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Home My WebLink About03-3513IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff : No. 03 --J~ VS, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant : CIVIL ACTION PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s), pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a judgement entered September 13, 2002 against the above-named defendant(s) before Philadelphia Municipal Court, as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount Post Judgment Interest (from September 13, 2002 to April 30, 2003 at 6% per annum) Payments 4,053.41 152.62 0.00 Total $4,206.03 Dated: April 30, 2003 2021817 AMATO AND MARGLE, P.C. ~ By: ~ Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS, DONALD E. FARNER JR. i/Ua THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant : NO. : CIVIL ACTION CERTIFICATION OF ADDRESSES do certify that the precise last known address of the within named plaintiff is: 2560 Renaissance Blvd. KING OF PRSA,PA 19406 do certify that the precise last known address of the within named defendant is: 216 West Shady Lane ENOLA PA 17025-2237 AMATO AND MARGLE, P.C.~--~ Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant(s) : CIVIL ACTION AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF NORTHAMPTON: The undersigned, being duly sworn, according to law, deposes and says that the Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers and Sailor' Civil Relief Act of Congress of 1940 as amended; That Donald E. Farner, Jr. is over 18 years of age, resides at 216 West Shady Lane, ENOLA PA 17025-2237 and is employed as the Wood Pros, Inc. Sworn to and subscribed before me this ~ day of ~c~% 2003 A.D. NOTARY P-~UBLIC NOTARIAL SEAL (~EOFFR EY O SCI~Oi~i~"~ Notnw Ptthlic HANOYE. R T()WN.~IHI~ NOI.[ rHAMPTON ~ Commission Expires M=r 29, 20~ COMMONWEALTH OF PENNSTLVANIA COUNTY OF PHIL~DEL?H[A PHIL~DEL?HIA MUNICIPAL CCUR- LOUIS ]. PRESENT_A, PRESIDENT JUDGE CER~FiCA~GN OF JUDG,'dE)tT 02-07-23-2505 !~IN'TIFF(S) YELLOW BOOK USA, INC. 1300 MORRIS DRIVE PHILA, PA 19087 DEFENDANT(S) DONALD F, FARNER,±/t/& THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION INC. 216 W. SHADY LANE ENOLA, PA 17025 THIS IS TO NOTiFf YOU THAT: ,X I JUDGMENT: JUDGEMENT IN FAVOR OF PLAINTIFF BY DEFAULT X I JUDGMENT WAS ENTERED IN FAVOR OF: YELLOW BOOK USA, INC. X llJUDGMENT WAS FNTE~FD AGAINST: DONAL E. ~1 and NATIONWIDE LOG HOME RESTORATION, X IN THE AMOUNT OF: $4,053.41 FARNER,i/t/a THE WOOD PROS, INC. DATE OF JUDGMENT: 09/13/02 INC. AHOUNT OF :UBGMENT J[ $4,053.41 POST :UDG, !~NT C~u[-S CERTIFIED ]UDGMENT $4,053 · 41 TOTAL ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENTS BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT FORM WITH YOUR NOTICE OF APPaLl_ CER~FIED ~,~Of~ THE RECORD ON'. JULY 14th, 2003 JOSEPH H. EVERS PROTHONOTARY OF PHILADELPHIA COUNTY CMS - Case Docket Page 1 of 1 Municipal Court of Philadelphia - Case Management System [~om_e_] [.CMS Home~ [Logout] Current user: Stephen Elliott < back Plaintiff Information YELLOW BOOK USA INC 1300 MORRIS DRIVE Defendant Docket View SC-02-07-23-2505 Case Information Defendant Information 2 THE WOOD PROS INC 216 W SHADY LANE PHILA, PA 19087 Attorney: RONALD AMATO ID: 32323 ENOLA, PA 17025 Disposed Filing Date Description 07/23/2002 Statement of Claims Results/Comments Hearing Scheduled: 09/'13/2002 01:30 PM Hearing Room 4A Fee: $43.50 Amount at Issue: $3,969.91 Filing Party CMS User 09/13/2002 Disposition - Judgment Judgment Amount: $4,053.41 Seamus P. for Plaintiff by Default McCaffery 09/13/2002 Notice - Notice of Seamus P. Judgment McCaffery < bac~ Docketed Under View THE WOOD PROS INC (D2) YELLOW BOOK USA INC (P) DONALD E FARMER JR (D1) NATIONWIDE LOG HOME RESTORATION INC (D3) THE WOOD PROS INC (D2) THE WOOD PROS INC (D2) View http://claims.verilaw.com/plununi/cms/caseDocket.j sp?viewType=defendant&casePartylnsta... 4/22/03 CMS - Case Docket Page 1 of 1 Municipal Court of Philadelphia - Case Management SYstem [Home[ [CMS Homej [Loooutl Current user: Stephen Elliott back Plaintiff Information YELLOW BOOK USA INC 1300 MORRIS DRIVE Defendant Docket View SC-02-07-23-2505 Case Information Defendant Information DONALD E FARMER 216 W SHADY LANE PHILA, PA 19087 Attorney: RONALD AMATO ID: 32323 ENOLA, PA 17025 Disposed Filing Date Description 07/23/2002 Statement of Claims Results/Comments Hearing Scheduled: 09/13/2002 01:30 PM Hearing Room 4A Fee: $43.50 Amount at Issue: $3,969.91 Filing Party CMS User 09/13/2002 Disposition - Judgment Judgment Amount: $4,053.41 Seamus P. for Plaintiff by Default McCaffery 09/13/2002 Notice - Notice of Seamus P. Judgment McCaffery Docketed Under View THE WOOD PROS INC (D2) DONALD E FARMER JR (D1) YELLOW BOOK USA INC (P) NATIONWIDE LOG HOME RESTORATION INC (D3) DONALD E FARMER JR (D1) DONALD E FARMER JR (D1) View http://claims.verilaw.com/phmuni/cms/caseDocket.j sp?viewType=defendant&casePartyInsta... 4/22/03 CMS - Case Docket Page 1 of 1 Municipal Court of Philadelphia - Case Management SYstem · [Home1 [CMS Ho. me] [Logout] Current user: Stephen Elliott < back Plaintiff Information YELLOW BOOK USA INC 1300 MORRIS DRIVE Defendant Docket View SC-02-07-23-2505 Case Information Defendant Information 3 NATIONWIDE LOG HOME RESTORATION INC 216 W SHADY LANE PHILA, PA 19087 Attorney: RONALD AMATO ID: 32323 ENOLA, PA 17025 Disposed Filing Date Description 07/23/2002 Statement of Claims Results/Comments Hearing Scheduled: 09/13/2002 01:30 PM Hearing Room 4A Fee: $43.50 Amount at Issue: $3,969.91 Filing Party CMS User 09/13/2002 Disposition - Judgment Judgment Amount: $4,053.41 Seamus P. for Plaintiff by Default McCaffery 09/13/2002 Notice - Notice of Seamus P. Judgment McCaffery < back Docketed Under View THE WOOD PROS INC (D2) NATIONWIDE LOG HOME RESTORATION INC (D3) DONALD E FARMER JR (D1) YELLOW BOOK USA INC (P) NATIONWIDE LOG HOME RESTORATION INC (D3) NATIONWIDE LOG HOME View RESTORATION INC (D3) http://claims.verilaw.com/phmuni/cms/caseDocket.j sp?viewType=defendant&casePartylnsta... 4/22/03 IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. : No. (~ -- : CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $ ON,J~:~ , 2003. A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY - CUMBERLAND COUNTY If you have any questions concerning the above, please contact the undersigned. AMATO AND MA~,GLE, P.C.~,~-~ Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS. DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant(s) No. 03-3513 Civil PRAECIPE FOR WRIT EXECUTION (MONEY JUDGMENT) To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) All cash on hand or in the possession of the defendant(s), accounts receivables, furniture, furnishinqs, ecluipment, inventory, tools, vehicles, electronic equipment, anv and all other personal property belongin(] to the above- named defendant(s). (2) against DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC., Defendant(s) (3) and against ........................................ Garnishee(s) (4) and index this writ (al against .................................. Defendant(s) and (b) against ....................................... Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:(Specifically describe the property) (5) Amount Due Statutory Interest From July 23, 2003 $ 4,206.03 $ .71 Less Payment $ 0.00 Costs Poundage Total $ 4,206.74 Date:July 24, 2003 Attorney File//: 2021817 AMATO AND MAR~ P.C. ~ Attorney I.D. No. 32323 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant(s) No. 03-3513 Civil CIVIL ACTION CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE I do certify that the precise last known address of the within named defendant(s) is the address provided below, and request that the Sheriff serve the above named defendant(s) at: 216 West Shady Lane ENOLA PA 17025-2237 Dated:July 24, 2003 AMATO AND MARGLE, P.C. By: ~ Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File #:2021817 · ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS. DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant(s) : No. 03-3513 Civil : CIVIL ACTION WAIVER OF WATCHMAN To the Sheriff: Any deputy sheriff levying upon or attaching any property under the within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before the sheriff's sale thereof. Dated: July 24, 2003 Attorney File #: 2021817 AMATO AND MARGLE, P.C. By: ~ Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant No. 03-3513 Civil CIVIL ACTION WRIT OF EXECUTION NOTICE THIS PAPER IS AWRIT OF EXECUTION. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY OF THESE RIGHTS. IF YOU WISH TO EXERCISE YOUR RIGHTS, YOU MUST ACT PROMPTLY. THE LAW PROVIDES THAT CERTAIN PROPERTY CANNOT BE TAKEN. SUCH PROPERTY IS SAID TO BE EXEMPT. THERE IS A DEBTOR'S EXEMPTION OF $300. THERE ARE OTHER EXEMPTIONS WHICH MAY BE APPLICABLE TO YOU. A SUMMARY OF SOME OF THE MAJOR EXEMPTIONS ARE LISTED ON THE NEXT PAGE. YOU MAY HAVE OTHER EXEMPTIONS OR OTHER RIGHTS. (1) (2) IF YOU HAVE AN EXEMPTION, YOU SHOULD DO THE FOLLOWING PROMPTLY: FILL OUT THE ATTACHED CLAIM FORM AND DEMAND FOR A PROMPT HEARING DELIVER THE FORM OR MAIL IT TO THE SHERIFF'S OFFICE AT THE ADDRESS NOTED. YOU SHOULD COME TO COURT READY TO EXPLAIN YOUR EXEMPTION. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. 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. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO03-3513 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Yellow Book USA Inc. Plaintiff (s) From Donald E. Farner, Jr i/Ua The Wood Pros., Inc. and Nationwide Log Home Restoration, Inc. 216 West Shady Lane, Enola, Pa. 17025~2237 (1) You are directed to levy upon the property of the defendant (s)and to sell All cash on hand or in the possession of the defendants-accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to the above names defendants. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account oftha defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,206.03 Interest Statutory interest from 7/23/03 $0.71 At1~"s Corem % Atty Paid $37.50 Plaintiff Paid Date: July 31, 2003 L.L. $0.50 Due Prothy $1.00 Other Costs (Seal) REQUESTING PARTY: Name Ronald Amato, Esquire CURTIS R. LONG Prothonotary By: ()~.,~- Deputy Address: 107 North Commerce Way Bethlehem, Pa. 18017 Attorney for: Plaintiff Telephone: (610) 866-0400 Supr~ne Court ID No. 32323 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Post Pone Sale Garnishee TOTAL 18.00 1.20 .5O 1.00 10.35 30.00 $ 61.05 Advance Costs: 150.00 Sheriff' s Costs: 61.05 $ 88.95 Refunded to Atty on 08/22/03 Swom and Subscribed to before me This -~a~day of 2003 A.D, 'Prdthonotary R. Thomas Kline, Sheriff By Claudia A. Brewbaker R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Post Pone Sale Garnishee TOTAL 18.00 1.20 .50 1.00 10.35 30.00 $ 61.05 Advance Costs: 150.00 Sheriff's Costs: 61.05 $ 88.95 Refunded to Atty on 08/22/03 Sworn and Subscribed to before me This .2~-~'day of ~.~ 'Pr6thonotary R. Thomas Kline, Sheriff&{~_~ ' By Claudia A. Brewbaker COURT OF 'COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW YELLOW BOOK USA, INC. Plaintiff VS, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant(s) No. 03-3513 Civil CIVIL ACTION NOTICE OF TAKING ORAL DEPOSITIONS To: Donald E. Farner, Jr. 4843 Spring Road Shirmansdale PA 17090 CERTIFIED MAIL RETURN RECEIPT REQUESTED PLEASE TAKE NOTICE THAT the Plaintiff will take tile oral deposition of Donald E. Farrier, Jr., on March 17, 2004, at 10:00 a.m. o'clock at the Cumberland County Bar Association, 2 Liberty Avenue, Carlisle, Pennsylvania before a person authorized to administer oaths. The Plaintiff in this action will take the deposition of Donald E. Farrier, Jr., upon oral examination in accordance with the Pennsylvania Rules of Civil Procedure 4001, et seq. The examination will continue from day to day until completed. At the ~foresaid time and place, the said deponent is required to appear to give testimony and to bring with them the following: all papers, deeds, records, copies of income tax returns (including all schedules and attachments), agreements, accounts receivables, profit and loss statements, financial statements, bank statements, titles or registration certificates to any vehicle owned or possessed by Defendant, and any and other proofs of the assets of the aforementioned Defendant, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC., from and in any source and matter whatever. AMATO AND M/ARGLE, P.C;..~ JRonald Amat~, Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 DATED: December 12, 2003 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND YELLOW BOOK USA, INC. VS DONALD E. FARNER JR, ET AL 03-3513 TO: Donald E. Farner, Jr. 1. YOu are ordered by the ~ to o3~ne to Cumberland County Bar Association, 2 Liberty Avenue at Carlisle at 10:00 (Specify courl,ocmor other place) Cumberland County, Pennsylvania, on3/17/04 o'clock, A.M., to testify On behmlf of Yellow Book USA, Inc. in the above case, and to re~tinuntil excused. 2. And to bringwmith you tl~ fo]]o,,ring: Ail items as specified in the attached Notice to Attend and Produce Documents. If you fall to attend or to ~ufuc~ce th~ doct~aents or thin~s re~i~ed-by this subl~oena~ you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not lJntited to costs, attorney fees and in~priSOr~_nt. R~-r~o BY A PARTY/ATTOrNEy IN fIl~PLI3%NCE WITH Pa.R.C.P. NO. 234.2(a): N~: Ronald Amato, Esquire AD~ 107 N Commerce Way TRLh:-~I~: 610-866-0400 ~JPR~g~fI~3RT ID ~ 32323 (Sea/ of the Court) Prothonotary, Civil Division O~'~'iCIAL N~rg: This fo~m of subpoena shall be used whenever a subpoena is iss~hle, includ- ing )~x~---~-~ngs .in (2x)ru-x,~-~tion i, rith ~l~Ositior~ and before arbil,~tor~, m~sters, etc. in o~np31ance with Pa.R.C.P. NO. 234.1. If a subpoena for production of c~ts, rec~x~ls or thimgs is desired, cc~nplete parag~ 2. (Eff. 7/97) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW YELLOW BOOK USA, INC. Plaintiff VS, No. 03-3513 Civil DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC. Defendant(s) CIVIL ACTION To: NOTICE TO ATTEND AND PRODUCE DOCUMENT~ Donald E. Farner, Jr. 4843 Spring Road Shirmansdale PA 17090 CERTIFIED MAIL RETURN RECEIPT REQUESTED (1) You are directed to come to the Cumberland County Bar Association, 2 Liberty Avenue, Carlisle, Pennsylvania, on March 17, 2004, at 10:00 a.m. o'clock, to testify in the above case, and to remain until excused. (2) At the aforesaid time, you are directed to produce the following: all papers, deeds, records, copies of income tax returns (including all schedules and attachments), agreements, accounts receivables, profit and loss statements, financial statements, bank statements, titles or registration certificates to any vehicle owned or possessed by Defendant, and any and other proofs of the assets of the aforementioned Defendant, DONALD E. FARNER JR. i/t/a THE WOOD PROS, INC. and NATIONWIDE LOG HOME RESTORATION, INC., from and in any source and matter whatever. If you 'fail to attend or to produce the documents of things required by this notice to attend and produce documents, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure. AMATO AND MA~RGLE, P.C.,/~ ~,,/'Ronald Amato~,~Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 DATED: December 12_~_2003