MEMORANDUM OPINION
KARON OWEN BOWDRE, UNITED STATES DISTRICT JUDGE.
In 1846, Chief Justice John Bannister Gibson of the Pennsylvania Supreme Court pithily described a negotiable instrument as a "courier without luggage." Overton v. Tyler, 3 Pa. 346, 347 (Pa. 1846). "It is a requisite," he wrote, "that it be...
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