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Home My WebLink About04-1299David J. Lanza I.D. No. 55782 2157 Market Street Camp Hill, Pennsylvania 17011 (717) 730-3775 Attorney for Plaintiff TRAFCON INDUSTRIES, INC., Plaintiff STEPHEN KUHN and, REBECCA KUHN, individually and tJd/b/a BLACK HILLS HORSE EQUIPMENT, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 David J. Lanza I.D. No. 55782 2157 Market Street Camp Hill, Pennsylvania 17011 (717) 730-3775 Attomey for Plaintiff TRAFCON INDUSTRIES, INC., Plaintiff STEPHEN KUHN and, REBECCA KUHN, individually and t/d/b/a BLACK HILLS HORSE EQUIPMENT, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW AVISO USTED HA SlDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes p~ginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despu~s de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escdto sus defensas de, y objecciones a, las demandas presentadas aqu| en contra suya. Se le advierte de que si usted falla de tomar acci6n como se descdbe 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 set dictado en contra suya por la Corte sin m~s 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 OFIClNA. ESTA OFICINA PUEDE PROVEERLE INFORMAClON 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 David L. Lanza I.D. No. 55782 2157 Market Street Camp Hill, Pennsylvania 17011 (717) 730-3775 Attorney for Plaintiff TRAFCON INDUSTRIES, INC., Plaintiff STEPHEN KUHN and, REBECCA KUHN, individually and tJd/b/a BLACK HILLS HORSE EQUIPMENT, Defendants COMPLAINT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AND NOW, this 24th day of March 2004, comes the Plaintiff, TRAFCON INDUSTRIES, INC., by and through its undersigned attorney, David J. Lanza, and files this Complaint, and in support thereof avers as follows: 1. The Plaintiff, Trafcon Industries, Inc., is a Pennsylvania corporation with its principal place of business at 81 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant, Stephen Kuhn, is an adult individual trading as Black Hills Horse Equipment with an address at 4183 Old Harrisburg Road, Gettysburg, PA 17325. 3. The Defendant, Rebecca Kuhn, is an adult individual trading as Black Hills Horse Equipment with an address at 4183 Old Harrisburg Road, Gettysburg, PA 17325. 4. At all times relevant herein, Defendants represented themselves to Plaintiff as an unincorporated entity or entities and/or a partnership. 5. Pursuant to Defendants' requests to Plaintiff at Plaintiffs Cumberland and Dauphin County offices from time to time, Plaintiff supplied horse mattresses and related materials to Defendants which mattresses and materials Defendants accepted, and agreed to pay the prices therefor. 6. The terms of the agreements between Plaintiff and Defendants are included in the invoices attached hereto as Exhibit "A." 7. Upon completion of the shipment of these supplies, equipment and accessories requested by Defendants, Plaintiff rendered invoices to Defendants showing each transaction and the prices charged, with payments to be made at Plaintiffs Cumberland County office. True and correct copies of these invoices are included as Exhibit "A." 8. Under the terms of the aforesaid agreements and invoices, Defendants agreed to pay to Plaintiff interest at the rate of 18 percent per annum for any amount unpaid more than 30 days after the date of invoice 9 Under the terms of the aforesaid sales agreement, Defendants are obligated to pay to Plaintiff "reasonable collection and/or attorney's fees" upon default. 10. The usual and customary fee charged by Plaintiffs attorneys, and the fee expected to be incurred in this case is $3,000.00. 11. Defendants are in default under the aforesaid sales agreements and invoices in that they have failed to pay for certain supplies, equipment and accessories as set forth more fully below 12. After credit to Defendants for sums, if any, paid on accounts of said invoices, the amount due to Plaintiff from Defendants is the sum of Thirteen Thousand Five Hundred Fifty Eight Dollars and Eighty-Five Cents ($13,558.85), calculated as follows: Principal Balance Interest at 18% per annum from 10/16/03 to 04/16/04 Attorney's Fees TOTAL: $ $ 9,684.83 $ 874.02 $ 3,000.00 $ 13,558.85 13. P~aintiff has demanded the total amount due but Defendants have refused and neglected and still refuse and neglect to pay the same or any part thereof. COUNT I BREACH OF CONTRACT 14. Paragraphs one (1) through thirteen (13) are incorporated herein by reference as though fully set forth below at length. 15. Defendant's failure to make payment for the products and materials specified above constitutes a breach of contract. WHEREFORE, Plaintiff demands judgment against Defendants in the amount of $13,558.85, together with interest from April 16, 2004, plus costs. COUNT II IN QUANTUM MERUIT 16 Paragraphs one (1) through fifteen (15) are incorporated herein by reference as though fully set forth below at length 17. Defendants requested all items delivered by Plaintiff and were aware that Plaintiff expected payment for Plaintiff's products. 18. Defendants received a material benefit from Plaintiff's products and materials. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $13,55885, together with interest from April 16, 2004, plus costs. COUNTI# BOOKACCOUNT 19. Paragraphs one (1) through eighteen (18) are incorporated herein by reference as though fully set forth below at length. 20. Defendants owe Plaintiff the amount of $13,558.85 for products supplied (plus interest and costs) in accordance with a book account, a true and correct copy of which is attached hereto as Exhibit A." WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $13,558.85, together with interest from April 16, 2004, plus costs. Respectfully submitted, David J. Lanza Attorney I,D. #55782 2157 Market Street Camp Hill, PA 17011 (717) 730-3775 Attorney for Plaintiff VERIFICATION I, John Williams, CEO of Trafcon Industries, Inc., verify that I am authorized to make the statements herein and that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. ~j4904 relating to unsworn falsification to authorities. Dated: ,-~ ~/~ / ~ ~C/~ ~*~- John Williams MODE - MEM~Y TRANSMISSION FILE HO. =736 STN NO. COVe. ABBR NO. 001 OK a START-OCT-1E 09:56 END=OCT-16 89:57 STATION N~ME/TEL NO. PAGES DURATION TRAFCON Inclustrims, In,-. Mechanicsburg, PA 17050 USA Voice: 717-691-8007 Fax: 717-697-08!3 Web: WWW. TRAFCON .COM Statement Oct i6, 2003 AccountOfi BLACK HILLS HORSE EQUIP. 41B3 OLD HARRISBURG ROAD GETTYSBURG Pa 17325 334-7282 334-3930 ~ llmte : Due Dato ! Re~toncc 73i/09 ~/~i/Ot ~c3vXO0004 js/~i/o~ ~1~i19~ ~¢sv~ooooi Paid D~sefipfio~.. ..... _A~_..o~mt ~O~ S0~26022 PAST DUiE PLEASE REMIT 2,5~0.001 7,377.50i 799. ]i! 6,176,81] 0-30 ~ 31-60 ~ 61-99 i Over 90 days .ndustries, Inc. Road ~nicsburg, PA 17050 Voice: 717-691-8007 Fax: 717-697-0813 Web: www. TRAFCON. COM Invoice Invoice Number: 19049 Invoice Date: Dec 12, 2002 Page: 1 Sales Order Numben Sold To: BLACK HILLS HORSE EQUIP. 4183 OLD HARRISBURG ROAD GE2~fYSBURG, PA 17325 Ship to: Customer ID BLACK HILLS HORSE EQ Quantity Item ~oo.oo H4~ HO~SE ~T Customer PO S0~26020 Shipping Method Our Truck Description Payment Terms Net 30 Days Ship D~e Due D~e 12/12/02 1/11/03 Qty Backordemd Unit Price ! Extension 25.00 2,500.00 CheckNo: Subtotal Sales Tax Freight Total Invoice Amount Payment Received TOTAL 2,500.00 0.00 0.00 2,500.00 0.00 2,500.00 TR~ Industries, Inc. 81 Texaco Road Mechan±c sburg, PA 170S0 USA Voice: Fax: Web: 717-691-8007 717-697-0813 WWW,TRAFCON.COM Sold To: BLACK MILLS HORSE EQUIP. 4183 OLD HARRISBURG ROAD GETTYSBURG, PA 17325 Ship to: Invoice Invoice Number: 19061 Invoice Date: Dec 17, 2002 Page: 1 Sales Order Number: Customer ID BLACK HILLS HORSE EQ Quantity Item 100.00 ~46 HORSE MAT 4.00 ~47 HORSE MAT Customer PO SO~26021 Shipping Method Our Truck Description PaymentTerms Net 30 Days Ship D~e Due D~e 12/17/02 [ 1/16/03 ' I Qty Backordered Unit Price Extension 25.00 2,500.00 20.00 80.00 Check No: Subtotal 2,58 o. 00 Sales Tax o. 00 Freight o. 00 Total Imvoic e Amount 2,5 s 0.00 Payment Received 0.00 TOTAL 2,580.00 TRAFCON Industries, Inc. 81 Texaco Road Mechan± c sburg, PA 17050 USA Voice: 717-691-8007 Fax: 717-697-0813 Web: wvrw. TRAFCON. COM Invoice Invoice Number: 19090 Invoice Date: Dec 19, 2002 Page: 1 Sales Order Number: Sold To: BLACK HILLS HORSE EQUIP. 4183 OLD HARRISBURG ROAD GET~YSBUI~G, PA 17325 Ship to: Customer ID BLACK HILLS HORSE EQ Customer PO SO#26022 Shipping Method Our Truck Quantity Item 100.00 H46 HORSE MAT Description Payment Terms Net 30 Days Ship Date Due D~e 12/19/02 1/18/03 Qty Backordered Unit Price Extens~n 25.00 2,500,00 Check No: Subtotal 2,500. oo Sales Tax o. oo Freight 0. oo Total Invoice Amount 2,500. oo Payment Received o. oo TOTAL 2,500. oo ,TB3%F~ON Industries, Inc. ~1 Texaco Road Mechanicsburg, PA 17050 USA Voice: 717-691-8007 Fax: 717-697-0813 Web: WWW. TRAFCON. COM Invoice Invoice Number: 20037 Invoice Date: Jun 17, 2003 Page: 1 Sales Order Number: Sold To: BLACK HILLS HORSE EQUIP. 4183 OLD HARRISBURG ROAD GETTYSBURG, PA 17325 Voice: 334-7282 Fax: 334-3930 Customer ID BLACK HILLS HORSE EQ Customer PO SO926023 Shaping Method Our Truck Quantity 25.00 1.00 2.00 1.00 ~em Description 46 RUBBER MATS 46 X 1/2 RUBBER MAT/SAMPLE 4 X 6' RECREATIONAL MAT/SAMPLE H46 NEW HORSE MAT/SAMPLE ORDERED BY: MARK MACSKIMMING FOR: DAVE MCMASTER Ship to: TOM WEBSTER PITTSBURGH, PA Payment Terms Net 30 Days Sh~ D~e Due Date 6/17/03 7/17/03 Qty Backordered Unit Price Extension 26.50 662.50 TERMS AND CONDITIONS OF SALE SERVICE CHARGE of 1.5% per month, (minimum chg. $.5 0) which is an Almual Rate of 18%, added to past duc balance, plus reasonable collection and/or atmmey's foes if required. WARRANTY OF TITLE: Seller warrants that Seller is the lewful owner of Equipment tmnsfe~ed herein, free of all encumbrances. WARP, AN/lES: Sdler makes no other express or implied warranty of any kind whatsoever with respect to the equipment, including but not limited to; the merchantabihty of the equipment or its fitness for any particular purpose; the design of the equipment; the capacity of the equipment; compliance of the equipment with the requirements of any law, rule, specification or contract pertaining thereto. Subtotal 6 6 2.5 0 Sales Tax 0. oc Freight o. 0 ¢ Total Invoice Amount 6 6 2.5 0 Payment Received o. 0 c TOTAL 662.50 W-W~q. TRAFCON. COM SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-01299 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAFCON INDUSTRIES INC VS KUHN STEPHEN ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KUHN STEPHEN but was unable to locate Him deputized the sheriff of ADANS serve the within COMPLAINT & NOTICE in his bailiwick. County, He therefore Pennsylvania, to On April 26th , 2004 , attached return from ADAMS Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Adams County 41.44 .00 78.44 04/26/2004 DAVID LJLNZA Sworn and subscribed to before me this 2~ ~ day ~0~mq A.D. Prothonotary this office was in receipt of the So answers ~ C~~j- / R. ~homas K~ine -/ Sheriff of Cumbe~q_and County SHERIFF'S RETURN - CASE NO: 2004-01299 P COMMONWEALTH OF PENNSYLVYuNIA: COUNTY OF CUMBERIJkND TRAFCON INDUSTRIES INC VS KUHN STEPHEN ET AL OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT KUHN STEPHEN T/D/B/A BLACK but was unable to locate Him deputized the sheriff of ADAMS , Sheriff or Deputy Sheriff who being says, that he made a diligent search and , to wit: HILLS HORSE EQUIPMENT in his bailiwick. He therefore County, Pennsylvania, serve the within COMPLAINT & NOTICE to On April 26th , 2004 attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .0O 16.00 04/26/2004 DAVID LANZA Sworn and subscribed to before me this 2[~ day of ~ POo~ A.D. Prothonotary this office was in receipt of the ~. Thomas Kl~ine Sheriff of Cumberland County SHERIFF'S RETURN CASE NO: 2004-01299 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TR-AFCON INDUSTRIES INC VS KUHN STEPHEN ET AL - OUT OF COUNTY Thomas Kline Sheriff or Deputy Sheriff who being a diligent search and , to wit: mo , duly sworn according to law, says, that he made and inquiry for the within named DEFENDANT KUHN REBECCA but was unable to locate Her deputized the sheriff of ADAMS serve the within COMPLAINT in his bailiwick. County, & NOTICE He therefore Pennsylvania, to On April 26th , 2004 attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 04/26/2004 DAVID LANZA Sworn and subscribed to before me this ~ ~ day of ~ ~3~ A.D. tProthonotary , this office was in receipt of the R. Thomas Klir~e~ ~ Sheriff of Cumberland County SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-01299 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRAFCON INDUSTRIES INC VS KUHN STEPHEN ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KUHN REBECCA T/D/E/A BLACK but was unable to locate Her deputized the sheriff of ADAMS County, serve the within COMPLAINT & NOTICE HILLS HORSE EQUIPMENT in his bailiwick. He therefore Pennsylvania, to On April 26th 2004 attached return from ADAMS Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 04/26/2004 DAVID LANZA Sworn and subscribed to before me this ~- day of ~ ~OY A.D. othonotary __ , this office was in receipt of the So answe~zs: .... ~ ~j]~~ R. Thomas Kline ' ~ Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Pennsylvania Trafcon Industries Ina VS. Stephen Kuhn et al SERVE: Stephen Kuhn No. 04-1299 civil hereby deputize the Sheriff of Adorns deputation being made at the request and risk of the Plaintiff. Sheriff of C~berland CounW, PA , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Now, within upon April 14 Complaint in Civil Action Stephen Kubn at by handing to bim a true & attested and made ka~own to Affidavit of Service ,2004 .,at 3:51 4183 Old Harrisburg Rd., Gettysburg, PA 17325 him Sworn and subscribed befbre me this N/A day of ,20 o'clock ?. M. served the copy of the original complaint the contents thereof. So ans~vers, _ I~heriff of Adams County, PA COSTS SERVICE $ 36.00 IvlILEAGE 5.44 AFFIDAVIT $ 41.44 BI. 4/22/04 In The Court of Common Pleas of Cumberland County, Pennsylvania Trafcon Industries Inc VS. Stephen Kuhn et al SERVE: Stephen Kuhn t/d/b/a Black Hills Horse Equit~ne~. 04-1299 civil Now, !~3 [~?¢, ~%~ hereby deputize the Sheriff of ~dans deputation being made at the request and risk of the Plaintiff. Sheriffof Cumberland County, PA , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Affidavit of Service Now, within April 14 ,20 04 ,at 3:51 o'clock P. M. served the Complaint in Civil Action upon Stephen Kubn t/d/b/a Black Hills Horse Equipment at 4183 Old Harrisburg Rd., Gettysburg, PA 17325 by handingto Stephen Kubn a true and attested. and made known to him copy ofthe original complaint the contentsthereo£ So an~wers~ Dep~ Sl~riff of Adams County, PA Sworn and subscribed before me t_his N/A day of ,20 COSTS SERVICE MILEAGE AFFIDAVIT Ia The Court of Common Pleas of Cumberland County, Pennsylvania Trafcon Industries Inc Stephen Kuhn et al SERVE: Rebecca Kuhn No. 04-1299 civil Now, Il ~ t~PP 200a hereby deputize the Sheriff of adans deputation being made at the request and risk of the Plaintiff. sheriff of Cumberland County, PA , I, SI-IERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Affidavit of Service Now, April 14 ,2004 ,at 3:51 within Complaint in Civil Action upon Rebecca Kubn at 4183 Old Harrisburg Rd., Gettysburg, PA by handing to Stepben Kubn a true and attested. and made known to him Swom and subscribed before me this N/A day of ,20 o'clock ?. M. served the copy of the original complaint the contents thereof. COSTS SERVICE MILEAGE AFFIDAVIT In The Court of Common Pleas of Cumberland County, Pennsylvania Trafcon Industries Inc VS. Stephen Kuhn et al SERVE: Rebecca Kuhn t/d/b/a Black Hills Horse Equipment No. 04-1299 civil hereby deputize the Sheriff of ~dana deputation being made at the request and risk of the Plaintiff. Sheriff of Cmberl~d Coua~, PA , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Now, within upon April 14 Complaint in Civil Action Affidavit of Service ,2004 ,at 3:51 Rebecca Kubn t/d/b/a Black Hill's Horse Equipment at 4183 Old H~rrisbur~ Rd., Gettysburg, PA 17325 by handing to Stephen Kubn a true and attested and made known to him Sworn and subscribed before me this N/A day of ,20 o'clock P. M. served the copy of the original complaint the contents thereof. So all~lwers, S-~eriff of Adams County, PA COSTS SERVICE MILEAGE AFFIDAVIT $ Ircluded on anott~er rem David L, Lanza I.D. No. 55782 2157 Market Street Camp Hill, Pennsylvania 17011 (717) 730-3775 Attorney for Plaintiff TRAFCON INDUSTRIES, INCl, Plaintiff STEPHEN KUHN and, REBECCA KUHN, individually and t/d/b/a BLACK HILLS HORSE EQUIPMENT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1299 CIVIL ACTION - LAW Defendants PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter judgment by default in favor of the Plaintiff, and against the Defendants, Stephen Kuhn and Rebecca Kuhn, individually and t/d/b/a Black Hills Horee Equipment in the amount of $13,558.85 plus costs, and interest from and after April 16, 2004, by reason of the failure of the Defendant to enter an appearance or to file an Answer within 20 days of the date of service of the Complaint endorsed with a Notice to Defend. It is hereby certified that written notice of intention to file this Praecipe was mailed to the Defendants, Stephen Kuhn and Rebecca Kuhn, individually and t/d/b/a Black Hills Horee Equipment at her last known address on May 4, 2004; said notice being mailed after the default occurred and at least ten (10) days pdor to the date of the filing of this Praecipe. A true and correct copy of the aforesaid notice, together with receipts for mailing, are attached hereto and made a part hereof. Dated: Respectfully submitted, David J. Lanza Attorney I.D. No. 55782 2157 Market Street Camp Hill, PA 17011 Telephone (717) 730-3775 Attorney for Plaintiff TRAFCON INDUSTRIES, INC., Plaintiff VS. IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1299 CIVIL CIVIL ACTION - LAW STEPHEN KUHN and REBECCA KUHN, individually and t/d/b/a BLACK HILLS HORSE EQUIPMENT Defendants TO: Stephen Kuhn, individually and tJd/b/a Black Hills Home Equipment 4183 Old Harrisburg Rd Gettysburg, PA 17325 (Defendant) DATE OF NOTICE: May 4, 2004 IMPORTANT NOTICE 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 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. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 David Lanza 2157 Market Street Camp Hill, PA 17011 (717) 730-3775 Attorney for Plaintiff TRAFCON INDUSTRIES, INC., Plaintiff VS. STEPHEN KUHN and REBECCA KUHN, individually and t/d/b/a BLACK HILLS HORSE EQUIPMENT IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1299 CIVIL CIVIL ACTION - LAW Defendants TO: Rebecca Kuhn, individually and t/d/b/a Black Hills Horse Equipment 4183 QId Harrisburg Rd Gettysburg, PA 17325 (Defendant) DATE OF NOTICE: May 4, 2004 IMPORTANT NOTICE 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 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. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 [~avid Lanza 2157 Market Street Camp Hill, PA 17011 (717) 730-3775 Attorney for Plaintiff