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Home My WebLink About00-02818 CUMBERLAND COUNTY ADULT PROI3ATfON IN THE COURT Of' COMMGN PLEAS Of' CUMI3ERLANDCOUNTY PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW James P. Robb 607 A Geneva Dr Mechanicsburg, NO. m-d'i?,Ig'Jn:VILtERM Apt 10 Pa. 17055 Defendant/Address RE: NO.99-2676 ClUMINAL TERl\1 PRAECIPE TO ENTER JUDGMENT TO.THE PROTHONOTARY: Enter judgment in favor of plaintiff, Cumberland County Adult Probation, and against 'defendant in the amount of,} 1.2 OJ q .4 q pursuant to 42 Pa. C.s.A. Section 9728 as set forth in the attached statement of certified case costs and fines. ' i)ennis E. Lebo, Clerk of Court Date: 5-5-00 U~ fc:;(dnr- \ J AND NOW, !his .J;+t.. day of in favor ofthe Plaintiff and against the Defendant in the ENTRY OF JUDGMENT d. 4--t1-1 judgment is entered ount set forth above. Curtis R. Long, ProUlOnOtary Attadunent cc: Defendant Probation Clerk of Court - u\[, 143059041200 , CCS746 ******************** *STATEMENT OF COSTS* ******************** Page 32 4712/2000 Case No. 1999-02676 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa 17013 ROBB JAMES P 607 A GENEVA DRIVE APARTMENT 10 MECHANICSBURG, PA 17055 ==============~================~=================================~============== Date Transaction Debit Credit Balance 02/ 15/00 SHERIFFS COST 2.99 2.99 Totals 2.99 2.99 02/22/00 COURT COSTS 23.10 23.10 Totals 23.10 23.10 02/22/00 SHERIFFS COST 1.50 1.50 Totals 1.50 1.50 02/22/00 OFF F.E. ACT158 5.00 5.00 Totals 5.00 5.00 02/22/00 cce ACT 139 15.00 15.00 Totals 15.00 15.00 02/22/00 cve ACT 139 15.00 15.00 Totals 15.00 15.00 02/22/00 STATE COST A 8.29 8.29 Totals 8.29 8.29 02/22/00 STATE COST B 7.11 7.11 Totals 7.11 7.11 02/22/00 JCP FEE 1. 50 1. 50 Totals 1.50 1.50 02/22/00 DISTRICT ATTY 10.00 10.00 Totals 10.00 10.00 02/22/00 PLEA 75.00 75.00 Totals 75.00 75.00 02/22/00 CO-DUI SCHOOL 200.00 200.00 ". 143059041200 , CCS746 ******************** *STATEMENT OF COSTS* ******************** Page 33 4712/2000 Case No. 1999-02676 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa 17013 ROBB JAMES P 607 A GENEVA DRIVE APARTMENT 10 MECHANICSBURG, PA 17055 Totals 200.00 200.00 02/22/00 DUI BOOKING FEE 200.00 200.00 Totals 200.00 200.00 02/22/00 ST - O.S.F. 75.00 75.00 Totals 75.00 75.00 02/22/00 CO - O.S.F. 75.00 75.00 Totals 75.00 75.00 02/22/00 COURT COSTS 5.00 5.00 Totals 5.00 5.00 04/04/00 LOCAL-DUI 150.00 150.00 Totals 150.00 150.00 04/04/00 DUI PRISON MNT 75.00 75.00 Totals 75.00 75.00 04/04/00 DUI DRUG/ACHOL. 75.00 75.00 Totals 75.00 75.00 04/04/00 EMS 10.00 10.00 Totals 10.00 10.00 04/04/00 CAT FUND 50.00 50.00 Totals 50.00 50.00 04/04/00 CCP FEE 90.00 90.00 Totals 90.00 90.00 04/04/00 ADMIN. FEE 25.00 25.00 Totals 25.00 25.00 143059041200 . 'C'CS746 ******************** *STATEMENT OF COSTS* ******************** Page 34 4712/2000 Case No. 1999-02676 To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa 17013 ROBB JAMES P 607 A GENEVA DRIVE APARTMENT 10 MECHANICSBURG, PA 17055 04/04/00 LOCAL FINES 12.50 12.50 Totals 12.50 12.50 04/04/00 STATE FINES 12.50 12.50 Totals 12.50 12.50 04/04/00 EMS 10.00 10.00 Totals 10.00 10.00 04/04/00 CAT FUND 30.00 30.00 Totals 30.00 30.00 case Totals 1259.49 .00 1259.49 You are liable for the above costs Pursuant to Title 42 of Judiciary and Judicial procedure, 42 PA CSA 9728, the Prothonotary is authorized to confess judgment on all unpaid costs and issue an execution and place same in tfie fiands of the Sheriff for the collection. We trust you will give the above account your prompt attention. A TRUE COPVfMMftIGllRD InTestlmony whereof.tllllll_~ and the~saId"" This s:- liar" W illIlililfilPi~ ,,-" ~jl!jJl!iljiillil'*lil~~ i _ , _ _ .,__~,....." - ilim~-f''-~_liII~''~iili1!ilillilisi _lilt" "".'1'(<10:) 3WlT A -........1 ,roels~w ,','-",,,,r nl .......llUo3ili1ialola5B "'" "". ..... fllyab_,_zi1T '-1"=:.a . ~ (") c~ C} & C C..,j '-n ~ "" ::>: -Om .-< ~ i;:~~ {lIen -< z..,.., ~, r z:c I -'urn \ ~z: {.Jj ,:<j? (J _ ~t:J .....~ (--, " =,-f=:;{ )> :): ZO 90 )>0 lY om ~ ':..> ;p! "'Ii- =< - ~ ........... -,I. ~ - ~,~ " ,,,,-,,,' "I j' -. L.B. SMITH, INC. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. CUMBERLAND VALLEY EXCAVATING, 1NC. DBA : CIVIL DIVISION - LAW CUMBERLAND VALLEY EXCAVATORS : Defendant : 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 F1LING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLA1MS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAlL TO DO SO THE CASE MAY PROCEED W1THOUT 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 L.B. SMITH, INC. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. :NO. C91- ~L~]~' ~ -"~'-~- CUMBERLAND VALLEY EXCAVATING, INC. DBA: CIVIL DIVISION - LAW CUMBERLAND VALLEY EXCAVATORS : Defendant : COMPLAINT The Plaintiff, L.B. SMITH, INC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of FOURTEEN THOUSAND, FIVE HUNDRED SEVENTY-ONE DOLLARS AND FIFTY CENTS ($14,571.50), along with cost of this suit and interest thereon from March 24, 2000 upon a cause of action of which the following is a statement: 1. The Plaintiff, L.B. SMITH, 1NC., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 2001 State Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, CUMBERLAND VALLEY EXCAVATING, INC. DBA CUMBERLAND VALLEY EXCAVATORS, is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 6375 Baseshore Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiffs books of original entry hereto attached, made a part hereof and marked Exhibit "A", Plaintiff, at the special instance and 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 FOURTEEN THOUSAND, FIVE HUNDRED SEVENTY-ONE DOLLARS AND FIFTY CENTS ($14,571.50). F:\USER\KATHY\CMPLAINT~26672LBS.MTH:07May01 4. The prices charged for said goods, wares and memhandise were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay Plaintiff therefor. 5. The balance due and owing by Defendant to Plaintiff is the sum of FOURTEEN THOUSAND, FIVE HUNDRED SEVENTY-ONE DOLLARS AND FIFTY CENTS ($14,571.50), as appears by the Statement of Account hereto attached, made a part hereof and marked as Exhibit "B". 6. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has 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 FOURTEEN THOUSAND, FIVE HUNDRED SEVENTY-ONE DOLLARS AND FIFTY CENTS ($14,571.50), together with cost of this suit and interest thereon from March 24, 2000. Respectfully submitted, UM, 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 F:\USER\KATHY~CMPLAINT~26672LB S.MTH:07May01 2 22~.20 13.4~ 0[/$0 'a ~,ZOt~L+LIL 'ON X~:I 0 I,/% 'd ' ~ '- 100,00 0[/90 'd ~ZOI$L+LIL 'ON 7, 5 $~VS HilN$ 8 S ltd 9N:20 ~.~,.0 ~tFW, 0008-£0-A01i 0;/80 'd ~80,8.+£~£ 'Ol~ X~d S3~S Hill, IS ~ q ~Id OI/EO 'd S~8OISL~LIL 'ON XW.q OL/OI 'd ~bSO~i+iI£ 'ON X~Y $3~S HilW$ 8 3 Md B~:~O 3~£ OOO~-~O-^ON Page: 1 Docut,~ent Name: In%titled ~., · LBOIL O~EN IT~,M LO01K-UP 11/ CUST.It15303 DIV 01 ADB~V CUMDE~LAND Or~N BAL 14,5?1.50 DAT£ NAME COM~ERLAND VALLEY EXCAVATORS PRINT INVOICE ~ DATE REF ~ 9-.999999-~1 6/26/98 p-154900~01 5/i0/99 5/10/~9 *d165 8/18/99 P-155200-01 5/!1/99 S/i1/99 ~4170 E-RSd443-01 ~/05/99 12/16/99 *83950 p-S%2804-01 8/27/99 ~-R5581~-01 9/20/99 E-R57045-01 10/19/99 E-R58323-Dl 11/20/99 E-R59297--O1 12/20/99 E-,K60063-01 1/18/00 2/12/00 R60657 p-813878-0i 3/24/00 INVOICE ~T BALANC~ 2120.54 2120.54 127.2]. '15.~3- !83.43- 40.99 59.12- 318~.00 ~678.00 502.00- 697.76 697.76 1908,00 1908.00 1~08.00 %90~.00 1908.09 1908,00 ]908.00 1908.00 1908.00 636,00 1272.00- 881.55 8~!.55 DUE 865 SIC CASN ADJ 460 438 414 323 !NV 294 CMEM 22B NO MORE TO COI~5, '7 2 gg-"2 FOP,~'~I P,C'¢ ].fJ'l Date: l~j0'?/2o0~ '~'~.'mg: 1:30:21~M OI/gO '8 g~ZOigL+L~L 'ON X~J I, ROBERT D. KODAK, state that I am not a party to the action but that, at the request of the Plaintiff, L.B. SMITH, 1NC., and based upon knowledge, information, records and documents supplied to me by the Plaintiff, the averments set forth in Plaintiffs Complaint are true. A Verification executed by the Plaintiffcan be supplied at time of trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: ~/ F:\USER\KATH~CMPLAINTX26672LBS.MTH:07May01 SHERIFF'S RETURN - REGULAR CASE NO: 2001-02818 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH L B INC VS CUMBERLAND VALLEY EXCAVATING PATRICIA SHATTO , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPIJtINT & NOTICE was served upon CUMBERLAND VALLEY EXCAVATING INC D/B/A CUMB VALLEY EXCAVAT the DEFENDANT , at 0920:00 HOURS, on the 4th day of June , 2001 at 6355-6375 BASHORE ROAD MECHANICSBURG, PA 17055 by handing to ROBERT YENTZER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.20 Affidavit .00 Surcharge 10.00 .00 34.20 Sworn and Subscribed to before me this ~, ~-- day of tfrdt honor ary t R. Thomas Kline 06/04/2001 KNUPP KODAK & IMBLUM Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA L.B. SMITH, 1NC., Plaintiff CUMBERLAND VALLEY EXCAVATING, INC., d/b/a CUMBERLAND VALLEY EXCAVATORS, Defendant CIVIL ACTION - LAW NO. 01-2818 Civil Term PRAECIPE TO: PROTHONOTARY Please enter my appearance on behalf of the Defendant, CUMBERLAND VALLEY EXCAVATING, INC., d/b/a CUMBERLAND VALLEY EXCAVATORS. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Attorney ID No. 57976 19 Brookrwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA L.B. SMITH, INC., Plaintiff go CUMBERLAND VALLEY EXCAVATING, INC., d/b/a CUMBERLAND VALLEY EXCAVATORS, Defendant CIVIL ACTION - LAW NO. 01-2818 Civil Term ANSWER AND NOW, this 282 day of September, 2001 comes the Defendant, CUMBERLAND VALLEY EXCAVATING, INC.,d/b/a CUMBERLAND VALLEY EXCAVATORS, by and through its' counsel, Law Office of Michael J. Hanft, and files the following Answer and in support thereof avers as follows: 1. Admitted. 2. Admitted. 3. Denied. It is specifically denied that Fourteen Thousand Five Hundred Seventy- One and 50/100 Dollars ($14,571.50) is due from Defendant to Plaintiff. Strict proof thereof is demanded at trial. 4. Denied. The averments of Paragraph 4 are a conclusion of law to which no responsive pleading is required. Should a responsive pleading be deemed necessary the averments are specifically denied. 5. Denied. The averments of Paragraph 5 are a conclusion of law to which no responsive pleading is required. Should a responsive pleading be deemed necessary the averments are specifically denied. 6. Admitted in part, denied in part. It is admitted that Plaintiff has demanded Fourteen Thousand Five Hundred Seventy-One and 50/100 Dollars ($14,571.50) from Defendant. It is specifically denied that said stun is owed by Defendant to Plaintiff. Strict proof thereof is demanded at trial. WHEREFORE, Defendant respectfully requests that judgment be entered in favor of Defendant and aga'mst Plaintiff. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT ~ ire Mic ael J. Hanft, Es~tmx~ Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this 28th day of September, 2001, I, Michael J. Hanfi, Esquire, hereby certify that I have this day served the following persons with a copy of the foregoing document, by first class, United States Mail, postage pre-paid, addressed as follows: Robert D. Kodak, Esquire KNUPP, KODAK & IMBLUM, P.C. 407 North Front Street P.O. Box 11848 Harrisburg, PA 17108-1848 LAW OFFICE OF MICHAEL J. HANFT Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 VERIFICATION 1 VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unswom falsification to authorities. L. B. SMITH, INC. ' IN THE COURT OF COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-2818CIVIL CUMBERLAND VALLEY EXCAVATING, INC. d/b/a CUMBERLAND VALLEY EXCAVATORS: Defendant RULE 1312-1. form: The Petition for Appointment of Arbitrators shall be substantially to the following PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Robert D. Kodak, Counsel for the Plaintiff in the above action, respecffully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is $14,571.50 + interest from 03/24/2000. The countemlaim of the Defendant in the action is $ (none). The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as Arbitrators: Robert D. Kodak, Esquire, Knupp, Kodak & Imblum, P.C. and/or Michael J. Hanft, Esquire. WHEREFORE, your Petitioner prays Your Honorable Court to appoint three (3) Arbitrators to whom the case shall be submitted. Robert D. Kodak Attorney I.D. No. 18041 ORDER OF COURT AND NOW, ~,;;~,2.001, in consideration of the foregoing Petition: , Esquire are ~pointed Arbitrators in the above-captioned action as prayed for. By the Court,