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Home My WebLink About12-7858COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Main Street Acquisition Corp. Plaintiff v. No. IOC ~S ~~~il ja°f'Yhc - • _. __., PETER SALVATORE ~= `"~ Defendant ~:~ ~ -' T . r./3.,,,, W ~~ • •-,? f "" :d izawo~i c-J ~` ,~. c:.: - - ~`- .._ - 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. Cumberland County Bar Association 34 S. Bedford Street Carlisle, Pennsylvania - telephone number 717-249-3166 ~103.~5 PO ATt`•( ~'aQ~l ,p.~a~l ~~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION -LAW Main Street Acquisition Corp. Plaintiff v. No. PETERSALVATORE Defendant ~~~~~~ COMPLAINT Plaintiff, Main Street Acquisition Corp., by and through its counsel, Demetrios H. Tsarouhis, files this Complaint and aver as follows: 1. Plaintiff, Main Street Acquisition Corp., ("Plaintiff') is a Nevada business corporation having an office at 3715 Davinci Court, Suite 200, Norcross, GA, 30092. 2. Defendant, PETER SALVATORE, is an adult individual resident of Pennsylvania who maintains an address at l 13 LANCASTER BLVD, Mechanicsburg PA 17055-3548. COUNTI BREACH OF CONTRACT 3. At all relevant times herein, Plaintiff s predecessor, HSBC BANK NEVADA NA/Direct Merchants Mastercard, was engaged in the business of extending credit to potential clients. 4. Defendant applied for and received a credit card issued by Plaintiff s predecessor with the account number ending in * * * * * * * * * * * * 123 6. 5 . Defendant used the credit card with account number ending in * * * * * * * * * * * * 1236, for purchases, cash advances and/or balance transfers. Use of the card in this manner constituted 2 acceptance of the terms and conditions and subjects the Defendant to the terms and conditions contained therein. 6. The Defendant was mailed monthly account statements relative to the Defendant's use of the subject credit card. Incorporated herein by reference as if set forth herein at length and attached as Exhibit "A" is a true and correct copy of the most recent statement. 7. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 8. The last payment of the Defendant was received and credited on 10/17/2008 and Defendant has failed pay any amounts since that time. 9. The account was charged of on or about 05/31 /2009. 10. The instant account was sold to Main Street Acquisition Corp. for valuable consideration and all rights under said account were assigned to Plaintiff. Incorporated herein by reference as if set forth herein at length and attached as Exhibit "B" is a true and correct copy of the Bill of Sale and Assignment. 11. The principal amount due at the charge off date was $3,181.23. 12. Plaintiff is also entitled to receive interest on the above amount determined by applying the statutory interest rate of 6% per annum to the past due balance, which currently totals $0.52 per diem. This amount will increase per day by the per diem amount until the date of judgment. 13. Plaintiff is entitled to have 6% per annum interest charge continue to accrue as set forth above, from the date of the filing of this Complaint until the date of judgment in this matter. 14. The total amount due and owing the Plaintiff including interest, is $3,181.23. 3 WHEREFORE, Plaintiff requests judgment in its favor and against Defendant as follows: a) Judgment in the amount of $3,181.23 due on the account; a) Interest at the per diem rate of $0.52 from the date of filing this Complaint until the date of Judgment; b) Costs of suit; and c) Any other relief as the Court deems just and appropriate. COUNT II ACCOUNT STATED 15. Plaintiff incorporates the allegations of every paragraph enumerated above this Complaint as if said paragraphs were fully set forth here at length. 16. The within account was an account in writing and expressly or impliedly accepted by both parties. 17. The amounts due and owing to Plaintiff by Defendant are based on a subsisting debt and arise from a preexisting account or course of dealing between the Defendant and Plaintiff's predecessor. 18. The account is an Account Stated, thereby operating to foreclose any dispute over the amounts due. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant as follows: a) Judgment in the amount of $3,181.23 due on the account; b) Interest at the per diem rate of $0.52 from the date of filing this Complaint until the date of Judgment; c) Costs of suit; and 4 d) Any other relief as the Court deems just and appropriate. COUNT III UNJUST ENRICHMENT 19. Plaintiff incorporates the allegations of every paragraph enumerated above this Complaint as if said paragraphs were fully set forth here at length. 20. At Defendant's request, Plaintiffs predecessor conferred a benefit upon Defendant by providing the credit described in the exhibits attached hereto. 21. Defendant received and accepted the benefit of said credit provided by Plaintiff's predecessor. 22. At all times material hereto, Defendant was aware that Plaintiff s predecessor was providing the aforesaid credit to Defendant and that Plaintiff expected to be paid for such. 23. At all times material hereto, Defendant, with the aforesaid knowledge, permitted Plaintiff s predecessor to provide said credit and to incur damages. 24. At all times material hereto, Defendant was unjustly enriched by retaining the benefit of receiving said credit without paying Plaintiff s predecessor fair and reasonable compensation. 25. Allowing Defendant to retain the benefit of said credit without paying fair compensation would be unjust. 26. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's expense, an implied contract exists between Plaintiff and Defendant and Defendant is obligated to pay Plaintiff the amount due described in the exhibits attached hereto in the amount of $3,181.23. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant as follows: a) Judgment in the amount of $3,181.23 due on the account; 5 b) Costs of suit; and c) Any other relief as the Court deems just and appropriate. Respectfully Submitted, DEMETRIOS H. TSAROUHIS I.D. #88513 Attorney for Plaintiff 21 S. 9`h Street-Suite 200 Allentown, PA 18102 610-439-1500 Date: October 29, 2012 6 Account Number New Balance Minimum Payment Due Payment Due Date Amount Enclosed 5468001612901238 $0.00 $0.00 08/22/2009 $~^^^^.^~ •~ ~~~~~ a a. rate anaror ovenlmrt tees, you must pay $0,00 (which incNdas the Minimum Payment Dua and any Past Due andlor Ovartimit Amountsl. Do we have your anent mailing antl email adtlresst Make check payable to: HSBC Grd Servloss Please check and provitle on the reverse side. Send Payment To: PETER SALVATORE 9a 113 LANCASTER BLVD MECHANICSBURG PA 1 70 55-3 548 ~~Illlllllrrl~lll~ll'~Ilrurllirr~~'I~I~'~Illl~rrll~~l'I'~Illlrll 545800 Mtach are ImoR this top portbn In tM orrcbaotl anrNOp. HSBC m PAYMENT CENTER PO BOX 17313 BALTIMORE MD 21297-1313 Irllrrl~rrnlllll~l~l~l~l'ICI'~~'~Il~rrllrrrrl'~~~~'lll~l~~l~l'r 15129D]r2360D000000000000008 8e sure the Payment Center adWess shows in the envelope wintlow. Pay your bill anytime at AccountCentralOnline.com YOUR HSBC ACCOUNT SUMMARY Statement Data .....................................May 31, 2009 Account Number ......................5469001612901236 Total Credit Limit .........................................$2,500.00 Total AvailableCredh .......................................$0.00 Cash Advance Credit Limit ............................$626.00 Cash Advance Available Credit .........................$0.00 Minimum Payment Due .....................................$0.00 Payment Due Date ...............................June 22, 2009 Past Due Amount ...............................................$0.00 OverlimR Amount ..............................................$0.00 •To avoid additional late and/orovarlimh fees, you must pay $0.00 (which includes the Minimum Payment Due and any Past Due and/or Overlimit Amountsl. YOUR BALANCE DETAILS Previous Balance ............................. ........... $3,181.23 Purchases ........................................ ................+$0.00 Cash Advances ................................ ...............+$0.00 Payments & Other Credits .............. ........ . $3,161.23 Fees/Other ......................................... ...............+$0.00 Finance Charges ............................... ...............+$0.00 New Balance ..................................... ................. $0.00 Notks: Sae revsrss skis for Important IMormstbn. YOUR TRANSACTIONS PAYMENTS Q CREDITS Trane. Post Date Date ReferenceB Description (-) Credits 1+) Charges 05/37 05/31 FS500004P00999990 05/31 05/31 F8800004P00999990 CHARGE OFF ACCOUNT-PRINCIPALS $2,462.78 CHARGE OFF ACCOUNT •FINANCE CHARGES' $728,46 5994 ~ ~~ ~ T7G _.e-~` sn. 1io;a 5 17 09p531 0 Z X PAGE 1 of 3 1 0 8800 1500 7089 018N599/ WHEN SENDING US YOUR PAYMENT... ALWAYS INCLUDE YOUR ACCOUNT NUMBER ON THE CHECK BE SURE TO SIGN YOUR CHECK REMOVE THE TOP PORTION OF YOUR STATEMENT AND RETURN WITH YOUR PAYMENT IN THE ENVELOPE PROVIDED PAYMENT IS DUE BY THE DATE INDICATED IN THIS STATEMENT ~ExhibiY ~t~[~, tt Chang, your atldrou rrnlin~ Inatantfy at AceountCsntnlOnl[nn.com YOUR CONTACT INFORMATION Please note-Address changes may take up to two (2) weeks to process. Please print clearly. Address # Street Name Apt # and Other Address Info City State Zip Code Your Home Phone Number ~ Voumineas Pho~n-e-{N`-`---~---~~ - Print Fm ail Add real' ~J ' Emdl ecHrara b opkrrel. Wa ael mnrmuniare aan louvre smell regerdWig you accouu era ocraeirre acrd erleme/ meraoring prrneca. # you prowowy opted out tram rrcdvhg emaas, proNrMg Nour send! addersr w#1 oarrcd /hsf dedlon,Marre/ errd ,About Your Payment, • You agree to pay at least the Minimum Paymed in time [o he credited to yom Aecewnt as of the Payment Due Date. • If yom Acemmt ie dehngtrent, You coo avoid an dditional bate Payment Fee by paying az least the Minknun Payment Due, which inchrdes arty Past due amoum, in time m be posted ae of the Payment Due Date. You may Pay tmro than the Minimum Payment Dueand you may pay the entiro New Balance az any time. ' Paymeds ahegld lx [nailed with a single coupon to the payment address shown oa th !root of this billing stazement. Paymrnu must be made by a single check ca• money order payable in US. dollars and drown on a US. Institution, • Paymeds received az the paymem address by 5:00 pm Faskm time, on avy day, will be credited to your Accaua as of the date of receipt; otherwise peymeat will be credited as of the next day. • Crediting payments to yom Accomd may be delayed up to five days if the payrrtent v not made u described about; k nd received az the address provided for romifunce; ie nd xcompanied by ate payment coupon; b roceivtd iu an envelope abet thw the envelope proviekd fa remittance; b appied, fokkd, or paper clipped; or includes mWtipk paymwtl coupons a chceke. • If your New Balame is a credit balance, it will be applied to fuhue purchases or rash advances. er refunded to you az yom written request. Requests should be mailed to the inquiry address shown on the from of yom billhrg suterrcnt. By sending rs a check for payment on your Account, yon authorize us to make a om time electroNc grnda transfer (EFT) from yom bank aernmtt or to process the payment u a check tranaaRbn. When we use information from yom check to [Hake au EFT, fttuds may be withdraw firm your accoum as soon ae the same day we receive yom paymen, and you will rot raeive yom check back from your financial btstimtron. It you do m[ went yom checks to be convmted to an EFT, please veil customer service az the phone number on the bxk of yom card Payment Ry Phone: When you use our optional payment by phone service, You authorize us to initiate an electronic foods transfer from your designated bade xeormt m to process the payment as a check transactieo. You must authorize the snout[ and timing of each payment. Please retain tlris erahorizazioa for your records. Card Renewal: An Annual Fee mry apply to yom Account If yom Annual Fee is billed amorally, You can avoid paying the fee if you call and close yom Account within 30 days of being billed. You may caatinue to use yom Cart) drrmg the 30 day period withom paying the F . If yorr fee tr billed modhly, whin you call and close yom. Account due to the Annual Fee charge, that month's fx will be credited back to your Accorm[. How We Crtlculs[e Finance CTuQee: We calculate the periodic Finance Charge on yomAccormt by mWtiplynrg the applicable Daily Periodic Rate by the Average Daily Balance for each category of transacliom shown on yom billing statement (e.g., purchases, balance trarrsfers, rash advancce); Use rcadu are then multiplied by the nwnber of days in the billing cycle. Determining the Daily Balance: We take the beginning balance for exh category of traoeadione each day. add any sew troosadione, soy previous ebbs periodk Fimnce Charges. any assessed foes and charges, and subtend any payments and/or credits. If a hansadien posts aRer the begiruring of are billing cycle, the appliable Daily Balance and arty related Finance Charge edcubtiom will be adjusted retroactively to include the trarrxdon amount ae of the day it was posted. Calculating the Average Daily Balance: Fa exh tramaction caregory, we add all the Daily Balarcea for the billing rycle together and divide the total by the mmrber of days in the billing cycle. if the balance for any day is Ices than zero, we trcd it os zero. This ie the Average Daily Balmtce (including now pmchasce) method. Grace Periods: Fa credit card purchases, periodic Finance Chargce begin to xaue on the daft of the transaction and continue to accrue until payment in fWl is credited to your Account. However, you have a Orece Period of at (east 20 days from the statement daft if no periodic Finance Charge was billed to the Accorot in the cureent billing period: otherwise the Payment Due Daze will be 25 days frdn the statement date. That means, if you paid the New Balance shown on your last billing statement by the Payment Due Dale for dent billing statement, you have until the payment Due Date for yom crarea[ billing rycle to pay your New Balance in full to avoid the impoakion of periodk Finance Clrergce on new credit card prrchases. periodic Fitrauce Charges that accrue aRer fhe statement date will appear em the next billing statement. There is m Grace Period for cash advmces and bebme transfers, including exdit card checks. That means, pedodic Fitunce Charges begin to xarc on We date of the tmruadion and cominrre to accrue unN paymed in fWl b crodited to your Account. Dally Periodic Rate/Annual Percenage gate: The Amual Percentage Rates on yom billing statement reFlect the amuelized egrrivalent oC the Daily Periodic Rates xlually applied during a particubr billing ryck. The Ammal Percentage Rates may differ from the Nomiml Arunul Percentage Aazce because of the inchuion of any Finance Charge abet than a periodic Fhrame Charge. Yom Amrual Percenage Rates and Daffy Periodie Rates may vary. Minimum Finance Chugs: A Minimum FINANCE CHARGF, of 51.00 will be charged in exh billing rycle in which periodic Finance Chagce aro payable. BiBhtg Rights Summary: In case of errors or questions about your biDiag sutemem: If you think you billing stazemed is wrong. a if you need more information about a transaction exr your billing statement, write m as soon as possible, on a separate dreeQ of paper, az Carekrrember Service Center, EO. Box 5251, Carol Stream, D- 60197-9642. We mutt hear from you m later than 60 days after uo seat you the fits[ billing sfaterneot on which Ore error a problem appeared. You can telephesre us, but doing eo w01 not preaervt your rights. In yom letter, Please include the foLLowing ioformaziem: • Yom name and xcoum mrmber. • The dollar amexrm of the suspected error. • A descriptive of the error Explain, if you Leo why you believe (here an error and soy steps you have liken to resolve the error You ek nd have [o pay any amount in question while vex are hrvostigaring, but you are obligated to pry We parts of yom bill that are nd in queetioa While wt iweatigate you grteetion, we camel report you as delinquent or take arty xtion to collect the amoum you yrrcetion. Speelal Rule !or Crertlt Card Purchases: [f you have a problem with the quality of goods or emiccr thaz you purchased with a credit card and you have tried in good faith m coned the problem with the merchant. You tray nd have to pay the remaitting amount dot on the goods or smites. This prdedion applies poly when the purchase price was more than S50 attd the purchase was road[ N your home state or within 100 miles of yom mailing address. If we owm or operate the merchant or if we mailed you the advertisement for the property ex services, all purchasce are covered regardless of amount or location of pmchaee. Debt CoBectlon: We zee required by law, when applicable, to trotlfy you that we zee attempting to collect s debt, and atry information obtairred w111 be turd for that ptvpere. Negatlve f7edit Bureau Reporting; We may report information about yom Account to eredil bureaus. bate payments, missed paymenl4 or other defaW[a on yom Acrnnnlenay be reBeded In yam credit report. OI BN5994 - I I - 02/1 I/:008 YOUR FINANCE CHARGES Average Daily Daily Days in FINANCE ANNUAL NOMINAL ANNUAL Balance Periodic Rate Billing Cycle CHARGES PERCENTAGE RATE PERCENTAGE RATE Purchases 50.00 0.07462%Iv1 30 $0.00 27.26% 27.24%Ivl Cash Advances 50.00 0.07941%(vl 30 50.00 28.99% 28.99%Ivl ~~~wui~ rw ~ofaf mAx vAf Ivl indicates variable rate. HOW TO REACH US Cardmember Service Center : ..................................................................................................................................................804379.7999 Pay by Phone :.....................................................................................................................................................................677.2 PAY-CARD Pay by Phone outside the U.S. (Call Collect) : .......................................................................................................................904987.9897 Hearing Impaired-TDD :............................................................................................................................................................877.902.0867 Mail Payments to : ......................................................................................Payment Canter, PO Box 17313, BeFtlmore, MD 27297.1313 Mail Inquiries to : .............................................................................Grdmember Servkes, PO Box 5250, Grol Strwm,! 80797.5260 Online Account Management :........................................................................................................................AecountCentnlOnllne.eom 5994 T7G t 5 77 090531 0 Z X PAGE 2 of 3 1 0 8800 7500 T0a9 O18N5994 5984 T7G 1 5 17 090537 0 Z X PAGE 3 of 3 1 0 8800 1500 T089 Ot8N5994 BILL OF SALE HSBC CARD SERVICES (III) INC. ("Seller"), for value received and pursuant to the terms and conditions of the Receivables Purchase Agreement ("Agreement") dated February 20, 2009 between Seller and Main Street Acquisitions Corp.("Purchaser"), does hereby sell, assign and convey to Purchaser, its successor and assigns, all right, title and interest of Seller in and to those certain purchased receivables listed on the Sale File attached as Exhibit A, without recourse and without representation of, or warranty of, collectibility, or otherwise, except to the extent provided for within the Agreement. EXECUTED this 30`h day of June, 2009. HSBC CARD SERVICES (III) INC. By: _ Name: Susan Solomon Title: Vice President-Assistant Secretary ~~ Exhibit "~" JUW-24-10 09:33 FROh~- T-721 P.002/003 F-754 Al+FIDAVIT OF OILt1GINATYON ANn ASSIGNMENT OF POYtTFOLIO ACCO'CTNTS STr -TE OF NBVADA ) :SS. CC) :JNT'Y C}F CLARK ) I, Stuart Austin, being first duly sworn on oath or upon affirmation, depose and state that T srn the authorized Rgent and a custodian of records of HSBC Bank Nevada, N.A. and HSBC CRS d Serviccs [III) Inc,, that I am of legal age with full authority to make the statements contained herein, that I have personal knowledge of the following facts and that they are true and correct, at~d if called as a witness I could competently Testify to the matters stated herein as fa i 1 ows: 1. I am familiar with the books and records of HSBC Bank Nevada, N.A. and HSBC C,~.~d Services {III) Inc. regarding credit card accounts sold to Main Street Acquisition Corp, by HSBC Card Services (III} Inc, pursuant to a forward flow Receivables Purchase Agreement entered into on February 20, 2009 ("Agreement"). 't'hese records are kept in the ordinary course oi' a regularly conducted business activity and are made either by a person having personal In awledge of the information contained therein ar based on informarion conveyed by a person h:~ ring personal knowledge of th.e information contained therein, and I know from my experience in reviewing such records and from common knowledge of haw credit cards work that those re~:ords are made and maintained by individuals wha have a business duty to make entries in the rrrords accurately at ar near the time of the event that they record. 2. The records consist of electronic information that is generated, stored and n3 ~intained in accordance with generally accepted standards in the financial industries by individuals that possess the knowledge and training necessFUy to ensure the accuracy and reliability of the records. JUN-24-10 09:33 FROM- T-721 P.003/003 F-754 3. The business records furnished show that HSBC Baril:. Nevada, N.A, was the eni i ty which originated the original credit card accaunt contracts, or re-originated the credit card ac~:nunt contracts after purchase from another entity by reissuing the account with the same card number and notifying the account holder of satnz, for all of the credit card accounts which have be?n ar will be sold by HSBC Card Services (III} Inc. to Main Sired Acquisition Corp, wider the AI;~~eement; and that HSBC Bank Nevada, N.A. transferred all of its rights and interest in these accounts, and the records related thereto, to its affiliate HSBC Card Services (III} Tnc. on ar about the date of charge off of each such account, pursuant to an agreement between HSBC Bn~ik Nevada, N.A. and HSBC Card Services (III} Inc., as such charge off date is identified in the electronic business records of zach account which has been or will be transferred to Main Sweet Acquisition Corp., contemporaneously with the sale of each such account. pursuant to the al, ~eement between HSBC Bank Nevada, N.A. and HSBC Card Services (III) Inc. all charged off aca;ounts were transferred to HSBC Card Services (III) Inc. in the ordinary course of business. Further Affi~-nt sayeth not. 1:~~«ted this~~ ay of ;1t~~- , 20~. ll-1 SBC Bsink Nevada, N.A. HSBC Card Services (Iill} Inc. B',. ~ By:~ FbrintName• ~~Ir 7~"`ter ~" FrintName: _ ~~~ ~~"J ']'~tle: Vice president Title: Vice president ~~abseribed and sworn to before me an this ~~ day of . ~,..-L , , 20 t~ . My cg4nmission expires: J HfVA h}Ald. NOTARY pPpU8~1~.IC • STA7E OF NEVADA P OFCLARK AAY APPY. EX P• 07.411Y 1 1 } 17 of 74 VERIFICATION I, Demetrios H. Tsarouhis, Esquire, verify that the statements contained in the aforementioned COMPLAINT are true and correct based on my communications with my client. I make this verification because my client is unavailable to sign this document at this time. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Sec. 4904 relating to unsworn falsification to authorities. sy ~A,~r Demetrios H. Tsarouhis, Esquire Date: October 29, 2012 7 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION—LAW Main Street Acquisition Corp., Plaintiff V. XT71 No. 12-7858CivilTerm ry !j r;�) PETER SALVATORE, r Defendant . :. PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR TERMINATION TO THE PROTHONOTARY/CLERK OF SAID COURT: You are hereby authorized, empowered, and directed to enter, as indicated,the following on the records thereof: A. 1. ❑ The within suit is Settled, Discontinued, Ended and costs paid. 2. The within suit is Settled, Discontinued,Ended WITH Prejudice and costs paid. 3. ❑ The within suit is Settled, Discontinued, Ended WITHOUT Prejudice and costs paid. B. 1. ❑ Satisfaction of the Award in the within suit is acknowledged. 2. ❑ Satisfaction of Judgment,with interest and costs, in the within matter is acknowledged. C. ❑ Other: By: Demetrios H. Tsarouhis 21 S. 9th St. Allentown, PA 18102 Phone: (610) 628-2440 Fax: (610)465-8844 Date: March 15, 2013 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION-LAW Main Street Acquisition Corp., : Plaintiff . V. No. 12-7858CivilTerm PETER SALVATORE, Defendant ; • 120040.001 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the Praecipe has been served by United States first-class mail, postage prepaid, upon the individual(s) at the address indicated below: Clayton Morrow 304 Ross Street 7th Floor Pittsburgh PA 15219 y�-�- Demetrios H. Tsarouhis 21 S. 9th St. Allentown,PA 18102 Phone: (610) 628-2440 Fax: (610)465-8844 Date: March 15, 2013