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Home My WebLink About00-02049 >.'--:; ~'liil111l , , ,n' - ~. ' ~1'!",""d!" COYNE INTERNATIONAL ENTERPRISES CORP. d/b/a COYNE TEXTILE SERVICES Plaintiff : IN THE COURT OF COMMON PLEAS v. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. to-;)t)'ItJ c;;;J THE GENERAL CASTING CO. Defendant : CIVIL DIVISION - lAW NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN 1WENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN 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. 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 NOTICA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VEINTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNAAPARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDA ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO 0 NOTIFICACION Y POR CUALQUIER QUEJA 0 ALlVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO 0 SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 -",-,-,~"-I.".."...", " ,,;..', "-,,<.., COYNE INTERNATIONAL ENTERPRISES CORP. d/b/a COYNE TEXTILE SERVICES Plaintiff IN THE COURT OF COMMON PLEAS v. CUMBERLAND COUNTY, PENNSYLVANIA NO. (}-o' .2AJ'-j C; ~ 7P.- THE GENERAL CASTING CO. Defendant : CIVIL DIVISION - LAW COMPLAINT The Plaintiff, COYNE INTERNATIONAL ENTERPRISES CORP. d/b/a COYNE TEXTILE SERVICES, by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of THREE THOUSAND, SEVEN HUNDRED SIXTY-FOUR DOLLARS AND EIGHTY-EIGHT CENTS ($3,764.88), along with interest thereon from April 22, 1997 upon a cause of action of which the following is a statement: 1. The Plaintiff, COYNE INTERNATIONAL ENTERPRISES CORP. d/b/a COYNE TEXTILE SERVICES, is a corporation organized and existing under the laws of the State of New York, having an office and place of business at P.O. Box 4854, Syracuse, NY 13221. 2. The Defendant, THE GENERAL CASTING CO., is a corporation organized and existing under the laws of the State of Ohio, having an office and place of business at 222 North Queen Street, Shippensburg, PA 17257. CAUSE OF ACTION 3. On February 26, 1992, Coyne entered into a rental service contract ("contract") with Defendant which provided that Coyne would furnish Defendant with its mats and related laundry services. 4. The contract provided that the term "shall be 156 weeks," and "shall automatically renew for additional terms of two years per term." Thus, after renewing on February 26, 1995 and February 26, 1997, the term of the contract would not expire until February 26,1999. A copy of the contract is attached as Exhibit "A." F:IUSERIRIKlCOMPIWORKI23076.WPD:08MarOO ,.., '~ 5. On or about February 15, 1997, however, Defendant wrongfully cancelled its contract with Coyne and commenced doing business with an unnamed competitor of Coyne. The contract stipulates that the contract may be cancelled by either party with at least 60 days written notice but not more than 90 days written notice before the end of a term. Exhibit "A" at paragraph 2. Defendant did not maii notice of cancellation to Coyne until January 14, 1997,43 days before the term was to end. See Defendant's letter at Exhibit "8." 6. Under the contract between Defendant and Coyne, Defendant agreed that if Defendant cancelled the contract prior to the termination date, Defendant would pay Coyne "liquidated damages equal to the foliowing percentages of the gross receipts that would be due for the balance of the particular term; a) 55% in the first year, b) 40% in the second year and c) 30% in the third year or in any year of the renewal period." Exhibit "A" at paragraph 7, 7. Defendant has breached its contract with Coyne by cancelling prior to the termination date and as a result has caused damage to Coyne in the approximate liquidated amount of THREE THOUSAND, SEVEN HUNDRED SIXTY-FOUR DOLLARS AND EIGHTY-EIGHT CENTS ($3,764.88). 10. The Contract further provides that in the event of a default by defendant, defendant "shall be liable for collection costs and reasonable attorney's fees." Exhibit "A" at paragraph 7. F:IUSERIRIKlCOMPIWORKI23076,WPD:01AprOO 2 ".. "J ~"""',"~~'~ WHEREFORE, Plaintiff Coyne demands judgment against defendant granting Coyne damages in the approximate amount ofTHREE THOUSAND, SEVEN HUNDRED SIXTY-FOUR DOLLARS AND EIGHTY-EIGHT CENTS ($3,764.88), plus interest, costs, and disbursements of this action, including reasonable attorney's fees, and such other relief as the Court deems just. Respectfully submitted, Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 --- Attorney for Plaintiff F:IUSERIRIKlCOIVIPIWORKl23076.WPD:08MarOO 3 __WiLl';- ~_4~ 0<""""""'."""_,,,,,,,,,- ~ ~~"nll:i~~_~"I~ ",j:,~,,-,,(" Agree:ner.t No. S5l6~ , RENEWAL SERVICE AGREEMENT COYNE INTERNATIONAL ENTERPRISES CORP, . .. SEAVIC~ AGREEME~T /./ ~".,.-:. Ill;" M ~ /. . 1. ServIce. In consIderation of the agreement by Coyne International EnterprIses Corp, d/b/a Coyne Textll Services ("CTS"), ~ervlce the hsted garments and/or goods, and any additions to them, Customer agrees to the terms of this Agreement for its full requirements of industrial laundry items. The garments andlor goods shall remain the property of CTS. No purchase order or term proposed by customer shall alter this Agreement unless the specific term is agreed to in writing by an Offict!-l' or General Manager of CTS. 2. TerM. The term of this Agreement shall be 156 weeks. After the mitial term this Agreement shall automatically renew for additional terms of t~o years per term, until c.ancelled by either party, at least sixty 160) days but not more than ninety (901 days prior to the end of the term, by service of wrItten notIce, matled return receipt requested, statmg the intention to terminate. 3, Guaranteed Price Protection., The staled price IS guaranteed except for.an annual increase of seven t71 percent, There shall be no abatement for va~tions, holidays, periods of suspension for late payml'nt, tlr similar situations. CTS may il11mediately terminate or suspend performance of t.hls !'-g:reement if Customer fails to pay un)' amuunts owed WIthin It!n (10) days of invoice. Customer shall be responsible fot snv sales, use or other SImIlar taxes. . 40 Guaranteed Replacement of Goods. ers will replal't' indi\'idual garments and goods as reasonabl.v required due to normal wear and tear. Customer shall pay for replacements of lost, stolen or damag:t'd items at im'oice cost or as stated below. 5. Guaranteed Delivery. Except for circumstances beyond CTS's control. CTS guarantees that it wlil maintain reasonable compliance With il~ delivery schedules or that a credit for the particular it",m will be given. 6. Additional Customer Obligations. Customer shall advise CTS in a writing addressed to the Corporate Safety Officer, 140 Cortland Avenue, Syracuse, New York 13221 of any contamination to the garments or goods picked up by CTS including any hazardous material undel' federal or state law. Customer shall defend and indemnify CTS for any loss or claim which is in whole or in part attributable to contamination to garments or goods. 7. Uquidated Damages and Costs. Customer recognizes CTS's substantial investment in equipment and merchandise and the difficulty of ascertaimng damages and, therefore, agrees that if t.his Agreement. is cancelled by Customer prior to a normal termination date or is cancelled by C1S because of Customer's default, Customer will pay CTS liquidated damages equal to the following percentages of the gross receipts that would be due for the balance of this Agreement; a) 55% in t.he first yellr. b} 40% in the second year and cl 30% in the third year or in any year of an automatic renewal of this Agreement pursuant 10 section 2, In addition to CTS's ot.her remedies, if customer defaults or cancels, customer shall be liable for collection costs and reasonable attorney's fees. B, Absence of Existing Contracts. Customer warrants that it is not under cont.ract with any third party ror these goods and services. 9. Early Termination. Customer may terminate this Agreement if there is a substantial breach by CTS but only if CTS fails to make reasonable efforts to remedy the breach after the following written notice is given to the General Manager of the CTS facility providing the service. Customer's written notice, which must be mailed return rec~ipt requested, must specifically state the intention to terminate if reasonable efforts are not made to cure the breach within thlrtv (301 davs from the date of receipt of the writtt'n notice. The notice must also specifically state the breach or breaches and in the event of service deficiencl",s the spt'cific deficit:ncies in sen' Ice must be stated. If reasonable efTortsare not made within the thirty (30l day period to cure the breach. Customer may llll'll lel'mmaW hy wntwn nOllC!.' to th... (rt.neral Manager mailed return reCPlpt requested. In the event of such a termmation. Customer shall pay CTS the amorlizl'd cu~t of lhe garnwrlt:' or goods. 10. Limitation of Liability, CTS shall haw no liability for dJl'(~cl. mdirect, conscqulontl1l1 or olher damages, whether for p...rsomil Injur~' ur otherwise, and CTS's sole liability shall be for return of mOlley plaid for garments or hOOt]:; provl'd tll hl' d.:ofectl\'e. CTS shall not he liahle for any failure in performance which r",sults from CBUSt.'S beyond its rt::tsunable control 11, Miscellaneous. This document is the entif'"e' Ag-reen1t.'lIl ut!t.....ccn lhe parties and any modification must be signed by an Officer or General Manager ofCTS. This Agreement shall benefit and bind the successors and ussigns of tht! parties and Customer consents to the assignment of this Agreement by CTS. 12. Warranty and Exclusion of Other Warranties, CTS warrants that it will clean garments In compliance with reasonable and customary industry standards, CTS makes no other warranties with respect to the garments, goods or service. ALL WARRANTIES, EXPRESSED OR IMPLIED INCLUDING WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE ARE EXCLUDED, 13. Protective Garments and/or Goods. CTS has available garmcnlJol and goods which may be warranted by the manufacturer to be flame retardant and protective and Customer acknowledges that Cuslomer is soldy responsible for determining the need for and ordering protective garments for the safety of its employees. CTS makes no warranty with rf:!spect to such garments or goods. Unless specifically stated by the manufacturer, no garment is protective or is name or chemical retardant. Customer shall defend and indemnify ~TS for an,y loss or claim which arises out of the use ofprotect.ive garments or goods or which is attributable, In whole or in part, to a failure to prOVIde protective garments or goods for its employees. BILLING AOORESS GENERAL CASTING DOMESTIC DIVISION PO BOX 220 DELAWARE OHIO CO. SOLO TO (ANDIOR OELlVER TOI 00' 00 00 00 00 00 00 00 43015 GARM,ID. I CONTRACT NO'1 PURCHAse ORDER NO. OR AUTHORIZATION 55183 PO. 08838 1/00/92 DESCRlPTIONIINDlVlDUAI.. 11== 'i: ~ I$S Q~FfT ~ ISS ~N-r f ISS ~\HT 4X6 BROWN MAT-OFFIl,' 3X5 SAFETY MAT-PLAl ,- i .. Xl0 BLUE-PLT OFFIl Xl0 BROWN-OFFICE 1 X5 BR-OFFICE UPSTl , X5 BR-OFFICE BAS~l Wi"'- l<5 SAFETY-FNDRY Ole X8 BROIjN MAT lE "'7 'j'!)OE/~ .... l/L1)/),l)EJ.. tHG-__ (;, ~t.' T:.1f.>:"u,_ GENERAL CASTING N QUEEN ST SHIPPENSBURG PA CO ~ I :51 ~~~ I ~::~o~ _I CUSTOMER NUMBER CHG 2-Z1530 BILLING TO READ PlANT YORK sea. NO. OELIVEREO PRice AMOUNT 5.30 5.i~ 3.45 17.2 7.20 14.4 7.Z0 7.2 3.45 3.4 3 ,- 3.4 3:~3 3.4 7.30 7.3 COMMENTS -- SIGNATURE: TITLE: (jl'&h1, JA; Wl'" '1.3' J J DATE: '10TE:<;:ullame.i. ,olely"lponllbl,lord-tlerminin;wh'"'1e' t~, \):..Il,:! ':; ',' ":!'fiIr~loY""~1;~Uj" pralecll.. llumenl. or goodl .i.J.J.J:)l.i. r:J. ~-,#-c;tL. 1- :z.~' 9S z_:l.-(, 'i 7 no ~~I~foRTYpe): ~....h4. to.'! (l..../;./p ",""", .* * @ * .* ~;. - THE GENERAL CASTING CO. * p ... P.O. BOX 218 . GRAFTON, OHIO 44044 (216) 926-2511 FAX (216) 926-2379 * 1f January 14, 1997 Mr, Stewart Fair Coyne Textile Services P,O, Box 4854 Department Y Syracuse, N.Y. 13221 VIA CERTIFIED MAIL No. P 257 947 139 RE: Termination of Mat Delivery for General Casting, Domestic Division: N. Queen St., Shippensburg PA Dear Mr, Stewart : It is with regrets that we must give notice that we will not be requiring the services of your company anymore to supply mats to our Domestic Division. We understand that it may take some time to effect this change so we suggest that we make the last day of service 30 days from today on February 15, 1997. If this is not agreeable, please call me at 216/926-2511, or Barb Cline at 717/532-6615. For the past year we have been seeking a company wide mat supplier as part of our Corporate Identity Program. This will make administration much easier and present continuity within our company, Given the fact that you are a regional company and would not be able to supply our facilities outside of your regional area, we felt that Coyne Textile Services would not make a good fit with our program, We would like to work with you on the removal of the mats so that we may have a smooth transition into our new service, without a loss of mats for our facility, fS- E- () 1;;' :l-c;J/'J 30 .EXHIBI1~ iJ :; i;..i:/ 'l'If"" h ;-( . '"-'~i: . "....... ,'~ We appreciate your time spent with our company, and wish you good luck in all future endeavors. Very Truly, THE GENERAL CASTING COMPANY cc: Barb Cline Loren Lamb Steve Richards ~ ,'," -, ,"" , . '0' ""'''' ~ ~, '~ "'.d" , ..<,',; liAR 0 1 '00 0:3: 50PM KNUPP & KODAK PC P.6 VERIFICATION I MICHAEL J>INSMOOR ,~ (nomoi GENERAL MANAGER ('''' of CO' 'NE I~ TERNATlONAl. ENTERPRISES CORP. d/b/a COYNE TEXTILE SERVICES, verify that the statements made in the a 'crego ng document are true and correct I understand that false statements herein are made subject to the penalties of 18 PI. C. ~ . ~4904, relating to unsworn falsification to authorities, COYNE INTERNATIONAL ENTERPRISES CORP. d/b/a COYNE TEXTILE SERVICES By: Title: 7?/:e/~E-d~~> CCA/a4 ~$4A14C:-&/C..- Dated.J1bd J 1 Pt;{J() -- ,':IUSE ~IRIK\COMP\WORK\230T6.WPD:08MarOO "l<s SHERIFF'S RETURN - REGULAR CASE NO: 2000-02049 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE INTERNATIONAL ENTERPRISE VS GENERAL CASTING CO THE BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GENERAL CASTING CO THE the DEFENDANT , at 0014:57 HOURS, on the 10th day of April 2000 at 222 NORTH QUEEN ST SHIPPENSBURG, PA 17257 by handing to BARBARA A. CLINE (ADMIN. SERV) a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 13,02 .00 10.00 .00 41.02 SO;?~~f R, Thomas Kline me this /0 ~ day of 04/12/2000 KNUPP, KOIJAl( J )::'LUM ;. By: !/itti) ~ ~ Deputy Sheriff ' Sworn and Subscribed to before ~ ,;lo-rytJ A. D . 'C)I/h 0 rh."p" j~ rothonotary ","--,,-' , , ;,,""""~'"lat~E''''''' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COYNE INTERNATIONAL ENTERPRISES d/b/a COYNE TEXTILE SI=RVICES, Plaintiff, Case No. 00-2049 v, Civil Division THE GENERAL CASTiNG CO., Defendant ANSWER Now comes Defendant, The General Casting Company ("Defendant"). and for its Answer to Plaintiffs Complaint, states as follows: 1. Defendant admits the allegations contained in Paragraph 1 of Plaintiffs Complaint. 2. Defendant admits the allegations contained in Paragraph 2 of Plaintiffs Complaint. 3. Defendant admits the allegations contained in Paragraph 3 of Plaintiffs Complaint. 4. Defendant admits the allegations contained in the first sentence of Paragraph 4 of Plaintiffs Complaint regarding the term and renewal provisions of the contract attached to Plaintiffs Complaint as Exhibit A. However, upon information and belief, it is denied that the aforementioned contract was renewed on February 26, 1997, as Plaintiff was notified in January of 1997 by Defendant that Defendant intended to terminate the contract on February 15. 1997. See Exhibit "8" to Plaintiffs Complaint. . "~" , ~"_'~'e",~~ 5. Defendant admits the allegations contained in Paragraph 5 of Plaintiff's Complaint regarding the notice provisions of the contract However, it is denied that Defendant "wrongfully cancelled its contract with [Plaintiffj" as provided in Paragraph 5 of Plaintiffs Complaint. Upon information and belief, Defendant notified Plaintiff of Defendant's intention not to renew the contract and requested that Defendant voice any Objections to termination of the Contract. Defendant waited until after expiration of the contract to notify Defendant of its objections, 6. Denied as stated. The contract is a document which speakS for itself and any characterizations are denied. It is denied that Defendant is obligated to pay Plaintiff the liquidated damages described in Paragraph 6 of Plaintiff's Complaint. 7, It is denied that Defendant breached its contract with Plaintiff and that Plaintiff has suffered any damages and/or damages in the amount described in paragraph 7 of Plaintiff's Complaint. NEW MATTERS 8, The Complaint. or some part of it, fails to state a claim or cause of action upon which relief can be granted. 9. The Complaint fails to state a claim sufficient to support an award of attorney fees. 10. The Complaint. or some part of it, Is barred by the statute of frauds. 11. The Complaint, or some part of it, is barred because of a failure of consideration. 12, Applicable laws, rules, statutes or regulations, including but not limited to the statute of limitations and/or doctrine of laches, controlling and requiring the . -2- - '1..-" 'illfiw,.,~,"..,IlI~_~"L institution of suit within a certain period of time following its accrual, were not complied with. and therefore, the Complaint is barred as a matter of law and equity. 13. Plaintiff does not possess the legal right to bring and maintain an action against Defendant. 14. Plaintiff has not incurred any legally cognizable damages as a result of Defendant's alleged conduct. 15, Any injury, damage or loss sustained by Plaintiff was solely and/or proximately caused by an intervening .and/or superseding act over which Defendant had no control. Alternatively. any amount which Plaintiff might be entitled to recover against Defendant must be precluded or reduced by an amount attributable to intervening and for superseding cause, 16. To the extent Plaintiff may have incurred any damages. said damages were a direct result of Plaintiff's conduct and, as a result, Plaintiff is precluded from asserting any claims against Defendant. 17. Plaintiffs claims are barred in that they seek recovery only for special, indirect and/or consequential damages. 18. To the extent Plaintiff may have incurred any damages, it failed to mitigate said damages. 19. Plaintiff failed to satisfy any and all conditions precedent to the institution of a claim against Defendant. 20. The liquidated damages provision of the contract, paragraph 7 of the contract, constitutes an unlawful penalty clause. . -3- ~ ~o ~ _";,;Jl' 21. Defendant reserves the right to assert other defenses or counterclaims, as such may be identified upon the conduct of further investigation and discovery. WHEREFORE: Defendant requests that Plaintiffs Complaint be dismissed and that Defendant recover its costs incurred herein. nd wL 0 e Kirkpatrick & Lockhart Payne Shoemaker Building 240 North Third Street Harrisburg, PA 17101-1507 Of 5?unsel: ~~ /~~ ;//5 Peter A. Lusenhop (00 9941) Vorys, Sater, Seymour and Pease LLP 52 East Gay Street P.O. Box 1008 Columbus,OH 43216-1008 (614) 464-8263 . -4- , ,'~-" -< " "~ m1~", 07/17/2000 15:30 FAX 614 464 2248 VSS&P COLS. ~008 VERIFICATION I, p,~rll..J;'. V..i'Ve- . ofthe General Casting Company. verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S. 94904, relating to unswom falsifications to authorities. THE GENERAL CASTING COMPANY By: ~A. ~ Title: ~... ~.A ~~ Dated: 7-~t/-OO -5- "~-"" "' . ~,'" J~' CERTIFICATE OF SERVICE The undersigned certifies that a true and accurate copy of the foregoing Answer of Defendant, the General Casting Company, was served upon Robert 0, Kodak, 407 North Front Street, P,O. Box 11848, Harrisburg, PA, 17108-1848, by Regular U,S, Mail, this ZB/4day of July, 2000. ~~ . -6- ~~ ,~~ COYNE INTERNATIONAL In the Court of COMMON PLEAS of ENTERPRISES CORP, D/B/A COYNE TEXTILE SERVICES Plaintiff Cumberland County v. NO, 00-2049 THE GENERAL CASTING CO. Defendant PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter as settled and discontinued with prejudice. TO Cumberland County Prothonotary Dated: March 8, 2001 Robert 0, Kodak Attorney 1.0. No. 18041 Attorney for Plaintiff -~....~ La. - -"IIiMI~~&iOJjitmlillliillffi~~1,;i.&~1'fuj~';h<&".."JMi!'lll~i "d.'^ 'I"m!l,h~,d~"","1~I. ~~~,. _~ ~,<- '"""'d,,," ".~ ~', ,~ ,. .,." .'"" 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