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Home My WebLink About02-4753IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BALL, MURREN & CONNELL, a partnership Plaintiff MOSAICA EDUCATION, INC. Defendant CIVIL ACTION LAW NOTICE 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. IF 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BALL, MURREN & CONNELL, a partnership Plaintiff MOSAICA EDUCATION, INC. Defendant NO. CIVIL ACTION LAW NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted de apariencia escrita o en -e ............ be presentar una v -o,,,~,~ u put aoogaao y arciulvar eD la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros decrechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADOO SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BALL, MURREN & CONNELL, a partnership Plaintiff MOSAICA EDUCATION, INC. Defendant NO. O CIVIL ACTION LAW COMPLAINT 1. Plaintiff, Ball, Murren & Connell, is a law firm and partnership, organized and existing under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 2303 Market Street, Camp Hill, Pennsylvania. 2. Defendant, Mosaica Education, Inc., is a Delaware corporation with registered office in Pennsylvania at CT Corporation System, 1635 Market Street, Philadelphia, PA 19103. 3. Plaintiff entered iht° an agreement with defendant whereby plaintiff agreed to provide legal services to defendant and defendant agreed to pay plaintiff its customary and usual fees for the services performed and all costs incurred on defendant's beho~ ~' .... ~'~ ~ connection with services rendered. 4. During the c°urse of its legal representation of defendant, plaintiff .maintained books of account on the services that it rendered and the costs that it recurred on defendant's behalf, which accounts are an accurate and running account of all debits and credits for the provision of such services and incurring of such costs. 5. Regular invoices were mailed to defendant setting forth the services which had been rendered by plaintiff on defendant's behalf during the previous months, the reasonable value being charged for the services, and any outstanding balance due on services rendered prior to that time. 6. During the course of plaintiff ,s representation of defendant, plaintiff has from time to time received payments on the outstanding balances of various accounts of defendant. 7. On or about June 3, 2002, plaintiffrendered an account to defendant in the amount of $34,128.68. A true and correct copy of the most recent accounts sent to defendant is attached to and incorporated into this complaint as Exhibit "A". 8. Although plaintiff has demanded payment of the balance due of $34,128.68, defendant has wrongfully failed and refused to pay all or any part of the balance due plaintiff 9. Plaintiffperformed its obligations under the agreement between it and defendant by providing legal services to defendant and incurring costs on its behalf, the fair and reasonable value remaining unpaid balance of which is $34,128.68. 10. Plaintiff has performed its services for defendant fully and conformed to, and complied with, all of the terms and conditions required of it under the oral agreement between it and defendant. 11. Despite defendant's obligation to pay plaintiff for the services performed and costs incurred on its behalf, and ' · despite plaintiff's demands on defendant for such payment, defendant has wrongfully failed and refused to pay to plaintiff the sums due it. 12. Defendant has had an opportunity to scrutinize the accounts. 13. Defendant has agreed to or acquiesced in the correctness of the accounts and in its obligation to pay plaintiff the invoiced amounts for services rendered on its behalf. 14. Defendant has never questioned or objected either specifically or generally to the numerous accounts rendered. WHEREFORE, plaintiff Ball, Murren & Connell, demands judgment against defendant in the amount of $34,128.68 together with costs, interest, and any other relief this court deems appropriate. Date:__~g) ~_____ Richard E. Connell, Esquire I.D. # 21542 Ball, Murren & Connell 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 Attorney for Plaintiff ~VERIFICATION I, Richard E. Connell, Esquire, verify that the statements in the foregoing 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 unsworn falsification to authorities. Date:_ CERTIFICATE OF SE_RVICE_ I, Richard E. Connell, Esquire, hereby certify that I placed a true and correct copy of the foregoing documents in the U.S. Mail, first-class, postage prepaid to the following: Mosaica Education, Inc. 61 Broadway, Suite 2924 New York, NY 10006-2810 and Robert Hurwich, Esquire 61 Broadway, Suite 2924 New York, NY 10006-2810 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BALL, MURREN & CONNELL, a partnership Ve Plaintiff MOSAICA EDUCATION, INC. Defendant : No. 02-4753 : CIVIL ACTION-LAW .PRAECIPE TO SETTLE, DISCONTI__~_NUE & END WITH PREJUDIC~E TO THE PROTHONOTARY: Kindly mark the above-captioned matter as "Settled, Discontinued and Ended with Prejudice." R~chard E Connell, Esqmre (PA I.D. # 21542) Counsel for Plaintiff Ball, Murren & Connell 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 Date: