HomeMy WebLinkAbout03-0976Su Kyong Kang
3815 Carriage House Drive
Camp Hill, PA 17011
Plaintiff
Tae Woo Kim
1 West Glenwood Drive
Camp Hill, PA 17011
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOCKETNO. O3- '97(,, ~
CIVIL ACTION - IN EQUITY
RESCISSION OF CONTRACT
DAMAGES, INJUNCTION
NOTICE
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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
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do so the case may proceed without you and a judgment may be entered against you by the Court
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Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
249-3166
Su Kyong Kang
3815 Carriage House Drive
Camp Hill, PA 17011
Plaintiff
Ve
Tae Woo Kim
1 West Glenwood Drive
Camp Hill, PA 17011
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
· DocI T NO.
CIVIL ACTION - IN EQUITY
RESCISSION OF CONTRACT
DAMAGES, INJUNCTION
COMPLAINT
Plaintiff, Su Kyong Kang, by and through her attorney John H. Broujos, of Broujos and Gilroy,
P.C., avers the following:
1. Plaintiff is Su Kyong Kang, an adult individual residing at 3815 Carriage House Drive,
Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant is Tae Woo Klm, an adult individual residing at 1 West Glenwood Drive,
Camp Hill, Cumberland County, Pennsylvania 17011.
3. On August 31, 2002, in the County of Cumberland, Pennsylvania, the parties executed an
agreement prepared solely by Defendant entitled Sales Contract of Lee's Tailor (hereinai~er
referred to as Contract), attached hereto as Exhibit A and incorporated by reference.
4. Lee's Tailor shop is located at 32nd and Trindle Road in the Camp Hill Mall in Camp
Hill, Cumberland County Pennsylvania, 1701 I. The primary businesses of Lee's Tailor are the
alteration and tailor of men's clothing and retail sales of accessories of men's clothing.
5. Pursuant to the Contract Defendant agreed to sell the business of Lee's Tailor to Plaintiff
for the sum of Fifty-eight Thousand Dollars and zero cents ($58,000.00).
6. Initial down payments totaling Forty Thousand Dollars and zero cents ($40,000.00) were
made to Defendant from Plaintiff on or before August 31, 2002.
7. Beginning on October 21, 2002 the remainder of the Contract's price would be paid in
ten monthly installments of One Thousand Eight Hundred Dollars and zero cents ($1,800.00)
each.
8. Four monthly installments of One Thousand Eight Hundred Dollars and zero cents
($1,800.00) were made by Plaintiff to Defendant during the months of October, November, and
December of 2002 and January of 2003. The total installments paid thereby totaling Seven
Thousand Two Hundred Dollars and zero cents ($7,200.00).
9. In exchange for the total Contract price of Fifty-eight Thousand Dollars and zero cents
($58,000.00) Plaintiffpromised and contracted that Defendant would have the right to use the
present location of the business of Lee's Tailor, and to receive all business equipment, records,
and items necessary for continuing operation and management of Lee's Tailor.
10. In order to induce Plaintiff to purchase Lee's Tailor, Defendant falsely and fraudulently
represented to Plaintiff that she would make money and that everything she needed was there to
make the business profitable enough to pay both the $1,702.00 per month rent for the Camp Hill
Mall location and the $1,800.00 monthly installments to Defendant and still have net profits
remaining for Plaintiff.
11. At all times prior to and during the execution of the Contract, Plaintiff was denied a copy
of the lease with Mall and an opportunity to review timely and properly the lease securing the
business location of Lee's Tailor, including the end of the lease term.
12. On or about August 31, 2002, Plaintiff took possession of Lee's Tailor business location.
13. After taking possession, the only part of the former business of Defendant was equipment
remaining at the business location: two Singer sewing machines, one overlook machine, one
hemming machine, showcase, and miscellaneous threads and items.
14. At no time was any current or past customer information ever provided to Plaintiff by
Defendant.
15. At the time of the execution of the Contract Defendant was committed by the Contract to
a lease contract with Connecticut General Life Insurance Company that secures the location of
Lee's Tailor business in the Camp Hill Mall.
16. The lease between Defendant and Connecticut General Life Insurance Company (lease)
prohibits the assignment or sublease by a lessee of his or her lease contract.
30.
One.
31.
current lease and would not be guaranteed a new lease.
26. During the month of January there were indications, followed by insistence, from the
Lessor's mall manager, that during a reconstruction phase of the Camp Hill Mall the business
would have to move to another location.
27. The process of moving and other aspects of the reconstruction were detrimental to profits
of the business and moving costs to Plaintiff were substantial and are being calculated.
28. Defendant attempted to negotiate terms of moving and costs of relocation with Lessor's
mall manager; however, discussion on the matter was refused because Defendant was not
considered by Lessor as the owner of the business nor a lessee of the Camp Hill Mall. It was at
that time that Lessor first became aware that there had been a sale of the Lee's Tailor business
and an attempted assignment of the lease.
29. Upon Plaintiff showing the Lessor's mall manager the sales Contract the manager
became angry with Plaintiff and informed Defendant that the lease would be terminated.
FIRST CAUSE OF ACTION
(Breach of Contract)
Paragraphs 1 through 29 are incorporated as averments and made a part of this Count
Defendant promised a functioning and productive business in the sale of Lee's Tailor to
Plaintiff. The equipment lef~ at the business location was in poor condition and no customer
information was ever provided to Plaintiff.
32. Plaintiff was promised that the location of Lee's Tailor was secure at least through the
time of the natural expiration of the existing lease with the Lessor, the term of which was not
disclosed by Defendant, so long as Plaintiff abided by the terms of such lease.
33. Plaintiff was promised that she had a right to use the location of Lee's Tailor in the Camp
Hill Mall.
34. Defendant not only did not effect an assignment of the lease to Plaintiff and make good-
faith efforts to perform contractual obligations under the lease and under the law; he had no
intention of ever obtaining an assignment to Plaintiff.
35. Unknown to Plaintiff at the time of signing the Contract, the present location of
Plaintiff's tailor business is to be moved to another location.
36. When Defendant was advised of the movement, he failed to inform Plaintiff. Plaintiff
was given no legal oppommity to object or otherwise bargain for mitigation of or compensatory
damages from Lessor.
37. As a direct and proximate result of Defendant's breach of Contract, Plaintiff has suffered
direct and incidental damages in an amount not yet determined but to be submitted.
38. Defendant had a duty to provide the customer lists and/or invoices with names and
addresses as an incident of good will.
39. Defendant had reason to know customer lists are an essential part of the tailor business,
particularly when there was a five mile non-compete area.
40. Customarily, customer lists are an essential part of the tailor business.
WHEREFORE, Plaintiff prays this honorable Court enter a judgment against Defendant as
follows:
2.
3.
4.
5.
General damages according to proof at trial;
Special damages according to proof at trial;
Costs of suit;
Prejudgment interest and post-judgment interest according to law; and
Such other and further relief as the court may deem proper.
41.
Two.
42.
SECOND CAUSE OF ACTION
(Misrepresentation)
Paragraphs 1 through 40 are incorporated as averments and made a part of this Count
Prior to, during, and following the execution of the Contract Defendant made
representations to Plaintiff that she would have everything she needed for a tailor shop.
follows:
2.
3.
4.
5.
General damages according to proof at trial;
Special damages according to proof at trial;
Costs of suit;
Prejudgment interest and post-judgment interest according to law; and
Such other and further relief as the court may deem proper.
50.
Three.
51.
THIRD CAUSE OF ACTION
(Fraud)
Paragraphs 1 through 49 are incorporated as averments and made a part of this Count
In Plaintiff's purchase of Lee's Tailor Shop, she had reason to believe it would include a
way to reach established customers, all necessary equipment to operate the business, and the
security of a lease enabling the business to remain in its established location. Plaintiff had a right
to the above ingredients of a business sale.
52. The misrepresentations described above were all material to the inducement of Plaintiff
to give Fifty-eight Thousand dollars and zero cents ($58,000.00) in consideration of such
promises.
53. The representations described above regarding the assiglunent of the lease were false
when Defendant made them, and Defendant knew they were false in that the Defendant had full
knowledge that the lease securing the established location of the business was not assignable to
Plaintiff and his actions of attempting to conceal the sale of the business from the Lessor is
indicative of his knowledge of that fact.
54. The representations described above regarding the sale of all equipment necessary to
operate the business were false when Defendant made them, and Defendant knew they were false
in that the Defendant was aware of the poor condition of the equipment remaining at the business
location. Due to the useless condition of the equipment Plaintiff was immediately forced to
expend sums to replace equipment to enable her to operate the business.
55. The representations described above regarding the sale of an established business
location and customer base were false when Plaintiff made them, and Plaintiff knew they were
false in that the Plaintiff had knowledge of the planned renovations to Camp Hill Mall and the
future relocation of the business.
56. Defendant intended that Plaintiff rely on the representations and misrepresentations as
averred above.
57. Had Plaintiff known, or had any reason to know, that Defendant's representations were
false and the conditions were as averred above, Plaintiff would not have agreed to purchase the
business.
58. The aforementioned acts of Defendant were willful, malicious, and performed with
wanton disregard toward Plaintiff's fights and justify the awarding of damages and particularly
exemplary and punitive damages.
WHEREFORE, Plaintiff prays this honorable court enter a judgment against Defendant as
follows:
1. General damages according to proof at trial;
2. Special damages according to proof at trial;
3. Punitive and exemplary damages according to proof at trial;
4. Reasonable attorney fees;
5. Costs of suit;
6. Prejudgment interest and post-judgment interest according to law; and
7. Such other and further relief as the court may deem proper.
59.
FOURTH CAUSE OF ACTION
(Rescission)
Paragraphs 1 through 58 are incorporated as averments and made a part of this Count
Four.
60.
61.
The consent of Plaintiff to the Contract was obtained by fraud.
The Contract on which Plaintiff sues is void because it was procured by Defendant's
purposeful fraud by the misrepresentation, concealment of facts, and inducement material to the
Contract.
62. Representations made by Defendant prior to and at the time of execution of the Contract
are now, and were when made, false, and Defendant knew such to be false at the time he made
the representations.
63. Defendant made the aforementioned misrepresentations and concealed material facts
intending to induce Plaintiff into entering into the Contract to her detriment.
64. In so executing the Contract Plaintiffwas not aware of the falsity of the representations
made by Defendant and reasonably believed the representations to be true.
65. Defendant further induced Plaintiff to go along with the Contract terms by saying not to
worry, we are Koreans and we will work it out.
66. Defendant made the false representations to Plaintiff with the intent to take advantage of
the confidential relationship existing between Defendant and Plaintiff. The confidential
relationship existed fi'om the fact that Plaintiff and Defendant are both of the nationality of
Korean, and being such resulted in Plaintiffplacing her trust, faith, and confidence in the
representations and advice given to Plaintiff, an inexperienced business entrepreneur, by
Defendant, an experienced businessman, in the negotiations formulating the inducement and
execution of the Contract.
67. Upon discovering that representations made prior to, during, and following the execution
of the Contract were false and presented with malice and wanton disregard toward Plaintiff's
rights, Plaintiff did elect to rescind the Contract and notified Defendant of such in writing.
68. Plaintiffhas demanded that Defendant restore to Plaintiff the Forty-seven Thousand Two
Hundred Dollars and zero cents ($47,200.00) paid to date to Defendant, but Defendant refused,
and continues to refuse, to do so.
69. Damages are claimed based on net worth and the seriousness of the offenses committed
as set forth herein.
70. By reason of Defendant's actions Plaintiff has suffered damages in an amount not yet
fully ascertained, but that include:
A: Risk of denial of any insurance claims which could be denied since she was not a
legitimate lessee of the space.
B. Loss of the established business location - essential to the retention of past
customers, where major portions of the business profits were expected to come from. The
business location was even more essential after Defendant failed to provide past customer
information;
C. Rental payments made to Lessor ($1,702.00 x number of months paid).
WHEREFORE, with regard all causes of actions above, Plaintiff prays this honorable court enter
a judgment as follows:
1. Rescinding and setting aside the sales Contract for the purchase of Defendant's business
entitled Lee's Tailor;
2. Order Defendant to repay to Plaintiff all sums paid to Defendant by Plaintiff, that sum
being Forty-Seven Thousand Two Hundred Dollars and zero cents ($47,200.00), plus interest;
3. Order Defendant to pay to Plaintiff all sums paid by Plaintiff for rental insurance from
the date of August 31, 2002 to the date Plaintiffobtalned a legal lease securing the location of
her tailor business;
4. Order Defendant to pay to Plaintiff the costs of this action;
5. Order Defendant to pay to Plaintiff reasonable attorney fees with regard to this matter;
6. Order Defendant to pay to Plaintiff exemplary and punitive damages (Plaintiff is unable
at this point to make a specific demand. However, damages will be in an amount in excess of
that requiring compulsory arbitration.);
7. Award Plaintiff any other and further equitable and law relief that this court deems just
and proper.
Jury trial is demanded.
Joh~H. Bro/tijos, Attorney for~inti~
4 ~er Street
CarlisY6, PA 17013
717/243-4574; FAX 243-8227
PaBar 06268
I verify that the statements made in this pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
TO DEFENDANT:
NOTICE TO PLEAD
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ABOVE
PLEADING WITHIN 20 DAYS FROM THE DATE OF SERVICE HEREOF OR A
JUDGMENT MAY BE ENTERED AGAINST O~
gohn H.
roujos, Attorney fo]~ Plaintiff
SU KYONG KANG,
3815 Carriage House Drive
Camp Hill, PA 17011,
Plaintiff
VS.
TAE WOO KIM
1 West Glenwood Drive
Camp Hill, PA 17011
Defendant
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 03-976 EQUITY TERM
CIVIL ACTION - IN EQUITY
RESCISSION OF CONTRACT
DAMAGES, INJUNCTION
PRELIMINARY OBJECTIONS OF DEFENDANT
AND NOW comes the Defendant, Tae Woo Kim, by his attorney, Michael L. Bangs,
Esquire, and flies the following Preliminary Objections based upon the following:
1. The Plaintiff's Complaint fails to state a cause of action or fails to conform to law in
that it attempts to seek both equitable relief in the form of rescission under Count Four and
damages from breach of contract claims in Count One (Breach of Contract), Count Two
(Misrepresentation), and Count Three (Fraud). The attempt to seek both in this Complaint filed
in Equity violates the Doctrine of Election of Remedies.
2. Defendant demurs to the claim for the imposition of attorney's fees under Count Three
(Fraud) and Court Four (Rescission).
3. Defendant demurs to Plaintiff's request for punitive damages under Count Three
(Fraud) and Count Four (Rescission) in that punitive damages are not available under either of
these claims.
Re~ectfully submitted, /~f
MICHAEL L. BANG~ (~..~#.~.~F2~63)
Attorney for Defendant t~
302 South 18th Street, Camp Hill, PA 17011
(717) 730-7310
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing PRELIMINARY
OBJECTIONS by depositing a copy of same in the United States mail, postage prepaid, at Camp
Hill, Pennsylvania, addressed to the following:
John H. Broujos, Esquire
Broujos & Gilroy
4 North Hanover Street
Carlisle, PA 17013
WEND'I~ ~. CJ~BRiJ- -
Legal Assist~tit
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and subnitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please l i~t the within matter for the next ~t Court.
CAPTION OF CASE
(entir~ caption must be stated in ~,ll )
SU KYONG KANG
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
( Plaintiff )
TAE WOO KIM
( Defendant )
No. 03-976 Civil Equity Term ~ 2003
State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
d~dzzer to c~,~!~int, etc.): Defendant's Preliminary Objections to
Plaintiff's Complaint.
e
Identify counsel who w~]] argue case:
(a) for p]mintiff: John H. Broujos
~ldress: 4 N. Hanover Street, Carlisle, PA 17013
(b) for defendant:
~d~ess:
Michael L. Bangs
302 S. 18th Street, Camp Hill, PA 17011
3. I will notify~ll parties in writingwithin tw~days that th!m case has
been li~ted for argtm~_nt.
0
Ar~t Court Date: I am requesting the Court to set a special date for
argument prior to May 18 since I will be in Ireland May 18 to May 28.
SU KYONG KANG,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TAE WOO KlM,
DEFENDANT
03-0976 EQUITY TERM
ORDER OF COURT
AND NOW, this
day of April, 2003, argument on the within
preliminary objections of defendant to plaintiff's compliant is rescheduled from May 21,
2003 until 8:45 a.m., Monday, June 2, 2003, in Courtroom Number 2, Cumberland
County Courthouse, Carlisle, Pennsylvania.1
Edgar B. ~J~y-'~, (L~
,~lohn H. Broujos, Esquire
For Plaintiff
,,,'Michael L. Bangs, Esquire
For Defendant
Taryn Dixon, Court Administrator
:sa, ~.~~~
' The case was listed for the May 21st argument court before the May 1st cutoff
date.
SU KYONG KANG,
PLAINTIFF
TAE WOO KlM,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Michael L. Bangs, Esquire
For Defendant
John H. Broujos, Esquire
For Plaintiff
AND NOW, this
(1) Pursuant to Pa. Rule of Civil Procedure 1509(c), the causes of action at law
for breach of contract, misrepresentation and fraud in plaintiff's complaint, ARE
TRANSFERRED TO THE LAW SIDE OF THE COURT.
(2) All claims for attorney fees, ARE STRICKEN.
(3) The preliminary objection of defendant to plaintiff's claim for punitive
IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT TO
damages, IS DENIED.
PLAINTIFF'S COMPLAINT
ORDER OF COURT
day of July, 2003:
: 03-0976 EQUITY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
SU KYONG KANG, PLAINTIFF
V.
TAE WOO KlM,
DEFENDANT : 03-0976 EQUITY
IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT TO
PLAINTIFF'S COMPLAINT
OPINION AND ORDER OF COURT
Bayley, J., July 17, 2003:--
On March 4, 2003, plaintiff, Su Kyong Kang instituted this complaint in equity
against defendant Tae Woo Klm. Plaintiff avers that she entered into a written
agreement on August 31, 2002, to purchase defendant's tailoring business located in
Camp Hill, Cumberland County. Plaintiff alleges four causes of action against
defendant: (1) breach of contract, (2) misrepresentation, (3) fraud, and (4) rescission.
Defendant filed preliminary objections which includes, pursuant Pa. Rule of Civil
Procedure 1028(a)(2), an objection that the complaint fails to conform to law or rule of
court by combining the cause of action in equity for rescission with the three causes of
action at law for breach of contract, misrepresentation and fraud.
Plaintiff cites Pa. Rules of Civil Procedure 1020(c) and 1021 for the proposition
that the cause of action in equity for rescission can be combined with the causes of
action at law for breach of contract, misrepresentation and fraud. These rules covering
the pleading of alternative causes of actions and types of relief are not applicable to a
03-0976 EQUITY
suit in equity which is governed by Rule 1508 which provides, "The plaintiff may state in
the complaint two or more causes of action cognizable in equity." Equity actions may
not be joined with causes of action at law. City of Philadelphia v. Pennrose
Management Co., 142 Pa. Commw. 627 (1991), citing D'Allessandro v. Wassel, 526
Pa. 534 (1991); Lustig v. Lustig, 438 Pa. Super. 320 (1995); Adams v. Wolf, 49
Cumberland L.J. 279 (2000)?
In Baker v. Cambridge Chase, Inc., 725 A.2d 757 (Pa. Super. 1999), the
Superior Court of Pennsylvania stated:
Rescission is an equitable remedy, to be granted only where the
parties to a contract can be placed in their former positions with regard to
the subject matter of the contract. Sullivan v. Allegheny lord Truck Sales,
Inc., 283 Pa. Super. 351,423 A.2d 1292 (1980). It is well known that the
purpose of equitable rescission is to return the parties as nearly as
possible to their original positions where warranted by the circumstances
of the transaction. Gilmore v. Northeast Dodge Co., Inc., 278 Pa. Super.
209, 420 A.2d 504 507 (1980), citing Fichera v. Gording, 424 Pa. 404,
227 A.2d 642 (1967) (emphasis added).
Therefore, restitution often goes with rescission, and should not be
characterized as damages, as appellees attempt to do. in fact, this
precise issue is not new to this court. In Boyle v. Odell, 413 Pa. Super.
562, 605 A.2d 1260 (1992), a case involving a fraudulent conveyance of
real property but not involving the UTPCPL, we stated:
Assuming the trial court finds fraud by the defendant, or a breach of
contract as alleged by the plaintiffs in the first count of their
complaint, it clearly appears that the plaintiffs would have a right to
obtain a rescission of the transaction, as well as a recovery of
monies from the defendant.
As discussed, if it is determined that a purchaser in a real estate
transaction has suffered from fraud by the seller, even in the nature
of an innocent misrepresentation of a material fact, a right of
~ The Supreme Court of Pennsylvania has published proposed recommendation No.
180, which is a Proposed Consolidation of the Action in Equity with the Civil Action.
-2-
03-0976 EQUITY
rescission is established. Moreover, the purchaser is given the
election of remedies; he may seek to rescind the deed, or in
the alternative, may sue for damages. A plaintiff in these
circun~stances seeking rescission may not also seek
damages, as such remedies would be inconsistent. However,
in addition to granting equitable relief, in the nature of
rescission, the trial court is also empowered to grant the
plaintiffs restitution of appropriate losses incurred.
Restitution, unlike damages, is a remedy not inconsistent with
rescission. (Emphasis added.)
Pa. Rule of Civil Procedure 1509(c) allows a legal claim in equity to be certified
to the law side of the court. See Adams v. Wolf, supra. In Pennsylvania, the filing of
a cause of action at law for damages and a cause of action in equity for rescission,
which are inconsistent remedies, does not constitute a binding election of one remedy
over the other. Wedgwood Diner, Inc. v. Good, 368 Pa. Super. 480 (1987). Thus,
plaintiffs legal causes of action and his cause of action in equity for rescission can
coexist at this stage. Id. Therefore, we will order that the causes of action at law for
breach of contract, misrepresentation and fraud be transferred to the law side of the
court.
Defendant further preliminary objects to plaintiffs complaint to strike claims for
attorney fees and punitive damages. In her brief, plaintiff withdraws her request for
attorney fees. Our reading of the complaint is that the only claim for punitive damages
is in the cause of action for fraud? That pleading is adequate. See, McClellan v.
2 Punitive damages cannot be awarded in a cause of action for rescission.
Estate of Barbagallo, 366 Pa. Super. 599 (1987).
-3-
Roberts v.
03-0976 EQUITY
Health Maintenance Organization of Pennsylvania, 413 Pa. Super. 128 (1992).
ORDER OF COURT
AND NOW, this Iq~" day of July, 2003:
(1) Pursuant to Pa. Rule of Civil Procedure 1509(c), the causes of action at law
for breach of contract, misrepresentation and fraud in plaintiff's complaint, ARE
TRANSFERRED TO THE LAW SIDE OF THE COURT.
(2) All claims for attorney fees, ARE STRICKEN.
(3) The preliminary ~)bjection of defendant to plaintiffs claim for punitive
damages, IS DENIED.
Edgar B. Bayley, J. J
John H. Broujos, Esquire
For Plaintiff
Michael L. Bangs, Esquire
For Defendant
:sal
PROTHONOTARY FOR THE COUNTY OF
CUMBERLAND IN THE
COMMONWEALTH OF PENNSYLVANIA
c- C=,
IN RE:
6 :
rl
KANG, Su KYONG V. KIM TAE WOO (T7 C )
v dW
IN EQUITY r
2003-976 -? -
5
"_? 1.T.k
PRAECIPE TO WITHDRAW AS COUNSEL
TO THE PROTHONOTARY
PLEASE WITHDRAW MY APPEARANCE AS COUNSEL IN THE ABOVE-REFERENCED
MATTER SINCE I HAVE RETIRED FROM PRACTICE AND HAVE NOT BEEN
INVOLVED FOR SOME TIME.
DATE: 10-18-2011
-'
JotIN H. BROUJos
ATTORNEY ID #6268
4 NORTH HANOVER ST.
CARLISLE, PA. 17013
PHONE: 717-243-4574