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Home My WebLink About02-4943ALAN S. CARPEL, ESQUIRE Identification Number: 12048 1129 Spruce Street Philadelphia, Pa 19107 (215) 238-7700 UNIVERSAL RECORD DISTRIBUTING : CORPORA TION 2055 RICHMOND STREET : PHILADELPHIA, PA 19125 : VS. FLOYD STOKES IND. & T/A PRODEJAS : ii WEST POMFRET STREET SUITE #4 : CARLISLE, PA 1 7013 AND : THE AMERICAN LITERACy CORPORATION~ 11 WEST POMFRET STREET SUITE #4 : : CARLISLE, PA 17013 COURT OF COItiON PLEAS OF CUMBERLAND COUNTY NOTICE TO PLEAD YOu have been sued in court. If you wish to defend against the claims set forth in the following pages, ou within twenty (20) days after thi ..... ~-~ Y~ mu.st take action ~ ~w~px~xnc aha no¢lce are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that do so, the case may proceed without and a judgment if you fail to may be entered against you by the court without further notice for any money claimed in the complaint by the plaintiff. You may lose money or property or other rights important to you. This and any future communication from our firm are attempts to collect a debt and information obtained will be used for that purpose· 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PEArNSYLVANiA 1 7013 71 7-249-3166 ALAN S. CARPEL, ESQUIRE Identification Number: 12048 1129 Spruce Street Philadelphia, Pa 19107 (215) 238-7700 UNIVERSAL RECORD DISTRIBUTING : CORPORATION 2055 RICHMOND STREET : PHILADELPHIA, PA 19125 : VS. FLOYD STOKES IND. & T/A PRODEJAS : 11 WEST POMFRET STREET : SUITE #4 CARLISLE, PA 17013 AND : THE AMERICAN LITERACY CORPORATION~ 11 WEST POMFRET STREET SUITE #4 : : CARLISLE, PA 17013 COURT OF CO~ON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION Plaintiff in the above-captioned matter, claims of defendant(s) the sum of $16,301.56, with interest, upon the following cause of action: 1. At the special oral instance and request of defendant(s), plaintiff sold and delivered to defendant (s) goods and merchandise at the times, of the kind, in the quantities, and for the prices set forth in the plaintiff's invoices and/or statements, true and correct copies of which are attached hereto, made a part hereof and marked as Exhibit "A' 2. Defendant(s) received the goods and merchandise described in Exhibit "A". 3. The prices set forth in Exhibit "A" are fair, reasonable and market prices for said goods and merchandise, and are the prices which defendant(s) agreed to pay. 4. All credits, if any, to which defendant(s) is entitled, are set forth in Exhibit "A". 5. Despite frequent demands, the defendant(s) has failed and neglected to pay the plaintiff the sum of $16,301.56, or any part thereof. WHEREFORE, the plaintiff demands judgment against the defendant(s) in the amount of $16,301.56, together with interest from the due date thereof. Attorney for/Plaintiff 1129 Spruce Street Philadelphia, Pa 19110 215-238-7700 09/19/2002 07:18 FAX NCO FINANCIAL SYSTEMS, I ~005/003 YERIFICATION I, the undersigned, in my capacity as oretor u~.~er of Universal Record Distr. Corp., , Plaintiff her~ln, certify that the facts set forth in the foregoing Complaint a:Ze true and correct to the best of my knowledge or information and belieL I make thti Verification subject to the Penalties of 1.8 Pa.. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false statements, I may be s~bject to criminal penalties. . Keith Brennan Print or Type Name SWORN TO AND SUBSCRIBED . BEFORE ME THIS 19TH DAY ' OF SEPTEMBER, A.D. 2,002. - ~ Y P' · Public L My ~ ~pims Apr. 8. ~ Signature EXHIBIT "A" o ~ ALAN S. CARPEL, ESQUIRE Identification Number: 12048 1129 Spruce Street Philadelphia, Pa 19107 (215) 238-7700 UNIVERSAL RECORD DISTRIBUTING : CORPORATION : 2055 RICHMOND STREET : PHILADELPHIA, PA 19125 : vs. : FLOYD STOKES IND. & T/A PRODEJAS : 17 WEST POMFRET STREET : CARLISLE, PA 17013 : AND : THE AMERICAiVLITERACY CORPORATION: 17 WEST POMFRET STREET : CARLISLE, PA 17013 : COURT OF CO~ON PLEAS OF CUMBERLAND COUNTY NO. 2002-04943 PRAECIPE TO REINSTATE CIVIL ACTION TO THE PROTHONOTARY: Kindly reinstate the Civil Action in the above-captioned matter. BY: L.~~C~PEL A , ESQUIRE ATTORNEY FOR PLAINTIFF SHERIFF,s RETURN CASE NO: 2002-04943 p COMMONWEALTH OF COUNTy OF PENNSYLVANIA CUMBERLAND - NOT FOUND UNIVERSAL RECORD DIST CORP VS FLOYD STOKEs IND ET AL k. Thomas Kline ,Sheriff or Deputy Sheriff, duly SWOrn according to law, Says, that he made a inquiry for the Within named defendant, ~ANT FLOYD STOKEs IND Unable to locate Hi_~_~m in his bailiwick. COMPLAINT & NOTICE, He therefore who being diligent Search and but Was returns the the within named DEFENDANT~____~, FLOYD STOKEs IND NOT FOUND NEW A/DDREss IS p~ - ' OX 5823 HARRISBURG, PA 17110 , as to Sheriff's Costs: Docketing Service Not FOUnd Surcharge 18.00 3.4S S.00 10.00 36.45 Sheriff of Cumberland County ALAN CARPEL 11/12/2002 Sworn and SUbscribed to before me this ~ day of~ L20~o 2, A.D. CAsE NO: 2002-04943 SHERIFF,S RETURN _ NOT FObTvD COMMONWEALTH OF P COUNTy OF PENNSYLVANIA CUMBERLAND VS ~ne --,Sheriff or Deputy Sheriff, duly SWOrn aCcording to law, Says, that he made a diligent inquiry for the Within named defendant, DEF_q~F~_EN~D__ENDANT Unable to lOCate H/_~__m in his bailiwick. who being search and but Was He therefore returns the the Within named ~AN~, _, NOT FOUND ~110 as to Sheriff's Costs: DOCketing Service Not Found Surcharge 6.00 So answers: _~ .00 ~ 5.00 lO.o0 ~ Sheriff of CUmberland County zz. 00 ALAN CARPEL 11/12/2002 Sworn and subscribed to before me this ~ day of ~.~. z~ CASE NO: 2002-04943 SHERIFF,S RETURN - NOT FOUND COMMONWEALTH OF P COUNTY OF PENNSYLVANIA CUMBERLAND duly SWOrn according to la ,Sheriff or Deputy Sheriff, who being ~nqu~ry for the . . w, says, that he made a diligent Search ~RAc~th~n named defendant' ~P_~AN T and Unable to l°Cate Th.~em in his ba~ but Was , ' herefore returns the n named ~, AMERICAN , NOT FOUND , Sheriff,s Costs: Docketing SerVice 6.00 Not Found · O0 ~ SUrCharge 5.00 10.00 ~ Sheriff of Cumberland County z~. O0 ALA1v CARPEL 11/12/2002 SWOrn and subscribed to before me this ~ day of ~ ~ A.D.