HomeMy WebLinkAbout01-1176BOEHRINGER -INGELHEIM VETMEDICA, INC.
Plaintiff
KENNETH KREAPS AND DEBBIE KREAPS, Each
Individually and Trading as KEN'S AGRI SERVICE
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO.
: CIVIL DIVISION - LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH 1N THE
FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND
NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND
FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A
JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY
CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU
MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE, OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HI~,LP.
OFFICE OF THE PROTHONOTARY
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE PA 17013
BOEHRINGER -INGELHEIM VETMEDtCA, INC.
Plaintiff
KENNETH KREAPS AND DEBBIE KREAPS, Each
Individually and Trading as KEN'S AGRt SERVICE
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. o/- / ?c.
: CIVIL DIVISION - LAW
COMPLAINT
The Plaint'iff, BOEHRINGER -INGELHEIM VETMEDICA, INC., by its attorneys, KNUPP, KODAK & IMBLUM,
P.C., brings this action of Assumpsit against the Defendants to recover the sum of SIXTEEN THOUSAND, TWO HUNDRED
AND FIFTY-THREE DOLLARS AND FORTY-EIGHT CENTS ($16,253.48), along with costs of this suit and interest thereon
from October 10, 2000 upon a cause of action of which the following is a statement:
1. The Plaintiff, BOEHRINGER -INGELHEIM VETMEDICA, INC., is a corporation organized and existing under
the laws of the State of Delaware, having its principal office and place of business at 2621 North Belt Highway, St Joseph,
Missouri 64506-2002.
2. The Defendant, KENNETH KREAPS, is an adult individual trading and doing business as KEN'S AGRI
SERVICE and has an office and place of business at 779 Creek Road, Carlisle, Cumberland County, Pennsylvania 17013-8965.
3. The Defendant, DEBB1E KREAPS, is an adult individual trading and doing business as KEN'S AGRI SERVICE
and has an office and place of business at 779 Creek Road, Carlisle, Cumberland County, Pennsylvania 17013-8965.
4. On the dates, in the amounts, and for the prices set forth in a tree and correct copy of the Plaintiff's books of
original entry hereto attached, made a part hereof and marked Exhibit "A", Plaintiff, at the special instance and request of the
Defendants, sold and delivered goods, wa~s and merchandise of the kind and description set forth on said Exhibit to the total
F:\L1SER~[ATHY'~MPLAINlh26750:26Feb01
amount of ELEVEN THOUSAND, SlX HUNDRED AND TWENTY-SlX DOLLARS AND FORTY-SlX CENTS ($l 1,626.46).
5. The prices charged for said goods, wares and merchandise wore just and reasonable, were the legal and market
prices therefor and were the prices which the Defendants promised and agreed to pay Plaintiff therefor.
6, Due to Defandants' default in payment of said amount due and owing as aforesaid, interest has beon added to
said aex, ount in the total amount of FOUR THOUSAND, SlX HUNDRED AND TWENTY-SEVEN DOLLARS AND TWO
CENTS ($4,627.02).
7. The batance due and owing by Defendants to Plaintiffis the sum of SIXTEEN THOUSAND, TWO HUNDRED
AND FIFTY-THREE DOLLARS AND FORTY-EIGHT CENTS ($ t 6,253.48), as appears by the Statement of Aceount hereto
attached, made a part hereof and marked as Exhibit "B".
8. Plaintiff has frequently demanded payment from Defendants of said amount due and owing as aforesaid, but
Defendants have refused and neglected and still refuses and neglects to pay said amount of any part thereof as shown on the
Affidavit as Exhibit "C" attached hereto and made a part hereof.
F:\L1SER~LAIN'B26750:26Feb01
2
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I CLAIMS FOR LOSS' OR DAMAGE MUST BE ACCOM
PANIED BY SIGNED REPORT FROM DELIVERING CAR
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OF DELIVERY. TO RETURN PRODUCTS FOR CREDIT
WRITTEN APPROVAL MUST BE OBTAINED FROI~
SELLER IN ADVANCE. SELLER MAKES NO WARRAN
TY, EXPRESS OR IMPLIED, EXCEPT THAT THE PRO
DUCTS SOLD SHALL BE MERCHANTABLE.
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METHOD OF SHIPMENT
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RIER, AND RECEIVED WITHIN 15 DAYS FROM DATI
OF DELIVERY. TO RETURN PRODUCTS FOR CREDIT
WRI'CI'EN APPROVAL MUST BE OBTAINED FROI~
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WRITFEN APPROVAL MUST BE OBTAINED FROk
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CLAIMS FOR LOSS OR DAMAGE MUST SE ACCOM
PANIED BY SIGNED REPOFFr FROM DEUVERING CAR
RIER, AND RECEIVED WITHIN 15 DAYS FROM DAT[
OF DELIVERY. TO RETURN PRODUCTS FOR CREDIT
WRITTEN APPROVAL MUST BE OBTAINED FRO~
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METHOD OF SHIPMENT
SHIP
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CLAIMS FOR LOSS OR DAMAGE MUST BE ACCOI~
PANIED BY SIGNED REPORT FROM DELIVERING CAR-
RIER, AND RECEIVED WITHIN 15 DAYS FROM DATE
OF DELIVERY. TO RETURN PRODUCTS FOR CREDIT.
WRIIlEN APPROVAL MUST BE OBTAINED FROM
SELLER IN ADVANCE. SELLER MAKES NO WARRAN-
TY, EXPRESS OR IMPLIED, EXCEPT THAT THE
DUCTS SOLD SHALL BE MERCHANTABLE.
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METHOD OF SHIPMENT
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CLAIMS FOR LOSS OR DAMAGE MUST SE ACCOM-
PANIED BY SIGNED REPORT FROM DELIVERING CAR.
RIER, AND RECEIVED WITHIN 15 DAYS FROM DATE
OF DELIVERY. TO RETURN PRODUCTS FOR CREDIT.
WRII~:N APPROVAL MUST BE OBTAINED FRO~/
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l'Y, EXPRESS OR IMPLIED, EXCEPT THAT THE PRO-
DUCTS SOLD SHALL BE MERCHANTABLE.
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CLAIMS FOR LOSS OR DAMAGE MUST BE AI~COM.
PANIED BY SIGNED REPORT FROM DELIVERING CAR-
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OF DELIVERY. TO Ri--tURN PRODUCTS FOR CREDIT!
WRIT-tEN APPROVAL MUST BE OBTAINED FROV
SELLER IN ADVANCE. SELLER MAKES NO WARRAN-
TY, EXPRESS OR IMPLIED, EXCEPT THAT THE
DUCTS SOLD SHALL BE MERCHANTABLE.
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OF DELIVERY. TO RETURN PRODUCTB FOR CREDIT
WRITTEN APPROVAL MUBT BE OBTAINED FBOIV
SELLER IN ADVANCE. SELLER MAKEB NO WARRAN.
TY, EXPRESS OR IMPLIED, EXCEPT THAT THE PRO
DUCTS SOLD SHALL BE MERCHANTABLE.
!7013-:~9~5
METHOD Of SHIPMENT
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T
AFFIDAVIT
STATE OF MISSOURI
COUNTY OF BUCHANAN
BE IT I%EMEMBEI~ED, that on this
~[~day of January, 2001, personally
appeared before me, the undersigned authority, Mark Kempf, known to me,
who being duly sworn, upon his oath, stated that he is Credit Manager of
Boehringer-Ingelheim Vetmedica
a corporation organized and doing business under the laws of the state of DELAWAI~E
and that as such makes this affidavit: that he is familiar with the books and
business of said Corporation; that the attached account against
Kenneth Kreaps dba
Ken's Agri service of carlisle, PA
is just and correct, within the knowledge of this affiant; that the items thereon
stated and composing the said account were sold and delivered to said account at
its special instance and request; that credit has been duly given for all payments
and just and lawful offsets to which said account is entitled as thereon stated;
and gha% the balance thereof amounting the sum of $11,~6.46 with interest from
is justly du. re.ains unpaid.
I hereby certify under my official seal that I am authorized as a Notary
Public to administer oaths under the laws of the State of Missouri
and that the foregoing was subscribed and sworn to before me on the day and
year first above stated.
Notary ~blic M
COUNTY Of BUCHANAN STATE OF MISSOURI
My commission expires
SARAH M~S~,~=~
NOTARY PUBLIC STATE OF MIS~)IJRI
A~REW COUNTY
~ C~[ON E~. JULY
VERIFICATION
I, ROBERT D. KODAK, state that ! am not a party to the action but that, at the request of the Plaintiff, BOEHRINGER
-INGELHEIM VETMEDICA, INC., and based upon knowledge, information, records and documents supplied to me by the
Plaintiff, the averments set forth in Plaintiffs Complaint are true. A Verification executed by the Plaintiff can be supplied at time
of trial or upon request.
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsification to authorities.
Robert D. Kodak
FAUSERXKATHY~CMPLAIIqT~26750:26Feb01
SHERIFF'S RETURN - REGULAR
CASE NO: 2001~01176 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERL~ND
BOEHRINGER-INGELHEIM VETMEDICA
VS
KREAPS KENNETH ET AL
DAWN KELL ,
Cumberland County, Pennsylvania,
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 9th day of March 2001
by handing to
true and attested copy of COMPLAINT & NOTICE
together with
says, the within COMPLAINT & NOTICE
KREAPS KENNETH
DEFEND~NT , at 0015:19 HOURS,
at 779 CREEK ROAD
CARLISLE, PA 17013
KEN KREAPS (ADULT SON)
a
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.1.0
Affidavit .00
Surcharge 10.00
.CO
31.10
Sworn and Subscribed to before
me this /~ day of
~t~A~ ~/ A.D.
rothonotary~
So Answers.
R. Thomas Kline
03/12/2001
KNUPP, KODAK & IMBLUM
Deputy Sheriff
SHERIFF'S RETURN
CASE NO: 2001-01176 P
COMMONWEALTH OP PENNSYLVANIA:
COUNTY OP CUMBERLAND
BOEHRINGER-INGELHEIM VETMEDICA
VS
KREAPS KENNETH ET AL
- REGULAR
DAWN KELL Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
KREAPS KENNETH T/A KENS AGRI SERVICE
DEFENDANT at 0015:19 HOURS, on the
at 779 CREEK ROA/}
CARLISLE, PA 17013
KEN KREAPS {AiDULT SON)
a true and attested copy of
was served upon
9th day of March
the
2001
by handing to
COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6
Service
Affidavit
Surcharge 10
16
0 0
O0
O0
O0
0 0
OO
Sworn and Subscribed to before
me this f~ day of
~,L~ Je~ / A.D.
honorary /
So Answers:
Thomas Kline
03/12/2001
KNUPP, KODAK & IMBLUM
Deputy Sheriff
SHERIFF'S RETURN -
CASE NO: 2001-01176 P
COHHONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BOEHRINGER-INGELHEIM VETMEDICA
VS
KREAPS KENNETH ET AL
REGULAR
DAWN KELL
Cumberland County, Pennsylvania,
says, the within COMPLAINT & NOTICE
KREAPS DEBBIE
DEFENDANT at 0015:19 HOURS,
at 779 CREEK ROAD
CARLISLE, PA 17013
KEN KREAPS (ADULT SON)
a true and attested copy of COMPLAINT & NOTICE
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 9th day of March 2001
by handing to
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.01}
Sworn and Subscribed to before
me this /g-~ day of
~ ,,2~.~ / A.D.
notary '
So Answers:
R. Thomas Kline
03/12/2001
KNUPP, KODAK & IMBLUM
By:
Deputy Sheriff
SHERIFF ' S
CASE NO: 2001-01176 P
COMMONWEALTH OF PENNSYLVS~NIA:
COUNTY OF CUMBERLAND
BOEHRINGER- INGELHEIM VETMEDICA
VS
KREAPS KENNETH ET AL
RETURN - REGULAR
DAWN KELL ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT & NOTICE was served upon
KREAPS DEBBIE T/A KENS AGRI SERVICE
DEFENDANT , at 0015:19 HOURS, on the
at 779 CREEK ROAD
CARLISLE, PA 17013
KEN KREAPS (ADULT SON)
a true
Sheriff or Deputy Sheriff of
who being duly sworn according to
9th day of March
by handing to
and attested copy of COMPLAINT & NOTICE
the
together with
, 2001
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6 00
00
00
10 00
00
16 00
Sworn and Subscribed to before
me this /g ~ day of
~ J.&o/ A.D.
thonot ary"
So Answers:
R. Thomas Kline
03/12/2001
KNUPP, KODAK & IMBLUM
Deputy Sheriff
BOEHRINGER -INGELHEIM VETMEDICA, INC.
Plaintiff'
KENNETH ICREAPS AND DEBBIE KREAPS, Each
Individually and Trading as KEN'S AGRI SERVICE
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1176 CIVIL TERM
CML DMSION - LAW
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUIVIBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT JUDGMENT
Enter judgment in favor of Plaintiff and against Defendant(s), KENNETH KREAPS AND DEBBIE
KREAPS, Each Individually and Trading as KEN'S AGRI SERVICE, Personal Guarantor, named for failure
to file within the required time an Answer to the Complaint in the above-captioned case and assess
the Plaintiffs damages as follows:
Amount claimed in Plaintiffs Complaint $16,253.48
Interest fi.om October 10, 2000 at the legal rate of 6% per annum $507,94
Total $16,761.42
It is hereby certified that a written notice of intention to file this Praecipe was mailed to the
Def~dant(s) and his attorney of record, at~er the default occurred and at least ten (I0) days prior to
the date of the filing of this Praceipe. See Exhibits A & B attached.
By
Robert D. Kodak, Attorney for Plaintiff
DATED:
Judgment entered and damages assessed as above.
Prothonotary
Robed L Knupp
Robert D. Kodok
Ga~/J. Imblum
LAW OFFICES OF
KNUPP, KODAK & IMBLUM, P.C.
CAMERON MANSION
407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
Telephone: 717/238-7159
Facsimile: 717/238~7158
email: kki-law~att, net
April 2, 2001
(1909-1976)
Rober~ H. Maurer
(1923-1998)
KENNETH KREAPS IND AND T/A
KEN'S AGRI SERVICE
779 CREEK ROAD
CARLISLE PA 17013-8965
RE:
VS:
Boehringer-lngelheim Vetmedica, Inc.
Kenneth Kreaps and Debbie Kreaps each ind. & t/a Ken's Agri Service
No. 2001 ol 176 Civil Term, Court of Common Pleas
Cumberland County, Pennsylvania
Our File No. 26750
Dear Mr. Kreaps:
In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith
a Notice of a PraecJpe for Entry of Default Judgment. According to the records as they are found
in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings
to the Complaint filed against you to the above term and number, nor has any attomey entered
an appearance on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do
not take action as set forth Jn this Notice, we, at the expiration of time indicated therein, will
request the Office of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment
against you in the amount as set forth in said Complaint.
Very truly yours,
KNUPP, KODAK & IMBLUM, P.C.
RDK/kqb
enclosure
Robert D. Kodak
cc: J E BESSENBACHER JR #122341
THE BESSENBACKER CO
POST OFFICE BOX 48108
KANSAS CITY MO 64148-0108
BOEHRINGER -INGELHEIM VETMEDICA, INC.
Plaintiff
KENNETH KREAPS AND DEBBIE KREAPS, Each
Individually and Trading as KEN'S AGRI SERVICE
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-1176 CIVIL TERM
: CIVIL DMSION - LAW
IMPORTANT NOTICE
TO: KENNETH KRF. APS IND. AND T/A KEN'S AGRI SERVICE , Defendant(s)
DATE OF NOTICE: APRII. 2. 2001
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU
IN THIS CASE. UNLESS YOU ACT WITH/N TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, OO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
NOTICIA IMPORTANTE
A:KF, NNETH KR~APS IND. AND T/A KF, N'S AGRI SERVICE. Demandado(s)
FECHA DE NOTICIA: APRIL 2. 2001
USTED NO HA COMPLIDO CON EL AVISO ENTERIOR PORQUE HA FALTADO EN TOMAR
MEDIDAS REQUERIDS RESPECTO AESTE CASE. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS
DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SEIA REGISTRADO CONTRA
USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD O OSTROS DERECHOS
IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGLViDA. SI USTED NO
TIENE ABOGADO O NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA O LLAME
A LA OFICINA ESCRITA ABA JO PARA AVERIGUAR A DONDE USTED PUEDE OBTENER LA AYUDA
LEGAC:
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
249-3166
BOEHRINGER -INGELHEIM VETMEDICA, INC.
Plaintiff
KENNETH KREAPS AND DEBBIE KREAPS, Each
Individually and Trading as KENvS AGRI SERVICE
Defendants
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-1176 CIVIL TERM
: CIVIL DIVISION - LAW
To KENNETH KREAPS IND. AND T/A KEN'S AGRI SERVICE, Defendant(s)
You are hereby notified that on
(Judgment) has been entered aga/nst you in the above-captioned case.
Judgment entered in the amount of $16.761.42.
,20_, the following
DATE:
Prothonotary
I hereby certify that the name and address of the proper person(s) to receive this notice is:
KENNETH KREAPS IND. AND T/A
KEN'S AGRI SERVICE
779 CREEK ROAD
CARLISLE PA 17013-8965
A/KENNETH KREAPS IND. AND T/A KEN'S AGRI SERVICE. Defendido/a Defendidos/as
Por este medio se le esta notificando que el de del 20_,
el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certiticao que la siguiente direction es la del defendido/a segun indicada en el cetificado de
residencia:
KENNETH KREAPS IND. AND T/A
KEN'S AGRI SERVICE
779 CREEK ROAD
CARLISLE PA 17013-8965
Abogado del Demandante
Roberl L Knupp
Robert D. Kodak
Gary J. Imblum
LAW OFFICES OF
KNUPP, KODAK & IMBLUM, P.C.
CAMERON MANSION
407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
Telephone: 717/238-7159
Facsimile: 717/238-7158
email: kki-~aw~att.net
April 2, 2001
Robert Ewing Knupf>
(190971976)
Robert H. Maurer
(1923-1998)
DEBBIE KREAPS IND AND T/A
KEN'S AGRI SERVICE
779 CREEK ROAD
CARLISLE PA 17013-8965
RE:
VS:
Boehringer-lngelheim Vetmedica, Inc.
Kenneth Kreaps and Debbie Kreaps each ind. & t/a Ken's Agri Service
No. 2001-1176 Civil Term, Court of Common Pleas
Cumberland County, Pennsylvania
Our File No. 26750
Dear Ms. Kreaps:
In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith
a Notice of a Praocipe for Entry of Default Judgment. According to the records as they are found
in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings
to the Complaint filed against you to the above term and number, nor has any attorney entered
an appearance on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do
not take action as set forth in this Notice, we, at the expiration of time indicated therein, will
request the Office of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment
against you in the amount as set forth in said Complaint.
Very truly yours,
KNUPP, KODAK & IMBLUM, P.C.
RDK/kqb
enclosure
Robert D. Kodak
cc: JE BESSENBACHER JR //122341
THE BESSENBACKER CO
POST OFFICE BOX 48108
KANSAS CITY MO 64148-0108
BOEHRINGER -INGELHEIM VETMEDICA, INC.
Plaintiff
KENNETH KREAPS AND DEBBIE KREAPS, Each
Individually and Trading as KEN'S AGRI SERVICE
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2001-1176 CIVIL TERM
: CIVIL DIVISION - LAW
IMPORTANT NOTICE
TO: DEBBIE KREAPS IND. AND T/A KEN'S AGK[ SERVICE , Defendant(s)
DATE OF NOTICE: APRIL 2. 2001
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU
IN THIS CASE. UNLESS YOU ACT W[THIN TEN (10) 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. 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
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
NOTICIA IMPORTANTE
A:DEBBIE KREAPS IND. AND T/A KEN'S AGRI SERVICE, Demandado(s)
FECHA DE NOTICIA: APRIL2. 2001
USTED NO HA COMPLIDO CON EL AVISO ENTERIOR PORQUE HA FALTADO EN TOMAR
MEDIDAS REQUERIDS RESPECTO A ESTE CASE. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS
DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SEIA REGISTRADO CONTRA
USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD O OSTROS DERECHOS
IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO
TIENE ABOGADO O NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA O LLAME
A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE OBTENER LA AYUDA
LE GAC:
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
BOEHRINGER -INGELHEIM VETMEDICA, INC.
Plaintiff
KENNETH KREAPS AND DEBBIE KREAPS, Each
Individually and Trading as KEN'S AGRI SERVICE
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-1176 CIVIL TERM
: CIVIL DIVISION - LAW
To DEBBIE KREAPS 1ND. AND T/A KEN'S AGRI SERVICE. Defendant(s)
You are hereby notilied that on in t~e ~ [.! l~ ,~ ,2~, the following
(Judgment) has been entered against you abo 7e-capiione,~ case.
DATE:
Judgment entered in the amount of $16,761.42.
Prothonotary
I hereby certify that the name and address of the proper person(s) to receive this notice is:
DEBBIE KREAPS IND. AND T/A
KEN'S AGRI SERVICE
779 CREEK ROAD
CARLISLE PA 17013-8965
A/DEBBIE KREAPS IND. AND T/A KEN'S AGRI SERVICE, De£endido/a Defendidos/as
Por este medio se le esta notificando que el de del 20_,
el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certificao que la siguiente direccion es la del defendido/a segan indicada en el cetiticado de
residencia:
DEBBIE KREAPS IND. AND T/A
KEN'S AGRI SERVICE
779 CREEK ROAD
CARLISLE PA 17013-8965
Abogado del Demandante