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Home My WebLink About09-0312THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. Goldman & Warshaw, P.C. BY:HEATHER N. DANESH, ESQUIRE Identification No.: 209645 PO Box 806 West Caldwell, NJ 07007 973-433-2104 EASTMAN OUTDOORS POB 380 Flushing, MI 48433 vs. SHERRY L. HUGHES 5261 E. SIMPSON FERRY ROAD MECHANICSBURG, PA 17050 and MARK A HUGHES 5261 E. SIMPSON FERRY RD MECHANICSBURG, PA 17050 and APPLE TRADING COMPANY INC dba BOWHUNTERS SUPERSTORE 5261 E. SIMOSON FERRY ROAD MECHANICSBURG, PA 17050 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09- ZIA eiv;1 term NOTICE 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 JUDGEMENT 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S BEDFORD STREET CARLISLE, PA 17013 717-249-3166 COMPLAINT IN CIVIL ACTION 1. At the special instance and request of the defendant(s), plaintiff sold and delivered to the defendant(s) merchandise and services, on the dates, of the kinds, in the amounts and for the prices set forth in a true and correct copy of plaintiffs books of original entry attached hereto, made part hereof, and marked Exhibit "A". 2. Defendant(s) accepted said merchandise and services without complaint. 3. The prices set forth in Exhibit "A" are the market prices for the said merchandise and services, and are the prices which the defendant(s) agreed to pay therefor. 4. All the credits, if any, to which the defendant(s) is(are) entitled are set forth in Exhibit: "A". 5. Plaintiff has made demand upon the defendant(s) for payment of the amount due, but the defendant(s) has(have) failed and refused and still refuse(s) to pay the same or any part thereof. 6. Defendant's last payment on account was made on January 4, 2008. WHEREFORE, plaintiff claims of the defendant(s) the sum of $37,417.46 plus applicable costs, interest and attorney's fees. Goldman & Warshaw, P.C. BY:?.?? ?!! c/ HEATHER N. DANESH, ESQUIRE Attorney for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE THIS COMMUNICATION IS FROM A DEBT COLLECTOR POMS 20081251 EASTMAN OUTDOORS VERIFICATION 20081251 I hereby state that I ant the agent for the plaintiff herein. and that the facts set forth in the attached Affidavit which is incorporated by relcrencc in the ti)argoinL, Complaint in Civil Action are true and con-ect to the best ol'my knowledge, infonnation and beliel'and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the .stmt that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This \erification is made subJect io 11 I'a.C'.S. §4904 which provides fi-o certain penalties (01, makill" false staleal?ents. t??ah/l B &Ala Print Name: &r I Ck 4 t.A in e y c L& ?-?'- Title: CleCDIT A4oW Q-,6P, EXHIBIT "A" Bowhunters Superstore 523369-2 EASTMAN OUTDOORS ?AFFIDAVIT 20081251 I, JVa r t?AnEMT%eing duly sworn according to law, depose and say that: 1. 1 am the agent for the Plaintiff herein and I am familiar with the files relating to this account; 2. 1 have personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. After allowing for all offsets and credits, a balance remains on the subject account having account number 523369-2 in the amount of $33,982.02; and 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best f knowl dge, inform• ai belief. N me of Affia Sworn to and Subscribed before me this 1J day 2008 Notary Public Qsj,N,J(tLtss1ok ELPI !-GS q?-t (7,0 1Z• si ?b" 00 m? mb"? D N C U 00 -9 3 0 w c $ $ 8 x : ? ? ? a O z V J 00 mm, i s is: al s: s $ 8; 8 $ 8; $? 8 $ $ 8i H 8 i g ffi': ffi cib'i ffii Bi ffi ffi? ffii 4 s sga'; 888! s 8 8 i g ffiffi ?ffi' ffiffi' s?'; g it gal; II B 8 88i 88i 88i 88i 88i g?ii 8t$i aa; 8 g a n g io 'Q !S ffi!ffiffiiffiffi3 8Is !Sffiibffi!1Sk ?A r `m 8 8 88 $$ 88; a8 88'; 9 8 8$ 88; 8$ is a o^ ? $ ? : ? i3 f3 Sd mN ?g T ag e m Z s 2 N Na b cjj n ? O8 C ?y 3 n ? e n z A 0 A O N s N 8 8 ? p? >> N O ? n CAA ii 33a??1 0 Q m r N g ti A ? PS G s s s a s g 8 8 bi ?! b` g !Si b 8 8 8; 8; 8; 8; 8; ? 8 G I s 8i ?; s s s ?? rn ? g 8; 8 8? 8 $ 8 8; 8 8; ? $ 8! 8i ?i Gi G ?? d 1S! p pq NN yM yy ig yi r N O i O O H O O N : O M O .' O O O?• N? $ 8i 8$. 89: 88i 88: 89: z 8 m m 0 4 ? oSm ? m v t4V 6B: 88 14 Ni gg: v, r ? C N 8 8 88 88:88:88; 88; 88 ? g o O R ? f3 ff ° S rG' S W? e a T T m A to o A ? N ?g a ? N d m T 0 C 2 m O N 03/22/2006 00:58 17174328947 ?a 4D CARBON EXPRESS, EASTMAN OUTDOORS, INC. n.." don GOON '"'sari A aAanuN 0.lrnrm.&- BOWHUNTERS SUPERSTOR 0 b? C111E917 APPLICATION AND rVRCRASE TER148 A(.tttM MT P.O. -- •••] Itttlyli4340 Pat ltlal7zl&ll PAGE 01 30 S, O D o ?I ? Ke'W?eek Saxes SP -? TO APPLY FOR AN EASTMAN OVTDOORB. INC. ACCOUNT, PLEASE SU>IMIT ALL OF TNIE FVLLOWE46INFORINATION: 1. Thia appNeagaa wait be empichd and signed by an oltleer/owner of else COMPANY. I 2. A Copy of your botenae/alate calm tat Iicrose. 3. A copy of a fort) of advardsing: ftsinen cNrd, copy of pheoebnok listiae, newspaper ad, etc.) a. Pravlde a pkotagrapb of your besiseaa. THIS APPLICAT/ONAND ANYORDER ACCOAIPYING THIS APPLICATION 07LL BE PUT ON HOLD IF ALL UrBQUESTED I/VPOJtmATIO/YIS NOT PROVIDED. PAYMENT TERMS REQUESTED- CODREPAY CREDIT CREDIT LIMIT REQUESTED E Tl. " COMPANY NAME: 1/Yie0ww DA.,f BILLING (MAILING) ADDRESS: P/d /?f/k /.<- r'i- CITY. STATE. ZIP: We I/ y;" pig 1236"5-- SHIPPING ADDRESS:___ 2eitL--L CITY, STATE. ZIP , GUP(G?fukl° ? WEBSITE ADDRESS: (.1/V• ?t a?'FCt._5 S V '4-0's Co BUSINES3/TAX LICENSEC 'NUMBER OF YEARS IN BUSINESS: a SIP YOUR Sti3tNESS 15 LESS T N 2 YEARN OLD. V b= 8IGt4 THE aERSONAL GtIARANTY TO D CONAIDERED FOR AN OPEN LINE '," OF CREDIT. TYPE OF-PRODUCTS SOLD r`(` k&W / ??Aq l'!/l ? ZZ Ie I(JiJ??.t BUSINESS LOCATION: CommunityBidg;Part of Homc Bldg on Premise NORMAL BUSINESS HOURS: /My- F'L' ^ C-1 5 771" k- ? TOTAL RETAIL SPACE (sq. ft.) J?U >4 N Of Employeac: Full-Tlme/_Pari-tirrd5- AVERAGE INVENTORY DOLLARS: 9 6100" ANNUAL SALES: ?O IL) ?T?- TYPE OF BUSINESS: PROPRIETORSHIP PARTNERSHIP CORPORnnONT OTHER FEDERAL-4DENTMCATION IF SOLE PROPRIETORSHIP OR PARTNERSHIP PLEASE LIST NAME OF OWNERS: 03/22/2006 08:58 17174328947 BOWHLINTERS SLIPERSTOR PAGE 02 (NAME) (TP?LE) (ADDRESS) (NAME) (TITLE) (ADDRESS) Has the company or any of ' 'Pala/owners and or guarantors been involved in a bankruptcy proceeding (citte]e one)? YES NO if yes, please describe the circumstances BusnesSPHONEM 71 2' tl3 - SM 371o PAxr 7 7 - ??') N S?/7 OWNER NAME: r OWNER RESTOENCE ADDRESS: RESIDENCEPRONEM // 7 ] ./ -A,13-3 BUYER NAME AND CONTACT 0 J /lrf_pZ? 7/ BUYER EMAIL:- ACCOUNTS PAYABLE NAME & CONTACT /nN /?//r te YA t..?4 7J7" Yc?a? 37 0 ACCOUNTS PAYABLE EMAIL: [7 ([?r42P?tA?'/ p'ly` TQinst nt*a:ata:MCa:1 PLEASE LIST 4 REPERENCES WITH wHoM YOU HAVE DONE BUSTNESS ON CREDIT TERMS FOR AT LEAST STX MONTHS NAME CONAC7PERSON PHONEII FAXfl NAME CONTACT PERSON PHONED FAX NAME CONTACT PERSON PHONEM FAXM NAME CONTACT PERSON PHONEN FAX BANK NAME CONTACT PERSON PHONE# PAXN ACCOUNT# PAUTIM HR'aa'9Y AGREE THAT ALL PURCHASES MADZ ARX SUWZCT TO TH.U 03/22/2006 08:58 17174320947 BOWHUNTERS SUPERSTOR PAGE 03 .ter nprnyr_ ¦'9 RMS CONDITIONS 1. i herby certify that I have the authority to apply for credit on behalf of Applicant(s) identified below and the Applicant(s) hereby authorize Easunim Outdoors, Inc. ("Creditor") to investigate Applicant(s) credit history, bank references and any other sour= of information deemed necessary to extend credit as allowed by the Federal Credit Reporting Act and applicable State law. 2. All sale; are coasiderod final. Returns, other than for defective product, are at the sole discretion of the Creditor and require a return auto a ization number (RA) from the Creditor's customer service department. 3. Authorized returns, excluding defective product end errors on the part of the Creditor, will be assessed a 15°x6 restocking charge. 4. Credit Applicant agrees to pay invoices in accordance with the Creditor's terms of We, which are Net 30 Days from date of invoice unless specified otherwise on invoice. t 5. Credit Applicant(s) shall be responsible to pay to Creditor a service charge of 1.5% per month (which equals 18% per annum) or the highest rate permitted by law, on any unpaid balance due over thirty (30) 6. Credit Applicant(s) is responsible for all costs of collection including reasonable attorney's fees Incurred by Creditor in collecting any amounts due it or umtbroing its rights. 7. Credit Applicant(s) hereby gives a security interest to Creditor in all products purchased from the Creditor (now owned and hereafter acquired) to secure payment of any account balance owed. 8. Credit Applicant(s) affirms that all information herein together with all information submitted in connection with this application is true and accurate and that it will promptly notify Creditor if any information changes. 9• Credit Applicant(s) agrees to immediately notify Creditor's customer service department for all shortages, price discrepancies or height disputes. 10. A 55.00 MINIMUM ORDER FEE will be added to all orders under $100.00, 11, Credit Applicant(s) acknowledge that a service charge of $25 will be applied to each check returned for insufficient funds. Eastman Outdoors. Inc. reserves the rlybt to discontinue credit If the above terms and conditions are not met. Maw-varry Name Aut sips e o f tlia r Please Print • a and Title Date PERSONAL GUARANTTidV OF rNDENTEDNESS •" To induce Eastman Outdoors, Inc. (hereinafter the "Seller") to approve this Credit Application and Purchase Terms Agreement with the above applicant (hereinafter the "Debtor") and in consideration of its so doing, the undersigned guaramor(s) does/do hereby jointly, severalty, and personally guarantee all sums which may be owed by the Debtor to the Seller and performance of all the terms of the purchase by the Debtor. ' 03/22/2006 88:58 17174326947 BM*"TERS StPERSTOR PAGE 04 Seller may enforce this sp een ent apW# the undo pad gumartor(s) Or say of them, jointly or wowly, whether or not any &Won is over taken by it against the above Debtor. The liability of the guarantor(s) dW 1 be primary and shall not be affecW by the bankruptcy of the Debtor. aw"mtor'a Sipmr (Do not Inmt Corpofft Titles) s+o.lR •? k ear ntNa a ee dim' 6l Ssr?iGi??n?IRA lylec(Uw°csb, P4 1706 Addm SlrneNro nn.i,. "? a.Nu#0 rDsw rnwor W4 sae e*A$ PRIYIOUSLY STATED IN CRIDTI' A"UCA71ON, tR YOUR COMPANY HAS BUN IN DUSINUM LESS THAN 2 YEARS, THI PERSONAL GUARANTEE MUST <1E SIGNED TO AE COM MER90 FOR CRIDIT. Col Ieft" of this "Pumlon does not pwuttee ww1t. a 00 N 91 0 rn -77 0 'D rv : C - W 4 v C _.s W SHERIFF'S RETURN - REGULAR CASE NO: 2009-00312 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EASTMAN OUTDOORS VS HUGHES SHERRY L ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HUGHES SHERRY L the DEFENDANT , at 1430:00 HOURS, on the 23rd day of January , 2009 at 5261 E SIMPSON FERRY ROAD MECHANICSBURG, PA 17050 SHERRY HUGHES by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.90 Affidavit .00 Surcharge 10.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 01/26/2009 GOLDMAN & WA W C - By: Dep y Sheriff of A. D. r--, r..a ? ,,r,., , ?? _ + vi 'A. ?`% E'er} !?{ ..? SHERIFF'S RETURN - REGULAR CASE NO: 2009-00312 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EASTMAN OUTDOORS VS HUGHES SHERRY L ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HUGHES MARK A the DEFENDANT , at 1430:00 HOURS, on the 23rd day of January , 2009 at 5261 E SIMPSON FERRY ROAD MECHANICSBURG, PA 17050 SHERRY HUGHES, WIFE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 6.00 .00 .00 W , 10.00 R. Thomas Kline .00 16.00 01/26/2009 GOLDMAN & WAR H By: day Deputy Sheriff A. D. Zo -ow -WM .rw. 4 w y . ro SHERIFF'S RETURN - REGULAR CASE NO: 2009-00312 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EASTMAN OUTDOORS VS HUGHES SHERRY L ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon APPLE TRADING COMPANY INC DBA BOWHUNTERS SUPERSTORE the DEFENDANT , at 1430:00 HOURS, on the 23rd day of January , 2009 at 5261 E SIMPSON FERRY ROAD MECHANICSBURG, PA 17050 by handing to SHERRY HUGHES, PART OWNER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 6.00 .00 .00 10.00 R. Thomas Kline .00 16.00 01/26/2009 GOLDMAN & WARS W C By: day epu Sheriff A. D. ??`' rY.a ;'? ;--? w ._..? 1 4 ... 'F ...?.? S;;,F 7 . +- "Y'; ?? ?„" TMAN OUTDOORS, Plaintiff v. SHERRY L. HUGHES, MARK A. HUGHES and APPLE TRADING COMPANY, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-312 CIVIL TERM CIVIL ACTION - LAW NOTICE TO PLEAD TO: Eastman Outdoors, Plaintiff and Heather N. Danesh, Esquire Goldman & Warshaw, P. C. P. O. Box 806 West Caldwell, NJ 07007 You are hereby notified that you have twenty (20) days in which to plead to the enclosed New Matter or a Default Judgment may be entered against you. SNELBAKER & BRENNEMAN, P. C. BY: Date: February 11, 2009 Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendants LAW OFFICES SNELBAKER & BRENNEMAN, P.C. EASTMAN OUTDOORS, Plaintiff V. SHERRY L. HUGHES, MARK A HUGHES and APPLE TRADING COMPANY, INC., Defendants IN "THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-312 CIVIL TERM CIVIL ACTION - LAW ANSWER WITH NEW MATTER Defendants Sherry L. Hughes, Mark A. Hughes and Apple Trading Company, Inc. by their attorneys, Snelbaker & Brenneman, P. C.. submit this Answer With New Matter in response to Plaintiff's Complaint as follows: A NTCX11 D 1. Denied. It is denied that Plaintiff sold and delivered Defendants merchandise and services as set forth in Exhibit A. It is further denied that any or all goods or services were provided at the "special instance" and request of Defendants. On the contrary, Plaintiff identifies itself in the lawsuit as Eastman Outdoors, not Eastman Outdoors, Inc., the entity with which Defendant Apple Trading Company conducted business. 2. Denied. It is denied Defendants accepted any merchandise and services from Eastman Outdoors for the reasons set forth in New Matter, the averments of which are incorporated by reference herein. 3. Denied. It is denied that Defendants agreed to the prices for the merchandise as set forth in Exhibit A. 4. Denied. It is denied that all credits to which Defendant Apple Trading Company, Inc. LAW OFFICES SNELBAKER & are entitled are set forth in Exhibit A. BRENNEMAN, P.G. 5. Denied. It is denied that Eastman Outdoors has made any demands for payment for reasons set forth in New Matter, the averments of which are incorporated by reference herein. 6. Admitted, with the qualification that any payments made were made to Eastman JOutdoors, Inc. WHEREFORE, Defendants request this Court to enter judgment in their favor and dismiss Plaintiff's Complaint. NEW MATTER 7. Plaintiff's Complaint fails to set forth any claim or cause of action against any one or more Defendant upon which relief may be granted. 8. Plaintiff identifies itself as Eastman Outdoors in the caption of this action. 9. Any business conducted by Defendant Apple Trading Company, Inc. was conducted l with Eastman Outdoors, Inc. 10. Neither Eastman Outdoors nor Eastman Outdoors, Inc. has obtained a certificate of authority in the Commonwealth of Pennsylvania. 11. If Plaintiff Eastman Outdoors is a fictitious name, the name has never been registered as such with the Pennsylvania Department of State. 12. The Credit Application and Purchase Terms Agreement attached as part of Exhibit A to Plaintiff's Complaint pertain to an Eastman Outdoors, Inc. account, not an account with Plaintiff Eastman Outdoors. 13. For the reasons set forth above, Plaintiff is not permitted to maintain this or any other LAW OFFICES 11 action or proceeding in this Court. SNELBAKER 8a BRENNEMAN, P.C. -2- 14. Plaintiff Eastman Outdoors has no standing or legal basis to maintain this action. 15. Plaintiff Eastman Outdoors is not a real party in interest. WHEREFORE, Defendants request this Court to enter judgment in their favor and dismiss Plaintiff's Complaint. SNF,LBAKER & BRENNEMAN, P. C. By: 14-?" Keith O. Brenneman, Esquire 44 W. Main Street Date: February 10, 2009 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Sherry L. Hughes, Mark A. Hughes and Apple Trading Company, Inc. LAW OFFICES SNELBAKER 8C -3- BRENNEMAN, P.C. VERIFICATION I verify that the statements made in the foregoing Answer With New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. I hereby verify that I am authorized on behalf of both Defendants Apple Trading Company, Inc. and Sherry L. Hughes to execute this, verification on their behalf. Date, Mark X, Hu s 4 CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Answer With New Matter to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Heather N. Danesh, Esquire Goldman & Warshaw, P. C. P. O. Box 806 West Caldwell, NJ 07007 SNELBAKF.R & BRENNEMAN, P.C. By:jht'-'-' Keith O. Brenneman, Esquire 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendants Sherry L. Hughes, Mark A. Hughes and Apple Trading Company, Inc. (Date: February 11, 2009 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. rvi .rr 20081251 Goldman & Warshaw, P.C. BY: HEATHER N. DANESH, ESQUIRE Identification No.: 209645 34 Maple Ave, Ste.101, POB 106 Pine Brook, NJ 07058-0106 973/439-0077 EASTMAN OUTDOORS COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET NO. : 09-312- SHERRY L. HUGHES, MARK A. HUGHES and APPLE TRADING COMPANY, INC. PLAINTIFF'S REPLY TO NEW MATTER 7. Denied. This averment is a conclusion of law which requires no response under the applicable Rules of Civil Procedure. However, this averment is denied and strict proof thereof is demanded at the time of trial. 8. Admitted. The original Complaint has the caption identifying plaintiff as Eastman Outdoors. 9. Denied. After reasonable investigation plaintiff is without knowledge or information sufficient to form a belief as to the truth of the averment. Therefore, it is denied and strict proof thereof is demanded at the time of trial. 10. Denied. After reasonable investigation plaintiff is without knowledge or information sufficient to form a belief as to the truth of the averment. Therefore, it is denied and strict proof thereof is demanded at the time of trial. 11. Denied. After reasonable investigation plaintiff is without knowledge or information sufficient to form a belief as to the truth of the averment. Therefore, it is denied and strict proof thereof is demanded at the time of trial. 12. Denied. After reasonable investigation plaintiff is without knowledge or information sufficient to form a belief as to the truth of the averment. Therefore, it is denied and strict proof thereof is demanded at the time of trial. 13. Denied. This averment is a conclusion of law which requires no response under the applicable Rules of Civil Procedure. However, this averment is denied and strict proof thereof is demanded at the time of trial. 14. Denied. This averment is a conclusion of law which requires no response under the applicable Rules of Civil Procedure. However, this averment is denied and strict proof thereof is demanded at the time of trial. 15. Denied. This averment is a conclusion of law which requires no response under the applicable Rules of Civil Procedure. However, this averment is denied and strict proof thereof is demanded at the time of trial. HEATHER N. DANESH, ESQUIRE, hereby states that she is the attorney for the plaintiff in this action and verifies that the statements made in the foregoing pleadings are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. sn?a e'a2? HEATHER N. DANESH, ESQUIRE C v Lax ii ?o W w 20081251 Goldman & Warshaw, P.C. Barry A. Rosen, Esquire PA Identification No: 42951 GOLDMAN &.WARSHAW, P.C. 312 W. Broad Street Quakertown, PP_ 18951 267-373-9730 Counsel for Plaintiff OF' THE PRUT~{~P~OTAr~Y 20CdQCT l5 A~tl~ 56 ~;t1~lBERLA~'~ COEJ~T~` `~~P~~SY~.~`?~P~l EASTMAN OUTDOORS vs. SHERRY L. HUGHES and MARK A HUGHES COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-312 ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: • 'Kindly mark the judgmententered September 17, 2009 in the .above-captioned matter satisfied upon payment of your costs only. Goldman & Warshaw, P.C. B`'f : BARRY OSEN, ESQUIRE Attorney for Plaintiff P005 ~~ ~~~~