HomeMy WebLinkAbout10-0182
MERCHANTS EXPRESS
MONEY ORDER COMPANY, INC.
PLAINTIFF
V.
Russell Matin
Individually, jointly and severally,
DEFENDANT
and
Mousumi Khatoon
Individually, jointly and severally,
DEFENDANT
and
MDMH, Inc., doing business as
Sunshine Market
Corporation
DEFENDANT
COURT OF COMMON PLEAS,
CUMBERLAND COUNTY
2009
No. 001D
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: $ 15,416.15
Interest: $ 97.64
Lost Fee Income: $ 2,349.00
Attorney Feed: $ 5,862.50
Total: S 23,725.29
Kevi M. Lutkins, Esq.
Attorney for Defendants
MERCHANTS ENPRESS
MONEY ORD COMPANY PLAINTIFp 'INC.
V.
Russell Matin
Individually, jointly and severally,
DEFENDANT
and
Mousumi Khatoon
Individually, jointly and severally,
DEFENDANT
and
MDMH, Inc., doing business as
Sunshine Market
Corporation
DEFENDANT
COURT OF COMMON AS,
CUMBERLAND COUNTY
2009
0 - OWE
No.
NOTICE
THE E
NOTICE IS GIVEN THAT A JUDGMENT IN BO- ATONED
MATTER HAS BEEN ENTERED AGAINST PROTHONOTARY /,Z
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 ORDPLAINMFANY, INC.
V.
Russell Matin
Individually, jointly and severally,
DEFENDANT
and
Mousumi Khatoon
Individually, jointly and severally,
DEFENDANT
and
MDMK Inc., doing business as
Sunshine Market
Corporation
DEFENDANT
COURT OF COMMON PLEAS,
CUMBERLAND COUNTY
2009
No. ? 0
COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY
COUNT I - CONFESSAIOfINN O Vii JUDGMENT
T1
MO V. MDAM M
Plaintiff is Merchants Express Money Order Company, Inc., hereinafter "MEMO"), a
1.
a corporation wholly owned by the Pennsylvania Food Merchants Association that
Pennsylvam
in the issuance and sale of money orders and whose address's 1029 Mumma Road,
engages
Wormleysburg, Pennsylvania, 17043.
2. Defendant MDMK Inc. (hereinafter "MDMIT'), is a corporation located at 56
Washington Street, Lynn, Massachusetts 01902 and doing business as Sunshine Market.
3 Defendant Russel Matin (hereinafter "Matilf ), is an individual residing at 182
Western Avenue, Lynn, Massachusetts 01904.
4. Defendant MOusumi Khatoon (hereinafter "Khatoon", is an individual residing at
182 Western Avenue, Lynn, Massachusetts 01904.
atin and Khatoon are the owners and/or operators of Defendant MDMH
5. Defendants M
o the Trust Agreement on behalf of said Defendant MDMH and themselves on or
and entered int
about June 1, 2008. A true and correct copy of the Trust Agreement under which Defendants
n and MDMH are confessing judgment is attached hereto as Exhibit "A".
Matra, Khatoo
6. Defendant Matin and Khatoon, with the intent to induce MEMO to enter into a Trust
Defendant M[DMK agreed to personally guaranty the obligations of Defendant
Agreement with
A true and correct copy of the Personal Indemnity and Guaranty under which
MDMH.
Mahn and Khatoon is confessing judgment is attached hereto as Exhibit "B".
Defendant is not
The forgoing judgment against Defendants Matin and Khatoon and MDMH,
7.
ed b confession against a natural person in connection with a consumer credit
being enter y
transaction.
The Plaintiff has not assigned the Trust Agreement and Personal Indemnity and
8.
Guaranty under which judgment is being confessed.
9. The Plaintiff has not entered judgment against Defendants in any jurisdiction for the
unpaid sum of $23,725.29 or any additional amount for a total of the debt demanded here.
The Defendants jointly and severally acted as selling agents for plaintiff from July 27,
10.
2007 until November 17, 2009.
11. pursuant to the Trust Agreement, Defendants are required to hold all monies received
from the sale of money orders, including money order fees (hereinafter "trust funds"),
by them fre and apart from other funds of the Defendant for collection by the Plaintiff through
separat
electronic or other means.
12. The Plaintiff attempted to collect the trust funds from Defendants on October 23,
009 through an Automated Clearing House (hereinafter "ACI.1 ') method.
2 ,
III The plaintiff, or its designated check-clearing banking center did not receive the
wired by the Trust Agreement.
payment of the trust funds on October 23, as required
rin banking center to receive trust
14. The failure of plaintiff or its designated check-clea g ent of default
ds from the Defendant in accordance with the Trust Agreement constitutes an ev
fun
allowing plaintiff to enter judgment against Defendants. b the Defendants
15. pursuant to the Trust Agreement, the Plaintiff suffered damages by
conduct as follows:
$ 15,416.15
Principal:
$ 97.64
Interest:
Lost Fee Income: $ 2,349.00
Attorney Fees: $ 5,862.50
Total: $ 23,725.29
The Defendants' most recent 10-week sales average equaled 29 money orders causing
16.
plaintiff Lost Fee Income of $2,349.00 as a result of Defendants' default.
Plaintiff demands judgment in the aforementioned amount as authorized by the
17.
Warrant of Attorney contained in the Trust Agreement attached hereto as Exhibit A.
Warrant of Attorney contained in the Trust Agreement is less than twenty (20)
18, The
years old.
Plaintiff demands judgment in the amount of $23,725.29, as authorized by
WHEREFORE,
t a eating in the attached Trust Agreement, together interest from the date of
the WarranpP
judgment and costs.
COUNT II - BHCIITINO ANCONT_RACT
D TOON)
(MEMO V NIDMH MA
19. The averments set forth in paragraphs 1 through 17 are incorporated by reference as if
set forth in full herein. Agreement, and the
20. Defendant Matin and Khatoon signed the above referenced Trust documents appended thereto, on behalf of The MDMH' reference Personal indemnity
21. Defendant Matin and Khatoon also signed the above-reference Personal Indemnity
pursuant to which he made himself personally liable for any default by
and Guaranty Agreement,
The MDMH under the Trust Agreement.
emit the trust funds is a violation of the terms
22. The failure of Mahn and Khatoon to r
s of the Trust Agreement, and in addition, is a breach of the fiduciary relationship
and provision
created by the Trust Agreement.
FORE Plaintiff demands judgment in the amount of $23,725.29, as authorized by
WHERE
in the attached Trust Agreement, together interest from the date of
Warrant appearing
the Warr judgment and costs.
COUNT III BREACH OF FIDU ?ATOO?
MO V. NIDMH MA'I'IN ANI?---""_'?
averments set forth in paragraphs 1 through 21 are incorporated by reference as if
23. The
set forth in full herein.
24. The Trust Agreement created fiduciary obligations owed by the Defendant to the
Plaintiff.
25. In breach of their fiduciary obligations, Defendant Matin and Khatoon:
a. Failed to hold the trust finds in trust, as property of Plaintiff;
b. Deprived Plaintiff of the use and benefits of its money;
C. Failed to make the required payments or dispositions of trust funds to Plaintiff;
d. Commingled the trust funds with those of their own' and
e. Appropriated the trust funds for their own use and benefit, or elsewhere.
fendant erformed all of the above actin intentionally, willfully, maliciously, and
26. De p
with wanton disregard for the rights of Plaintiff.
merated above, constitute a breach of fiduciary duty to
. Defendant's actions, as enu
27
plaintiff under the laws of the Commonwealth of Pennsylvania and the terms of the Trust
Agreement.
BEFORE, plaintiff demands judgment in the amount of $23,725.29, as authorized by
WHEREFORE,
the Warrant appearing in the attached Trust Agreement, together interest from the date of
judgment and costs.
COUNT TV - CONvERSION TOON
HMO v NID 4% MATnv AND
The averments set forth in paragraphs 1 through 26 are incorporated by reference as if
28.
set forth in full herein.
. Plaintiff avers, on information and belief, that Defendant Matin and Khatoon
29
converted the trust funds owed Plaintiff to his own personal uses.
30
Defendant Matin and Khatoon's personal use of the trust funds and thus his
tional derivation of the use and benefit of the trust funds properly due and owing Plaintiff,
mten p
constitutes conversion under the laws of the Commonwealth of Pennsylvania.
WHEREFORE, plaintiff demands judgment in the amount of $23,725.29, as authorized by
the Warrant appearing in the attached Trust Agreement, together with interest from the date of
judgment and costs.
COUNT V - UNJUST ENRICHMENT
(1?M0 v. MDMH MATIN AND KHATOON
forth in paragraphs 1 through 29 are incorporated by reference as if
31. The averments set
set forth in full herein.
avers u on information and belief, that Defendant wrongfully retained the
32. Plaintiff a , p
trust funds.
1 intiff conferred the benefit of the use of the money orders and other property upon
33. P a
Defendant and said Defendant appreciated, accepted and retained such benefits.
the the
4. The Defendant's retention of the benefits conferred by plaintiff without Paying
3
value of such benefits would be inequitable and unjust.
As a result of Defendant's retention of the trust funds and/or Plaintiff's other
35.
Defendant has damaged Plaintiff while unjustly enriching himself in the amount set
property,
ve to ether with the value of the property retained, and the benefits conferred upon
forth abo g
ndant as a result of the use of the money orders and property, plus interest and costs.
Defe
ORE Plaintiff demands judgment in the amount of $23,725.29, as authorized by
WHEREF ,
earin in the attached Trust Agreement, together with interest from the date of
the Warrant app g
judgment and costs.
36. The averments set forth in paragraphs 1
set forth in full herein.
37.
through 34 are incorporated by reference as if
The Trust Agreement clearly states that all money orders and trust funds are
Plaintiff's property. Trust Agreement require the Defendant to segregate and hold apart,
38. The terms of the
all trust funds and/or proceeds from the sale of money orders.
of the Trust Agreement clearly state that all non-trust funds and/or property
39. The terms
with trust funds and/or proceeds are impressed with a trust for the Plaintiff s
commingled
benefit.
B operation of law, Plaintiff is the owner and Defendant is the trustee for all assets
40. Y so commingled. Defendant
41. Despite Plaintiff's demand for return of the trust funds and other property,
remit the trust funds and other property impressed with a trust by operation of law to
refused to
Plaintiff in violation of the Trust Agreement.
FORE, plaintiff demands judgment in the amount of $23,725.29, as authorized by
WHERE
ant appearing in the attached Trust Agreement, together interest from the date of
the Warr
judgment and costs.
Kevin . Lutkins, Esq.
Attorney for Plaintiff
Attorney ID: 76859
Date: 17 7I °
VERIFICATION
individual hereby states that he/she is an employee cof the Pe instheania
The undersigned
Food Merchants Association with the authority to verify the statements Inc., a
Merchants Express Money Order Company,
foregoing complaint involving of the Pennsylvania Food Merchants
Pennsylvania corporation and
Ily who also sstates that the statements made in t formation,
Association. The undersigned individual)
aforementioned complaint are true and correct to the bent therein are made of his/her knowledge, information,
to stat
and belief. The undersigned understands t that the
worn falsifications to authorities.
penalties of 18 Pa. Cons. Stat. §4904
Daniel C. Oliva
MERCHANTS EXPRESS
MONEY ORDPLAINTIFY, INC.
V.
COURT OF COMMON PLEAS,
CUMBERLAND COUNTY
2009
Russell Matin
individually, jointly and severally,
DEFENDANT
and
Mousumi Khatoon
Individually, jointly and severally,
DEFENDANT
and
MDMH, Inc., doing business as
Sunshine Market
Corporation
DEFENDANT
• No.
AFFIDAVIT OF ADDRESSES
• SS:
COMMONWEALTH ERLAND S?VANIA
COUNTY OF
The undersigned being duly sworn according to law, deposes and states that he is an
Pennsylvania Food Merchants Association with the authority to make this
Inc, a wholly
employee of the Express Money Order Company, states
Affidavit on behalf of the Plaintiff, Merchants also
The caned subsidiary of the Pennsylvania Food Merchants Association.
P nn ylvania
0 17043 and
that the address of the the Defendants ar29 e as fo l wsoa ,
that the addresses o
Russell Matin Mousumi Khatoon
MDMH, Inc. 182Westem Avenue
56 Washington Street 182 Western Avenue
Lynn, MA 01902 Lynn, MA 01904
Daniel C. Oliva
SWORN to and subscribed
before me this 0
2009.
day of DtCbk
N t is
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Jennifer R. Hamelin, Notary Public
Wormleysburg Boro, Cumberland county
my Commission Expires July 12, 2012
Member, Pennsylvania Assoclatlon of Notaries
MERCHANTS EXPRESS
MONEY ORDER COMPANY, INC.
V.
COURT OF COMMON PLEAS,
CUMBERLAND COUNTY
2009
Russell Matin
Individually, jointly and severally,
DEFENDANT
and
Mousumi Khatoon :
Individually, jointly and severally,
DEFENDANT
and
MDMH, Inc., doing business as
Sunshine Market
Corporation
DEFENDANT
No.
AFFIDAVIT OF NON-M11,I1ARY SERVICE
SS:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND :
undersigned being duly sworn according to law, deposes and states that he is an
make this
The un
Associatioauthority t
emPtoYee of the Pennsylvania Food Merchants Association t0 der Company?inc , a wholly
Affidavit on behalf of the Plaintiff, Merchants Express Money
owned subsidiary of the Pennsylvania Food Merchants Association. The undersigned also states the that to the best of my knowledge, information, and belief, the Defendants are not i s of?eitary
+lkp
ies, or or Naval Service of the United R Relief Act of Conlgress of lh?
Soldiers' and Sailors' C
Daniel C. Oliva
SWORN to and subscribed
before me this---3L-----,
day of kL 2009.
lic
N;4?r\
YLVANIA
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
R. Hamelin, Notary Public
[?rmIeysJennnniffer
burg Boro, Cumberland County
y Commission Expires July 12, 2012
Member, Pennsylvania Association 01 Notaries
A
MONEY ORDER COMPANY, INC. / MEMO MONEY ORDER COMPANY, INC.
MERM ERCHANS MONEY ORDER )RFSS COMPANY OF NEW YORK, INC. / MERCHArM EXPRESS USA, INC.
ORDER TRUST AGREEMENT
PERSONAL MONEY INC. d/b/a MEMO,
INC. d/b/a MEMO, MEMO MONEY ORDER COMPANY, O, or
EXPRESS MONEY YO ORDER INC., COMPANY, Atvi T5 F?RFSS USA INC. d/b/a MEMO,
AGREEMENT is ,made between MERCHANTS d/b/a MEMO, a New York Corporation MERCH
identificd below, hereafter referred to as Trustee(s).
peruasypvania Corporations or MEMO MONEY ORDER CO) entities 0N
any subsidiary d/b/a/ MEMO (vMO' , and the indn dual() bound hereby, die Pan1e5 agree as followx
t and intending to be legally issued by MEMO. It is expressly agreed that
In consideration of the mutual pranise5 contained in this agreemen roved for the sale of money orders
t of MEMO at each of Trustee's reran establishmeri app joint venture or agency (other than as expressly desc°
1. Agency. MEMO appourts Trustee to act as a special agar between are Parties shall not constitute a partnership, µ shall be binding on the other, without
MEMO and Trustee shall be independent contractors and that the relationship rations or conirriitmenis of any kind, or rake any action t and in the attached Rider herein
O nor Trustee shall have the -authority to make any staterrienes, repreSen and conditions sic ofied in this Agreemen
herein). Neither con Trustee accepts such appointment in accordance with die terms
the prior written ode at part the other Parry. MEMO and all money received by Trustee from the sale of money orders,
incorporated and made a part hereof O all blank rtaorxy, orders delivered to Trustee by and apart from other funds of Trustee. The
Trust Relationship. Trustee shall receive and hold intrust for MEMO 'Must f ands'. Trustee shall hold the trust farads 'eos ?u t en g of MEMO to immediate iii 2 including without limitation the rndmey order fees established by MEMO fi!om tame to Urne ( at the °ptim of MEMO, be a breach
from any other funds of the Trustee shall and such other remedies, Including termination this Agreerrent as
falue of Trustee to hold trust funds separate and ? for money order sales from consumers have been deposited
accounts into which funds received a fee (`Money the attached rider. Money
possession account or Order Fees' SPe°Fiei1 in
are psirovided of o for any herein Order Pees
3. Money Order Fees. In consideration of the services rendered to Trustee by MEMO, Trustee shall pay MEMO
to Trustee MEMO will supply Trustee with the followira&
may be nwdified by MEMO at any time upon thirty (3o) of days prior notice
money orders pursuant to this Agreement
4. Materials S Wfi d by MEMO. For the sole purpose selling
A. An adequate supply of sen* numbered blank rnoney orders required to implement and maintain a mmney order agency. on of anYitem. The money order dispenser
B. An agency ins order so as to inhibit the alterati of MEMO
tallation lit containing the supplies and training mateflal req firrrrl into the money
cnpnnt the money order dollar vah o? Y such tee, order in9nnoers shall at all three continue to be the sole property
C. A money order imprinter of the quality necessary to rimed money t{ispenSets not owned by MEMO and used by Trustee
shall be programmed by MEMO to indicate Trustee I.D. number on unP b MEMO. Any other money order
and shall not be removed from the Trusro MEMOIishment where it was originally installed by
ro at all times. retail to imprint money orders must be app onal materials, all of which Trustee agrees ? Y with or without noticeto access Trustee's premises and to
D. Regulatory Postings SVS, P°S? window decals and other purorruoti MEMO shall have the right, at all reasonable times the accounting (store) copies of money
p] Notwithstanding any Other provision of this Ag}eeritent of, the cash receipts, Money Order Fees,
t to an Accounting. is to ins and perform an accounting t Trustee m recover expenses incurred by MEMO when an audits
5. Right
and perform an accounting of, or cause its employees or
unissued money orders. A charge will be assessed agars
orders sold if applicable, daily sales report and the Trustee's inventory See audit fee/penalty fee schedule).
made due to Trustee's breath of this Agreement or if the audit discloses
es a bandreacegt>h. ()atioru
t as allowed by MEMO.
6. Rnules and Regulations. Trustee shall comply with the following mantles for Trustees own Trustee _Cep
t of anobligation of Trustee or used in any of by Trustee to or for MEMO shall constitute a remittance to
A. No money order shall be issued or sold to anyone in orderers any deposited
for matey orders issued or solo No check or other Paper transolmd such paper for collection
B. Only cash shall be accepted as Payment in each case as to whether to &Posi any ceercised in regard to motley orders shall be at least as that MEMO until actually collected, MEMO to have the option imprinter with the highest degree of ca The care to the event immediately upon discovery of
stolen
ME all unissued money traces and the money ° each Bey order stolen or missing, and all other information elating can be stopped on such missing or and hold
C. Trustee shall Safeguard ort to MEMO the serial number to MEMO so that payment
applicable to cash. Trustee shall rep 2 hours prior to the money orders being presented for payment fry and shall indemnify MEMO
of
the fact, but in any event not later than twenty-four (24) confirmed in writing, Trustee shall be solely resQorsrble for all losses a>iSinB for or replacement
money orders. Such report shall be by telephone and immediately oc?r;mpante? issued to Trustee. Ftmhemaore Trustee shall be responsible reprur Trustee's
hamikss regarding any and all stolen or missing irony orders as well as any money Said responsibility and liability of Trustee shall not be limited by
a result of misuse, negligence, abuse, fie or otherwise
any issued matey order dispensers stolen or damaged as set forth in dins paragraph.
and reporting obligations tested by MEMO. Trustee shall conduct operations so that the funds
corthpliance with the safeguardiiiP, care, non pro ide current financial information to MEMO as e9 o of money orders and notify and on of a reasonable person to be in jeopardy and shall cease the issuance Catdition" Shall
D. Trustee shall at all times maintain a sound financial posy not seem in the opuini m
generated from the sale of money osiers will not be in jeopardy de proillptlY lore and irrurhediately confirmed `that r has
MEMO irrhrraediately, should such jeopardy arse Noafi°ti°n to MEMO shall l (financial condition of due Trustee and that neither Trustee or any Guaranto
in the business operators or otherwise) or prospects assigriment for the benefit of creditors, instituted a
mean drat there has been no material adverse change mvolunt inly suspended transaction of its business, made a general in Paragraph h 7B or consented Jing described become insolvent, generally unable to pay its debts as they become due, or relief described therein, institute a pros is instituted, or has taken any
described in Paragraph 7B or consented to any such order for relief, declaration, finding of its whether or riot any such proc
proceeding d eeduag
any appointment or t r the taking of possession by any such official or all or any substantial part property, on the date which ate same is due, any sum payable hereunder
to such A lack of sound financial cc,"tion shall also include when Trustee fails to Pay, under conditions which, in the sole discretion of MEMO, it
action in furtherance of any of the foregoing to MEMO or to other creditors that it must delay any such payment
or fails to pay its creditors generally or makes representations
appears that Trustee is no longer in a sound financial condition
E. Trustee shall provide MEMO by facsimile transmittal or registered (1 three (3) weeks advance notice of proposed change(s red ) in thery C Ownership of either Trustee's business,
t 51%) or more of Trustee's assets, or the entry into emnnati ompany or partnership s interest or
the management of Trustee's business , the sale of Fifty-one pcurren
Transactions includ e d within this paragraph 6(E) include transfer of stock of Trustee, sale of Partnership, interests
No transaction, discussed in this subparagraph, shall be effective with the prior written approval of MEMO. , has entered into
any similar transaction which effects a change in owne ?shrp I°r control of Tnutee. No such transaction shall be apPOTOVlf Trustee n fails to give such'notification Trustee, as
appropriate documentation including a mist agreement. f ownership or other
Any attempt by Trustee to effect such a transaction without MEMO approval shall be void, rib undo es re ME all well as its successor,e shall meaning remain liable for the payment of all successor or assigneecto?he temps and conditionstof this gre MEM with at lease 90 days notice of
of this paragraph shall bind Trustee's Orders.'Tnute
assignment within th e must pro
those newly opened or acquired, Trustee shall sell only MEMO money
F. At all of Trustee's retail establishment including locatioru d by MEMO. Trustee shall not appoint and /or offer
lace G. business as approve
its intent to close its current retail location and to reopen at spe another ther l proved places of business or future p
G. Trustee shall sell MEMO money orders only -at is agreement.
are services at or to any entity not a party to this agreement hours for the dtuatiOn of this agreement Failure to do so shall constitute a breach of this agreement
during course of norrrhal business order of any court, except for the benefit of MEMO.
H. Trustee shall remain open g I of execution, or sequestration by
p, No funds received by Trustee shall be subject to atrachrruen? e`, I tsader*iarlk and/or service maze without -MO's prior wntten consent for successive five (? year Pe4O? After
Trustee is prohibited from unauthorized use of MEMO's name o$o, and shall rethew automatically (60) this Agreement rent The term of this Agreement shall run for a period of five (5) years from the date no m notice to MEMO, and MEMO may ?tninate his Agreemen t f the upon sixty contract m
7. Term of Agreern Trustee may I-, this Agreem nt upon six (6) Mond, P ble for lost fee income to MEMO for the duraci
the initial five-year rezm of this Agrce?rnau y not rovide Proper terrtrination notice, Trustee shall be responsible
to this Agreerr>erat at any time, or any location covered termina
days prior written notice to Trustee. In the Tenter ? ?t 14week sales average- Notwithstanding the foregoing, MEMO may of any the following events:
effect Fee income shall becilculared using t according to the provisions of Paragraph 11 hereof, upon the h> gipueriing y order saes proceeds and money order
by this agecmeru, mme diacely and without notice, and/center x does dgm not en receive theaccounting dM usestation or payment of trust funds (including money insolvency, or moratorium
q ML, O or its designated check clearirt8 lxiri ing in the Rider to airs Agree<re tit under an bankmpteY+ re°
fees), within the time period acid on the terms sP a6 l nitre or any Guarantor of any Petition the a rgar Za' of a re ceiver trustee to take
B. Trustee or any Guarantor commits any act of iruoly o rb o any olan?y petition ahy t Trustee under any bankruptcy ' r or agency,
or sale for or by any creditogovernmental
law, or any law for the relief or, or relating to debtors, or assets to any levy, se""re, assignment
or assets of Trustee; or the subjection of any Trustee's prof Y
possession of the PToperY pursuant to this Agreement of Trustee and/or
C. The non-performance by Trustee of any obligations e of Trustee t and, without any notice from MEMO, constitute a default under any and all agreements O for the duration
inv. In the event bIEMO terminates this agreement due to a default Trustee shall 'responsible for lost fee income to MEMO
The happening of any of the foregoing events shall be a default under this Agreetnc'n
TnicteC s euarantot{s) with any other related corrgr
the sale Of money orders, money order Fees cue
imprinter and any and all materials or docvrrients provided to Trustee by MEMO pursuant. to chis
8. Termination. Upon the expiration ortermination of this Ageaily sales more immediately shall deliver to MEMO all cash receipts from 'hall survive the expiration or tenninatior of his
sales rr out the money order deliver
accounting; (store) copies of money orders issued if applicable; daily rep liabilities, and indemruries of Tnutee hereunder ' of anv such event -using te:trnruzt on
Ageernettt, including, but rut limited to, all blank money order form All obligation, covenanexpiration of this Agreement shall be effective as of the happening
nL A termination notice provided by MEMO for any reason other than the expiration or any location covered by this agreement in
Agreeme t whichever first occurs. MEMO may in-Vdiately tematiate this location
under pparagraph 7 hermf or upcm the: entry of confessed judgmen t to the contrary , violate an local, state or federal law or regulation or any court
A, In its sole discretion and not withstanding any other provision of the agreetrneti of its affiliates to violate or potentially Y
the event MEMO determines that compliance with this agecanent would cause MEMO or any
n or after the occ urrence of any
any attorney or the Prothonotary or Clerk of any court of record, upon
pursuant to this Agreement' the
order. amount of all money orders sold puts
9. Confession of Judgment Trustee hereby icrev t Trustee for the face due MEMO under this Agreement,
and to confess or enter judgment a xgim cee t lg./.), and for any other sums
event described in paragraph 7, to appear interest expense not to exceed eighteen percrn (t of said amour?t and s"ms+ for collection as provided herein
applic.bie Money Order Fees, accrued inteforreast le thin, `4 -t attorney's fees and said fees not to exceed thirty percent (?./e) ariounit by
together Trustee or on behalf of Trustee by said
with expenses and coat of suit and reasorhab dhis Agreement or a. copy hereof verified Obtained
irchwing all legal fees incurred in any Bankruptcy of Trnrstee I. such phrpose, warrants obtained herein shall be enforced in accordance with the
attorney, Prothonotary or Clerk shall be sufficient warrant. The remedies of MEMO the a provided herein and as often as occasion therefore shall occur. The failure to
and may be pursued singly, successively, or together at sole discretion of and MEtheMO an to 'appear for and confess or enter judgment against
terns of this Agreement as a waiver or release thereof The authority and power W own nm?? and desirable, and this
exercise any such right or remedy shall in no event be construed from time to time, as often as MEMO cotmties for all or pan of the
not be exhausted by the initial exercise thereof, and the sane maybe exercised, for any
Tmstee shall ants may bs confessed or entered in the same by different behalf Y opened upon application Agreement or a copy hereof shall be a sufficient Warrant therefoeri erect One ag?t Trost hereunder is stricken or w? again ? for and confess or enter judgment against
h In the event any judrn a and only and to the
i
stars described in this paragtsp the Prothonotary or Clerk of any court of record is hereby authorized and ernpo errors in prior proceedings
subsequent entry or confession of judgment may only be done to cure any
whatsoever, then any attorney or such
Trustee; subject, however, to the limitation that
extent that such errors are subject to cure in the late proceedings'
ce or other fault shall be absolutely liable: Order Fees, and all other monies due MEMO under this Agreement, regardless of the
10. Liability. Trustee, regardless of Trustees freedom from negligence livable Money
to MEMO of the face amount of all money orders sold the app on won of the hares[ or dishonest act of any person act of God, otherwise
irids A To make remittarnce ham Trustees MEMO to Trustee that are subse -dy
mysterious or nor-mysterious disappearance or loss of any that may e pendecl by or for MEMO in paying any money orders delivered by
B money order as to which Trustee shall have fully performed
shall not apply to -Y
B. To remit to MEMO the total amount of all sums of money Y the same This s,bp,,gaph
presented for payment, whether or not MEMO is legally liable to pay judgments, assessments, fines
suits, proceeding,,
or
from or ansing out Y
and hold harmless MEMO from and against any and all losses, damages, liabilities, claims, sustained actitironsME, resulting MO of any
Trustee's duties under this Agreement
11. Indemnity. Trustee shall ithdetrit»Ey, defend but not limited to, settlement cost acrd reasonable legal and accounting ) ?? (whether within ei without their scope of perfomtance)•
penalties, cosM o wk the and expen hones t or otherwise by Trustee a Trustee's employees MO,s Property f version Trustee hereby gram MEMO a continuing perfect
MEMO as its agent, and in order protect ME, to execute all documents uire additional
12 Security. As further conshonest, ideration of appointment by of lease, and fixtures at all Trustee locations. Trustee Furthermore, agrees MEMO reserves the night to req
'rou NCC fillings
interest in Trustee's bank account n tol??°antt? bUnifform Commercial Code Finaruial Statement
inters[, including, ownership in Trustee's business iii anY transaction ?'? to those set
such secuuiry t In the event 'rrinsree changes such transaction until such time as
collateral as it deems necessary for ongoing approval and for the duration of the Ageerrierr a security interest in the proceeds of any
forth in paragraph 6(E) hereof, without prior notice and approval by MEMO as set forth therein Trustee hereby giants an approved trust account is re-established-
F TOTRU5TEE: sSeelattbe in writing achhedltider and addressed as follows:
13. Notices. Except as otherwise: stated, all notices, correspondence, and communications under Agreement
IF TO MEMO: MEMO
P.O. Box 8863
Camp I lill, PA 17001-8863 sales re]ating to the choice or conflict of laws.
and in accordance with the laws of the Commonwealth of Pennsylvania disregarding any h 11 hereof, in any other coon of record
14. Choice of Law. This agreement shall be construed in Cumberland County, I'eruhsylvarhiaa, or, in the case of MEMO's exercise of riglhts under r P aragrap
The parties consent to venue and personal jurisdiction federal, state and kcal laws and reguations applicable to Trustees business and
in Pennsylvania or elsewhere and employees to abide by) all fed c Federal cash reporting reyctiterrierhts and regulations; (d) Sum
15. C,,nplianc a with law. Trustee shall abide by (and cause its officers Pt ws; (b) the Bank Secrecy Act and its regulations; ( )
services provided. They are to include but are not limited to (a) State Lken ? a) all miles and regulations; (t) aft app cue state laundering d money transfer or sale of a beck laws and regulation; (9)
Currency reporting re luirrments; (e) Federal and/or State and n1O?Y
breach
federal and stare prvacy laws and regulations: (h) the USA Patriot Act shall not constitute a waiver or any or of any
orits failure to declare a default under this Ageerrirnt of this Ageemetu
16. Nor[-Waive. 'The faltue of MEMO to enforce any provision ot th fat o Agreement MO to proceed as hilly as if it had not tailed to enforce any p- p
provision of the Agreement and shall not prejudice the tight and/ Or that MEMO shall, in addition to all rights it might have under the law, have the right of senf r sae nt of
enforcement of his Agr-rient and/or the enforcement o
Trustee -9- the
of this Agreement, sdiction of a court of equity regarding
17. Enforcement. In the event of default under the terms th
Furdxarrioi'e, 'T'rustee agrees to consent to e 1
-e in ights the court event ?ry Trustees. s fees insured by MEMO in connection with the enforcement of this
perfom>W r
MEMO(s) rights in the of arty default by MEMO, all costs and expenses including reasonable aromey' .
18. Cost of Enfor chasm-, Trustee shall pay, on demand by shall include all other genders. All covenants,
Agree-L shall be construed to include the plural where applicable and the miassuline of this Agreement are for
19. Consuuction. All references in this Agreement in the singular ' Dint and several convetiariLS. Headings of the paragzphs
t assumed by Trustee shall be, and shall be deemed to be, j
agreements and obligations in this Ageemern or contents of this Agreement MEMO for the issuance of
convenience only and do not limit expand, or otherwise construe the provisions security docharieriLS and such rules and regulations as may be promulgated by between the parties with
remment This Ageeirieri4 toga tier with all tare agree e m between ? 'there are no, other ogee it ..il s undersmnoiing? y written 20. Entire Ag ent to in woorg W d by par- This Agreement
money orders from time to time, shall constituute the entire be n m or alterations to this AgrerYr>er>< telefax S is as valid
c There shall be n e modifications, ? and pier UVIS. MEMO and Trustee understand that a completed 'g'ang
-pea to the subject matter of this Agreerren successors, rep
shall bind and inure to the benefit of the Pares. their respective Vheirs, the ongahaf• t and he Rider. A COURT
21. Time of the Essence. Titre is of the essence in this Agreemen IF YOU DO NOT PAY ON TIME, AND E POWER OF A COURT CAN BE USED TO COLLECT FROM
WARNING - BY SIGNING THIS PAPER, YOU GIVE UP YOUR RIGHT TO NOTICE AND COURT
GOODS, FAULTY
N BE GOODS, FAILURE ON HIS WITOUT YOUR JUDGMENT MAY BE TAKEN AGAINST YOU ???GAINSTPTHE CREDIT?? R FOR YOU REGARDLESS OF ANY CLAIMS YOU CAUSE.
PART TO C MP Y WITH AGREEMENT, OR ANY OTHER 'IRUSTEE
Date INC / Corporate/St Name-- 0 ?. 1 ? . . a3 Yl
MERCIIANTS EXPRESS MONEY ORDER CON ANY,
MEMO MOX Y ORDER COMPANY, INC /
:R1 ONE'Y ORDER COMPANY O EW Y IK INC. /
` + ) USA lkC.
By v ` cWy
Tide
io/2937
Trustee Signatum(hidivid*
•I-_tee Signanrre(inarvnaoai
Trustee Signature(rditidual)
'T'rustee Sigmanure(hthdi<idual}
MERCHANTS EXPRESS MONEY ORDER COMPANY, INC.
MEMO MONEY ORDER A O P N W YORK, INC. MERCHANTS INC.
MEMO MONEY ORDER
EXPRESS USA, INC.
PERSONAL MONEY ORDER TRUST AGREEMENT
REMITTANCE BY ELECTRONIC FUNDS TRANSFER
executed herewith
both
This Rider is an integral part of the Personal Money Order Trust Agreement inn ext ut d by thewhenes simultaneous
Any changes to this Rider shall serve as an authorized addendum to the original
parties.
TRUSTEE: IT ?-
t,?
Corporate /Business Name /
5Ga State??4 Zip Code L?___
h-M
Street Address City
- ?5 s1 jL > ? ?gent Number _.?----
', 1(-(7C., /'?, Fax Number
Telephone Number Partnership Sole Proprietorship
Legal Entity: Corporation LLC 'je MONEY ORDER FEES:
Money Order fees shall based _ Money Orders ??d by Trustee. Trustee's
g price of $ Additionally, a
item weekly a volume
50 the average
maximum retail sellin
Money order fee shall be e $ 4 apply plus
money included on
draft. Monthly money order dispenser fees sh ll bes
order dispenser fee of $ Per week/month shall
shall be included with Trustee's last (if applicable) regular weekly
the next regular weekly ACH draft following the last calendar day of a particular month. i per month beginning on
The minimum monthly revenue generated by Trustee's account must equal $ g the close of a
The difference between the minimum monthly revenue notice approximately three weeks followiner fees/money and a order dispenser fees will be calculated monthly, reported via debit transmittal
calendar month, and will be drafted one week thereafter as part of Trustee's regular ACH draft.
Money r fees may be modified by MERCHANTS EXPRESS ifON°EY ORDER COMPANY, INC. d/b/a MEMO, or MEMO
Order Y
MONEY ORDER COMPANY, INC. d ew MEMO, Pennsylvania rporations, or MEMO MONEY ORDER COMPANY O
?RCHANTS EXPRESS USA, INC. d/b/a MEMO,
NEW YORK, INC., d/b/a/ MEMO, a New York Corporation O's to'?>
on thirty (30) days notice to Trustee or when 1VIEM0 ten week sales analysis indicates per item weekly volume not
any time up
consistent with MEMO's fee rate schedule.
PROCEDURE FOR SALE OF MONEY ORDERS:
Trustee shall sell money orders strictly pursuant to the following procedures:
sare eem in
that not them j ney ordenor rs
money orders in each retail establishment. Trustee shall ensure
A. Trustee shall sell only MEMO secure at all times, and that
l °Pa dYhand shall cease the issuance of?money orders and notify NIEMO
toorders etalong
able such money
the opinion of a reason person,
immediately, should such jeopardy arise.
ee shall sell money orders in strict numerical sequence in accordance with the numbs printed on each blank money order.
B. Trust JOa
C. The face amount of any money order sold by Trustee shall not exceed the sum of $
the applicable amount on the face of the money
D. Trustee shall not issue a money order until such time as Trustee has imprinted collected from the pp utilizing only the imprinter approved by NIEMO and no other imprinter; and removed and purchaser the face ( amount of store)
order,
the money y order and an additional amount determined by Trustee's retail copy of the money order if applicable.
mone order imprinter is not in proper operating condition or properly inked, Trustee shall immediately report such fact to
E. If the y
MEMO's Help Line at 1-800-864-5246.
MEMO may deliver blank money orders to Trustee, or to any agent, employee or representative of Trustee, by whatever me ans
for blank money orders on behalf of Trustee.
F.
. i tO deems appropriate, and MEMO is authorize t receive and issue a receipt
TERMINATION: of the Trust :agreement by Trustee, Trustee hereby agrees to one day's written demand
Upon termination, can cellation, or breach next day US mail or common mail carrier all Trust instrum in its possession, including but money
due
notice by NIEDIO to forthwith return by
imprinting machines, all blank money order forms ?ma Est PPa d able see by?MEMO in the fe
to Tru
not limited to money order imp g balances due MEMO, al ty )on. g In with the any event othex that Trustee fails to return such items upon one
MEMO to date, and all other outstanding
the Tru st Agreement (hereinafter "Trust Proper
hereb authorizes MEMO or its repesentatives?e appointed yes reigpneesossesstoiaon pp by ear MEMO Trustee's place o
r costs of an MO shall be borne
accordance day's written with themand, Trustee y auth listed herein.
business and peaceably obtain custody of all such Trust Property
exclusively by the Trustee.
TRUST FUNDS REMITTANCE: y money order Sales Summary Report,
rder disment will be forwarded a weekly
Any Trustee utilizing electronic money or der Sales Summary Report will reflect money order sales for the
to the close of the sales reporting day. TThe ensi weekly money order
applicable reporting period.
SALES PERIOD:
BEGINNING DAY
uAlk (10
ENDING DAY
REPORTING DAY
ACH/WIRRE
Report. As per predetermined
on the weekly money order SalesnSaininm method of remittance i amount is visolda, plus
wire,
transfer of funds due MEMO. including value of money orders
Trustee will be provided all pertinent reporting ? formation the face v
schedules, MEMO will mate an trom
eof applicable money order sales proceeds plus money order fees from Trustee's
applicable fees due MENIO, from Trustee's bank account e MEMO's bank plus applicable i00 PM ne the designated remittance day. All
conincluded
Trustee will initiate a wire t to the money order Trust must be included with reemittance when due. p All outstanding statement balances due at this time must be
teleanphd/orone bank and paccountsromptly as identified
e
confirm in
its due MEMO and/or credits due Trustee. If MEMO o f tee such changes change ban by banks
funds due MEMO
with remittance, including deb if Trustee did not sell any money
clue MEM full.
in the Trustee's EFT agreement, Trustee shall immediately inform alarices as notified by MEMO. All voided money orders
writing. This arrangement shall not be revoked unless an funds o tstanding0 are pad in
s to Trustee's account. If a ayment for during the Sales Period, Trustee must sell p the sale date only to avoid charge
"NOT USED FOR PURPOSE INTENDED"
must be voided through the electronic money order dispenser during Trustee shall write,
voided money order is not voided in the money order dispenser, account
mone order and deposit the money order into Trustee's bank . If Trustee should write «v ex is
mone order to the MEMO office and MEMO will
al voided
on the backside of the original y
on the face of the original money order, Trustee shall forward the origin all ensure that the electronic money order er does
the electronic money order dispenser does not poll
e in the form of a replacement money order. Trustee sh
as xe uested. Trustee ensures that electric
issue a refund to Trustee data on a daily basis. available for MEMO to electronically transmit Polling
s promptly connected to a clear telephone line during electronic polling
consistently, Trustee must provide MEMO with the money order sales date manually q
s turned on and alway
money order sales dispenser is always turned on and alway
transmission times.
WEEKLY ACCOUNTING AND REMITTANCE: calculate a weekly money order
Gc V of each week, MEMO will AAB-Al and ?-transmission of the money order dispenser. MEMO will
on
es total from d?ily data obtained from Trustee via electronic polling store copies if
Order Sales Summary Report to Trustee as stated Trustee Trustee rustee must shall retain the reconcile accounting the weekly weekly Money Order
forward the weekly Money co pies, if
Sales rtin period. . Trustee shall forward the accounting (Store) i any differences.
eport with its records and inform MEMO °
, aSummary at its R its location for a period of three months from the p store copies are not requested during the unting applicable, to the MEMO office upon request.
copies c its own discretion.
period, Trustee shall discard the accounting (store) MERCIIANTS EXPRESS MONEY ORDER COMPANY, INC./
TRUSTEE MEMO MONEY ORDER COMPANY, INC. INC.
MEMO MO Y ORDER COMPANY OF NEW YORK,
MEMO EXISS USA, IN? f ?J
Signature
corporate St e Name
Signature o
p Date
4-L
Tide l- A ELECTRONIC: 10/07
Date
2)
MERCHANTS EXPRESS MONEY ORDER COMPANY, INC. - MEMO MONOEY ORDER COMPANY, ZNC•
MEMO MONEY ORDER COMPANY OF NEW
MERCHANTS EXPRESS USA, NC.
PERSONAL INDEMNITY AND GUARANTY ANY, INC. d/b/a/
and in order to induce MERCHANTS EXPRESS MONEY ORDoRM CEMO'MONEY ORDER
Intending to be legally bound hereby, INC d/b/a/ MEMO Pennsylvania Corporations, b a MEMO, or any subsidiary
MEMO, ?fEDIO MONEY ORDER COMPANY, INC, a New York Corporation, N?RCIiANTS EXPRESS USA, INC. d/
Rider and amendments or changes thereto as
certain Personal Money Order Trust Agreement,
COMPANY d/b/a/ MEMO OF (???fNEW ,pYO) to YOM l Money Order Trust Agreement,
« " i that
to time (collectively the "Agreement") with:
may be in effect from time
ma
Corporate/Business Name Zip Code
State ?
f -9_, - _r? c city
ersonally guarantee and
Street Address absolutely and unconditionally, p all
e Undersigned, jointly and severally,
without limitation the prompt and punctual and ? damage,
and in consideration of its so doing, th di
surety for Trustee's full performance of the Agreement, inclung and hold MEMO harmless again y
amounts becoming due from Trustee to MEMO thereunder, and shall indemnify
become ??Mp
's fees) and/or liability sustained by it by reason of or related to Trustee's failure to per
is°GuaranA
The loss expense (including attorney
Pennsylvania (to which
modified ME1?fO and Trustee without notice to the undersigned and without affecting this
m whether or not any action is
as to any other n court and state having jurisdiction, ounty,
may enforce this Guaranty against t the undersigned as the
jurisdiction of said Court the Undersigned consents),
ever taken by MEMO against Trustee.
except for notice of demand for payment from the
The Undersigned hereby waive all notices whatsoever with respect to this Guazanmcludin but not limited to any renewals, extensions,
modifications, rsi ned hereby consent to the taking of, or th Agreement, a to takeg, from time to time without notLc to the
U rights
Undersigned. The Unde g
ndersigned, any action any nature whatsoever with respect the ee an° f the foregoing. failure to
compromises, indulgences, waivers, surrenders exchanges, releases, and rto pursue or preserve
as provided herein,
and n,
difications, postponements, liable hereon notwithstanding any () payment, provided
against any p gn hereunder except the defenses of 1
erson, and the Undersigned shall remain fully
the Undersigned hereby waive all defenses whatsoever to the Undersi ed s liability
of
lack of notice as required in the Agreement.
Unoxdersany Clerk or
waiving attorney y de
Undersigned for all amounts
hereunder, the Undersigned hereby authorizes and end mp to owers confess juirrevocably thedgment against Prothonotary
errors, any
Upon default zersig leasing any court record of Pennsylvania or elsewhere t appear ° percent (30%) added for attorneys fees,
hereunder, plus all costs of suit, legal interest to date, and thirty p in accordance with the Pennsylvania Rules of Civil Procedure.
or copy hereof verified by affidavit by the Undersigned or on behalf of the Undersigned by said
execution, and authorizing the immediate issue of a writ of execution, all er g a ear for and to confess or enter judgment
as
For such purpose, this Guaranty o PY app Prothonotary, Clerk or attorney, shall be sufficient warrant. mitt. The authority and warrant a e e The Undersigned acknowledge that by
, as often therefor. against the Undersigned shall not be exhausted by the initial exercise thexehocf'1en a same may be exercised, from time to ?eroceedin to
MEMO shall deem necessary and desirable, and this Guaranty shall be a suf
O to confess judgment hereunder, the Undersigned have waived the right to notice in a prior judlci p
authorizing MElvi
determine their rights and liabilities.
This Guaranty is given in connection with and payment in connection with a
evidences the obligation of the Undersigned to make Guaranty is irrevocable tY
all be governed d by and construed in
rules relating to the choice or conflict of laws. shall have been paid all
commercial
disregarding an HThis Guaranty
- BY transaction. This
SIGNING THIS PAPER, YOU le GIandVE shall UP be bin YOUR ding and RIGHT operative until such time
Commonwealth of Pennsylvania, pursuant
sums owed to it the laws the Agreement
IF YOU DO NOT
PAY accord ON accordance with t TIME, he A COURT JUDGMENT MAY BE TAKEN TO NOTICE AND COURT TRIAL. OUR PRIOR AGAINST YOU WITH YOU ANY CLAIM O?MAY HAVE
FAILURE ON HIS PART TO
THE POWER OF A COURT CAN BE USED TO COLLECT FROM YOU REGARDLESS
AGAINST THE CREDITOR, WHETHER FOR RETURNED GOODS, FAULTY GOODS,
Y WIT AGREEMENT, OR ANY OTHER CAUSE.
r
CO All
f Guarantor's Signature
Chu rantor's Signature O d
Print Spouse's Name r, s
r fr-%
print Guarantor's Nam
?ome Address
Home Address
S Zi de .
Sta
? ? Zi Co Ci
State lp
City
Date 10/2007
"N/A" on line for second Guarantor's signature.
Date 'DIG please indicate by affixing
If not married,
PLED-OFFrCE
OF THE OMTH, MITARY
2010 JAN -5 PM 12: 10
CUMSE"N cwm
pal bA
C?a
i
MERCHANTS EXPRESS
MONEY ORDER COMPANY, INC.
PLAINTIFF
v.
Russell Matin
Individually, jointly and severally,
DEFENDANT
and
Mousumi Khatoon
Individually, jointly and severally,
DEFENDANT
and
MDMH, Inc., doing business as
Sunshine Market
Corporation
DEFENDANT
r~ •~.,,
r_-
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COURT OF COMMON PLEAS,
CUMBERLAND COUNTY
No. 2010 - 0182 Civil
ORDER TO MARK JUDGMENT SATISFIED
To the Prothonotary:
Kindly mark the above-captioned matter satisfied of record upon payment of your
costs only.
Kevin .. uktins, Esq.
Attorney for Plaintiff
Attorney ID: 76859
Merchants Express Money Order Company
1029 Mumma Road
P.O. Box 8863
Camp Hill, PA 17001-8863
(800)543-8207
AI
CERTIFICATE OF SERVICE
I, Kevin M. Lutkins, Esquire, hereby certify that on this 14th day of April, 2010, I
served a true and correct copy of the foregoing Order to Mark Judgment Satisfied upon
the following individuals and parties of record via First Class Mail, postage prepaid.
MDMH, Inc.
56 Washington Street
Lynn, MA 01902
Russell Matin
182 Western Avenue
Lynn, MA 01904
Mousumi Khatoon
182Western Avenue
Lynn, MA 01904
Kevin M. Lutkins, Esq.
Attorney for
Merchants Express Money Order Company
1029 Mumma Road
P.O. Box 8863
Camp Hill, PA 17001-8863
717-760-5903