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HomeMy WebLinkAbout08-1616Merchants Express Money Order Company, Inc. PLAINTIFF V. Young - Ja Jung individually, jointly and severally, DEFENDANT and Min - Woo Lee individually, jointly and severally, DEFENDANT and Min Kyung Lee individually, jointly and severally, DEFENDANT and Union Business Services, Inc. d/b/a Remington Deli. Corporation DEFENDANT COURT OF COMMON PLEAS, CUMBERLAND COUNTY 2008 No. b$ Itelto C, i vi l -TTam CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney, the original or a copy of which is attached to the compliant filed in this action, I appear for the Defendants and confess judgment in favor of the Plaintiff and against the Defendants as follows: Principal: $59,246.46 Lost Fees: $ 2,201.10 Interest: $ 584.40 Attorney Fees: $18,434.27 Total: $80,466.23 Kevin . Lutkins, Esq. Attorney for Defendants VERIFICATION The undersigned individual hereby states that he/she tis an he employee of the Pennsyl in thew Food Merchants Association with the authority to verify statements contained foregoing complaint involving its wholly owns also byes subsidiary, hams Express Min the Order Company. The undersigned individual the statements made aforementioned complaint are true and correct to the best is//htherein are made subject information the and belief. The undersigned understands that the statements penalties of 18 Pa. Cons. Stat. §4904 relating to unworn falsifications to authorities. David W. Bush Merchants Express money order Company, Inc. PLAINTIFF V. COURT OF COMMON PLEAS, CUMBERLAND COUNTY 2008 young - Ja Jung Individually, jointly and severally, DEFENDANT and Min - Woo Lee Individually, jointly and severally, DEFENDANT and Min Kyung Lee Individually, jointly and severally, DEFENDANT and Union Business Services, Inc. d/b/a Remington Deli. Corporation DEFENDANT No. COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY I . Plaintiff is Merchants Express Money Order Company, Inc. (hereinafter "MEMO"), a Pennsylvania Corporation wholly owned by the Pennsylvania Food Merchants Association that engages in the issuance and sale of money orders and whose address is 1029 Mumma Road, Wormleysburg, Pennsylvania, 17043. 2. Defendant Union Business Services, Inc. (hereinafter "Union"), is a corporation doing business as Remington Deli at 25736 AP Hill Boulevard, Port Royal, Virginia 22535. 3. Defendant Young - Ja Jung (hereinafter "Jung"), is an individual residing at 9434 Inaugural Drive, King George, VA 22485. 4. Defendant Min - Woo Lee (hereinafter "Woo"), is an individual residing at 9434 Inaugural Drive, King George, VA 22485. 5. Defendant Min Kyung Lee (hereinafter "Kyung" ), is an individual residing at 79434 Inaugural Drive, King George, VA 22485. 6. Defendants Jung, Woo and Kyung are the owners and/or operators of Defendant Union, and entered into the Trust Agreement on behalf of said Defendant and themselves on or about December 9, 2005. A true and correct COPY of the Trust Agreement under which Defendants Jung, Woo, Kyung, and Union are confessing judgment is attached hereto as Exhibit «A„ 7. Defendants Jung, Woo, and Kyung, with the intent to induce MEMO to enter into a Trust Agreement with Defendant Union, entered into the Personal Indemnity and Guaranty on or grabout December 9, 2005 and December 27, 2005. A true and correct copy of the Personal Indemnity and Guaranty under which Defendants Jung, Woo and Kyung are confessing Judgment is attached hereto as Exhibit "B". g. The forgoing judgment against Defendants Jung, Woo, Kyung, and Union, is not being entered by confession against a natural person in connection with a consumer credit transaction. 9. The Plaintiff has not assigned the Trust Agreement and Personal Indemnity and Guaranty under which judgment is being confessed. 10. The Plaintiff has not entered judgment against Defendants in any jurisdiction for the unpaid sum of $79,881.83 or any additional amount for a total of the debt demanded here. 11. The Defendants jointly and severally acted as selling agents for Plaintiff from on or about October 5, 2006 until February 25, 2008. 12. Pursuant to the Trust Agreement, Defendants are required to hold all monies received by them from the sale of money orders, including money order fees (hereinafter "trust funds"), separate and apart from other funds of the Defendant for collection by the Plaintiff through electronic or other means. ect the trust funds from Defendants on February 19, . The Plaintiff attempted to coil 13 2008 and February 21, 2008, through an Automated Clearing House (hereinafter "ACTT") method. 14. The Plaintiff, or its designated check-clearing banking center did not receive the a ment of the trust funds on February 20, 2008 and February 22, 2008 as required by the Trust pY Agreement and the Remittance by Electronic Funds Transfer agreement (hereinafter "Rider"). A true and correct copy of the Rider is attached hereto as part of the Trust Agreement in Exhibit "A" 15. The failure of Plaintiff or its designated check-clearing banking center to receive trust funds from the Defendants in accordance with the Trust Agreement and its Rider constitutes an event of default allowing plaintiff to enter judgment against Defendants. 16. Pursuant to the Trust Agreement, the plaintiff suffered damages by the Defendants conduct as follows: Principal: $59,246.46 Lost Fees: $ 2,201.10 Interest: $ 584.40 Attorney Fees: $18,434.27 Total: $80,466.23 17. Plaintiff demands judgment in the aforementioned amount as authorized by the warrant of Attorney contained in the Trust Agreement attached hereto as Exhibit A. 18. The Warrant of Attorney contained in the Trust Agreement is less than twenty (20) years old. WHEREFORE, Plaintiff demands judgment in the amount of $80,466.23 as authorized by the Warrant appearing in the attached Trust Agreement, together with Lost Fee Income, interest from the date of judgment and costs. Kevin . Lutkins, Esq. Attorney for Plaintiff Attorney ID: 76859 Merchants Express Money Order Company, Inc. PLAINTIFF V. Young - Ja Jung Individually, jointly and severally, DEFENDANT and Min - Woo Lee Individually, jointly and severally, DEFENDANT and Min Kyung Lee Individually, jointly and severally, DEFENDANT and Union Business Services, Inc. d/b/a Remington Deli. Corporation DEFENDANT COURT OF COMMON PLEAS, CUMBERLAND COUNTY 2008 No. 08 - I(QILP l.jvi l TerrA NOTICE ABOVE-CAPTIONED NOTICE IS GIVEN THAT A JUDGMENT AD AGAINST YOU. MATTER HAS BEEN PR THON If you have any questions concerning the above, please contact: Kevin M. Lutkins, Esq. Merchants Express Money Order Company 1029 Mumma Road P.O. Box 8863 Camp Hill, PA 17001-8863 (800) 543-8207 MERCHANTS EXPRESS MONEY ORDER COMPANY/MEMOMONEY ORDER COMPANY MERCHANTS EXPRESS USA' INC/ MEMOMONEY ORDERCOWANY OF NY, INC PERSONAL MONEY ORDERTRUSf AGREEMENT MEMO MO1?Y ORDER COdv1PANY, W. MEMO, MERCI/?NIS IF]IS AGREEMENT is made between MERCHANTS ES{pRE$$ MOI.IEY ORDER MANY d/b/a MEMO MEMO MONEY ORDER COMPANY OF NEW YORK, INC, d/b/a MEMO, a New York CArpomaaioa, or any subsidiary EXPRESS LEA, INC d/b/a MEMO, Pennsyhvama Corpo??om or dm as Trustee(s). d/b/a/ MEMO(1EM0r) andtbe individual(s) ard/ore?es iden?edbebw,hereafter referee as follavvs: In consideration of the mtual promises contaicred in t}nis agreemntand intending w be kBaIlYb01rOd ?' agree orders issued byMEMO. It is eapcecslyagieed that or thesale of m oney expressly described 1. Agency. MEMO appoints Tnntee to act as a special agent of MEMOateachof Trustee's retail establishmeits approved f venture or agenry ( than as relationship between the Parties shall not constitute a pammerskp. joint on the other, wthot haIlbe binding MEMO and Trustee shall be indep endent contracrors and that the 'rep orcorntrhimem of wrytkiod, ortalx auction, which s h accordance n the tams and con3iiom specified in this Agreement and in the attached Rider herein incorporate and be>*• Neither MEMO nor Trustee shall have the artbortym males any the prior consent of the other Party. Trustee accepts such ppo with I made a put hereof. orders delivered to Trustee by MEMO and all money woeiv ed byTnnroee from the sale of money Orders, 2. Trust Rektimbip. Trustee shall receive and bold in trust forMEMO all black money mist foods"). Tnatee shall hold the trout funds separate and apart from otl?ME to immediate g without limitation the moneyorder fees established byMEMO fnxn time to tone (" ME M0, be a breach of the Agreement: atalmg Pat from any other funds of the Trustee shall, at the option Hied and such other rarnedics, imiuding won of this Agreement, as failure of Tnntee to bold trust fords separate and 2 dersales from consumers have been depos possession of anyaocoumt or arcahms into which funds received for money or provided for bereio ayMEMO a fee ('Money order Fees' speafed in the attached rides Money Order Fees of the services rendered to Trustee by MEMO, Trustee shall p are provOrder Fees. Inconsideration 3. Macey g0 prior notice to Tnutee. m this Apeanent, MEMO will supply maybe modified upp MEEM0 the sole purpose selkvg ?Yo? Plmant Trustee withthe follawirg 4. Maoeriab Stipp by mbete A An adequate supplyof serially . the dblariltm a, lers. a mo order agenry _ and maintain ricy dispenser `Ihe money Order B. An agency msallation kE containing Pp training n ?'m.per -y y material dollar firmly into the money °rdnt so as to sinhibit the akeratim Of hall at allvines continueetto be the sole proper of MEMO C A moneyomder imp the quAy orders. Such moneyotder ivmprinters derdis not awnedbyMEMO and used byTnstee shall be prograr>mted byMEMO to indicate Truntee ID. numbs on or awaso installed b MEMO. Anyohis moneyor P Y and shall not be removed franthe Trustee's MEestablishment where igin to imprint mooeyonders taut be approved by materials, all of which Trustee agues to display at 21 times. notice, without at 111 reasonable times, to access Trustees premises and to D. RegU121tOrYPOstiriP, Sim, posters, y ? provision of this Agreement, MEMO shall have the r ,of, the cash receipts, Money order Fes, the accounting (sue) COPS of money with or 5 ? AccotiWing. cam its employees or agents to =P= and perform an accamnng ?? by MEMO when an audit a made due to TREWS experises orders sold and the Tnstee's inventory of unissued money orders. A change will. be assessed against Thistee to recover breach of this Agreement or if the audit disdoses a breach. (See audit fee/penakyfee schedule). 6. Rules and Regulatiow- Trustee shall corrtplywith the following le and ?om: Trustee cruised is manner for Trustee's own purposes, except as allowed byMEMO. A. No monEyorder shall be issued said to anyone orders in anyobkpraon any Tnstee to or for MEMO shall constitute a zerxz>ce to 1 issued or sold. No c heckor other pape<uans>? or deposited by B. Only cash shall be accepted as Pa}anen, for money y?h paper for collection. exercised in regard to money orders shall be at least as that MEMO until actuallycokcted, MEMO to have the option in each case as to whether to deposit any of cue The= c Tnutee shall safeguard all unissued money orders and the money order imprinter with the NghM tepee to the evert, Y ' O`"?' applicable to cash Trustee shall report to MEMO the serial member Of each money order stolen missing, a all other inform so information ordas being presenred, for payment to MEMO so that payment can be stopped on such missing ? event not later than twenty four (24) hours prior to the money le for all losses using from and shall ioderxmify hold the fact, but in any ?firned m writ,. Trustee shall be solely responsible T shall be respomrble f? repair or mepbwmm of money orders. Such report shall be tOr MSSi]3g ,milers u well u anymoneyonler mhpnmrens issued to Tnstee. F7ut > and ?y of T? shall not be limited byTnstee's any issued r more g arty cad all stolen err ey abuse, fire or otherwise. Said responsibility any ??, coder dispensers stole, or n or damaged as a result of rhisuae, negligence, compliamoe with the safeguarding, set forth in this parag?aph so that the funds MEMO as requested byMEMO. Tnareeshallconductoperathom r + and reporting °. ns anent f narrml information to a sound fi macal position provide opinion of a reasonable person to be in jeopardy and shall cease the issuance of money orders and W* D. Trustee shall at tall he e sale e o of f money orders will not be in jeopudy nor seen in the op coafua>ed in • "Sound Financial Condition shall generated from t hone and immhediately MEM0 mmdia*, should such jeopardy arise. 1Voof'can°n to MEMO shall be made promptly b or offs be the Trustee and that nether Trusree or anyGtnrutor has the butsiness, operations, widmon ( °r ° its bus l?P for the benefit of creditors, iasttuited a business, made a general assignment mean that there his been no material advise change in transaction of its become insolvent, gesherallyunable to pay is debts as they become due, im ohritanlpsuspended of relief described therein, insttute a proceedirig descnlxd m Panpaph 7B or consented proceeding described in Paragraph 7B or j cu possession anYsany ? for relief, al orran subs=" fits hosttured, or his taken any such official or all or any put of its property, whethher or not 'such proceeding . . to any such appointment or to the taking o possession by eery can shall also inchde when Trustee fails to pay, on the date which the same mthjue, any sum. esole discretion payable MEMO, hereunder of I action in f rherame c any of the foregoing. A lack of sound financial under conditions which, or fails to payits creditors generally. makes representations to MEMO orm other creditors throat it twat delay anysurh payment appears that Tnstee is no longer in a sound financial condition. m the ownership of either Tnstee's business, E. Trustee shall provide MEMO by facsimile transmittal or regist n mu7 threre (3) wre of eeks ar?e n sse s ou proposed th change(s) c.u,ir,Qon ? bu meas a?ed wit nterest or uamy . to or the management of 'Trustee's business, time sale of fift?one percent o T has ented into Transactions included within this p -graph 6(E) include transfer of stock of Trustee, sale of partnership, interests, limited liability company o Ptsucc similar transaction which effects a change in ownership or control of Tru No such transaction shall , shall be effective wtil ithout thespriornwrittten approval ofaMEMO. appropriate documentation, including a trust agreement. No transaction, discussed in this subparagraph Any attempt by Trustee to effect such a uansactron without MEMO approval shall be void, ab rntro as to MEMO. If Trustee farts to give such no oWation?.T of tu[he A r and the pformance of all well as its successor, shall remain liable for the pay bind Trustees successor orfassignee to the twits and condtrons of this Agreement. Any change assignment within the meaning of this parapap MEMO money orders. Tnatee mist provide MEMO with at lease 90 days nonce of those newly opened or acquired, Tnntee shall sell only F. At all of Tnstee's reran esablisbment i. and MEMO. Trustee shall not appoint and /or offer is intent to close its norm real location atYd to mopes s another b?f n? p? of business or future place of business as approved by G. Tnstee shall sell MEMO money orders only at Tnatee's spea6cally the services at or to uryenntyno a paityto this ageement: is agreemem Failure to do so shall constitute a breach of this ant- H Trustee shall remain open during the course of normal business hours for dur?nn of amycouut, eaoel?t fortis benefit of MEMO. 1. No Tunis pr` hibit byromiun shall be sub' to attachment .Lyf ,logoms and/or serum andtwihat MEMO's pot written count or mpesmatic by-d- frorn the date of this Ap-meat aid shall renew mtomatidfyfor successive five (5) }ear periods. After J. Trutsree is prohibited fromtmutlvorized use ofMEMdsname, ,tra tee this A>'?nt upon sixty (60) 7. Term of Agieernent The tern of this Agreement shall tun for a period of five (? }ear? six (6) nmorths prior written notice to MEMO, and MEMO may effect. e initial five-Seas tam of this Agreenment, Trustee maytaminate this Agreement ? F Trustee shall be responsible sble for lost fee income to MEMO for the duration of the coact in th n notice to Tnsree. In the event Trustee does no provide proper tag.matuen nonce, the fottgoiog, MEMO maytaminate this Agreement a anytime, or a?bcanoi CO` e? days t i written, shall be calculated using Tnstees mast recent 10-week sales r --age. l`1 Paragraph 11 hereof, upon the happening of any of the following events: immediately and without notice, and/or enter judgment according to the provisions agreement, ?,? order sales proceeds and. money ocher designated check-clearing banking center does not receive the accounting documentation or payment of ta ut funds (,d,* money A MEMO or its ?iad in the Rider to this Agreement i Lwlveny, or moratorium fees), within the time period and an the team spec art of insolvency, or upon the fulling by Trustee or any Guarantor nutter any bankruptcy, reorganvat n, B. Trustee or any Guarantor commits any Trustee under any bwkn>lxcystuzxe, or the ppcimment of a receiver or mstee m taint law, law for the relief Or, Orrelatirgmdebtorrorthe fl4Ofanyim?oh>otuyPdLb- against to or sale for or byanyaedaororgovernmental agency possession of the property or assets of Trustee; or the subjecrion of nyTnntee's property Or assets anylevy, seizure' assg u C Tire nonperformance! by Trustee of any obligations of Trustee pursuant to this Agreement. a default under any and all veemem of Trustee and/or Tine happening of any of the foregoing ever, shall be a default under this Agreement and withm -Y-6- fret MEMO' cAnstarxemespenshlmle for lost fee income to MEMO for the duration Tr stee% guarantor(s) with any other related conVaaY- I. the evert MEMO termnates this agreement due to a defau, Trustee shall be of the contract in effect _ otdeas order fees due MEMO, 10. 11 12. of this Agl=ieors Trustee immediately shall deliver to MEMO all cash receipts from the sale O mnep to rho Ag menu 'r'ev nor iclx Teaninatian Upon the expiration or tstrrvrrannon andall materials or doceasim proved to Tmsme by pr?? t of this t,- Agmeme t A n& b.Li anon any s ?piration or tempo arxotiumr>g{store) copies of moneYo?rs issued, the moneyorder unprtoner and cuns covenants, liabilities, and ixieranities of Trustee hereunder shall stall be effective as of the happening of any such event causing tecmirmon under paragraph 7 hereof or lirrr¢e d to, all blank money order f All o notice by MEMO for any reason other than the expiration of this Agreerrem this location or anybcaaion covered byt6is in agreernerit lmmediatelyterrri? tin Hof confessed not iudgroers, whn withstanding first occurs. of the agreement to the contrary, MEMO may or court ns would came MEMO oratry of its affliates to violate orI violate my" scats or federal law or regulation aoY A. In is sole discretion and not vv dattY? provision withthis agreement ert mo' the event MEMO determines that compliance count of record, upon orafterthe occurrence of any order, hwvocably au doxi s and empowers any attomey orthe Prothonotary or Ckdt of any sold ors to this Agreement, the applicable ession of Judgment: aiph 7, hereby' against Trustee for the face amount of all money orders p nrdgment exeed e:iglmeen percent (18%), and for any other suns due MEMO under this Agreement, event abdescnl)ed le Mo!,o in n Ordparager raph Fees, , to appear for and er confess es enter exp judgment se;ht (3096) of said amount and stain, for collection as provided herein not in exceed thirty percent: attorneys interest fees a together w of suit and reasonable thereon, legal fees enses and incurred cost o o in f any suit Ban and said d few exceed of Trustee. For such purpose, this Agreement or a copy hereof verified by affidavit by Trustee or on behalf of Trustee by said Bankruptcy The remedies of MEMO as provided herek and the warrants obtained herein shall be enforced in accordance with the including all ith expenses wiaedc' d shall be ussued siwarrant together at the sole discretion of MEMO and as often as occasion therefore shall occur. The f dl ue to ten r of Prothonotary or itt& and may be pursued singly, warrant a aive power to appear for and confess or enter judgment against beers of this Agreement Trustee any such right or remedy shall in exercise t cons and d the a waiver or e ?icise:d, flan time to time, as often as MEMO shall deem necessary and desirable, oble, and this son Trustee shall not be y exhaiusted hereof s by the initial enVaunt therefore. and same may Odgments may be confessed or entered in the same or different counties pat Agreement described a copy hereof shall be a sufficient nty jud t therefore. One more here a oJer s stricken or opened upon application by or on Trustee's behalf for any reaof the sorts over, the in this atparagraph. In torney or a the event any of entered agai red to again appear for and confess or enter judgment against only be done to cure ny etrtrrs in prior proceedings, and only and to the Trwhustatsoree; whatsoever, en hanyowecver, to wt, t)' thhee die Pro@wnotary or s of any court of record fessiis hereby on of judgment n ofmay and, limitation that such subsequent entry or con extent that such enots are subject to cure in the late proceedings. T, dl of Tnntees freedom from negligence or other fault, shall be absohaslyliable: A. To mare wider of the Liability . ale re rerrrm ttaanc ce t eto MEMO the fee amount of all money orders sold, the applicable Money Order Fees, and all ocher monies due MEMO at are subsequstbtly rnysteriotu or n?mystenous disappearance or lass of azryfunds fromTrtsaw's possession byreason ofthe honer or coo dishonest orders ers of delivered anypetson, as byME of MO God, to Trustee or otherwithse. of all suns of money that maybe e?°?, by or for MEMO in paying any neY r B. presented to MEMO the total amount liabie w the same. iris svbparag,aph shail ncit apply W auy nra,ey 01,1ta. • at to wIM61 T.,.Srex sh.' . a e fuuy ?x[furrrt>1 ptssnexi for payment, whether or iY:t ivt"MU is leggy pay judgrzients, assessments, fin-, Trustee's dories under this Ageernem liabilities, claims, actions, suits, proceedings, . Indemnity. Tnrntee shall d expenses (inclu and but hold h not ar fmlinnessed to, sextMOleitfrom ent ? a reasonable- legal and aocou mini fees) sustained by MEMO resulting from or arming out of my act or • and ? (vvhetknerfPeriotmanee) omissrion to castsace, , i wnthetherest,er honest, dishonest, (t, riegligeil or otherwise by Trustee orTnstee's employees, agents, associates or from conversion, bether wihhieren by g orwairhmas to tlveirscoMEMOpe a o of perfcnog security Secs MEMO as its agent, and m order to protect MWO s Property to create or perfect rity. AS further consideration °f appo ?t ts receivable, assignment of 1?, and fixtures at all Trustee locations. Trustee agrees to man all docusnents ' Security. interest in. Trustee s bank acocunt, inventory accounts MEMO reserves the e rigku to regerina additional such security interest, including, bus not limited to, WCOMW Uniform CDrsnetaal C'.ode-Fin2ncial Statement ( M(s)) fillings. Furthermore, usiness aura ri& t similar those set approval Thbtee and for the duration of the Agreement. In the event Trustee changes ownership m p b ,such transaction until such t time et the roceeds of collateral a it deems necessary for ongoing nee and approval byMEMO as sex feath therein, Trustee herebygr? a secunry forth in paragraph G(E) hereof, without prior and addressed as follows: an approved trust accost is re estab]shed communications under this Agreement shall be in writing an 13. Notices. Except as otherwise stated, all notices, correspondence, and IF TO-MLf;ME: See attached Rider IF TO ME 0. MEMO P.O. Box 8863 Camp Hill, PA 17001-8863 ruiles tt to the choice or conflict of hors. shall be construed trader ad in accordance with the hors the Cow Penmylwa h 11 bereof, in any other cant of record 14. Choice of Law. This ageesreot in Uunbedahd may, p a or, in the case of MBMCys exercise of tv bts under The parties consent sevenue and personal jutisdretion le to Trustees business and in Peaasy or elsewhere. ?p]oyees to abide by) all federal, state and )cal laws and regulations applicable and re.•gttiatio ; (d) 15. Compliance with law. Trustee shall abide by (ate cause its officers, principals and )- to bide b) and sit te?ula to an (c) Federal cash reportug to sire ru State services provided. The:yai a to include but are not limin to. (a) State Lirs? Laws; (b) state moneytransfer or sale of check laws and lregL? atio s (h all (e) Federal and/or State ar6morey laundering laws mid all rules and regulations; (f) all applicable ?Yd a state mpg requirements; iver or any breach or of any federal and pirvacylaws and regulations; (ln) the USAPauiot thAct- is or orits fortune to declare a default under this Agreement shall -a conscitits aw 16. No ision o this The freene of and shall not prejudice the r'k and/or power of MEMOto proceed as fullyas if it had not farted to enforce aryPrrn anon of this Ag etrrnem provision be t that MEMO shall, in addition to all tights it might have under the law, have the tight of seeking speied 17. Enforcement In the event of default under the reins of this !?geecrnent, Trustee agrees the ernforcerrrete of this Agrerroen< and/or the enforcement of -- performance in the taut n of I equity. Furthemtore, Z•n? agrees to consent to the jurisdiction of a court of a 4* regarding MEMO(s) rights in the evert of anydefauh byTnrstees. reasonable attomey?s fees incurred by MEMO in connection with the eof°rraro? of this 18. Cost of Enforcement. Trustee shall pay, on demand byMMMO, all costs and expenses including; the s;nguar shall be construed to include the phial where applicable and the masculine shall include all other genders. All covenants, A mrnt, Arenvor in 19. greemtrction. All rationsrces this Agreement; ih this assumed by Trustee shall be, and shall be deemed to be, joint and several convenaras. I loadings the P° of this Ageelnett are for it, convenience odynd do not brit t, exparid, or otherwise consmre the provisions or contents of this Agreement- and riders, related security documents and such stiles and regulations as tt be promulgated by MEMO for the issuance of to between the parties with 20. Entire a from This Ate, together with all attachments s between the parties hereto. There are not other agreements or tandentanditngs, written or oral, n?Y orders f from tinne cater of thssAgeeerrem constitute 'Ththe = ere slra b age modifications, amendmerxs, or Aeratiow to this Agr?t unless a? ro in writing, signed by? te parties. This Agreement is respect to the subject successors, represertatises and proper assign. MEMO and Trustee understand complexed shall bind and inure to the benefit of the parties, their respective beirs, as the otiginal. and the Rider. 21. Tire of the Essence. Time is of the essence in this Agnes YOU DO NOT PAY ON TIME, A COURT WARNING - SIGNING AE THIS PAPER, YOU TH G[VE UP YOUR RICOTT TO NOTICE , AND HCOURT E POTRIAL. FAULTY USED T , FAILURE F HIS YOUR GA MAY BE BE TAKEN AGAINST' YOU W AST THE CRED LED EWFIETAND MEROR RETURNED GOODS, BE USED TO AILURE FROM YOU REGARDLESS OF ANY CI-AIMS YOU U MAY HAVE PART TO LY WITH AGREEMENT, OR ANY OTHER CAUSE' TRLIS TEE t n 05, MERORPM Data fZ Al CAT?/S11=NameQPiQ0 ht?5i$45S SP.("QiZP-$ 2226-. XPRESS MONEY ORDERea"XviPANY/ YORDERCOMPANY/ Signanue Tale EXPRESS A, revs J M YORD Trustee S odividua? •- _ sf tee Sig>armpdivdtA Tna 1Byn "( Trustee ot„bff 13, 20Z Trustee Signatute(Iodrvd A MERCHANTS EXPRESS MONEY CORDER COMPANY MEMO MONEY ORDER MERCHANTS EXPRESS USA, OF NY, INC. MEMO MONEY ORDER COMPANY PERSONAL MONEY ORDER TRUST AGREEMENT REMITTANCE BY ELECTRONIC FUNDS TRANSFER taneo ith. This Rider is an integral part of the Personal Money Order Trust Agreement being executed by thewhenproperly exe used er both Any changes to this Rider shall serve as an authorized addendum to the original Trust Ag parties. TRUSTEE: Corporate/Business Name oo?? ?.?caG j State VA Zip Code- .2-:9-535 Street Address 2S 73q d ,O l-?ILI_&d• City Fax Number Agent Number l Z•7?" N ? Telephone Number LLC ? Partnership [ Sole Proprietorship Legal Entity: [J,,` Corporation MONEY ORDER FEES: Money Order fees shall be based upon the average weekly volume of 5.0 Money Orders sold by Trustee. Trustee's Q , G 9V Additionally, a money il selling price of $ Money Order fee shall be $ per item at a maximum reta -? er week/month shall apply plus applicable taxes. Weekly money order dispenser fees order dispenser fee of $ P shall be included with Trustee's last (if applicable) regulday ad draft. monthmoney order dispenser fees shall be include on the next regular weekly ACH draft following the last calendar y of The minimum monthly revenue generated by Trustee's account must equal $ per month. The difference between ill cal the minimum monthly revenue and a combination of per three °el? following the close ofra calendar monthsand will b drafted monthly, reported via debit transmittal nonce approximately one week thereafter as part of Trustee's regular ACH draft. Money Order fees may be modified by MERCHAI' S EXPRESS MONEY ORDER COMPANY, d/b/a MEMO, or MEMO MONEY ORDER COMPANY, d/b/a MEMO, MERCHANTS EXPRESS USA, INC. d/b/a MEMO, Pennsylvania Corporations, or Corporati t any ti MEMO MONEY ORDER COMPANY OF NEWMOORK,ri wINC, eek sales analysis Odicates per?tem weeklyvol (umelnotOco) aistent with upon thirty (30) days notice to Trustee or when ME MEMO's fee rate schedule. PROCEDURE FOR SALE OF MONEY ORDERS: Trustee shall sell money orders strictly pursuant to the following procedures: that mone A Trustee shall sell only MEMO money orders in each retail efLM? grated from such s, not beein jeopardy nor se mend secure at all times, and that such money orders along with the opinion of a reasonable person, to be in jeopardy, and shall cease the issuance of money orders and notify MEMO immediately, should such jeopardy arise. B. Trustee shall sell money orders in strict numerical sequence in accordance with the number printed on each blank money order. C. The face amount of any money order sold by Trustee shall not exceed the sum of $ 560-00 the mone D. Trustee shall not issue a money order until such time as d b andnnoeother imprinter, collected frolm the purchaser the f ce amoun of order, utilizing only the imprinter approved by MEMO the money order and an additional amount determined by Trustee's retail fee; and removed and retained the accounting (store) copy of the money order. E. If the money order imprinter is not in proper operating condition or properly inked, Trustee shall immediately report such fact to MEMO's Help Line at 1-800.8645246. hatever F. MEMO may deliver blank money EMO is or to receive agent,employee receipt for blank money orders on behalf of Trustee MEMO deems appropriate, and d TERMINATION: y agrees one Upon termination, cancellation, or breach of the Trust Agreement c won C tie Trus Thebtents in its po sessionmincluding but nonce by MEMO to forthwith return by next day US not limited to money order imprinting machines, all blank money order forms, the face amount and applicable money order fees due MEMO to date, and all other outstanding balances due MEMO, along with any other materials supplied to Trustee by MEMO in accordance with the Trust Agreement (hereinafter "Trust Property'). In the event that Trustee fails to return such items upon one appointe rustee ace days written demand, Trustee hereby authorizes MEMO Tti representatives hereine The costs of any repossession on by MEMO hall be borne business and peaceably obtain custody of all such Trust Property exclusively by the Trustee. TRUST FUNDS REMITTANCE: Any Trustee utilizing electronic money order dispensing equipment will be forwarded a weekly money order Sales Summary Report, prior to the close of he sales reporting day. The weekly money order Sales Summary Report will reflect money order sales for the applicable reporting period. SALES PERIOD: BEGINNING DAY 0-? ENDING DAY 14 Mini 5day REPORTING DAY ACH RE FCrclczu -rto v c--sa'6FL-1 ided all pertinent reporting information on the weekly money order Sales Summary Report. As per predetermined Trustee will be prov schedules, MEMO will initiate an electronic transfe runt to MENIO's bank acc1ountIf Trustee's method of remittance is via wire, funds d applicable fees due MEMO, from Trustee's bank acc Trustee will initiate a wire transfer of applicable mone0ybankr de paccountppr. r toh2:001 PM o theddesignat d remittance day,tee?'s money order Trust Account to the designated MEM Pos funds due MEMO must be included with remittance when ?? All outstanding t an ??tee statement barilssandue at this time must d/or bank accounts aseidinclude entified with remittance, including debits due MEMO and/or in the Trustee's EFT agreement, Trustee shall immediately inform MEMO of such change by telephone and promptly confirm in ot se y or writing. This arrangement shall not be revoked unless ?funds clue Obalances as notified byuMEMO.nAll voided money orders during the Sales Period, Trustee must still remit payment for outstanding o Trustee's account. If must be voided through the electronic money order dispenser ' g Trustee he sal ?iee NOT USED FOReP tURPOSE INTENDED" voided money order is not voided in the money order dispenser, write " on the backside the original money order and desit the ? forward money the original voided _money order to he MEMO offir eoand MEMO will on the face of the e original money order, Trustee s nser issue a refund to Trustee in he form of a replacement money on a order. daily b tis. shall If the electrthat onichrnoney ordermdisPenser does speot poll available for MEMO to electronically transmit polling rust consistently, Trustee must provide MEMO with hand aolwa ordro? ?? ot?e of ya Clear telephone line during electronic polling money order sales dispenser is always turned on ys P P transmission times. WEEKLY ACCOUNTING AND REMITTANCE: ,/ calculate a weekly money order On Qy1 ?( y and UT S[ 11 L? of each week, MEMO will C / onrcdree dthe weekly ispenser. MoMEMO ney Owill as statetransmission boveTrustee thesmoney sales total from d ' y data obtained from Trustee li Ton c poUing forward the weekly Money Order Sales Summary Report v Sales Summary Report with its records and inform MEMO of any differences. Trustee must retain he accounting (store) copies at its MEMO location for a period of three months from the rep°arse not requested deurinshall forward the g the three monhcretention(periodcTrustee shall discard office upon request. If the accounting (store) cop the accounting (store) copies at its own discretion. TRUSTEE MERCHANTS EXPRESS MONEY ORDER CO. MEMO MONEY ORDER COMPANY. MERCHANTS EXP USA, INC MERCHANTS EXP 4 SS ONEY ORDER MP Corporate/Store N=_m OA ?YfUi TIV"ignature Signature Title Title ?G i Gj -C Date _ Date Z- 1 < ? -L 19 4 NY ELECTRONIC. August 26, 2004 G, bra .B MERCHANTS EXPRESS MONEY ORDER COMPANY -MEMO MONEY ORDER COMPANY MERCHANTS EXPRESS USA, INC. - MEMO MONEY ORDER COMPANY OF NY, INC. PERSONAL INDEMNITY AND GUARANTY Intending to be legally bound hereby, and in order to induce MERC HANTS EXPRESS MONEY ORDER COMPANY, d/b/a/ MEMO, Pennsylvania MEMO MONEY ORDER COMPANY, d/b/a/ MEMO MERCHANTS EXPRESS USA, INC. d/b/a MEMO, Corporations, or MEMO MONEY ORDER COMPANY OF NEW YORK, INC, a New York Corporation, or any subsidiary d/b/a/ MEMO ("MEMO") to sign that certain Personal Money Order Trust Agreement, Rider and amendments or changes thereto as may be in effect from time to time (collectively the "A_"greement") with: Corporate/Business Name V411l od 1,1L1?/?1 S S D IL f Street Address9573tf Q0 t-t? 1 1 u OtY ?? ? l State_V_ Zip Code _2?5 and in consideration of its so doing, the Undersigned, jointly and severally, absolutely and unconditionally, personally guarantee and become surety for Trustee's full performance of the Agreement, including without limitation the prompt and punctual payment of all amounts becoming due from Trustee to MEMO thereunder, and shall indemnify and hold MEMO harmless against any and all damage, loss expense (including attorney's fees) and/or liability sustained by it by reason of or related to Trustee's failure to perform the Agreement. The Agreement may be modified by MEMO and Trustee without notice to the undersigned and without affecting this Guaranty. t which may enforce this Guaranty against the undersigned in the Court of Common Please of Cumberland County, Pennsylvania jurisdiction of said Court the Undersigned consents), as well as in any other court and state having jurisdiction, whether or not any action is ever taken by MEMO against Trustee. The Undersigned hereby waive all notices whatsoever with respect to this Guaranty except for notice of demand for payment from the Undersigned. The Undersigned hereby consent to the taking of, or the failure to take, from time to time without notice to the Undersigned, any action of any nature whatsoever with respect to the Agreement, including but not limited to any renewals, extensions, modifications, postponements, compromises, indulgences, waivers, surrenders exchanges, releases, and failure to pursue or preserve rights as provided herein, against any person, and the alll def nses shall remain fully liable hereon whatsoever to the Undersigned's liability hereunder except the defensescof (1) payment,, and (2) the Undersigned hereby w lack of notice as required in the Agreement. Upon default hereunder, the Undersigned hereby authorizes and empowers irrevocably the Prothonotary or any Clerk or any attorney of any court of record of Pennsylvania or elsewhere to appear for and to confess judgment against the Undersigned for all amounts due hereunder, plus all costs of suit, legal interest to date, and thirty percent (30%) added for attorney's fees, releasing errors, waiving stay of execution, and authorizing the immediate issue of a writ of execution, all in accordance with the Pennsylvania Rules of Civil Procedure. For such purpose, this Guaranty or a copy hereof verified by affidavit by the Undersigned or on behalf of the Undersigned by said Prothonotary, Clerk or attorney, shall be sufficient warrant. The authority and power to appear for and to confess or enter judgment against the Undersigned shall not be exhausted by the initial exercise thereof; the same may be exercised, from time to time, as often as MEMO shall deem necessary and desirable, and this Guaranty shall be a sufficient warrant therefor. The Undersigned acknowledge that by authorizing MEMO to confess judgment hereunder, the Undersigned have waived the right to notice in a prior judicial proceeding to determine their rights and liabilities. This Guaranty is given in connection with and evidences the obligation of the Undersigned to make payment in connection with a commercial transaction. This Guaranty is irrevocable and shall be binding and operative until such time as MEMO shall have been paid all sums owed to it under the Agreement and that may arise pursuant to this Guaranty. This Guaranty shall be governed by and construed in la-rs of the Corr yC^? e 1t>? of Perns;iva? a, disregarding any.: - rClg.na tC the choice OC COrf?1Ct of l'3R5. accordance with the b WARNING - BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHT TO NOTICE AND COURT TRIAL. IF YOU DO NOT PAY ON TIME, A COURT JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR KNOWLEDGE, AND THE POWER OF A COURT CAN BE USED TO COLLECT FROM YOU REGARDLESS OF ANY CLAIMS YOU MAY HAVE AGAINST THE CREDITOR, WHETHER FOR RETURNED GOODS, FAULTY GOODS, FAILURE ON HIS PART TO COMPLY WITH AGREEMEP T R AV(OTHE CAUSE. Guarantor's Signature Guarantor's Signature' HT, k<1'4"0 Lem lc? Print Guarantor's Name Print Spouse's Name 0143y- aa,5"g Dt . Home Address Home Address V 2,? 4(0 (City State Zip Code l???/oS City State Zip Code Date *If not married, please indicate by affixing "N/A" on line for second Guarantor's signature. rbvembu7.2002 MERCHANTS EXPRESS MONEY ORDER MEMO MONEY ORDER COMPANY OF NY, INC. MERCHANTS EXPRESS USA, INPERSONAL INDEMNITY AND GUARANTY Intending to be legally bound hereby, and in order to induce MERCHANTS EXPRESS MONEY ORDER COMPANY, d/b/a/ MEMO, MEMO MONEY ORDER COMPANY, d/b/a/ MEMO MERCHANTS EXPRESS USA, INC d/b/a MEMO, Pennsylvania orati Corporations, or MEMO MONEY ORDER COMPANY OF NEW YORK, INC, a New amendments ronchanges th , or any su to? d/be in MEMO ("MEMO") to sign that certain Personal Money order Trust Agreement, effect from time to time (collectively the "Agreement") with: Corporate/Business Name ???i100? ?U?l?11$ @ llC,?S? Street Addressj?? State Zip code 275.3 J ?31f ????? ' Caty?_ tee and and in consideration of its so doing, the Undersigned, jointly and severally, absolutely and unconditionally, personally guarantee all become surety for Trustee's full performance of the Agreement, including without limitation the prompt and punctual payment reason i f or and hold related to MO eh armless amounts becoming due from Trustee to MEMO thereunder, a bsi shall to perform the Agreement. gainst any and all loss expense (including attorney's fees) and/or liability by igne The Agreement maybe modified by MEMO and Trustee e without notice of c?°?on Please o f Cumberland County, Pthis O which may enforce this Guaranty against the undersigned jurisdiction of said Court the Undersigned consents), as well as in any other court and state having jurisdiction, whether or not any action is ever talkn by2.ficM0 agai ;st T:?.;;t- The Undersigned hereby waive all notices whatsoever with respect to this Guaranty except for notice of demand for payment from the with Undersigned. The Undersigned hereby consent t?s? respect ?go tof, or the he Agreemenincluding buno limited t any renewals?extensionse Undersigned, any action of any nature whatsoever modifications, postponements, compromises, indulgences, waivers, surrenders exchanges, releases, and failure to pursue or preserve fights in, of (1) payment, and against any person, and the Undersigned shall remain ully? Undersigned's liability hereunder excep?the dng.efExce the Undersigned hereby waive all defenses whatsoever of notice as required in the Agreement. bly the attorney Upon default hereunder, the Undersigned hereby aut wear for ana?o c nfess judgment against the Undersigneldrfo? all amounts d? any court of record of Pennsylvania or elsewhere to pp ing hereunder, plus all costs of suit, legal interest of a wriof? epercent xecution, all in ) cordance with the Pennsylvania Rule of Civil Procedure. execution, and authorizing the immediate For such purpose, this Guaranty or a copy hereof verified by affidavit by the Undersigned or on behalf of the Undersigned by said Prothonotary, Clerk or attorney, shall be sufficient warrant. The authority and power to appear for and to confess or enter judgment same exerci oft against the Undersigned shall not exhausted ?tGuant hall be a sufficientewanan herefor. The Undersig d acknowledge that by MEMO shall deem necessary and da esirable, and t ty s authorizing MEMO to confess judgment hereunder, the Undersigned have waived the right to notice in a prior judicial proceeding to determine their rights and liabilities. aymen connecti This Guaranty is given in connection with and evidences the obligation of the Undrsigned to and shall be binding and operative until such timme as ME Otshall have been paid all commercial transaction. This Guaranty is irrevocable • Guaranty shall be governed by and construed in sums owed to it under the Agreement and that may arise pursuant to this Guaranty. ies rs Guaranty ,o t ie choice o conflict of laws. accordance with the laws of the Commornmalth of Pennsylvania. disregarding • y g WARNING - BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHTY O N OTI O ANDO PRIOR SN. IF YOU D NAND PAY ON TIME, A COURT JUDGMENT MAY BE TARN AGAINST OTO COLLECT FROM YOU R RETURNED GOODS, REFAULTY GARDLESS OF ANY FAILUCLAM YOU RE N HIS PARTA O THE POWER OF A COURT CAN BE USED AGAINST' THE CREDITOR, WHETHER COMPLY WITH AGREEMENT, OR ANY HER CAUSE. Guarantor's Signature Guarantor's Signature NGn-Woo Lee- Print Spouse's Name Print Guagrantor's Name `f3 4 Lo`U u Home Address Home Address 'n ?Z?fB O State Zip Code CityState Zip Code tY 0- 7 Date Date **If not married, please indicate by affixing "N/A" online for second Guarantor's signature. rbvemb?7.2002 MERCHANTS EXPRESS MONEY ORDER COMPANY - MEMO MONEY ORDER COMPANY MERCHANTS EXPRESS ONAL INDEMNITYOANMONEY ORDER D GUARANTY?MPANY OF NY, INC. PE Intending to be legally bound hereby, and in order to induce MERCEANTS EXPRESS MONEY ORDER COMPANY, d/b/a/ MEMO, MEMO MONEY ORDER COMPANY, d/b/a/ MEMO MERCHAN S EXPRESS USA, INC: d/b/a MEMO, Corporations, or MEMO MONEY ORDER COMPANY OF NEW YORK, INC, a New York Corporation, or any subsidiary d/b/a/ MEMO ("MEMO") to sign that certain Personal Money Order Trust Agreement, Rider and amendments or changes thereto as may be in effect from time to time (collectively the "Agreement") with: Corporate/Business Name 60 6 ©0 &-L5i d t ?- ,- d 7c--7 q .4V JJi // ,'?Ucl • city State t1,4 zip code Z?? Street Ad ress - and in consideration of its so doing, the Undersigned, jointly and severally, absolutely and unconditionally, personally guarantee and become surety for Trustee's full performance of the Agreement, including without limitation the prompt and punctual payment of all amounts becoming due from Trustee to MEMO thereunder, and shall indemnify and hold MEMO harmless against any and all damage, loss expense (including attorneys fees) and/or liability sustained by it by reason of or related to Trustee's failure to perform the Agreement. The Agreement maybe modified by MEMO and Trustee without notice to the undersigned and without affecting this Guaty.tMEMO may enforce this Guaranty against the undersigned in the Court of Common Please of Cumberland County, Pennsylvania jurisdiction of said Court the Undersigned consents), as well as in any other court and state having jurisdiction, whether or not any action is ever taken by MEMO against Trustee. The Undersigned hereby waive all notices whatsoever with respect to this Guaranty except for notice of demand for payment from the Undersigned. The Undersigned hereby consent to the taking of, or the failure to take, from time to time without notice to the Undersigned, any action of any nature whatsoever with respect to the Agreement, including but not limited to any renewals, extensions, modifications, postponements, compromises, indulgences, waivers, surrenders exchanges, releases, and failure to pursue or preserve rights against any person, and the Undersigned shall remain fully liable hereon notwithstanding any of the foregoing. Except as provided herein, the Undersigned hereby waive all defenses whatsoever to the Undersigned's liability hereunder except the defenses of (1) payment, and (2) lack of notice as required in the Agreement. Upon default hereunder, the Undersigned hereby authorizes and empowers irrevocably the Prothonotary or any Clerk or any attorney of any court of record of Pennsylvania or elsewhere to appear for and to confess judgment against the Undersigned for all amounts due hereunder, plus all costs of suit, legal interest to date, and thirty percent (30%) added for attorney's fees, releasing errors, waiving stay of execution, and authorizing the immediate issue of a writ of execution, all in accordance with the Pennsylvania Rules of Civil Procedure. For such purpose, this Guaranty or a copy hereof verified by affidavit by the Undersigned or on behalf of the Undersigned by said Prothonotary, Clerk or attorney, shall be sufficient warrant. The authority and power to appear for and to confess or enter judgment against the Undersigned shall not be exhausted by the initial exercise thereof; the same may be exercised, from time to time, as often as MEMO shall deem necessary and desirable, and this Guaranty shall be a sufficient warrant therefor. The Undersigned acknowledge that by authorizing MEMO to confess judgment hereunder, the Undersigned have waived the right to notice in a prior judicial proceeding to determine their rights and liabilities. This Guaranty is given in connection with and evidences the obligation of the Undersigned to make payment in connection with a commercial transaction. This Guaranty is irrevocable and shall be binding and operative until such time as MEMO shall have been paid all sums owed to it underoAhre Caemmonwealt of Pennsylvania, disrepardinQ an rules relatinng ° he chobce o? conflicbof 1 d?construed in accordance with the la WARNING - BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHT TO NOTICE AND COURT TRIAL. IF YOU DO NOT PAY ON TIME, A COURT JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR KNOWLEDGE, AND THE POWER OF WHETHER FOR RETURNED GOODS, FAULTY GOODS, FAILURE ON HIS PARTA O AGAINST THE CREDITOR, RCAUSE. COMPLY ? ?_ E ? ??? 0 Guarantor's ignature Guarantor's Signature Al ©? Print Guarantor's Name g (3 4 a L Home Address ?9 City State ZIP Code Date I Print Spouse's Name Home Address City State Zip Code Date *If not married, please indicate by affixing "N/A" on line for second Guarantor's signature. rbvemb? 7.2002 C"7 r.a T,7 t --{ O , o z 1029 MUMMA ROAD • PO. BOX 8863 I CAMP HILL. PENNSYLVANIA 1 700 1-8863 www memoco. com i 4 c as ?. e Z' ? `1 C N r= O -n 77 ry ?r .* o{` L 0 r r r' r..._ t,3 zz o Merchants Express Money Order Company, Inc. PLAINTIFF V. Young - Ja Jung individually, jointly and severally, DEFENDANT and Min - Woo Lee Individually, jointly and severally, DEFENDANT and Min Kyung Lee Individually, jointly and severally, DEFENDANT and Union Business Services, Inc. d/b/a Remington Deli. Corporation DEFENDANT COURT OF COMMON PLEAS, CUMBERLAND COUNTY 2008 No. b%- 11alia- 0,i v. ( Term rl 47- C.: NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE-CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. P THONG If you have any questions concerning the above, please contact: Kevin M. Lutkins, Esq. Merchants Express Money Order Company 1029 Mumma Road P.O. Box 8863 Camp Hill, PA 17001-8863 (800) 543-8207 Q c? eyi CL. N M t ?S , v ?1 - I ±® ;yl ky v E999-1o0Lt VINVA7ASNN3d '771HdWVo cm X08 'od • oVOtl VAM#V wol Merchants Express Money Order Company, Inc. PLAINT= V. Young - Ja Jung Individually, jointly and severally, DEFENDANT and Min - Woo Lee Individually, jointly and severally, DEFENDANT and Min Kyung Lee Individually, jointly and severally, DEFENDANT and Union Business Services, Inc. d/b/a Remington Deli. Corporation DEFENDANT COURT OF COMMON PLEAS, CUMBERLAND COUNTY 2008 No. 08 - l Civi l -Ferw 0 rn NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE-CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. l , zf i6l[1439W P THON Y If you have any questions concerning the above, please contact: Kevin M. Lutkins, Esq. Merchants Express Money Order Company 1029 Mumma Road P.O. Box 8863 Camp Hill, PA 17001-8863 (800) 543-8207 r-1) c"> _ CF C=t -y r.7 r ? x' w :t th WOD'ODOU/BUIS *tm E9MIOOL I VINVAIASNN3d '"H dMVO me XOB "O d • OYOH Vrwn owl S.MWW CMWAWaWW 933WAMM MOM" SUAMM MK7 Merchants Express COURT OF COMMON PLEAS, Money Order Company, Inc. CUMBERLAND COUNTY PLAINTIFF V. Young - Ja Jung 2 2008 Individually, jointly and severally, DEFENDANT C 1 ler?? and iv No. CS - [(,2 (to Min - Woo Lee Individually, jointly and severally, DEFENDANT and c o Min Kyung Lee , Individually, jointly and severally, DEFENDANT * a?.' = - 4s and Union Business Services, Inc. d/b/a = - = r ? t Remington Deli. _ Corporation DEFENDANT -c NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE-CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. PR ONOT If you have any questions concerning the above, please contact: Kevin M. Lutkins, Esq. Merchants Express Money Order Company 1029 Mumma Road P.O. Box 8863 Camp Hill, PA 17001-8863 (800) 543-8207