UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA

AMERICAN EQUIPMENT LEASING : 

a division of EAB LEASING CORP., : 

 Plaintiff : 

 : 

vs. : Civil Action 

 : 

SALEEM SIDDIQI aka SALEEM R. SIDDLEL, indiv., : 

RAMALINGA PRASAD ADUSUMALLI aka : 

RAMALINA P. ADUSOMACCI, individually : 

PRASAD NANNAPANENI, individually, and : 

SRINIVAS NANNAPANENI aka : No. 02-cv-2758 

SRINIVAS RAO NANNAPANENI aka : 

SRINIVAS NANNAPANEN, individually, : 

 Defendants :

MOTION OF PLAINTIFF TO REOPEN CASE FOR THE ENTRY OF FINAL JUDGMENT

 Plaintiff, by its undersigned counsel, hereby files this motion to reopen this matter 

pursuant to the Court’s Order of January 14, 2003 and the Stipulation filed on December 9, 

2002 for the purpose of entering judgment against the defendants, Prasad Nannapaneni 

and Srinivas Nannapaneni (the “Nannapanenis”), and in support thereof, avers the 

following: 

 1. On or about November 4, 2002, the Nannapanenis and Saleem Siddiqi (the 

“Stipulating Defendants”) signed a Stipulation which served as a resolution of the issues 

contained in the complaint. 

 2. On or about January 14, 2003, the Court entered an Order dismissing this case with 

prejudice subject to plaintiff’s right to reopen the case for the purpose of entering judgment 

against the Stipulating defendants pursuant to the terms of the Stipulation. A true and 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 1 of 8
correct copy of the Stipulation and Order are attached hereto and made a part hereof as 

Exhibit A. 

 3. The Stipulating Defendants defaulted under the terms of the Stipulation in that the 

total Obligation was not paid by January 31, 2003 and thereafter, the Stipulating Defendants 

failed to make the first payment of $1,000.00 January 31, 2003 or any payment 

subsequently due thereunder as provided under paragraph 1 of the Stipulation. 

 4. Defendant, Saleem Siddiqi filed a Voluntary Petition under Chapter 7 of the United 

States Bankruptcy Code on May 3, 2003, and plaintiff is subject to the automatic stay 

provisions of the United States Bankruptcy Code. 

 5. The Nannapanenis were provided with written notice of default and given ten (10) 

days to cure the default, as required by paragraph 7 of the Stipulation. 

 6. The Nannapanenis failed to cure the default. 

 7. The balance due under the Stipulation at this time is $35,276.96. 

 WHEREFORE, plaintiff demands that this matter be reopened and that judgment be 

entered in favor of the plaintiff and against the defendants, Prasad Nannapaneni AND

Srinivas Nannapaneni, individually, jointly and severally, in the amount of $35,276.96, 

together with interest from the date of judgment and costs of suit. 

BARBARA LANZA FARLEY, 

A PROFESSIONAL CORPORATION 

 BY: 

 Barbara L. Farley, Esquire 

 Attorney for the plaintiff 

 Attorney I.D. No. 18845 

 325 Chestnut Street, Suite 915 

 Philadelphia, Pennsylvania 19106 

 (215) 923-9696 

 (215) 923-1454 (fax) 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 2 of 8
UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA

AMERICAN EQUIPMENT LEASING : 

a division of EAB LEASING CORP., : 

 Plaintiff : 

 : 

vs. : Civil Action 

 : 

SALEEM SIDDIQI aka SALEEM R. SIDDLEL, indiv., : 

RAMALINGA PRASAD ADUSUMALLI aka : 

RAMALINA P. ADUSOMACCI, individually : 

PRASAD NANNAPANENI, individually, and : 

SRINIVAS NANNAPANENI aka : No. 02-cv-2758 

SRINIVAS RAO NANNAPANENI aka : 

SRINIVAS NANNAPANEN, individually, : 

 Defendants :

CERTIFICATE OF SERVICE

 I hereby certify that a true and correct copy of the attached Notice of Motion, Affidavit of 

Default, Affidavit of Attorney and proposed Order has been mailed by first class mail, postage 

prepaid, to the following persons: 

Prasad Nannapaneni Srinivas Nannapaneni 

5230 Franklin Road 5230 Franklin Road 

Bloomfield, Michigan 48302 Bloomfield, Michigan 48302 

 I certify that the foregoing statements made by me are true. I am aware that if any of the 

foregoing statements made by me are willfully false, I am subject to punishment. 

Dated: July 23, 2003 

 Barbara L. Farley, Esquire 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 3 of 8
UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA

AMERICAN EQUIPMENT LEASING : 

a division of EAB LEASING CORP., : 

 Plaintiff : 

 : 

vs. : Civil Action 

 : 

SALEEM SIDDIQI aka SALEEM R. SIDDLEL, indiv., : 

RAMALINGA PRASAD ADUSUMALLI aka : 

RAMALINA P. ADUSOMACCI, individually : 

PRASAD NANNAPANENI, individually, and : 

SRINIVAS NANNAPANENI aka : No. 02-cv-2758 

SRINIVAS RAO NANNAPANENI aka : 

SRINIVAS NANNAPANEN, individually, : 

 Defendants :

ORDER

 AND NOW, this ____ day of ________, 2003, upon consideration of the motion of the 

plaintiff to reopen this matter for the sole purpose of entering judgment against the 

defendants in accordance with the terms of this Court’s Order of January 14, 2003 and 

Stipulation entered into between the parties, it is hereby ORDERED and DECREED that the 

motion is GRANTED. 

 FURTHER ORDERED that final judgment be and hereby is entered in favor of the 

plaintiff and against the defendants, Prasad Nannapaneni AND Srinivas Nannapaneni, 

individually, jointly and severally, in the sum of $35,276.96, together with interest from the 

date of judgment and costs of suit. 

BY THE COURT: 

 

 PETRESE B. TUCKER, U.S.D.J. 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 4 of 8
UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA

AMERICAN EQUIPMENT LEASING : 

a division of EAB LEASING CORP., : 

 Plaintiff : 

 : 

vs. : Civil Action 

 : 

SALEEM SIDDIQI aka SALEEM R. SIDDLEL, indiv., : 

RAMALINGA PRASAD ADUSUMALLI aka : 

RAMALINA P. ADUSOMACCI, individually : 

PRASAD NANNAPANENI, individually, and : 

SRINIVAS NANNAPANENI aka : No. 02-cv-2758 

SRINIVAS RAO NANNAPANENI aka : 

SRINIVAS NANNAPANEN, individually, : 

 Defendants :

AFFIDAVIT OF ATTORNEY

STATE OF NEW JERSEY: 

COUNTY OF CAMDEN : ss. 

 BARBARA L. FARLEY, ESQUIRE, of full age, being duly sworn according to law, upon 

her oath, deposes and says. 

1. I am the attorney for the plaintiff in the above-captioned matter. 

 2. On May 30, 2003, I mailed to the defendants, Prasad Nannapaneni and Srinivas 

Nannapanei a letter advising the defendants of their default under the terms of the 

Stipulation entered into between the parties and signed on November 2, 2003. A true and 

correct copy of said letter, mailed to the defendants at the address stated in the Stipulation, 

is attached hereto and made a part hereof. 

 3. I am making this Affidavit in Support of the motion of the plaintiff to reopen this matter 

for the sole purpose of entering judgment against the defendants in accordance with the 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 5 of 8
terms of this Court’s Order of September 25, 2002 and the Stipulation entered into between 

the parties. 

 

Barbara L. Farley, Esquire 

Sworn and subscribed to before me 

this ___ day of July, 2003. 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 6 of 8
UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF PENNSYLVANIA

AMERICAN EQUIPMENT LEASING : 

a division of EAB LEASING CORP., : 

 Plaintiff : 

 : 

vs. : Civil Action 

 : 

SALEEM SIDDIQI aka SALEEM R. SIDDLEL, indiv., : 

RAMALINGA PRASAD ADUSUMALLI aka : 

RAMALINA P. ADUSOMACCI, individually : 

PRASAD NANNAPANENI, individually, and : 

SRINIVAS NANNAPANENI aka : No. 02-cv-2758 

SRINIVAS RAO NANNAPANENI aka : 

SRINIVAS NANNAPANEN, individually, : 

 Defendants :

AFFIDAVIT OF DEFAULT

STATE OF TEXAS: 

COUNTY OF DALLAS: ss. 

 KELLEY GALLEMORE, of full age, being duly sworn according to law, upon his/her 

oath, deposes and says: 

 1. I am Senior Litigation Specialist of Citicapital Technology Finance, Inc., f/k/a EAB 

Leasing Corp. and as such, have knowledge relevant in this matter. 

 2. I am competent to testify regarding the matters stated in this Affidavit and make this 

affidavit based upon my own personal knowledge and after full and complete review of the 

business records maintained by plaintiff which are in my care, custody and control and which 

are maintained in the regular course of plaintiff’s business. 

 3. The defendants, Prasad Nannapaneni and Srinivas Nannapaneni are in default under 

the terms of the Stipulation entered into between the parties in that the payments due 

January 31, 2003 and all payments due thereunder have not been made. 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 7 of 8
 4. The balance due as of this date is as follows: 

 Remaining principal balance under paragraph 6 of Stipulation $34,200.22 

 Accrued interest at 7% per annum to July 10, 2003 $1,076.74 

 TOTAL AMOUNT DUE $35,276.96 

 6. I am making this Affidavit in support of the motion of the plaintiff to reopen this 

matter for the sole purpose of entering judgment against the defendants, Prasad 

Nannapaneni AND Srinivas Nannapaneni in accordance with this Court’s Order of January 

14, 2003 and the terms of the Stipulation entered into between the parties. 

 

KELLEY G. GALLEMORE 

Sworn and subscribed to before me 

this 9th day of July, 2003. 

 

Case 2:02-cv-02758-PBT Document 13 Filed 07/28/2003 Page 8 of 8