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Home My WebLink About05-4796THE PARABLE GROUP, INC. Plaintiff V. CHRISTIAN PUBLICATIONS, INC. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 - 141?6 0 c ."tu i C `Tea-m CIVIL DIVISION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the courtyour defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 THE PARABLE GROUP, INC. Plaintiff V. CHRISTIAN PUBLICATIONS, INC. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ps'., y'194. CIVIL DIVISION - LAW COMPLAINT The Plaintiff, THE PARABLE GROUP, INC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of SIXTEEN THOUSAND, EIGHT HUNDRED NINETY DOLLARS AND FIFTY-ONE CENTS ($16,890.51), along with interest thereon, at the rate of 1.5% per month, from April 16, 2005 upon a cause of action of which the following is a statement: The Plaintiff, THE PARABLE GROUP, INC., is a corporation organized and existing under the laws of the State of California, having its principal office and place of business at 3563 Empleo Street, San Luis Obispo, California 93401. The Defendant, CHRISTIAN PUBLICATIONS, INC., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 3825 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiff's Invoices hereto attached, marked Exhibit "A" and made a part hereof, Plaintiff, at the special instance and oral request of the Defendant, sold and delivered goods, wares and merchandise of the kind and description set forth on said Exhibit to the total amount of Fifteen Thousand, Nine Hundred Ninety-One Dollars and Zero Cents ($15,991.00). F:\USER\STAMCCP COMPLAINTS\WORK\31668.wpd:I8AugO5 4. The prices charged for said goods, wares and merchandise were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay to Plaintiff. The balance due and owing by Defendant to Plaintiff , including finance charges, is the sum of Sixteen Thousand, Eight Hundred Ninety Dollars and Fifty-One Cents ($16,890.51), as appears by Plaintiffs Statement hereto attached, marked as Exhibit "B" and made a part hereof. 6. Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of SIXTEEN THOUSAND, EIGHT HUNDRED NINETY DOLLARS AND FIFTY-ONE CENTS ($16,890.51), along with interest thereon, at the rate of 1.5% per month, from April 16, 2005. Respectfully submitted, KNUPP, KOD BLUM, P.C. Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff E\USER\STACY\CCP C0MPLAINTS\W0RK\31668.wpd: l SAug05 T H E U P' G R O 1 BILL TO: SHIP TO: INVOICE NUMBER: 211115 CHRISTIAN PUBLICATIONS CHRISTIAN PUBLICATIONS DATE: 09109104 3825 HARTZDALE DRIVE 3825 HARTZDALE DRIVE CAMP HILL, PA 17011 CAMP HILL, PA 17011 P.O. NUMBER: TERMS: Net 30 Days ACCOUNT# CHR DESCRIPTION CODE OTY UNIT PRICE NET OCT CATALOG ADV.-Lovers for Life V-C-FALL 1 4997.0000 4997.00 N Post Office Box 8126 s San Luis Obispo, A finance 1896 annoml will Total Invoice of 1.5% per month 4997.00 .7?F3`LQ4.4 rimR QQ.U ? 5Jv THE W G R 0 BILL TO: SHIP TO: INVOICE NUMBER: 212948 CHRISTIAN PUBLICATIONS CHRISTIAN PUBLICATIONS DATE: 10/08/04 3825 HARTZDALE DRIVE 3825 HARTZDALE DRIVE CAMP HILL, PA 17011 CAMP HILL, PA 17011 P.O. NUMBER: TERMS: Net 30 Days ACCOUNT# CHR DESCRIP TION CODE OTY UNIT PRICE NET NOVEMBER CATALOG ADV.-Fathers Love Letter C-CHR-1 5997.0000 5997.00 N Total Invoice A finance charge of 1.596 per month {T896 annum) will be added to all pas' due in,oices. 5997.00 Past Office Box 8126 • San Luis Obispo, California 93403-8126 • 805 543-2644 • Fax 805 543-2136 THE rGAW INVOICE BILL TO: SNlP TO: INVOICE NUMBER: 220272 CHRISTIAN PUBLICATIONS CHRISTIAN PUBLICATIONS DATE: 03116105 3825 HARTZDALE DRIVE 3825 HARTZDALE DRIVE CAMP HILL, PA 17011 CAMP HILL, PA 17011 P.O. NUMBER: TERMS: Net 30 Days ACCOUNT# CHR DESCRIPTION •, APRIL CATALOG ADV.-You're Going to Be My Mom V-C-SPRIN 1 4997.0000 4997.00 N Total Invoice 4997.00 A Finance chorge of 1.54E per month (1896 annum) will be added to all pest due invoices. Past Office Box 80126 - San Luis Obispo, California 33403-8126 4 805 543.2644 • Fax 805 543-2136 T H E G R 1 WO BILL TO: CHRISTIAN PUBLICATIONS 3825 HARTZDALE DRIVE CAMP HILL, PA 17011 STATEMENT DATE: 04121!05 ACCOUNT* CHR ACCOUNT AMOUNT REMITTED: - 211115 09/09104 4997.00 4997.00 211115 4997. 212948 10108104 5997.00 5997.00 212948 5997. 214341 10129/04 Finance Charge 74.96 74.96 214341 74. 216159 11/30/04 Finance Charge 164.91 164.91 216159 164. 217182 12/31104 Finance Charge 164.91 164.91 217182 164. 218843 01131/05 Finance Charge 164.91 164.91 218843 164. 219602 02128/05 Finance Charge 164.91 164.91 219602 164. 220272 03/16/05 4997.00 4997.00 220272 4997. 221140 03131/05 Finance Charge 164.91 164.91 221140 164. Current Over 0 Over 30 Over 60 Over 90 164.91 516121 164.91 164.91 11233.87 15890.51 16890.51 A mon.,?......... (789•c on t due invoices. Post Offi ce Box 81 26 • San Luis 93403-8126 STATEMENT DATE: 04/21/05 0812812005 15:13 FAX AUG-19-2005 02:13 MP? IMAX S IMBLUM VERTFICAIION Q1002 717 239 7158 P.05 Rick Sletten credit Manaeer (nM ) Mug) of THE PARABLE GROUP, INC., verifythat the statements made in the afnregoing document are trae and I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to L falsification to authorities. THE PARABLE GROUP, INC. /,/ A? BY Titlc: Dated: 8/31/05 i 31668 F:\USEMTACYNCCP COMPLAI!M\WOR 01668.Wpd:ISAug05 TOTAL P.05 (vim` V , Vi G f 1 1 G.? G, i SHERIFF'S RETURN - REGULAR CASE NO: 2005-04796 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARABLE GROUP INC THE VS CHRISTIAN PUBLICATIONS INC GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CHRISTIAN PUBLICATIONS INC the DEFENDANT , at 1843:00 HOURS, on the 15th day of September, 2005 at 3825 HARTZDALE DRIVE CAMP HILL, PA 17011 JOHN MARTZALL, INFO SERVICES a true and attested copy of COMPLAINT & NOTICE by handing to MANAGER, ADULT IN CHARGE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.20 Postage .37 Surcharge 10.00 .00 39.57 Sworn and Subscribed to before me this _r_ day of A.D. Prot otar So Answers: r- e4p R. Thomas Kline 09/16/2005 KNUPP KODAK IMBLUM Deputy Sher f J. Stephen Feinour, Esquire Supreme Court ID #24580 Lucinda C. Glinn, Esquire Supreme Court ID No. 84737 NAUMAN SMITH SHISSLER & HALL, LLP 200 North Third Street P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717-234-1925 THE PARABLE GROUP, INC Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 -4796 CIVIL CHRISTIAN PUBLICATIONS, INC. Defendant NOTICE TO PLEAD TO: The Parable Group, Inc. and Robert D. Kodak, Esquire, its Attorney You are hereby notified to plead to the enclosed Preliminary Objections within twenty (20) days from the service hereof. NAUMAN, SMITH, SHISSLER & HALL, LLP BY: Li l_ "4L-1 ' J. Stephen Feinour, Esquire Supreme Court ID# 24580 Lucinda Glinn, Esquire Supreme Court ID# 84737 200 North Third Street, P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel for Christian Publications, Inc. Dated: October 4, 2005 J. Stephen Feinour, Esquire Supreme Court ID #24580 Lucinda C. Glinn, Esquire Supreme Court ID No. 84737 NAUMAN SMITH SHISSLER & HALL, LLP 200 North Third Street P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717-234-1925 THE PARABLE GROUP, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTIAN PUBLICATIONS, INC. Defendant NO. 05 -4796 CIVIL PRELIMINARY OBJECTIONS OF DEFENDANT, CHRISTIAN PUBLICATIONS INC TO COMPLAINT OF PLAINTIFF, THE PARABLE GROUP INC AND NOW, comes Christian Publications, Inc., (hereinafter "CPP'), Defendant, by its attorneys, Nauman, Smith, Shissler & Hall, LLP, and files the following Preliminary Objections to the Complaint filed by The Parable Group, Inc. (hereinafter "Parable") pursuant to Pa. R.C.P. 1028: Objection 1 - Failure of Pleading to Conform to Rule of Court or Law On or about September 14, 2005, Parable filed a Complaint ("Complaint') against CPI. 2. The Complaint was served by Sheriff on September 15, 2005, upon John Martzall, Information Services Manager for CPI. Paragraph 3 of the Complaint alleges: "On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiff's Invoices hereto attached, marked Exhibit "A" and made a part hereof, Plaintiff, at the special instance and oral request of the Defendant, sold and delivered goods, wares and merchandise of the kind and description set forth on said Exhibit to the total amount of Fifteen Thousand, Nine Hundred Ninety-One Dollars and Zero Cents ($15,991.00)." 4. In accordance with Rule 1019(a) "The material facts on which a cause of action or defense is based shall be stated in a concise summary form." See Pa. R.C.P. 1019(a). 5. Parable failed to state the material facts upon which its asserted cause of action is based, instead relying upon invoices attached to its Complaint at Exhibit "A." 6. The attachment of three invoices, each presumably involving a separate transaction, does not satisfy the rules of fact pleading. 7. Further, the attachment of Exhibit A, consisting of three invoices, constitutes evidence which is improperly attached to the Complaint. In accordance with Rule 1019(a), it is insufficient for a plaintiff to attach evidence to its complaint and assert that the contents include the material facts to which a response is sought. 9. Parable failed to set forth the material facts in separately enumerated paragraphs, as required by Rule 1019. 10. Specifically, Parable failed to set forth the date of the alleged agreement(s), the amount of the alleged agreement(s), date(s) of delivery of the alleged goods to be delivered, whether the goods were accepted, or the date upon which agreement was secured for the invoiced goods, and with whom. 11. Parable's failure to set forth each material fact in separately enumerated paragraphs precludes CPI from providing an answer to the unspecified and grouped allegations. WHEREFORE, Defendant, Christian Publications, Inc., hereby objects to the Complaint, and the attached exhibits referenced therein, for failure to conform to rule of court or law to comply with Pa. R.C.P. 1019, and respectfully requests this Honorable Court to grant its preliminary objection in accordance with Pa. R.C.P. 1028(a)(2), and dismiss the Complaint. Objection 2 - Insufficient Specificity in a Pleading Under Rule 1028(a)(3) 12. Paragraphs 1 through 11 above are hereby incorporated by reference as though fully set forth herein. 13. Parable failed to plead with sufficient specificity the material facts of its alleged claim. 14. Parable did not plead the specific facts necessary to establish its unspecified claim in assumpsit. 15. The failure of Parable to assert each of the material facts required to prove its cause of action with sufficient specificity such that CPI is enabled to respond, constitutes insufficient specificity under Rule 1028(a)(3). WHEREFORE, because The Parable Group, Inc., has failed to plead material facts with sufficient specificity to enable Defendant, Christian Publications, Inc., to respond, Christian Publications, Inc., respectfully requests this Honorable Court to grant its preliminary objection pursuant to Pa. R.C.P. 1028(a)(3), and dismiss the Complaint, or in the alternative, to direct Plaintiff to file a more specific pleading, and grant such other relief it deems appropriate. NAUMAN, SMITH, SHISSLER & HALL, LLP BY:? r a &a J. Stephen Feinour, Esquire Supreme Court ID# 24580 Lucinda Glinn, Esquire Supreme Court ID# 84737 200 North Third Street, P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel for Christian Publications, Inc., Defendant Dated: October 4, 2005 4 CERTIFICATE OF SERVICE AND NOW, on the date stated below, I, Lucinda C. Glinn, Esquire, of the firm of Nauman, Smith, Shissler & Hall, LLP, hereby certify that I this day served the foregoing Preliminary Objections via U.S. Mail, addressed to the following: Robert D. Kodak, Esquire Knupp, Kodak & Imblum, P.C. 407 North Front Street, P. O. Box 11848 Harrisburg, PA 17108-1848 NAUMAN, SMITH, SHISSLER & HALL, LLP By: Lucinda C. Glinn, Esquire Supreme Court ID# 84737 200 North Third Street, P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel for Christian Publications, Inc. Date: October 4, 2005 r,? => ?, a ?; ?,?, -,-,,,; ?- ;?.?? _, :_ ,.. ^, > =- __. (?J .. j rr; ; _? _? c-. :?? ?< THE PARABLE GROUP, INC., Plaintiff V. CHRISTIAN PUBLICATIONS, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-4796 CIVIL TERM CIVIL DIVISION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 AVISO USTED HASIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que. si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UNABOGADO,LLAMEOVAYAALASIGUIENTEOFICINA. ESTA OFIC INA PU EDE PROVEERLE IN FORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTAOFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 THE PARABLE GROUP, INC., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-4796 CIVIL TERM CHRISTIAN PUBLICATIONS, INC., CIVIL DIVISION -LAW Defendant AMENDED COMPLAINT The Plaintiff, THE PARABLE GROUP, INC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of SIXTEEN THOUSAND EIGHT HUNDRED NINETY DOLLARS and FIFTY-ONE CENTS ($16,890.51), along with interest thereon, at the rate of 1.5% per month, from April 16, 2005, upon a cause of action of which the following is a statement: The Plaintiff, THE PARABLE GROUP, INC., is a corporation organized and existing underthe laws of the State of California, having its principal office and place of business at 3563 Empleo Street, San Luis Obispo, California 93401. 2. The Defendant, CHRISTIAN PUBLICATIONS, INC., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 3825 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. On or about May 24, 2004, Plaintiff and Defendant entered into an agreement whereby Plaintiff would promote Defendant's product, Father's Love Letter, in Plaintiff's catalog, for an agreed price of $5,997.00. A true and correct copy of said May 24, 2004 contract is attached hereto, marked Exhibit "A" and made a part hereof 4. On or about June 1, 2004, Plaintiff and Defendant entered into an agreement whereby Plaintiff would promote Defendant's product, Lovers for Life, in Plaintiff's catalog, for an agreed price of $4,997.00. A true and F:\USER\ROBIN\CCP&DJ CMPS\FORMS - Common Pleas\MASTERCOMP.wpd:I IOct05 correct copy of said June 1, 2004 contract is attached hereto, marked Exhibit "B" and made a part hereof. 5. On or about December 7, 2004, Plaintiff and Defendant entered into an agreement whereby Plaintiff would promote Defendant's product, You're Going To Be My Mom, in Plaintiff's catalog, for an agreed price of $4,997.00. A true and correct copy of said December 7, 2004 contract is attached hereto, marked Exhibit "C" and made a part hereof. 6. Plaintiff performed its duties to Defendant in accordance with the three (3) contracts referenced in Paragraphs 3, 4 and 5 in that Plaintiff promoted in its catalog the materials set forth in the contracts as requested by Defendant. 7. The prices charged for said promotions were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant contractually promised and agreed to pay to Plaintiff. 8. Due to Defendant's default in payment of said amount due and owing as aforesaid, interest/finance charges have been added to said account as follows: A. 10/29/04 Finance Charge 74.96 B. 11/30/04 Finance Charge 164.91 C. 12/31/04 Finance Charge 164.91 D. 01/31/05 Finance Charge 164.91 E. 02/28/05 Finance Charge 164.91 F. 03/31/05 Finance Charge 164.91 for a total amount of Eight Hundred Ninety Nine Dollars and Fifty One Cents ($899.51), as more fully set forth on Plaintiff's Statement of Account, labeled Exhibit "D" attached hereto and made a part hereof. F:\USER\ROBIN\CCP&DJ CMPS\FORMS - Common Pleas\MASTERCOMP.wpd:I IOct05 2 9. The balance due and owing by Defendant to Plaintiff under the contracts attached hereto as Exhibits "A", "B" and "C", together with the Finance Charges set forth on Exhibit "D", is the sum of Sixteen Thousand Eight Hundred Ninety Dollars and Fifty-One Cents ($16,890.51), as appears by Plaintiff's Statement of Account hereto attached, marked as Exhibit "D". 10. Plaintiff's Invoices are not attached to this pleading as same have previously been provided to Defendant. 11. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount of any part thereof WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of SIXTEEN THOUSAND EIGHT HUNDRED NINETY DOLLARS and FIFTY-ONE CENTS ($16,891.,51), together with interest thereon from April 16, 2005. Respectfully submitted, KNUPP, KOD BLUM, P.C. Y / ^ 1 Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff F:\USER\ROBIN\CCP&DJ CMPS\FORMS - Common Pleas\MASTERCOMP.wpd:I 1 W05 3 08/03/05 10:40 FAX 805 543 2136 PARABLE GROUP [A 009 PIAY-24-2004 04:54 FROM: UICTDRY MARKETIW 717-432-0193 TO:180554s866S P,2 Agreement for N„AM 290 PM 0", 0 mup * Nov mba ?isftW t&09 met . WedtmthW. NOVMterg.24U4 Christian Pubros fans Vf0wFwk (800j333.441a Fax C,1T)791-7M Thl% k dua rto kldlls' #m Rt W. NW 21, 2W. Pmduot pka W go m ar aWy Kira dW no low #wA-I a mft, .key 01.2 )04. You WI0 gWMMW yaur pmadtxtm + tam by Wv meday. Cdcl+ar 20. *no4 K Perot a wmnbm order Or. 1v?s.,. +r.punMn? amt br sml.e?nv es, zit P 1whaBsn DeMtt"aw Haw tan Yaer tu+o"be r?etkld h to " , upie of txatst?ts ewieftft? By pbd v It in to cebltap. "hw wm is bath WrAdahav ranrsneed P?• a b4 forte yaw pmduebi In op qsft m Hr ? we wM apam ombi v the dddior i sw pVtetnm a4siOpe td naodrnian ousaon+er rtlrs tCM A%wbd n PdAk adorn: . P" .. ta -rtraad m-L4+.UM tW-weIPANaO Pro leg* Tab: "AT.aaJ Wa a0roo t4 advnl?a #f. abovrr produels ac st?brt - rrQ dw m t--dmd. W* strv j*6 tvn mr use orf? praducht tl+ kma wbmk and aetlllrdsj an the bomst and Wo Pm MOaattel vei . '?MrO b a Van d wg* tpr a+Y ON too A 1T.ft? Z ` we the,raaa?M .ad aafiar?res!da?eln+raapr aete' o?oe,` o?.a•?++t ..?-+..?- .- 1 1 Cu"Am m Mates tmr NOW., Gft vftraaryr wym ebooas ep pmW art %vrtr (Ws hov* m b sai d: +rm ft xn rase w t ,% OWN sera lw bar sept&v*w 1. sift zw. >2yrsbk ar?P 9SA Ewplad t9?eet M& 14b 0bhM CA M40 ie6.a 34M4 PAM 9M04"Wie 10 'd EL& 19L L 1L 'ON XV.i 90:11 Noy POOZ-LI-dills 08103105 10:40 FAX 805 543 2136 PARABLE GROUP 16010 ADDITIONAL TERMS AND PROVISIONS TO CATALOG AGREEMENT 1. NggLotiation of Purchase Terms. The obligations of Vendor and TPG under this Catalog Agreement shall be subject to the prompt negotiation of the terms upon which the Christian retailer members of TPG ("Members') may purchase the advertised goods referred to in this Catalog Agreement. 2. Additional Terms of Purchase Orders. Vendor acknowledges and agrees that the Purchase Orders it receives from the Members shall include the Additional Terms and Provisions contained on the reverse side of each Purchase Order. Vendor further acknowledges and represents that it has received a copy of such Additional Terms and Provisions of Purchase Order and has read and acquainted itself with them. It is anticipated that, in many instances, the reverse side of a Purchase Order will be omitted when the Purchase Order is transmitted to the Vendor by telecopy. In the interest of time and efficiency, Vendor agrees that it will not be necessary to receive a copy of such Additional Terms and Provisions each time it receives a Purchase Order, but nevertheless agrees to be bound by them in connection with each Purchase Order it ships to any of the Members. 3. Payment Terms. Unless otherwise noted in this Catalog Agreement, the net amount due for advertising shall be paid to The Parable Group, Inc. C7PG") within 30 days from the print date. Such amount, if not timely paid, shall bear interest at the rate of 1.5% per month or at the maximum interest rate allowed by the law, whichever is less. Should it become necessary for'TPG to engage legal counsel to enforce its rights under this Catalog Agreement, it shall be entitled reimbursement of attorney's fees and court costs. 4. Failure to Publish Advertising. If for any reason, one or more of the items shown on the front of this Catalog Agreement are not published in said catalog, Vendor's sole remedy shall be to receive a refund of, or credit against the advertising cost charged by TPG for such omitted items. Neither TPG nor any of its officers, employees, Members or agents shall be liable for any incidental or consequential damages resulting from a failure to advertise such items, regardless of the cause of such failure. Substantial Co=liance. Vendor acknowledges that it has reviewed and approved the format TPG intends to follow in producing the catalog referred to in this Catalog Agreement. Vendor agrees that TPG's advertising fees shall be deemed to be fully earned by TPG at the time the items described in this Catalog Agreement are advertised in such catalog in substantial compliance with this Catalog Agreement. If a material mistake is made in the advertising of any such items, the sole remedy of Vendor shall be to receive a refund or credit for the cost of the item incorrectly advertised. Vendor hereby waives any claims it may now or at any time in the future have with regard to consequential or incidental damages resulting from any mistake in advertising on the part of TPG or its officers, employees, Members of agents. 6_ Confidentiality. Vendor agrees to hold all information contained in this Agreement as well as any other proprietary information furnished to Vendor by TPG or the Members strictly confidential, except that this provision shall not apply to any information which has become publicly disclosed by TPG or the Members. 08/03/05 10:39 FAX 805 543 2136 PARABLE GROUP 16006 JI]N 01-2004 TUE 11:17 Ar CHRISTIAN PUBLICATIONS I FAX NO. 717 761 7273 F. 01 T It I Agreeni6t for ' wo? October Big Salle Cal slog Street ppte: wednesdsy, Septemt or 29, 2004 Christian Publications Ck%W park (600) 2334443 Fax: (717) 781.7273 This Agned apmw Cnt b due no Ieter fft911: Friday. May 21, 2W- . Pmdud wmp(eu phu 36 * orde of Copy we an no idler h n: Fd*w, May 28,20& You wilt guW&-tee W product in MS by Wednesday, Sepwnhw 15, 20041f Pei W* members order dY (k*w maaw P oRlrs by ANpm 13. RAati Promodop Damilpeo": Our BIGGEST Bale of the year has a prvm track record of sales Mmase& MOM then a sale. aria is truly mn ar IWI &mm for cask ws, They ac W* put Ran tA* calendar and Comae ii1 mady to wrA b a BIG way in pteperattan for Ghrtatritea. +NhYe Ihey taC? btlyktQ ChiisLrlae pre6enb. t114Y allO flrld Haflowedn 310 sn7e4V8 mateclais ? Tltartk?Iroltg products, and 1tse re pro gftd to romwim their pastor ror CWV AppreeMM IV 00. . Naft. Kenneth -JSale 513.99 94,997.00 647 UPC: 8110": INK In - Rerama LL - Lkw Lbw w - Not PmnoASC Pronwlkm To t ak D;. ,a We agrev to adveriiae the abow products as - no day w needed, We also O ve permicrcm for vae of Moe products (lndud-inia artwork and contents) an the Internet and omer prnmctlanal we ikla. There Is a X150 charge for any c MMM Pat Friday, daly 19, 04. Wa agree b i add•Wet *ffrA end "A "M on ire r-&;" sid+ w "M in 0;0 t of ON pro-aaaa aareeraent mate wA? aq neaesaatr ?hsnWs and stMl?w+ibn ebb feeye. we 00" ID ft waft I w" wm-w- * of Iii Mftw Sim Whtch art 10 t aft WO ift ww"Oft Gomm PC Nose: Other Notes: '918 Vernd= #-"w choose to Pnwft art wark 0031t6els,Y to bo semi *0 the pm:hM oldbrs, pba send rho by W X =4, MM Nrd& Groap 3663 ]&"*a Shea &m )Lair OWq% CA 93M01 8t16•'i4J-U" VAZ 495-43.5663 08/03/05 10:39 FAX 805 543 2136 PARABLE GROUP 16007 ADDITIONAL TERMS AND PROVISIONS TO CATALOG AGREEMENT 1. Negotiation of Purchase Terms. The obligations of Vendor and TPG under this Catalog Agreement shall be subject to the prompt negotiation of the terms upon which the Christian retailer members of TPG ("Members") may purchase the advertised goods referred to in this Catalog Agreement- 2_ Additional Terms of Purchase Orders. Vendor acknowledges and agrees that the Purchase Orders it receives from the Members shall include the Additional Terms and Provisions contained on the reverse side of each Purchase Order. Vendor further acknowledges and represents that it has received a copy of such Additional Terms and Provisions of Purchase Order and has read and acquainted itself with them. It is anticipated that, in many instances, the reverse side of a Purchase Order will be omitted when the Purchase Order is transmitted to the Vendor by telecopy. In the interest of time and efficiency, Vendor agrees that it will not be necessary to receive a copy of such Additional Terms and Provisions each time it receives a Purchase Order, but nevertheless agrees to be bound by them in connection with each Purchase Order it ships to any of the Members. 3. Payment Terms. Unless otherwise noted in this Catalog Agreement, the net amount due for advertising shall be paid to The Parable Group, Inc. ("TPG") within 30 days from the print date. Such amount, if not timely paid, shall bear interest at the rate of 1.5% per month or at the maximum interest rate allowed by the law, whichever is less. Should it become necessary for TPG to engage legal counsel to enforce its rights under this Catalog Agreement, it shall 6e entitled reimbursement of attorney's fees and court costs- 4. Failure to Publish Advertising. If for any reason, one or more of the items shown on the front of this Catalog Agreement are not published in said catalog, Vendor's sole remedy shall be to receive a refund of, or credit against the advertising cost charged by TPG for such omitted items. Neither TPG nor any of its officers, employees, Members or agents shall be liable for any incidental or consequential damages resulting from a failure to advertise such items, regardless of the cause of such failure. 5. Substantial Compliance. Vendor acknowledges that it has reviewed and approved the format TPG intends to follow in producing the catalog referred to in this Catalog Agreement. Vendor agrees that TPG's advertising fees shall be deemed to be fully earned by TPG at the time the items described in this Catalog Agreement are advertised in such catalog in substantial compliance with this Catalog Agreement. If a material mistake is made in the advertising of any such items, the sole remedy of Vendor shall be to receive a refund or credit for the cost of the item incorrectly advertised. Vendor hereby waives any claims it may now or at any time in the future have with regard to consequential or incidental damages resulting from any mistake in advertising on the part of TPG or its officers, employees, Members of agents. 6. Confidentiality. Vendor agrees to hold all information contained in this Agreement as well as any other proprietary information furnished to Vendor by TPG or the Members strictly confidential, except that this provision shall not apply to any information which has become publicly disclosed by TPG or the Members. 08/03/05 10:38 FAX 805 543 2136 PARABLE GROUP DEC-07-2004 TUE 08:47 AM CHRISTIAN PUBLICATIONS I FAX NO. 717 781 7273 T R I Agreement for !? .April Spring Cata1 ?g G R 0 U strred Date: Wednesday, Apil 6, 2006 Christian P'ublimbOrm (ago) 3- 3 Rx:(T17)761-T7T3 Drew Park W 003 P. 01 ,cm 12SO4 12USS PM This shed aq dement Is due no taut t w; Monday. November 1S. 2004, ? 10, 2444• Product sarnpb! s Pius 36 wards of copy are We no tr W thaws: FAW, POW* You VA W.Maltee Y"product In ire by WeMwdW. March 75,2M ? opm bw mufth +a 20M N Pane mem! bets order try' . ? pmmcwn tH krtpaort: We Maas this CHN0 •Ones Your F RA partiap sips n in proms" Yo' Product beoeuee SVWY F blo i1° product mss' are th" erg 66cond busleat time of year. chft ilin Pubkdtkm t? 1bq'rs G:k9 bJly - FtlYara. A*d 4j° JTq ?. rn*o...... ? To Qe toots J,.? resit. ae?! lums ups. _ EA ['obit' 54,997;44 prgtnoCae Tod: r?I [ _ T ,neea 11-1?a Lm w r4p - rat pluffloo0 we agree bD ;rdmVM file *Pm prod"as stdiad - no a!e W needed- Wr a give porrtttt;stort I'or use ai these Ptpdu& (Including wwok and cottte116s) on the lnt;ymot adod Odw pmmdor el vehddes. Mw@ >* fl 5130 eherpe kr any tt? wa past Tuat*, Fabnraty 01.2006 Aurhxtad etquem _ WIP mro is Mw adtaYa?ol urns antl pmvLslat? m 81C Isve+x tidt wkilrh err w pa110( proYnOtl??i0 ? other Hotew send 1 0 0 oft Vendor:c Ef you shod" to prrtvide iwt work (sal e-84) to be seat w? it a prnd?ese orders, Base by Dew?. W 71 w E arabie Gr"p 3563 Bmpraa 8mwj 5.7.mw 0biwp% CA 9340! 869.54&2644 FATO $m6m&-ti W 08/03/05 10:38 FAX 805 543 2136 PARABLE GROUP W004 ADDITIONAL TERMS AND PROVISIONS TO CATALOG AGREEMENT 1 _ Negotiation of Purchase Terms. The obligations of Vendor and TPG under this Catalog Agreement shall be subject to the prompt negotiation of the terms upon which the Christian retailer members of TPG ("Members'D may purchase the advertised goods referred to in this Catalog Agreement. 2. Additional Terms of Purchase Orders. Vendor acknowledges and agrees that the Purchase Orders it receives from the Members shall include the Additional Terms and Provisions contained on the reverse side of each Purchase Order. Vendor further acknowledges and represents that it has received a copy of such Additional Terms and Provisions of Purchase Order and has read and acquainted itself with them. It is anticipated that, in many instances, the reverse side of a Purchase Order will be omitted when the Purchase Order is transmitted to the Vendor by telecopy. In the interest of time and efficiency, Vendor agrees that it will not be necessary to receive a copy of such Additional Terms and Provisions each time it receives a Purchase Order, but nevertheless agrees to be bound by them in connection with each Purchase Order it ships to any of the Members. 3. Payment Terms. Unless otherwise noted in this Catalog Agreement, the net amount due for advertising shall be paid to The Parable Group, Inc- ("TPG") within 30 days from the print date. Such amount, if not timely paid, shall bear interest at the rate of 1.5% per month or at the maximum interest rate allowed by the law, whichever is less. Should it become necessary for TPG to engage legal counsel to enforce its rights under this Catalog Agreement, it shall be entitled reimbursement of attorney's fees and court costs. 4. Failure to Publish Advertising. If for any reason, one or more of the items shown on the front of this Catalog Agreement are not published in said catalog, Vendor's sole remedy shall be to receive a refund of, or credit against the advertising cost charged by TPG for such omitted items. Neither TPG nor any of its officers, employees, Members or agents shall be liable for any incidental or consequential damages resulting from a failure to advertise such items, regardless of the cause of such failure. 5. Substantial Compliance. Vendor acknowledges that it has reviewed auod approved the format TPG intends to follow in producing the catalog referred to in this Catalog Agreement. Vendor agrees that TPG's advertising fees shall be deemed to be fully earned by TPG at the time the items described in this Catalog Agreement are advertised in such catalog in substantial compliance with this Catalog Agreement. If a material mistake is made in the advertising of any such items, the sole remedy of Vendor shall be to receive a refund or credit for the cost of the item incorrectly advertised. Vendor hereby waives any claims it may now or at any time in the future have with regard to consequential or incidental damages resulting from any mistake in advertising on the part of TPG or its officers, employees, Members of agents- b_ Confidentiality. Vendor agrees to hold all information contained in this Agreement as well as any other proprietary information furnished to Vendor by TPG or the Members strictly confidential, except that this provision shall not apply to any information which has become publicly disclosed by TPG or the Members. T H E GROUP` BILL TO: CHRISTIAN PUBLICATIONS 3825 HARTZDALE DRIVE CAMP HILL, PA 17011 211115 09/09/04 212948 10/08/04 STATEMENT DATE: 04/21/05 214341 10/29/04 a Finance Charge 216159 11130/04 Finance Charge 217182 12/31/04 Finance Charge 218843 01/31/05 Finance Charge 219602 02/28/05 Finance Charge 220272 03/16/05 221140 03/31/05 Finance Charge Current Over 0 Over 30 164.91 5161.21 164.91 (18°rc c Post Office Box 8126 • San Luis 1 ACCOUNTS CHR STATEMENT DATE: 04/21105 ACCOUNT NUMBER: CHR AMOUNT REMITTED: 4997.00 4997.00 211115 4997.0 5997.00 5997.00 212948 5997.0 74.96 74.96 214341 74.9 164.91 164.91 216159 164.9 164.91 164.91 217182 164.9 164.91 164.91 218843 164.9 164.91 164.91 219602 164.9 4997.00 4997.00 220272 4997.0 164.91 164.91 221140 164.9 Over 60 Over 90 164.91 11233.87 15890.51 16890.51 n n ..._..... j= invoices. : . 3403-8126 OCT-18-2005 14:17 OCT-11-2005 14:20 KNUPP KODAK & IMBLOM VERIF I C ATION P. 06/06 L1--• --- 717 238 7158 P.06 I, RICK SLETTEN, credit manager of The Parable Group, Inc., verify that the statements made In the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unworn falsification to authorities. THE PARABLE GROUP, INC. By: 1-?? RICK SLETTEN Title: Credit Manager Dated: lG - IC- 'c,6"- F:WSRRIR081N%CC?&W CkP$%PORMS- Commo11 ?1=S MASTMCOMP.wpd:I 10dW5 316M TOTAL P.06 TOTAL P.06 CERTIFICATE OF SERVICE I, ROBERT D. KODAK, ESQUIRE, hereby certify that on October20, 2005, I served a true and correct copy of the AMENDED COMPLAINT in the above-captioned matter upon the below listed individual(s) by causing same to be deposited in the United States mail, first class postage prepaid at Harrisburg, Dauphin County, Pennsylvania, addressed as follows: J STEPHEN FEINOUR ESQUIRE LUCINDA GLINN ESQUIRE 200 N THIRD STREET PO BOX 840 HARRISBURG PA 17108-0840 KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak 407 North Front Street Post Office Box 11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney I.D. No. 18041 Attorney for Plaintiff Dated: October 20, 2005 t"" r. ... c.?.- ? ?'t __ --I S -+ ?.. J. Stephen Feinour, Esquire Supreme Court ID #24580 Lucinda C. Glinn, Esquire Supreme Court ID No. 84737 NAUMAN SMITH SHISSLER & HALL, LLP 200 North Third Street R O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717-234-1925 THE PARABLE GROUP, INC. Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 -4796 CIVIL CHRISTIAN PUBLICATIONS, INC. Defendant NOTICE TO PLEAD TO: The Parable Group, Inc. and Robert D. Kodak, Esquire, its Attorney You are hereby notified to plead to the enclosed New Matter within twenty (20) days from the service hereof. NAUMAN, SMITH, SHISSLER & HALL, LLP BY: J. Stephen Feinour, Esquire Supreme Court ID# 24580 Lucinda Glinn, Esquire Supreme Court I)# 84737 200 North Third Street, P. O. Box 840 Date: January _ff_, 2006 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel for Christian Publications, Inc., Defendant J. Stephen Feinour, Esquire Supreme Court ID #24580 Lucinda C. Glinn, Esquire Supreme Court ID No. 84737 NAUMAN SMITH SHISSLER & HALL, LLP 200 North Third Street P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717-234-1925 THE PARABLE GROUP, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTIAN PUBLICATIONS, INC. Defendant NO. 05 -4796 CIVIL CHRISTIAN PUBLICATIONS, INC.'S ANSWER WITH NEW MATTER TO AMENDED COMPLAINT AND NOW, comes Christian Publications, Inc., (hereinafter "CPI"), Defendant, by its attorneys, Nauman, Smith, Shissler & Hall, LLP, and files the following Answer with New Matter to the Amended Complaint filed by The Parable Group, Inc. (hereinafter "Parable") as follows: Admitted. 2. Denied as stated. Christian Publications, Inc. is a non-profit corporation organized under the laws of the State of Delaware with offices located at 3825 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania. This averment contains a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are specifically denied. Exhibit A is a document that speaks for itself and any characterization thereof is specifically denied. By way of further answer, it is specifically denied that said documents constitute a "contract," and strict proof thereof is demanded at trial. 4. This averment contains a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are specifically denied. Exhibit B is a document that speaks for itself and any characterization thereof is specifically denied. By way of further answer, it is specifically denied that said documents constitute a "contract," and strict proof thereof is demanded at trial. 5. This averment contains a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are specifically denied. Exhibit C is a document that speaks for itself and any characterization thereof is specifically denied. By way of further answer, it is specifically denied that said documents constitute a contract and strict proof thereof is demanded at trial. 6. This averment constitutes a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are specifically denied. By way of further answer, it is specifically denied that the documents referred to are "contracts." 7. This averment constitutes a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are specifically denied. By way of further answer, it is specifically denied that the prices charged by Parable for marketing services were "just and reasonable" or "legal and market prices," and were higher than those charged by comparable entities. 8. This averment contains a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are denied, and strict proof thereof is demanded at trial. Exhibit D is a document that speaks for itself and any characterization thereof is specifically denied. 9. This averment contains a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are denied and strict proof thereof is demanded at trial. 10. After reasonable investigation, the truth of this averment can be neither admitted nor denied. It is admitted that invoices are not attached to the Amended Complaint. 11. This averment contains a conclusion of law to which no response is required. To the extent it is deemed to contain facts, they are denied and strict proof thereof is demanded at trial. WHEREFORE, Christian Publications, Inc., Defendant, demands judgment in its favor and against The Parable Group, Plaintiff, as to any and all claims set forth in the Amended Complaint. NEW MATTER 12. Paragraphs 1 through 11 are hereby incorporated herein by reference as though fully set forth herein. 13. Plaintiff's claim fails for lack of consideration. 14. Plaintiff has failed to plead the requisite elements of a breach of contract. 15. Plaintiff s claims are barred by the applicable statute of limitations. 16. Plaintiff has failed to state a claim upon which relief can be granted. WHEREFORE, Defendant, Christian Publications, Inc., requests this Honorable Court to enter judgment in its favor and against Plaintiff The Parable Group, Inc., as to any and all claims contained in its Amended Complaint NAUMAN, SMITH, SHISSLER & HALL, LLP BY: J. Stephen Feinour, Esquire Supreme Court ID# 24580 Lucinda Glinn, Esquire Supreme Court ID# 84737 200 North Third Street, P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel for Christian Publications, Inc., Defendant Dated: January /K, 2006 VERIFICATION I, K. R. Paton, President of Christian Publications, Inc., Defendant in the foregoing proceeding, make the following statement subject to the penalties of 18 Pa. C.S.§4904, relating to unsworn falsifications to authorities, and do state that as President of Christian Publications, Inc., I am authorized to make this verification on its behalf, and do state that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. K. R. Paton Date: January ? 7, 2006 CERTIFICATE OF SERVICE AND NOW, on the date stated below, I, Lucinda C. Glinn, Esquire, of the firm of Nauman, Smith, Shissler & Hall, LLP, hereby certify that I this day served the foregoing Christian Publications, Inc.'s Answer with New Matter to the Amended Complaint via U.S. Mail, addressed to the following: Robert D. Kodak, Esquire Knupp, Kodak & Imblum, P.C. 407 North Front Street, P. O. Box 11848 Harrisburg, PA 17108-1848 NAUMAN, SMITH, SHISSLER & HALL, LLP B Y• Lucinda C. Glinn, Esquire Supreme Court ID# 84737 200 North Third Street, P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel for Christian Publications, Inc. Date: January /?, 2006 ?.,? ?' i ", '?} C " ?'? r? . f ,? ? i?i 1, .. i?"? _ C. Curtis R. Long Prothonotary (Office of the Protbonotarp Cumberranb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor () S -''/'Y Q& CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573