HomeMy WebLinkAbout11-7451
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LAM? LC
ROBERT D. KODAK, ESQUIRE
KODAK LAW OFFICES, P.C.
407 N FRONT STREET, PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-7159 Attorney for Plaintiff
STATE AUTO INSURANCE IN THE COURT OF COMMON PLEAS
COMPANIES Cumberland COUNTY, PENNSYLVANIA
Plaintiff 1'?9
v
KIMBOB, INC. doing business as CIVIL ACTION - LAW
Gemini Equipment Business Trust
Defendant(s)
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 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, 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.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
G
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i
??6 5P2 'S'e
9 .
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion
dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y
Aviso radicando personalmente o por medio de un abogado una comparencencia escrita
y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion
como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier
suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio
solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso
adicional. Usted puede perder dinero o propiedad u otros derechos importantes para
usted.
USTED DEBE LLEVAR TSENE UN ABOGADO, LLAME O VA AGA DLA
INMEDIATAMENTE. SI USTED NO
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
SOBRE
POSIBLE QUE ESTA OFICINA LE LDEGALEOS SIN CARGO INFORMACION
A
AGENCIAS QUE OFREZCAN S
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
STATE AUTO INSURANCE IN THE COURT OF COMMON PLEAS
COMPANIES Cumberland COUNTY, PENNSYLVANIA
Plaintiff
NO.
v
KIMBOB, INC. doing business as CIVIL ACTION - LAW
Gemini Equipment Business Trust
Defendant(s)
COMPLAINT
The Plaintiff, STATE AUTO INSURANCE COMPANIES, by its attorneys, KODAK
& IMBLUM, P.C., brings this action of Assumpsit against the Defendant(s) to recover the
sum of NINETEEN THOUSAND SIX HUNDRED SIXTEEN DOLLARS AND SEVENTY-
ONE CENTS ($19,616.71), along with interest as set forth herein, upon a cause of action
of which the following is a statement:
1. The Plaintiff, STATE AUTO INSURANCE COMPANIES, is a corporation organized
and existing under the laws of the State of Ohio, having its principal office and place
of business at 518 East Broad Street, Columbus, OH 43215.
2. The Defendant, KIMBOB, INC. doing business as Gemini Equipment Business
Trust, is a corporation having its principal office and place of business at 840
Market Street, Suite 33333, Lemoyne, Cumberland County, PA 17043.
3. Defendant, KIMBOB, INC. doing business as Gemini Equipment Business Trust, is
a corporation organized and existing under the laws of the Commonwealth of
Pennsylvania, as more fully set forth on the Pennsylvania Department of State
Corporation Bureau print out attached hereto, marked Exhibit "A" and made a part
hereof.
COUNT I
Period 311110 through 311/11
4. The averments of paragraphs 1 through 3 above are incorporated the same as if
fully set forth at length herein.
5. Defendant contracted with Plaintiff for the purpose of Plaintiff providing various
insurance policies and insurance coverages to and on behalf of Defendant, at
Defendant's request. Specifically, a business automobile policy (BAP2288199 for
the period 3/1/10 through 3/1/11), a commercial general liability policy
(PBP2557790 for the period 3/1 /10 through 3/1 /11) and a workers compensation
policy (WCP2161565 for the period 3/1 /10 through 3/1 /11).
6. The prices charged for said insurance policies were just and reasonable, were the
legal and market prices therefor and were the prices which the Defendant(s)
promised and agreed to pay to Plaintiff.
3
r.\ T icFR\ RnRTN\ COMM PLEAS CMP & FORMS\CCP COMPLAINTS\1 N to Z\STATE AUTO 38214.wpd
7. After calculating all premiums, payments, credits, and audits, the balance due and
owing by Defendant to Plaintiff for the aforesaid policies for the period March 1,
2010 through March 1, 2011 is Sixteen Thousand One Hundred Thirteen Dollars
and Fifty Cents ($16,113.50) as set forth on Plaintiff's statement of account
attached hereto, marked Exhibit "B" and made a part hereof.
8. The balance due and owing by Defendant(s) to Plaintiff is the sum of Sixteen
Thousand One Hundred Thirteen Dollars and Fifty Cents ($16,113.50), as appears
by Exhibit "B" hereto.
9. Plaintiffs Invoices, policies and applications are not attached to this pleading due
to the voluminous nature of same and have previously been provided to
Defendant(s).
10. Plaintiff frequently demanded payment from Defendant(s) of said amount due and
owing as aforesaid, but Defendant(s) refused and neglected and still refuse and
neglect to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant (s) the sum of
Sixteen Thousand One Hundred Thirteen Dollars and Fifty Cents ($16,113.50), together
with interest as set forth herein.
F:\USER\ROBIN\COMM PLEAS CMP & FORMS\CCP COMPLAINTS\1 N to Z\STATE AUTO 38214.wpd 4
COUNT II
Period 6/11/09 - 6/11/10
11. Plaintiff incorporates by reference the averments set forth in Paragraphs 1 through
10 herein, the same as if fully set forth at length herein.
12. Defendant contracted with Plaintiff for the purpose of Plaintiff providing various
insurance policies and insurance coverages to and on behalf of Defendant, at
Defendant's request. Specifically, a business automobile policy (BAP22224879 for
the period 6/11/09 through 6/11/10), a commercial general liability policy
(PBP2493167 for the period 6/11/09 through 6/11/10) and a workers compensation
policy (WCP2133634 for the period 6/11/09 through 6/11/10).
13. The prices charged for said insurance policies were just and reasonable, were the
legal and market prices therefor and were the prices which the Defendant(s)
promised and agreed to pay to Plaintiff.
14. After calculating all premiums, payments, credits, and audits, the balance due and
owing by Defendant to Plaintiff for the aforesaid policies for the period June 11,
2009 through June 11, 2010 is Three Thousand Five Hundred Three Dollars and
Twenty One Cents ($3,503.21) as set forth on Plaintiff's statement of account
attached hereto, marked Exhibit "C" and made a part hereof.
F:\ USER\ ROBIN\COMM PLEAS CMP & FORMS\CCP COMPLAINTS\1 N to Z\STATE AUTO 38214.wpd 5
15. The balance due and owing by Defendant(s) to Plaintiff is the sum of Three
Thousand Five Hundred Three Dollars and Twenty One Cents ($3,503.21), as
appears by Exhibit "C" hereto.
16. Plaintiffs Invoices, policies and applications are not attached to this pleading due
to the voluminous nature of same and have previously been provided to
Defendant(s).
17. Plaintiff frequently demanded payment from Defendant(s) of said amount due and
owing as aforesaid, but Defendant(s) refused and neglected and still refuse and
neglect to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant the following
sums:
Count I: the sum of Sixteen Thousand One Hundred Thirteen Dollars and Fifty
Cents ($16,113.50), plus interest at the statutory rate from April 1,
2011; and
Count II: the sum of Three Thousand Five Hundred Three Dollars and Twenty
One Cents ($3,503.21), plus interest at the statutory rate from July 11,
2010;
F:\USER\ROBIN\COMM PLEAS CMP & FORMS\CCP COMPLAINTS\1 N to Z\STATE AUTO 38214.wpd 6
For a total balance due and owing of NINETEEN THOUSAND SIX HUNDRED
SIXTEEN DOLLARS AND SEVENTY-ONE CENTS ($19,616.71) plus interest and court
costs.
Respectfully submitted,
KODAK LAW OFFICES, P.C.
7
Jdffty I . Troutman, Esquire ID#53984
Robert D. Kodak, Esquire ID# 18041
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7159
Attorney for Plaintiff
F:\USER\ROBIN\COMM PLEAS CMP & FORMS\CCP COMPLAINTS\1 N to Z\STATE AUTO 38214.wpd
? r. r 7!
, ION
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Business Entity Filing
History
Date: 9/13/2011 (Select the link above to view
the Business Entity's Filing
History)
Business Name History
Name
KIMBOB, INC.
Name Type
Current Name
Business Corporation - Domestic - Information
Entity Number: 189355
Status: Active
Entity Creation Date:
State of Business.:
Registered Office Address:
Mailing Address:
Officers
10/18/1972
PA
MCCORMICK RD
PO BOX 58
BOWMANSDALE PA 17008-0
Cumberland
No Address
Name: ROBERT M MUMMA II
Title: President
Address: P 0 BOX 5
CAMP HILL PA 17001-21
Name: WILLIAM D BOSWELL
Title: Secretary
Address: P 0 BOX 5
CAMP HILL PA 17001-21
Name: ROBERT M MUMMA 11
Title: Treasurer
Address: P 0 BOX 5
CAMP HILL PA 17001-21
Name: FRANKLIN RUSHONG JR
Title: Vice President
Address: P 0 BOX 5
CAMP HILL PA 17001-21
https://www.Corporations.state.t)a.u-,/corn/soc Wit.
?rN'ti'1 _
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Copyright ® 2002 Pennsylvania Department of State. All Rights Reserved.
commonwealth of PA Privacy Statement
Business Entity Filing
History
Date: 9/13/2011 (Select the link above to view
the Business Entity's Filing
History)
Business Name History
Name Name Type
GEMINI EQUIPMENT BUSINESS
TRUST Current Name
Business Trust - Domestic - Information
Entity Number: 2577346
Status: Active
Entity Creation Date:
State of Business.:
Registered Office Address:
Mailing Address:
4/22/1994 11:21:12 AM
PA
614 N FRONT ST
STE A
HARRISBURG PA 17101-0
Dauphin
No Address
Officers
Name: ROBERT M MUMMA 11
Title: President
Address: BOX E
BOWMANSDALE PA 17008-21
Name: ROBERT M MUMMA II
Title: Treasurer
Address: BOX E
BOWMANSDALE PA 17008-21
https://www.corporations.state
pe ??/??'' 7:.-2 ^94.5 1e,,71
PAGE ?•/^=
INSURED;
POLICY:
ACCOUNT NO:
EFFECTIVE DATE:
EXPIRATION DATE:
BILL ACCOUNT SUMMARY
Kimbob Inc
SAP2288199, PBP2557790, WOP2161565
CL00033333
03/01/10
06123/10
PROCESS
DATE DE qR PTiON
03/13110 BAP New Business
03/13/10 PBP New Business
03/13/10 WCP New Business
03/13110 Invoice due 4/3110
04/17110 BAP Chng eff 4/14110
04121/10 PBP Chng eff 4/16/10
04/21/10 PBP Chng eff 4/16/10
04/21110 WCP Chng eff 4116/10
04122/10 BAP Chng eff 4/13/10
04/26/10 Payment
05/05/10 BAP Chng eff 4/30/10
05111/10 Invoice due 611/10
06/02/10 BAP Chng elf 5126/10
06/05/10 Request Nonpay Cancel-all pies
06/19110 PBP Chng eff 4116110
06/24/10 BAP Cancellation eff 6123/10
06/24/10 PBP Cancellation eff 6123/10
06/24/10 WCP Cancellation eff 6/23/10-Subject to Audit
07/12/10 Invoice due 8/2/10
08/11/10 Invoice due 8/2/10
09110/10 Invoice due 812/10
10/11/10 Invoice due 8/2110
11/10110 Invoice ,1P 8//1jj0 _.
12/10/10 WCP Audit Processed 311110 to 6123110 -
12/10110 Invoice due 8/2/10
01/11/11 Invoice due 8/2/10
INVOICE
AMOUNT AMO N
$ 42,694.00
$ 50,280.00
$ 27,741.00
$ 12,074.50 $ 3.00
$ 1,087.00
$ (5,304.00)
$ (922.00)
$ (3,578.00)
$ (27,051.00)
$ (12,074,50)
$ (1,557.00)
$ 15,851.52 $ 3.00
$ 34.00
$ 15,848.52 $ -
$ 406.00
$ (7,885.00)
$ (30,012.00)
$ 12,478.60 $ 3.00
$ 12,478.60 $ -
$ 12,478.60 $ -
$ 12,478.60 $ -
$ 12,478.60 $ -
$ (17,754.00)
$ 16,113.50 $ -
16,113.50 $
$ 16,113.50
Total Rolicy Premium BAP
Total Pplicy Premium PBP
Total Pplicy Premium WCP
Invoice chgs
Total Paid
4 -?
$ 7,322.00
S 14,448.00
$ 6,409.00
$ 9.00
$ (12,074.50)
S 16,113.50
0-6/A?/2p'.?. '.?:.'.2 490-4551471 rA?,P?,__, T,_T?,A.?=A^S ^AGr 26/2=
INSURED:
POLICY:
ACCOUNT NO:
EFFECTIVE DATE:
EXPIRATION DATE:
BILL ACCOUNT SUMMARY
Kimbob Inc
SAP2224879, PBP2493167, WCP2133634
CL00020848
06/11/09
01/23/10
PROCESS INVOICE
DATE- DESCRIPTION AMOUNT AMOUNT
05/12109 WCP Renewal $ 20,855.00
05/21109 BAP Renewal $ 11,046.00
05/21/09 invoice due 6/11109 $ 2,903.10 $ 3.00
05/30/09 WCP Chng eff 6111/09 $ 30.00
06110/09 BAP Chng eff 8/27108-prior term-deleted 2002 Ford PU $ (573.00)
06/10/09 BAP Chng eff 6/11/09-deleted 2002 Ford PU $ (716.00)
06/14/09 Payment $ (2,903.10)
06/16109 BAP Chng eff 6/11/09-deleted various vehicles $ (1,978.00)
06/19/09 Invoice due 7/11/09 S 2,063,70 $ 3.00
06123/09 PBP Renewal S 35,815.00
07/07109 PBP Chng eff6/11/09-amended schedule $ 9,025.00
07/21/09 Invoice due 8111/09 $ 4,988.23 $ 3.00
07127109 Payment $ (2,063.70)
08/21/09 Invoice due 9/11109 S 5,273.40 $ 3.00
08/26109 Payment $ (4,988.23)
09/13/09 Payment $ (5,273.40)
09/18/09 PBP Chng eff 8127/09-deleted various items $ (1,810.00)
09/21/09 Invoice due 10112/09 $ 12,142.66 $ 3.00
09/29109 - d d 601 $ 3,706.00
10/23/09 PBP Audit PreceSc_d fill 116&611 I log $ 2,021 00
0/23/09 WCP Audit Processed 6/11/08 to 6111/09 Sw 13.568.00
11/04/09 Payment $ 12,142.66)
11/20109 Invoice due 12/11/09 $ 31,606.70 $ 3.00
12121/09 Invoice due 12111/09 $ 15,592.00 $ 3.00
12/31/09 Payment $ (18,038.70)
01/21/10 Invoice due 2/11/10 $ 10,608,39 $ 3.00
02/04/10 Payment $ (6,784.00)
02/18/10 Invoice due 3111 /10 $ 7,052.85 $ 3.00
02118/10 Payment $ (6,784.00)
02/26110 WCP Cancel eff 1/23/10-Subject to Audit $ -
03112110 BAP Cancel eff 1123/10 $ (3,173.00)
03/121,JQ ??AE Cancel eff 1/23/10 $ (16,210 M
04/091`10 WCP Cancellation Audit 6/11109 to 1/23110 $ (9,155.00)
04/20/10 Invoice due 5111110 $ 3,503.21 $ 3.00
05/21/10 Invoice due 5/11/10 $ 3,503.21 $ -
06/21/10 Invoice due 5111/10 AgpMoomp $ 3,503.21 $ -
a
A5!O?/2A'.'. 7: PAGE 67/25
_.
07/21 /10
08105/10
I rnvoice due: 5/11 /10
Final Notice Sent
$ ;1,503.21 $
1_ 3,503.21 $ 3,503.21
Total Policy Premium SAP
Total Policy Premium PBP
Total Policy Premium WCP
PaP Audit 08/09
WCP Audit 08109
BAP Chng eff 8127/08
Invoice chgs
Total Paid
$ 5,179.00
$ 26,820.00
$ 15,436.00
$ 2,021.00
$ 13, 568.00
$ (573.00)
$ 30.00
(58,977.79)
$ 3,503.21 411111jMMMMMMM?
VERIFICATION
I, V /ck-?C C- t} C'Clle L11 Dr -SpPC1r,'t_
(name) (title)
of STATE AUTO INSURANCE COMPANIES, verify that the statements made in the
aforegoing document are true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to
authorities.
STATE AUTO INSURANCE COMPANIES
By:
Title:
Dated:
KI#38214 / CLT#111609
KIMBOB
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
L 4' 11
7 , 1;
Ronny R Anderson
'i
Sheriff 4??tit3, kt ?R?+nbrr???t
Jody S Smith = ° ? ] 1 I OCT -7 PM ? I ^y
Chief Deputy
CUMBEF%'LAjri0 C I,'i
Richard W Stewart PEM4SY° ? A' 1I?
Solicitor
State Auto Insurance Companies Case Number
vs. 2011-7451
Kimbob, Inc.
SHERIFF'S RETURN OF SERVICE
09/30/2011 01:23 PM - William Cline, Corporal, who being duly sworn according to law, states that on September 30,
2011 at 1323 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kimbob, Inc. d/b/a Gemini Equipment Business Trust, by making known unto Lori Perry,
Office Manager for Kimbob, Inc. at 840 Market Street, Suite 158, Lemoyne, Cumberland County,
Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct
copy of the same.
ILLIAM CLINE, DEPUTY
SHERIFF COST: $44.44
October 05, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
; C'. CouMYSIAe'rEi!'!?r. le i CS,^.'t. Inc
l I
2Q 2 JUL 11 P? t : 20
STATE AUTO INSURAN 1 A IN THE COURT OF COMMON PLEAS
laintiff CUMBERLAND COUNTY, PENNSYLV
v
NO. 2011-7451
KIMBOB, INC. doing business as Gemini
Equipment Business Trust
Defendant(s) CIVIL ACTION - LAW
PRAECIPE FOR DEFAULT JUDGMENT
Enter judgment in favor of Plaintiff and against Defendant(s), KIMBOB, INC. doing bu mess as
Gemini Equipment Business Trust, named for failure to file within the required time an Answer to the
Complaint in the above-captioned case and assess the Plaintiff's damages as follow.
Amount claimed in Plaintiff's Complaint (Count I) ........................ $ 16,11 .50
Amount claimed in Plaintiff's Complaint (Count II) ....................... $ 3,50 .21
Less payments, if any ................................................. $ .00
Interest at the rate of 6% per annum from 4/1/11-7/12/12 (2.65 per diem) (Count I) $ 1,24C.20
Interest at the rate of 6% per annum from 7/11/10-7/12/12 (0.58per diem) (Count II) $ 424.56
Total ............................................................... $ 21,28 .47
I hereby certify that a written Important Notice of the intent to file this Praecipe was railed or
delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after the default occurred and
at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice() is/are
attached. ar"A s (S, Sopd aN
C-O D?4
KODAK LAW OFFICES, P.C. ¢ o{?'Ge &1CNUA
By 98y
r Ro odak, Attorney for Plaintiff
DATED: 1 I ?? l? a Judgment entere d 47- -ago essed as ve
KODAK LAW OFFICES, P.C.
CAMERON MANSION 1 elel
Robert D. Kodak 407 NORTH FRONT STREET 717.238•
Jeffrey L. Troutman POST OFFICE BOX 11848 Facs
HARRISBURG, PA 17108-1848 717.23
June 21, 2012 1 L E, Ell C) 11 "
KIMBOB INC DBA
GEMINI EQUIPMENT BUSINESS TRUST
C/O ROBERT E CHERNICOFF ESQ
CUNNINGHAM & CHERNICOFF PC
2320 N 2"D STREET
HARRISBURG PA 17110
RE: State Auto Insurance Companies
VS: Kimbob, Inc. doing business as Gemini Equipment Business Trust
No. 2011-7451, Court of Common Pleas, Cumberland County, PA
Our File No. 38214
Greetings:
In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing
a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are foL
Office of the Prothonotary of Cumberland County, you have not filed responsive pleadin
Complaint filed against you to the above term and number, nor has any attorney entered an ap
on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you (
action as set forth in this Notice, we, at the expiration of time indicated therein, will request
of the Prothonotary of Cumberland County to enter judgment against you in the amount as
said Complaint.
Very truly yours,
KODAK LAW OFFICES, P.C.
Raderr 2), ?o&W
ROBERT D. KODAK, ESQUIRE
rkodak@kodaklaw.com
RDK/ akr
Enclosures
c AIDA HUST
CAMPBELL HIGHTOWER & ADAMS
4645 S LAKESHORE DRIVE STE 11
TEMPE AZ 85282-7127
X101
in the
to the
not take
Le Office
forth in
111609
STATE AUTO INSURANCE COMPANIES,
Plaintiff
v
KIMBOB, INC. doing business as Gemini
Equipment Business Trust
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2011-7451
CIVIL ACTION - LAW
IMPORTANT NOTICE / AVISO IMPORTANTE
TO/ A: KIMBOB, INC. doing business as Defendant(s) / Defendido(s)
Gemini Equipment Business Trust
DATE OF NOTICE / FECHA DEL AVISO: Tune 21, 2012
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE 0:)U]
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPE T)
OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO OT
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 I
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER' LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
.......................................................................................................................................................................................................................................
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SO ER
CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN
PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE' DIEZ DI DE
HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CON
SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U
OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTA DOCUMENTO A SU ABOGADO INMEDIATEME TE.
SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. E TA
OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONStGUIR
ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES PO
QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE
OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE
CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
STATE AUTO INSURANCE COMPANIES,
Plaintiff
v
KIMBOB, INC. doing business as Gemini
Equipment Business Trust
Defendant(s)
TO/ A: KIMBOB, INC. doing business as
Gemini Equipment Business Trust
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV
NO. 2011-7451
CIVIL ACTION - LAW
Defendant(s) / Defendido/a,
You are hereby notified that on 2012 the following
Judgment has been entered against you in the above-captioned case.
Por este medio se le esta notificando que el de del 2012
siguiente(Fallo) ha sido anotado en contra suya en el caso enci do a el epigrafe.
Date: Fecha :
on*Mf tonotario
judgment entered in the amount of $ 2128147
I hereby certify that the name and address of the proper person(s) to receive this notice
KIMBOB INC
DBA GEMINI EQUIPMENT BUSINESS TRUST
C/O ROBERT CHERNICOFF ESQUIRE
2320 N 2ND STREET
HARRISBURG PA 17110
;/as
/la
Attorney for Plaintiff
Abogado del Demandante
x.712 AUK '2 PM ?: 2K
STATE AUTO INSURANCE APGI3 1 si '
AIN THE COURT OF COMMON PLEA
CUMBERLAND COUNTY, PENNSYL ANIA
Plaintiff,
v. No. 2011-7451 Civil Term
KIMBOB, INC., doing business as :
Gemini Equipment Business Trust CIVIL ACTION - LAW
Defendant(s)
ANSWER TO COMPLAINT WITH NEW MATTER
TO: Jeffrey L. Troutman, Esquire
Robert D Kodak, Esquire
Kodak Law Offices, P.C.
407 N Front Street, P.O. Box 11848
Harrisburg, PA 17108-1848
NOW COMES, Robert M. Mumma, II and responds to the Complaint in this
matter, filed by State Auto Insurance Companies through its attorneys, including New
Matter as follows:
1. Admitted.
2. Denied. Entity filings for Kimbob and Gemini are shown at Exhibits A to the
Complaint.
3. Denied. See Answer No. 2.
COUNTI
4. No response.
5. Admitted that State Auto provided insurance in a joint policy to Kimbob and
Gemini.
6. Denied. The prices charged in this Complaint are not the prices agreed upon or
for the items insured under the policy. These reputed additional charges are
disputed and inappropriate. The Defendants have never agreed to pay the
audited premiums.
7. Denied. The balance is not due and owing.
8. Denied. Plaintiff has charged inappropriate rates and for items that should not
have been included.
9. Admitted that the documentation is not attached. Defendants demand to be
provided with specific documentation to answer this allegation.
10. Defendants have repeatedly refused to pay because they were over billed and
payments previously made were misapplied by Plaintiff to Defendant's account.
COUNT II
11. No response.
12. See Answer No. 5.
13. See Answer No. 6.
14. See Answer No. 7.
15. See Answer No. 7.
16. See Answer No. 9.
17. See Answer No. 10.
2
NEW MATTER
Defendant, Gemini Equipment Business Trust, a party to this joint policy is
presently in Bankruptcy in the Middle District of Pennsylvania (Case No. 05-03489) ar
Plaintiffs are aware of the Bankruptcy proceedings. Plaintiffs should be precluded fro
proceeding due to the automatic stay.
Dated: August 2, 2012 Zspectfully Submitted,
cz-t
Robert M. Mumma, II
Box F
Grantham, PA 17027
(717) 448-1127
PRO SE EE'S l DST fj
- cc- e!?- ell /tit t ?u iu/
VERIFICATION
I, Robert Mumma, II, hereby verify that the statements of fact contained in tlhe
attached document are true and correct to the best of my knowledge, information a
belief. I understand that this Verification is made pursuant to the penalties of
18 Pa. C. S. §4904 relating to unsworn falsification to authorities.
Robert M. Mumma, 11
CERTIFICATE OF SERVICE
I hereby certify that on this 2nd day of August, 2012, a copy of the foregoing
Answers to Complaint and New Matter was served upon the person(s), at the address
and in the manner indicated below:
SERVICE VIA UNITED STATES MAIL
FIRST CLASS POSTAGE PREPAID TO:
Jeffrey L. Troutman, Esquire
Robert D Kodak, Esquire
Kodak Law Offices, P.C.
407 N Front Street, P.O. Box 11848
Harrisburg, Pa 17108-1848
iab- X4 -, j
l1
Robert M. Mumma, 11
0TH01-NOTAi 'f
2312 AUG -9 AM 11: 41
CUMBERLAND COUNTY
PENNSYLVANIA
KODAK LAW OFFICES, P.C.
407 N FRONT STREET, PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-7159 Attorney for Plaintiff
STATE AUTO INSURANCE
COMPANIES
Plaintiff
v
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY,
PENNSYLVANIA
NO. 2011-7451
KIMBOB, INC. dba Gemini Equipment
Business Trust ' CIVIL ACTION - LAW
Defendant(s)
Plaintiff's Reply to Defendant's New Matter
The Plaintiff, STATE AUTO INSURANCE COMPANIES, by its attorneys, KODAK
LAW OFFICES, P.C., files its Reply to Defendant's New Matter and in support thereof
states as follows:
Plaintiff incorporates by reference the averments contained in Paragraphs 1 through
17 of Plaintiff's Complaint, the same as if fully set forth at length herein.
Admitted in part and denied in part. It is admitted that Gemini Equipment Business
Trust is currently the debtor in the Middle District of Pennsylvania bankruptcy case No.
05-03489. Any implication that Kimbob, Inc. is in bankruptcy is denied in that Kimbob, Inc.
F:\USER\ROBIN\MISC\REPLY TO NM CC etc\38214 reply to rim.wpd
has not filed bankruptcy. The averment that Plaintiff should be precluded from proceeding
due to the automatic stay is denied as a conclusion of law to which no response is required.
By way of further Answer, the debt that is the subject of Plaintiff's Complaint was incurred
after the bankruptcy filing by Gemini Equipment Business Trust. Therefore, the debt is
post-petition debt and is enforceable in state court proceedings.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment in its favor, and against Defendant, for the amount prayed for in Plaintiff's
Complaint.
Respectfully submitted,
KODAK LAW OFFICES, P.C.
J L. TROUTMAN, ESQUIRE #53984
for Robert D. Kodak, Esquire #18041
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7159
Attorney for Plaintiff
F:\ USER\ ROBIN\ MISC\ REPLY TO NM CC etc\38214 reply to nm.wpd
VERIFICATION
I, JEFFREY L. TROUTMAN, state that I am not a party to the action but that, at the
request of the Plaintiff, and based upon knowledge, information, records and documents
supplied to me by the Plaintiff, the averments set forth in Plaintiff's Complaint are true.
A Verification executed by the Plaintiff will be supplied as soon as it becomes
available.
I understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsification to authorities.
Dated: F ( //?
CERTIFICATE OF SERVICE
I, Robin Z. Shahan, Secretary for ROBERT D. KODAK, ESQUIRE and JEFFREY L.
TROUTMAN, ESQUIRE, hereby certify that on l ?a true and
correct copy of the Plaintiff's Reply to Defendant(s) New Matter, in the above-captioned
matter was served upon the Defendant, via Regular U.S. Mail, deposited at Harrisburg,
Pennsylvania, addressed as follows:
KIMBOB INC dba
GEMINI EQUIPMENT BUSINESS TRUST
PO BOX F
GRANTHAM PA 17027
KODAK LAW OFFICES, P.C.
Robin Z. Shaha cretary for
Robert D. Kodak, Esquire
State Auto Insurance Companies In the Court of Common Pleas of Cumberland
Plaintiff
Kimbob, Inc., d/b/a Gemini Equipment Business Trust County, Pennsylvania No. 11 -7451
Defendant
Civil Action—Law.
Oath
We 1�n solemnly swear(or affirm)that we will support, obey and defend the Constitution of the Unite ates
t n Commonwealth a that we will discharge the duties ur9ffY.-_e-wit ide.KE
nstitut n I s
tj
Z7 Wi.
ature nature
iganature Z& W
Delano A Lantz James DeCinti Richard D. Koch
Name(Chairman) Name Name
Delano M. Lantz & Associates Pion Johnston
Law Firm Law Firm Law Firm
4 North Hanover Street 355 North 21st St., Suite 102 Six Clouser Road
Address Address Address
Carlisle 17013 Camp Hill 17011 Mechanicsburg 17055
City, Zip City, Zip City, Zip
Award
We,the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following
award: (Note: If damages for delay are awarded,they shall be separately stated.)
va4s
'Th �A-VV r F/A
14-1 a,,/ * 3,�V3-�Al
Arbitrator, dissents. (Insert name if applicable.)
Date of He
Date of Award: (Chairman)
Notice of Entry of Award
Now,the day of , 20�_, at M.,the above
award was entered upon:the docket and notice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $ JV/IL- 906
By:
,000e Prothonotary Deputy
jr7
16 All lj �
"UMBERLAND Ctj;!.J�
PENNsYLVAt
IN RE: IN THE COURT OF COMMON PLEAS
STATE AUTO INSURANCE CUMBERLAND COUNTY, PENNSYLVANIA
COMPANIES,
Plaintiff, No. 11-7451
Civil Action - Law ,
VS. c-s ;
KIMBOB INC. d/b/a ter'' " J
GEMINI EQUIPMENT BUSINESS " -;
-� oo - r�
TRUST, i--
Defendant
=C:;, v
t
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
PLEASE enter the appearance of Darrell C. Dethlefs, Esquire on behalf of Kimbob, Inc. d/b/a
Gemini Equipment Business Trust in the above captioned matter.
Respectf 1 submitted,
Darrel . Dethlefs, Esquire
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
Date: May 8, 2013
IN RE: IN THE COURT OF COMMON PLEAS
STATE AUTO INSURANCE CUMBERLAND COUNTY,, PENNSYLVANIA
COMPANIES,
Plaintiff, No. 11-7451
Civil Action - Law
VS.
KIMBOB, INC. d/b/a
GEMINI EQUIPMENT BUSINESS
TRUST,
Defendant
CERTIFICATE OF SERVICE
I hereby certify that I am more than 18 years of age, and that on May 8, 2013, a copy of
the foregoing Praecipe to Enter Appearance was filed with the Cumberland County of Common
Pleas, and served upon the following using United States Postal Service, First Class Mail;
Robert D.Kodak,Esquire Robert M. Mumma 11, President
Jeffrey L Troutman,Esquire Kimbob, Inc. d/b/a
407 N. Front Street Gemini Equipment Business Trust
P.O. Box 11848 Box F
Harrisburg, PA 17108-1848 Grantham, PA 17027
Respectful s bmitted,
Respectful
—
Darrell #_. ethlefs, Esquire
Dethlefs-Pykosb Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
Date: May 8, 2013
IN RE: IN THE COURT OF COMMON PLEAS
STATE AUTO INSURANCE CUMBERLAND COUNTY, PENNSYLVANIA
COMPANIES,
Plaintiff No. 11-7451
Civil Action - Law
vs. -
rrt,
KIMBOB, INC. d/b/a x_;u
GEMINI EQUIPMENT BUSINESS ,r- 'CO '
TRUST, f -�
Defendant
�.
NOTICE OF APPEAL 4
FROM AWARD OF BOARD OF ARBITRATORS
TO THE PROTHONOTARY:
Notice is given that Kimbob, Inc. d/b/a Gemini Equipment Business Trust appeals from
the award of the board of arbitrators entered in this case on April 16, 2013. (A copy of the Award
is attached).
G 'ri
A jury trial is waived. m W w
I hereby certify that the compensation of the arbitrators has been paid.
°o ca°
z`
Respectfully u fitted, , iz
-<
Darrell ' . Dethlefs
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
Y
c���`2
State Auto Insurance Companies In the Court of Common Pleas of Cumberland
Plaintiff
Kimbob, Inc., d/b/a Gemini Equipment Business Trust County, Pennsylvania No. 11 _7451
Defendant
Civil Action-Law.
Oath
We do-'solemnly swear(or affirm) that we will support, obey and defend the Constitution of the Unite sates
thnstitution tl 's Commonwealth a� that we will discharge the duties ur of e witl ide.it, .
Signature J -� S'r " at.L e
g �S nature
Delano M. Lantz James DeCinti Richard D. Koch
Name (Chairman) Name Name
Delano M. Lantz & Associates Pion Johnston
Law Firm Law Firm Law Firm
4 North Hanover Street 355 North 21st St., Suite 102 Six Clouser Road
Address Address Address
Carlisle 17013 Camp Hill 17011 Mechanicsburg 17055
City, Zip City, Zip City, Zip
Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following
award: f (Note: If damages for delay are awarded, they shall be separately stated.)
'T7 �V"; ��lGi%Yi7'T` `1iy d l d�j f �L>> �+���) i`� F C (l''z�J '. �6��=1� ��Ie"L-
y Arbitrator, dissents. (Insert name if applicable.)
Date of Hearing: ���`� �G ��/3
Date of Award: �f �G, ��� -� (Chairman)
Notice of Entry of Award
Now,the me day of � 20 at I_ _ _ �- .1�4* the above
award was entered upon the docket andpotice thereof given by mail to the pgrties or their attornevs.
Arbitrators' compensation to be paid upon appeal: S
TRUE COPY FROM RECORD
_' y hAnd--'
P1'GthonoLary and the sea of said CnJn ai Carlisle, P>alt uty
This��av of 1,
► Prothonotary
IN RE: IN THE COURT OF COMMON PLEAS
STATE AUTO INSURANCE CUMBERLAND COUNTY, PENNSYLVANIA
COMPANIES,
Plaintiff, No. 11-7451
Civil Action - Law
VS.
KIMBOB, INC. d/b/a
GEMINI EQUIPMENT BUSINESS
TRUST,
Defendant
CERTIFICATE OF SERVICE
I hereby certify that I am more than 18 years of age, and that on May 8, 2013, a copy of
the foregoing Notice of Appeal was filed with the Cumberland County of Common Pleas, and
served upon the following using United States Postal Service, First Class Mail;
Robert D.Kodak,Esquire Robert M. Mumma II, President
Jeffrey L. Troutman, Esquire Kimbob, Inc. d/b/a
407 N. Front Street Gemini Equipment 13usiness Trust
P.O. Box 11848 Box F
Harrisburg, PA 17108-1848 Grantham, PA 17027
Respectful submitted,
Darrell . ethlefs, Esquire
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
Date: May 8, 2013
:2 t301. 21 110: 1,,.
Darrel C.Dethlefs,Esquire
ID#58805 (�i 41tri f GU; ,.�
Y Group, PENNSYLVANIA
Dethlefs- Pykosh Law Grou , LLC
2132 Market Street
Camp Hill,Pennsylvania 17011
Telephone—(717)975-2309
Fax—(717)975-2309
Ddethlefs @aol.com
STATE AUTO INSURANCE IN THE COURT OF COMMON PLEAS
COMPANIES, CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
v.
KIMBOB, INC. d/b/a No. 2011-7451
GEMINI EQUIPMENT
BUSINESS TRUST,
Defendant(s) : CIVIL ACTION - LAW
PETITION FOR LEAVE TO WITHDRAW APPEARANCE
AND NOW, comes the Petitioner, Dethlefs-Pykosh Law Group, LLC, by Darrell C.
Dethlefs, Esquire, counsel for the Defendant, Kimbob Inc. d/b/a Gemini Equipment Trust, and
hereby files the within Petition for Leave to Withdraw Appearance, and in support thereof avers
as follows:
1. On August 29, 2011, State Auto Insurance Companies, (hereinafter"Plaintiff'), brought a
civil suit against Kimbob, Inc. d/b/a Gemini Equipment Business Trust (hereinafter
"Defendant").
2. Plaintiff brought an action in Assumpsit against the Defendant to recover the sum of
$19,616.17 along with interest.
3. On or about July 17, 2012 a default judgment was entered against the Defendant by the
Court of Common Pleas of Cumberland County Prothonotary's office.
4. Following the default judgment, Robert M. Mumma, II, president of Kimbob, Inc
represented Defendant in the above-captioned action.
5. On or about May 8, 2013, Defendant retained Darrell C. Dethlefs, Esq. and Dethlefs-
Pykosh Law Group, LLC, as counsel, on an hourly basis to perform legal work in relation
to the above-captioned action. Said work was performed at 2132 Market Street, Camp
Hill, Cumberland County, Pennsylvania 17011.
6. On May 8, 2013, undersigned counsel filed a Notice of Appeal on Defendant's behalf.
7. The undersigned counsel has contacted Defendant regarding the payment of legal fees
currently owed.
8. Defendant has made promises to make payment which payment has not been made.
9. Defendant currently has an outstanding balance of$997.50.
10. Pursuant to the Rule of Professional Conduct 1.16(b), a lawyer may withdraw from
representing a client if:
(1) withdrawal can be accomplished without material adverse effect on the interests of
the client;
(5) the client fails substantially to fulfill an obligation to the lawyer regarding the
lawyer's services and has been given reasonable warning that the lawyer will withdraw
unless the obligation is fulfilled;
(6) the representation will result in an unreasonable financial burden on the lawyer or has
been rendered unreasonably difficult by the client; or,
(7) other good cause for withdrawal exists.
11. Pursuant to Rules of Professional Conduct 1.16(b)(5) and (6), the representation has
resulted in an unreasonable financial burden by the client's failure to fulfill an obligation
to the lawyer regarding the lawyer's services (in excess of$997.50).
12. Pursuant to Rules of Professional Conduct 1.16(a)(2) and 1.16(a)(3)requiring mandatory
withdrawal pursuant to Rules of Professional Conduct 1.16(a)(1), (5), (6) and (7)
12. Pursuant to Rules of Professional Conduct 1.16(a)(2) and 1.16(a)(3) requiring mandatory
withdrawal pursuant to Rules of Professional Conduct 1.16(a)(1), (5), (6) and (7)
allowing permissive withdrawal, and for all the reasons set forth herein, the undersigned
counsel cannot continue to represent the above-captioned Defendant in this action.
13. Withdrawal by undersigned counsel will not further delay this matter insofar as a timely
appeal was filed on behalf of Defendant.
14. As reflected by the attached Certificate of Service, a copy of the foregoing Petition has
been served upon all counsel of record and all parties.
WHEREFORE, the undersigned counsel respectfully requests that this Honorable Court
grant the within Petition and enter an Order granting leave to withdraw entry of appearance for
the Defendant, Kimbob, Inc, and to grant any other or further relief which the Court deems just
and equitable.
Respectfully' submitted,
Date: 1U-1
DETHLEFS-PYKOSH LAW GROUP, LLC
Darrell C. Dethlefs, Esquire
Attorney ID #58805
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
ddethlefs @aol.com
Petitioner
Darrel C. Dethlefs, Esquire
ID#58805
Dethlefs- Pykosh Law Group, LLC
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone—(717)975-2309
Fax—(717)975-2309
Ddethlefs @aol.com
STATE AUTO INSURANCE IN THE COURT OF COMMON PLEAS
COMPANIES, CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
v.
KIMBOB, INC. d/b/a No. 2011-7451
GEMINI EQUIPMENT •
BUSINESS TRUST,
Defendant(s) : CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Petition for Leave to Withdraw Appearance
was hereby served by depositing the same within the custody of the United States Postal Service,
First Class, postage prepaid, addressed as follows:
Robert D. Kodak, Esquire Robert M. Mumma, II, President
Jeffrey L. Troutman, Esquire Kimbob, Inc. d/b/a
407 N. Front Street Gemini Equipment Business Trust
P.O. Box 11848 Box F
Harrisburg, PA 17108-1848 Grantham, PA 17027
Respect j _ 1j -d,
Date:
DETHLEFS-PYKOSH LAW GROUP, LLC
Darrell C. Dethlefs, Esquire
Attorney ID #58805
2132 Market Street
Camp Hill, PA 17011
(717) 975-9446
ddethlefs @aol.com
STATE AUTO INSURANCE •▪ IN THE COURT OF COMMON PLEAS OF
COMPANIES, •▪ CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : CIVIL ACTION—LAW
KIMBOB, INC., d/b/a •
GEMINI EQUIPMENT •
BUSINESS TRUST, •
Defendant •▪ NO. 11-7451 CIVIL TERM
IN RE: PETITION FOR LEAVE TO
WITHDRAW APPEARANCE
ORDER OF COURT
AND NOW, this 28th day of October, 2013, upon consideration of the Petition for
Leave To Withdraw Appearance, a Rule is hereby issued upon Plaintiff and Defendant
to show cause why the relief requested should not be granted.
RULE RETURNABLE within 20 days of service.
BY THE COURT,
' r
Christyle L. Peck, J.
v4obert D. Kodak, Esq.
Jeffrey L. Troutman, Esq.
407 N. Front Street
P.O. Box 11848
Harrisburg, PA 17108-1848 - / �` F r-
Attorney for Plaintiff
cnr >a
,/barrel C. Dethlefs, Esq. �
2132 Market Street
s: F�
Camp Hill, PA 17011
Attorney for Defendant
I
v1 obert M. Mumma, II
President
Kimbob, Inc. d/b/a
Gemini Equipment Business Trust
Box F
Grantham, PA 17027
Defendant
:rc
t4( r tE (1 1r
Darrell C. Dethlefs, Esquire
Attorney I.D. #58805 CUMBERLAND COUNTY
Dethlefs-Pykosh Law Group, LLC PENNSYLVANIA
2132 Market Street
Camp Hill, PA 17011
Telephone—(717) 975-9446
Fax—(717) 975-2309
Ddethlefs(ajaol.com
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS OF
COMPANIES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : CIVIL ACTION—LAW
KIMBOB, INC., d/b/a
GEMINI EQUIPMENT
BUSINESS TRUST, :
Defendant : NO. 11-7451 CIVIL TERM
MOTION TO MAKE RULE ABSOLUTE
AND NOW, comes the Petitioner, Dethlefs-Pykosh Law Group, LLC,by Darrell C.
Dethlefs, Esquire, counsel for the Defendant, Kimbob, Inc., d/b/a Gemini Equipment Trust, and
hereby files the within Motion to Make Rule Absolute, and in support therof avers as follows:
1. On October 21, 2013, Petitioner, Darrell C. Dethlefs, Esquire and Dethlefs-Pykosh
Law Group, LLC, filed a Petition for Leave to Withdraw Appearance.
2. On October 28, 2013, this Honorable Court, by the Honorable Judge Christylee L.
Peck, signed an Order issuing a Rule to Show Cause upon Plaintiff and Defendant to
show cause why the relief requested in Petitioner's, Darrell C. Dethlefs', Petition for
Leave to Withdraw Appearance should not be granted.
3. Said Rule was returnable by filing an Answer in the form of a written response at the
Office of the Prothonotary in and for this Honorable Court within twenty (20) days of
service.
4. No response to the rule has been filed by the Plaintiff or the Defendant.
5. It has been more than 20 days since the Rule was issued.
WHEREFORE, Petitioner respectfully requests this Honorable Court make the Rule
Absolute and grant Petitioner's Petition for Leave to Withdraw Appearance.
Respectfully submitted,
/ )01 ( I
I
Date:
Darrell . Dethlefs, Esquire
Attorney I.D. #58805
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
Telephone—(717) 975-9446
Fax—(717) 975-2309
Ddethlefsaol.com
Darrell C. Dethlefs, Esquire
Attorney I.D. #58805
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
Telephone—(717) 975-9446
Fax—(717) 975-2309
Ddethlefs @aol.coin
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS OF
COMPANIES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
•
v. : CIVIL ACTION—LAW
KIMBOB, INC., d/b/a
GEMINI EQUIPMENT •
BUSINESS TRUST, •
Defendant : NO. 11-7451 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Motion to Make Rule Absolute was served by
depositing the same within the custody of the United States Postal Service, First Class, postage prepaid,
addressed as follows:
Robert D. Kodak, Esquire Robert M. Mumma, II, President
Jeffrey L. Troutman, Esquire Kimbob, Inc., d/b/a
407 N. Front Street Gemini Equipment Business trust
P.O. Box 11848 Box F
Harrisburg, PA 17108-1848 Grantham, PA 17027
Respectfully ii itted,
Date: /)� G� �
1
Darrell C. r'Iefs, Esquire
DETHLEFS-PYKOSH LAW GROUP, LLC
Attorney I.D. #58805
2132 Market Street
Camp Hill, PA 17011
(717)975-9446
Ddethlefs @aol.com
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS OF
COMPANIES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : CIVIL ACTION—LAW
•
KIMBOB, INC., d/b/a
•
GEMINI EQUIPMENT
•
BUSINESS TRUST,
Defendant : NO. 11-7451 CIVIL TERM
IN RE: MOTION TO MAKE RULE ABSOLUTE
ORDER OF COURT
AND NOW, this 26th day of February, 2013, upon consideration of the Petition for
Leave To Withdraw Appearance, and no response having been filed thereto, and upon
further consideration of the Motion To Make Rule Absolute, the Petition for Leave To
Withdraw Appearance is granted. Defendant is hereby ordered to retain counsel within
30 days of the date of this Order.
BY THE COURT,
Christy ee L. Peck, J.
ob D. Kodak, Esq.
q
Jeffrey L. Troutman, Esq.
407 N. Front Street
P.O. Box 11848
Harrisburg, PA 17108-1848
Attorney for Plaintiff M
rn rri TY
C/) N
Darrel C. Dethlefs, Esq. < '`' --' '.:
2132 Market Street nc
-a
•
Camp Hill, PA 17011 ry t
Attorney for Defendant -_ �:. =_
./Robert M. Mumma, II
President
Kimbob, Inc. d/b/a
Gemini Equipment Business Trust
Box F
Grantham, PA 17027
Defendant
•rc
t eS / 'Za4 l!L
Z/2.?/'Y
="yr)
ABRAHAM LAW OFFICES, LLC
45 East Main Street, Hummelstown, PA 17036
717-566-9380;abelaw@comcast.net; Fax 566-9385
Attorney for Defendant, Kimbob, Inc. d/b/a Gemini Equipment Business Trust
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS
COMPANIES : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. : NO. 11 - 7451
KIMBOB, INC. d/b/a/ GEMINI
EQUIPMENT BUSINESS
TRUST
Defendant
: CIVIL ACTION - LAW
PRAECIPE TO ENTER APPEARANCE
Please enter the appearance of James W. Abraham, Esquire, Abraham Law
Offices, LLC, Hummelstown, Pennsylvania, as attorney for Defendant, KIMBOB, INC,
d/b/a Gemini Equipment Business Trust, in the above-captioned action.
Respectfully submitted:
James W. Abraham, Esquire
Abraham Law Offices, LLC
45 East Main Street
Hummelstown, PA 17036
717-566-9380
Attorney for Defendant,
KIMBOB, INC., d/b/a
Gemini Equipment Business Trust
DATE: 3/21/14
CERTIFICATE OF SERVICE
I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served
a true and correct copy of the foregoing document by first class mail upon the following
person(s) at the following address on the date stated below:
Robert D. Kodak, Esq.
Jeffrey L. Troutman, Esq.
407 North Front St.
PO Box 11848
Harrisburg PA 17108
DATE: 3/21/14
James W. Abraham, Esquire
ABRAHAM LAW OFFICES, LLC
‘45 East Main Street, Hummelstown, PA 17036
717-566-9380;abelaw@comcast.net; Fax 566-9385
Attorney for Defendant, Kimbob, Inc. d/b/a Gemini Equipment Business Trust
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS
COMPANIES : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 11 - 7451 c-)
KIMBOB, INC. d/b/a/ GEMINI : CIVIL ACTION - LAW
EQUIPMENT BUSINESS
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TRUST -<> cp
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Defendant
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MOTION TO WITHDRAW AS COUNSEL
AND NOW, comes James W. Abraham, Esquire, Abraham Law Offices, LLC,
Hummelstown, Pennsylvania, counsel of record for Defendant, Kimbob, Inc. d/b/a Gemini
Equipment Business Trust, and files the following:
1. On or about March 19, 2014, Robert M. Mumma, II, the principal and sole
officer/owner of Defendant, Kimbob, Inc. d/b/a Gemini Equipment Business Trust (hereinafter
"Mumma") retained James W. Abraham, Esquire, Abraham Law Offices, LLC, Hummelstown,
Pennsylvania (hereinafter "Counsel") for legal representation in the above -captioned action.
2. On March 21, 2014, Counsel filed a Praecipe to Enter Appearance as counsel for
Mumma.
3. After Counsel filed the Entry of Appearance, Counsel and Mumma met to discuss the
action herein, and other matters, on or about April 30, 2014, at which time Counsel and Mumma
incurred a complete breakdown in communication and irreparable disagreement as to
this action, and at which time, Mumma left Counsel's office and indicated and/or stated as he
was leaving, that he would no longer be using Counsel as his attorney for this action.
4. Since the April 30, 2014 meeting, Mumma has not contacted Counsel in regard to this
action and there have been no discussions or authorization by Mumma for Counsel to proceed
with representation in the case.
5. Counsel submits that Mumma has no intention of maintaining Counsel as his attorney
for this action and Counsel and Mumma are unable to reach any agreement on any aspect of this
case and are at a total impasse.
6. Counsel has contacted the attorney for Plaintiff, Robert D. Kodak, Esquire, and
Attorney Kodak has advised that there is no objection by Plaintiff to Counsel's Motion for
Withdrawal as Counsel for Mumma.
7. Counsel submits that there is no prejudice to Mumma if Counsel's Motion is granted
as Mumma has had more than sufficient time and opportunity to secure another attorney for
representation in this action.
WHEREFORE, Counsel respectfully requests Your Honorable Court to grant Counsel's
Motion To Withdraw As Counsel and order that James W. Abraham, Esquire, Abraham Law
Offices, LLC, Hummelstown, Pennsylvania, is no longer attorney of record for Defendant,
Kimbob, Inc., d/b/a Gemini Equipment Business Trust, in the above -captioned action and is
excused from any and all court appearances in this action.
Respectfully submitted:
James W. Abraham, Esquire
Abraham Law Offices, LLC
45 East Main Street
Hummelstown, PA 17036
717-566-9380
DATE: 7/30/14
CERTIFICATE OF SERVICE
I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served
a true and correct copy of the foregoing document by first class and/or certified mail to the
following persons at the following addresses:
Robert D. Kodak, Esquire
407 North Front Street
PO Box 11848
Harrisburg PA 17108
(regular mail and email)
Robert M. Mumma II
Box F
Grantham PA 17027
(certified mail)
DATE: 7/30/14
James W. Abraham, Esquire
s
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS
COMPANIES : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 11 - 7451
KIMBOB, INC. d/b/a/ GEMINI
EQUIPMENT BUSINESS
TRUST
Defendant
: CIVIL ACTION - LAW
RULE
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AND NOW, this 41U day of saQGnus , 2014, a Rule is hereby
issued upon Defendant, Kimbob, Inc. d/b/a/ Gemini Equipment Business Trust, to show cause as
to why the relief requested in the Motion To Withdraw As Counsel, filed herein, should not be
granted. /�
This Rule is returnable within (20 days upon service of the aforesaid Motion
upon Defendant.
BY THE COURT:
4c/C,
Chri lee L. Peck, Judge
c: ert M. Mumma, II, Box F, Grantham, PA Sobert D. Kodak, Esq., PO Box 11848, Harrisburg PA 17108
—James W. Abraham, Esquire, 45 E. Main St., Hummelstown, PA 17036.
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• ABRAHAM LAW OFFICES, LLC
45 East Main Street, Hummelstown, PA 17036
717-566-9380;abelaw@comcast.net; Fax 566-9385
Attorney for Defendant, Kimbob, Inc. d/b/a Gemini. Equipment Business Trust
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS
COMPANIES : CUMBERLAND COUNTY, PENNSYLVANIA c
Plaintiff
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KIMBOB, INC. d/b/a/ GEMINI : CIVIL ACTION - LAW �c
EQUIPMENT BUSINESS
TRUST i>
v. :NO. 11 -7451
Defendant
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MOTION TO MAKE RULE ABSOLUTE
AND NOW, comes James W. Abraham, Esquire, Abraham Law Offices, LLC,
Hummelstown, Pennsylvania, counsel of record for Defendant, Kimbob, Inc. d/b/a Gemini
Equipment Business Trust, and files the following:
1. On July 30, 2014, James W. Abraham, Esquire, Abraham Law Offices, LLC,
Hummelstown, Pennsylvania (hereinafter "Counsel") filed a Motion To Withdraw as Counsel
(hereinafter "Motion") as to Defendant, Kimbob, Inc. d/b/a/ Gemini Equipment Business Trust,
which company's principal and sole officer/owner is Robert M. Mumma, II (hereinafter
"Mumma").
2. On August 4, 2014, a Rule to show cause was issued by the Court as to why the
Motion should not be granted, which Rule was returnable within twenty (20) days from service
upon Mumma, and said Rule was mailed to Mumma on August 4, 2014 by the Court, as
indicated by the Prothonotary and/or Court Administrator's Office's notes of "Copies Mailed",
on said Rule. A true and correct copy of the Court's Rule, as well as the Rule with the aforesaid
notes, are attached hereto as Exhibit "A".
3. Additionally, Counsel served Mumma with the Motion by certified mail and the Rule
by certified mail, which Motion was received by Mumma on July 31, 2014 and the Rule was
received by Mumma on August 18, 2014. A true and correct copy of the Post Office certified
mail return receipt cards confirming receipt of the Motion and Rule by Mumma are attached
hereto as Exhibit "B".
4. More than twenty (20) days has passed since the August 4, 2014 mailing of the Rule
to Mumma by the Court, and as of September 8, 2014, twenty (20) days has passed since the
receipt and service of the Rule upon Mumma by certified mail on August 18, 2014, and Mumma
has not filed a response to the Motion.
5. Counsel respectfully submits that Mumma has had more than sufficient time to
respond to and/or answer the Motion, and now has failed to respond to and/or answer the Motion
within the time allocated and ordered by the Court pursuant to the Rule, and Mumma has had
more than sufficient time to retain other counsel and has failed to do so.
WHEREFORE, Counsel respectfully requests Your Honorable Court to grant Counsel's
Motion To Withdraw as counsel for Defendant in this action and be excused from any and all
court appearances and proceedings in this action.
Respectfully submitted:
James W. Abraham, Esquire
Abraham Law Offices, LLC
45 East Main Street
Hummelstown, PA 17036
717-566-9380
DATE: 9/9/14
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS
COMPANIES : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 11 - 7451
KIMBOB, INC. d/b/a/ GEMINI
EQUIPMENT BUSINESS
TRUST
Defendant
: CIVIL ACTION - LAW
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AND NOW, this .94 day of kct.451--- , 2014, a Rule is hereby
issued upon Defendant, Kimbob, Inc. d/b/a/ Gemini Equipment Business Trust, to show cause as
to why the relief requested in the Motion To Withdraw As Counsel, filed herein, should not be
granted.
This Rule is returnable within 020 days upon service of the aforesaid Motion
upon Defendant.
BY THE COURT:
c: Robert M. Mumma, II, Box F, Grantham, PA 17027
Robert D. Kodak, Esq., PO Box 11848, Harrisburg PA 17108
James W. Abraham, Esquire, 45 E. Main St., Hummelstown, PA 17036.
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STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS
COMPANIES : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
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: NO. 11- 7451 -12Z1-- --f
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RULE
AND NOW, this `%U day of alL
, 2014, a Rule is hereby
issued upon Defendant, Kimbob, Inc. d/b/a/ Gemini Equipment Business Trust, to show cause as
to why the relief requested in the Motion To Withdraw As Counsel, filed herein, should not be
granted.
This Rule is returnable within (2 0 days upon service of the aforesaid Motion
upon Defendant.
BY THE COURT:
Chri lee L. Peck, Judge
c: ert M. Mumma, II, Box F, Grantham, PA 17027
�Drt D. Kodak, Esq., PO Box 11848, Harrisburg PA 17108
games W. Abraham, Esqu� e,,5 E. Main St., Hummelstown, PA 17036.
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`COMPLETE; THIS SECTION;ON;DELIVERY;:
Comple e Items 1, 2, and 3. Also complete
item 4 if Restricted -Delivery is desired.
• ■ Print your name and address on the reverse
so that we can retum the card to you.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
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b (Printed Name)
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D. Is delivery address different from item
If YES, enter delivery address below:
0 No
2
3. Se ce Type
edified Mall° 0 Priority Mall Express'"
0 Registered 0 Return Receipt for Merchandise
0 Insured Mail 0 Collect on Delivery
4. Restricted Delivery? {Extra Fee)
' 0 Yes
_2 Arilds N,arr.l _
7014 1200 0002 211? 1425
PS Form 3811, July 2013
Domestic Return Receipt
SENDER •eOMPLFTE 7NIS SECTION;
• Complete items f, rand 3. Also complete
item 4 if Restricted°Delivery is.desired.
• Print your name•and address on the reverse
so that we can return the card to you.
• Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
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COMPLETE,THIS SECTION•OND'ELIVERY
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0 Addressee '
D. Is delivery address different from Rem
If YES, enter delivery address below:
No
3. Service Type
Registered
0 Insured Mail
0 Priority Mall Express
D Retum Receipt for Merchandise '
0 Collect on Delivery
4. Restricted Delivery? (Extra Fee)
0 Yes
7014 1200 0002 2117 1432
PS Form 3811, July 2013
Domestic Retum Receipt
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CERTIFICATE OF SERVICE
I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true
and correct copy of the foregoing document by first class mail to the following persons at
the following addresses:
Robert D. Kodak, Esquire
407 North Front Street
PO Box 11848
Harrisburg PA 17108
Robert M. Mumma II
Box F
Grantham PA 17027
DATE: 9/9/14
James W. Abraham, Esquire
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS
COMPANIES : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : NO. 11 - 7451
mW
KIMBOB, INC. d/b/a/ GEMINI : CIVIL ACTION - LAW .rT;
EQUIPMENT BUSINESS,
TRUST r—
Defendant > c
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ORDER
Fri
AND NOW, this /a tZ day of k , 2014, in consideration of the
Motion To Withdraw As Counsel and Motion To Make Rule Absolute, as filed herein, it is
hereby ordered that said Motions are granted and that Defendant's Counsel of Record, James W.
Abraham, Esquire, Abraham Law Offices, LLC, Hummelstown, Pennsylvania, is no longer
counsel and/or counsel of record for Defendant, and said Counsel is hereby excused from any
and all court appearances and/or proceedings as to Defendant and/or the above -captioned action.
2) i / 3 'r - A 54itiyt Ce e ,1/t .76)
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BY THE COURT:
Christylee . Peck, Judge
c:ert M. Mumma, II, Box F, Grantham, PA 17027
ert D. Kodak, Esq., PO Box 11848, Harrisburg PA 17108
James W. Abraham, Esquire, 45 E. Main St., Hummelstown, PA otufts.41.
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PRAECIPE FOR LISTING CASE FOR NON JURY TRIAL
(Must be typewritten and submitted in triplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY
Please list the following case for a TRIAL WITHOUT A JURY.
CAPTION OF CASE
{entire caption must be stated in fulls
STATE AUTO INSURANCE COMPANIES
(Plaintiff)
vs.
KIMBOB, INC. doing business as Gemini
Equipment Business Trust p
(Defendant)
vs.
(check one)
ri Civil Action — Law
n Appeal from arbitration
(other)
Indicate the attorney who will try case for the party who files this praecipe:
Jeffrey L. Troutman, Esquire, Kodak Law Offices, P.C.
Indicate trial counsel for other parties if known:
No attorney has entered an appearance on behalf of Defendant since Defendant's
most recent counsel was granted leave to withdraw as counsel per Order of Judge
Peck dated September 12, 2014.
This case is ready for trial.
Date: November 14, 2014
Signed:
Print Na
Jeffrey L. Troutman
Attorney for: Plaintiff
amk s 9q
-pid ai4t-
Da- 30155
12-431 UPI5
CERTIFICATE OF SERVICE
I, Robin Z. Forry, Secretary for Robert D. Kodak, Esquire and Jeffrey L. Troutman, Esquire , hereby
certify that on
, a true and correct copy of the Praecipe for Listing Case for Non -Jury
Trial , in the above -captioned matter was served upon the Defendant (or Defendant's counsel), via Regular
U.S. Mail , deposited at Harrisburg, Pennsylvania, addressed as follows:
KIMBOB INC
PO BOX 5
CAMP HILL PA 17001
KODAK LAW OFFICES, P.C.
Robin Z. Forry, S retary to
Robert D. Kodak, Esquire and
Jeffrey L. Troutman, Esquire
STATE AUTO INSURANCE : IN THE COURT OF COMMON PLEAS OF
COMPANIES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v. : CIVIL ACTION — LAW
KIMBOB, INC., d/b/a
GEMINI EQUIPMENT
BUSINESS TRUST,
Defendant
: NO. 11-7451 CIVIL TERM
IN RE: NONJURY TRIAL
AND NOW, this 26th day of November, 2014, a pretrial conference in this case is
scheduled for Monday, March 9, 2015, at 3:00 p.m., in Courtroom No. 5, Cumberland
County Courthouse, Carlisle, Pennsylvania. Pretrial memoranda shall be submitted by
each party in accordance with the local Cumberland County Rules of Procedure 212-4, at
least five days prior to the pretrial conference.
A NONJURY TRIAL in this case is scheduled for Friday, April 10, 2015, at 9:30
am., in Courtroom No. 5, Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
Jeffrey L. Troutman, Esq.
407 N. Front Street
P.O. Box 11848
Harrisburg, PA 17108-1848
Attorney for Plaintiff
Kimbob, Inc.
P.O. Box 5
Camp Hill, PA 17011
Defendant
Court Administrator
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