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.?
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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
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,,
,? . ??.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
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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
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:364713
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