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Home My WebLink About01-1461 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METZGER, WICKERSHAM, KNAUSS & ERB, P.C., Plaintiff TODD A. FIELDS, Defendant NO. CIVIL ACTION -LAW 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 is served, by entering a written appearance, personally or by attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint, or document, 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. NOTICIA Le han demandado a used en la corte. Si used quiere defenderse de estas demandas expuestas en las paginas siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notificacion. Used debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomaramedidas y puede entrar una orden contra used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero o sus propiedades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717/249-3166 Document #: 200136.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METZGER, WICKERSHAM, KNAUSS & ERB, P.C., Plaintiff VS. TODD A. FIELDS, Defendant CIVIL ACTION -LAW COMPLAINT AND NOW, comes Plaintiff, Metzger, Wickersham, Knauss & Erb, P.C., by and through its attorney, Steven C. Courtney, Esquire, and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Metzger, Wickersham, Knauss & Erb, P.C, is a professional corporation authorized to conduct business in the Cormnonwealth of Pennsylvania with an office and/or a place of business situate at 3211 North Front Street, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Todd A. Fields, is an adult individual with a last known address of 26 Rear Factory Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff is, and at all relevant times material hereto was, a law finn providing legal representation and other related services to Plaintiff. 4. Defendant is, and at all relevant times material hereto was, the recipient of the legal representation and other related services rendered by Plaintiff. 5. On or about October 1, 1998, Defendant sought legal representation and advice by Plaintiff. Document #: 200136.1 6. Plaintiff and Defendant emered into a contract whereby legal representation and other legal services would be provided by Plaintiff and on behalf of Defendant. 7. Pursuant to the parties agreement, Defendant would remit payment to Plaintiff on behalf of the services and other related costs provided and/or incurred by Plaintiff. 8. At all relevant times hereto, Plaintiff provided legal representation, advice, attended hearing and performed and/or rendered other related services on behalf of Defendant. 9. The prices charged for the legal services rendered by Plaintiff and on behalf of Defendant were the fair and reasonable prices of the services, and the prices that Defendant agreed to pay. 10. Defendant has accepted the services provided by Plaintiff pursuant to the terms and conditions of the parties agreement. 11. Plaintiff has maintained a statement of account keeping an accurate and running account of debits and credits for the services provided to Defendant by Plaintiff. A true and correct copy of the Statement of Account is attached hereto, incorporated herein and marked as Exhibit "A". 12. Plaintiff has submitted to Defendant a statement of the account accurately showing all debits and credits for transactions with Defendant. 13. Defendant has not objected to any of the monthly statements of account submitted by Plaintiff to Defendant. 14. As of February 13, 2001, the balance due, owing and unpaid on Defendant's Document 14:200136.1 account with Plaintiff is the sum of Three Thousand Two Hundred Twenty-five and 21/100 Dollars ($3,225.21). 15. Despite Plaintiff's reasonable demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on Defendant's account balance, all to the damage of Plaintiff. 16. Plaintiff has performed any and all conditions precedent to the bringing of this action. 17. arbitration. The amount in controversy is within the jurisdictional amount requiring compulsory COUNT I BREACH OF CONTRACT 18. Paragraphs One (1) through Seventeen (17) are incorporated herein by reference as if set forth in their entirety. 19. Defendant has accepted the services provided by Plaintiffpursuant to the terms and conditions of the parties' agreement. 20. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on Defendant's account balance, all to the damage of Plaintiff. WHEREFORE, Plaintiff, Metzger, Wickersham, Knauss & Erb, P.C., respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Todd A. Fields, in the amount of Three Thousand Two Hundred Twenty-five and 21/100 Dollars ($3,225.21), plus Document #: 200136.1 interest, the costs of this action, attorney fees and such other relief as the Court deems just and proper. COUNT II OUANTUM MERUIT 21. Paragraphs One (1) through Twenty (20) are incorporated herein by reference as if set forth in their entirety. 22. The aforesaid amount of Three Thousand Two Hundred Twenty-five and 21/100 Dollars ($3,225.21) is the fair and reasonable value of the legal services provided to Defendant by Plaintiff. 23. Despite Plaintiff's reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay the fair and reasonable value of the services rendered to Defendant plus any accrued interest, all to the damage of Plaintiff. WHEREFORE, Plaintiff, Metzger, Wickersham, Knanss & Erb, P.C., respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Todd A. Fields, in the amount of Three Thousand Two Hundred Twenty-five and 21/100 Dollars ($3,225.21 ), plus interest, the costs of this action, attorney fees and such other relief as the Court deems just and proper. COUNT III UNJUST ENRICHMENT 24. Paragraphs One (1) through Twenty-three (23) are incorporated herein by reference as if set forth in their entirety. Document #: 200136.1 25. Defendant would be unjustly enriched if he was permitted to benefit from the services provided by Plaintiff without paying the monies owed to Plaintiff. 26 The aforesaid legal services provided by Plaintiff and accepted by Defendant have enriched Defendant in the amount of Three Thousand Two Hundred Twenty-five and 21/100 Dollars ($3,225.21). 27. Said enrichment would be unjust if Defendant was not required to pay the monies owed to Plaintiff, and said Defendant accordingly is obligated to Plaintiff for said amount. WHEREFORE, Plaintiff, Metzger, Wickersham, Knauss & Erb, P.C., respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendant, Todd A. Fields, in the amount of Three Thousand Two Hundred Twenty-five and 21/100 Dollars ($3,225.21), plus interest, the costs of this action, attorney fees and such other relief as the Court deems just and proper. Respectfully submitted, Dated:Q~.) 2001 J! METZGER, WICKERSHAM, KNAUSS & ERB, P.C. BY; re st 3211 N. Fron~x.~t Box 5300 Harrisburg, PA 17110 (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document #: 200136.1 VERIFICATION I, Nancy Markey, do hereby certify that I am the Office Accountant for the Plaintiff and the statements made iu the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C. $. §4904 relating to unsworn falsification to authorities Dated Nancy Mar~yy Document#:162754.1 Exhibit A 717/238 8187 Noven%ber 1, 2000 Billed t}urou~h 10/31/00 Bill nk~nber Todd A. Field~ 26 W. Factory Street #Rear Mech~/~icsburg, PA 17055~6207 000091-00159-033 SCC billing timekeeper STEVEN C. COURT~EY date of last bill 08/18/00 date of last reminder 08/18/00 (SCC) 3-s~u~z~ary fees ~d exp 4-bill fees and exp 5 sumn~ary fees/detail e 30 days 60 days 38~57 90 d~ys 29.32 120 d~ys 3118.75 billing freq~/ency M-09 last pa~nent 09/07/99 .00 billing realization 98 % FIELD~, TODD $ 3,186-64 717/ fees billed to date exps billed to date fees recd to date exes recd to date * [ ] OK - Send Out * [ ] Correct and Send ~t * [ ] Correct and Return * [ ] Re=ur~ for Letter * [ ] Delete/Hold 4842.00 436.35 1998.21 194.35 TOTAL CPL~GES FOR THIS BILL $ .00 ~ET B]~LJ%NCE FORWA/~D $ 3,186.64 38.57 3225.21 .00 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-01461 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND METZGER WICKERSHAM KNAUSS & ER VS FIELDS TODD A R. Thomas Kline duly sworn according to law, says, that he made and inquiry for the within named DEPENDANT FIELDS TODD A but was unable to locate Him deputized the sheriff of YORK Sheriff or Deputy Sheriff a diligent , to wit: in his bailiwick. County, serve the within COMPLAINT & NOTICE who being search and He therefore Pennsylvania, to On April 2nd , 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep. York Co 53.12 Service 6.20 96.32 0~/02/2001 METZGER, Sheriff of Cumberland County WICKERSHAM Sworn and subscribed to before me this )/~----'~ day of 6~3~ A.D. P~othonotar~ ' COUNTY OF YORK OFFICE OF THE SHERIFF 28 EAST MARKET ST, YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1. PLAINTiFF/S/ 2. COURT NUMBER 01-1461 Civil Metzqe, Wickersham, Knauss & Rrb,_ P.C. 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ Notice & Complaint Todd A. Wields ~' 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION DP PROPERTY TO SE LEVIED, ATTACHED, OR SOLD. SERVE Todd A. ~ie]ds · 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO. C~TY, BORO, TWp., STATE AND Z~P CODE AT · ]46 S. Second St, Dillsburg, PA 17019 7. INDICATE SERVICE: r~ PERSONAL r~ PERSON IN CHARGE ~1DEPUTIZI~ UI~i [~:~1'~[~ ~J r~ 1 ST CLASS MAIL [~ POSTED D OTHER NOW ~/20/0] 19 I, SH E-RIFF OF ~]~RK.~O_U.U N.~[, P..~ll~'do hereby d. gj;luj~.[~t, he sheriff of v o r k _ _ COUNTY to ex ef..~~ [9~according to law. This deputation being made at the request and risk of the plaintiff. ~.. · SHER~¢F ql ~"~(~COUNTY -- 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING Cumberl and OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY SHERIFF NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any propetty under within writ may leave same without a watchman, in custody of whomever is found in possession, a~ter notifying person of lev? or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10, TELEPHONE NUMBER 11. DATE FILED METZGER WICKERSHAM 3211 N. FRONT ST. PO BOX 5300 HBG., PA 17110 238-8187 3-13-01 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND CO. SHERIFF SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 13. I ~cknowledge receipt of the writ SIGNATURE OF AUTHORIZED CLERK 14. Date Received 15~ Expiration/Hearing Date or complaint as indicated above. R. AHRENS 3-21-01 4-12-01 16, HOW SERVED: PERSONAL ( ) RESIDENCE~J~ POSTED ( ) POE { ) SHERIFPS OFF ( ) OTHER ( ) SEE REMARKS 17. Q I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc, named above. (See remarks below) 18. NAME AN~) TITLE OF INDIVIDJf~..S~RV~ED / LIST ADDRE~ HERE IF NOT SHOWN A~DVE (Relationship to Defendant) I 19. D~te of Service) 20. ]~me of Service 21.ATTEMPTS[D,~I~[TimelI~es[ Ct. [DatellNme Miles Int. Date Time!Miles Int, IDatelTime ~liles Int. l'DatelTime Miles Iht. Date Tme Miles 22. REMARKS: '~34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Cert. 38. Mileage/Postage/N.E 39. Total Costs 40. Cost Due or Refund 28~{ so ANSWER. ,, Deo, She~ff ~ 3/28/01 MY COMMISSION EXPIRES '~ ~ '-~ ~unN Shedff 5 Date COUNTY OF YORK OFFICE OF THE SHERIFF 28 EAST MARKET S'[, YORK, PA 17401 SHERIFF" SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1. PLAINTIFF/S/ 3. DEFENDANT/S/ SERVICE CALL (717) 771-9601 INSTRUCTIONS PLEASE TYPE ONLY LINES 1 TO 12 DO mT DETACH ANY C~S. 2. COURT NUMBER ~ i ~; r:, ~, 4, TYPE OF WRIT OR COMPLAINT SERVE ~* 5. NAME OF INDIVIDUAL COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO., ClT~ BORO TWp., STATE AND ZiP CODE 7. INDICATE SERVICE: r~ PERSONAL ~] PERSON IN CHARGE ~ [3 DEPUTI~ [j ;'~ F~[~ (~E~T~ MAIL O 1 ST CLASS MAIL r~ POSTED [] OTHER NOW , , r~ ~ 19 __ I, SHERIFF OI~'OR~/C'OUNTY, PA, do hereby deputize the sheriff of '·~ ~ COUNTY to execute this Writ and make return thereof according to law. This deputation being made at the request and risk of the plaintiff. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: NOTE ONLY APPUCABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy shedff levying upon or attaching any property under within wdt may leave same without a watchman, in custody of whomever is found in possession, affer notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before shedff's sale thereof, 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE. 1711 ~ ~; ~ ..;; ~ .i NUMBERL 11. B~A'~E FILED 12. SEND NOTICE OF SERVICE COPY TO NAME ,AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THiS LINE 13. I acknowledge receipt of the writ SIGNATURE OF AUTHORIZED CLERK 14 Date Received 15 Expiration/Hearing Date or complaint as indicated above. ~ ~ ~i '? ~'~ ~- :2 ~ ,, /~ ( ) RESIDENC.~%'~ ) POSTED ( ) POE ( ) SHERIFF'S OFF ( ) OTHER i ) SEE REMARKS 16. HOW SERVED: PERSONAL 17. O I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc, named above. (See remark~ below.) 18. NAMEANDTITLEOFINDIVlDUALSERVED/LISTADDRESS ,ERE IF NOT SHOWN ABOVE (Re afionship to Defendant) 19 ~)ateof.$en/ice 20 Time of Ser~ice 21. Al'tEMPTS, ~t~l ([Time[Mites?.t~;;' I ;tnt'] I [ q ID're ,Tim~ ut,.I ,.t.g.I. I i I TImel Mt,e.[ t.t. [ O.te I' ~' Miles Int. Date :l' Time! Mgesi, tnt. Date Time i'Mges' Int. · 2, ,3 ~NotaryFee 31.Surcharge 32. TotaICosts 33. CostD~;orRefunO ~. 23. Advance Costs 24. Se~'ice Costs 25. N/F 26. Mileage 27, Postage 8. Sub Total 29. Pound 0. .<, 34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Ced. 38. Mileage/Postage/N.E 39. Total Costs 40. Cost Due or Refund · .... SO ANSWER· 2·Uayof ; / /, , <- ' ;~/~,, ' County Sheriff OF AUTHORI~D ISSUING AUTHORI~ AND TITLE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METZGER, WICKERSHAM, KNAUSS & ERB, P.C., Plaintiff TODD FIELDS, Defendant NO. : : .. : _. .. 2001-01461 CIVIL ACTION -LAW PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against: Todd Fields, for want of Answer to Complaint. ( X ) Assess damages as follows: Debt ......................................................................... $ 3,225.21 Interest from date of judgment .......................................... STo be determined Attorney's Commission .................................................. $ To be determined Filing costs ................................................................. $ To be determined TOTAL ..................................................................... $ 3.225.21 ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( X ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this p~aecipe and a copy of the notice is attached. DATE: ~.~ Signature: //' \ PO ~B6x 5300 -- Harrisburg, PA 17110 (717) 238-8187 Supreme Court ID#: 74669 Attorney for Plaintiff NOW, Document ~: 204130.1 ,2001, JUDGMENT IS ENTERED AS ABOX/~. Deputy [3] Pardon and Parole ~::~56 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METZGER, WICKERSHAM, KNAUSS & ERB, P.C., Plaintiff VS. TODD A. FIELDS, Defendant NO. 2~1-01~1 CIVIL ACTION -LAW TO: TODD A FIELDS 26 Rear Factory Street Mechanicsburg, PA 17055 DATE OF NOTICE: APRIL 17, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Pennsylvania Lawyers Referral Service Pennsylvania Bar Association P.O. Box 186 ~ Harrisburg, Pennsylvania 17108 /f~ ~ (800) 692-7~/~ By: ~ ~X Steven C. Cou~ey,~quir~) METZGER WICKE~ 3211 N. Front Street Harrisburg, Pennsylvania 17110 Telephone: (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document #: 203436.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METZGER, WICKERSHAM, KNAUSS & ERB, P.C., Plaintiff VS. TODD FIELDS, Defendant NO. .. _. .. .. .. 2001-01461 CIVIL ACTION -LAW TO: TODD FIELDS, Defendant You are hereby notified that on ]~f)O't~ ,~7t ~,~C'Y')! ,thefollowing(~) (g~,gve~) (Judgment) has been entered against you in the above captioned case for your failure to file an answer to the complaint. A Judgment in the total amount of $3.225.21, plus interest and costs (to be determined), and attorney's fees (to be determined). Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: Todd Fields 26 Rear Factory Street Mechanicsburg, PA 17055 Document #: 204130. l A~ TODD FIELDS, ido/a (Defendidos/as) Por este medio se le esta notificando que el del de · el/la siguiente (Ord.) (t~o) (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Prothonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Todd Fields 26 Rear Factory Street Mechanicsburg, PA 17055 Document ii: 204130. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METZGER, WICKERSHAM, KNAUSS & ERB, P.C., Plaintiff TODD FIELDS, Defendant NO. .. .. .. .. .. 2001-01461 CIVIL ACTION -LAW ENTRY OF APPEARANCE Please enter the Appearance of Steven C. Courtney, Esquire, as counsel for Plaintiff in the above captioned action. Respectfully Submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Date: By St~en C. Cm tn~Esauire Att~ney I.I~. P.O. Harrisburg/P ~ 10-0300 (717) 23~ Attorneys for Pla~tiff Document #: 204130.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METZGER, WICKERSHAM, KNAUSS & ERB, P.C., Plaintiff VS. TODD A. FIELDS, Defendant : NO. 2001-01461 ._ : ._ : ._ : : CIVIL ACTION -LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above referenced Judgment as satisfied in full. Dated: METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By ~y'f~