HomeMy WebLinkAbout11-6908
31- F! E
l HARTMAN UNDERHILL & BRUBAKER LLP 't t'? C u Tfa Y
By: Robert W. Pontz, Esquire r
Attorney I.D. No. 56554
221 East Chestnut Street fE RLV" D. COUNTY
Lancaster, PA 17602 Attorneys for Plaintiff. r' 1t Pi S Y Lti n l A
(717) 299-7254/(717)299-3160 (Fax) CIT Technology Financing Services, Inc.
CIT TECHNOLOGY
FINANCING SERVICES, INC.
Plaintiff
V.
CORPORATE DISTRIBUTION LTD.,
a/k/a Corporate Distribution Limited,
Inc.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. U,, l a q?g l lVi ?
: CIVIL ACTION -LAW
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served, by entering a written appearance personally or by attorney
and filing in writing with the Court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may proceed without you and
a judgment may be entered against you by the Court without further notice for any money
claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING
A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
Lawyer Referral Service
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Telephone Number (717) 249-3166
(800) 990-9108
00624289.2
QY`ti? ?q o?• ? I
12-9
1
i
NOTICIA
USTED HA SIDO DEMANDO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accio'n dentro
de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso
radicando personalmente or por medio de un abogado una comparecencia escrita y radicando
en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas asqui en
contra suya. Se le advierte de que si usted falla de tomar accio'n como se describe
anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de diner
reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el
demandante puede ser dictado en contra suya por la Corte sin ma's aviso adicional. Usted
puede perder dinero o propiedad o otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A
CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PEUDE PAGAR POR LOS SERVICIOS DE UN ABAGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
Lawyer Referral Service
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Telephone Number (717) 249-3166
(800) 990-9108
HARTMAN UNDERHILL & BRUBAKER LLP
Attorneys for Plaintiff
Dated: q 2] %1 By:
Robert W. Pontz, quire
00624289.2
It
HARTMAN UNDERHILL & BRUBAKER LLP
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554
221 East Chestnut Street
Lancaster, PA 17602 Attorneys for Plaintiff:
(717) 299-7254/(717)299-3160 (Fax) CIT Technology Financing Services, Inc.
CIT TECHNOLOGY IN THE COURT OF COMMON PLEAS OF
FINANCING SERVICES, INC. CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
V. NO.
CORPORATE DISTRIBUTION LTD.,
a/k/a Corporate Distribution Limited,
Inc., : CIVIL ACTION -LAW
Defendant
COMPLAINT
1. Plaintiff CIT Technology Financing Services, Inc. is a Massachusetts
corporation, qualified to do business in Pennsylvania, with a principal place of business at
10201 Centurion Parkway North, Suite 100, Jacksonville, Florida 32256.
2. Defendant Corporate Distribution Ltd., a/k/a Corporate Distribution Limited,
Inc., is a New York corporation with a principal place of business at 8 Long Lane,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. On or about November 15, 2006, Defendant entered into a written Lease
Agreement for certain commercial copying equipment ("Equipment Lease") with Canon
Financial Services, Inc. ("Canon Financial'). A true and correct copy of the Equipment
Lease is attached hereto, incorporated by reference and marked Exhibit A.
00624289.2
1 4. The particular equipment leased by Defendant from Canon. Financial ("Leased
Equipment") is described more fully in the supplier invoice, a true and correct copy of which
is attached hereto, incorporated by reference and marked Exhibit B ("Invoice").
5. Defendant took delivery of and accepted the Leased Equipment as described in
the Invoice attached as Exhibit B.
6. Canon Financial subsequently assigned the Equipment Lease to Citicorp
Vendor Finance, Inc. ("Citicorp"). A true and correct copy of a certification of such
assignment executed on behalf of Canon Financial is attached hereto, incorporated by
reference and marked Exhibit C. Under the terms of the Equipment Lease, Citicorp, as
assignee, acquired all of Canon Financial's rights and benefits in and to the Equipment
Lease and the Leased Equipment, including the right to receive all rental payments, but none
of Canon Financial's obligations under the Equipment Lease (See Exhibit A, ¶18).
7. Citicorp and its related entity Citicapital Technology Finance, Inc. assigned the
Equipment Lease to CIT Technology Financing Services I LLC ("CIT I I.LC") on or about
March 31, 2007. A true and correct copy of the applicable Notice evidencing such
assignment is attached hereto, incorporated by reference and marked Exhibit D. Under the
terms of the Equipment Lease, CIT I LLC, as assignee of the Equipment Lease from
Citicorp, likewise acquired all of original lessor Cannon Financial's rights and benefits in
and to the Equipment Lease and the Leased Equipment, including the right to receive all
rental payments, but none of original lessor Canon Financial's obligations under the
Equipment Lease (See Exhibit A, ¶18).
00624289.2 2
1 8. CIT I LLC further assigned the Equipment Lease to Plaintiff on or about July
7, 2011. A true and correct copy of the applicable Non-Recourse Assignment of Purchased
Assets evidencing such assignment is attached hereto, incorporated by reference and marked
Exhibit E. Under the terms of the Equipment Lease, Plaintiff, as assignee from CIT I LLC,
likewise acquired all of original lessor Cannon Financial's rights and benefits in and to the
Equipment Lease and the Leased Equipment, including the right to receive all rental
payments, but none of original lessor Canon Financial's obligations under the Equipment
Lease (See Exhibit A, $18).
9. The term of the Equipment Lease is sixty (60) months, with Defendant's first
payment having become due on November 22, 2006.
10. Under the terms of the Equipment Lease, Defendant is obligated to make sixty
(60) consecutive monthly installment payments of $4,356.84, plus applicable sales or use
tax.
11. Pursuant to the terms of the Lease, Canon Financial duly filed a UCC-1
financing statement with the Pennsylvania Department of State on November 29, 2006 (File
No. 2006112906542), placing of public record its ownership of the Leased Equipment. A
true and correct copy of said financing statement is attached hereto, incorporated by
reference and marked Exhibit F.
12. The Equipment Lease identifies a series of circumstances which constitute an
"Event of Default" by Defendant, including, without limitation, Defendant's failure to make
any payment due under the terms of the Equipment Lease (See Exhibit A, $15).
00624289.2 3
% 13. Defendant is in default under the terms of the Equipment Lease for, among
other reasons, failing to make the monthly rental payments due on January 1, 2010, and on
the same day of each month thereafter.
14. The Equipment Lease provides for the imposition of a late charge in the
amount of ten percent (10%) of each scheduled payment that is not paid on or before the due
date (See Exhibit A, ¶17).
15. As a consequence of Defendant's default under the terms of the Equipment
Lease, the following remedies, among others, are available to Plaintiff:
(a) Plaintiff is entitled to declare all amounts unpaid under the Equipment Lease to be
immediately due and payable in full, with Plaintiff retaining title to the Leased
Equipment;
(b) Plaintiff may terminate the Equipment Lease;
(c) Plaintiff may take possession of the Leased Equipment, with or without notice to
Defendant or legal process, and retain the Leased Equipment and all payments
under the Equipment Lease or, at Plaintiff's option, sell or otherwise dispose of
the Equipment, apply the net proceeds to the amount owed under the Equipment
Lease and collect from Defendant any amount remaining due after application of
such sale or disposal proceeds;
(d) Plaintiff may exercise any other right or remedy available at law or in equity; and
(e) Plaintiff is entitled to recover all costs of enforcing its rights including, without
limitation, reasonable attorneys' fees and court costs. Defendant has stipulated in
the Equipment Lease that if the lessor must bring any court action to enforce the
terms of the Equipment Lease, attorneys' fees in the amount of twenty-five
percent (25%) of the amount sought to be recovered by such court action shall be
deemed reasonable (See Exhibit A, ¶¶ 16-17).
16. The total amount due and owing by Defendant to Plaintiff, excluding
attorneys' fees and costs of suit, as a consequence of Defendant's defaults under the terms of
the Equipment Lease, is $142,231.19, as follows:
00624289.2 4
9*
Accelerated Rent Balance $129,193.64
Late Charges $ 13,037.55
TOTAL $142,231.19
17. On November 30, 2010, counsel for Plaintiff issued notice of default under the
Equipment Lease to Defendant and demand for return of the Leased Equipment and payment
of the accelerated balance. A true and correct copy of said written notice is attached hereto,
incorporated by reference and marked Exhibit G.
18. Despite Plaintiffs notice of default and demand for payment and return of the
Leased Equipment, Defendant has, to date, failed to comply with Plaintiff s demands.
19. CIT has complied with all of its obligations under the terms of the Lease.
20. As a consequence of Defendant's failure to pay rental due as required under
the terms of the Equipment Lease, Defendant is in breach of its contractual commitments to
Plaintiff.
21. As a consequence of Defendant's defaults under the Equipment Lease, as set
forth above, Plaintiff is entitled to recover damages in the amount of $142,231.19, as set
forth in paragraph 16 above, together with accruing interest, late charges and all costs of
enforcing its rights including, without limitation, reasonable attorneys' fees in the amount of
25% of the foregoing sum, as stipulated under the Lease, and costs of suit.
WHEREFORE Plaintiff, CIT Technology Financing Services, Inc., demands
judgment in its favor and against Defendant Corporate Distribution Ltd., a/k/a Corporate
Distribution Limited, Inc., in the amount of One Hundred Forty-Two Thousand Two
Hundred Thirty-One and 19/100 Dollars ($142,231.19), together with accruing interest, late
00624289.2
* charges, all costs of enforcing its rights including, without limitation, reasonable attorneys'
fees in the stipulated amount of twenty-five percent (25%) of the foregoing sum, as provided
under the Lease, costs of suit, and such other and further relief as the Court deems just and
appropriate under the circumstances.
HARTMAN UNDERHILL & BRUBAKER LLP
Attorneys for Plaintiff
Dated: I2 I By:
Robert W. Po , Esquire
00624289.2 6
VERIFICATION
I hereby verify that I am Vice President - Bad Debt Recovery for CIT Technology
Financing Services, Inc., the Plaintiff herein; that as such I am authorized to make this
verification; and that the information set forth in the foregoing Complaint is true and
correct to the best of my knowledge, information and belief. I understand that any false
statements contained herein are subject to the penalties of 18 Pa.C.S. 4904, relating to
unworn falsification to authorities.
Dated: Qlxw`?l
2-011
Mark R. Powers,
Vice President - Bad Debt Recovery
CIT Technology Financing Services, Inc.
00624289.2
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EXHIBIT B
{00511655.1 }
ge 7 of 43)
IKON Office Solutions Inc
CIO PNC Lockbox #827891
Route 38 and East Gate Drive
Moorestown, NJ 08057
(478) 238.7693
(478) 238-7694 fax
Bill To:
Canon Financial Services
158 Gaither Drive Suite 200
Mt. Laurel
NJ 08054
Line
Items:
Line Type
Transaction
Equipment:
IZITYOIC38
Invoice No:
Date:
Ship To:
Corporate Distribution Limited inc
8 Long Lane
Mechanicsburg
PA 17055
Description
IKON #1948899 Canon #466681
60088A
Oct 25, 2006
Amount
$222,287.76
Description S/N
Canon IR 110 NSW02092
Finisher XES01453
AspenV240 F N61510112
Cabinet CFS non serialized
Nlodem2 Booking Date non serialized
Cabinet MIP non serialized
Qla Kit NOV 1- 5 - 2 non serialized
--er-S-- - 2W6 Npupply non serialized
Stacker Doily non serialized
liMicator Lamp Approval r.on serialized
LO PAID
Total Due: E222,287.76
a
CJ
Banking Information: Funds to be wired to PNC Bank, 1600 Market St 19'h Fir, Philadelphia, PA 19103
v
Acct#8606089333, ABA#031000053, Swift Code: PNCCUS33
Make all wires payable to: IKON Office Solutions Inc
If you have any questions concerning this invoice, call (478) 238-7698
THANK YOU FOR YOUR BUSINESS!
{ I'SS91 ISoo}
CERITICATION OF ASSIGNMENT
This Certification of Assignment is executed and delivered by Canon Financial
Services, Inc. ("Canon") on )v?y 13 , 2011.
Canon entered into that certain Lease Agreement with Corporate Distribution
Limited, Inc. ("Customer") signed by the Customer on or about 9/29/2006, a copy
of which are attached hereto as Exhibit A (the "Lease").
Canon and CIT Technology Financing Services, Inc, as assignee of and
successor-in-interest to Citicorp Vendor Finance, Inc. ("CIT") are parties to that
certain Program and Servicing Agreement effective on July 15, 20044
("Agreement").
Canon hereby certifies that Canon sold and assigned the Leases and the
equipment covered thereby to CIT during 2006 in accordance with the terms and
conditions of the Agreement.
Canon Financial Services, Inc.
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Signature:
Name: soY K7 'rac&C F-
Title: N? GdG??d??tS ?j(?,y.?
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EXHIBIT D
{00511655.1 }
NOTICE
Please be advised that pursuant to a certain Purchase & Sale Agreement dated
as of March 31, 2007, Citicapital Technology Finance, Inc., a Pennsylvania
corporation, and Citicorp Vendor Finance, Inc., a Delaware corporation (each, a
"Seller", collectively, "Sellers") have sold, granted, conveyed and assigned all of
their respective right, title and interest in the contract(s) listed on Schedule A
hereto and any and all related receivables, equipment thereunder and ancillary
documentation thereto to CIT Technology Financing Services I LLC
("Purchaser'). This transaction closed as of 11:59 P.M. (EST) on April 30, 2007:
It is Sellers' and Purchaser's intent that this document be used as evidence in
legal proceedings of the transfer and assignment of the contract(s) and any all
related equipment thereunder and ancillary documentation thereto by Sellers to
Purchaser and their successors and assigns. Sellers by execution below and
Purchaser by acceptance hereof do consent to the filing of this Notice in court
proceedings for such purpose.
IN WITNESS WHEREOF, each Seller has caused this Notice to be executed in
its. name and by an authorized officer as of April 30, 2007.
Citicapi?tal?Technology Finance, Inc.
By: ' !/ tom-( C.xt,. c t',
Mary C. Tucker
Deputy General Counsel - Litigation Management
Citicorp-Vendor-Finance,-Inc,
By: 1!11
Mary C. Tucker
Deputy General Counsel - Litigation Management
CIT Technolog Fin ncing Services I LLC
By:
-4
'n
Title:] ?e¢
Schedule A
Purchased Asset:
1. CORPORATE DISTRIBUTION LTD 200280362 (CIT # 910-0059282-000)
a 1191.1XXXINCI
{ I'SS9I I S00}
a
i
NON=RECOURSE ASSYGNMEN T OR PVRR iSED ASSET
Crr Technology ImmmI ag; Services I LLC , a Delaware united liability
coiporatzQn, byavlug rts p4naiFai Plates 0budoom at I CIT Drive, LivingstM N'ew immy
07039 "Assitor")', for gal g grid valuable consideration, the re**. and s. fficieney
of wltieh ere Eby a?ckriouvldge<i? .hereby sells, °as?ggs, transfers' and aonveps to CI'I'
Technology I;3naacin
?g, Servim' Inc, a Musuhuseits corPor dpa, having its.place of
bus agesa at IQ2Q 04bioh Patlcfty North, Jacksonville, Florida 32256i "As?igttee"),
the wed AMU desesribed :ori E*bitA sttacW;.horeto, on ari as=is; where is basis,
without recourse to Assignor.
Dated this 7 h day of July, 2011.
"Assignee"
CiTTeahnology Financing Services, Inc.
Portfolio Services
CIT Technology Financing Services
I I LLC.
It
EXHIBIT A
Purchased Assets
1. CORPORATE DISTRIBUTION LTD. 200280362 (CIT # 910-0059282-000)
EXHIBIT F
{00511655.1}
I Is'
UCC FINANCING 6TATEM11INT
UCC Direct Services
UCC Direct Services
FIO Box 8148
Houston TX 77253
EMail: tmooosemtoro.com, glang.xu*wkglobal.com
t. DEBTOR'S EXACT FULL LEGAL NAME
1t. ORGANIZATION'S NAME
OR CORPORATE DISTRIBUTION LTD
1b. INDMDUAL'S LAST NAME
NAME
File Number: 2006112Ia06is4Z
Defe Filed: 11/2002M 07:00 pM
Pedro A. Corbis
Secrehry of the Commonwealth
Barooda too bW to 111 In this arm
MIDDLE NAME I SUFFIX
to. MAILING ADDRESS CITY STATE POSTAL CODE COUNTRY
8 LONG LN MECHANCSBURG PA 17066 USA
In. TYPE OF ORGANIZATION H JURISDICTION OF ORGANIZATION 1g. ORGANIZATIONAL. ID 0
Corporation PA 2810642 None
1. SECURED PARM NAME
2s. ORGANIZATION'S NAME
., CANON FINANCIAL SERVICES
- 2b. INOMDL)AL-S LAST NAME FIRST NAME MIDDLE NAME SUFFIX
20. MAIUNGADDRESS
158 GAITHER DRIVE, N>R200 CITY
MT LAUREL STATE
NJ POSTAL CODE
06064 COUNTIIY
USA
TM FIINANGIMO STATEMENT OOYara NIb 10100ft OGIMtani:
All equipment now or hereafter based, sold, or financed by Carron Financial Services, Inc. and all general intangibles and accounts
receivable with respect to said equipment, and all replacements of, additions to, substitutions for and proceeds of the foregoing. Lease #
009-0212828-002
&ALTERNATENAME DEWHATN7N ® LESEFAESeOR ? ppN81GNEE00N91(mm SMEEleNLOR SELLERBUYER AS. LIEN
.r??? NON•UCC
_O•? TrU PNANCNS STATENM Is to bO bedW om for rocordod) its IIwREAL ESTATE RE 00ROS.
S.OPTIOWJ. FLOR REIMMICE DATA '*^
PA-0.21588818 PA 12828-0021284 FAYE MICHA 000 SM70 8D6071
9 IIIIIHX21
11 S59115001
aI
i40
ANDREW F. LUCARELLI
WILLIAM C. McCARTY
ALEXANDER HENDERSON, III
ROBERT M. FRANKHOUSER, JR.
THOMAS W. BERGEN
MICHAEL W. RABIC
MARK STANLEY
MARK E. LOVETT
KEVIN M. FRENCH
JOSHUA D. COHEN
KIM R. SMITH
STACEY L. MORGAN
RORY O. CONNAUGHTON
JEFFREY C. GOSS
JOHN A. MATEYAK
THEODORE L. BRUBAKER
ROBERT W. PONTZ
BRETT D. JACKSON
JEFFREY P. OUELLET
WILLIAM J. ZEE, III
DANA C. PANAGOPOULOS
MICHELLE L. GROLEAU
HARTMAN UNDERHILL & BRUBAK.ER LLP
ATTORNEYS AT LAW
221 EAST CHESTNUT STREET
LANCASTER, PENNSYLVANIA 17602-2782
(717) 299-7254
FAX (717) 299-3160
Web Site: www.hublow.com
Direct ,gbR&
CM
November 30, 2010
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
AND FIRST CLASS MAIL
Corporate Distribution Ltd.
8 Long Lane
Mechanicsburg, PA 17050
COUNSEL
CHRISTOPHER S. UNDERHILL
MARK L. JAMES
JOHN I. HARTMAN, JR.
(1919-2000)
THEODORE L. BRUBAKER .
(1911-2002)
GEORGE T..BRUBAKER .
(1942-2006)
HARRY ST. C. GARMAN
(1945-2006)
Re: CIT Technology Financing Services, Inc.
ai ment Lease No. 910-0059282-000 dated November 15, 2006
To whom it may concern:
We represent CIT Technology Financing Services, Inc. ("CIT"), successor-in-
- inter-est to-or-igiaal-4essor-C non Finaneiaf-Services-Inc -under-the-above=referenced--
Lease Agreement ("Lease"). The Lease covers certain commercial copying equipment
including, without limitation, a Cannon Image Runner 110 and related equipment
("Leased Equipment").
You have failed to pay amounts due and owing under the Lease since January
2010. Accordingly, the Lease is in default, and all amounts due thereunder have been and
are hereby accelerated. CIT has referred your account to us for collection. CIT's records
indicate that the total amount due and owing under the Lease, as of the last date of
computation, is $142,231.19: Additional interest, fees and costs for which you are
responsible will continue to accrue pursuant to the Lease until the balance is paid in full.
N
s
Corporate Distribution Ltd.
November 30, 20.10
Page 2
Be advised that unless your account is paid in fiill,. or you make satisfactory
arrangements through this office regarding payment of your account, in either case prior .
to 4,00 p.m. on December 15, 2010, CIT will not hesitate to commence legal action to
regain possession of the Leased Equipment and to collect the above-referenced obligation
without further notice to you. Your immediate response is essential if that step is to be
avoided. You should send payment in full to me at the address indicated on the letterhead
above.
As authorized under your Lease, CIT hereby demands that you immediately
return the Leased Equipment. You should telephone Sharon Onwuka at CIT at
(904) 620-7547 to make arrangements for doing so. If you fail to return the Leased
Equipment voluntarily, CIT will not hesitate to repossess the same, with or without
legal process, as authorized under the terms of your Lease.
THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
Please govern yourselves accordingly.
Very truly yours
Robert W. Pontz
RWP/ald:00602793
cc: Ms. Sharon Onwuka,
Senior Litigation Specialist
? 4#-
• complete Ibsrrts 1, and 3. Also complete
JWn Restricted DeWvery Is desired.
¦ Print your name and address on the reverse
so that we can return the Attach this card to the back of the maiipiece,
or on the front If space permits.
1. Article Addre to:
Corp ate Distribution Ltd.
8 Loa Lane
Mechticsburg, PA 17050
,
Tknahn
13 Agent
(Prhrted Name) , C. Date ofDeliyse?ry
D. Is delivery address different from item 1? ? Yes
If YES, enter delivery address below: ? No
14. . Service Type
Q CertHbd Mall ? Express Mail
? Registered ? Retum Receipt for Merchandise
? Insured Mail ? O.O.D.
Restricted Delivey? (Delia Fee) Yes
Z. Article
&ww mbar 7009 0960 0000 3508 7888
PS rm3 811, February 2004 Domestic Return Recelpt 102695-02-M•1540
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
?gttN?!, ci ?itnt?ierf,rtr
I_l?iJ-it- pw4
G"F PPOI !a i4f? ,a
s Li I i S E P Z l AM '
Richard W Stewart
Solicitor
!'LlMBERLANO C0iJ `. e.
PENNSYLVAI IJ
CIT Technology Financing Services, Inc. Case Number
vs.
Corporate Distribution Ltd. 2011-6908
SHERIFF'S RETURN OF SERVICE
09/08/2011 09:40 AM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on
September 8, 2011 at 0940 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Corporate Distribution, Ltd. a/k/a Corporate Distribution Limited, Inc., by
making known unto Kathleen O'Donnell, Part Business Owner of Corporate Distribution Ltd. at 8 Long
Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $38.44
September 09, 2011
RYAN BURGETT, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
j
Keith O. Brenneman, Esquire
Snelbaker & Brenneman, P.C.
44 West Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Corporate Distribution, LTD
CIT TECHNOLOGY FINANCING
SERVICES, INC.
Plaintiff
V.
CORPORATE DISTRIBUTION, LTD,
a/k/a Corporate Distribution Limited, Inc.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2011-6908
CIVIL ACTION - LAW
NOTICE TO PLEAD
TO: CIT Technology Financing Services, Inc., Plaintiff
and
Robert W. Pontz, Esquire
221 East Chestnut Street
Lancaster, PA 17602
You are hereby notified that you have twenty (20) days in which to plead to the enclosed
New Matter or a Default Judgment may be entered against you.
SNELBAKER & BRENNEMAN, P. C.
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
By: I?
Date: October 26, 2011
Keith O. Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Defendant
Corporate Distribution LTD
Keith O. Brenneman, Esquire
Snelbaker & Brenneman, P.C.
44 West Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Corporate Distribution, LTD
CIT TECHNOLOGY FINANCING
SERVICES, INC.
Plaintiff
V.
CORPORATE DISTRIBUTION, LTD,
a/k/a Corporate Distribution Limited, Inc.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2011-6908
CIVIL ACTION - LAW
ANSWER WITH NEW MATTER
Defendant Corporate Distribution LTD., by its attorneys, Snelbaker & Brenneman,
P. C., submits this Answer with New Matter in response to Plaintiffs Complaint as follows:
A ATIQ X11P ?
1. Admitted.
2. Admitted with the qualification that although the name Corporate Distribution
Limited, Inc. appears on the lease agreement attached to Plaintiffs Complaint as Exhibit A,
Corporate Distribution LTD does not hold itself out or do business as Corporate Distribution
Limited, Inc.
3. Admitted, with the qualification that the Lease Agreement (the "Equipment Lease")
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
being in writing speaks for itself.
4. Admitted.
5. Admitted.
6. Denied. Paragraph 6 of Plaintiffs Complaint contains a series of unwarranted
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied pursuant to Pa.R.C.P. 1029(d). By way of further response, the document
attached to Plaintiffs Complaint as Exhibit C which is entitled a "CERITICATION [sic] OF
ASSIGNMENT" purports to be evidence of an alleged assignment and does not constitute an
instrument providing for the assignment of the Equipment Lease. On the contrary, Exhibit C
claims to certify that "Leases" were sold and assigned during 2006 in accordance with the terms
of a July 15, 2004 Agreement which was not attached to the Complaint contrary to the
requirements of Pa.R.C.P. 1019(i). Furthermore, although the Lease Agreement is made
reference to in Exhibit C as the "Lease", Exhibit C alleges Canon certified it sold and assigned
"the Leases". For these reasons, to the extent Plaintiff claims there was either an assignment or
valid assignment of the Equipment Lease, same is specifically denied.
7. Denied. Paragraph 7 of Plaintiffs Complaint contains a series of unwarranted
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, the document attached as Exhibit D to the
Complaint is a "Notice" of a purported assignment, not proof or evidence of any assignment.
In addition, Schedule A of Exhibit D identifies no contract or any asset or assets which were
purportedly sold or assigned. For these reasons, to the extent Plaintiff claims that there was
either an assignment or a valid assignment of the Equipment Lease, same is specifically denied.
8. Denied. Paragraph 8 of Plaintiffs Complaint contains a series of unwarranted
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, the document attached as Exhibit E to the
Complaint fails in any way to describe the "Purchased Assets" in Exhibit A thereto or
2
otherwise. Further, the Assignor is identified on Exhibit E as CIT Techology Financing
Services, II, LLC and also as CIT Technology Financing Services I LLC. For these reasons, to
the extent that Plaintiff claims that there was either an assignment or a valid assignment of the
Equipment Lease, same is specifically denied.
9. Admitted with the qualification that the Equipment Lease, being in writing, speaks
for itself.
10. Admitted with the qualification that the Equipment Lease, being in writing, speaks
for itself.
11. Admitted in part; denied in part. It is admitted only that an organization by the
name of Canon Financial Services (not Canon Financial Services, Inc.) filed a UCC-1 financing
statement as alleged noting a security interest in the collateral specified.
12. Admitted, with the qualification that the Equipment Lease, being in writing, speaks
for itself.
13. Denied. Paragraph 13 of Plaintiffs Complaint contains a series of unwarranted
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, although it is admitted that Defendant did not
make the January 1, 2010 payment on January 1, 2010, it did make a payment or payments
after January 1, 2010.
14. Admitted, with the qualification that the Equipment Lease, being in writing, speaks
for itself.
15. Denied. Paragraph 15 of Plaintiffs Complaint contains a series of unwarranted
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, the Equipment Lease, being in writing speaks for
itself.
3
16. Denied. Paragraph 16 of Plaintiffs Complaint contains a series of unwarranted
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, the Equipment Lease, being in writing speaks for
itself. It is also denied that Defendant owes Plaintiff the sums noted for the reasons set forth in
New Matter, the averments of which are incorporated by reference herein.
17. Admitted.
18. Denied. It is denied that Defendant has failed to comply with Plaintiffs demands.
On the contrary, Defendant has on one or more occasions advised Plaintiff that the equipment
can be removed by Plaintiff.
19. Denied. Paragraph 19 of Plaintiffs Complaint contains a series of unwarranted
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, the Equipment Lease, being in writing speaks for
itself
20. Denied. Paragraph 20 of Plaintiffs Complaint contains a series of unwarranted
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, the averments of Defendant's New Matter are
incorporated by reference herein.
21. Denied. Paragraph 21 of Plaintiffs Complaint contains a series of unwarranted
conclusions of law to which no response is required by the Defendant; therefore same is
deemed denied. By way of further response, the averments of Defendant's New Matter are
incorporated by reference herein.
WHEREFORE, Defendant requests that Plaintiffs Complaint be dismissed and
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
judgment be entered in favor of Defendant.
4
NEW MATTER
22. Plaintiffs Complaint fails to set forth any claim or cause of action against the
Defendant upon which relief may be granted.
23. The Plaintiff attached as Exhibit C to the Complaint a document entitled
"CERITICATION OF ASSIGNMENT".
24. Exhibit C attaches a copy of the Lease Agreement as Exhibit A and refers to the
Lease Agreement as the "Lease".
25. Exhibit C purports to certify that Canon sold and assigned "the Leases and the
equipment covered thereby".
26. There is no reference or description of what the "Leases" are in Exhibit C.
27. Exhibit D to Plaintiffs Complaint purports to be a notice of the assignment of the
"contracts listed on Schedule A", which Schedule A is attached to Exhibit D.
28. Schedule A to Exhibit D purports to identify a "Purchased Asset".
29. There is no asset described or identified on Schedule A.
30. Exhibit E to Plaintiffs Complaint purports to be an assignment of purchased assets.
31. Exhibit E makes reference to "the Purchased Assets described on Exhibit A
attached."
32. Neither Exhibit A to Exhibit E nor Exhibit E describes any assets being assigned or
purchased.
33. Exhibit E purports to identify the "Assignor" as CIT Technology Financing
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
Services I LLC
34. Exhibit E also identifies the Assignor as CIT Technology Financing Services II
LLC.
5
35. For the reasons set forth above, Plaintiff has failed to plead an assignment or valid
assignment of the Equipment Lease.
36. Plaintiff has failed to attach the assignment agreements or instruments with respect
to the notices of assignment attached through Exhibit C and D.
37. For the reasons noted above, Plaintiff has no standing to bring this action.
38. For the reasons set forth above, Plaintiff is not a proper party in interest and cannot
assert a claim for any rents purportedly due under the Equipment Lease.
39. Plaintiff estimates the value of the equipment leased to be $12,500.00.
40. Plaintiff claims a rent balance due $129,193.64.
41. Plaintiff s actions in claiming rent together with late charges and other amounts
grossly in excess of the value of the equipment it leases is commercially unreasonable and
unconscionable.
42. Defendant has on one or more occasions prior to the initiation of this action given
Plaintiff the opportunity to take back all of the leased equipment.
43. The interest rate charged under the Equipment Lease may be usurious.
WHEREFORE, Defendant requests that Plaintiffs Complaint be dismissed and
judgment be entered in favor of Defendant.
SNELBAKER & BRENNEMAN, P. C.
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
By: I
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Defendant Corporate
Distribution LTD
Date: October 26, 2011
6
VERIFICATION
I verify that the statements made in the foregoing Answer with New Matter are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
Corporate Distribution LTD
By; ,? Z CL9-?
Kathie O'Donnell, Vice President
Date: October 26, 2011
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date,
icaused a true and correct copy of the foregoing Answer with New Matter to be served upon the
person and in the manner indicated below:
FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS:
Robert W. Pontz, Esquire
221 East Chestnut Street
Lancaster, PA 17602
By:
Date: October 26, 2011
SNELBAKER & BRENNEMAN, P.C.
jkl"
Keith O. Brenneman, Esquire
44 W. Main Street
P. O. Box 318
Mechanicsburg, PA 17055
(717)697-8528
Attorneys for Defendant Corporate Distribution LTD
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
SALDUTTI, LLC '� , ( , ,]'- r
! � rltlJ�l+ll 1!`141 1
BY: Robert L. Saldutti, Esquire r
Identification No. PA-63867 ' ` ' FEB � J �; G
461 N. 3rd Street, Suite 2B w ��lF, fti! 1 800 N. Kings Highway, Suite 300
Philadelphia, PA 19123 PEN / CUUr T;Cherry Hill,NJ 08034
�',�lS YC.yA��lA
(877) 809-4345
Attorney for Plaintiff
CIT TECHNOLOGY CUMBERLAND COUNTY
FINANCING SERVICES, INC. COURT OF COMMON PLEAS
Plaintiff, Case No. 11-6908
v.
CORPORATE DISTRIBUTION LTD CIVIL ACTION-LAW
a/k/a Corporate Distribution Limited, Inc.
Defendant(s).
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of Robert L. Saldutti, Esquire qn behalf of Plaintiff,
CIT Technology Financing Services, Inc. in the above-caption matter.
Li,
SALDUTT, LL
/
ROBERT L SAL K I TTI, ESQUIRE
Dated: February 20, 2014
SALDUTTI, LLC
BY: Robert L. Saldutti, Esquire
Identification No. PA-63 867
461 N. 3rd Street, Suite 2B 800 N. Kings Highway, Suite 300
Philadelphia, PA 19123 Cherry Hill,NJ 08034
(877) 809-4345
Attorney for Plaintiff
CIT TECHNOLOGY CUMBERLAND COUNTY
FINANCING SERVICES, INC. COURT OF COMMON PLEAS
Plaintiff, Case No. 11-6908
v.
CORPORATE DISTRIBUTION LTD CIVIL ACTION-LAW
a/k/a Corporate Distribution Limited, Inc. s y
•
Defendant(s).
mow Pi 111 `,;
-+ -
-mac'
PRAECIPE TO SETTLE,DISCONTINUE,AND END
TO THE PROTHONOTARY:
Kindly mark matter Settled, Discontinued and Ended. /
SALDUTT, L
ROBERT SALD TI, ESQUIRE
Dated: February 20, 2014