HomeMy WebLinkAbout13-5428 MEMO MONEY ORDER COURT OF COMMON PLEAS,
ORDER COMPANY, INC. CUMBERLAND COUNTY
PLAINTIFF
V.
Effiom Archibong 5 2013
Individually, jointly and severally,
DEFENDANT ,p
No. - 5 q; l �'
and
Green City, Inc., doing business as
Destiny
Corporation
DEFENDANT
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the warrant of attorney, the original or a copy of
which is attached to the compliant filed in this action, I appear for the Defendants and
confess judgment in favor of the Plaintiff and against the Defendants as follows:
Principal: $ 18,501.50
Interest: $ 1,489.97
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Lost Fee Income: $ 723.22 - =
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Attorney Fees: $ 6,214.41
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Total: $ 26,929.10 i3 ' M
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Kevin utkins, Esq.
Attorney for Defendants
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MEMO MONEY ORDER COURT OF COMMON PLEAS,
ORDER COMPANY, INC. CUMBERLAND COUNTY
PLAINTIFF
V.
Effiom Archibong , 2013 ,
Individually, jointly and severally,
DEFENDANT
and cn — �
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Green City, Inc., doing business as
Destiny
Corporation y c ry
DEFENDANT
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COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY
COUNT I — CONFESSION OF JUDGMENT
(MEMO V. GREEN, ARCHIBONG)
1. Plaintiff is MEMO Money Order Company, Inc., hereinafter "MEMO "), a
Pennsylvania corporation wholly owned by Merchants Express Money Order Company, Inc.,
that engages in the issuance and sale of money orders and whose address is 1029 Mumma Road,
Wormleysburg, Pennsylvania, 17043.
2. Defendant Green City Inc., (hereinafter "Green "), is a corporation located at 2610
Walnut Hill Lane, Dallas, TX 75229, and doing business as Destiny.
3. Defendant Effiom Archibong (hereinafter "Archibong "), is an individual residing at
600 Breakers Point Court, Irving, TX 75063.
4. Defendants Archibong is the owner and/or operator of Defendant GREEN and
entered into the Trust Agreement on behalf of said Defendant GREEN and themselves on or
about August 22, 2011. A true and correct copy of the Trust Agreement under which Defendants
Archibong and GREEN are confessing judgment is attached hereto as Exhibit "A ".
5. Defendant Archibong, with the intent to induce MEMO to enter into a Trust
Agreement with Defendant GREEN, agreed to personally guaranty the obligations of Defendant
GREEN. A true and correct copy of the Personal Indemnity and Guaranty is incorporated into
and a part of the Trust Agreement under which Defendant Archibong is confessing judgment is
attached hereto as Exhibit "A ".
6. The forgoing judgment against Defendants Archibong and GREEN, is not being
entered by confession against a natural person in connection with a consumer credit transaction.
7. The Plaintiff has not assigned the Trust Agreement and Personal Indemnity and
Guaranty under which judgment is being confessed.
8. The Plaintiff has not entered judgment against Defendants in any jurisdiction for the
unpaid sum of $26,929.10 or any additional amount for a total of the debt demanded here.
9. The Defendants jointly and severally acted as selling agents for Plaintiff from
October 5, 2011 until February 22, 2013.
10. Pursuant to the Trust Agreement, Defendants are required to hold all monies received
by them from the sale of money orders, including money order fees (hereinafter "trust funds "),
separate and apart from other funds of the Defendant for collection by the Plaintiff through
electronic or other means.
11. The Plaintiff attempted to collect the trust funds from Defendants on July 8, 2013 and
July 23, 2013 through an Automated Clearing House (hereinafter "ACH ") method.
12. The Plaintiff, or its designated check - clearing banking center did not receive the
payment of the trust funds on January 17, 2013, January 23, 2013 and January 15, 2013, as
required by the Trust Agreement.
13. The failure of Plaintiff or its designated check - clearing banking center to receive trust
funds from the Defendant in accordance with the Trust Agreement constitutes an event of default
allowing Plaintiff to enter judgment against Defendants.
14. Pursuant to the Trust Agreement, the Plaintiff suffered damages by the Defendants
conduct as follows:
Principal: $ 18,501.50
Interest: $ 1,489.97
Lost Fee Income: $ 723.22
Attorney Fees: $ 6,214.41
Total: $ 26,929.10
15. The Defendants' most recent estimated 10 -week sales average equaled Ss- money
orders causing Plaintiff Lost Fee Income of $4,861.91 as a result of Defendants' default..
16. Plaintiff demands judgment in the aforementioned amount as authorized by the
Warrant of Attorney contained in the Trust Agreement attached hereto as Exhibit A.
17. The Warrant of Attorney contained in the Trust Agreement is less than twenty (20)
years old.
WHEREFORE, Plaintiff demands judgment in the amount of $26,929.10, as authorized by
the Warrant appearing in the attached Trust Agreement, together interest from the date of
judgment and costs.
COUNT II — BREACH OF CONTRACT
(MEMO V. GREEN, ARCHIBONG)
18. The averments set forth in paragraphs 1 through 17 are incorporated by reference as if
set forth in full herein.
19. Defendant Archibong signed the above referenced Trust Agreement, and the
documents appended thereto, on behalf of The GREEN.
20. Defendant Archibong also signed the above - reference Personal Indemnity and
Guaranty Agreement, pursuant to which he made himself personally liable for any default by
The GREEN under the Trust Agreement.
21. The failure of Archibong to remit the trust funds is a violation of the terms and
provisions of the Trust Agreement, and in addition, is a breach of the fiduciary relationship
created by the Trust Agreement.
WHEREFORE, Plaintiff demands judgment in the amount of $26,929.10, as authorized by
the Warrant appearing in the attached Trust Agreement, together interest from the date of
judgment and costs.
COUNT III — BREACH OF FIDUCUARY DUTY
(MEMO V. GREEN, ARCHIBONG)
22. The averments set forth in paragraphs 1 through 21 are incorporated by reference as if
set forth in full herein.
23. The Trust Agreement created fiduciary obligations owed by the Defendant to the
Plaintiff.
24. In breach of their fiduciary obligations, Defendant Archibong:
a. Failed to hold the trust finds in trust, as property of Plaintiff;
b. Deprived Plaintiff of the use and benefits of its money;
c. Failed to make the required payments or dispositions of trust funds to Plaintiff;
d. Commingled the trust funds with those of their own; and
e. Appropriated the trust funds for their own use and benefit, or elsewhere.
25. Defendant performed all of the above actins intentionally, willfully, maliciously, and
with wanton disregard for the rights of Plaintiff.
26. Defendant's actions, as enumerated above, constitute a breach of fiduciary duty to
Plaintiff under the laws of the Commonwealth of Pennsylvania and the terms of the Trust
Agreement.
WHEREFORE, Plaintiff demands judgment in the amount of $26,929.10, as authorized by
the Warrant appearing in the attached Trust Agreement, together interest from the date of
judgment and costs.
COUNT IV — CONVERSION
(MEMO V. GREEN, ARCHIBONG)
27. The averments set forth in paragraphs 1 through 26 are incorporated by reference as if
set forth in full herein.
28. Plaintiff avers, on information and belief, that Defendant Archibong converted the
trust funds owed Plaintiff to his own personal uses.
29. Defendant Archibong's personal use of the trust funds and thus his intentional
deprivation of the use and benefit of the trust funds properly due and owing Plaintiff, constitutes
conversion under the laws of the Commonwealth of Pennsylvania.
WHEREFORE, Plaintiff demands judgment in the amount of $26,929.10, as authorized by
the Warrant appearing in the attached Trust Agreement, together with interest from the date of
judgment and costs.
COUNT V — UNJUST ENRICHMENT
(MEMO v. GREEN, ARCHIBONG)
30. The averments set forth in paragraphs 1 through 30 are incorporated by reference as if
set forth in full herein.
31. Plaintiff avers, upon information and belief, that Defendant wrongfully retained the
trust funds.
32. Plaintiff conferred the benefit of the use of the money orders and other property upon
the Defendant and said Defendant appreciated, accepted and retained such benefits.
33. The Defendant's retention of the benefits conferred by Plaintiff without paying the
value of such benefits would be inequitable and unjust.
34. As a result of Defendant's retention of the trust funds and/or Plaintiff s other
property, Defendant has damaged Plaintiff while unjustly enriching himself in the amount set
forth above together with the value of the property retained, and the benefits conferred upon
Defendant as a result of the use of the money orders and property, plus interest and costs.
WHEREFORE, Plaintiff demands judgment in the amount of $26,929.10, as authorized by
the Warrant appearing in the attached Trust Agreement, together with interest from the date of
judgment and costs.
COUNT VI — CLAIM FOR POSSESSION OF PROPERTY AND TRUST FUNDS
(MEMO V. GREEN, ARCHIBONG)
35. The averments set forth in paragraphs 1 through 35 are incorporated by reference as if
set forth in full herein.
36. The Trust Agreement clearly states that all money orders and trust funds are
Plaintiff's property.
37. The terms of the Trust Agreement require the Defendant to segregate and hold apart,
all trust funds and/or proceeds from the sale of money orders.
38. The terms of the Trust Agreement clearly state that all non -trust funds and /or property
commingled with trust funds and/or proceeds are impressed with a trust for the Plaintiff's
benefit.
39. By operation of law, Plaintiff is the owner and Defendant is the trustee for all assets
so commingled.
40. Despite Plaintiff's demand for return of the trust funds and other property, Defendant
refused to remit the trust funds and other property impressed with a trust by operation of law to
Plaintiff in violation of the Trust Agreement.
WHEREFORE, Plaintiff demands judgment in the amount of $26,929.10, as authorized by
the Warrant appearing in the attached Trust Agreement, together interest from the date of
judgment and costs.
J
e ✓ vi � n ^ M.
5
Lutkins, Esq.
Attorney for Plaintiff
Attorney ID: 76859
Date:
VERIFICATION
The undersigned individual hereby states that he /she is an employee of Merchants
Express Money Order Company, Inc., with the authority to verify the statements contained in
the foregoing complaint involving MEMO Money 'Order Company; Inc., a wholly owned
subsidiary of Merchants Express Money Order Company, Inc., a Pennsylvania corporation.
The undersigned individual also states that the statements made in the aforementioned
complaint are true and correct to the best of his/her knowledge, information, and belief. The
undersigned understands that the statements therein are made subject to the penalties of 18
Pa. Cons. Stat. §4904 relating to unsworn falsifications to authorities.
David Bush
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MERCHANTS EXPRESS MONEY ORDER COMPANY, INC.
AND SUBSIDIARIES
1029 Mumma Rd, P.O. Box 8863 Camp Hill, PA 17001— 8863
(800) 922 — 8079 Fax (717) 214 — 5989
www.memoco.com
MONEY ORDERS Trustee Agreement for:
Corporation Name: Green City Inc
Store Name: Desti # of Locations:
Address: 2610 Walnut Hill Lane City: Dallas State: IX Zip Code: 75229
Telephone Nurnber: QU4 366 — 3734 / (469) -3945 Fax Number:
E-Mail Address: C" w ol 0 Website Address:
Legal Entity: 0 Corporation ❑ LLC ❑ Partnership ❑ Sole Proprietorship
Products: Money Orders,
ACH Report receipt method: 0 Fax: r � 6 Email: C6 A
Instructions: 0 4 d C'" "/
If you are an officer or the owner of 10% or more of the business you will need to sign at one i of the red
numbered signature areas on the Trust Agreement and the Electronic Funds Transfer. If married, your
spouse will need to sign at the corresponding blue numbered spouse signature areas, if not married please
notate by affixing N/A in the corresponding blue numbered spouse signature areas.
Please attach a voided check for the account MEMO or its designated representative will be drafting.
Please provide copies of photo ID's of all individuals who sign these documents.
If you have any questions please feel free to contact your sales representative or the Sales and
Marketing Department at (800) 922 — 8079.
FOR INTERNAL USE ONLY
MERCHANTS EXPRESS MONEY ORDER COMPANY, INC Money Orders Lead # 25087
MEMO MONEY ORDER COMPANY, INC.
MERCHANTS EXPRESS USA, INC.
MEMO MONEY ORDER COMPANY OF NEW YORK, INC.
BY Tnisbm #
Sales Representative RMn Hmnan Machine Type: VwFone — Electra
Date If Machine Type Is Electra: Stu printer? — Yes No
Send Manual To: Sales Rep _Warehouse
MERCHANTS EXPRESS MONEY ORDER COMPANY, INC., MEMO MONEY ORDER COMPANY, INC., MERCHANTS EXPRESS
USA, INC., MEMO MONEY ORDER COMPANY OF NEW YORK, INC., MONEY ORDER TRUST AGREEMENT
THIS TRUST AGREEMENT is made between MERCHANTS EXPRESS MONEY ORDER COMPANY, INC., MEMO MONEY ORDER COMPANY,
INC., MERCHANTS EXPRESS USA, INC., Pennsylvania Corporations or MEMO MONEY ORDER COMPANY OF NEW YORK INC., a New York
Corporation, or any subsidiary (Collectively `` MEMO'S and the individual(s) and /or entities identified below, hereafter referred to as Trustee(s).
In consideration of the mutual promises contained in this Trust Agreement and intending to be legally bound hereby, the parties agree as follows:
Recitals.
A h1Eh40 is engaged in the issuance and distribution of money orders and gift certificates (herein NENI0 products) through electronic Terminals.
B. Trustee desires to sell MEMO products utdizing an ekctmnic Temrinal pursuant to the terms of this Tmst Agreement
1. Trustee MEMO appoints Trustee to act as an agent of NIENIO at each of Trustee's retail establishments approved for the sale of hIFNfO products and that the relationship between the
Parties slid not constitute a partnership, joint venture or agency (other than as esPsssly descnbed herein). Nadler MEMO nor Trustee shall have the authority to make any statements,
representations or commitments of any kind, or take any action, which shall be binding on die other, without the prior written consent of the other Party. Trustee accepts such appointment in
accordance with the terms and conditions specified in dais Trust Agreement
2 Test Relationship. Tnmstee shall receive and hold in trust for MFAIO all blank money orders delivered to Trustee by XTAlO and all money received by Trustee form die sale of money
orders, including without limitation the money order fees established by MEMO from time to time ("trust funds'). Trustee shall hold the trust funds separate and apart from other funds of
Trustee. The failure of Trustee to hold trust funds separate and apart from any other funds of die Trustee shall, at the option of MEMO, be a breach of dais Agreement entitling i fE1\.10 to
immediate possession of arty Account or accounts into which funds received for money order sales from consumers have been deposited and such other ranedies, including termination of
this Agreement, as are provided for herein.
3. Materials Supplied by MEMO. For the sole purpose of selling MEMO products pursuant to dais Trust Agreement, MEMO will supply Trustee with the following.
A. An adequate supply of serially numbered blank money orders and /or gift certificates.
B. An agency installation kit containing the supplies and traiaingmaterial required to implement and maintain a MEMO agency relationship.
C. Equipment of the quality necessary to allow Trustee to execute all types of transactions gmvaned by die Trust Agreement The equipment MEMO will provide, includes, such
equipment that will imprint the money order and /or gift certifi dollarvalue and Trustee ID number fimily into the money order or gift certificate so as to inhibit die alteration of
such items. All equipment provided to Tmstee shall at all times continue to be die sole property of Is1EMO and shall not be removed from the Trustee's retail establishment where it
was originally installed by MEMO, unless approved by MEMO in writing. Any other equipment not owned by NIENIO and used by Trustee to sell MEMO products must be
approved by MEMO.
D. Regulatory postings, signs, posters, window decals and otherpmmotional materials, all of which Trustee agrees to display at all times, in a conspicuous location on die premises.
4. Right to an Accounting. Notwithstanding any other provision of this Trost Agreement, MEMO shall have the right, at all reasonable times, with or without notice, to access Trustee's
premises and to inspect and perform an accounting of, or cause its employees or agents to inspect and perform an accounting of, die cash receipts, fees, the accounting (sure) copies ofmoney
orders and gift certificates sold if applicable, daily sales reports, the Trustee's inventory of unissued money orders and /or gift certificates.. A ch arge - will be assessed against Tmstce to recover
esgpenses incurred by MEMO when an audit is conducted due to Trustee's breach of this Trust Agreement or if die audit discloses a breach.
5. Rules and Regulations. Trustee shall cc mply with the following miles and regulations.
A Trustee shall not sell or issue a I%T -\40 product until Trustee has collected a cash payment in an amount equal to the face amount of the sale or issuance of the N ENIO product plus
any additional amount detemhined by the retail fee except as otherwise set fords herein. Trustee will only accept cash as payment for all AIFXIO products. No check or other paper
transmitted or deposited by Tmstte to or for MEMO shall constitute a remittanc to NIENIO until actually collected NT.NIO has the option in tads case to deposit any such paper for
collection.
B. Tmstee slid safeguard all unissued inventories of all products and MEMO provided equipment with the highest degree of care. The care exercised in regard to MEMO products shall
be at least as that applicable to cash. Trustee shall report to hl XfO die serial number of each money order stolen or missing and all other information relating to the event,
immediately upon discovery of the fact, but in any event not later than twenty -four (24) hours prior to the money orders being presented for payment to XIEbIO so that payment can
be stopped on such missing or stolen money orders. Such report shall be by telephone and immediately confirmed in writing. Trustee shall be solely responsible for all losses arising
from, and shall indemnify and hold MEMO Ihamiless regarding any and all stolen or missing items as well as any MEMO equipment issued to Trustee. Furthermore, Trustee shall be,
responsible for repair or replacement of any \EMO issued equipment stolen or damaged as a result of misuse, negligence, abuse, fire or otherwise. Said responsibility and liability of
Trustee shall not be limited by Tnmstee's compliance with the safeguarding, care, and reporting obligations set forth in this paragraph
C. Trustee shall at all times maintain a sound financial position and provide current financial infommation to All XT IO as requested by ?EEMO. Trustee shall conduct operations so that die
funds generated from die sale or issuance of money orders and /or gift certificates, will not be in jeopardy nor seem in the opinion of a reasonable person to be in jeopardy. Trustee shall
cease the issuance and sale of money orders and /or, gift certificates and notify NIEN10 immediately, should such jeopardy arise. Notification to MEMO shall be made promptly by
telephone and immediately confirmed in writing. "Sound Financial Condition" shall mean that there has been no material adverse change in the business, operators, condition
(financial or otherwise) or prospects of the Trustee and that neither Trustee or any Guarantor has became insolvent, g7nendly unable to pay its debts as they become due, invohintatily
suspended transaction of its business, made a general assignment for the benefit of creditors, instituted a proceeding described in Paragraph 7B or consented to any such order for relief
any appointment or to the taking of possession by any such official of all or any substantial part of its property, declaration, fording or relief descobed therein, whether or not any such
proceeding is instituted, or has taken any action in furtherance of any of the foregoing. A lack of sound financial condition shall also include when Trustee fads to pay, on the date which
the same is due, any sum payable hereunder or fails to pay its creditors generally or makes representations to MEMO or to other creditors that it must delay any such payment under
conditions which, in die sole discretion of MEMO, it appears that Trustee is no longer in a. sound financial condition.
D. Trustee shall provide MEMO by facsimile transmittal or registered mail 30 days advance notice of proposed change (s) in the ownership of either Trustee's business,
the management of Trustee's business, the sale of fifty -one percent (51 %) or more of Trustee's assets, or the entry into or termination of business affiliated with
Trustee. Transactions included within this paragraph 5(D) include transfer of stock of Trustees, sale of partnership, interests, Limited Liability Company or
partnership's interest or any similar transaction which effects a change in ownership or control of Trustee. No such transaction shall be approved until any successor
entity, if any, has entered into appropriate documentation, including a trust agreement with MEMO. No transaction, discussed in dais subparagraph, shall be effective
without the prior written approval of XMXIO. Any attempt by Trustee to effect such a transaction without MEMO approval shall be void ab initio as to MEMO. If
Trustee fails to give such notification, Trustee, as well as its successor, shall remain liable for the payment of all sums and the performance of all duties required by the
Trust Agreement Any change of ownership or other assignment within the meaning of this paragraph shall bind Trustee's successor or assignee to the terms and
conditions of this Trust Agreement
E. During the tern of this Trust Agreement including any renewals hereof, Trustee shall sell only MEMO products at all of Trustee's retail establishments including those newly opened or
acquired. Trustee must provide NIEh10 with at least 30 days notice of its intent to close its business operations or currant retail location and to reopen at another location. Trustee shall
notutilize NIENIO equipment for any otherpumpose dean sellingblEMO products.
F. Trustee shall sell MEMO products only at Trustee's specifically approved places of business or future place of business as approved by NIEN40. Trustee shall not appoint and /or offer
the services at or to any entity not a party to this Trost Agreement
G. Trustee must stand ready to complete all transactions co tinplated by this Trust Agreement at all times when the Trustte's business is open. Failure to do so shall constitute a bmacn of
this Trust Agreement No funds received by Trustee shall be subject to attachment, levy of execution, or sequestration by order of any court except for die benefit of MEMO.
R Trustee is prohibited from unauthorized use of MEAIO's name, logo, trademark and /or service mars; without NIEMO's prior written consent
I. No NIE?v10 products shall be issued or sold to anyone in payment of any obligation of Trustee, owner or guarantor or used in any manner for Trustee, owner or guarantees own
purposes, except as allowed by M,MNIO.
1. Trustee shall sell money orders in strict nu maical sequence in accordance with the number printed on each blank money order. The face amount of any money order sold by Trustee
shall not exceed die sum of S 1000.00 . NIFNIO may deliver blank money orders to Trustee, or to any agent, employee or representative of Trustee, by whatever means
MEMO deems appropriate, and MEMO is authorized to receive and issue a receipt for blank money orrle s 6n behalf of Trustee, AR voided money orders must be voided through the
electronic money order dispenser during the sale date only to avoid charges to Trustee's account If a voided money order is not voided in the money order dispenser, Trustee shall
write, "NOT USED FOR PURPOSE INTENDED" on the backside of the original money order and deposit the money order into Trustee's bank Account If Trustee should
write `void" on the face of the original money order, Trustee shall forward the original voided money order to the'MEMO office and MEMO will issue a refund in Trustee in the form
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MEMO MONEY ORDER COURT OF COMMON PLEAS,
ORDER COMPANY, INC. CUMBERLAND COUNTY
PLAINTIFF
V.
,
Effiom Archibong � 2013 �
Individually, jointly and severally, rri00 `n =r' -
DEFENDANT te rn
No. 3 -0
r
ar%
and
Green City, Inc., doing business as
D =K
Destiny
Corporation
DEFENDANT
AFFIDAVIT OF NON - MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA SS:
COUNTY OF CUMBERLAND
The undersigned being duly sworn according to law, deposes and states that he is an
employee of Merchants Express Money Order Company, Inc., with the authority to make this
Affidavit on behalf of the Plaintiff, MEMO Money Order Company, Inc. The undersigned also
states that to the best of my knowledge, information, and belief, the Defendants are not in the
Military or Naval Service of the United States or its llies, or otherwise within the provisions of
the Soldiers' and Sailors' Civil Relief Act of Congr s 1940 a amende .
David Bush
SWORN to and subscribed
before this
day of �' 2013.
: OMMONWEALTH OF PENNSYLVANIA
SEAL
Notary Public THERESA N
SMITH, Notary Public
dormleysburg Scro, Cumberland County
.".y Ccmmissicn Expire, Jar:: 12, 2017
MEMO MONEY ORDER COURT OF COMMON PLEAS,
ORDER COMPANY, INC. CUMBERLAND COUNTY
PLAINTIFF
V.
•
Effiom Archibong 92013
Individually, jointly and severally,
DEFENDANT
: No.
and C:
Green City, Inc., doing business as -0=
=M i—
Destinyc
En
Corporation
DEFENDANT
AFFIDAVIT OF ADDRESSES } F
SS: =-
COMMONWEALTH OF PENNSYLVANIA _
COUNTY OF CUMBERLAND
The undersigned being duly sworn according to law, deposes and states that he is an
employee of Merchants Express Money Order Company, Inc., with the authority to make this
Affidavit on behalf of the Plaintiff, MEMO Money Order Company, Inc. The undersigned also
states that the address of the Plaintiff is: 1029 Mumma Road, Wormleysburg, Pennsylvania,
17043 and that the addresses of the Defendants are as follows:
Green City Inc. Effiom Archibong
2610 Walnut Hill Lane 600 Breaker Point Court
Dallas, TX 75229 Irving, TX 75063
David Bush
SWORN to and subsc ed
before , ,
day of , 2013 COM MONWEALTH OF PE NNSYLVANIA
NOTARIAL SEAL
THERESA H. SMITH, Notary Public
Wormleysburg Boro, Cumberland County
Qotary Public My Commission Expires June 12, 2017
MEMO MONEY QRDER COMPANY,
INC.
PLAINTIFF,
V.
EFFIOM ARCHIBONG, Individually
and severally
and
GREEN CITY, INC. dba DESTINY
CORPORATION
DEFENDANTS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 13-5428
RELEASE AND SATISFACTION OF JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, MEMO Money Order Company, Inc. ("Plaintiff'), and files this Release
and Satisfaction of Judgment.
Plaintiff would show the Court that the judgment in this case has been fully paid and
satisfied.
Respectfully submitted,
JACKSON WALKER LLP
100 Congress Avenue, Suite 1100
Austin, Texas 78701
(512) 236-2000 — Main Telephone
(512) 236-2002 — Main Facsimile
www.jw.com
By: � I
e fer F. Wert
ate Bar No. 24072822
(512) 236-2247 — Direct Dial
(512) 391-2147 — Direct Fax
Email: jwertz)jw.com
ATTORNEYS FOR PLAINTIFF
I Nor
CERTIFICATE OF SERVICE
I hereby certify that on the 10th day of October 2014, a true and correct copy of the
foregoing was served via regular and certified mail, return receipt requested upon the following:
Effiom Archibong
2129 W. Northwest Hwy.
Dallas, Texas 75220
Green City, Inc. d/b/a Destiny Corporation
2129 W. Northwest Hwy.
Dallas, Texas 75220
Kenneth S. Harter
1620 Belt Line Rd.
Carrollton, Texas 75006-6309
11407133v.1 124284/00010