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HomeMy WebLinkAbout07-3959 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING IN THE COURT OF COMMON PLEAS OF SERVICES, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 2007 - 3859 KATSCO, Inc. and DANNY EPPS, Defendants 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 and Notice are 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 Complaint or for any other claim or relief requested by the Plaintiffs. 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: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 F:\F1LES\Geeera1\Current\12156\ 12156.9.com/mah Created: 11/05/01 09:49:53 AM Revised: 06/28/07 10:10:47 AM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 3 9S9 c4c;d- -r4l.. COMPLAINT AND NOW, comes the Plaintiff, Madden Engineering Services, Inc., by and through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers as follows: 1. Plaintiff, Madden Engineering Services, Inc., is a Pennsylvania corporation with a registered address at 10 Irvine Row, Carlisle, Cumberland County, Pennsylvania. 2. Defendant, Katsco, Inc., is a Pennsylvania corporation with an address of 17 Montego Court, Dillsburg, York County, Pennsylvania, and a registered address of 417 South Lewisberry Road, Lewisberry, York County, Pennsylvania. 3. Defendant, Danny Epps, is an adult individual, with an address of 17 Montego Court, Dillsburg, York County, Pennsylvania. 4. Plaintiff is in the business of providing services, mainly engineering services, to certain businesses and individuals. 5. Defendant Epps is the owner of 87 Chestnut Grove Road, Dillsburg, Pennsylvania. 6. Plaintiff has provided services to Defendants at 87 Chestnut Grove Road, Dillsburg, Pennsylvania. 7. Plaintiff and its agents and employees, have provided services to Defendants for a total value of $6,250.02. True and correct copies of Plaintiff's invoices are attached hereto as Exhibit "A." 8. Defendants have failed to pay for such services and therefore is liable to Plaintiff for the amounts owed plus interest, costs and attorney fees. 9. Despite repeated demands, no payments have been made by the Defendants for amounts due nor have Defendants disputed this debt. COUNT I - BREACH OF CONTRACT 10. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 9 as if fully set forth. 11. Defendants have breached an expressed or implied agreement, directly or through agents, to pay for the goods and services provided to Defendants from Plaintiff and/or Plaintiff's agents. WHEREFORE, Plaintiff demands judgment against Defendants in the total amount of $6,250.02 plus interest at the rate of 18% per annum, attorney's fees and costs. COUNT II - QUANTUM MERUIT 12. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 11 as if fully set forth. 13. Defendants are liable to the Plaintiff and/or have been unjustly enriched in the amount of $5,715.68. 14. Defendants have received and retained the benefit of Plaintiff s services. WHEREFORE, Plaintiff demands judgment against Defendants in the total amount of $6,250.02, plus interest at 18% per annum, attorney's fees and costs. MARTSON LAW OFFICES By Lig ? S Christopher E. Rice, Esquire ID Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: Z $ _ 67 Attorneys for Plaintiff EXHIBIT "A" EARTH RESOURCE ASSOCIATES, INC. 33S SOUTH Eir3HTH STFFET, SWTE 2 LEDANON, PENNSYLVANIA 1 7042-601 £j PHONE (7 T 7) 273-2 1-77 FAX (71 7) 270-5502 Invoice Date Invoice # 12119%2(Mltj ?(x)?gj8 P.O_ No. Terms Due Date Project 1 hte !m recpt 1211 W2owX Qty Description Rate Amount For Prole; sioual tic rvices Rendered and Fxpeii-?es lucmed in as cx iaLion tivith a prclirninan hrdrugcrologic stud !nitrate I( ding ask s,?ncart of The Chestnut CSro? e Road prolxr, York CO LUJtriT. Senicc . invoiced herein include a review of the site ecology x11d ground%ratcr flow directions, the collrttion and aruilysis of nprns ntative groimdwatcr samples. rcvicta 01 ale wlaktic 1l resuhs, consultations v+ith Mud&r. I?neineering comxnu.ng results - RevZe?ti ofsitc geolop travel and urn plc collection 4!K) W 400 tiO Grotmdwatcr ample wwl Nes fur bncten., turd ;ut ntc , 40 80 204 W review Of results. [?alculntions of lot -, acs and cat sultatious and V Ith M dd . , a en F:nguteering. 125.00 12i'C7 Mwk Nou for T.he opportumty to }lave Imwldc-d these _ sen"tcc. Weapp=iateyourhtLStncss. Tot l a ti12a C)D Skelly & Loy, Inc. Engineers-Consultants P.O. Box 5141 Harrisburg, PA 17110 (717) 232-0593 John Madden Madden Engineering Services 10 Irvine Row Carlisle, PA 17013 Project: 1606605 Madden- Daniel Epps Property 1606605-P INVOICE Invoice Number: 40965 November 14, 2006 Professional Services for the Period: 10/1/2006 to 10/28/2006 001 Contract: Maximum: $3,200.00 Previous Billings Against Maximum: $0.00 Current Billings Against Maximum: $1,455.00 Balance After This Invoice: $1,745.00 Professional Services Hours Rate Charge Senior Manager 1 Senior Professional 1 12.00 $100.00 $1,200.00 3.00 $85.00 $255.00 15.00 $1,455.00 $1,455.00 Reimbursables Auto/Taxi/Mileage Charge Reproduction/Publications $17.80 $0.72 $18.52 *** Total Invoice Amount *** $1,473.52 Aged Receivables: CURRENT 31-60 61-90 91-120 +120 $1,473.52 $0.00 $0.00 $0.00 $0.00 All invoices are due within Thirty (30) days. A late charge will be added to any unpaid balance after 30 days. TRUE NORTH SURVEYING & MAPPING, LLC WILLIAM JOHN GROW, P.L.S. 207 12 RENO AVE NEW CUMBERLAND, PA 17070 Bill To Madden Engineering Services, Inc. 101rvine Row Carlisle, Pa 17013 Invoice Date Invoice # 10/15/2006 1301.16 Ship To Madden Engineering Services, Inc. 101tvine Row Carlisle, Pa 17013 P.O. Number Terms Rep Ship Via F.O.B. Project Net 30 10116/2006 Email Rrlwid 015'/y? Quantity Item Code Description Price Each Amount 2.5 8.75 26.5 2 PLS Time PIS Time Survey Field time PIS Time Professional Time DEED RESEARCH Professional Time base map & Boundary Solution Survey Crew Time Professional Time plot deeds & plans 60.00 60.00 85.00 60.00 150.00 525.00 2,252.50 120.00 Total $3,047.50 Madden Engineering Services, Inc. I 10 Irvine Row 'Carlisle, PA 17013 Bill To KATSCO 17 Montego Court Dillsburg, PA 17019 Invoice Date Invoice # 10/6/2006 04.491 Terms Due Date Project Net 15 10/21/2006 Epps - Chestnut Grove Road Description Amount Professional Services: through 9/29/2006 Data Collection Administration with Surveyor, Wetland Specialist and Hydro-Geologist Authorize survey, delineation and well sampling 1,000.00 Payment is due immediately upon receipt of this statement. If payment is not received within thirty (30) days of the date of this statement, interest at 18% per annum will be added to any unpaid balance, along with the costs of suit and attorney's fees should the same be incurred as a result of any action by us to collect any balance past due. Total $1,000.00 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. W. John M amen, President Madden En neering Services, Inc. '* !k 00 O ? ? ? J - ?J t?r i n m O SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-03959 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MADDEN ENGINEERING SERVICES IN VS KATSCO INC ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: KATSCO INC but was unable to locate Them deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, Pennsylvania, to On July 27th , 2007 , this office was in receipt of the attached return from YORK Sheriff's Costs: So answers: - Docketing 18.00 "7J Out of County 9.00 ` Surcharge 10.00 R. Thomas Klin A?. Dep York County 48.43 Sheriff of Cumberland County Postage 2.23 87.66 07/27/2007 MARTSON LAW OFFICES Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-03959 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MADDEN ENGINEERING SERVICES IN VS KATSCO INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: EPPS DANNY but was unable to locate Him deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, Pennsylvania, to On July 27th , 2007 , this office was in receipt of t attached return from YORK Sheriff's Costs: So answers: -? Docketing 6.00 Out of County .00 Surcharge 10.00 R. Thomas Kline .00 Sheriff of Cumberland County .00 16. 00 1/ S+ 131 0`1, 07/27/2007 MARTSON LAW OFFICES Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. 1 OF 2 COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE IIMSTRUCTM3NS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LME 1 THRU 12 DO NOT DETACH ANY COPES 1 PLAINTIFF/S/ 2 COURT NUMBER 200-395'9 Madden Engineering Services, Inc. 07-3959 civil 3 DEFENDANT/S/ 4. TYPE OF WRIT OR COMPLAINT N O T I C E & KATSCO, Inc., and Danny Epps Civil Complaint C I CA SERVE 5 NAME OF INDIVIDUAL. COMPANY. CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD KATSCO, Inc. 6 ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO. CITY. BORO. TWP. STATE AND ZIP CODE) AT 17 Montego Court, Dillsburg, PA 17019 7. INDICATE SERVICE O PERSONAL J PERSON IN CHARGE XX&EPUTIZE -1 CERT MAIL O 1 ST CLASS MAIL U POSTED J OTHER NOW July 2 20 07 I, SHERIFF OF 66UNTY, PA, do hereby deputize the sheriff of York COUNTY to execute this Wrl feturn thereof/ i a,.?ng to law. This deputization being made at the request and risk of the plaintiff., igqde ? ?"/ SHERIFF OF COtgWr ? 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERMR T 0 F C 0 U N T Y Ctmberland V Please mail return of service to Ctxnberliand County Sheritt. Thank you.0 NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under 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 property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY I ORIGINATOR and SIGNATUR 10. TELEPHONE NUMBER 11 DATE FILED Christopher E. Rice, 10 East High St., Carlisle, PA 17013 / 17-243-3341 6 / 2 9 / 2 0 0 7 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This a e yst be completed d notice is to be mailed) Christopher E. Rice, Esquire, Martson Law ices 10 East High Street, Carlisle, PA 17013 CUMBERLAND CO SHERIFF SPACE BELOW FOR USE OF THE SHERFF - DO NOT WRITE BELOW THIS t,11+1E 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date o r comptaint as indicated above. M J M C G I L L Y C S O 7/5/2007 17/29/2007 16. HOW SERVED PERSONAL ( RESIDENCE POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O 1 hereby cedily and return a NOT FOUND because I am unable to locate the individual. oomoanv. etc named above. (See remarks below.) E TI E OF INDIVIDU4 SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19 Date of Service 20 Time of Service X C1? /Z 21. ATTE PTS Date Time Int. - ate Time Miles Int Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Dale Time Miles Int. 91 22. RtM0kHK5: J / J e?? p l ??_ 3- F. 23. Advance Costs 24 Service Costs 25. N/F 26 Mileage 27. Postage 28 Sub Total 29. Pound 30 Notary 31. Surchg. 32 Tot. Coats 33 Costs Ne Refund Check N $100.00 MOO 6,06 1CO"16-i'l 1,4.3 0 ? . 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cert. 38. Mdeage/Postage/Not Found 39. Total Costs 40 Costs Due or Refund SO ANSWERS 41. AFFIRMED and subscribed to be( this 44. Signature of /J S A' 45. DATE 42, day of . T I) bNm jX „, Dep. Sheriff (ice AC j? 3 -? 46. Signature ff DATE NOTARIAL SEAL LISA L ?A Sheri County 7/25/07 . ) NOTARY PUBLIC CITY OF YC?; YORK COU f F i 48 Si t a9 DATE NTY MYCOMRA(SS• C gn gna ure o ore . r:_XF;RESAUG CounfyShenrt `OWLEDG I NATURE `ORIZED ISSUING AUTHORITY AND TITLE 51 DATE RECEIVED i Authonty 2. PINK - Attorney 3. CANARY -Sheriff's Office 4. BLUE - Shenffs Office 4 c.`.' Est r- a -e rn ° Cl) ro v -v rn rn cn v 2OF2 Ij COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE INSTRtJCT10NS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LIE I THRU 12 DO NOT DETACH ANY COPES 1 PLAINTIFF/S/ 2 07-3959 COURT E Z007-3959 C I V I L Madden Engineering Services, Inc. 4 TYPE OF WRIT OR civil COMPLAINT NOTICE & 3 DEFENDANTISI KATSCO, Inc., and Danny Epps Civil Complaint C I CA SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION Of PROPERTY TO BE LEVIED, ATTACHED, OR SOLD Danny Epps 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO CITY, BORO. TWP. STf1 ODE) AT i'?-F? - ege Eetrrt- -B I'nrr tt-? - 7. INDICATE SERVICE O PERSONAL U PERSON IN CHARGE U DEPUTIZE U CERT MAIL U 1ST CLASS MAIL U POSTED U OTHER NOW July 2 20 I, SHERIFF O NTY, PA, do hereby deputize the sheriff of or COUNTY to execute t_hi ,,Fake return thereof according to law. This deputization being made at the request and risk of the plaintiff., SHERIFF OF 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SER • Please mail return of service to Cumberland County Sheriff. Thank you.v ADVANCE FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under 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 property before sheriff's sale thereof. 9. TYPE NfM E and ADDRESS of ATTORNEY /ORIGINATOR and SlGNATUR 10. TELEPHONE NUMBER 11 DATE FILED ristopner E. Rice, Esquire 17_243-3341 6/2 9/ 2 0 0 7 10 East High St., Carlisle, PA 17013 1 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed it notice is to be mailed) Christopher E. Rice, Esquire, Martson Law Offices FOR USE OF THE SHERIFF - BERLAN F 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or complaint as indicated above. M J M C G I L L Y C S O ?/5/2007 ?/29/2007 16. eHr SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE( ) SHERIFF'S OFFICE ( j OTHER( ) SEE REMARKS BELOW 17. 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 16. NAME AND TITLE OF IVIDU S VED / IS ADDRESS H RE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20 Time of Service 21. ATTEMPTS Gale T e Miles Int. D Time Miles In Date Time IM Date Time Miles Int. Dale Time Miles Int Date Time Mites Int Z f;SS 5? f? 22. KtIIMKRJ: ( /f l /- 1 ? ( (J ?C uef DANNVEPPS DOES NOT LIVE AT THIOADDRESS PER ARNOLD FREES AND HE THINKS HE IS SOMEWHERE IN GETTYSBURG. PER-POST OFFICE CHECK NOT KNOWN AT THIS ADDRESS. 23. Advance Costs 24 Service Costs 25 N/F 26. Mileage 27 Postage 28 Sub Total 29. Pound 30 Notary 31. Surchg. 32 Tot. Costs 33 Costs Due or Refund Check No U. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cert. 38 Mdeage/Postage/Not Found 39 Total Costs 40 Costs Due or Refund 4 i AFFIRMED b f SO ANSWERS 1. and su scr or me this bed to be 42 day of . T 11-1.V -2a '437 14. Signature of Dep. Sheriff 45. DATE r?L 46.Signature rt York ? 47 DATE 7/25/07 'ARYPUBLIC FOR WILLIA SHERIF HOSEI COUNTY 48 Signature of Foreign 49 DATE AUG. 12, 2009 County Sheriff Sri 1 ACKNML11 FM Rl?C1?IPt tllf- {? a (' NATURE 51 HATE RFCF IVFfI OF AUTHORIZED ISSUING AUTHORITY AND TITLE t. WHITE - Issuing A thority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriff's Office 0 ?+ -rr o cr --4 T" h r ,.? Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants TO: KATSCO, INC., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the J/ day of September, 2007, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $6,250.02, plus interest and costs of suit as prayed for in the Complaint for failure to file an Answer to Plaintiff s Complaint. Date: 9/// /0) /S/ ?°•? Prothonotary ` I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: KATSCO, INC. 17 Montego Court Dillsburg, PA 17019 F:\FILES\Chafts 12156112f56.9.pmdefmWnieh Created: 1110510109:49:53 AM Revived: 09/1110710:29:24 AM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 3959 CIVIL TERM PRAECIPE Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant KATSCO, INC., in the amount of $6,250.02, plus interest and costs of suit as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on August 13, 2007, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES By ya, ?= ? Z Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: J-//-07 P O LE S\ 12156\12156,9. 10daynoticelmah Created: 11/05/0109:49:53 AM Revised: 08/13/07 11:18:05 AM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING IN THE COURT OF COMMON PLEAS OF SERVICES, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2007 - 3959 CIVIL TERM KATSCO, INC. and DANNY EPPS, Defendants IMPORTANT NOTICE TO: KATSCO, INC. DATE OF NOTICE: August 13, 2007 417 South Lewisberry Road, Lewisberry, PA 17339 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES Christopher E. Rice, Esquire Attorneys for Plaintiff Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff v. KATSCO, INC. and DANNY EPPS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 3959 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff(s) in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on August 13, 2007. (2e'4 "t 'e Christopher E. Rice, Esquire Sworn to and subscribed before me this rl d day of , 2007. LA o c.? 4otjPublic COMMONWE/U?Tt! OF P NNSYWANIA NoWfri sad Mary M. P" NOWY Pubic came am, OuOWIM 4 ON* *C"Wm pnE*UA4i8.201i ?. ' ,.?,,? t E" , 1r'L?c),}?yt.:?.f'y?ta.?Yi G2 .l ,`'St .. Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant's last know address is 17 Montego Court, Dillsburg, PA 17019. Said Defendant's place of employment is unknown. 1 Christopher E. Rice, Esquire Sworn to and sub c 'bed before me this !/ W day of , 2007. v CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: KATSCO, INC. 17 Montego Court Dillsburg, PA 17019 MARTSON LAW OFFICES By M Price Ten Eldst High Street Carlisle, PA 17013 (717) 243-3341 Dated: / ` /!/O cn Asi O ?.r ls? F:\FILES\Clients\12156\12156.9.pmmim ehrAh Created: 1110510109:49:53 AM Revised: 09118/07 11:08:09 AM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM Defendants PRAECIPE TO THE PROTHONOTARY: Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By 0, ej" t f r- ?2 Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: f' I $ - 0? ac r0 UJ C?> ao v' o na r Fn 52 C4 cil crt I Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants TO: KATSCO, INC., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 3959 CIVIL, TERM NOTICE OF AMENDED ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the / 8' ! day of September, 2007, the following amended Judgment was entered against you in the above-captioned action: judgment in the amount of $6,250.02, plus interest at 18% per annuum, attorneys fees and costs as prayed for in the Complaint for failure to file an Answer to Plaintiff's Complaint. r Date: Prothonotary C I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: KATSCO, INC. 17 Montego Court Dillsburg, PA 17019 I F:1FUYS\Clicurts\12156\12156.9.pnL&fwh/meh Created: 1110510109:49:53 AM Revised: 09/18/07 10:14:20 AM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 3959 CIVIL TERM AMENDED PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant KATSCO, INC., in the amount of $6,250.02, plus interest at 18% per annum, attorney's fees and costs as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on August 13, 2007, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES Dated: qll 8l Q 7 By S /? Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff F TILES\12156\12156.9.10daynotice/mah Created. 11105)01 09:49:53 AM Revised: 08/13/07 11:18'05 AM 1,,883 8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING IN THE COURT OF COMMON PLEAS OF SERVICES, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2007 - 3959 CIVIL TERM KATSCO, INC. and DANNY EPPS, Defendants IMPORTANT NOTICE TO: KATSCO, INC. DATE OF NOTICE: August 13, 2007 417 South Lewisberry Road, Lewisberry, PA 17339 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. Cumberland County Lawyer Referr at Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 %IARTSON LAW OFFICES ..y, ,1 Christop Rice, Esquire Attorneys for Plaintiff Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant's last know address is 17 Montego Court, Dillsburg, PA 17019. Said Defendant's place of employment is unknown. S rc- Christopher E. Rice, Esquire Sworn to and subscribed before me this JAL day of , 2007. No ublic ? ?? (^,QMMWEf1LTH OFY(W?N?A Meat M. PdWN0Wy ? ??C0Ur9y Member. PNnaylvaM* IN?od?aon of NOW" .,, , ? . .,l; ,_. Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM Defendants COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff(s) in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on August 13, 2007. (2-ad S tc-- Christopher E. Rice, Esquire Sworn to and subscribed before me this JA_ day of 2007. t,m i AL I- No blic COMMONWEALTH OF PENNSYLVANIA NOWM Sed Mary M. Pros, N ymy Pw* come ft% oAtow d COU* My Cor w"M EOW ALO I& 70'11 Men*w, Pennsylvania Assodalbn of NoMMs y CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Amended Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: KATSCO, INC. 17 Montego Court Dillsburg, PA 17019 MARTSON LAW OFFICES By M . Price Ten ast High Street Carlisle, PA 17013 (717) 243-3341 Dated: 1/10-) ? '?: _..., to •? , ° ? '' ? ? `_ ':?- r t? ,? ° ? f ..? ?.. ?.; -? : ? ? - SHERIFF'S RETURN - OUT OF COUNTY CAg7 NO: 2007-03959 P COMMONWEALTH OF PENNSYLVANIA: 1COUNTY OF CUMBERLAND MADDEN ENGINEERING SERVICES IN VS KATSCO INC ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: EPPS DANNY but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 8th , 2007 , attached return from ADAMS s office was in receipt of t Sheriff's Costs: So answers: Docketing 18.00 Out of County 9.00 -' Surcharge 10.00 . Thomas Kli e Dep Adams County 26.00 Sheriff of Cumberland County Postage 1.33 64.33 ?%?Jb? 10/08/2007 MARTSON LAW OFFICES Sworn and subscribe to before me this day of A. D. ?fi The Court of Common Pleas of Cumberland County, Pennsylvania Madden Engineering Services Inc vs. Katsco Inc et al 07-3959 civil SERVE : Danny Epps No. Now, September 19, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, October 3 , 20 07 , at 1: 50 o'clock P. M. served the within Reinstated Complaint in Civil Action upon Danny Epps at the Sberiff's Office, Adams County Courtbouse, 111 Baltimore St., Gettysburg, PA by handing to _ Danny Epps a true & attested . copy of the original reinstated complaint and made known to Danny Epps the contents thereof. Sworn and subscribed before me this day of N/A , 20 So answers, e tam ui heriff of Adams County, PA COSTS SERVICE $ 18.00 MILEAGE 8.00 AFFIDAVIT $26.00 Pd. 10/4/07 F& :UNAOO swvoV n h 1 :11 d 17 dlS t00t Cl3A1 ??' ? b7- 395y Interrogatories 1. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did you owe the Defendant any money or were you liable to Defendant on any negotiable or other written instrument, or did Defendant claim that you owed them any money or were liable to them for any reason? If so, specify the nature and amount of such liability or claim and, if applicable, the negotiable or other written instrument on which such liability or claim is based. ANSWER: ?A- 2. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by Defendant? If so, describe the property and specify the ownership, location and fair market value of such property. ANSWER: -2- ? l 3. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did you hold legal title to any property of any nature owned solely or in part by Defendant or in which Defendant held or claimed any interest? If so, describe the property and specify the ownership, location and fair market value of such property, together with the extent of Defendant's ownership interest therein and the value thereof. ANSWER: 4 4. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did you hold as fiduciary any property in which Defendant had any interest? If so, describe the property and specify the ownership, location and fair market value of such property, together with the extent of Defendant's ownership interest therein and the value thereof. ANSWER: N?A -3- 5. At any time before or after you were served did Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent? If so, describe the property, when and to whom it was transferred or delivered and the consideration thereof. ANSWER: ,AJ I A 6. At any time after you were served, did you pay, transfer or deliver any money or property to Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of Defendant against you? If so, describe the property or amount of money, when and to whom the money or property was transferred or delivered. ANSWER: Or -4- h A 7. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did Defendant maintain with you at your main office or any of your branch offices, any bank accounts or safe deposit boxes, or did you hold any money of Defendant in any capacity whatsoever? If so, specify the account names, account numbers, safe deposit box numbers, account types, balances on the date you were served and current balances. ANSWER: ? a1. si) ne ?? UN'P'Uc -Tz. D TRANSAICTIONS 8. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did Defendant own jointly with any other person or entity any bank accounts or safe deposit boxes held by you? If so, specify the account names, account numbers, safe deposit box numbers, account types, balances on the date you were served and current balances. ANSWER: A)l I- -5- 9. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, was any money on deposit for Defendant in any bank account in a name other than those previously listed? If so, specify the account names, account numbers, account types, balances on the date you were served and current balances. ANSWER: ?4 rA ov, ;,- ? ? L' B ' . Downey (PA 59891) Ju t' G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 (717) 255-1155 (717) 238-0575 downeyb@pepperlaw.com weberjg@pepperlaw.com Dated: October 2, 2007 Attorneys for Plaintiff -6- ./ VERIFICATION , state that I am the Llqaq- op'QUJ _c?- of M&T Bank, the garnishee in this matter, that I am authorized to make this verification on its behalf, and that the averments of fact in the foregoing document are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. C.S. § 4904 (unsworn falsification to authorities). Signature Dated: ? \ ` S`§ , 2007 ? ? <__> ?:? _.._, f:'e?' - ... ?, i ?4 ?.....^. ?? Cl.t ? t ? c r?ri ? 7 = - -r'r s ?. i ' _ _ _ i "-- ..... J-mf i - _?? .. ? { .f? ' ,,, "'? y i 1 V F TILES\Clients\12156\ 12156.9.pra.defauh.de/mah Created: 11/05101 09:49:53 AM Revised: 11)28107 10:32:12 AM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM KATSCO, INC. and DANNY EPPS, Defendants PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant, DANNY EPPS, in the amount of $6,250.02, plus interest at 18% per annum, attorney's fees and costs as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on October 24, 2007, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: j//,2 q1 ?? PTILES\Chents\ 12156\ 12156.9.10daynoticeVrnah Created: 11105/01 09:49:53 AM Revised: 10/24/07 03:10:13 PM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING : IN THE COURT OF COMMON PLEAS OF SERVICES, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2007 - 3959 CIVIL TERM KATSCO, INC. and DANNY EPPS, Defendants IMPORTANT NOTICE TO: DANNY EPPS DATE OF NOTICE: October 24, 2007 4209 York Road, New Oxford, PA 17350 . YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES By 5. ?-- Christopher E. Rice, Esquire Attorneys for Plaintiff Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service ofthe United States of America, that he has knowledge that the said Defendant's last know address is 17 Montego Court, Dillsburg, PA 17019. Said Defendant's place of employment is unknown. (?2? S Y2Z - Christopher E. Rice, Esquire Sworn to and subscribed before me this4AIday of Vpye-oj?tr- , 2007. 1 JA VA444) 7 C "0 Not ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary PU* My ConvriqWw EE)Ores Member, Pennsyivanis Assoaietion of NoNHf! a Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 3959 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA ) SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff(s) in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on October 24, 2007. ( 12-- Christopher E. Rice, Esquire Sworn to and subscribed before me this day of Nogmbfr , 2007. Not ublic ' COMMONWEALTH OF PENNSYLVANIA NotariM Seal My M. Prkw NotWY Pd*- QvNe 8m, CUrr60*4 County My Cornrr>WWW Expires Aug. 18, 2011 Member, Fenney1V0n14 Association of Notsriea CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Danny Epps 4209 York Road New Oxford, PA 17350 MARTSON LAW OFFICES By / 1 --??? I A Q'1-6 M Price Ten E t High Street Carlisle, PA 17013 (717) 243-3341 Dated: / 116Z1 9/4J 7 N [V/ T T. ?.._ C t 7 ii C1 77 P rI O ?t co -3 D n C Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING SERVICES, INC., Plaintiff V. KATSCO, INC. and DANNY EPPS, Defendants TO: DANNY EPPS, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 3959 CIVIL TERM NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the A 14 day of November, 2007, the following amended Judgment was entered against you in the above-captioned action: judgment in the amount of $6,250.02, plus interest at 18% per annuum, attorneys fees and costs as prayed for in the Complaint for failure to file an Answer to Plaintiff s Complaint. Date: 11 laq I 4A -1 P, - " '0 ir-4 otb notary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Danny Epps 4209 York Road New Oxford, PA 17350