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HomeMy WebLinkAbout07-06971 REAGER & ADLER, P.C. By: Thomas O. Williams, Esquire Attorney I.D. No. Email: Twilliams(u,)ReagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney I.D. No. 85520 Email: Rjo ce a, ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Plaintiff KERN & COMPANY, PC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. d? -' 104 ?l(J L? CAPITOL TUXEDO, INC., : Defendant Civil Action -Law NOTICE 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 is 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 Counterclaim 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de a notificacion de esta Demands y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Code por escrito sus defensas de, y objecciones a, las demandas presentadas aqua en contra suya. Se le advierte de que si usted falla de tomar accion como se describe antenormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reciamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Code sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE DUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS CUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS DUE CUALIFICAN. Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 1 • REAGER & ADLER, P.C. By: Thomas O. Williams, Esquire Attorney I.D. No. 67987 Email: Twilliams(a,ReagerAdlerPC.com By: Richard J. Joyce, Esquire Attorney I.D. No. 85520 Email: RjoyceL)ReagerAdlcrPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Plaintiff KERN & COMPANY, PC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0-Y - OT C t c? lrT CAPITOL TUXEDO, INC., Defendant Civil Action -Law COMPLAINT 1. The Plaintiff is Kern & Company, PC (hereinafter "Kern"), a professional corporation incorporated and doing business under the laws of the Commonwealth of Pennsylvania, with its principal place of business located at 2331 Market Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Capitol Tuxedo, Inc. (hereinafter "Capitol"), a corporation incorporated and doing business under the laws of the Commonwealth of Pennsylvania, with its principal office located at 5517 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania, 17050. At all times relevant to this Complaint, Kern is an accounting firm which provides accounting and business advisory services. COUNT I - Breach of Contract 4. On or about June of 2005 through September 2006, Capitol requested Kern to perform professional accounting services. In exchange for performing the requested professional accounting services, Capitol agreed to pay Kern in accordance with Kern's usual and customary charges and rates for those services. Kern completed all of the services requested by Capitol in a professional, efficient and satisfactory manner, and all services were accepted by Capitol. 6. During the course of its work, Kern submitted invoices to Capitol. True and correct copies of Kern's aforesaid invoices describing the accounting services performed and the charges therefore are attached hereto and incorporated herein by reference at Exhibit "A". 7. Despite demand by Kern that Capitol pay all of the charges for the services as outlined in Kern's invoices, and despite promises by Capitol's President, Ronald Kaplan, that Capitol would pay all invoices, Capitol has failed and refused to pay all the charges. 8. As of Kern's invoice of December 31, 2006, Capitol owed Kern a balance of $21,749.11. 9. Capitol's failure and refusal to pay Kern's invoices in full constitutes a breach of contract. 10. Capitol has never advised Kern that it disputed any of the charges set forth in the invoices submitted by Kern to Capitol. 11. As a result of Capitol's breach of contract, Kern has suffered damages in the amount of $21,749.11 as of December 31, 2006. 12. All conditions precedent for the bringing of this action have occurred and/or have been performed. WHEREFORE, Plaintiff, Kern & Company, PC, respectfully requests this Honorable Court to enter judgment in its favor and against Defendant, Capitol Tuxedo, Inc., in the amount of $21,749.11, plus costs and interest. COUNT II - Account Stated 13. Plaintiff incorporates herein by reference the averments of Paragraphs 1 through N 12 above as if set forth fully herein. 14. At Capitol's specific request, Kern provided accounting services as more fully described in the invoices attached hereto and made a part hereof and marked as Exhibit "A". Copies of these invoices were delivered to Capitol. 15. The accounting services were provided on the dates and for the charges set forth in Exhibit "A". 16. The prices charged in Exhibit "A" by Kern are correct, just and reasonable, and are the usual market prices for the services rendered to Capitol, and further are the prices which Capitol agreed to pay. 17. Capitol has received all credits to which Capitol is entitled. 18. Capitol is indebted to Kern in the amount of $21,749.11. 19. Although Kern has often demanded payment of the sum in question, Capitol refuses to pay. Capitol has never questioned the invoices, nor denied that it owes the amounts set forth therein. WHEREFORE, Plaintiff, Kern & Company, PC, respectfully requests this honorable Court to enter judgment in its favor and against Defendant, Capitol Tuxedo, Inc., in the amount of $21,749.11, plus interest and costs. February o? , 2007 Thbmas O. Williams, Esqu Attorney I.D. No. 67987 Richard J. Joyce, Esquire Attorney I.D. No. 85520 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff 00198 CapiVl Tuxedo, Inc. 07/15/05 Standard Bill 7619 437 .50 07/31/05 Standard Bill 7641 3967 .00 • 07/31/05 Finance Charge 90 .49 08/15/05 Standard Bill 7675 075 .00 08/31/05 Finance Charge 126 .87 09/30/05 Finance Charge 125 .62 10/31/05 Finance Charge 125 .62 11/30/05 Finance Charge 125 .62 12/31/05 Finance Charge 105 .62 01/31/06 Finance Charge 105 .62 02/28/06 Finance Charge 95 .62 03/31/06 Finance Charge 95 .62 03/31/06 Standard Bill 8153 2811 .50 09/15/06 Standard Bill 8296 795 .00 04/30/06 Finance Charge 95 .62 09/30/06 Standard Bill 8451 257 .50 05/31/06 Finance Charge 124 .62 06/30/06 Finance Charge 114 .62 07/31/06 Finance Charge 87 .24 08/15/06 Standard Bill 8671 4338 .00 08/31/06 Finance Charge 87 .24 08/31/06 Standard Bill 8704 2286 .00 09/15/06 Standard Bill 8724 3475 .00 09/30/06 Finance Charge 130 .62 09/30/06 Standard Bill 8750 703 .50 10/31/06 Finance Charge 195 .27 11/30/06 Finance Charge 195 .27 12/31/06 Finance Charge 195 .27 00198 Totals 18.14 3967.00 90.49 875.00 126.87 125.62 125.62 125.62 105.62 105.62 95.62 95.62 2811.50 795.00 95.62 257.50 124.62 114.62 87.24 4338.00 87.24 22B6.00 3475.00 130.62 703.50 195.27 195.27 195.27 0.00 195.27 195.27 195.27 4309.12 16854.18 21749.11 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 41 717763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS kern@ponetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 July 15, 2005 Page 1 Billing Statement For Professional Services Rendered: For services rendered regarding the compiling of financial statements for the year ended December 31, 2004. 437.50 Total Current Charges 4 0 Beginning Balance 101,580.64 Payments Received 1,000.00- Current Bill Amount 437.50 Amount Due This Bill $101018.14 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 530.85 103.49 772.71. 4,079.46 4,531.63 Total A/R 10,018.14 Terms: Net 30 days. Interest 1% per month on balance over 30 days. 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS 40 kern@ponetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 July 31, 2005 Page 1 Billing Statement For Professional Services Rendered: For the completion of compiled financial statements for the year ended December 31, 2004. 3,967.00 Total Current Charges Beginning Balance No Payments Received This Period Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 0-30 Days 31-60 Days 61-90 Days 91-120 Days 4,494.99 93.35 103.49 3,954.21 3,967.00 10,018.14 0.00 90.49 3,967.00 $14,075.63 > 120 Days Total A/R 5,429.59 14,075.63 Terms: Net 30 days. Interest 1% per month on balance over 30 days. R 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC ACCOUNTANTS AND BUSINESS ADVISORS 717.763.1581 FAX kern@Ponetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 August 15, 2005 Billing Statement Page 1 For Professional Services Rendered: For the revision of financial statements as of December 31, 2004. 875.00 Total Current Charges 875.00 Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 4,932.49 530.85 103.49 772.71 8,611.09 14,075.63 0.00 875.00 $14,950.63 Total A/R 14 , 950.63 Terms: Net 30 days. Interest 1% per month on balance over 30 days. 11 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX -i-i t1 ;, T;1 N ArJp RI.i CI NfS'. ,. ','i . C., r , kern@ponetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 August 31, 2005 Billing Statement For Professional Services Rendered: No Charges This Period Beginning Balance Payments Received Service Charge on Unpaid Balan Current Bill Amount Amount Due This Bill Page 1 0.00 14,950.63 1,000.00- 126.87 0.00 $14,077.50 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 1,001.87 4,494.99 93.35 103.49 8,383.80 14,077.50 Terms: Net 30 days. Interest 1% per month on balance over 30 days. >, 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS 10 kern@panetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 September 15, 2005 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period loft wlmk 0.00 Is WS Beginning Balance 14,077.50 No Payments Received This Period 0.00 Current Bill Amount 0.00 Amount Due This Bill $14,077.50 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 126.87 4,932.49 530.85 103.49 8,383.80 14,077.50 Terms: Net 30 days. Interest 1% per month on balance over 30 days. x 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS kern@ponetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 September 30, 2005 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period Beginning Balance Payments Received Service Charge on Unpaid B Current Bill Amount Amount Due This Bill 0.00 14,077.50 1,000.00- 125.62 0.00 $13,203.12 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 252.49 875.00 4,494.99 93.35 7,487.29 13,203.12 Terms: Net 30 days. Interest 1% per month on balance over 30 days. I Adh KERN AND COMPANY, PC ACC OU N1-ANTS AND P, U SINES', ADVISORS IV Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 October 15, 2005 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern @ panetwork. coni Page 1 For Professional Services Rend r No Charges This Period Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill 0.00 13,203.12 0.00 0.00 $13,203.12 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 125.62 126.87 4,932.49 530.85 7,487.29 13,203.12 Billing Statement Terms: Net 30 days. Interest 1% per month on balance over 30 days. L 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS kern@panetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 October 31, 2005 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period IR's Beginning Balance No Payments Received This Per Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 0.00 13,203.12 0.00 125.62 0.00 $13,328.74 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 125.62 125.62 1,001.87 4,494.99 7,580.64 13,328.74 Terms: Net 30 days. Interest 1% per month on balance over 30 days. a 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX A:"000NTANTS AND BUSINESS ADVISORS 41 kern@panetworkcom Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 November 15, 2005 Page 1 Billing Statement For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This Perio Current Bill Amount Amount Due This Bill 0.00 13,328.74 0.00 0.00 $13,328.74 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 125.62 125.62 126.87 4,932.49 8,018.14 13,328.74 Terms: Net 30 days. Interest 1% per month on balance over 30 days. A 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS kern@pane t work. corn Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 November 30, 2005 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This P Service Charge on Unpaid Bal nce Current Bill Amount Amount Due This Bill 0.00 13,328.74 0.00 125.62 0.00 $13,454.36 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 251.24 0.00 125.62 1,001.87 12,075.63 13,454.36 Terms: Net 30 days. Interest 1% per month on balance over 30 days. 2331 Market Street Camp Hill, PA 17011 lAddftkl 717.763.0888 TEL KERN AND COMPANY, PC 717763.1581 FAX '•'"`?kern @patietwori-.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 December 15, 2005 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period 0.00 Beginning Balance 13,454.36 Payments Received 2,000.00- Current Bill Amount 0.00 Amount Due This Bill: $11,454.36 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 125.62 125.62 125.62 126.87 10,950.63 Total A/R 11,454.36 Terms: Net 30 days. Interest 1% per month on balance oN er 30 days. t 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS kern@ponetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 December 31, 2005 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period 0.00 Beginning Balance ,4 » 11, 454.36 No Payments Received Thisi 0.00 Service Charge on Unpaid..eT`" 105.62 Current Bill Amount 0.00 Amount Due This Bill $11,559.98 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 105.62 125.62 125.62 125.62 11,077.50 11,559.98 Terms: Net 30 days. Interest 1% per month on balance over 30 days. x 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS kern@panetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 January 15, 2006 Page 1 Billing Statement For Professional Services Rendered: No Charges This Period , Beginning Balance No Payments Received This Pe od Current Bill Amount Amount Due This Bill 0.00 11,559.98 0.00 0.00 $11,559.98 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 105.62 125.62 125.62 125.62 11,077.50 11,559.98 Terms: Net 30 days. Interest 1% per month on balance over 30 days. 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS 40 kern@panetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 January 31, 2006 Page 1 Billing Statement For Professional Services Rendered: No Charges This Period 0.00 Beginning Balance 11,559.98 No Payments Received This Period 0.00 Service Charge on Unpaid Balance 105.62 Current Bill Amount 0.00 Amount Due This Bill $11,665.60 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 105.62 105.62 125.62 125.62 11,203.12 11,665.60 Terms: Net 30 days. Interest 1% per month on balance over 30 days. t 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 41 717.763.1581 FAX ACCOUNTANTS AND BUSINESS ADVISORS kern@panetwark.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 February 15, 2006 Page 1 Billing Statement For Professional Services Rendered: No Charges This Period 0.00 Beginning Balance 11,665.60 Payments Received 1,000.00- Current Bill Amount 0.00 Amount Due This Bill $10,665.60 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 105.62 105.62 125.62 125.62 10,203.12 10,665.60 Terms: Net 30 days. Interest 1% per month on balance over 30 days. t 2331 Market Street Camp Hill, RA 17011 717763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND 6USiNESS ADVISORS kern @panei work. corn Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 February 28, 2006 Page 1 Billing Statement For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This Service Charge on Unpaid 9U91 Current Bill Amount Amount Due This Bill 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 10,761.22 0.00 0.00 0.00 0.00 0.00 10,665.60 0.00 95.62 0.00 $10,761.22 Total A/R 10,761.22 Terms: Net 30 days. Interest I% per month on balance over 30 days. 2331 Market Street Camp Hill, PA 17011 A&L 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND 13USINESS ADVISORS wil kern@panetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 March 15, 2006 Billing Statement Page 1 For Professional Services Rendere - No Charges This Period Ak. Iff Beginning Balance No Payments Received Thi riod Current Bill Amount Amount Due This Bill 0.00 10,761.22 0.00 0.00 $10,761.22 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 95.62 105.62 105.62 125.62 10,328.74 10,761.22 Terms: Net 30 days. Interest 1% per month on balance over 30 days. t KERN AND COMPANY, PC ACCOUNTANTS AND BUSINESS ADVISORS Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 March 31, 2006 Billing Statement For Professional Services Rendered: For services to date regarding the preparation of corporate income tax returns for 2005. Total Current Charges Beginning Balance No Payments Received This Period Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@panetwork.com Page 1 2,811.50 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 2,907.12 201.24 105.62 0.00 10,454.36 2,811.50 10,761.22 0.00 95.62 2,811.50 $13,668.34 Total A/R 13,668.34 Terms: Net 30 days. Interest 1% per month on balance over 30 days. KERN AND COMPANY, PC AC( O".lni-"..N I IS 1,, I- .. 1. E ? ADVISORS 9.1 Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 April 15, 2006 Billing Statement For Professional Services Rendered: For services to date regarding the preparation of corporate tax returns for 2005. For the preparation of federal, state, and local tax returns for 2005_ Total Current Charges Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill $14,463.34 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 3,702.12 95.62 105.62 105.62 10,454.36 14,463.34 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@panetwork.com Page 1 324.00 471.00 795.00 13,668.34 0.00 795.00 Terms: Net 30 days. Interest 1% per month on balance over 30 days. 2331 Market Street Camp Hill, PA 17011 KERN AND COMPANY, PC 717.763.0888 TEL A r ) u N' r, 1 :. 717.763.15 81 FAX kern @ pone t work. c oni Capitol Tuxedo, Inc_ Mr_ Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 April 30, 2006 Billing Statement Page 1 For Professional Services Rendered: For the preparation of extensions for federal, state, and local income tax returns for 2005. 257.50 Total Current Charges 257.50 Beginning Balance 14,463.34 No Payments Received This Period Service Charge on Unpaid Balance 0.00 Current Bill Amount A 95.62 Gur 257 _ 50 Amount Due This Bill $14,816.46 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 4,055.24 0.00 201.24 105.62 10,454.36 14,816.46 Terms: Net 30 days. Interest 1% per month on balance over 30 days. t 2331 Market Street Camp Hill. PA 17011 717.763.0888 TEL Aft KERN AND COMPANY, PC 717.763.1581 FAX kern@ponetwork.com Capitol Tuxedo, Inc_ Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 May 15, 2006 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period 0.00 Beginning Balance 0%0?1 14,816.46 Payments Received 1,000.00- Current Bill Amount 0.00 Amount Due This Bill $13,816.46 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 1,148.12 2,907.12 95.62 105.62 9,559.98 13,816.46 Terms: Net 30 days. Interest 1% per month on balance over 30 days. 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX 1C ;-C!;N 7.. ^! TS A.NC 3t151N[S? ADV IS OR>. kern@ponetwork.com Capitol Tuxedo, Inc_ Mr_ Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 May 31, 2006 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This P Service Charge on Unpaid e Current Bill Amount Amount Due This Bill 0.00 13,816.46 0.00 124 .62 0.00 $13,941.08 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 124.62 1,148.12 2,907.12 201.24 9,559.98 13,941.08 Terms: Net 30 days. Interest 1% per month on balance over 30 days. i 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC Al C011NTA N TS AND RU S.N ESS ^DNIS Ct^.S >r 717.763.1581 FAX f f kern@panetwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 June 15, 2006 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period 0.00 Beginning Balance ' 13,941.08 Payments Received Ail .0 1,000.00- Current Bill Amount y 0.00 Amount Due This Bill $12,941.08 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 124.62 353.12 3,702.12 95.62 8,665.60 Total A/R 12,941.08 Terms: Net 30 days. Interest 1% per month on balance over 30 days. k 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX kern@ponetwork.com Capitol Tuxedo, Inc. Mr_ Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 June 30, 2006 For Professional Services Re No Charges This Period Beginning Balance No Payments Received This Period Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill atement Page 1 0.00 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 239.24 0.00 1,148.12 2,907.12 8,761.22 12,941.08 0.00 114 .62 0.00 $13,055.70 Total A/R 13,055.70 Terms: Net 30 davs. Interest 1% per month on balance over 30 days. t KERN AND COMPANY, PC Capitol Tuxedo, Inc. Mr_ Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 July 15, 2006 u w Billing Statement F'or Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717763.1581 FAX kerr4 pone twork. corn Page 1 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 114.62 124.62 353.12 3,702.12 8,761.22 0.00 13,055.70 0.00 0.00 $13,055.70 Total A/R 13,055.70 Terms: Net 30 days. Interest 1% per month on balance over 30 days. X AWL KERN AND COMPANY, PC I S .; -P I Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 July 31, 2006 Billing Statement 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern @pone (work, corn Page 1 For Professional Services Rendered: No Charges This Period Beginning Balance Payments Received Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 0.00 13,055.70 3,000.00- 87.24 0.00 $10,142.94 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 87.24 114.62 124.62 1,148.12 8,668.34 10,142.94 Terms: Net 30 days. Interest 1% per month on balance over 30 days. KERN AND COMPANY, PC Am-. Ar ...; 1 ... i Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 August 15, 2006 Billing Statement For Professional Services Rendered: For services to date regarding the preparation of corporate income tax returns for 2005. Services to date regarding the compiling of financial statements for the year ended December 31, 2005. Total Current Charges Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@panetwork.com Page 1 344.00 3,994.00 4,338.00 10, 142 .94 0.00 4,338.00 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 4,425.24 114.62 124.62 353.12 9,463.34 $14,480.94 Total A/R 14,480.94 Terms: Net 30 days. Interest 1% per month on balance over 30 days. it 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC 717.763.1581 FAX ACCOUNTANTS AND GU ;INESS ADV!S O KS kern@ponet work. corn Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 a let August 31, 2006 Billing Statement Page 1 For Professional Services Rendered: For the compiling of financial statements for the year ended December 31, 2005. 2,286.00 Total Current Charges Beginning Balance No Payments Received This Period Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 6,711.24 87.24 114.62 124.62 9,816.46 2,286.00 14,480.94 0.00 87.24 2,286.00 $16,854.18 Total A/R 16,854.18 Terms: Net 30 days. Interest 1% per month on balance over 30 days. c KERN AND COMPANY, PC Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 September 15, 2006 1A 1 ' r Billing Statement 2331 Market Street Camp Hill. PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@panetwork.com Page 1 For Professional Services Rendered: For services to date regarding the compiling of financial statements for the year ended December 31, 2005. Total Current Charges Beginning Balance No Payments Received This Period Current Bill Amount_ Amount Due This Bill 0-30 Days 31-60 Days 61-90 Days 91-120 Days 5,848.24 4,425.24 114.62 124.62 Terms: Net 30 days. Interest 1% per month on balance over 30 days. 3,475.00 3,475.00 16,854.18 0.00 3,475.00 $20,329.18 > 120 Days Total A/R 9,816.46 20,329.18 t 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC %•. c_<.i??_1 ^.; 1.'. r:l; nND ;iu SiN?`:S :?D l'IS O PS 717.763.1581 FAX kern @panetwork, con, Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 September 30, 2006 For Professional Services Rerred: 703.50 Page 1 For the completion of federal, state, and local tax returns for 2005_ 276.50 For the completion of compiled financial statements for 2005. 427.00 Total Current Charges Beginning Balance No Payments Received This Period Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 0-30 Days 31-60 Days 61-90 Days 6,682.36 4,338.00 87.24 Statement 20,329.18 0.00 130.62 703.50 $21,163.30 91-120 Days > 120 Days Total A/R 114.62 9,941.08 21,163.30 Terms: Net 30 days. Interest 1% per month on balance over 30 days. KERN AND COMPANY, PC ACCC)UNI ^tJ'> . Np FM!. IN; 11S ADVP,ORS Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 October 15, 2006 Billing Statement l?rry 2 For Professional Services Render';' ` No Charges This Period v Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern @po network. corn Page 1 0.00 21,163.30 0.00 0.00 $21,163.30 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 4,309.12 2,373.24 4,425.24 114.62 9,941.08 Total A/R 21,163.30 Terms: Net 30 days. Interest 1% per month on balance over 30 days. R 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL KERN AND COMPANY, PC A r i 0 I t,rt r; 717.7631581 FAX ke-@parelwork.com Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 October_ 31, 2006 Billing Statement Page 1 For Professional Services Rendered: No Charges This Period 0.00 Beginning Balance 21,163.30 No Payments Received This Period 0.00 Service Charge on Unpaid Balance 195.27 Current Bill Amount 0.00 Amount Due This Bill $21358.57 , .? 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 195.27 4,309.12 6,711.24 87.24 10,055.70 Total A/R 21,358.57 Terms: Net 30 days. Interest 1% per month on balance over 30 days. a` KERN AND COMPANY, PC ACCOUNTANTS AND BUSINESS ADVISORS Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 November 15, 2006 coQ'? Billing Statement For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@panetwork.com Page 1 0.00 21,358.57 0.00 0.00 $21,358.57 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 195.27 834.12 5,848.24 4,425.24 10,055.70 21,358.57 Terms: Net 30 days. Interest 1% per month on balance over 30 days. f KERN AND COMPANY, PC +,(. t_O U N I A NTS AND i'U SIN ES ADVISOR , Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 November 30, 2006 %%A Billing Statement 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@ponetwork.com Page 1 For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This Period Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 0.00 21,358.57 0.00 195.27 0.00 $21,553.84 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 390.54 0.00 4,309.12 6,711.24 10,142.94 21,553.84 Terms: Net 30 days. Interest t% per month on balance over 30 days. KERN AND COMPANY, PC Capitol Tuxedo, Inc. Mr. Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 December 15, 2006 Billing Statement For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This Period Current Bill Amount Amount Due This Bill COPY 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@panetwork.com Page 1 0.00 21,553.84 0.00 0.00 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days 195.27 195.27 834.12 5,848.24 14,480.94 $21,553.84 Total A/R 21,553.84 Terms: Net 30 days. Interest 1% per month on balance over 30 days. • KERN AND COMPANY, PC ACCOUNTANTS AND PUSINFSS ADVISORS Capitol Tuxedo, Inc. Mr_ Ron Kaplan 5517 Carlisle Pike Mechanicsburg, PA 17050 December 31, 2006 Billing Statement For Professional Services Rendered: No Charges This Period Beginning Balance No Payments Received This Period Service Charge on Unpaid Balance Current Bill Amount Amount Due This Bill 2331 Market Street Camp Hill, PA 17011 717.763.0888 TEL 717.763.1581 FAX kern@ponetwork.com e4p 4r Page 1 0.00 21, 553 . 84 0.00 195.27 0.00 $21,749.11 0-30 Days 31-60 Days 61-90 Days 91-120 Days > 120 Days Total A/R 195.27 195.27 195.27 4,309.12 16,854.18 21,749.11 Terms: Net 30 days- Interest 1% per month on balance over 30 days. VERIFICATION 6A.#iR "-f a 4 G,Co I, Charles L. Kern, hereby verify that I am Pfesi&rri of Kern & Company, PC., and, as such, I am authorized to verify the averments of the foregoing document are true and correct to my personal 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. Date: a - / - 0 7 By: oC `?6 Charles L. Kern, Pfesident- CA41 --.1110 aCGG V O V t4L Cl) cr, O C?1 t _^ f\t r.3 ca c.? Gil Lei mss= f- ? 'Sl -a l"J CASE NO: 2007-00697 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KERN & COMPANY PC VS CAPITOL TUXEDO INC R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CAPITOL TUXEDO INC but was unable to locate Them in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT 5517 CARLISLE PIKE NOT FOUND , as to CAPITOL TUXEDO INC MECHANICSBURG, PA 17050 OUT OF BUSINESS SIGN ON DOOR. IN BANKRUPTCY. Sheriff's Costs: So answer ..-??,---- Docketing 18.00 Service 12.32 ' Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Postage .39 45.71 REAGER & ADLER i5 I 02/12/2007 Sworn and Subscribed to before me this day of , SHERIFF'S RETURN - NOT FOUND A. D. Anthony T. McBeth, Esquire 407 North Front Street Harrisburg, PA 17101 (717) 238-3686 Attorney for Plaintiff SANDRA CADO, Plaintiff, V. JEROME J. RAHM, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-0697-Civil Term CIVIL ACTION - LAW CUSTODY COUNSEL'S MOTION FOR ADOPTION OF STIPULATION AS ORDER OF COURT 1. Attached hereto and marked Exhibit "A" is a written stipulation into which the Parties have entered with respect to the custody of their daughter, Toriana J. L. Rahm, born September 12, 2001. 2. The Parties believe that the attached stipulation represents the custody arrangement that best promotes the best interests of and the permanent welfare of Torianna J. L. Rahm. 3. As such, the undersigned on behalf of the Parties, respectfully requests that the Court enter an Order adopting the Parties' Stipulation as its order of Court. WHEREFORE, the undersigned requests that this Honorable Court enter an Order adopting the Parties' Stipulation as described above, and to provide any other relief the Court deems appropriate. aAntfiony T. Mc e )ti At torney for P in407 North Fron t., First Floor Harrisburg, PA 17101 (717) 238-3686 Supreme Court I.D. # 53729 4 STIPULATION BY AND BETWEEN JEROME RAHM FATHER AND SANDRA CADO, MOTHER, WITH RESPECT TO THE CUSTODY OF THEIR DAUGHTER, TORIANA J.L. RAHM, BORN SEPTEMBER 12 2001 WHEREAS, the Parties to this Stipulation are the parents of, Toriana J.L. Rahm born September 12, 2001 and WHEREAS, the Parties desire to settle the pending petition for modification filed in Cumberland County Action Number 2007-679, wherein Jerome Rahm seeks a modification of the order presently in force under that action and WHEREAS, the Parties have agreed to a custody arrangement that they believe and represent to be in the best interests and permanent welfare of Toriana J.L. Rahm, THE PARTIES HEREBY STIPULATE AS FOLLOWS: I. The prior Orders of this Court dated March 26, 2007 and August 21, 2008 shall be vacated and replaced with this Order. 2. The Mother, Sandra Cado, and the Father, Jerome Rahm, shall share having legal custody of Toriana J. L, Rahm, born September 12, 2001. Major decisions concerning the Child, including but not necessarily limited to, her health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither Party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated 1DIT "A!r thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. The parties shall have physical custody of the child as follows: A. School Year: During the school year, the Father shall have custody of the Child on three (3) out of every four (4) weekends from Friday after work, between 5:00 p.m. and 5:30 p.m.,through Sunday at 7:00 p.m. The fourth (4`h) weekend, which shall be the Mother's weekend period of custody, shall be scheduled to coincide with the weekend on which the Father has to work. 2. During every week, the Father shall have custody of the Child on Wednesdays and Thursdays from after work, between 5:00 p.m. and 5:30 p.m. until 7:15 p.m. The Father shall ensure that the Child has completed her homework during his period of weekday evening custody. The Father's period of weekday evening custody may be expanded to overnight if agreed between the parties. B. Summer School Break: 1. During the summer school break each year, the parties shall share having custody of the Child on an alternating weekly basis, with the exchange to take place every week on Monday at 5:30 p.m. Unless otherwise agreed between the parties, the summer custody schedule shall begin on the first Monday following the end of the school year with the Father having custody of the Child. Unless otherwise agreed between the parties, the summer custody schedule shall end each year at least one week prior to the first day of school, with the Mother having custody of the Child. C. After following the summer custody schedule for at least one (1) month in 2009, the parties shall cooperate in assessing whether a more shared custody schedule during the school year would be in the Child's best interests in light of the experience on the alternating weekly schedule. The parties agree to initiate discussions concerning possible adjustments to the school year schedule in sufficient time to have the issue resolved prior to the beginning of the 2009-2010 school year. 4. The parties shall share having custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided in to Segment A, which shall include all of Christmas Eve day through Christmas Eve in the evening, and Segment B, which shall run from Christmas Eve in the evening through Christmas Day. In even-numbered years, the Mother shall have custody of the Child during Segment A and the Father shall have custody of the Child during Segment B. In odd-numbered years, the Father shall have custody of the Child during Segment A and the Mother shall have custody during Segment B. The specific time for exchanges of custody shall be arranged by agreement between the parties. B. Thanks iving: In even-numbered years, the Mother shall have custody of the Child for Thanksgiving Day and in odd-numbered years, the Father shall have custody of the Child for Thanksgiving Day, with the specific times for exchanges to be arranged by agreement between the parties. C. Mother's Day/ Father's DU: In every year, the Mother shall have custody of the Child for Mother's Day and the Father shall have custody of the Child for Father's Day, with the specific times for exchanges of custody to be arranged by agreement between the parties. D. The holiday custody schedule shall take precedence over the regular custody schedule. Each party shall be entitled to have vacation custody with the Child each year, which shall be scheduled during the his or her alternating weeks of custody unless otherwise arranged by agreement. 6. Unless otherwise agreed between the parties, the parent receiving the custody of the Child shall be responsible to provide transportation for the exchange of custody. 7. Both parents shall promptly ensure that the other parent has all medical/dental insurance coverage information, cards or copies thereof or any other essential information pertaining to the Child's insurance coverage. 8. The parties shall cooperate in obtaining and sharing medical/dental information concerning the Child's care and treatment. Each party shall notify the other on the same day that he or she makes a medical or dental appointment for the Child. 9. The parties specifically desire that this stipulation be adopted as and made an order ofthe Cumberland County, Pennsylvania Court ofCommon Pleas in the case known as Sandra Cado v. Jerome J. Rahm, II, Cumberland County No. 2007-679. 10. The parties acknowledge that each has been represented by counsel (Jerome Rahm represented by Thomas D. Gould, Esquire and Sandra Cado represented by Anthony T. McBeth, Esquire) and that the parties have consulted with their respective counsel to the parties' satisfaction with respect to the parties' entry into this stipulation. Date VJo J. Ra 3 Date andra Cado COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this, the Ct day of ? Q I" , 200 before me, the undersigned officer, personally appeared JEROME RAHM, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. Notary p eNWEALTN OF PENNSYLVANIA Nollerlel Sal My Commission Expires: Lads M. G ould. Notary Public LowerANen Twp., Cumberland County Com MO" Expires M2 29, 2012 Member, PennaylveMe Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF ?t?lv SS. On this, the a day o , 200 before me, the undersigned officer, personally appeared SANDRA CADO, kn!!nrr e (o r satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purpose therein contained. IN WITNESS WHEREOF, I have h*oary my ha tarial seal. ublic MyCommission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Melissa S. Myers, Notary Public City Of Harrisburg. Dauphin County My Commission Expires June 11, 2011 Momber, Pennsylvania Association of Notaries C3 r`' C ril cry navid'(D. Bue(( Prothonotary y,irkS. Sohonage, ESQ Solicitor _F Ci. 77SO &nee X. Simpson i 1st Deputy Prothonotary +i Irene E. 9YOrrow 2nd Deputy Prothonotary Office of the Prothonotary Cumber(and County, Pennsy(vania ny_ Jg of. CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 30TH DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P. 230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 * Carlisle, PA 17013 0 (717 240-6195 • Fax (717) 240-6573