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Home My WebLink About00-01667 ~, rJ ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- /(,(,7 CIVIL TERM HALL TRUCKING, INC., Defendants 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 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 of 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 II -I.., 'c "",,_ -~ ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- /f.,r, 7 CIVIL TERM HALL TRUCKING, INC., Defendants COMPLAINT 1. Plaintiff, All American Plazas, Inc. is a Pennsylvania Business Corporation with a registered address of P.O. Box 657,1181 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, Hall Trucking, Inc. is an Ohio Corporation with a last known address of 110 Bentley Court, Findlay, Ohio, 45840. 3. At all times relevant hereto Plaintiff, All American Plazas, Inc. (hereinafter All American) was in the business of providing diesel fuel and truck repairs to the Defendant and others similarly situated. 4. From at least the beginning of 1999 to the present the Defendant, Hall Trucking, Inc. did utilize the services of All American at various locations owned by the Plaintiff for both the purchase of diesel fuel as well as truck repairs. 5. At some point in 1999 the Defendant fell seriously behind in its account with the Plaintiff and the President of the company, Jeff Hall, indicated to Plaintiff that he would make lump sum payments in order to bring the account current. 6. Based on such assurances the Plaintiff did continue to extend the credit to the Defendant which credit continued through the end of 1999 until the beginning of the year 2000. 7. As a result of these assurances the Plaintiff did extend credit to the Defendant for the purchase of diesel fuel in the amount of $203, 616.64 and for repairs in the amount of $900.14 for total amount due to Plaintiff by Defendant $204,516.78. 8. Despite repeated demand the above sum has remained unpaid as of the date of this complaint. II ". j,o 'I, ,',__..:', --'0"".' i-illllliilii,',: 9. As recently as March 6, 2000 Jeff Hall, President of Defendant, did agree to pay the sum of $209,088.64, which was the principle sum due plus interest from February 1 through April 30 in the amount of $5,472.00. 10. Even having agreed to make these payment arrangements the Defendant failed to follow through on his agreement and consequently the entire principle sum complained above is due and payable with interest. Wherefore, for all the above reasons, the Plaintiff, All American Plazas, Inc. requests judgment in its favor in the amount of $204, 516.78 plus interest and costs of suit. Respectfully Submitted TURO LAW OFFICES :>ktcY Date Ron Turo, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for All American Plazas, Inc. .I~ , . - ~ " " .-",' "~ VERIFICATION I, Ron Turo, Esquire, am the attorney for the All American Plazas, Inc. I am familiar with the facts concerning the above complaint against Defendant Hall Trucking, Inc. and I do swear and affirm that the facts set forth in the complaint are true and correct to the best of my knowledge, information and belief which have been provided to me by my client or gathered by myself during the preparation of this complaint. I understand that false statements herein made are subject to the penalties of 18 Pa. C.SA 94904 relating to unsworn falsification to authorities. 3/~ to Date 8..' , , , - '. -m' "'~"Hli.llltilliillillll~.-.....i......'~'fjlSl~~_;;:i~m~.......<~--..~,rd_ ........., -. '~_IIII'" '-",~ ~,. () ~ :;.. "1:Jm rprn ~:o Z (()~: ,,..."'S- r>6 :;e:: J'~ 20 );;0 f;; = =< F~ ..c '" l~ ~ <> -J "\ Cl .'-, ~ ,~ <:> <::> .:;::r )>. ::0 N <::) $fl --,I ::r rn~ -om 8? --:19 ::-C-r{ ~;,~o am :;;! ~ :<:>> :J: S> f:'" ...J --< @ ~ J ~ ... ..c: ~ .\ . V" ~ ~ c:: V, ;, r '" , I b.<l I '~ . ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- /~(P 7 CIVIL TERM HALL TRUCKING, INC., Defendants AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Complaint filed in the above captioned case upon Hall Trucking, Inc., by certified mail, return . receipt requested on March 20, 2000 addressed to: Hall Trucking, Inc. 110 Bentley Cou rt Findlay, Ohio 45840 and did thereafter receive same as evidenced by the attached Post Office receipt card . dated March 24, 2000. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 3)~<Z/Ob Date ' lURO LAW OFFICES Ron Turo, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff " '~ .,1 Z 452 476 336 US Postal S"",ice Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse 5enlto ) Hall Truckin In Street & Number 110 n Post Office, State, & 21 F' Postage $ 3 Certified Fee ,,", Special Delively Fee Restricted Delivery Fee U) '_ m Retum Receipt Showing to T"" Whom & Date DeJivered .~ Return Receipt ShowiIgto Whom, <( Date, & Addressee's Adless Q ~ TOTAL Postage & Fees C") Postmark or Date E ~ C/) 0.. $ .1>1 (}JJ I!). 000 \ ~ SENDER: ";; ~ i tl Ii I ~ <.. I also wish to receive the follow. ing services (for an extra fee): 1. 0 -Adtlressee's Address 2. 0 Restricted [;>elivery o '4b. Service Type tJ Regist~red D E;xpre,ssMall ~:@.etum Ae,celpt for Merchandise 7. ":.11);.,'.- of qeliv~rr 6 .-cd--..,- (){) 8. Address,ee's Address (Orily if requested and fee is pa/p) [J Complete items 1 and/or 2 for additional services. Complete items 3, 4a, and 4b. o Prin.lyour name and address on the reverse ofthis form so that-we can,retum this cflTdtoyou. [J~Altach this form to the, front, of the mail piece, or on the back if space does not ~rmit. , -~ I:PI'J~te" "Return Receipt Requested" on the mailpiece below tR& !;lrti,cle nLlmber. D l1!i!;i"REitu'!f:Reeeipt wlll-show 10 whom the article was deli~ffid and the date ,!!Ieii}i,ere,d, c. .' " . ';,- Ik Artlole Mdressed to: " 4a. .Article Number 'Z 452476 336 ",:\1>" .. J. ',1,' d'1'bu. '<:,' C'ld.', !11g In, c. -''''.-;' '0,- 'j"~~" "I ',' i1ir)Qi~leyCourl ~~t-, Ohio 45~40 i I " Kl Certified - J o Insured t DCOD ~ J! I ~ .. .c .. "1-Q25fJ5-!*J::?-~22S ~ ,~omestic Return Re6eipt Ii lift" "li._iiilillilf'>"~' ,,""' ,0 ~ . " -"""-- 'c'"'" ". nh""" ,0.'" """ -' ""''''''''''''''N'. "','" ., , , ~;, , (') c 0 ~ a 'T1 ~ ::J!:: -Ow :;:~ -n mrTi ::0 r= Z:::c N . ;:~G9 :Z:C' (f) 1:.'" '.0 " j, ~t: "~::~ ~..J "\:.1 -"--i, ("5}:2 :!e'o -,,~ ~7l J ;s: C) N ~''''-m 5e: C) --j ~ "::J 55 ,.0 =< . '............. ...........~," ..// 1'>- ALL AMERICAN PLAZAS, INC., Plaintiff " !~\ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1667 HALL TRUCKING, INC., Defendants PRAECIPE CIVIL TERM TO THE PROTHONOTARY OF THE SAID COURT: Please enter a default judgment in favor of Plaintiff, All American Plazas, Inc. and against the Defendant, Hall Trucking, Inc. based on its failure to plead to the Complaint filed March 20, 2000 and served on the Defendant by certified mail, return receipt requested on March 24, 2000. J hereby certify that I sent a Notice of Default and Intention to Take Default Judgment to the Defendant pursuant to the Rules of Civil Procedure on April 13, 2000 and the Defendant failed to respond in ten days as required by the Rule. A copy of the ten-day Notice is attached hereto and made a part of this Praecipe. Please enter the judgment in the amount requested by the Plaintiff that sum being $204,516.78 plus interest and cost of action. Respectfully Submitted LAW OFFIC yt~6 Date i J , on Turo, Esquire 8 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II ~, ".. ".' {~. ,~~ , .J L,," ,~ j \"!fi,,' , I ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY , PENNSYLVANIA v. : NO. 00-1667 CIVIL TERM HALL TRUCKING, INC., Defendants ~(Q)~w TO: Hall Trucking, Inc. 110 Bentley Court Findlay, Ohio 45840 DATE OF NOTICE: April 13, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 yhloo Date Respectfully Submitted ~~LAWOFFICES _ . ~~ Ron Turn, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff .liiR~"iI:~~~~J'f~"''''"~~~;<:~~<k;,;;,jl1ti~''.,~~d.' , " ~^ , ,1. ~~ - ^. ~ ,." "C'. " '.' IlMlIillllll H.. 0 (":0 '~ C.: E.J' " ::','" "'TJ (":'-, ~ rnf~ .. ~ ?:=: ~ Z~,~- ;"-0 t .IJ (.i),,"- u; 7" 8 -<~ ~G' :c:"" ~ " ~f- .1;) ~ 1:- >c C:) C) ~ J::... 2: r.:- ~i5 ~ -J 10 f =-< (1) -I=- -< """- -l 1'> ~ oQ 0\ g- ~ ,j "~<""'" lil _ ,I ',< ...1~', ,