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HomeMy WebLinkAbout07-6066?y " ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7159 Attornev for Plaintiff ADVANCED COMMUNICATIONS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. u7 - (coup L; iv?1 ?cri++ YELLOWCAKES, INC. and JENNIFER HAMMAKER, personal guarantor CIVIL ACTION - LAW Defendant(s) NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 Avlso 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 la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte 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 O 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 QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 ADVANCED COMMUNICATIONS Plaintiff v YELLOWCAKES, INC. and JENNIFER HAMMAKER, personal guarantor Defendant(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW COMPLAINT The Plaintiff, ADVANCED COMMUNICATIONS, by its attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of EIGHT THOUSAND FIVE HUNDRED SEVENTY-FIVE DOLLARS AND TEN CENTS ($8,575.10), along with interest thereon at the statutory rate from October 4, 2007, upon a cause of action of which the following is a statement: 1. The Plaintiff, ADVANCED COMMUNICATIONS, is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 3000 Canby Street, Harrisburg, Pennsylvania 17103. 2. The Defendant, YELLOWCAKES, INC., is a corporation organized and existing underthe laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 10 Cherish Drive, Camp Hill, Cumberland County Pennsylvania 17011. 3. The Defendant, JENNIFER HAMMAKER, personal guarantor for Yellowcakes, Inc., F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\ADV COMMUNICATIONS 33743.wpd 2 is an adult individual residing at 10 Cherish Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 4. On or about January 16, 2007, Defendant submitted a Credit Application and Personal Guaranty to Plaintiff, which credit was granted to Defendant, a true and correct copy of which is attached hereto, marked Exhibit "A" and made a part hereof. 5. On the dates, in the amounts, and for the prices set forth in the true and correct copies of the Plaintiffs Invoices hereto attached, collectively marked Exhibit "B" and made a part hereof, Plaintiff, at the special instance request of the Defendants, sold and delivered goods, wares, merchandise and/or services of the kind and description set forth on said Exhibit to the total amount of Seven Thousand One Hundred Forty-Five Dollars and Ten Cents ($7,145.92). 6. The prices charged for said goods, wares, merchandise and/or services were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant promised and agreed to pay to Plaintiff. 7. The balance due and owing by Defendants to Plaintiff is the sum of Seven Thousand One Hundred Forty-Five Dollars and Ten Cents ($7,145.92), as appears on Exhibit "B" hereto. F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\ADV COMMUNICATIONS 33743.wpd 3 8. Due to the default of Defendant, and pursuant to the terms and conditions of the Credit Application and Personal Guaranty executed by Defendant and hereto attached as Exhibit "A", attorney's fees in the total amount of One Thousand Four Hundred Twenty-Nine Dollars and Eighteen Cents ($1,429.18) have been added to said account. 9. Plaintiff frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of EIGHT THOUSAND FIVE HUNDRED SEVENTY-FIVE DOLLARS AND TEN CENTS ($8,575.10), together with interest as set forth herein. Respectfully submitted, KODAK & I UM, P.C. Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney ID No. 18041 Attorney for Plaintiff F:\ USER\ ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\ADV COMMUNICATIONS 33743.wpd 4 A D V A N C E D C O M M UN I C A T I ON S A G E N C Y P 'PLEASE FAX TO 717-233-3800 OR MAIL TO: 3000 CANBY ST., HARRISBURG, PA 17103 M Corporation ? Sub S Cor Legal Name P El Partnership C3 Individual ty_ 1i AO - Yt%I?Dw??.1??s ?74-,L , DBA Street Address D ?? ??! 3 I TY OFFICE . tn. V L3 Own ? Lease City State91 , Zip 1 ?a 11 Years there Date Compa y Started Date Und r CurremAgmt. Fisc YJeear End Business ?Phone No. Bu t% Fax NQ(.} ?{ yet A?upl?os?.&a c7 c?S ??`' / No. of Employees Type of usiness / Feral Tax I M / W 3 " f :5- 0 0 11 .113 R2 REMMUM, 0 Check all that apply: ? Prepaid ST O O I, ©O J f A W\ ?6y- )<-Net 30 Credit Requested $ l"" , ? 3rd Party Billing Available based on following conditions only: (I) Customer to be billed MUST approve final proof, (2) Advanced MUST be able to contact billed customer for payment status and billing issues, (3) Ultimate responsibility for payment lies with person/company shown on this credit application. 111111241-1110.319MMEM Active in DailM mt. of Company ? No Name: Firs Middle Last Social Security No. (if not incorporated) Home Address" - ??? - C?tY State TOwn-ership there Horn TeP hho? nee-- - l Jhrt •? I Job Title or Position 7( l ° l 7? ll _ 9 `.3 ? h? 1 U ?? / % Active in Dail M t. of Company ? Yes ? No Name: First Middle Last Social Security No. (if not incorporated) Home Address City State Zip Years there Home Phone Job Title or Position Ownership % B? lame Ch kin Account No. Phone No. Person to Contact 3? 7. 53319 y? Any Loan? Yes o Account No. Any line of Credit? ? Yes No Account No. Ba4 Nalo 5 Checking Account No. P N y Person to Co ac 'I /L? /, ??) ' Any Loan?? (I Yes o Account No. Any line of Credit? es ? No ¢?gygtt No, Qd ??/J?l??dl - $ cue h$uLA l &`W G 'T -1 S -,° /0 3s0 / go S Company Name City/State Account o. 1 Dn_l.<? y? Sl,L fi L? 2. PhoNo,-?????rsontoCpntac[ Ol^h2 rs U O{/ 3 L 3. 4. IF YOU ARE TAX EXEMPT., PLEASE ATTACH A VALID EXEMPTION CERTIFICATE. i PAGE 1 OF 2 EXHIBIT 1 r `.? ,:} v4 jan 1 TERrINIS AND CONDITIONS PAYMENT: UAless otherfoom specified, the [arms are Net Thirty )30) Days, due and payable thirty DO) days from data Of invoicing covering the wuft authorized by this contract. A Inoeco charge of one end a hag percent 11.5%1 per month nightmare portent (18X) per annum, will be charged on all past dun balances until paid. It is understood and agreed that lane is of the essence in print contracts, and it the customer defaults in the payment of any pan thereof. the entire amount of the convect ehali immediately become cue and payable without notice, at the option of the Primer, together with all costs of collection, including reasonable altmnoys tees it collected by law through an attorney. In the evert Customer defaults in mak- ing any payment under arty contract currently being performed for Customer by Printer. Printer may sus- pend performance under this contract. QUOTATION: Prices are subject to change. A quotation not accepted wilhein Oily 1301 days is subject to review. ORDERS: Orders entered, either verbal or maii cannot be cancelled except upon forms that wilt compen- sate ADVANCED COMMUNICATIONSAGENCY INC. againsr loss. Cost of materials used and weer com- pleted. all to the Me of stoppages will be charged to eustamec PRODUCTION: Skmcnns, copy, dummies end allprep lfaterywank created or rrrmishad byADVANCED COM- MUNICATIONS AGENCY, INC. shah remain its exclusive property and no use of same shag be made, rem any ideas obtained therefrom be used except upon prior written consent. Aswork. ly ea, plates, negatives, posmvcs and odlar items supplied by ADVANCED COMMUNICATIONS AGENCY, INC. shag remain its exckrsivo properly until invoice & paid in fug. al Film: When film is furnished, the following shall apply I, film must be one piece per color per page, right reading, emulsion deem negatives at 133 line screen or ns Dth"se specified. 2. All type is to be at least 114- inside the final trim. 3. Bleed pages are to have 1W extra image area outside the linal trim. a. Center spread pages may have type that extends across the gutter, but type is to be kept welfare [he IM' inside final trim. 5. Photographs and art may be less than 1/4'seside final trim, but cannot be critical to the final reptoduc. Ilan of the pace. 6. All film furnished by Customer or service bureaus must have registration marks indicating blaeds and final trim. Film or pages of multiple color are to have the color spacthed on each piece of film. Machine marks must be I/T outsde final Drove. 1. A color proof must accompany all four color process film. Separated black & wly to proofs must accom- parry off other file,,. bl Camera-beady Mechanicah: When Customer is to furnish mochanicals ready for camera, the following shall apply: 1. Type must be pasted up an a mechanical in page form with windows for ""elms: and art. 2. All line an or color must be pasted up on full sue acetate overlay, or on a separate mechanical regis. lefed to base mecharlicol so as to allow for one line shot per color. 3. All type must not he closer than 1/4' team the trimmed edge of the page. 4. Unless otherwise specified, all halhones, reverses, screens, Late. extra line slits, are, in excess of one line shot per color per page will be charged extra. c) Proofs: AN proofs are to be returned to Printer by Customer, marked approved and signed by properly authorized person. The Primer is not responsible for errors in work printed in accordance with Customer's approval. In the absence of signature. the return of proof shall be sufficient authorization for Printer to print, unless a revised proof is requestud. ADVANCED COMMUNICATIONS AGENCY riff rot be hold responsible it the customer has not requested or has refused to accept proofs at has failed to return proals with indication of changes or has insiniemd ur verbally to proceed wimour return of proofs. d) AutWmAlterationcteprosentwwkperfarnedinaddibbntoorigina/specifications Such adesefforialwank shall be charged at current rates and supposed with documentation upon request el Supplied Paper: When supplying stock Customer is responsible to furnish paper of a quality suitable for efficient and ec unomicaI production. Sufficient additional paper as spmeified by the printer must be fur. hislip d to allow for normal spoilage. The Primer reserves die right to reject any furnished Paper which the Printer determines is not suitable to run on its presses. f) Overruns and Underm s: A variation of 10% in ilia ordered quantity as specified in any quotation shall constitute lull and acceptable delivery and price will be adjusted accordingiv. A transition of 5% or less shall constitute a lull and acceptable delivery and no adjustment will be made to invoice. g) Preduction Schedule: Upon receipt of a verbal or written order, a detailed Production Schedule will be mutually agreed upon in writing it requested between the Customer and the Printer for all work to be per- formed on this correct. The prices in this quotation are based upon full compliance with said schedule, and any deviation from the agreed-upon schedule on the part of the Customer may result in a revised delivery date or additional charges [or downtime or overtime incurred by Primer. In any case, no additional work will he perforated by the Printer until such revised schedule and/or pricing is approved by Customer. UNION LABEL, The union label may be added to all hems which are political in nature, and to other items print- ed by Advanced Communications Agency, Inc. unless otherwise requested to he omitted. POSTAGE AND FREIGHT: Customer shall pay Printer in advance for all postage. AOarders are FOS, Point of Shipment. As a courtesy, Printer wig arrange for common carrier shipments on babel of Customer, nam- ing Customer as shipper: such shipments to be collect or prepaid by Customer absent agreement to the contrary. Customer releases Primer from any liability for nondelivery or late delivery of printed materials. Pennsylvania bureau of Saks & Use Tax, Riding No. 169 requires that we cdfect sates tax an allprepaid hoighr shipments. 73030198 P,1 STORAGE Unless otherwise noted, this contract does not provide for storage of the Customei s finished matenaie of finished goods. QUALITY OF WORN: The Printer wig use reasonable efforts to reproduce copy faithful to the materials fur- nished by the custamet. Normal shrinkage of the paper and reasonable variation in color helrveml proofs and finished product shag constitute acceptable work. We do not guarantee to match style of typog- raphy, color of papers minks. In all cases, a variation in size. position, folding, trim, Dec.. of 1116' or less will constitute acceptable work. TITLE Title to printed material. and risk of loss shall pass to the Customer upon loading into Customei s vehi- cle, common carrier, or delivery to the Postal Service, mailing service, or shipper. ALTERATIONS: No handwrtten alterations to the typewrinen portion of this agreement am valid unless Hei- haled by Customer AND Primer. Any changes to the original speciticaions of this agreement after accep- tance by Printer will be billed as extra charges at Printer's usual rates. INDEMNITY: Customer will indemnity, and agrees to hold harmless. The Printer, of and from any and all dam. ages, losses, Ices and costs which the Printer may incur. sustain, or suffer as the result of any claim, charge or suit bnsod upon any allegations of Ideal, obscenity, unlawful matter, infringement for misuse at copy, pictures, portraits, photographs, of other material, published by Customer and sal, plated, printed or bound by the Printer under the terms of this agreement, it being understood and acknowledged Ihm the ,Printer has no central over the same; and any suppressions, impounding or seizure of printed matter because of libelous, obscene or unlawful matter, infringement or misuse, shall not release the customer from liability to the primer for monios to he paid underthe terms of their agreement. LIABILITY: The Printer shall not be liable for delays or non-performance resulting from war, national emer- gency. strike% forms, goods, Dr other casualties, riots, Insurrections, accidents, delays or accidents to transportation of raw materials or finished products, or acts or dafaults of subcontractors or suppliers. rules and restrictions by levy or government agency during periods of national emergency, and other causes beyond the Parner'I: control 'HE Ru"U'SENUDIGNS AND WARRAIMES CONTAINED KREIN ARE THE SOrE REPRESENTATIONS Alto WARRANEIES Of PFRNT- Ee, Wol e1SCUUM ANY AND All QLIJR afflESSED OR DIMED wAMIINTIEC r.rltD C M^AAhI ES re Aa'sn 41wAUblary ANa HnrESS FOR A VgahElxAa MelPrrSE PRwtERS uAlli fm ALLCIA1M5 ARISING HEREUNDER wCteO- IWi Ntta'Ti[raI CR 0aFA01 OF WAPRaXtr SHALL RE UMllFD 10 namT ten Ata ens PW TO PmNTEN WR Direct , WORK AND W-HO EWNT WIL McNfEq aE L A9F ma loss Of REVENUI OR A SY M R RE TINE alt CDH fNr LNLIDENIAS D.l _ GE<_ RETURNS: Cams for detects. damages wshartages must be made by me customer in wririrrg nvehin a pan, od of five 131 days after deNwify. Failure to make such claim within the stated period shalt constitute inlay. ocab/n acceptance and admission that goods fully comply with forms conditions and specifications ADVANCED COMMUNICATONS AGENCY, INC. liability shall be Grafted to stated selling price of any defective product sent. ERRORS: If a customer notifies Printer of a defect within the required time. Primer has the right to require Customer to retain, at Customer's expense, all delamive materials for review. II customer has used the product in whole or in part regardless of any dated material that may become late during the proper defect review process, then this well constitute implied acceptance and no adjustmenlwill bo addressed regardless of any noobcahon made within 5 days after delivery. It the nature of the defect is wilNn the guidelines set forth in these TERMS AND CONDITIONS with regards to acceptable variations, no adjust- ment will be made to the cost of the project, any outstanding amounts will (amain due- and tie product wig be returned to the customer at the ctutomerls expanse. If the nature of the defect is outside the guide- lines set forth in these TERMS AND CONDITIONS, Printer will calculate the value of the defect as a par- certtage of the whole based an the percentage component cost of the defect to the entire project cost This amount wig be credited against the total cost of the project. In the avant that a project is comprised of multiple parts, the adjustment will be limited to the cost of any that singular component and aft other parts will not be adjusted. In the event of a bound or gathered product. the credit [or a defect wili t im- Red to the value of the page, panel. or side as a percentage of the whole value calculated by the printer. SUBSEQUENT PRINTING JOBS: To facilitate and expedite the parties' dealings on future printing jobs, it is agreed that the terms set forth on this pope shag apply to all future pr itiev jobs unless amended or con. tradicted by a willing signed by bath parties. MISCELLANEOUS: The Printer reserves the right to perform any and all work described in this contract in its own plant or the plant of any affiliated company or to subcontract in whole or in part No addendum lo or amendment in the provisions of this agreement shwa loo effective or binding Upon e parry here- to unless embodied in a written instrument executed on behalf of such parties by an authorized represemative. Thu Production schedule, when attached and agreed, and any agachmentjs) herein referred to and attached eore:titule a part of this contract. This contract contains the entire Agreement of the parties and no inducements, representations, promises, agreements, or understandings, mat or in writing between the Denies, not embodied herein or subse- quently made pan hereof by a properly executed addendum or amendment hereto as herein provided, shall not be of any force or effect Notwithstanding the foregoing, and recognizing bath the frequency of change orders and press deadlines, Printer's written change order sent to Customer shall amend the terms of the specific job to which it is paramount without counter signature of Customer, provided the Customer does let controvert the change order 1Midun 24 hours of receipt thereat by mail or fax. This Agreementis made pursuant to and shall be governed by the laws of the Commonwealth of Pennsylvania and the venue for any and all claims shall be Dauphin County, Pennsylvania. Customer consents to this junsdiction I/We acknrnvledge that I/1Ve have made this application will the intent that ymt rely upon Ure information contained hereht for granting hho credit reyursted. 1/l1'e understand that if the rA•trycstud credit is hnlumed, you nmv report infnnnation concerning the cradir m consumer reporting agencies and to others. I/ We alloit that my)our answers cue coulplete and u•ue and authorize you to eerily, or obtain any, information eoncet-tting them. Upon your request, UINe further authorize any firm or htdividuaf from whom If We may have obtained ill' rcquasied credit to furnish ynu ifeci fls of that transaction. I/Wealw agree to provide current financial infnnnation upon request, in a form acceptable In you. Ilyv'c agree that ifany funds are, unctdleciibhe hnnn the applying entity, that IIWe %vill be personally liable for these amounts. IlWe further authorize Advanced Communications Agency, Inc. to furnish the above information and/ornnanciai infornmion provided to any financial service. Advanced Communications Agency, tile. may deem it necessary to asslgn this information. i/%Vu rep- resent that we are duty authorized to make these smtements and commitments on behalf of the cmnpany. IJWc acknowledge that ht•signhtg below thin allTenns and Conditions con- tained herein are legible. acknowledged, and accepted. Princip •s Signature pale I Co-Applicant/Principal's Signature Date ------ rue - -- ..--- Title PLEASE FAXTO 717-233-3800 OR MAILTO 3000 CANBY ST., HARRISBURG, PA 17103 PAGE 2 OF 2 i r t: 10/10/2007 10:40 7172333800` ADVANCED COMMUNICATI PAGE 03/06 Advanced Communications Invoice 3000 Canby Street Harrisburg, PA 17103 Tel: (717)233-3000 Fax: (717)233-3800 Invuice Dxte Invoice Number 3/23/2007 INV-12841 Yellowcakes, Inc Due Date Terms 10 Cherish D.rive 4/22/2007 Net 30 Camp Hill, PA 17011 United States Job Number Account ED I Yelcak-1403 Customer Purchase Order Namber, 5,000 YcllowcakesMogaxine SALES TAX 1.11 5,548.31 100 Overs SALES TAX 1.11 110.97 1 Author's Alterations SALES TAX 30.00 30.00 i i THANK YOU FOR YOUR BUSINESS! A monthly service fee of 1.5% (18% per years will be churned _to ail nact f i . b? Advanced Communications Agency, Inc. is a qualified s • in 4 PA code 2.32. 1 exMBrr Subtotal: $ 5,689.28 Total Tar: $ 341.36 ces. efined Amount Due: ' ° :: ; f (k3(3,t ? (0030 .uy 10/10/2007 10:40 7172333800 Advanced Communications 3000 Canby Street Harrisburg, PA 17103 Tel: (717)233-3000 Fax: (717)233-3800 Yellowcakes, Inc 10 Chcrish Drive Camp Hill, PA. 17011 United States $,000 100 i ADVANCED'COMMUNICATI PAGE 02/06 Invoice SuNteription Cards - pert, fold and Stitch into Magazine Overs Invoice Date brivoice Number 3/23/2007 1TIV-12842 Due Date Terms 4/22/2007 Net 30 Job Number Account )<D Yelmk-1403 Customer Purchase Order Number SALES TAX SALES TAX 0.14 695.74 0.14 13.91 THANK YOU FOR YOUR BUSINESS! Subtotal: s 709.65 A monthly service fee of 1.5% (18% per yeor) will be charged to all past due balances. Total Tax: $ 42.5$ Advanced Communications Agency, Inc. is a qualified small business concern as defined in 4 PA code 2.32. ` Amount Due: i 10/10/2007 10:40 7172333800 ADVANCED COMMUNICATI PAGE 04/06 -Ad-Viihced Ctimitiunic' E6ns • 3000 Canby Street Invoice kbi l isburQ- :-PA' • 1'7103 Tel:•'(717)233-3000 (71.7)233-3800- . Invulue Data Itavoice Number 9/4/2007 INV 13372 Yellowcakes, Inc Due Date'. Terms . 10 Cherish Drive 9/4/2007 Due On Receipt, Camp Hill, PA 17011 United States Job Number Account ID'' ; Yekcak-1403 • Customer Purcha9e Order. Number 1 Finance Charges May 22nd Thru Aug3lst 2007 For Our Inv #12842 i i SALES TAX 37.98 37.98 THANK YOU FOR YOUR BUSINESS! A monthly service fee of 1.5% (18% per year) will be charged to all past due balances. Advanced Communications Agency, Inc, is a qualified small business concern as defined in 4 PA code 2.32. Subtotal: 1 $ 37 Total Tax: $ 2.28 :. Amount Due: :,,......_ ......................... 4o .210 ADVANCED' COMMUNICATI PAGE • ? ' ?: : ?Adv'?nt;?(?:Camrriunicdtions • ?• ??3• _? ?° ? .;300d:.Canby •Street• • Harri:?Ehura, P•A`' 1710 3• "'<•, .t•::;; . `•Te1:.(71'7)233=3000 . .. . .:Faz:. (7.17)233.3800•• Ycllowcakcs. fnc 10 C.harkli Drive Camp Bill, PA 17011 United States l Finance Charges - May 22nd Thru Aug 31st 2007 For Our Inv#1280 i Invoke Dace. 'In'voice Number-' '•' 9/4/2007 . : INYA2I3 7, Due Date :. Termq 9/4/2007 Due-OriReceipt. ' Job-Number Account M . . ?Yclcak?-1403 Customer Purchase Order Number SALES TAX 304.52 304.52 Cnht?tal: $ 304. THANK YOU FOR YOUR BUSINESS! A monthly service fee of 1.5% (18% per year) will be charged to all past due balances. Total Tax: $ 18.27 Advanced Communications Agency, Inc. is a qualified small business concern as defined in 4 PA code 2.32. Amount 3aD,g9 OCT-03-2007 17:24 KNUPP KODAK & IMBLUM VERIFICATION of ADVANCED COMMUNICATIONS, verify that the states document are true and correct. I understand that false states to the penalties of 18 Pa. C. S. §4904, relating to unsworn ADVANCED COA By: Title: Dated: d ?e-' 717 238 7158 P.07i07 ct?ol made in the aforegoing herein are made subject ration to authorities. (CATIONS 33743 yellowcakes TOTAL P.07 ,?v ? £; "l O CI CTi D ti c:1 T7 U r i 4f CASE NO: 2007-06066 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADVANCED COMMUNICATIONS VS YELLOWCAKES INC ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon YELLOWCAKES INC the DEFENDANT , at 1213:00 HOURS, on the 22nd day of October , 2007 at 10 CHERISH DRTVF CAMP HILL, PA 17011 by handing to JENNIFER HAMMAKER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.44 Postage .58 Surcharge 10.00 00 !!1 DI D 1 42.02 Sworn and Subscibed to before me this day So Answers: ,0100 j00 ?..P R. Thomas Kline 10/23/2007 KnATC K, TMRT.TTM By of A. D. zrSHERIFF'S RETURN - REGULAR CASE NO: 2007-06066 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADVANCED COMMUNICATIONS VS YELLOWCAKES INC ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAMMAKER JENNIFER the DEFENDANT , at 1213:00 HOURS, on the 22nd day of October , 2007 at 10 CHERISH DRIVE CAMP HILL, PA 17011 by handing to JENNIFER HAMMAKER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 6.00 .00 i Affidavit .00 Surcharge 10.00 R. Thomas Kline l1 ?Dt?b 1 .00 16.00 10/23/2007 KODAK Sworn and Subscibed to F before me this day of A.I ADVANCED COMMUNICATIONS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V NO. 07-6066 CIVIL TERM YELLOWCAKES, INC. and JENNIFER HAMMAKER, personal guarantor CIVIL ACTION - LAW Defendant(s) TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) JENNIFER HAMMAKER, personal guarantor (only), named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint $8,575.10 Interest at the statutory rate of 6% per annum from October 4, 2007 $171.52 Total = $8,746.62 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant(s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. KODAK & , P.C. By Robert D. Kodak, Attorney for Plaintiff DATED: Judgment entered and damages assessed as above. Pr onota '-Y-?/ LAW OFFICES OF KODAK & IMBLUM, P.C. Robert D. Kodak CAMERON MANSION Gary J. Imblum 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 kUlaw®verizon.net January 24, 2008 JENNIFER HAMMAKER 10 CHERISH DRIVE CAMP HILL PA 17011 F, if E RE: Advanced Communications VS: Yellowcakes, Inc. and Jennifer Hammaker, Personal Guarantor No. 2007-6066 Civil Term, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 33743 Dear Ms. Hammaker: COPY Telep8.hon715e 717.232 Facsimile 717.238.7158 In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you or your attorney have not filed responsive pleadings to the Complaint filed against you to the above term and number or an attorney has not entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KODAK & IMBLUM, P.C. Robert D. Kodak THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/kqb enclosure cc: KIMBERLY WILLIAMS #241595 GUARDIAN FINANCIAL NKA COLLECTION AMERICA 16011 COLLEGE BLVD STE 101 LENEXA KS 66219 MARK K EMERY ESQUIRE 410 NORTH SECOND STREET HARRISBURG PA 17101 F.! E COPY ADVANCED COMMUNICATIONS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. 07-6066 CIVIL TERM YELLOWCAKES, INC. and JENNIFER HAMMAKER, personal guarantor CIVIL ACTION - LAW Defendant(s) IMPORTANT NOTICE TO: TENNIFER HAMMAKER, PERSONAL GUARANTOR, Defendant(s) DATE OF NOTICE: TANUARY 24, 2008 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING 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 BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 ADVANCED COMMUNICATIONS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V NO. 07-6066 CIVIL TERM YELLOWCAKES, INC. and JENNIFER HAMMAKER, personal guarantor Defendant(s) CIVIL ACTION -LAW TO: IENNIFER HAMMAKFR PERSONAL G ARANTOR Defendant(s) You are hereby notified that on F 20A the following (judgment) has been entered against you in the a ve-captioned case. Iudgment entered in the amount of S,746,62, DATE:. 4, a M r P tho I hereby certify that the name and address of the proper person(s) to receive this notice is: JENNIFER HAMMAKER - PG 10 CHERISH DRIVE CAMP HILL PA 17011 c' cr, ?. FS N 0 c °v