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Home My WebLink About14-5772 F �o6S"Sgvo Supreme Coj, ennsylvania t � �� f' a COu^ m O v leas For Prothonotary Use Only: J ch, �• , s Docket No: County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S 0 Complaint 0 Writ of Summons ® Petition 0 Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiffs Name: Lead Defendant's Name: PQ T FIRSTLEASE, INC., 4.„A -7-1-,.'�+aft V 5ivar:,o Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? [D Yes 0 No (check one) Doutside arbitration limits O N Is this a Class Action Suit? 0 Yes x..; No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff/Appellant's Attorney: WILLIAM T. MOLCZAN, ESQUIRE ' Check here if you have no attorney(are a Self-Represented (Pro Sel Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection:Credit Card 0 Board of Assessment 0 Motor Vehicle Debt Collection:Other Board of Elections Nuisance Dept.of Transportation Premises Liability Statutory Appeal:Other S 0 Product Liability(does not include C� Employment Dispute: E mass tort) Slander/Libel/Defamation Discrimination C 0 Other: _ Employment Dispute:Other Zoning Board ` T 0 Other: I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 4 0 Toxic Tort-DES 0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 0 Other: i0- Ejectment 0 Common Law/Statutory Arbitration B 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent Mandamus Landlord/Tenant Dispute 0 Non-Domestic Relations Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 0 Quo Warranto 0 Dental Partition 0 Replevin r 0 Legal � 0 Quiet Title 0 Other: 0 Medical 0 Other: REPLEVIN TWO COUNTS O Other Professional: Updated 1/1/2011 GF THE 2014 OCT /+ p ;l�,, , .� � r t� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC. 7 - Plaintiff No. vs. COMPLAINT IN REPLEVIN CENTRAL PA FAMILY FUN CENTERS, INC. TIMOTHY SEVERINO Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG& REIS CO., L.P.A. 436 Seventh Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR#20655800 0-a � � ��l-7 yV IN THE COURT OF COMMON'PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC. Plaintiff vs. Civil Action No. CENTRAL PA FAMILY FUN CENTERS, INC. TIMOTHY SEVERINO Defendants COMPLAINT IN REPLEVIN AND 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 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. OF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COUNT I - REPLEVIN 1. Plaintiff is a corporation having offices in 1300 Virginia Drive, Suite 450, Fort Washington, PA 19034. 2. Defendant, Central PA Family Fun Centers, Inc., is a Pennsylvania corporation with a last known principal place of business located at 1419 Wellgate Lane, Mechanicsburg, PA 17055. 3. Defendant, Timothy Severino, is an adult individual residing at 1419 Wellgate Lane,J Mechanicsburg, PA 17055. 4. On or about November 21, 2013, Defendants entered into an equipment lease (hereinafter referred to as the"Agreement") for the lease of equipment as follows: Price is Right 6-Player, Serial Number PEF11#0102 Terminator 42" Fixed Gun, Serial Number 1035 A true and correct copy of the Agreement is attached hereto, marked as Exhibit "1" and made a part hereof. 5. By the terms of the Agreement, Defendants were to make Forty-Eight (48)payments of $657.35. 6. The terms of said Agreement provide for termination upon satisfaction by Defendants of all obligations provided thereunder and upon the return of the equipment by Defendants to Plaintiff at the end of the lease term, which term would end Forty-Eight (48) months after it commenced. 7. Defendants is in default of the terms and conditions of the Agreement because Defendants have failed to make the required monthly payments. 8. Defendants have made partial payment under the Agreement leaving an unpaid balance in the amount of$29,219.20 as of July 15, 2014. 9. Plaintiff is entitled to immediate possession of said equipment in which Plaintiff holds a security interest in by virtue of Defendant's default. 10. Plaintiff has performed all conditions precedent as holder of all right, title and interest in the collateral, but Defendants wrongfully remain in possession of the equipment at the above-stated address. 11. Under the terms of the Agreement, Defendants have undertaken to pay to Plaintiff its reasonable attorneys' fees and costs of retaking possession of the collateral. WHEREFORE, Plaintiff prays for Judgment against Defendants, Central PA Family Fun Centers, Inc. and Timothy Severino, in Count I of this Complaint In Replevin, for possession of the equipment, more particularly identified as: Price is Right 6-Player, Serial Number PEF11#0102 Terminator 42" Fixed Gun, Serial Number 1035 COUNT II ACTION IN CONTRACT FOR IN PERSONAM DAMAGES 12. Plaintiff incorporates herein by reference thereto each of the preceding paragraphs of this Complaint in their entirety as if the same were more fully set forth herein. 13. In the alternative to Count I, Plaintiff pleads an action in contract as a result of Defendants' default for the accelerated balance due under the Agreement in the amount of$29,219.20. 14. Under the terms of the Agreement, Plaintiff is entitled to recover reasonable attorneys' fees and costs of retaking possession of the collateral. WHEREFORE, Plaintiff prays for the entry of Judgment on Count II against Defendants, Central PA Family Fun Centers, Inc. and Timothy Severino, in the amount of$29,219.20, plus reasonable attorney's fees, expenses for retaking possession, and costs. WELTMAN, WEINBERG AND REIS, CO. L.P.A. William T. Molczan, Esqu' e PA I.D. #47437 WELTMAN, WEINBERG&REIS CO., L.P.A. 436 Seventh Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR#:20655800 Effective Dale. r Contract No.: CV W5 ® Equipment FlnDnce Agreement i 1300 Virginia aDrive,x:2 Suite 4$0, Fort Washington, nli 19034 e.com Phone:866-A93-4778• Fax;215 283-3870.�w,nv.tirsiteaseonline.com Full Legal Name of 00blor Tax ID d: Central PA(otnoity run Centers I= Contact Name E•Mnl; Phone a: TIMOTHYSEVERINO TIM.SEVERIN010GiVUL.CO14 (7171700.3520 OddngAddtassr City Slot* 7Jp 1419%blipoletone lAcchantscburp PA 17055 Equipment Vandor(Supplier H onto indualdes TERMSAND CONDITIONS.PLEASE READ CAREFULLY 811FORE SIGNING Quantity I MAUE.MODEL,FIATURES SFJtIALNUtADEft See Ec ulpmentScitedule'A"AtlachadHctoloAndMadeAPartHereof Equipmenitowllarl(IfdiAarenlalonORMpAddreis] 4011Y Stale Xip Ui9trttillpatatana MECt(ANICSaURG PA 17oss TERM BILLING FREQUENCY PAYMENTAMOUNT ADVANCE PAYMENT (mollths) llnchtdas Applicable Taxes) [] �] Advance Payment(s) 51 Monthly QuartorY ScoVadobla Payment Dovm Payment $O.OD [] Other - bon and UCC Fee 599.00 fOTAt amount due at signing $99,00 1,, Agreement. This Is an Equipment Finance Agreement beNjecn Debtor (referred to throughout this Agreement as *Debtor", 'You' and 'Your") and MILeaso, Inc. (referred to throughout this Agreement as 'Cmditof', 'Payee, 'Us', 'We or"Our. This Agreement may be signed In counlrrpofts, You agree that a facsimile copy of this Agroemontv4111 a focstmlle 01Your signature may be treated as an original and will be admissible as the best evidence of the Agreement R Payments. You want to acquire The above equipment from the above vendor. You Want us to (nama the purchase of the equipment for you. Payments are due monthly, on the scheduled duo dale, the first scheduled dua data to be approximaldly Thirty (30) days after the Effective pole, Payments under this Agrcomont at* unaondlifanal and Will continue for the entire Term. You agree to pay art interim rental.payment In on amount not to exceed one-Ulinleth (1r301t) of the Payment for each day from and Inaluding the Efroctiva pale unill the day preceding the PrA scheduled Payment Tim* is of Iho essence with rospect to each and every Payment and ivith respect to pedbfmanea of any and ag other obligations owing to Vs under this Agreement If any Payment due,under this Agreement Is not retelvad by Ua within Ave (b)days of when the same comes dua,You shall pay to Ut(a)the overdue payment and (b)a late charge of 15%of the overdue Instillment or twenty Ave dollars (325.00). whichever is greater. Lola charges may he assessed to the maximum Emits allowed by 12111.You afrco to pay Us a charas of 550 1(any payment made Is dishonored or returned. 9. Non•Cancoltobla; Supplier not an Anent THIS AGREEMENT IS NON•CANCELtABLE. Thts Agteamont is Irrevocable and may not be cancelled, terminated or revohod by Debtor during the term hereof for any reason. We ate not totaled to the Supplier and We cannot act at refund, nor Is the Supplier allowed to walvo or modify any(arm of this Allmoment.Neither the Supplier nor any of their solosmam,employees orOther agentsisOut signal. 4. Security interest, You understand and agree that We are the secured party and not owner regarding the Equipment listed above. As security for the indebtedness evidenced by this Agreement and all of Your other Indebtedness, flabtiriea and obilgations to UN of any oatore whatsoever, whether dlrec% Indbaet, contingent, pdmary. secondary, alone, Joint with arty other person, due, to become due, advanced to the future, now existing, hereafter created, pdacipal. Interest, expensa payments, onrorcamont and liquidation costs,andfor altomaye fees and expenses,You hereby grant to Us a lion and secudty interest in the oqufpment(isled above, S, No Warranties. YOU ARE PURCKASING THE EQUIPMENT IN AS 1S7 CONDITION. We did not manufacture IL You chase the Equipment and Supplier based on Your Judameni. You may contact the Supplier for a statement of the w0mintrs, if any, that the manufacturar or Supplier Is providlog. WE MAKE NO WARRANTIES EXPRESS OR IMPLIED. INCLUDING THE WARRANTIES OF MERCtfANTABILITY OR FITNESS FOR A PART(CUTAR PURPOSE, You must Settle any disputo regarding the parfoRmrlce of ilia equipment with the supplier. You am imponsl bid for tnsla]iation and all service of the equipment. The. Equipment also includes all Present and fvlum altz6hracnts, accessories, aubSOUtions and replacements To or for-tha foregoing, as well as all proceeds and products of Na foregoing, including, i without llmitallon,Insurance pioceedsand condemnation awards. i VilrAgroomonllsnotbfndln u1 1e g dbyCradiloa ouesrtlfylhat all actions requlrodtoauthodxsthe execution ofthisAarsement.including youraulbatfty,have boonfulfillod, f, A 'Atilhodred Sipnaltue:X Print Sipnar Namo: Timothy Sovedna Slanor'nita: Pros dent Oat*Slfnod: GUARANTY The ondoWlined petsonolly guarantees that Debtor tvil maka an payments and other ahbmeo required under thls Agreement when they are dua and wgt perform all ocher abtitiattons under this Agreement. The undersigned tvalves any noltrralion of default and consents to any extensions and modifications.fronted to Iho Debtor. The underslened agrees Ilial INa do not have to proceed againd the Debtor,Equipment at other Guarantors, in the event of a default Ilia undersigned tv10 Immediately pay to accordance viidr cur detaull.providon of INs Agreament and all aalfms na*undrr die tem or It Afreament.lndudmD reasonobla attomcy's fees. the undersigned consents to petconot(wlsdiction, venue,c oica of lavr and Jury hlalwoWarosrllntehtfrNySpldomds. Signed:X / �1 Print Nome: Timethy Saverine Date: t r f Signed:X((( Pmt Homo., 00110: r DEI.IVPRYAHOACCEPTANCE RECEIPT Debtor hereby ocknowledom delivery and acceptance of the above Equipment on ilio date Indlwted below. Debtor does heteby corilly to Creditor that•(a)at Equipment requested and 'listed abovo has boon detiverod: (b)that Debtor has fully Inspected and examined the Equipment; (c]the Equipment is in full compli2rrce with the above dbSeQpdom(d)Ilia Equipment Ts In good operating wnditlan and repair,and (e)The Equipment t01 be used exclustvaly for business purposes. creditor may,from time to time in Its colo discretion,us pod of an audit function, geek vedficatton of the Debtor's receipt and acceplance of Ilia Equipment by eonducling telephone vedQcation vAlh Debtor. During Stith telophone vedneallon, Geaaor shag, s among other things,vcAV inn Debtor's Identity by confirmation of Debtors social ateudty number,federal Idenlircallon number or olher pncilcai means,as applicable,and Shall connan j delivery. inspection and acceptance a[ uta Equipment. 0E01OR FULLY AND FINALLY ACCEPTS THE EQUIPMENT AM) AUTHORIZES PAYMENT BY CREOITOR TO THE SUPPLIER OVITIE EQUIP MEtiT. Dale or0eirvery U(/S� Slgnaly :X r Title: Prcadent 4mclhy vcd'n -- INTERNAL ACCEPTED THIM. President Date: USEONLY FIRSTLEASE.INC. !1 Uf EXHIEHT 1 Effoctive Dato: .. F Contract No.: c`d to 5 B. Covenants. Until payment in full of ON Obligations You will;(a)COMM With 011 apPi1e3111e laws, !otos,regulations and decrees, a Nolattoru or which may have a material adverse elect on Your business,operations or financial condition, and obtain any permits or licenses requited by any such law, rule, regulation or decree; (b) pay when due all taxes and assessments upon You or upon Your Income,profits or property; (c)promptly Polity Us of the occurrence of any default or any Overt!, development or circumstance Which might materially adversely affect Your business,operations or rinandal condalon;(d)Ir You purport to be b corporation,limited flabflity company or similar cnilly,maintain Your corporate existence In good stantfing. 7. Equipment 030: Location and Sorvlce, YOU CERTIFY THAT THIS IS A COMMERCIAL TRANSACTION AND THAT TILE PROCEEDS OF THIS AGREEMENT ARE TO BB USED IN THE OPERATION OF A BUSINESS, Until payment In full of all Obligations You Will;(a)permit Us or Our agent to Inspect and examine the Equipment or any of Your records pertaining to the Equipment at any reasonable time and tram time to lime without Pollee; (b) not permil to exist any Ren or security Interest upon the Equipment of any natura whalsoover other than Iiia lien created by this Agreement; (e)at Your expense,defend U04 to the Equipment; (d)deliver to Us any documents.Including executed financing statements,live may require In onlor to perfect and maintain perfected Our first Ren on the Equipment, and pay all costs totaling thereto, including, without Ilmllollon, teeaonable otlornays' teas and expenses, filing fees and recordation loxes;(0)not sell, lease,transfer or otherwi3o dispose of any of the Equipment without Out prior written censonv and (Q keep the Equipment at the location(s)set forth In this Agreement end nor move any of iho Equlpmonl whhout Our pdorwrilten consent. 9. toss; Damage:insurance. You agree to maintain the Equipment In good condition and to make, at Your expense, all ropaks. renewals and replacements necessary to maintain the Equipment in goad condition and will not permit anything to be done that may impair the value of the Equipment or the security intended(o be afforded by this Agreement You shall, at all times during this Agreement, (0)bear the risk of toss, (holt,destruction, and damage of the Equipment or any potion thereof from any Cause Whe160ewer, (b) keep the Equipment Insured against all risks of damage and lose in an amount equal to its replacement cost,with Us homed os $olo 'toss payee ' You aholl provide Us with evidence of such Insurance containing other terns acceptable to Us ('Insurance Proof Within 30 days of(Ile Effective Data. We may require you la cony liability Insurance covering bodiy injury arid property damage, in an amount acceptable to Us,v4lh Us named as•'addlgonai Insured: if you fan to provide Insurance Prod,or it such ln3wanca for ilmilas for any reason,then ()We have the right,but not(he obllgotion, to obtain such Insurance In such forms and amounts from an Insurer of Our choosing ('Other Insvraneo'),and 01) You agree to pay a periodic charilo for such Other Insurance. This periodic chorgo will Include reimbursement for premiums advanced by Us, billing and tracking (ecu, charges for Our processing'and related fees, and a finoncs charge of up to 10% per annum(or the maximum allowed by low.If less)on any advances We make for premiums (collectively, the'In3urunce Chargol. Wo ondfor one or more of our affiliates andlar agents may receive a portion of the insurance Charge,which may Include,a proliL Vve arc not obligated(o oblaln,and may cancel,Other Insurance at any limo without notice to You, Any Other Insurance need not name You as an Insured or protect Your Interests,The Insurance Charge may be higher then the cast to You If You obtained Insurance on Your own. 9. Taxes. You must pay directly all taxes Including but not limited to &alas, use, property and other taxes (and any ponatt es),which may now or horoartor may be Imposed by any governmental body or agency totaling to this Agreement and the ownership, lensing, rental, sale, purchase, possession or use of Ilio Equipment excluding however, all taxes on or measured by the not Income of Crociltor. 10.ASSIGNMENT You shall not lease, lend, sell, assign, transfer(by operation of law or o(hcrwiso) or grant a smelly interest in all or any part of Its interest in the Equipment or this Agreement without the prior express written oonsOnl of Creditor. Creditor may lend, sell,assign,transfer or grant a security interest in ail or part of Its rights, obligations,title or Interest In the Equipment or this Agreement er any amount payable under this Agreement, without Pollee to Debtor. This Agreement is binding upon the parties hereto, their respective agents, Successors,legal reptesenlatives and permitted assigns. 11, UCC FILINGS. You hereby authorize Us to m0 a copy or this Agreement as a financing statement and appoint Us and Our agents as my attorney 4n-fact to execute and filo,on Your behalf, Rnancing statements covering the Security which Short be suffiden) as a financing statement under Iho Uniform Commercial Code, plus any amendments thereto and to sign on Your bohat(any other timmonts needed to confirm,establish,reestablish,continue,paned,protect or Insure Our Interest In the Security. 12, Indemnity.You agree to indemNry and hold Us, Our successors and assigns harmless from all flabliffes, obligations, losses,dombgas and Claims and al costs and expenses thereof (including legal ress and expenses) of arw kind misting to or arising out of the Equipment, Including, wllhout Grtdiallon, the monufacturo, purchase, tease, ownership,delivery,installation, malnienanco, possession, operation, condition, storage, return or use of the £yulpment howsoever sitting. The provisions of this porogmph shall Survive the oxpimUon or torminallon of !Itis Agreement. 13. Notices. Any notice required to be given pursuant to this Agreement shall be In writing and sant by coriglod moll or notionally reeog ozed overnight couder sa;iCia with confirmed delivery to the party's principal placo of buslnoss designated homin,or to such other addiess as the potty shag designate In writing(o the other party,and shall be effective as of iho third business day after date of mailing or thu data of ranfimad delivery. 14.Validity.'This Agreement contains the onlim undotstaading of the parties and may not be modlRod or waived except by an ogracmont In writing,Signed by the parties hereto. No delay or failure on Our part to Insist upon strict porrornancat of any form or Condition of this Agreement or to exercise any right or remedy oholl operate as a waiver or any such term or condition or of any broach thereof or produdo Us from exorcising any such right or ramedy at any later time. All covenants, agreements,representations and wommIlas made herein shall centimre In full(arca and effect un18 the repayment in full of all ObilgaUoru,and whenever In this Agreement You or VWls are referred to.Such roforanfxcr ahol be deemed to Include the successors and assigns of such parry. If any poillon of this Agreement Is round to be Invalid or unanforcoobio, Such invalidity or unerdoreaabilly shag not affect the remaWng pat9ons of this AgmomenL which shag ram la In full force and effect and to this and lh03O provlslone arc doemod sevorabre. 15. Default. You Shag be In dofbufl of this Agreement upon the occurrence of any one of the following (Evenl of Defaull): (a)You fall to pay when duo any payments required by tits Agreement;(b)You fail-to obtain and maintain any Insurance required pursuant to this Agreement; (c)You or any guarantor of this Agreement ('Guatantmq fogs to perform or observe any provision,covenant or condition under thts Agreement any Guaranty, or any other agreement You or Guarul(or may have with Us; (d) a petition Is fled by You or Guarantor under any bankruptcy,insolvency,receivership or similar proceeding.You or Guarantor makes an assignment for(he bonefit of crodltore or is otherwise unable to pay Its debts as they become duo; (0) o petition Is flied against You or Guarantor under any bankruptcy, Insolvency,receivership or similar proceeding whleh Is not dismissed Within alidy (60)days of the date of filing: (Q any representation or warranty or credit InfolmaWn provided by You or Guarantor to Ua Is Incorrect In any material ro3poQ (g)'You or Guarantor winds up,dissolves or otherwise f MIfnales 113 business.consolidates or merges with another entity,or sells,leases or othavdso transfers al or substantially all of Its assets to any entity: (h) Uta EquipmOal or any of Your property Is attached,satzod,levied or executed upon of Is cubjeot to any judgmant wit or warrant; (Q You make or poring,any unauthorized assignment or transfer of this Agreement,the Equipment or any(Mores!therein; 0)there Is a default with respect to any gunronly executed by Guarantor in connection with this Agreement;or (k)We deem ourselves insecure due to any chongo In Your business,manner of operation or financial condition. 18. Romodlea.The occuffenca of an Event of Default by You relating to this Agreement shall engUo Us to exercise the rights and remedies se(forth below. The oxerrJse of any one or more of cuch remedies shot!not preclude Us from any other remedles available to Us under this Agreement. Upon the occurrence of any Event of Default We may;(a)without COhnl order or prior notice, enter any promises where the Equipment Is located and disconnect, tic-knstoO and repossess any or on or the Equipment or randor the Equipment unusable,without Rabillty la You for any demeges oaasioned by such actions: (b)sol or olhoryAso dlsposo of any or al of the Equlpmant at publb or private solo,wllh or without notice,adveftisemom or publication, or may use,hold or keep the Equipment; (c)charge you interest on all monlos duo at the rate of 111%per annum or the highest rate permilted by law from the data of default (d)declare Immodfa(ely due and payable ell sums due'and to bacomo duo for the fug romatnlno term; (o)with or without tarminaung this Agreement,recover from You damages, not as a penalty, but horotn liquidated for all purposes and In on amount equal to the sum of (Q any accrued and unpold payments as of the dale of entry,of judgment in favor of Us plus fate dhnigea and all other sums that may aewo hereunder, (10 the present value of el,unpold future payments roserved in the Agreement and contracted to be paid over the unexpired term discounted at o rate equal to the discount rate of the Federal Reserve Bank of Philadelphia as of the dale of entry of judgment In favor of Us plus aria percent (195),and (Il) all commerdogy reasonable costa entl expenses Incurred by Us in any repossession, recovery, storage, repair, 3010, ra•loaso or other disposition of (he Equipment Including reasonable oitomey*V fees of twenty percent (2015)but in no event toss than one thousand dollars (51.000.00), and costs incurred In connection therewith or olhcnvho resulting from Your defeull (induslve or fees of wyection agencies, overnight dellv6ry charges,.codified moll costs, long distance telephone charges and ago Inepactions and other costs Incurred In the Collection of the balance due): and (Q exerelso any other right or remedy which may be available under any other applicable taw.No remedy referred to in this Paragraph Is Intended to be oxdusNo,but shall be cumulative and in oddIII0 to any other remedy referred to above or othonvlso available to Us in low or In equity,by statute or o(herwisa and may be exercised or enforced concurrently therawiih or tram lime to limo, — 17. Law and Jurisdtc0on. You acknowledgo and agree that (his Agreement coos negotiated, accepted and executed In Montgomery County, Pennsylvanle, Accordingly, this Agreement and the rights and duties of the partios hereunder Shap be governed by and construed pursuant to Pennsylvania law. NI disputes arising out of this Agreement shall be,at Our option , subject to the exclusive judadlctfort and venuo of the Court Of Common Pieas of Montgomery County or the United Slates District Court for the Eastern District of Pennsylvania, and the parties consent to the personal and exck131Ve jurisdlctlon of those courts. You further waive any objections You may Ihavo as to proper vonue or forum non.convenience or similar claims wllh respect to the Jurisdiction and Vanua of such courts. 18. Waiver of Jury Trial, YOU HERCDY WAIVE TRIAL BY JURY IN ANY ACTION OR PROCEEDING TO WHICH THE CREDITOR AND DEBTOR MAY BE PARTIES ARISING OUT OF OR IN ANY WAY PERTAINING TO THIS AGREEMENT. '(his waiver Is knowingly, willingly and voluntarily made by You and You hereby acknowledge Ural no representation of fact or opinion has been made by Us to Induce this waiver of trial by jury or In any way to modify or nullify Its effect. You further acknowlodge that You have boon mprosanted In the signing of this Agreement and waiver by independent legal counsel, selected of Your own two will, and that You have had (he opportunity to discuss this waiver with counsal,or have voluntarily waived such right. Page 2 of 2 Equipment Schedule A Contract No.do 19-6_ To: FirstLease,Inc. From: Central PA family Fun Centers,Inc. This schedule is attached to and made a.part of the above-referenced Contract. Description: (1)Price is Right 6-Player,Serial Number PEF1140102 Located at: r.! t ._j2_p_M, I/ Landlord.Name and Phone Number (1)Terminator 42"Fixed Gun,Serial Number 1035 Located at:r (\y le h es le R rn-L I Landlord Name and Phone Number Your Interest in the equipment/property shall include all present and future attachments. LESSEEfDESTOR CENTRAL PA FAMILY FUN CENTERS,INC. Sy v f President Timothy SeverinC Title Page 1 of 1 Payment Schedule B Contract No.aa�g5 To: Firsti-ease,Inc. From: Central PA family Fun Centers,Inc. This schedule is attached to and made a part of the above-referenced Contract. Payment schedule as follows: Number of Amount of Lease Payment Payments (plus applicable taxes) 3 $0.00 48 $657.35 LESSEEIDEBTOR CENTRAL PA FAMILY FUN CENTERS,INC. a ' Si ner: Timothy Seve ino Thle: resident 1 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PAD. C.S. 4904 i relating to unsworn falsifications to authorities, that he/she is y— �2L. (NAME) COi1t!/�'10► ANA l�� of FIP-15'hEgg, plaintiff herein, that (REPRESENTATIVE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint in Replevin are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) WWR# 20655800 ACCT#: 22185 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY fJF THE PROTHONOTARY at Cu JFFiCEOF TUE�H FIFE 2014 OCT 21 PH 2: 57 CUMBERLAND COUNTY PENNSYLVANIA Firstlease, Inc. vs. Case Number Central Pa Family Fun Centers, Inc. (et al.) 2014-5772 SHERIFF'S RETURN OF SERVICE 10/10/2014 12:45 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint in Replevin by handing a true copy to a person representing themselves to be Julie Severino, wife of owner Timothy Severino, who accepted as "Adult Person in Charge" for Central Pa Family Fun Centers, Inc. at 1419 Wellgate Lane, Lower Allen, Mechanicsburg, PA 17055. 10/10/2014 12:45 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint in Replevin by handing a true copy to a person representing themselves to be Julie Severino, Wife, who accepted as "Adult Person in Charge" for Timothy Severino at 1419 Wellgate Lane, Lower Allen, Mechanicsburg, PA 17055. SHERIFF COST: $55.30 SO ANSWERS, October 15, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuito Sheriff, Teleosoft. Inc. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No. 47437 436 Seventh Ave, 2500 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 20655800 FIRSTLEASE, INC., vs. CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Attorney for Plaintiff(s) Cumberland County Court of Common Pleas No.: 14 -5772 -CIVIL PRAECIPE TO DISMISS WITH PREJUDICE (AS TO COUNT I, FOR POSSESSION ONLY) TO THE PROTHONOTARY: Kindly dismiss the above matter with prejudice, as to Count I only, for Possession. WELTMAN, WEINBERG & REIS CO., L.P.A. By GJ - William T. Molcza squire Attorney for Plainti Kiti DEC --9 Vi 9: 43 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF.COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC., Plaintiff No. 14 -5772 -CIVIL vs. CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants PRAECIPE FOR DEFAULT JUDGMENT AS TO COUNT II, ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2500 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#20655800 Judgment Amount $ 17,719.20 oivti-‘1b4S6 a+11 \t8I52ol8 2�3I`�3�s IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC., Plaintiff vs. CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants TO THE PROTHONOTARY: Civil Action No. 14 -5772 -CIVIL PRAECIPE FOR DEFAULT JUDGMENT AS TO COUNT II, ONLY COUNT II Kindly enter Judgment against the Defendants, Central PA Family Fun Centers, Inc., and Timothy Severino, above named, in the default of an Answer, in the amount of $17,719.20 as follows: Amount claimed in Complaint: $29,219.20 Interest from date of judgment at the Legal interest rate of 6.00% per annum $0.00 Reasonable Attorneys' fees: $0.00 Less payments from sale of collateral - ($11,500.00) TOTAL $17,719.20 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: *1^��_ William T. Molczan, Esquir PAiO.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2500 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15719 (412) 434-7955 WWR#20655800 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2500 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 And that the|oatknownaddrenamftheDefendants''is:CENTRALPAR\yW|LYFUNCENTER.|NC..1419VVELLGATE LN., K8ECHAN|CSBUR{3, PA 17055 and TIMOTHY SEVERINO, 1419 WELLGATE LN., W1ECHAN|CGBURG, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC., Plaintiff CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants 14 -5772 -CIVIL IMPORTANT NOTICE ON COMPLAINT IN REPLEVIN TO: CENTRAL PA FAMILY FUN CENTERS, INC., 1419 WELLGATE LN., MECHANICSBURG, PA 17055 Date of Notice:it /OS YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT 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 PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: (/n�el- (/v William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2500 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #20655800 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY; PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC., Plaintiff CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants TO: TIMOTHY SEVERINO 1419 WELLGATE LN., MECHANICSBURG, PA 17055 Date of Notice: /1(° r//Y 14 -5772 -CIVIL IMPORTANT NOTICE ON COMPLAINT IN REPLEVIN YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT 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 PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. i By: (n/ 4 1 r William T. Molczan, Esq PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2500 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #20655800 FIRSTLEASE, INC., Plaintiff vs. IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 14 -5772 -CIVIL NON-MILITARY AFFIDAVIT CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendants, CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO are not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO 1419 WELLGATE LN., MECHANICSBURG, PA 17055 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities. Affiant Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: SEVERINO First Name: TIMOTHY Middle Name: Active Duty Status As Of: Dec -03-2014 Results as of : Dec -03-2014 11:50:09 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA -r,.+. -, •-;,', - ..... . „ NO.'S. NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date f Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date : The Member or His/Her Unit Was Notified of a Future Call Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA N . • -,No , NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty . � r • Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 • The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 803102126169320 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC., Plaintiff vs. CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants Civil Action No. 14 -5772 -CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judg ent w s entered against you on (xx) Assumpsit Judgment in the amount of $17,719.20, on Count II, plus legal interest at 6.00% per annum, reasonable attorneys' fees, and costs. Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non -Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitreion Award Prothonotary I CENTRAL PA FAMILY FUN CENTER, INC., 1419 WELLGATE LN., MECHANICSBURG, PA 17055 By: PROTHONOTARY (OR DEPUTY) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC., Plaintiff vs. Civil Action No. 14 -5772 -CIVIL CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment uveas entered against you on [ 1 (xx) Assumpsit Judgment in the amount of $17,719.20, on Count II, plus legal interest at 6.00% per annum, reasonable attorneys' fees, and costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non -Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROTHONOTARY (OR DEPUTY) TIMOTHY SEVERINO 1419 WELLGATE LN., MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION — FIRST LEASE, INC Case No.: 14-5772 Plaintiff vs. Central PA Family Fun Centers, Inc Timothy Severino Defendant NOTICE TO DEFEND ANSWER COUNT -1 REPLEVIN: And now, comes the Defendant, Central PA Family Fun Centers, Inc- Timothy Severino, pro se, who answers Plaintiffs Complaint Count 1 as follows regarding the surrender of the following collateral gaming equipment in accordance with the lease terms: a. Price is Right 6 -Player, Serial Number PEFI 1#0102 b. Terminator 42" Fixed Gun, Serial Number 1035 1. The Defendant's location (Manchester Mall) where the equipment being leased was located was unceremoniously and suddenly lost by the Defendant and could no longer afford to make the required lease payments. 2. The Plaintiff steadfastly and arrogantly refused to work with the Defendant while the Defendant endeavored to recover a new location for the equipment or find other financial alternatives in order to continue to make lease payments. The only recourse to stop the relentless and harassing phone calls, email, and physical contact was to surrender the aforementioned two games to First Lease under intense duress. 3. The big business condescending ruthlessness displayed by the Plaintiff to the Defendant small business owner implied that they would make more money off of the Defendant if forced into default. 4. The defendant agrees to pay for reasonable fees associated with the physical pickup and return of the equipment to the First Lease warehouse of approximately $250 pending an itemized invoice of the physical pickup of the two games. ANSWER COUNT -2 REPLEVIN: And now, comes the Defendant, Central PA Family Fun Centers, Inc- Timothy Severino, pro se, to continue to answer Plaintiffs Complaint Count 2 as follows: 5. The Defendant willingly and voluntarily agreed to return the collateral in accordance with the lease agreement upon the ability of not being able to make the monthly payment. The equipment was barely used in a less than six month time frame and was in pristine condition at the time of surrender. 6. The Defendant should only be charged approximately $250 pending an itemized invoice of the physical pickup of the two games and not the entire lease balance of $29,219.20. Wherefore, Defendant prays for the entry of Judgment on the Plaintiff Count 1 of approximately $250 for the physical return of the two games to the First Lease warehouse pending an itemized list of manpower and fuel expenses necessary to relocate the two games to the Plaintiff's warehouse. Timothy Severino Central PA Family Fun Centers 1419 Wellgate Lane Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRSTLEASE, INC., Plaintiff vs. CENTRAL PA FAMILY FUN CENTERS, INC., TIMOTHY SEVERINO Defendants TIMOTHY SEVERINO 1419 WELLGATE LN., MECHANICSBURG, PA 17055 Civil Action No. 14 -5772 -CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud pient Was entered against you on ) Jas (xx) Assumpsit Judgment in the amount of $17,719.20, on Count II, plus legal interest at 6.00% per annum, reasonable attorneys' fees, and costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non -Pros ( ) Confession (xx) Default ( ) Verdict (. ) Arbitration Award°\ Prothonotary / By:�g�- PROTHON'COTARY (OR DEPUTY)