HomeMy WebLinkAbout00-03762
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MASON-NORTON COMPANY, INC.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: CIVIL ACTION-LAW
PHOENIX INDUSTRIAL, INC.,
Defendant
: NO. 00 - .)7'-:2........
CUl'(T~
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 have been served. To
defend against the aforementioned claims, a written appearance stating your defenses and objections must
be entered and filed in writing by you, the defendant, or by an attorney, You are warned that if you fail to
take action against these claims, the court may proceed without you and a judgement for any money
claimed in the complaint or for any other claim required by the plaintiff may be entered against you by the
court without further notice. You may lose money, 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 (800) 990-9108
NOTICIA
Le han demandado a usted en la corte, Si usted quiere defenderse de estas damandas expuastas
en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la
notificacion, Usted debe presentar una apariencia escr~a 0 en persona 0 por abogado y archivar en la
corte en forma escr~a sus defensas 0 sus objeciones alas 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 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda, Usted
puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE
ABOGAD 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA
ESCRIDA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA. 17013 -- (717) 249-3166 (800) 990-9108
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MASON-NORTON COMPANY, INC.,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION-LAW
vs.
PHOENIX INDUSTRIAL, INC.,
Defendant
NO. (H. 31(,.2.. &J. Ii.<.--
COMPLAINT
1. The Plaintiff is Mason-Norton Company, Inc., a corporation organized and
existing under the laws of the Commonwealth of Pennsylvania with an address of 310
South Tenth Street, Lemoyne, Cumberland County, Pennsylvania 17043.
2. The Defendant, Phoenix Industrial, Inc. (hereinafter Phoenix), is an entity duly
organized and existing under the laws of the Commonwealth of Pennsylvania, with an
address of 4590 Industrial Park Road, Camp Hill, Cumberland County, Pennsylvania 17011.
4. On or about May 10, 1999, Plaintiff and Defendant Phoenix entered into an
agreement for the purchase and delivery of certain items, as more fully set forth and
described on the quotation prepared by the Plaintiff, which is attached hereto as Exhibit
"A", which quotation was accepted by the Defendant on August 10, 1999 as noted thereon,
attached as Exhibit "B".
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5. The items were shipped and delivered by the Plaintiff to the Defendant Phoenix,
and finoll payment was due and owing 30 days thereafter, pursuant to the terms and
conditions of the parties' contract.
6. The Plaintiff billed the Defendant Phoenix for the full amount of the items, after
delivery, as stated on the invoices, copies of which are attached as Exhibit "C".
7. Pursuant to the terms of the contract, interest accrued at the rate of 12 percent
per annum, 30 days after each invoice. In addition, Plaintiff is entitled to reasonable
attorneys fees under the terms of the contract.
8. The Plaintiff has made no payment on account of the invoices, leaving a balance
due of $2,003.40, plus continuing interest.
.
9. Despite demand, the Defendant Phoenix has failed and refused to pay the
aforementioned unpaid balance plus interest as aforesaid.
10. By reason of the contract with the Plaintiff, Defendant Phoenix is liable to the
Plaintiff for the aforesaid unpaid balance and interest.
WHEREFORE, the Plaintiff requests this Honorable Court to enter judgment in favor
of the Plaintiff and against the Defendant Phoenix in the amount of $2,003.40 plus
2
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continuing interest at the rate of 12 percent per annum, plus reasonable and necessary
attorneys fees and costs oftms proceeding.
Respectfully submitted,
PURCELL, KRUG & HALLER
BY
. Pur ll, Jr, Esquire
North Front Street
H 'sburg, PA 17102
17) 234-4178
LD. #29955
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MATERIAL
QUOTATION
(BLUE)
~
"
MATERIAl
QUOTATIO~
(BLUE)
MASON - NORTON COMPANY INC.
ESTABLISHED
1952
GEORGE 0, PREBLE - President HERBERT N. PREBLE - founder
3]0 S, TENTH ST" LEMOYNE, PA 17043""""""""""""""""".PHONE: 717-737-4558
FAX: 717-761-8287
DATE: May 10, 1999
TO: PHOENIX INDUSTRIAL
ATTN: DEAN W.
PROJECT: Historical Society
LOCATION: Dillsburg, Pa.
OUR QUOTE: MQ0507-99
ADDENDAS: None
SHEET
1
OF
1
\'{,'e are pleased to quore you for furnishing only the following materials, in rypes, quantities. sizes and accessories as stated. All items not specif-
ically listed are expressly excluded, MASON-NORTON COMPANY, INC. "Installation Quotation" will be attached where applicable.
ANY KIND OF TAXES ARE JiQI INCLUDED
TOILET PARTITIONS: BY Flush Metal
4 - toilet compartments with doors, headrail braced, standard
hardware, all in a standard color baked enamel finish
For the sum of --------------------------------------------------------- $1,375.00
TOILET ACCESSORIES: BY American Specialties, Inc.
4 - toilet paper holders (7305.S) 2 - grab bars 36 (3201)
2 - mirrors 18 X 24 (0620A) 2 - grab bars 42 (3201)
2 - paper toweldi.,pensers (0210) 2 - feminine napkin disposals (0852)
For the sum of -----------~~~------------------------------------------- $ 515.00
t(grP1f
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Exhibit "AU
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MASON-NORTON COMPANY, INC.
'c ptd By 6~JYJ.-i./~'."m""m""
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MASON-NORTON COMPANY, INC.
MERCHANDISE BROKER
STAL'fDARD TERt\tlS AND CONDITIONS OF SALE AND PERFORtvlANCE
FOR SPECIALTY BUILDING PRODUCTS
L This quotation is subject to change Ot withdrawal at any time as ivL\SON,NORTON CO:'fP.-\"iY, INC is doing a brokerage
business! for sp~cialc:- products used in Construction. All quotations are based on delivery of materials within ;l reasonable time,
subject to ~scJ.btion on a net basis, without profiT or over head. Proof of changes in cost will be produced on request of buyer.
Nbt~rial must be shipped within one year [mm the latest date of quotation, or order could be subject to Facrory escalation.
2. This quotation does not include ta.xes of any kind; such as Federal, State. Local, Busin~ss or Privilege Ta.xes are not included.
Use ta.'(e5 are not included. This quotation is subject to any future taxes or td.,( increase which may be imposed. Collection of
Taxes is for the convenience of the purchaser and will be remitted ro the Taxing Authoriry on his behalf. IvlASON-NORTON
COMPANY. INC assumes no responsibiliry for taxes unpaid by buver,
3, !vlASON-NORTON COMPANY, INC does not intend to be bound ro any buyer based upon a contract which thar buyer
may have with another parry. Quotations are given in good faith for materials which afe considered to be acceptable for the
project referenced, but it must be kept in mind that final approval is Jt the discretion of others over whom we have no coneroL
4. .4JI guarantees on materials are the l\[anufacturers standard and no other warranty is made by l\1ASON-NORTON
COl\fPANY, INC., JUSt as all quot:l[ions cover materials made to the standard speciticarions and details of the named
manufacturer. which is deemed to be what is desired. Contracts which may be cancelled due to a third parry interpretation of
the requiremems, which vary from our own, shall impose no liabiliry on MASON-NORTON COMPANY, INC to furnish
other m~tterials or pay any parr of the Cost of so doing. Cancellation of this contraCt is subject to written acceptance of the
manuracturer, and :'L-\SON-NORTO:-.i CO"IPA:-.iY, I:-.iC A minimum cancellation charge of ten percent may be imposed
on the buyet. ylateriallS not to be returned wichouc \vtttten permission.
5. Quoc.ltions include freight COSt unless stated otherwise. however, shipment is EO.B. Facwr:-. for delivery to job, or to the nearest
rail or trtlck terminal. Tide of goods sh:lll p3.SS From the shipper ro the buyer on receipt of a common carrier or by receipt given
to the Jdivering agent of the shipper. Collect shipments :lre ro be paid by buyer then deducted from account if applicable.
Dam:lge 'claims, unloading of shipments and storage of same are the responsibility of the buyer. ~orificarion of shortages,
damages. and/or defecti\'e materials must be made to MASON-:-.iORTOC; COr,IP."u"lY. [:-iC, the dav of deliven', Material
ddive~ies are nor to be refused under any circumstances. . .
, ,
6, "IASON,:-.iORTO:--i COIvIPA:-':Y,' rc;c shail not be liable for any loss, damage, detention or delav caused by freight damages,
shortages, defective or incorrect material. or b;: circumstJ.nces beyond their coorrol: Delivery dates are dependent upon the
performance of others. $0 the;; :lre given as probable. not JS a guarJ.ntee of performance.
The J.cceptance of this quot:ltion by J. signature here-on, by telephone, \vritten purchase order or subconeract. shall constitute a
comracr of sale only af,er writteo acknowledge me or by "L-\S00:-:-iORT00i COMPA:--iY, I:-iC
8, This quotJtion shall be deemed a parr of ,he agreement between ,,(.-\SON,NORTON CO ,,1 P,-\.'iY, I:-iC and the buyer even
if nOt specitlcallv meorioned in anv wri"en of verbal order given to :'IASO:-.i-:-':ORTON COivlP,-\:-iY, I:-':C bv the buyer.
9, A written acknowledgement from IvlASO:-i-:--iORTON COMPA:-iY, I:-.iC shall constitute an acceptance of the contract in
Cumberland Co un')', Pennsylvania. IvL-\SO:-.i-NORTON COlvlPA:-iY. INC will only perform on the basis of the terms and
conditions herein stared. which terms shall govern. in case ofcontlicts between the buyer's order and this quotation. Any contract
which develops ftom this quotation mav be assigned to a third parry for handling and/or collection of the accouor without any
liabiliry on the parr of :'lASON-NORTON COMPANY, INC
10. Terms of paymem: are 30 days net, arrer date of invoice. on full or panial shipments and interest will be charged at the rate of
12% annually on all over due J.ccoums. No waiver of payment terms will be granted for J.ny reason if not requested in writing
bdare the 30 days expire,
In the event of default of the payment of anv sums due hereunder. and upon the necessiry of ivL-\SON-NORTON COMPANY.
INC placing the collection of such sums in the hands of an attorney upon default, MASON-NORTON COMPAt'lY, INC
shall be entitled ro reimbursement of all reasonable and necessary attorney's fees incurted for the collection of the same, and all
costs and expenses of collection, which amount shall be in addition to all other sums due and owing hereunder,
11. Waiver and Releases of Liens will not be executed by MASON-NORTON COMPANY, INC until full payments are received.
12, ivlASON,NORTON COMPANY, INC. accepts no parrial payments, retainages, liquidated damages, or backcharges withour
previous written notitlcation of problem and their costs, Any charges MUST have the written acceptance of MASON-
NORTON COMPANY, INC
To our Cuswrners: These terms and conditions have developed over many years and are stated to clarify the abilities and
position of IvlASON,NORTON COMPANY. INC as a manufacturers agent. We have no intention of neglecting you, On rhe
contrary, we J.ssure you of our cooperation and aid, especially when a problem arises.
Thank You
Form ~Ol()')
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~fATERIAL
QUOTATION
(BLUE)
I
.
MATERIAL
QUOTATIOt
(BLUE)
MASON - NORTON COMP
ESTABLISHED
1952
GEORGE 0, PREBLE - President HERBERT N, PREBLE. Founder
310 S, TENTH ST., LEMOYNE, PA 17043""""""""""".""""""PHONE: 717-737-4558
FAX: 717-761-8287
DATE: May 10, 1999
TO: PHOENIX INDUSTRIAL
ATTN: DEAN W.
OF
PROJEC~ Historical
LOCATION: Dillsburg,
OUR QUOTE: MQ0507-99
/illDENDAS: None
Society
Pa.
SHEET
I
1
We are pleased to quote you for furnishing only the following materials, in types, quantities, sizes and accessories as stated. All items not specif~
ical!y listed are expressly excluded. MASON-NORTON COMPANY, INC. "Installarion Quorarion" will be ateached where applicable,
ANY KIND OF TAXES ARE NOT INCLUDED
TOILET PARTITIONS: BY Flush Metal
4 - toilet compartments with doors, headrail braced, standard
hardware, all in a standard color baked enamel finish
For the sum of --------------------------------------------------------- $1,375.00
TOILET ACCESSORIES: BY American Specialties, Inc.
4 - toilet paper holders (7305.S) 2 - grab bars 36 (3201)
2 - mirrors 18 X 24 (0620A) 2 - grab bars 42 (3201)
2 - paper towel dispensers (0210) 2 - feminine napkin disposals (0852)
"or the sum of -----~~-~-~-~-------------------------------------------- $ 515.00
A i ~q c.
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BEM:gdb
FORM 0199
MASO:'i.NORTON COMPANY, INC.
By "",.",,,,,,,,,.4A,(fi),~,,.,,,,,,.,,,,,,..
"B~ian E. Myers - E~'tr,jfa'to~ls~Ies
SEE TERj\1S AND CO!-;D1T10NS ON RJ::.'YERSE SIDE Exhibit "B"
MASON-NORTON COMPANY, INC.
MERCHANDISE BROKER
STANDARD TERMS AND CONDITIONS OF SALE AND PERFORMANCE
FOR SPECIALTY BUILDING PRODUCTS
1. This quotation is wbject to change or withdrawal at any time as MASON,NORTON COMPANY, INC. is doing a btokerage
business, for specialty products used in Construction. All quota.tions are based on deEve.ry of materials within a reasonable time,
subject ro escalation on a net basis, without profit or over head. Proof of changes in cost will be produced on request of buyer.
Material must be sbipped within one year from the latest date of quotation, or order could be subject to Factory escalation.
2, This quotation does not include taxes of any kind; such as Federal, State, Local, Business or Privilege Taxes are not included.
Use taxes are not irtcluded. This quotation is subject to any future ta.-xes or tax increase which may be imposed. Collection of
Taxes is for the convenience of the purchaser and will be remitted to the Taxing Authority on his behalf. MASON-NORTON
COMPANY, INC. assumes no responsibility for taxes unpaid by buyer,
3, MASON-NORTON COMPANY, INC. does not intend to be bound to any buyer based upon a contract which that buyer
may have with another party. Quotations are given in good faith for materials which are considered to be acceptable for the
project referenced, but it must be kept in mind that final approval is at the discretion of others over whom we have no control.
4. All guarantees on materials are the Manufacturers standard and no other warranty is made by MASON-NORTON
COMPANY, INC., just as all quotations cover materials made to rhe standard specifications and details of rhe named
manufacturer, which is deemed to be what is desired. Contracts which may be cancelled due to a third parry interpretation of
the requiremenrs, which vary from our own, shall impose no liability on MASON-NORTON COMPANY, INC. to furnish
other materials or pay any part of the cost of so doing. Cancellation of this contract is subject to written acceptance of the
manufacturer, and MASON,NORTON COMPANY, INC. A minimum cancellation charge of ten percent may be imposed
on the buyer. Material is not to be returned without written permission.
5, Quotations include freight cost unless stated otherwise, however, shipment is F.O,B. Factoty for delivery to job, or to the nearest
rail or truck terminal. Title of goods shall pass from the shipper to the buyer on receipt of a common carrier or by receipt given
to the delivering agent of the shipper. Collect shipments are to be paid by buyer then deducted from account if applicable,
Damage claims, unloading of shipments and storage of same are the responsibility of the buyer. Notification of shortages,
damages, and/or defective materials must be made to MASON-NORTON COMPANY, INC., the day of delivety, Material
deliveries are not to be refused under any circumstances.
6, MASON-NORTON COMpANY, INC. shall not be liable for any loss, damage, detention or delay caused by freight damages,
shortages, defective or incorrect material, or by circumstances beyond their control: Delivery dates are dependent upon the
performance of others, so they are given as probable, not as a guarantee of performance.
7, The acceptance of ,his quotation by a signature here,on, by telephone, facsimile, written purchase order or subcontract, shall
constitute a contract of sale only aftet written acknowledgement by tvIASON-NORTON COMPANY, INC. Change orders are
accepted under the original terms and conditions of our Order Acknowledgmenr.
8, This quotation shall be deemed a part of the agreement berween MASON-NORTON COMPANY, INC. and the buyer even
if not specifically mentioned in any written of verbal order given to tvIASON-NORTON COMPANY, INC. by the buyer.
9, A written acknowledgement from MASON-NORTON COMPANY, INC. shall consritute an acceptance of the contract in
Cumberland County, Pennsylvania, MASON-NORTON COMPM'Y, INC. will only perform on the basis of the terms and
conditions herein st.ted, which terms shall govern, in case of conflicts berween the buyer's order and this quotation, Any contract
which develops frorr> rhis quotation may be assigned to a third party for handling and/or collection of the account without any
liability on the part of MASON-NORTON COMPANY, INC.
10, Terms of payment are 30 days net, aftet date of invoice, on full or partial shipments and interest will be charged at the rate of
120/0 annually on all over due accounts. No waiver of payment terms will be granted for any reason if not requested in writing
before the 30 days expire,
In the event of default of the payment of any sums due hereunder, and upon the necessity of MASON-NORTON COMPANY,
INC. placing the collection of such sums in the hands of an attorney upon default, MASON-NORTON COMPANY, INC.
shall be entitled to reimbursement of all reasonable and necessary attorney's fees incurred fot the collection of the same, and all
costs and expenses of collection, which amount shall be in addition to all other sums due and owing hereunder.
11. Waiver and Releases of Liens will not be execured by MASON-NORTON COMPANY, INC. until full payments are received,
12, MASON-NORTON COMPANY, INC. accepts no pattial payments, retainages, liquidated damages, or backcharges without
previous written notification of problem and their costs, Any charges MUST have the written acceptance of MASON-
NORTON COMPANY, INC.
To our Customers: These terms and conditions have developed over many years and are stated to clarifY the abilities and
position of MASON-NORTON COMPANY, INC. as a manufacturer's agent, We have no intention of neglecting you, On the
contrary, we assure you of our cooperation and aid, especially when a problem arises.
Thank You
Rev. 0999
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CONSTRUCTION
MASON-NORTON COMPANY, INC.
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INVOICE
ESTABLISHED
1m SPECIALTY CONSTRUCTION PRODUCTS
For the Commerical Construction Industry
GEORGE O. PREBLE - PRESIDENT HERBERT N. PREBLE - FOUNDER
310 S. TENTH ST., LEMOYNE PA 17043
PHONE: 717-737-4558 FAX: 717-761-8287
Sales Rep 10
BEM
Invoice Date: 'Invoice Number:
To:
PHOENIX INDUSTRIAL INC
P.O. BOX 356
CAMP HILL, PA 17011
9/30/99
19060-01
Shipped Tei:
HISTORICAL SOCIETY
GREENBRIAR LANE & HBG PIKE
DILLSBURG, PA 17019
TERMS OF SALE: 30 DAYS NET: 1% INTEREST PER MONTH ON OVERDUE ACCOUNTS
Customer ID:~__,_~_~~te Ship'p.e~ Shipped V~.c:bL P!,,_~.O,B.:!oint ~____TerlT1~ __~Your ~ra~r Number
PHOE,NIX _ 01060 9/29J_9}___, 'I'ROC::[{nX'd,?~CTORLN_~t_J9-n[)~E-__~__ ____,
. Descrrptlo~ri~---_n_' n -- -- -Amount
TOILET ACCESSOR~SS M?G BY AMERICAN SPECIALTIES AS PER APPROVALS
515.00
Subtotal
Sales Tax
Total Invoice Amount
Payment Received
TOTAL
515.00
30.90
545.90
0.00
545.90
PLEASE PAY FROM THIS INVOICE
BE ADVISED THAT IF THIS INVOICE GOES
BEYOND OUR TERMS OF PAYMENT, IT WILL
BE NECESSARY UNDER THE BONDING
REQUIREMENTS TO NOTIFY YOUR
BONDING COMPANY, ARCHITECT, OWNER
AND OTHERS ON THE SIXTIETH DAY FROM
THE DATE OF THIS INVOICE.
NO PARTIAL PAYMENTS, RETAINAGES, BACKCHARGES
OR LIQUIDATED DAMAGES MAY BE DEDUCTED FROM
THIS INVOICE WITHOUT PRIOR WRITTEN APPROVAL.
FEDERAL ID #23-2984787
_n
Exhibit "c"
-
ifin
MASON-NORTON COMPANY. me.
INVO~~(pY
ESTABLISHED
1m SPECIALTY CONSTRUCTION PRODUCTS
For the Commerical Construction Industry
GEORGE O. PREBLE - PRESIDENT HERBERT N. PREBLE - FOUNDER
310 S. TENTH ST., LEMOYNE PA 17043
PHONE: 717-737-4558 FAX: 717-761-8287
Sales Rep 10 r Invoice Date: I Invoice Number:
BEM i 10/18/99 r 19060-D2
To:
PHOENIX UmUSTRIAL INe
PO BOX 356
CAt'lI' HILL PA 17011
Shipped To:
HISTORICAL SOCIETY
COR..'mR OF GREENBRL<ill LAi'IE & HBG PIKE
DILLSBURG PA 17019
TERMS OF SALE: 30 DAYS NET: 1% INTEREST PER MONTH ON OVERDUE ACCOUNTS
Customer 10: Date Shipped Shipped Via eOL PP F,O.B. Point Terms Your Order Number
PHOENIX 01060 10/05/99 USF REDS'L<ill X ,~CTO?:~ )Ie:. 30 Davs
_Qesc~ption Amount
TOILET PARTITIONS :lFG BY FLUSH-METAL PARTITION AS PER APPROV.-U.S 1 3-- 00
, n.
PLEASE PAY FROM THIS INVOICE
Subtotal
Sales Tax
Total Invoice Amount
Payment Received
TOTAL
1,375.00
82.50
1,457.50
0.00
1,457.50
BE ADVISED THAT IF THIS INVOICE GOES
BEYOND OUR TERMS OF PAYMENT, IT WILL
BE NECESSARY UNDER THE BONDING
REQUIREMENTS TO NOTIFY YOUR
BONDING COMPANY, ARCHITECT, OWNER
AND OTHERS ON THE SIXTIETH DAY FROM
THE DATE OF THIS INVOICE.
NO PARTIAL PAYMENTS, RETAINAGES, BACKCHARGES
OR LIQUIDATED DAMAGES MAY BE DEDUCTED FROM
THIS INVOICE WITHOUT PRIOR WRITTEN APPROVAL
FEDERAL 10 '#23-2984787
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VERIFICATION
COMPANY NAME: MASON-NORTON COMPANY, INC.
I verify that the statements made in the foregoing Complaint 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.
Dated: Q,,v€" 14, ;((/od
~1'
SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-03762 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
""'-itl"";
MASON-NORTON COMPANY INC
VS
PHOENIX INDUSTRIAL INC
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
PHOENIX INDUSTRIAL INC
the
DEFENDANT
, at 0013:10 HOURS, on the 21st day of June
, 2000
at 950 WOODLAND ST
CAMP HILL, PA 17011
by handing to
DAN BEIGH (OWNER)
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
Service
Affidavit
Surcharge
So Answers:
18.00
7.44
.00
10.00
.00
35.44
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R. Thomas Kline
06/22/2000
PURCELL, KRUG & HALLER
Sworn and Subscribed to before
me this 1.;1 Q-- day of
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Ch:.L C' ~Pf}I~ ~ #'
rothonotary ,
By:
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Deputy Sheriff
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MASON-NORTON COMPANY, lNC.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2000 - 03762
PHOENIX INDUSTRIAL, lNC.,
Defendant
: CIVIL ACTION-LAW
PRAECIPE
TO THE PROTHONOTARY:
Please enter judgment in favor of the Plaintiff and against the Defendant for
failure to file an Answer to the Complaint within twenty days of service, and after
Ten Days Notice of Default dated July 12, 2000 pursuant to Pa. R.C.P. 237.1 in the
amount of $2,003.40 plus continuing interest at the rate of 12% per annum as follows:
Principal
Interest through 10/16/00
$2,003.40
223.22
Total
$2,226.62
I hereby certify that Notice was given in accordance with the above referenced
Rule:
Respectfully submitted,
PURCELL, KRUG & HALLER
BY
o W. Purcel,
1. . #29955
19 North Front Street
Harrtsburg, PA 17102
(717) 234-4178
Dated
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MASON-NORTON COMPANY, INC" : IN THE COUET OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO, 2000-03762
PHOENIX I INDUSTRIAL, INC"
Defendant
: CIVIL ACTION-LAW
IMPORTANT NOTICE
TO: PHOENIX INDUSTRIAL, INC.
4590 INDUSTRIAL PARK ROAD
CAMP HILL, P A 17043
DATE OF NOTICE: JULY 12,2000
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN 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 (800) 990-9108
BY
. Purcell, Jr.
.D. 955
9 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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NOTICIA IMPORTANTE
TO: PHOENIX INDUSTRIAL, INC.
4590 INDUSTRIAL PARK ROAD
CAMP HILL, PA 17043
FECHA DE NOTICIA: JULY 12, 2000
USTED NO HA COMPLIDO CON EL A VISO ANTERIOR PORQUE HA F AL T ADO EN
TOMAR MEDIDAS REQUERIDAS RESPECTO A ESTE,CASO. SI USTED NO ACUTA
DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN
F ALLO SERIA RESITRADO CONTRA USTED SIN UNA AUDENCIA Y USTED PODRIA
PERDER SU PROPIEDAD 0 OTROS DERECHOS IMPORTANTES. USTED DE BE LLEV AR
ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE ABOGADO 0 NO
TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABAOGADO, VAYA 0 LLAME A LA
OFICINA ABAJO PARA A VERIGUAR A DONDE USTED PUEDE OBTENER LA A YUDA
LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
- . Carlisle, PA 17013
(717) 249-3166 (800) 990-9108
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MASON-NORTON COMPANY, INC.
Plnillt.iff
: IN TilE COURT Of COMMON PLEAS
:CUlfiliERLAND COUNTY, PENNSYLVANI A
vs.
PHOENIX INDUSTRIAL, INC.,
CIVIL ACTION - LAW
Defendilnt
NO . 2000-03726
To Phoenix Industrial, Inc.
Defendant(s)
You are hereby notified that on (}~.2.Y
, Jt!fJ.:Ji>1/i) the following (~) (~)
TJi.ldgmentJllas-ubeen-entered ogainst you in the above-.
cilptione(l cnse.
F:dlnrp "to filp ~n AnAlATPr Tn rhp, rnmp1 :::lint- Tl,,-lgmont ]1"'1
the amount of $2,003.40 plus continuing interest, late charges
:::lnrl l?Xrens.e.s
D^TE: (]J~ :L.'f,.:J.uv-o
14cG,,-r;;; r? ~ ,~
Prothonotary . I
I hereby certify that the name and address of the
[,roper persorl(R) to receive tIlls notice is:
..1'hQ~nix Indust:!:ial, Inc.
4590 Industrial Park Road
Camp Hill, PA
17043
^ Phoenix Industrial, Inc.
De ('end ido/"
Defendidos/as
Par este me(lio se 1e esta notificando que e1
de del 19 ,el/la siguiente
(m:xmii,j-;--rl~T. (rnllo/h'" sido anotaoo en contra
SIlYil en e1 caso Incnci.OIl1ldo en e.l epLgraEe.
f'P.CII^:
Tit, o tonot a r io.
Certifico <]uo 1" ~ig\1iente direccion es la del
defendido/a segun illdicnda en el certificado de
residencia:
Phoenix Industrial, Inc.
4590 Industrial Park Road
Camp Hill, PA
17043
^bog<3do del Demandante
DCBA-400-Rule 236(a)(2)-8/1/89
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