The URL can be used to link to this page

Home My WebLink About08-2727ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7159 Attornev for Plaintiff PRIME RATE PREMIUM FINANCE IN THE COURT OF COMMON PLEAS CORP., INC. CUMBERLAND COUNTY, PA Plaintiff Olvft NO. TetM? v BANGKOK WOK, INC. CIVIL ACTION - LAW Defendant 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 AVISO 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 PRIME RATE PREMIUM FINANCE IN THE COURT OF COMMON PLEAS CORP., INC. CUMBERLAND COUNTY, PA Plaintiff -77- NO. OP-2 -7 ?..` v BANGKOK WOK, INC. CIVIL ACTION - LAW Defendant COMPLAINT The Plaintiff, PRIME RATE PREMIUM FINANCE CORPORATION, INC., by its attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of THREE THOUSAND THIRTY-ONE DOLLARS AND SIXTY-THREE CENTS ($3,031.63), along with interest thereon at the rate of 20.75% from April 16, 2007, as set forth herein, upon a cause of action of which the following is a statement: 1. The Plaintiff, PRIME RATE PREMIUM FINANCE CORPORATION, INC., is a corporation organized and existing under the laws of the State of South Carolina, having its principal office and place of business at 2141 Enterprise Drive, Florence, South Carolina 29501-0507. 2. The Defendant, BANGKOK WOK, INC., is a corporation organized and existing underthe laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 125 Gateway Drive, Suite 111, Mechanicsburg, Cumberland F:\USER\ROBMCCP&DJ CMPS\CCP COMPLAINTS\PRIME RATE INS. CO\PRIMERATE33563.wpd: 2 County, Pennsylvania 17050. 3. On or about April 8, 2005, the Defendant entered into a Premium Service Agreement with Plaintiff for financing of insurance coverage. A true and correct copy of said Premium Service Agreement is attached hereto, marked Exhibit "A" and made a part hereof. 4. The price charged for said financing was just and reasonable, was the legal and market price therefor and was the price which the Defendant contractually promised and agreed to pay to Plaintiff. 5. The Defendant defaulted on its obligation to make payments, and refused to honor the remaining installment payments. Based upon Defendant's default Plaintiff issued a Notice of Intent to Cancel dated May 24, 2005 and a Notice of Cancellation dated June 9, 2005, true and correct copies of which are attached hereto, collectively marked Exhibit "B" and made a part hereof. 6. The balance due and owing by Defendant to Plaintiff is the sum of Two Thousand Five Hundred Twenty-Six Dollars and Thirty-Six Cents ($2,526.36) as appears by Plaintiffs Statement of Account hereto attached, marked as Exhibit "C" and made a part hereof. 7. Due to the default of Defendant, and pursuant to the provisions of the Premium Service Agreement at Exhibit "A", attorney's fees in the total amount of Five Hundred Five Dollars and Twenty-Seven Cents ($505.27) have been added to said account. 8. Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount, or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of THREE THOUSAND THIRTY-ONE DOLLARS AND SIXTY-THREE CENTS ($3,031.63), along with interest thereon as set forth herein. Respectfully submitted, KODAK & IMB OW. 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 h/ Hpr, 11 05 04:37p PRIME RATE PREMIUM FINANCE CORPORATION, INC. 2141 Enterprise Dr. P.O. Box 100507 www.primeratepfc.com Florence, South Carolina 29501-0507 Phone: (800) 777-7458 Insured's Name: Bangkok Wok, Inc. Submitting Agent Broker: 125 Gateway Drive - MECHANICSBURG, PA 17050 I ? 61 q;X PREMIUM SERVICE AGREEMENT ACCOUNT NO. PA - 149999 George R. Flinn Insurance 1085;' 19027 Rosewood Drive STEWARTSTOWN, PA 17363 (717) 993-5183 Release Date: 04108/2005 Quote: Policy Eff. _ Date Term ` Name of lnsurance Company or General Agent ! T of i Policy Number - - or Policy issuing Agent R Cod erage i Total Premium 04/010-005 12 04/01/2005: 12 i CPP0116080 DONEGAL MUTUAL INS CO CA 0118 1587 Y ; 54 COMM P>CK $9,580.00 04/01/2005 12 682 02 DONEGAL MUTUAL INS CO I WC 0030924 02 'DONEGAL MUTUAL INS CO 1'587 Y ; 89 BAP 1587 $1,055.00 Y 51 WC-STD/ $3,702.00 Creditor: Prime Rate Premium_ Finance Corporation, Inc. Federal Truth In Lending Disclosures (A) Total T (B) Cash (C) Amount Financed (D) Finance Charge (E) Total of payments paym (F) Annual Premiums Down (The amount of credit (The dollar amount the (The amount you will have Percentage Rate ! Payment provided to you or on credit will cost you) paid after you have made all (The cost of your credit ' your behalf) payment as scheduled) as a yearly rate) $14,337.00 52,521.00 $11,816.00 ' $1,044.91 $12,860.91 20.75% Your PAYMENT SCHEDULE will be: "Includes a non-refundable You have the right to receive an ..._.... service charge. of $10.00 Itemization of the Amount Financed No. of Payments ; . Amount of Payments , When Payments Are Due , )( I want an Itemization r On the 1 Day of each month, I I do not want an Itemization ....... S 1•ti428.99 ! 'Beginning -20qA ?. ...._. _ _ __ Security: You are giving a security in e-rest in the under a premium(s) due under the policy(ics) being purchased. - Late Charge: You will be charged 5% of the payment, subject to a minimum charge of S 1.00 on any payment received more than 5 days after the due date. Prepayment: If you pay off early, you may be entitled to a refund of part of the finance charge. See Above and on next page of this document for any additional information about non-payment default, any repayment in full before the scheduled date, and prepayment refunds and penalties. Would you prefer your monthly payment debited from your checking account? -Yes Complete appropriate form _ No In consideration of the payment(s) to be made by PRIME RATE ("PR") to the above insurance companies ("Insurer(s)'), their agents or representatives, the UNDERSIGNED INSURED (jointly and severally if more than one): (1) Promises to pay to the order of PR at the above address, the Total Payments in accordance with the Payment Schedule set forth in the above Truth-in-Lending Disclosures. (2) Irrevocably appoints PR as Attorney-In-Fact with full authority to effect cancellation of the policies covered hereby or amendment g thereof in accordance with the provisions herein, to receive all sums assigned to PR, to execute and deliver on behalf of the undersigned all z documents, forms and notices relating to the policies covered hereby in furtherance of this agreement, and to execute subsequent premium finance agreements pertaining to the renewal of the policies stated above upon payment by the insured ofthe required down payment for the g renewal period. The Power of Attorney is coupled with an interest and the powers given herein may be exercised by the Attorney-in-Fact, ° or its successors and assigns. 2 (3) Acknowledges that they have received a copy of page 2 of this agreement and if the borrower is a consumer, the undersigned acknowledges that they have received a copy of PR's Privacy Statement. (Paragraphs (4) to (17) on the Following Page) THE UNDERSIGNED AGREES TO THE PROVISIONS ABOVE AND ON THE FOLLOWING PAGE NOTICE: A. Do not sign this Agreement before you read it or if it contains blank spaces. B. You are entitled to a copy of this Agreement 4 at the t* sign. Ke your c p o i Agreement to protect your legal rights. and a xecute his an eceived 7 a co ttyereof tlys 8 day of April 2005 Signature Of nsu ( o c!'er) DATES / /Signature Of Insured (must be 18 or older) DATE All insureds designated in the policies t sign. If insured is a corp., or partnership, an authorized officer or general partner must sign. ,PRODUCER'S REPRESENTAT S• ?, r g undersigned agent has read a Insuran s Ctertifi to ` ollowing page and make;,alls a ese?tabons and ;warranties recited therein. By 1 Date '? d v/ .%I: ....... ...-... ...... - -- PRODUCER'S CERTIFICATION The Producer represents that the insurance policies listed upon this agreement are in force, that the premiums therefore are correct and tb the insured has received a copy of this agreement. The agent further represents that all PR guidelines have been followed in respect to tl financing of policies listed on this contract. REMAINING PROVISIONS OF YOUR PREMIUM SERVICE AGREEMENT (4) Assigns to PR as security for the total amount payable hereunder any and all unearned or return premiums and dividends which mE become payable under the insurance policies scheduled or covered by this Agreement ("Policies") and loss payments under said policit which reduce the unearned premiums (subject, .however, to any loss payee or mortgagee interests), and hereby authorize and instruct m insurer(s) to pay such funds or proceeds to PR. (5) Agrees in the event of a default in payment of any installment due hereunder, or upon failure by the undersigned to comply with any c the terms or conditions hereof, and after a fifteen day notice is mailed to the insured, the unpaid balance due hereunder shall be immediatel due and payable. In such event, PR may cancel the policies covered hereby. (6) Agrees that any payments received by PR subsequent to the expiration of any notice of intended cancellation, will only be accepted fo credit to the undersigned's account and shall not constitute reinstatement or obligate PR to withhold cancellation of any insurance policy Any sum received from an insurer shall be credited to the undersigned's indebtedness to PR, any surplus will be returned within 60 days o the cancellation date. In case of a deficiency greater than or equal to $5.00, the undersigned shall remain liable and pay the same wit] interest after maturity at the maximum legal rate. (7) May prepay the full amount due and under certain conditions be entitled to receive a partial refund of the FINANCE CHARGI (computed in accordance with the method prescribed by regulatory authority of the state of jurisdiction) after deducting any fully earnec charge permitted by state law. If the refund is less than the minimum refund amount as stated by law in the State of Pennsylvania, nc refund will be made. (8) Understands that the FINANCE CHARGE begins to accrue as of the earliest of the Policy Effective Date, the date of this Agreement, or any other date prescribed by state law("Finance Charge Accrual Date"). (9) Authorizes PR to correct obvious errors in the completion of this. agreement; the undersigned will be notified at the address shown hereon of any change or correction to this agreement. (10) Warrants that each of the policies covered hereunder (or a binder thereof) has been issued to the undersigned, is in full force and effect and that no other power of attorney or other encumbrance or assignment is in effect nor will same be put into effect, except for the interest of mortgagees or loss payees, and agrees that all rights conferred upon PR shall inure to PR's successors or assigns. (11)Agrees, that in the event the total premiums are greater than that shown hereon, this agreement may be amended and/or refinanced to reflect the actual premiums and the undersigned will either (i) pay the difference in premium due, or (ii) pay any required additional down payment and any additional finance charge permitted by law; in such event PR will forward the undersigned a revision notice showing all information required by law. It is agreed and understood that in the event of default in the payment of any installment, or payment within 31 days from the billing date of any additional premium, and after notice has been given as required by law, PR may cancel the policies covered hereby. (12) Agrees that (i) PR assumes no liability as an insurer, (ii) this agreement shall not be effective until accepted by PR, (iii) singular words used herein shall be deemed plural and vice versa as the sense of the agreement demands, (iv) if any court of competent jurisdiction finds any part or provision of this agreement to be invalid or unenforceable, such findings shall not affect any other part or provision. (13) Agrees with respect to any auditor reporting form policy covered hereby, in the event of default hereunder, to be liable to the insurer for the earned premiums (computed in accordance with the policy provisions) remaining due after crediting payment(s) made to the insurer with respect to such policy, including such payment (s) made by PR to the insurer, less any amount refunded to PR by the insurer and credited by PR to the balance due hereunder but only for deficiencies greater or equal to- $5:00: (14) The maximum fee allowed by state statute shall- be charged for each check returned to PR because the drawer has insufficient funds or no account in the payor's bank. (15) Agrees that any refunds may be applied against prior deficiencies owed PR (16) Agrees that a $5.00 Administration Fee will be applied to any refund check that falls under the Abandoned Property Procedures. (17) Agrees to pay reasonable attorney's fees and or collection agency'fees and all other costs of collection if this contract is referred for collection to any attorney or collection agency not a salaried employee of PR. NOTICE: SEE PREVIOUS PAGE FOR IM[PORTANT INFORMATION PA 08/02 Prime Rate Premium Finance Corporation, Inc. Electronic Funds Transfer (EFT) Pre-authorized Payment Agreement To Enroll: Read the Terms and Conditions and complete the form below. Please attach a voided check from the account you will be using to make your payments. /NC- Name Account Number This is my auth zation to Prime Rate Premium Finance Corporation, Inc., 57-0785141, to automatically debit my =hecking Savings account # 1039197,11 03/3 a 29 S%5- At Tej Bank Transit Number Financial Institution G 49 State I have read and agree to 5?49- 6 8- yS7L Social Security Number n X Date termsAnd conditions below. APR + -d 141 . TPrma..an? f nsdainne•_ ?• may- - .., . . _ _ . ..? ... ... ._ ' 8311 by ' BANGKOK WOK PH. 717-795-7292 sn 125 GATEWAY DRIVE MECHANICSBURG, PA 50 /111 313 DATE $ TO THE ?- f late, Z;e ORDER OF pp DOLLARS u .-. _ Ind ®MOBank = FOR _ --? 118008 3 1 IV +40 3 130 2 9 5 SI: L0'398 79 LII' unt entry credited to your account by your Financial Institution, if, within 15 days following the date on which you were sent a statement of account or a written notice of such entry or 45 days after posting, whichever occurs first, you give your Financial Institution a written notice identifying the entry, statin that it is in error and requesting credit back to your account. S 5 1 4/15- Please /nail this form along with your voided check attacked to: Prime Rate Premium Finance Corporation, Inc. ATTN: Cory Pickett PO Box 100507 Florence, SC 29501 Revised 04108103 API9PTPA1499596IMIQiT NOT NOTICE OF INTENT TO CANCEL LICENSE NO. ACCOUNT NUMBER PA 1499586 DATE MAILED 05/24/2005 Fj N W Your installment in the amount of $1,428.99 has not been received. This payment was due on 05/01/2005 . $71.45 LATE CHARGE MUST BE ADDED TO YOUR INSTALLMENT. TOTAL NOW DUE IS $1,596.89 . Because of your failure to make patyrnent f the amo t due rder your premium fin?n a (service) agreement with our company, we shall reques and a ect cancellation o your insurance pohcx(ies?, pursuant to the ower of attorney si ed !A you)u less the amount now due, shown below, is received in our office within pl 5 days from the mai?lmg te of this invoice. IMPORTANT NOTICE TO INSURED: If the purpose of this loan was the financing of automobile liability insuranq , then it is youl statutory duty to replace such insurance on or before the date of cancellation, i the motor vehicle is to continue being licensed in this state. If the amount shown differs from what you expected, please consider these possible reasons: 1. Your payment and our notice crossed m e mail. 2. The amount you paid was not your correct payment. (Please check your records) TO INSURE PROPER CREDIT, PLEASE USE ATTACHED COUPON. Prime Rate Premium Finance Corporation, Inc. 2141 Enterpprise Drive P.O. Box 1D0507 Florence, S.C. 29501-0507 Telephone (843) 669-0937 4---------------------------------------------------------------------------------- Prime Rate Premium Finance Corporation, Inc. PRESORTED P.O. Box 100507 Florence, S.C. 29501-0507 FIRST-CLASS MAIL U.S. POSTAGE PAID Return Service Requested FLORENCE, SC PERMIT NO. 21 H F' W PA 1499586 BANGKOK WOK INC 125 GATEWAY DR MECHANICSBURG PA 17050-2905 APIS"PA1699566CJ ZL-INS PRIME RATE PREMIUM FINANCE CORPORATION, INC. 2141 Enterprise Drive P.O. Box 100507 Florence,South Carolina 29501-0507 Phone (843) 669-0937 NOTICE OF CANCELLATION LICENSE NO. ACCOUNT NUMBER DATE MAILED CANCELLATION DATE PA 1499586 06/09/2005 06/14/2005 INSTALLMENT DUE NOW ACCOUNT BALANCE $2,954.43 $12,957.36 Please cancel the below described olicy(ies) for non-payment of an installment in accordance with the terms and conditions of the insures premium fmance (service) agreement with this company which incorporates a power of attorney executed pursuant to Pennsylvania Statue 40 P. S. 3310, as amended. Pennsylvania law recognizes this as a valid notice of cancellation and provides that the gross unearned premi be returned to our company at the above address within 60 days of the effective date of cancellation for distribution. Warranted that 15 days written notice of our intent to cancel subject policy has been furnished to the insured, and to the insurance a ent or broker when required by law: fhat copy hereof has been mailed to the insured at insured's last adsess as set forth in this company's records. Cancellation to be effective on the above captioned date or as soon thereafter as statutory, regulatory or contractual restrictions permit. NOTICE TO INSURED: In order o sto cancellation, please pay. this amount $ 2 9 5 3 by the date shown above. This cancellation 1nAormation is being to your insurance com?anyties . You have the right to avoid cancellation o your coverage if tlie payment of indebtedness-balance ue is received by this premium service company at the above address on or before 06/14/20 05 IMPQRTANT NOTICE. TO INSURED: If the purpose of this loan was the financ' g of automobile liability insurance, then it is our statutory duty to replace such insurance on or beore the date of cancellation, if the motor vehicle is to continue being licensed in this state. If the amount shown differs from what you expected, please consider these possible reasons: 1. Your payment and our notice crossed in the mail. 2. The amount you paid was not your correct payment. (Please check your records) AGENT: PA01085 GEORGE L FLINN INS AGY POLICY NUMBER: WC 0030924 02 DONEGAL MUTUAL INS CO 01587 ATTN:ACCOUNTING 1195 RIVER RDL PO BOX 302 MARIETTA PA 177547 Prime Rate Premium Finance Corporation, Inc. P.O. Box 100507 Florence, S.C. 29501-0507 Return Service Requested POLICY NUMBER: PRESORTED FIRST-CLASS MAIL U.S. POSTAGE PAID FLORENCE,SC PERMIT NO. 21 Ln 1P Ln PA 1499586 BANGKOK WOK INC 125 GATEWAY DR MECHANICSBURG PA 17050-2905 Page: 1 Document Name: untitled R136-F 17:30:44 RECOVERY MANAGEMENT SYSTEM B90141 ACTIVE BBT1 Financial Transactions From: To: Acct...: 01380001499586 Birthdate.: Tax No.: 00-0000000 Comaker Count: 00 Status....: Name...: BANGKOK WOK INC Loan Type.: Address: 125 GATEWAY DR STE 111 Recoverer.: Address: Lst Pmt Dt: City...: MECHANICSBURG State: PA Lst Paymnt: Ph(Ho).: 0000000000 Zip..: 17050 Commiss..o: Ph(Off): Cnty.: Interest %: Date Code Description Post ed Amount 08/03/06 62810 ADJUSTMENT 594.00 08/03/06 02810 SYSTEM-RECOVERY ON PRIN CIPAL 594.00 04/28/06 14P03 PRIME RATE CHARGE OFF 3,120.36 ** END OF TRANSACTIONS PF Keys: 3=Prev 4=Next Acct 7=Back 8=Fwd 16=Post Dt Date: 3/16/2007 Time: 5:30:49 PM 03/16/07 REL6.1.0 500 0276 1403 08/03/06 594.00 .00 .00 Balance 2,526.36 'Ok 3,120.36 FEB-11-2008 11:19 KNUPP KODAK & IMBLUM 717 239 7158 P.07 VERIFICATION Donna Baldwin, Banking Officer, BB&T agent (name) (twe) of PRIME RATE PREMIUM FINANCE CORPORATION, INC., verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities. PRIME RATE PREMIUM FINANCE CORPORATION, INC. By: Title: Banking Officer Dated: a // 31®e 33563 TOTAL P.07 c'x A ?7. 73 c: ?r v / 7? W O CD 09 7 0 Y f"' r ! `rk a O SHERIFF'S RETURN - REGULAR CASE NO: 2008-02727 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRIME RATE ?REMIUM FINANCE COR VS BANGKOK WOKIINC -TTY TT TT' T Cumberland ounty,Pennsylvania, who being duly sworn according to law, says, the w thin COMPLAINT & NOTICE was served upon BANGKOK WOK INC the DEFENDANT , at 1400:00 HOURS, on the 30th day of April , 2008 at 125 GATEWAY DRIVE STE 111 MECHANICSBURG, PA 17050 BONNIE ESTILL, MANAGER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof Sheriff's Cc Docketing Service Postage Surcharge /, ,'/071 ` ts. 18.00 12.00 .58 10.00 ?J ! .00 %``' ? 40.58 Sheriff or Deputy Sheriff of by handing to ADULT IN CHARGE So Answers: R. Thomas Kline 05/01/2008 KODAK & IMBLUM Sworn and Subscibed to before me this of By: day Deputy Sheriff A. D. PRIME RATE PREMIUM FINANCE CORP., INC. Plaintiff v BANGKOK WOK, INC. Defendant IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA NO. 08-2727 CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter as settled and discontinued with prejudice. TO: Cumberland County Prothonotary Dated: May 5, 2008 Robert D. Kodak, Esquire Attorney for Plaintiff Attorney I.D. No. 18041 na -t c`;: j ? ?? .. s- r.,a