Lehigh, Montgomery, Chester, Lancaster,
Lebanon, and Schulykill counties in Pennsylvania.
3. Defendant Pennsylvania Home Inspectors’ Coalition, Inc. (“PHIC”), is a non-stock,
non-profit corporation organized and existing under the laws of the Commonwealth
of Pennsylvania and maintains its principal place of business at 187 Marlboro
Road, Yardley, Pennsylvania. (Bucks County).
4. Kelly is and was at all times relevant to this action a member of PHIC. He
was one of the founders of PHIC and is currently the Secretary of PHIC.
JURISDICTION AND VENUE
5. This Court has jurisdiction over the Defendants because all Defendants are
citizens of Pennsylvania, all of Plaintiff’s claims arise out of the Defendants’
conduct in Pennsylvania, and the acts of Defendants caused harm to the Plaintiff
and its members in Pennsylvania.
6. Venue is proper in _____ County because ________ and because Plaintiff is
seeking to enforce joint and several liability against it and all of the other
defendants.
GENERAL ALLEGATIONS
7. The home inspection industry is made up primarily of individuals who conduct
home inspections as sole proprietors or through single-owner corporations or limited
liability companies.
8. Home inspections have become common in the real estate industry as part of
the buying and selling of residential homes, and they are usually performed on
behalf of prospective buyers.
9. Generally, home inspectors market their services through real estate agents,
through affiliations with trade associations, and through direct marketing to
consumers.
10. There are three major national trade associations representing the interests
of home inspectors. They are the Plaintiff (“INTERNACHI”), the National Association
of Home Inspectors (“NAHI”), and the American Society of Home Inspectors (“ASHI”).
11. INTERNACHI is an entity separate and distinct from the National Association
of Certified Home Inspectors, Inc. (“NACHI”), but is an outgrowth of NACHI. All
NACHI members automatically became members of INTERNACHI when NACHI’s leadership
decided to transition away from NACHI to INTERNACHI, but many in the home inspection
industry continue to use the term “NACHI” to refer to INTERNACHI and its members.
It is common knowledge in the industry that NACHI transitioned to INTERNACHI,
and therefore any statement that casts NACHI and its members in a bad light also
casts INTERNACHI and its members in a bad light.
12. There is some competition between the three trade associations in that they
compete for members and attempt to help market the services of their members;
however, INTERNACHI allows members of NAHI and ASHI to also be members of INTERNACHI.
13. Prior to 1998 INTERNACHI was an unincorporated association, but INTERNACHI
incorporated as a Pennsylvania non-profit corporation in 1998 and was later converted
to a Colorado nonprofit corporation. Since incorporating INTERNACHI has grown
to become the largest trade association in the Home Inspection industry. The
reasons for INTERNACHI’s success are many, but one significant reason is that
INTERNACHI does a better job of promoting the services of its members than other
trade associations. INTERNACHI also provides more benefits to its members than
the other trade associations at a better price.
14. As a result of INTERNACHI’s growth after its incorporation, some members
of NAHI, ASHI, and/or other trade associations in the industry began to lose business
to INTERNACHI members and/or began to worry that they would lose business to INTERNACHI
members.
15. In approximately 2000 the Pennsylvania General Assembly began to consider
legislation to regulate the home inspection industry in Pennsylvania.
16. Between approximately January 1, 2000, and November 26, 2001, the exact date
being unknown to Plaintiff, a group of Pennsylvania home inspectors comprised
largely of members of NAHI and ASHI began to lobby the Pennsylvania General Assembly
and/or local governments for legislation they believed would be favorable to them
and unfavorable to INTERNACHI and its members. This group called itself the Pennsylvania
Home Inspectors Coalition (“PHIC”) and incorporated as a Pennsylvania non-profit
corporation on November 26, 2001.
17. On December 20, 2001, the Pennsylvania Home Inspection Law, 68 Pa. C.S.A.
Section 7501 et seq. (the “Act”) became effective.
18. The Act governs the home inspection industry in Pennsylvania by establishing
requirements for home inspectors. The Act is incorporated herein by reference,
but a summary of the Act’s requirements is as follows:
a. Home inspectors are required to be a full member in good standing
of a national, not-for-profit home inspection association or must be supervised
by someone who is;
b. Members must comply with a code of conduct and attend continuing
professional education classes as an ongoing condition of membership;
c. Home inspectors are prohibited from performing repairs on the
same house he or she inspected within the preceding 12 months;
d. The party selling the property that is the subject of the inspection
has the right to receive a free copy of the report upon request;
e. Home inspectors must maintain insurance against errors and omissions
and general liability coverage;
f. A violation of this new law amounts to a violation of Pennsylvania's
Consumer Protection Law;
19. The Act defines a “national association” as an association with members in
more than 10 states.
20. INTERNACHI has members in all fifty states and throughout Canada and is therefore
a “national association” under Pennsylvania law.
21. The Act defines a “full member” as a person who has performed or participated
in more than 100 home inspections and has passed a recognized or accredited examination;
INTERNACHI defines a “full member” the same way and has done so at all times relevant
to this action.
22. INTERNACHI has been in compliance with the Act since the Act became effective
in December 2001.
23. PHIC asserts to the public now and has in the past asserted to the public
that INTERNACHI is not and has never been compliant with Pennsylvania law. PHIC
sometimes offers no explanation for these public statements, but when it does
offer an explanation, PHIC’s explanation tends to be that “only three home inspection
associations have submitted verifiable proof of compliance with the state law”
or words to that effect; the three associations that PHIC lists as compliant are
NAHI, ASHI, and the American Institute of Inspectors (AII).
24. Membership is PHIC is not open to INTERNACHI members because membership in
PHIC is only open to inspectors who belong to a national home inspector organization
that has provided PHIC with “verifiable proof of compliance” with Pennsylvania
law.
25. PHIC has never publicly defined what constitutes “compliance” or “verifiable
proof,” but upon information and belief, PHIC’s internal position is that INTERNACHI’s
examinations are not “recognized” or “accredited” under Pennsylvania law because
INTERNACHI allows its members to take its examinations online. Therefore, full
members of INTERNACHI can never provide verifiable proof of compliance with Pennsylvania
law to PHIC’s satisfaction.
26. The allegations above, and the allegations set forth hereafter, are incorporated
by reference into each and every cause of action set forth in this Complaint as
if separately set forth therein.
ALLEGATIONS OF STATEMENTS AND ACTIONS OF DEFENDANTS
27. The PHIC website contains an article “for immediate release” dated October
15, 2005. The article states in relevant part, “…Pennsylvania Home inspectors
Coalition was formed to represent a unified voice of the majority of Compliant
home Inspectors in the State and act as a watchdog to further legislative initiatives
effecting [sic] the Profession. Since our law is self enforcing PHIC also took on the task
of verifying compliant organizations and Inspectors.”
28. The article further states in relevant part, “NACHI: Responded with only
verbal communication and direction to their website. . . It is PHIC’s opinion,
that due to a lack of verifiable responses and continued refusals, NACHI is not
compliant.” PHIC’s website also misleads visitors into believing that PHIC has
the official support of the Pennsylvania attorney general by including a link
to that office beneath the words “Supporters of the Coalition.”
29. In September of 2003, PHIC and Joe Kelly, who presently acts as PHIC’s corporate
Secretary, filed a complaint in the Court of Common Pleas in Chester County, Pennsylvania
for Declaratory Relief (“The PHIC/Kelly lawsuit”). The complaint sought a declaration
that NACHI was not at the time the Act became effective in Pennsylvania and “has
never been subsequent thereto a National Home Inspectors Association.”
30. The PHIC/Kelly lawsuit was dismissed on June 15, 2005. The case was not
dismissed on the merits but for lack of proper service. Further, in dismissing
that action, the Court stated: “Finally there is no indication that Plaintiffs
are authorized to enforce the Home Inspection Law, 68 Pa. C.S.A.”
31. Since the dismissal of the PHIC/Kelly lawsuit, PHIC and its members, officers,
and directors (including Delaney, Steger, and Koloskee) have continued to hold
themselves out to the public as a watchdog organization in Pennsylvania, suggesting
powers to interpret and enforce the Act that it does not have. Defendants have
done this with the intent of hurting INTERNACHI’s image, reducing INTERNACHI’s
membership, to discourage Pennsylvania consumers from hiring INTERNACHI members
to perform home inspections, and to stifle competition from INTERNACHI members
in the home inspection industry.
32. Since the dismissal of the PHIC/Kelly lawsuit, PHIC and its members, officers,
and directors (including Kelly) continue to make false statements concerning INTERNACHI’s
alleged non-compliance with Pennsylvania law.
33. Recently, PHIC, its members, supporters, and Kelly have begun to be more
aggressive in making public statements, particularly to realtors, about INTERNACHI’s
alleged failure to comply with Pennsylvania law.
34. Kelly maintains a website at www.advancedhi.com and maintained it at all
times relevant to this action. Kelly’s website indicates he is a member of PHIC
and of ASHI.
35. Kelly’s website contains the following statements:
Not All Home Inspectors are the same
It seems concerns for compliance of "The Home Inspection Law", in Pennsylvania,
are also within the Real Estate community. Is the law working? Is there enforcement?
These are questions, which deserve clearer answers.
One way you, as a consumer, can identify Inspectors as being Compliant with our
enacted law is to request a signed copy of the "Pennsylvania Home Inspectors Compliance Statement". Pennsylvania's ACT 114 states; Reliance - A buyer shall be entitled to rely in good faith, without
independent investigation, on a written representation by a home inspector that
the home inspector is a full member in good standing of a national home inspection
association.
Beware of altered copies of this copyrighted document, if you do not see the
PAR (Pennsylvania Association of Realtors) logo in the upper left corner, and the
PHIC (Pennsylvania Home Inspectors Coalition) logo right corner, the document has
been altered, should be reported, and should not be relied upon.
Buying a home may well be the most expensive purchase of your life and insuring
your right to the highest level of professionalism is critical. ACT 114 is a Consumer Protection law, be aware of its intent.
PHIC has done extensive research into validating truly compliant Home Inspection
organizations and has found only members of ASHI (American Society of Home Inspectors), NAHI (National Association of Home Inspectors), and AII (American Institute of Inspectors)
have offered verifiable proof of compliance with the guidelines and intent of
Pennsylvania's ACT 114.
Be aware, ask questions, and "Protect Your Investment". Advanced Home Inspections
if fully compliant with our law and stands ready to ease you through this potentially
stressful process.
36. The statements on Kelly’s website are misleading in that:
a. The statements suggest that a home inspector who does not sign
PHIC’s Compliance Statement is not in compliance with Pennsylvania law.
b. The statements suggest that any compliance statement other than
the one prepared by PHIC is not proof of compliance with Pennsylvania law.
c. The statements suggest that any compliance statement other than
the one prepared by PHIC is not reliable.
d. The statements suggest that only ASHI, NAHI, and AII are in compliance
with Pennsylvania law.
e. The statements suggest that INTERNACHI is a not a national association
as defined under Pennsylvania law.
f. The statements suggest that INTERNACHI has not offered verifiable
proof of compliance with the guidelines and intent of Pennsylvania’s law even
though NACHI (prior to the transition to INTERNACHI) informed PHIC concerning
where to find the necessary information on NACHI’s website.
g. The statements suggest that INTERNACHI cannot offer verifiable
proof of compliance with the guidelines and intent of Pennsylvania’s law even
though NACHI (prior to the transition to INTERNACHI) informed PHIC concerning
where to find the necessary information on NACHI’s website.
37. The statements on Kelly’s website as set forth in paragraph 35 above are
intended to mislead consumers and realtors.
38. The statements of PHIC at set forth in paragraphs 23, 27, and 28 above are
intended to mislead consumers and realtors.
39. Upon information and belief, Kelly maintains the above-referenced statements
on his website with the knowledge and permission of PHIC.
40. INTERNACHI relies on its good reputation among consumers and realtors to
recruit and retain members. INTERNACHI members rely on INTERNACHI’s good reputation
to attract customers and to obtain referrals from real estate agents.
41. All of the statements of the Defendants complained of herein either referred
explicitly to INTERNACHI or were worded so as to make clear that INTERNACHI was
the organization being referred to as not being compliant with Pennsylvania law.
42. All of the statements of the Defendants complained of herein tended to disparage
INTERNACHI and the services of its members, to harm the reputation of INTERNACHI
and its members, to lower INTERNACHI and its members in the eyes of the community,
to deter existing INTERNACHI members for renewing their INTERNACHI memberships,
to deter other inspectors from joining INTERNACHI, to deter consumers from using
INTERNACHI inspectors, and to deter realtors from referring customers to INTERNACHI
and/or to INTERNACHI inspectors.
43. All of the statements of the Defendants complained of herein were understood
by those who heard or saw the statements as referring to INTERNACHI and its members.
44. All of the statements of the Defendants referred to in this Complaint were
made with knowledge that the statements were false or with reckless disregard
of whether they were false.
45. All of the statements of the Defendants referred to herein were made with
malice and warrant an award of exemplary damages.
46. As a result of the defamatory and deceptive conduct of the Defendants at
outlined above, INTERNACHI and its members in Pennsylvania have been harmed and
continue to be harmed through loss of business, loss of membership, and damage
to their reputations. The monetary damages suffered by Plaintiff on each Count
in this Complaint exceeds $50,000.00.
FIRST COUNT
(Defamation)
47. The Defendants’ public statements, including those identified above, are,
on their face, false and deceptive.
48. Defendants have published the false, deceptive and defamatory remarks to
third parties through defendants’ use of the Internet, websites, newsletters and/or
mass communication to consumers and real estate agents throughout Pennsylvania.
49. Defendants’ false allegations target consumers and the real estate industry
and are sufficient to negatively affect INTERNACHI’s professional reputation in
the home inspection industry, and to impact third parties in their decisions not
hire INTERNACHI inspectors, and to impact real estate agents in their decisions
not to refer business to INTERNACHI inspectors and/or not to associate with INTERNACHI
and INTERNACHI inspectors.
50. As a result of the aforementioned defamatory communications by Defendants,
INTERNACHI and its membership have suffered financial injury in the form of present
and future loss of business and loss of reputation.
SECOND COUNT
Injurious Falsehood / Commercial Disparagement
51. The statements of the Defendants complained of herein all referred to the
business of INTERNACHI, INTERNACHI’s compliance with Pennsylvania law, and the
competency and ethics of INTERNACHI’s members in the home inspection industry.
52. The statements of the Defendants complained of herein were all false.
53. Defendants intended that publication of their statements would cause pecuniary
loss to Plaintiff or reasonably should have recognized that publication would
result in pecuniary loss.
54. Defendants’ publication of the statements caused actual pecuniary loss to
INTERNACHI and to its members.
55. Defendants knew the statements were false or acted in reckless disregard
of their truth or falsity.
THIRD COUNT
(Tortious Interference with Existing and Prospective Business Relations)
56. At the time of the statements of the Defendants, INTERNACHI had existing
contractual relationships with its existing members in Pennsylvania, and reasonably
expected that those members would renew their INTERNACHI membership. INTERNACHI
also contracted with a number of vendors to provide benefits for its members in
Pennsylvania, and those benefits included education as well as discounts on goods
and services. INTERNACHI reasonably expected its good relations with its vendors
to continue.
57. At the time of the statements of the Defendants, INTERNACHI had prospective
contractual relationships with current inspectors who were likely to renew their
membership in INTERNACHI, with inspectors who were likely to join INTERNACHI,
and with vendors who were likely to contract with INTERNACHI in order to provide
benefits to INTERNACHI members.
58. At the time of the statements of the Defendants, INTERNACHI members had contractual
relationships with consumers. INTERNACHI members also had good relationships
with realtors likely to refer potential customers to them.
59. The Defendants’ false and deceptive statements have been published and disseminated
to third parties with the intent to interfere with INTERNACHI’s existing and prospective
business relationships with its members and vendors, and to interfere with the
existing and prospective business expectancies of INTERNACHI’s members.
60. Defendants published their false and misleading statements maliciously and
with no justification.
61. As a result of Defendants’ acts, INTERNACHI has suffered actual harm in reduced
renewal of memberships, reduced recruitment of new members, and being unable to
obtain benefits for its members on favorable terms. These things have resulted
in less revenue to INTERNACHI from membership dues. INTERNACHI members have also
suffered actual harm in damage to their reputation and reduced referrals from
realtors.
FOURTH COUNT
Unlawful Practice of Law
62. At all times relevant to this action, Pennsylvania law prohibited any person
from providing legal advice or otherwise practicing law in Pennsylvania unless
that person was licensed to practice law in Pennsylvania.
63. Defendants’ statements to realtors and consumers in Pennsylvania that INTERNACHI
and its members are not compliant with the Act or Pennsylvania laws were statements
of a legal opinion, and Defendants intended the realtors and other recipients
of those statements to rely on those statements to the detriment of INTERNACHI
and its members.
64. Upon information and belief, none of the Defendants were licensed to practice
law in Pennsylvania at the time they made or published the statements that are
the subject of this action.
65. INTERNACHI has been harmed by the Defendants’ actions in providing legal
opinions to realtors and others that Defendants are not competent to provide because
they are not licensed to practice law in Pennsylvania.
66. Consumers and real estate agents in Pennsylvania have been deceived by the
Defendants’ statements that INTERNACHI is not compliant with Pennsylvania law,
and will continue to be so deceived unless Defendants are restrained from making
any such statements.
FIFTH COUNT
Misleading Corporate Name
67. PHIC deliberately chose a name designed to imply that it has legal authority
to determine what trade associations and which home inspectors are in compliance
with the Act and other laws of Pennsylvania. Further, PHIC typically uses the
acronym “PHIC” to imply that it is a government agency and has legal authority
to determine what trade associations and which home inspectors are in compliance
with the Act and other laws of Pennsylvania.
68. At all times relevant to this action Pennsylvania law provided that no corporate
name shall imply that the corporation is an agency of the Commonwealth. See,
15 PA.C.S.A. § 1303(c)(1)(i).
69. PHIC’s name and acronym mislead the public to believe that PHIC is a government
agency, that it has legal authority to interpret the law, and/or that PHIC is
a neutral private agency working for the public good, when, in fact, PHIC is a
group of home inspectors composed primarily of NAHI and ASHI members that seeks
to stifle competition from INTERNACHI and its members.
70. INTERNACHI and the public have been harmed by PHIC’s use of a misleading
name, and will continue to be so harmed unless PHIC is restrained from using that
name and acronym or unless PHIC is required to include an appropriate disclaimer
in all communications making clear that it is not an agency of the Commonwealth
and has no legal authority to determine which home inspector associations are
in compliance with Pennsylvania law.
SIXTH COUNT
Revocation of Non-Profit Status
71. PHIC is and was at all times relevant to this action an organization designed
and intended to promote the interests of NAHI and ASHI and their members, and
designed and intended to harm the interests of INTERNACHI and its members.
72. At all times relevant to this action Pennsylvania law provided that a nonprofit
corporation must be able to fulfill its purpose without financial benefit to the
members, except as salaries and expenses. The law also required that the nonprofit
should not contemplate pecuniary gain or profit, incidental or otherwise.
73. Upon information and belief, PHIC has provided and continues to provide pecuniary
gain to its members by reducing competition from INTERNACHI and INTERNACHI inspectors,
and by allowing PHIC inspectors to promote their businesses by using a nonprofit
entity to disparage INTERNACHI and discourage competition from INTERNACHI and
its members.
74. INTERNACHI, its members, and the public have been harmed and continue to
be harmed by PHIC’s improper use of the nonprofit corporate form in the manner
described herein.
75. INTERNACHI, its members, and the public will continue to be harmed by PHIC’s
improper use of the nonprofit corporate form in the manner described herein unless
PHIC is restrained from continuing to do so.
SIXTH CLAIM FOR RELIEF
Civil Conspiracy
76. As set forth above, upon information and belief, Defendants acted with a
common purpose to do one or more unlawful acts or to do one or more lawful acts
by unlawful means or unlawful purpose.
77. The Defendants have acted in unison to systematically destroy the reputation
and business of INTERNACHI and its membership by falsely alleging INTERNACHI is
not compliant with the Act.
78. PHIC has historically held itself out as the watchdog of the home inspection
industry in Pennsylvania and continues to do so.
79. Through their public statements the Defendants have overtly acted to harm
the interests of INTERNACHI and its members, to stifle competition from INTERNACHI
inspectors, and to further the interests of NAHI and ASHI.
80. INTERNACHI has suffered actual legal damages as a result of the conspiracy
of the Defendants.
RELIEF REQUESTED
WHEREFORE, Plaintiff asks this Court to provide the following relief:
1. That Defendants be permanently enjoined from publishing any statements
that INTERNACHI is not compliant with the Act or Pennsylvania law unless and until
Defendants have obtained a judicial declaration from a court of competent jurisdiction
that INTERNACHI is not compliant with the Act or Pennsylvania law.
2. With regard to any statements of Defendants that INTERNACHI is
not compliant with the Act or Pennsylvania law, an Order requiring Defendants
to include a conspicuous disclaimer making clear that Defendants are not attorneys,
that PHIC is not a government agency, and that PHIC has no authority to determine
which inspector organizations are in compliance with the Act or the laws of Pennsylvania.
3. An Order that Defendants identify all statements made by any of
them during the past five years stating or implying that INTERNACHI is not compliant
with the Act or Pennsylvania law, and identifying the recipients of all such statements.
4. An Order that Defendants include the following conspicuous disclaimer
whenever it or its members or agents use the terms “PHIC” or “Pennsylvania Home
Inspector’s Coalition,” to wit: “PHIC is not an agency of the Commonwealth of
Pennsylvania and has no legal authority to determine which inspector organizations
are in compliance with the laws of the Commonwealth.”
5. An Order enjoining any Defendants who are not licensed to practice
law in Pennsylvania from publishing any legal opinion that INTERNACHI is not compliant
with the Act or Pennsylvania law.
6. Judgment against the Defendants for damages resulting from their
per se defamation of INTERNACHI.
7. Judgment against the Defendants for actual damages proven at trial.
8. Judgment against the Defendants for exemplary damages.
9. Such other relief as the Court finds appropriate.
Respectfully submitted.
___________________________
Joseph A. Ferry, Esquire
Attorney I.D. #46774
Two Penn Center Plaza
Suite 200
Philadelphia, PA 19102
(215) 854-6444 telephone
(215) 243-8202 fax
Attorney for Plaintiff,
INTERNATIONAL ASSOCIATION OF
CERTIFIED HOME INSPECTORS
V E R I F I C A T I O N
I, NICK GROMICKO, do hereby verify that the statements made in the foregoing
Complaint are true and correct to the best of my knowledge, information and belief.
I understand that false statements herein are made subject to the penalties of
18 Pa. C. S. §4904 relating to unsworn falsification to authorities.
Nick
Gromicko
