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Home My WebLink About04-0062CITICORP VENDOR FiNANCE, iNC. Plaintiff SHIRLEY I. KRADER and RICHARD M. KRADER, each Individually and Trading As COMMONWEALTH DATA SERVICES Defendants iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW 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 CITICORP VENDOR FINANCE, INC. Plaintiff SHIRLEY I. KRADER and RICHARD M. KRADER, each Individually and Trading As COMMONWEALTH DATA SERVICES Defendants 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL DIVISION -LAW COMPLAINT The Plaintiff, CITICORP VENDOR FINANCE, INC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of SIXTY-THREE THOUSAND, FIVE HUNDRED FIFTY-FIVE DOLLARS AND NiNETY-EIGHT CENTS ($63,555.98), along with interest thereon from November 26, 2003, upon a cause of action of which the following is a statement: 1. The Plaintiff, CITICORP VENDOR FINANCE, INC., is a corporation organized and existing under the laws of the State of Delaware, having an office and place of business at 1800 Overcenter Drive, Moberly, Missouri 65270. 2. The Defendant, SHIRLEY I. KRADER, an adult individual, is trading and doing business as COMMONWEALTH DATA SERVICES and has an office and place of business at 120 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Defendant, RICHARD M. KRADER, an adult individual, is trading and doing business as COMMONWEALTH DATA SERVICES and has an office and place of business at 120 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. F:\USER\BONNIEJOL4SSOC\WORK\COMP\03420com.wpd:23 Dec03 SUPPUER'~ Signature Printing Products EQUIPMENT '~ r AB DICK 9910 XCD w/airtech Dry powder unit AB DiCK DPM 2340 ~4at=n,a~ter Baumcut 2614 Paper Cutter 220/1/60 Baum XLT Air Folder w! car~ TERM AND RENT~' Ilglt~TB~ 60 ~r~s Commonwealth Data Services u~ (Fa.L rEM. ~ 120 St Johns Drive Camp Hill PA 17011 ~(717 ) 761-8666 THIS AGREEMENT IS NOT CANCELABLE TI~ RL~ER~ IIDE ARE IMM A PAR1' H~REeF LEASE ORIGINAL FORM CITICORP VENDOR FiNANCE, iNC. Plaintiff SHIRLEY I. KRADER and RICHARD M. KRADER, each Individually and Trading As COMMONWEALTH DATA SERVICES Defendants iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW COMPLAINT The Plaintiff, CITICORP VENDOR FiNANCE, iNC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of SIXTY-THREE THOUSAND, FIVE HUNDRED FIFTY-FIVE DOLLARS AND NiNETY-EIGHT CENTS ($63,555.98), along with interest thereon from November 26, 2003, upon a cause of action of which the following is a statement: 1. The Plaintiff, CITICORP VENDOR FINANCE, 1NC., is a corporation organized and existing under the laws of the State of Delaware, having an office and place of business at 1800 Overcenter Drive, Moberly, Missouri 65270. 2. The Defendant, SHIRLEY I. KRADER, an adult individual, is trading and doing business as COMMONWEALTH DATA SERVICES and has an office and place of business at 120 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Defendant, RICHARD M. KRADER, an adult individual, is trading and doing business as COMMONWEALTH DATA SERVICES and has an office and place of business at 120 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. F:\USER\BONNIEJO\ASSOC\WORK\COMP\O3420com.wpd:23Dec03 4. On or about September 20, 2000, Defendant, Shirley I. Krader, did enter into a Lease with Signature Printing Products for the provision of certain equipment as set forth thereon, with said Lease financed by Plaintiff herein. A true and correct copy of said Lease is attached hereto, marked as Exhibit "A" and made a part hereof. 5. On or about September 20, 2000, Defendant, Shirley I. Krader, did sign a Guaranty thereby guaranteeing the debt of Commonwealth Data Services. A true and correct copy of said Guaranty is attached hereto as a portion of Exhibit "A' and made a part hereof. 6. Plaintiff attaches hereto as evidence of Defendants' receipt of said leased equipment a true and correct copy of Plaintiff s Equipment Delivery and Acceptance Receipt signed by Defendant, Shirley I. Krader on or about December 5, 2000. Said Equipment Delivery and Acceptance Receipt is marked as Exhibit "B" and made a part hereof. 7. Plaintiff attaches hereto a true and correct copy of the Invoice for said leased equipment, marked as Exhibit "C" and made a part hereof. 8. Defendants did make payment on account, leaving a balance due and owing in the amount of Fifty- Seven Thousand, Six Hundred Eleven Dollars and Forty Cents ($57,611.40) as more fully set forth on Plaintiffs Legal Prep Worksheet, attached hereto, marked as Exhibit "D" and made a part hereof. 9. Due to Defendants' default in payment of said amount due and owing as aforesaid, late charges have been added to said account in the total amount of Five Thousand, Nine Hundred Forty-three Dollars and Fifty-Eight Cents ($5,943.58), as shown on Exhibit "D" attached hereto and made a part hereof. F:\US ER\BONNIEJO~ASSOC\WORK\COMP\03420com.wpd:23 Dec03 2 10. The balance due and owing by Defendants to Plaintiff is the sum of Sixty-Three Thousand, Five Hundred Fifty-Five Dollars and Ninety-Eight Cents ($63,555.98), as appears by the Legal Prep Worksheet hereto attached, marked as Exhibit "D" and made a part hereof. 11. Plaintiff has frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants have refused and neglected and still refuse and neglect to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of SIXTY-THREE THOUSAND, FIVE HUNDRED FIFTY-FIVE DOLLARS AND NINETY-EIGHT CENTS ($63,555.98), together with interest thereon from November 26, 2003. Respectfully submitted, KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff F:\USER\BONNIEJO~ASSOC\WORKSCOMP\03420com.w~d:23 Dec03 3 SUPPUER'~ Signature Printing Products EQUIPMENT ~' AB DICK 9910 XCD wi airtech Dry powder unit AB DICK DPM 2340 t. Aaten,&~,te~ Baumcut 2614 Paper Cutter 22011/60 Baum XLT Air Folder wi cart TERM AND RENT~ 60 Commonwealth Data Services 120 St Johns Ddve Camp Hill PA 17011 mee.~(717 ) 761-8666 1HIS AGREEMENT I~ NOT CANCEl. ABLE DN THE REVERSE IIDE JIRE IL~OE A R~qT HER~0F GUARANTY S Y ' ' ' ~-o 0 X X ~ LEASE ORIGINAL FORM CC~O0-'f · k,G)-d, p(~ daffmOes, INpaMN IM r.M~ (k~ dh'mly~ f#s and (;oets) ll~ out M or In COOMCU(~ with 1M ~u~ ~ W ~ w~ ~, ~ OIilqiliT LOGATEO IN VAAIOUI ITMTI k. suOject b) s~ls taxlw which ,equiethat m b~ paid up h~nt. fl y~u cheo. m ~ ~ w q m, ~ ~ ~. ~ ~ s~ 11. ~ YI)U Xk~T NO RIGHT TO SELL, 'f~, kSSGN THI$ AGREEMENT OR SUGLF. ASE, PItDGE O~ OTI~RWISE F.I~UMBE R TI~ EG4.11/UlAENT. We In~ M. assk~ or 1~, GM~ I~ JUi~ ANDIOV~ L&~. YQU CON~ TO 1HE P~NAI. JU~SOK;TIOI4 OF Ti~ C~S OF 'r14E ~ ~ ~ ~ ~H ~ TO ~ ~ ~ONE INTERNATIONAL BL~.. MAHWAH. NJ 07430~0~1 · · FO~M CC~eO~2 Equipm~nl: belivery and Accept~,nc,i Receipt cfl capitai' The unde'slg I ~;d does hereby ac~owledge ~he complete and satlslactory delivery and installation of~eEq~iprrl, 9t. leasedfror'nCiflcorpVendor Finance, Inc. 9'~;unde~igneddoesfurlher~ledge that Less~,- h~m made no warranties expressed or Implied regalx~ing ~.~ equipment~ b~at our obliga~ons to Lessor or ,i . assignees as set forth in the aforementioned lease are free of any and all claims, counter claln" , defenseS, or set-offs. · DEC .01 a000. 10:17 AM ~R MBO ~INANCE 461-O Blue E~gle Ave Harrisburg, PA t7112 717-545-9060 717,-545-0068 Fix Commonwealth i20 St. Johns Dr. Camp Hill, PA .l?01t Copslc~ Capital One Inlernationai Bird 'lOth FI Mah Wah, NJ 07430 ' 9?8 54~ 9~Z9 TO 187785BB344 Ct~e~l~r No, Irh~:~ ~ IAvolell N~. P.O. Numbe~ Sm~m~ ~ P,'O1/01' Invoice Item # Order~l Shipj~d 9910 2340 I 1 2614 9 1 714 1 0 AB Dick 9910 XCD w/AJrech Dry-Podgier & ' $ T~ ~ t~l ~ 9910-700~ 0 ~ D~k DPM 2~0 Plat~a~r 0 ~ 2614 Pa~ C~ ~n 7~139 0 gaum ?14~TNrF~wI~ ~n 014NF0~7 U~ Prim T~tal 8g,$70.o0 '$ 89,370,00 TM~ $ 89.370.00 TOTAL PAGE.OI ~z LEGAL PREP WORKSHEET RATE PLAN: DATE ATTY/AGENCY: 11/26/03 LEASE ~ : 2432290 BAL~LNCE : 57,611.40 LESSEE : COMMONWEALTH DATA SERVICES RESIDUAL : 1.00 ADDR1 : 120 ST JOHNS DR LATE CHG : 5,943.58 ADDR2 : MISC : 0.00 CITY : CAMP HILL INSURAi~CE : 0.00 STATE :PA ZIP :17011 TOTAL : 63,555.98 TELE # :(717)761-8666 SALES TAX @ 0 % : 0.00 SUPPLIER: MBO BNDER & CO OF AMERICA INC TOTAL DUE : 63,555.98 COgtMENCEMENT DATE DATE OF DEFAULT ORIGINAL BALANCE : ORIGINAL TERM : REMAINING TERM : CURRENT PAYMENT AMT. : : 12/o5/oo 115,222.80 61 ADV RENTAL BEGIN : ADV RENTAL END : SECURITY DEPOSIT : 0.00 0.00 0.00 1,920.38 EQUIPMENT DESCRIPTION: VARIOUS EQUIPMENT EQUIPMENT COST : 89,370.00 DEC.24.800~ 8:34AM KNUPP KODAK & IMBLUM M0,451 P.6x6 VERIFICATION By: Title: 3030420 F:\USI~P,~ON'N'IKIO~ S OCAWOP, E~COMI:qI3410~om.wpd:l~D~03 SHERIFF'S RETURN - REGUI~AR CASE NO: 2004-00062 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITICORP VENDOR FINANCE INC VS KRADER SHIRLEY I ET AL BRYAN WARD , Cumberland County,Pennsylvania, says, the within COMPLAINT & NOTICE KRADER RICHARD M DEFENDANT , at 1618:00 HOURS, on the at 146 CLOUSER ROAD MECHA-NICSBURG, PA 17055 RICHARD KP~ADER a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 14th day of January , 2004 by handing to & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service 6.90 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 22.90 01/15/2004 KNUPP KODAK IMBLUM Sworn and Subscribed to before By: me this ~. day of G~_~ ~r~ A.D. ~ ~rothonotary SHERIFF'S CASE NO: 2004-00062 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITICORP VENDOR FINANCE INC VS KPJtDER SHIRLEY I ET AL RETURN - REGUIJtR BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KRADER RICHARD M T/A COMMONWEALTH DATA SERVICES the DEFENDANT , at 1618:00 at 146 CLOUSER ROAD MECHANICSBURG, PA 17055 RICHARD KHADER a true and attested copy of HOURS, on the 14th day of January , 2004 by handing to COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this j2~ day of (~,~,~ .:2 ~72 '-~ A.D. (' '~othc~not~ar~y~,' '.~ ~ So Answers: R. Thomas Kline 01/is/2004 KNUPP KODAK IMBLUM By: D~D~uty h~er-~ iff SHERIFF'S RETURN - CASE NO: 2004-00062 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITICORP VENDOR FINANCE INC VS KRADER SHIRLEY I ET AL REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT & NOTICE was served upon KRADER SHIRLEY I DEFENDANT , at 1410:00 HOURS, at 4931 CARLISLE PIKE MECHANICSBURG, PA 17055 SHIRLEY I KRADER a true and attested copy of COMPLAINT & NOTICE the on the 14th day of January by handing to together with law, , 2004 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this 2~ ,~ day of ~ ~ prothonotary So Answers: R. Thomas Kline Ol/ S/2oo4 KNUPP KODAK IMBLUM. SHERIFF'S RETURN - CASE NO: 2004-00062 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITICORP VENDOR FINANCE INC VS KRADER SHIRLEY I ET AL REGULAR CPL. MICHAEL BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE was served upon KRADER SHIRLEY I T/A COMMONWEALTH DATA SERVICES the DEFENDANT , at 1410:00 HOURS, on the 14th day of January 2004 at 4931 CARLISLE PIKE MECHANICSBURG, PA 17055 by handing to SHIRLEY I KP~ADER a true and attested copy of COMPLAINT & NOTICE together with Sheriff or Deputy Sheriff of who being duly sworn according to law, and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 '' Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 01/15/2004 uPP KODAK Sworn and Subscribed to before me this 2~,_ day of A.D. /~ ~Prothonotary CITICORP VENDOR FINANCE, INC. Plaintiff SHIRLEY I. KRADER and RICHARD M. KRADER, each Individually and Trading As COMMONWEALTH DATA SERVICES Defendants TO: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-00062 CML : CML DIVISION - LAW PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) SHIRLEY 1. KRADER and RICHARD M. KRADER, each Individually and Trading As COMMONWEALTH DATA SERVICES, named for failure to file within thc required time an Answer to the Compla'mt in the above-Captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint Interest from November 26, 2003 at the legal rate of 6% per annum Total $63,555.98 $ 953.34 $64,509.32 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 Praeeipe. See Exhibits A & B attached. Robert D. Kodak, Attorney for Plaintiff Prothonotary Robert g Knupp Robert D. Kodak Gary J. Irnblum LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17t08-1848 Telephone: 717/238-7159 Facsimile: 7171238-7158 email: kki.law~verizon.net (1909-1976) Robert H. Maurer (19'Z3-1998) February 12,2004 SHIRLEY I KRADER INDIV & T/A COMMONWEALTH DATA SERVICES 120 ST JOHNS DRIVE CAMP HILL PA 17011 RE: VS: CitiCorp Vendor Finance, Inc. Shirley I. Krader and Richard M. Krader each indiv. & t/a Commonwealth Data Services No. 2004-00062 Civil, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 3030420 Dear Ms. Krader: 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 have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney 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, KNUPP, KODAK & IMBLUM, P.C. RDK/kqb enclosure CC: Robert D. Kodak, Esq. THIS LETTER IS AN A'I-rEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE ROBERT A FLYNN LIQUIDATION ANALYST CITICORP VENDOR FINANCE INC 1800 OVERCENTER DRIVE MOBERLY MO 65270 #2432290 CITICORP VENDOR FINANCE, INC. Plaintiff SHIRLEY I. KRADER and RICHARD M. KRADER, each Individually and Trading As COMMONWEALTH DATA SERVICES Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2004-00062 CIVIL : : CML DMSION - LAW IMPORTANT NOTICE TO: SI-ffRLEY I. KRADER INDIV. AND TRADING AS COMMONWEALTH DATA SERVICES, Defendant(s) DATE OF NOTICE: FEBRUARY 12, 2004 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 FORTHBELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TH/S OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHAT 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 Robert L. ~,nupp Robert D. Kodak Gary J. Imblurn LAW OFFICES OF KNUPP, KODAK 8, IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17'108-1848 Telephone: 717/238-7159 Facsimile: 7'171238-7'158 email: kki.law~verizon.net February 12, 2004 (19o9-1976) Robert H. Maurer (1923-1998) RICHARD M KRADER INDIV & T/A COMMONWEALTH DATA SERVICES 120 ST JOHNS DRIVE CAMP HILL PA 17011 RE: VS: CitiCorp Vendor Finance, Inc. Shirley I. Krader and Richard M, Krader each indiv. & t/a Commonwealth Data Services No. 2004-00062 Civil, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 3030420 Dear Mr. Krader: 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 have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney 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, KNUPP, KODAK & IMBLUM, P.C. RDK/kqb enclosure CC: Robert D. Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE ROBERT A FLYNN LIQUIDATION ANALYST CITICORP VENDOR FINANi 1800 OVERCENTER DRIVE MOBERLY MO 65270 #2432290 CITICORP VENDOR FINANCE, 1NC. Plaintiff SHIRLEY I. KRADER and RICHARD M. KRADER, each Individually and Trading As COMMONWEALTH DATA SERVICES Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-00062 CIVIL CIVIL DMSION - LAW IMPORTANT NOTICE TO: RICHARD M. KRADER INDIV. AND TRADING AS COMMONWEALTH DATA SERVICES, Defendant(s) DATE OF NOTICE: FEBRUARY 12, 2004 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 RIGI-ITS. 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, TH/S OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHAT 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 CITICORP VENDOR FINANCE,/NC. Plabatiff SHIRLEY I. KRADER and RICHARD M. KRADER, each Individually and Trad/ng As COMMONWEALTH DATA SERVICES Defendants 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-00062 CML CML DMSION - LAW To SHIRLEY I. KRADER INDIV. AND TRADING AS COMMONWEALTH DATA SERVICES, Defendant(s) You are hereby notified that on 7~ ~ oD~ ~ (Judgment) has been entered against you in the above-captioned case. DATE: Judmnent entered in the amount of $64,509.32. , Prothonotary the following I hereby certify that the name and address of the proper person(s) to receive this notice is: SHIRLEY I. KRADER INDIV AND TRADING AS COMMONWEALTH DATA SERVICES 120 ST JOHNS DRIVE CAMP HILL A 17011 A/ SHIRLEY L KRADER IND1V. AND TRADING AS COMMONWEALTH DATA SERVICES. Defendido/a Defendidos/as Por este medio se le esta notificando que el de del 20_, el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: SHIRLEY I. KILADER INDIV AND TRADING AS COMMONWEALTH DATA SERVICES 120 ST JOHNS DRIVE CAMP HILL A 17011 Abogado del Demandante CITICORP VENDOR FINANCE, INC. - IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-00062 CIVIL SHIRLEY I. KRADER and RICHARD M. : CIVIL DIVISION - LAW KRADER, each Individually and Trading As: COMMONWEALTH DATA SERVICES Defendants To RICHARD M. KRADER INDIV. AND TRADING AS COMMONWEALTH DATA SERVICES Defendant(s) You are hereby notified that on (Judgment) has been entered against you in the above-captioned case. ,20_, the following Judgment entered in the amount of $64.509.32. DATE: Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: RICHARD M . KRADER INDIV AND TRADING AS COMMONWEALTH DATA SERVICES 120 ST JOHNS DRIVE CAMP I-IILL A 17011 Ad RICHARD M. KRADER INDIV. AND TRAD1NG AS COMMONWEALTH DATA SERVICES, Defendido/a Defendidos/as Por este medio se le esta notificando que el de del 20_, el/la siguiente(Failo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: RICHARD M. KRADER 1NDIV AND TRADING AS COMMONWEALTH DATA SERVICES 120 ST JOHNS DRIVE CAMP HILL A 17011 Abogado del Demandante CITICORP VENDOR FINANCE, INC. : In the Court of COMMON PLEAS of Plaintiff : CUMBERLAND County, Pennsylvania SHIRLEY I. KRADER and RICHARD M. KRADER, Each Individually and Trading As COMMONWEALTH DATA SERVICES Defendants : NO. 2004-00062 CIVIL : CIVIL DIVISION -LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned Judgment as settled and satisfied in full. TO Cumberland County Prothonotary Dated: May 5, 2004 Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041