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HomeMy WebLinkAbout02-5028Johnson, Duffie, Stewart & Weidner By: David J. Lanza I.D. No. 55782 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PFB MEMBERS' SERVICE CORPORATION, Plaintiff V. COCHRANTON COOPERATIVE ASSOCIATION, Defendant NOTICE TO DEFEND To the Defendant: NO. ?spO CIVIL CIVIL ACTION - LAW 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 defense 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Johnson, Duffle, Stewart & Weidner By: David J. Lanza I.D. No. 55782 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff PFB MEMBERS' SERVICE CORPORATION Plaintiff V. COCHRANTON COOPERATIVE ASSOCIATION, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. (21a , (? CIVIL CIVIL ACTION - LAW -COMPLAINT AND NOW, this day of October 2002, comes the Plaintiff, PFB MEMBERS' SERVICE CORPORATION, by and through its undersigned attorneys, Johnson, Duffle, Stewart & Weidner, and files this Complaint, and in support thereof avers as follows: 1. The Plaintiff, PFB Members' Service Corporation, is a Pennsylvania Corporation with an address at PO Box 8736, Camp Hill, PA 17001. 2. The Defendant, Cochranton Cooperative Association, is a business entity of undetermined nature with an address at 136 West Pine Street, Box 246, Cochranton, PA 16314. 3. On or about July 31, 2000, Plaintiff and Defendant entered into an Agreement whereby Plaintiff agreed to provide and Defendant agreed to pay for supplies and materials, including baler twine and replacement wire. A true and correct copy of Defendant's Application for Credit is attached hereto as Exhibit „A„ 4. Plaintiff has performed all of its duties under the aforesaid Agreement, including the provision, from time-to-time, of various amounts of baler twine, replacement wire and farm supplies to the members of Defendant, Cochranton Cooperative Association. 12. Plaintiff conferred a material benefit upon Defendant upon the promise of Defendant to pay the reasonable value of Plaintiff's products. 13. Defendant requested and authorized all shipments made by Plaintiff. 14. Plaintiff expected remuneration from Defendant at the time of Defendant's performance. 15. Defendant was aware the Plaintiff expected payment for Plaintiff's products. 16. Despite demand by Plaintiff for payment for Plaintiff's products, Defendant has failed and refused to make payment as required. 17. Defendant's failure to make payment has resulted in Defendant's unjust enrichment. 18. The value of the aforesaid products (less payments made) to Defendant equals $39,920.98 (plus costs and interest in the amount of $2,990.00). WHEREFORE, Plaintiff demands judgment against Defendant, Cochranton Cooperative Association, in the amount of $42,919.98 plus costs and interest from October 26, 2002. COUNT III. BOOKACCOUNT 19. Plaintiff incorporates the averments of Paragraphs one through eighteen as if fully set forth herein. 20. Defendant owes Plaintiff the amount of $42,919.98 for services performed (including interest) in accordance with a book account, a true and correct copy of which is attached hereto as Exhibits "A" and "B„ 21. Plaintiff has demanded the total due. Exhibit A umi, `JUL X31-00 MON 12:48 PM 8144251083 P.01 S" MARK P.O. Box 349 Middletown, PA. 17057 Phone # 1.000-732.8473 PAZ # UT-'/02.42441 APnICATION FOR CRICOIT To: Credit Manager Application in hereby made for an open lino of credit with SAVISMARK In U1e em0unt of 10,000.Oq if this application for credit Is approved, we agree to meet your terms of gjr 30 RM for payment of invoices, COMPAIIY NAME: COC)D WQ Cm--O-gEWJVE SS'N ADDREBSs 136 W. PINE STREET, BOX 2477 5gMAWT014, PA 16414 pIIOpE * 814-425-7401 _ FAR # 814-425-1083 YEARB IN XUG111p881 ,j,4}_ yRS,. CONTACT: ?q-nr vwTUr Mrs NATt1RD OT VU$lNftet FEED SEED gERT1],17FR _ HARD6/ARF RRTAIL STORE COW"ItATION: PARTNEROMPs *OLZPRCPa ASSN X BANK: SEE ATTACHED SHEET ADDRRSS: PH OW3 # CONTACT: ACCT. # TRADE RLPSR&DiGEB COMPANY AADRE88 1 SEE ATTACHED SHEET ACCT• 2, ACCT# V _ 3. , ACCT# 4. --- ACCI'# PAX # 1. PNONS: 2. rAX SIGNATURE: .7 +? -,e-le, DATBj 7/31/00 Exhibit B Sent By: PA FARM BUREAU; 7177313515 Sent B}?• , Oct-10-02 9:08AM; . PFB SAFEMARK TIRE; 717 702 4275 ? p?*y,?,, Oct-9.02 3:17PM; -- S11C 1.,{ alt R A Members' Service of the Pennsylvania Form Bureau P,O. Box 549, Middletown, PA 17067 (7171944-1466 Ship To COCHRANTON CO-OP ASSOCIATION 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 COCBRANTON CO-OP ASSOCIATION Sold TO ; 136 WEST PINS STREET Box 247 COCHRANTON, PA 16314 50 50 125 125 009174 009194 111 ?-_ L .. 175 -. HOLLAND EXTRA 10000/290 SISAL TWIN BRAZILIAN NORSK 9000/325 SISAL TWI .,, To SRIPPED PROUD TO BE AN AMERICAN Page 2/4 Page 2 P g310f3SD0 08 1011Z000 Dare E 0712eiz0" Oats Order Rauivvd DOUG H ..._ us[amer Order d SEbmaimk Ex rem a via 17.41 672.50 17.4 2181.25 SAFEMARK From ; COCHRANTON Co-OP ASSOCIATION 136 WEST PINE STREET SOX 247 COCHRANTON, PA 16314 PFB Members' Service Corporation To : SAFEMARK Division PO Box 549 Middletown, PA 17057 TERMS NET 30 DAYS par month SerVICS Charga on Accounts over 36 days. fANNOAL PERCENTAGE RATE OF 1896) 8 1 8600 0810112000 - Dara 3053.75 Amourtt Due 111 4acoum 1 0 M? I I Sent By: PA FARM BUREAU; 7177313515 Oct-10-02 9:08AM; Sent By., PFB SAFEMARK TIRE; 717 702 4275; Oct-9.02 3:17PM; A Members' Service of The Pennsylvania Farm Bureau P.O. Box 549, Middletown, PA 17Q57 (717) 944-1466 549, Middletown, PA 17057 (717) 944-1466 Ship To : COCHRADITON CO-OP ASSOCIATION 136 WEST PINE STREET SOX 247 COCHRANTON, PA 16314 TERMS NET 30 RAYS t.6% par monrh SGrWe• Charge en Accoume over 30 days. IANNUAI PERCENTAGERAT2 Or 1s1%1 COCHRANTON CO-OP ASSOCIATION Sold To : 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 111 eCeUnt 600 800 009164 PREMIUM HOLLAND 9000/325 SI9AT. TWI 150 150 009187 PREMIUM HOLLAND 10000/290 SISAL TW 150 190 009188 PREMIUM HOLLAND 7200/410 SISAL.TWI SAFEMARK CURRENTLY TAKING EARLY SPRING ORDERS FOR BALER TWINE, NET WRAP AND SILLAGE WRAP. CALL YOUR SALESPERSON NOW. SAFEMARK From COCHRANTON CO-OP ASSOCIATION 136 WEST PINS STREET SOX 247 COCHRANTON, PA 16314 PFB Members' Service Corporation Tu : SAFEMARK Division PO Box 549 Middletown, PA 17057 21525000 02001 Date 16940.00 Amount Due _ 11,1 ... Aecoum N" y :r Page 4/4 Page 4/4 21525890 0210812001 -- 712'01 L 12 Data Order Rocaived 1949 t4 r -are DIRECT SHIPMENT a 15.00 12320.00 15.40 2310-00 15.40 2310.00 SAFEMARK A Members' Service of the Pennsylvania Farm Bureau P.O. Box 549, Middletown, PA 17057 (717) 944-1466 Ship To: COCHRANTON CO-OP ASSOCIATION 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 COCHRANTON CO-OP ASSOCIATION Sold To ; 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 111 Ccount 21526000 0310112001 Date 0210712001 Date Order Received 1949 Customer Order p Safemark Ex ress i e a loo 300 100 300 009085 009127 SM 9000/130 PLASTIC BALER TWINE 1 SM 9000/325 SISA 14.13 1413.00 150 150 009130 L BALER TWINE PREMIUM HOLLAND 16000/180 SISAL 4 4620.00 552 150 552 150 009148 1 BRIDON 20000/130 PLASTIC BALER TWI 17.4 0 T 13 10 2610.00 009187 PREMIUM HOLLAND 10000/290 SISAL TW . 15 40 7231.20 . 2310.00 DATE TRM SAFEMARK CURRENTLY TAKING EARLY SPRING ORDERS FOR BALER TWINE, NET WRAP AND SILLAGE WRAP. CALL YOUR SALESPERSON NOW. 18184 22 -----------------------Please Return Lower SAFEMARK From COCHRANTON CO-OP ASSOCIATION 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 PFB Members' Service Corporation To : SAFEMARK Division PO Box 549 Middletown, PA 17057 TERMS NET 30 DAYS 1.5% per month Service Charge on Accounts over 30 days. (ANNUAL PERCENTAGE RATE OF 18%) 21526000 0310112001 Date 18184.20 Amount Due 111 Account N SAFEMARK A Members' Service of the Pennsylvania Farm Bureau P.O. Box 549, Middletown, PA 17057 (717) 944-1466 Ship To COCHRANTON CO-OP ASSOCIATION TERMS 04 21584900 10612001 136 WEST PINE STREET NET 30 DAYS BOX 247 Date COCHRANTON, PA 16314 1.5% per month Service Charge on Accounts over 30 days - (ANNUAL PERCENTAGE RATE OF 18%) 0310112001 Date Order Received COCHRANTON CO-OP ASSOCIATION Sold To : 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 111 Customer Order # ccount Safemark Ex ress e .a FLIantity Quantity Item rdered Shipped Code Description Unit 48 17.00 816.00 400 400 009008 SM2M0000/10104PLASTIC BALERCTWINE '14 48 48 009120 SM 4000/350 WIRE 'REPLACEMENT 13.10 5240.00 50 50 009124 SM 10000/290 SISAL BALER TWINE 16.50 792.00 450 450 009171 HOLLAND EXTRA 9000/325 GOLD SISAL 15.40 6930.00 DATE TRM PLASTIC BALER TWINE SUPPLIERS HAVE A NNOUNCED A $1.50.82.00 PRICE INCREASE EFFECTIVE WITH SHIPMENTS AFTER APRIL 30, 2001 - - - - - - - - - - - - - Please Return Lower Portion With SAFEMARK From : COCHRANTON CO-OP ASSOCIATION 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 PFB Members' Service Corporation To SAFEMARK Division PO Box 549 Middletown, PA 17057 llm? 21584900 0410612001 Date 14548.00 Amount Due 111 Account # SAFEMARK A Members' Service of the Pennsylvania Farm Bureau P.O. Box 549, Middletown, PA 17057 (717) 944-1466 Ship To COCHRANTON CO-OP ASSOCIATION 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 COCHRANTON CO-OP ASSOCIATION Sold To : 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 111 Account 21774600 0510412001 Date E0412412001 Date Order Received DOUG Customer Order 11 I Safemark Express I - Shipp-?Vla • Ordered shi? d Descri ti Unit Price 300 450 )pe 250 450 Code 009002 009127 p on BRIDON 20000/110 PLASTIC BALER TWI SM 9000/325 SISA . h, 1 13.10 Mount 3275.00 48 48 009192 L BALER TWINE BRIDON 4000/350 WIRE REPLACEMENT 15 .40 6930.00 16.50 792.00 748 of/]VJ, UNITS RHjj!PEn PLASTIC BALER TWINE SUPPLIERS HAVE ANNOUNCED A 51.5042.00 PRICE INCREASE EFFECTIVE WITH SHIPMENTS AFTER APRIL 30, 2001 ----------------------- Please Return Lower SAFEMARK From COCHRANTON CO-OP ASSOCIATION 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 PFB Members' Service Corporation To : SAFEMARK Division PO Box 549 Middletown, PA 17057 TERMS NET 30 DAYS 1.5% per month Service Charge on Accounts over 30 days. (ANNUAL PERCENTAGE RATE OF 18%) mfffi? 21774600 0510412001 Date 10997.00 Amount Due 111 Account # "fdtBT AtTfL?uYtt Et1cl?sed:;>, Sent By: PA FARM BUREAU; 7177313515 Sent,By; PFB SAFEMARK TIRE' ' Oct-10-02 9:08AM; 717 702 4275; Oct-9-02 3:17PM; r- SAFEMARK A Members' Service Of the Pennsylvania Farm Bureau P.O. Box 648, Middletown, PA 17067 (717) 9+44-1486 ship To ; COCHRANTON CO-OP ASSOCIATION TERMS BOX 36 WEST 8TN8 STREET jN "30 AYS 1 COCHRAta TON, DA 3.633.4 MU rh ae CherF en [ANNUAWTAD' 30 E EMASE CF 76%I COCMW4TON Co-DP ASSOCIATION Sold To ; 136 WEST FINE 9TRggT BOX 247 COCHRANTON, PA 16314 .111 co so 50 009002 BRZMN 20000/110 PLASTIC BALER "'rWI THANK YOU FOR YOUR VALUED PATRONAGE, ...._ SAFEMARK From : COCHRANTON Co-OP ASSOCIATION 136 WEST PINE STARET 90X 247 COCHRANTON, DA 16314 PFB Members' Service Corporation To : SAFE-MARK Division PO Box 649 Middletown, PA 17067 71ez4eaG as o01 Dsts 655.00 AmOurq- _..? ccoaae y L F y -- s• s+ r Y , P .., ,r =? Page 3/4 Page 3/4 21924800 0812812001 E Ntd] L;ii 13.10 655.00 SAFEMARK A Members' Service of the Pennsylvania Farm Bureau P.O. Box 549, Middletown, PA 17057 (717) 944-1466 Ship To : COCHRANTON CO-OP ASSOCIATION TERMS 136 OX 247T PINE STREET NET 30 DAYS B COCHRANTON, PA 16314 1.5% per month Service Charge on Accounts over 30 days. IANNUAL PERCENTAGE RATE OF 18%) COCHRANTON CO-OP ASSOCIATION Sold To ; 136 WEST PINE STREET BOX 247 COCHRANTON, PA 16314 111 ccount rdered shipped Code Description 100 100 009101 HOLLAND EXTRA 10000/290 GREEN SISA I THANK YOU FOR YOUR VALUED PATR DATE TRM ONAGE. - Please Return i nw., D, SAFEMARK From : COCHRANTON CO-OP ASSOCIATION 136 WEST PINE STREET BOX 247 COCHRANTON, pA 16314 PFB Members' Service Corporation To : SAFEMARK Division PO Box 549 Middletown, PA 17057 22002600 0612612001 Date 1540.00 Amount Due 111 Q.. ci:?i,1)q vY<;n;CTI?:V" N::4<^t 22002600 061262001 Date 0611 Ordd E Account a DO UG customer Order k Safemark Ex ress e is 15.401 1540.00 r w CJ `? :J (rl l.? ..JJJJ??? , f J `'t = LI) a p SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-05028 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PFB MEMBERS' SERVICE CORP VS COCHRANTON COOPERATIVE ASSOC R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: COCHRANTON COOPERATIVE ASSOCIATION but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of CRAWFORD County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 30th , 2002 , this office was in receipt of the attached return from CRAWFORD Sheriff's Costs: Docketing Out of County Surcharge Dep Crawford Cc .00 77.50 10/30/2002 JOHNSON DUFFIE STEWART WEIDNER So answer 18.00Y 9.00 10.00 R. Thomas Kline 40.50 Sheriff of Cumberland County Sworn and subscribed to before me this 4 L' day of 71r?? JeP.2- A. D. L w L )71 Z Irj, ?.k? Prothonotary IN THE COURT OF COMMON PLEAS OF CRAWFORD COUNTY Pennsylvania PFB Members' Services Corporation VS Cochranton Cooperative Association Sheriff's Return SERVED Cochranton Cooperative Association on October 22, 2002 at 1:40 PM by handing copy of Complaint to Ryan Mattocks, Adult in Charge at business, 136 W. Pine Street Association, Box 246, Cochranton, Crawford County, PA 16314. So answers, c' ) o"U 0'?kU f)"aj D?A.?ollins, Deputy Sheriff Robert M. Stevens, Sheriff Crawford County Costs: $40.50 Sworn to and subscribed before me this 25th day of October, 2002w. 2 Pr h notary In The Court of Common Pleas of Cumberland County, Pennsylvania PFB Members' Services Corporation VS. Cochranton Cooperative Association SERVE: same No. 02 sots civil Now, October 17, 2002 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Crawford County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sheriff of Sworn and subscribed before me this day of , 20 20, at o'clock M. served the COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( ) for JURY trial at the next tezm of civil court. ( X ) for trial without a jury. ------------------------------------------ CAPTION OF CASE (check one) (entire caption must be stated in full) ( X) Civil Action - Law PFB VENDERS' SERVICE CORPORATION, ( ) Appeal from Arbitration (other) VS. (Plaintiff) COCHRANTON COOPERATIVE ASSOCIATION, VS. (Defendant) The trial list will be called on and Trials comTence on Pretrials will be held on (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No5028 Civil Action )b& 2002 No. _ Indicate the attorney who will try case for the party who files this praecipe: David J. Lanza, Esquire Diane E. Hawk, Esquire indicate trial counsel for other parties if known: This case is ready for trial July 29, 2003 Date: Print Name: David J. Lanza Signed: Attorney for: Plaintiff L ?.._ t7 a T Mr FTIt= - L PFB MEMBERS' SERVICE CORPORATION, Plaintiff V. COCHRANTON COOPERATIVE ASSOCIATION, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5028 CIVIL TERM ORDER OF COURT AND NOW, this 126 day of August, 2003, a pretrial conference in the above matter is scheduled for Wednesday, October 15, 2003, at 3:30 p.m., in chambers of the undersigned judge, Cumberland County Courthouse, Carlisle, Pennsylvania. Pretrial memoranda shall be submitted by counsel in accordance with C.C.R.P. 212-4, at least five days prior to the pretrial conference. A NONJURY TRIAL in the above matter is scheduled for Thursday, October 30, 2003, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. .avid J. Lanza, Esq. 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorney for Plaintiff ,Mane E. Hasek, Esq. P.O. Box 77926 Seneca, PA 16346 Attorney for Defendant RKs OS-13?3 :rc BY THE COURT, ?rnr?-???sr?r?ad ?tt.h,???- ? ??,?,vn? dIJ,,L':?.'r??_ -- rid PFB MEMBERS' SERVICE CORPORATION, Plaintiff V. COCHRANTON COOPERATIVE ASSOCIATION, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5028 CIVIL TERM IN RE: PRETRIAL CONFERENCE A pretrial conference was held in the chambers of Judge Oler on Wednesday, October 15, 2003. Present on behalf of the Plaintiff was David J. Lanza, Esquire. Participating by telephone on behalf of the Defendant was Diane E. Hasek, Esquire. This is an action for breach of contract brought by the seller of certain supplies and materials including baler twine and replacement wire, which was allegedly not fully paid for by Defendant. The estimated duration of trial is one day. No unusual issues are expected to arise during the trial. By separate order of court, a non-jury trial has been scheduled for Thursday, October 30, 2003, at 9:30 a.m. in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Counsel have indicated that they anticipate that this case may be settled. To that end, Defendant's counsel is afforded an additional eight days from today's date to submit to the Court Administrator her pretrial conference memorandum. The Plaintiff's pretrial memorandum has previously been received by the Court. In the event that the case is settled, Defendant's counsel is excused from any requirement to submit a pretrial memorandum. By the Court, David J. Lanza, Esquire For the Plaintiff Diane E. Hasek, Esquire For the Defendant 42, Court Administrator lfh Y_3 y _ 11 PFB MEMBERS' SERVICE CORPORATION, Plaintiff V. COCHRANTON COOPERATIVE ASSOCIATION, Defendant IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 02-5028 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of October, 2003, upon consideration of the complaint filed in the above-captioned matter, and pursuant to an agreement reached between counsel in the person of David J. Lanza, Esquire, on behalf of the Plaintiff, and Diane E. Hasek, Esquire, on behalf of the Defendant, entered into in chambers of the undersigned judge, judgment is hereby entered in favor of the Plaintiff and against the Defendant in the amount of $41,304.56. It is noted that counsel have entered into an understanding, which will be memorialized through correspondence between them, as to a payment plan for collection of this judgment. avid J. Lanza, Esquire For the Plaintiff ?biane E. Hasek, Esquire For the Defendant By the Court, J.' Wesley 0 V pp 11 Rn?(g wcy ??"?n?6Z) ,, ,? . ??.tc??p???+ ^ {y°,;, fPFB MEMBERS' SERVICE CORPORATION, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. COCHRANTON COOPERATIVE ASSOCIATION, Judgment in Favor of Plaintiff on November 12. 200: for $A130-456. NO. 02-5028 Defendant PRAECIPE TO SATISFY JUDGMENT/POWER OF ATTORNEY PFB Member Service Corporation, Plaintiff in the above Judgment, do appear and acknowledge that on Ar 29, 2009 this day have had and received and from Cochranton Cooperative Association the defendant in tl above Judgment, full payment and satisfaction of the same, with interest and costs, and desired th satisfaction therefore shall be entered upon the records thereof. And further, Elizabeth D. Snover, the attorney for Plaintiff does hereby authorize and empower Curtis Lon the Prothonotary of said Court, to appear on behalf of PFB Members' Service Corporation and in Pf Members' Service Corporation name and stead to enter full satisfaction upon the record of said Judgmei as fully and effectually, to all intents and purposes, as PFB Members Service Corporation could were Pf Members' Service Corporation personally present in person to do so. And for so doing this shall be yc sufficient warrant of authority. In testimony whereof, I have hereunto set our hands and seals this 29"' day of April, 2009. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHNSON, DUFFIE, STEWART & WEIDNER By: Elizab D. Snover Attar I.D. No. 200997 Attorneys for Plaintiff Personally appeared before me, the subscriber, Elizabeth D. Snover, attorney for PFB Merril Sevice Corporation, the Plaintiff in the above judgment, and in due form of law acknowledged the v Power of Attorney to Satisfy the Judgment set forth, to be PFB Members' Service Corporation's act deed, and desired that same shall be filed in the office of the Prothonotary of the Court of Common Pie said County, In testimony whereof, I hereunto set my hand and official seal this _L day of ?c? , 2 ,17?r?T1 }'? -. duT ?` P?c?tl{?Ya1l?. Y:???A 'u17r'. My Cammrssitr a s,, ?? +Ws 30, e --? c tt n' NObaf1? CERTIFICATE OF SERVICE AND NOW, this j22"day of April, 2009, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Diane E. Hasek, Esquire 224 S. Main Street, Suite 210 PO Box 77926 Seneca, PA 16346 JOHNSON, DUFFIE, STEWART & WEIDNER By: I' abeth D. Snover ,?. :364713 IF 2069 ki-,R 30 Pig 2-, 4