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Home My WebLink About97-00220 \~\ \1 i \J \. ~ ~ ., ~ t o i i l? '> v u ... ~ tl L1 ~ , ! - \I. ~ q () - . l.1 ~ "1 ~ ~~ ~d "~ '. \ I ! - . , .:) ~ ~I ~I ! Leisawitz Heller Abramowitch Phillips, p,e. Attorneys at [aw IIlan 9, I]askln 1951,1990 IIlan (j, Ceisawitz MervTn II, Heller. "Jr, <Jalj IIbramowitch t:harles <], Phillips William R, I]lumer' IIl1en R, Shollenberger Robert <], Kirwan. II KevIn II. Moore Kathleen I/. 1], Kovach Douglas paul Rauch Kenneth Millman <]onathan R, Wachs" October 19, 1999 . c.l.M 'Taxation .. Admittrd to practice "" Mary/arid. Conntrticut""" D.C. on/I} Wayne F. Shade, Esquire 53 West Pomfret Street Carlisle, PA 17013-3217 VIA FACSIMILE 717-249-0017 & REGULAR MAIL Re: Professional Resource Group, Inc. v, CompSource, Inc. Cumberland County CCP, Civil Action No. 97-220 Civil Tenn Dear Attorney Shade: This letter will confirm our telephone conversation of Monday, October 18, 1999 with reference to the above-captioned action. Please accept this letter as the explanation of the events resulting in the Praecipe to Settle, Discontinue and End this case not being filed. While this case was pending Arbitration, the parties reached a settlement which was executed in March 1998. The Settlement Agreement provided for three payments made over time. Once the payments were completed, the Agreement provided that Plaintiff would file a Praecipe to Settle, Discontinue and End. By letter dated May 11. 1998 this office forwarded the final payment to Plaintiff and requested a copy of the Praecipe to Settle, Discontinue and End. However. the Praecipe to Settle, Discontinue and End was never filed, rather, Defendant, without the benefit of counsel. filed a District Justice action before OJ Placey to CV- 376-98 alleging that the final payment was one day late. I later confirmed that Attorney Craig Diehl, who represented Plaintiff in the above-captioned action refused to represent his client in this matter. After I informed DJ Placey that I would not be appearing for the OJ Hearing, Criminal Contempt Proceedings were initiated against me, I later clarified these issues with OJ Placey in a letter dated October 20, 1998. which is attached. We took a de novo appeal from the District Justice action in October of 1998, and before any Complaint was filed in the Court of Common Pleas, the matter was resolved by and through the execution of a Settlement Agreement and General Release which was tied to the 1998 docket number 98-6039. That Settlement Agreement and Release did not include language providing for the settlement, discontinuance and end of the 1997 action. !Je,ksll/,e Commons Suite 400 2201 nldgewood noad Wyomlss/ng. P"'- 19610-1193 fJ~'m1(' (Glr)) 37) 35{){j t0x (fJlO) "~1) 8fj71 r:. mill! kHUXJ'CGlJUfl1jJhlWlOH1 lIH N()fUI'rhl,(I~rll d l/am/JWlf. INI 1')';/1) (',10) 'JI) Ij/lj') 138 N 'Jlh 0..;,,, d r'lwlim/ 1711 ")fj01 ((JI()) ~/} ~')n(J I :~~, 1 To: Wayne Shade, Esquire Re: Professional Resource Group, Inc, v, CompSource, IIlC, Date: October 14, 1999 Page: 2 By copy of this letter, 1 am asking Attorney Craig Diehl, lhe attorney of record in the 1997 action, to liIe the appropriate Praecipe to Settle, Discontinue and End, as 1 arn unable to do so representing the Defendant in that action. 1 trust this letter clarities the situation for you. 1 regret any inconvenience the delay has caused you. If you have any questions regarding the content of this letter, please do not hesitate to contact me. Very truly yours, LEISAWITZ HEUER AORAMOW/TCII PIIILLlPS, P.c. / /' /.-,-~ ~-/~ .' KEVIN A. MOORE KAM:bel 32465.010 Enclosure cc: Craig Diehl, Esquire 11\1'1 W A \'NE F. SIIADE ^ Ill)R,~I,\' ^" ^,v ~JI\'IS11~J\IIRI,I\nll:ll CARlISI 1'.1'1 ~"\\'1 V^~I^ IlUIl 171712H.()220 1&001 24J.o220 f^XI7l7ll~9.{l()ll September IS, 1999 Craig A. Diehl. Esquire Attorney-at-Law 3464 Trindle Road Camp Hill, Pennsylvania 170 II Ke\'in A. Moore. Esquire Baskin Leisawitz Heller & Abramowitch, P.C. 220 I Ridgewood Road Wyomissing, Pennsylvania 19610-1193 Re: Professional Resource Group, Inc. v. CompSource, Inc. No. 97-220 Civil Tcnn Gentlemen: You may recall our letter of July 20. 1999, with respect to the above. In response, we received a letter from Mr. Moore covering a Praecipe to Discontinue. However, the caption of that case indicated that it was docketed to No. 98-6039 Civil Tenn rather than the No. 97-220 Civil Tenn to which this office was appointed as Chainnan of the Board of Arbitrators. Before we alert the Court to the fact that the case at No. 97-220 Civil Tenn remains an open case, we wanted to give you an opportunity to educate us on the relationship, if any, between the two cases. Very truly yours, Wayne F. Shade WFS/cjt JIL-27 1 'J'J'J 1G: 10 DASKIN LEISAWITZ HELLeR Gl0 372 OG71 r.02/04 uw 0IIIm Alan o. LcIuWIt1 M....InA.H,U...lr. J.y N. AbrllllOWtldl CIwIM I. PblWpt WIWa.III R. Blumor t AlIto R. SIlolllaboq.r Robcn I. Kirw&ll. D JCn In ". t.loott lCIllllMo A.B. Komb DauaIu P. .....h K.....lbMIIIIIlIl\ Baski Leisawitz 'JI}, HeUer61 Abramowitch, P. C. 171 Ncnlt Thlrd 5_1 Hamburl. PA 19'26 (610) '62--414' '. III N. '11I5",.. RIIdioa, PA 1ge01 (610) 372.3'00 IIorklbln Coounons "'I"~ 2201 Rid&1To'Olld Rood W)'CClIiIIicc, PA 1~1()'1l03 (610) m.]jOO PAX (610)372..671 e-Mail kmoorcOt..l.... July 27, 1999 .4"'" I. ..,kIII mZ.JgPO 'LLM II TWlloI Wayne F. Shade, Esquire 53 West Pomfret Street Carlisle, PA 17013-3217 VIA FACSIMILE R,: Pro/'SJiorud Rtsourct Group, Inc. 1'. CIlmpSourt:t. Inc. Dear Wayne: , , ! I I '1 Enclosed please fmd a time-stamped copy of the Praecipe to Discontinue with respect to the above-caption case. Should you have any questions, please do not hesitate to contact me. Very truly yours, BA3KlN LEISA. WlTZ H1IUER & ABRAMOWlTCll, P. C. /1V/I1.A ~U KEvIN A. MOORE KAM:bel 32465.010 Enclosure JUL-27-1999 16:10 DASI< I N LE I SAW IlZ HELLER 610 372 0671 P.03/04 '- 0, Plaintiff IN THE COUll.T OF COMMON PLEAS OF CUMBERLAND COUN'l'Y, PENNSYLVANIA NO. 98-6039 CIVIL TE PROFESSIONAL RESOURCE GROUP. INC., v. CIVIL ACTION - UAW COMPSOURCE, INC., Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: please mark the above-captioned matter "Plaintiff full and case discontinued with prejudice." LAW OFFICES OF CRAIG A. DIEHL Oar-ed: . DUltftlY H IH~ By: ~.lr~ Craig A. Diehl, Esquire Attorney ID No. 52801 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Attorney for Plaintiff T '..0 n c.... "11 -, "T, " , r", . , .,'J ;"::., ... c. :~'. I I , '0 l:-.:. (..': :7 '.. .. ..... irJ ~.. :".'..) .. ('1 . ~CI :~', . ":? '.'l-fit , ~ ~., ~~ IX) :1) .... Law Offices of Craig A. Diehl ~4M Trimlle Road Camp Hill.l'el1n~ylvania 17011 ~@[JJW Telephone (717) 763-76D TeleCllpier (717) 76~-R2l)J Craig A, Diehl. Esquire. C.P.A, Linda A. Cllllfeller, Esquire In Spring Grove. Pennsylvania 119 Wesl Hanover Street Spring Grove. PA 17362 Telephone: (717) 22~-1929 July 26, 1999 Office of the Court Administrator Cumberland County Court of Common Pleas One Courthouse Square Carlisle.PA 17013 RE: Professional Resource Group v. Compsource. Inc. Dear Court Administrator: Please be advised that the above-referenced proceeding was sellled prior to the arbitration hearing. Kindly make note of this and vacate the appointment of the Board of Arbitrators. Sincerely, ~~a. !J:d Craig A. Diehl, Esquire CAD:her cc: L wn)'ne F. Shade, Esquire Robert p. Nelson I ~ , WAYNE F. SHADE AlTOllNEY AT LAW II WEST I'OMFIlET STREET CARLISLE, PENNSYLVAN1^ 1701l :' t717l20-4220 (800) 14l-4UO FAX(717)249.{J()17 July 20, 1999 Craig A. Diehl, Esquire Attorney-at-Law 3464 Trindle Road Camp Hill, Pennsylvania 17011 Kevin A. Moore, Esquire Baskin Leisawitz Heller & Abramowitch, P.C. 220 I Ridgewood Road Wyomissing, Pennsylvania 19610-1193 Re: Professional Resource Group, Inc. v. Compsource, Inc. t I '- Gentlemen: , , I I . Enclosed is a copy of a letter from the Office of the Court Administrator. . Please contact that office and advise of your intentions with a copy to this office. Very truly yours, Wayne F. Shade WFS/cjt Enclosure ~~~. fJ)I ::;~ ;~'r7'Q1 t' Richerd J. Plorce Cou~ Admmlslralor OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT OF COMMON PLEAS 1 Cou~house Square' Carlisle. PA 17013 Phono Teryn N. Dixon (717) 240.6200 Assislant Court Administralor (717) 69700371 (717) 53207286 (717) 24006462 FAX ~ July 16, 1999 Wayne F. Shade, Esq. 53 W. Pomfret St. Carlisle, PA 17013.3217 Dear Mr. Shade: I am writing to you in regards to Professional Resource v. Compsource. On June 16,1997, you were assigned as chairperson in the above mentioned case. Currently the Prothonotary's docket indicates no settlement or disposition. On behalf of the Court of Common Pleas of Cumberland County, we arc asking you to contact the litigants and notify the court by August I, 1999, of your findings. We realize that many of the delays involved in this case may be of no fault of your own. However, should the court not receive adequate information regarding the status of this case, the court will vacate the appointment of this Board of Arbitrators. Sincerely, CJv~rUJ-. O~~ - Christine Anthony Office Intern l..."OfTktl Alan G. lelsawlll Mcr"lOA. Hellcr.1r. Jay N. ,\hramllwlldt TIUlOlU W, Deaver Randy A. Rahcnuld.t Charles J. Plullips Wilham R. U1umer t Allen R. Shnllenbtrger Roben J. Kirwan. 11 Kevln'\. Moore Douglas P. Raul:h Baskin Leisawitz& Heller Abramowitch, P. C. 13M N. ~Ih Succi Rudll1g, PA IlJhOI 17H Nonh TIurd SUCCI lIamhurK. PA 1I)~2h lfllOl ~h2--'14S ISI We\IIIlKhSueel WnmelsdtJrt'. I'A 11)~h7 u'>101 ~HI).2().l3 Derk\tllre Cllmmnm SUlle 4()() 22tH RldRewlXllI Ruad WynmlSslnlf. PA \IJhIO.l (in (hill) J72.K427 FAX Ihlllll7lHhll Kathleen A.D. Kuvach. Cuun5el Alan I, 8aj~ln 19n199t) .-'1..., Mrmlltr l)llUII:IIlI ("ul\lmllllllal tLLMm rU111I1II October IS, 1997 Craig A. Diehl, Esquire Law Offices of Craig A. Diehl 3464 Trindle Road Camp Hill, PA 17011 Re: Professional Resource Group, Inc. v. CompSource, Inc. Cumberland County CCP Docket No. 97-220 Dear Mr. Diehl: A review of this file indicates that you were served with discovery on or about July 23, 1997, which you have not yet responded to. In addition. I further requested that you provide me with available dates for which to depose Mr. Seo, and have not yet received any possible dates from you. In order to move this case forward. I am requesting that you respond to discovery on or before October 31, 1997, and that you provide me with possible dates in November for Mr. Seo's Deposition. As you may recall during a previous telephone conversation. I agreed that Mr. Seo's Deposition will take place in your offices. This will further cClnfinn our agreement that the Arbitration in this matter shall take place as soon as practical followi,"~ Mr. Seo's Deposition. and once we confinn the date of Mr. Seo's Deposition. we will imonn the Panel of our availability for the Arbitration thereafter. Thank you for your cooperation in this matter. Very truly yours, BASKIN LEISAWITZ HELLER & ABRAMOWITCH, P.C. /{/ ,?pz~ KEVIN A. MOORE KAM:smm/32465.01O cc: Russell A. Hinnershilz Charles J. Phillips. Esquire Wayne F. Shade, Esquire - Arbitrator Chainnan ~ r !' '-"~"'" .,~~ . utl~. ,-qt, ._,.- . Lo. otlka Alan O. U:WWlll Mc~in A. Heller. Jr. /ly N. AbrunowllJ:b TIwmu W. Beaver Randy A, Rabeoold'f Charles I. Phillip. William R. Blumer f AUcn R. Shollcnbcr&cr Roben I. Klrwln. II Kevin A. Moore Doualu P. Rauch Baskin Leisawitz& Heller Abramowitch, P. C. Il8 N,'tb Su<er R.ldllll. PA 19601 178 Nonlt Third s..... IIlmbuq, PA 19'26 (610) 562--4145 .^IIO Mcmbet DIIU'K1 ofCoIymbll BaI tlLM In TU&1I011 DcrluiUre Cnmmoru Suite 400 220 I Rida'wood Rold WyomlS.lIll. PA 1%lo-lI9l (610) l72-8427 FAX 1610) In.867\ I' I W.stlllah S"'OI Womclsdorl, PA 19'67 (610) '89-200 K.ttbl..n A,S. KoYlcb 0 CllWlICl Alan I. &utln JgJ2ol990 July 17, 1997 Craig A. Diehl, Esquire Law Offices of Craig A. Diehl 3464 Trindle Road Camp Hill, PA 17011 Re: Professional Resource Group, Inc. v. CompSource, Inc. Cumberland County CCP Docket No. 97-220 Dear Mr. Diehl: This letter confinns the substance of our recent telephone conversation wherein we agreed that the Deposition of your client. Mr. Seo, will take place in your offices as soon as we confmn dates. In addition, I will send you a Request for Production of Documents which I would ask be responded to within three (3) days prior to the Deposition of Mr. Seo. Very truly yours, This will further confinn our agreement that the Arbitration in this matter shall take place as soon as practical following Mr. Seo's Deposition, and once we confmn the date of Mr. Seo's Deposition, we will infonn the Panel of our availability for the Arbitration thereafter. Thank you for your cooperation in this matter. BASKIN LEISA WITZ HELLER & ABRAMOWITCH, P.C. j:'/ ~ KEVIN A. MOORE KAM:smm/32465.01O cc: Russell A. HinnershilZ Charles J. Phillips, Esquire Way~ F. Shade, Esquire - Arbitrator Chairman Law Offices of Craig A. Diehl 3464 Trindle Road Camp Hill, Penmylvania 17011 ~(IDlPW i r " Telephone (717) 763-7613 Teleeopier (717) 763-8293 Craig A. Dichl, Esquirc, C.P.A. Thomas J. Rozman, Esquirc Jeffrcy C. G055, Esquirc In Spring Grove, PennsylvAnia 402 NOrlh Main Slreet Spring Grove, PA 17362 Telephone: (717) 225-1929 July 1, 1997 Kevin A. Moore, Esquire BASKIN, LEISAWITZ, HELLER & ABRAMOWITCH, P.C. Berkshire Commons Suite 400 2201 Ridgewood Road Wyomissing, PA 19610-1193 RE: Professional Resource Group, Inc. v. CompSource, Inc. .f ! i Dear Mr. Moore: I attempted to contact you regarding your correspondence dated June 27, 1997. Unfortunately, it is my position that the contents of said correspondence are unfounded. Initially, I believe the pleadings are closed. On what basis you may believe the pleadings are still open has me somewhat disturbed. Defendant's Answer with New Matter was filed in February, 1997 with no notice to defend nor endorsed with a notice to plead. Accordingly, pursuant to Pa. Rule of Civil Procedure 1026, no response is required. Secondly, you suggest that a violation of the Cumberland County local rules occurred because you did not receive a copy of the Petition for Appointment of Arbitrators. Notwithstanding the fact that I do not believe such a rule exists, as a professional courtesy, I apologize if a secretary from this firm did not send you a courtesy copy. Finally, your statement on discovery is more troublesome. Four months have elapsed since the final pleading occurred. I believe if it was your true intent to conduct discovery, more than sufficient time has elapsed. It is my client's position that your comments are only serving as a dilatory tactic. ~ r :;. Kevin A. Moore, Esquire July 1, 1997 Page Two If it is your desire to spend money on a Motion for Reconsideration and travel to Carlisle to present it, that is obviously your choice, If your Motion has merit other than what I have seen so far, we will not object, However, if the same meritless considerations are raised, we will vigorously object. Sincerely, Sr~ l[:;, I , 1. Esquire cc: ~ne Shade, Esquire Mr. Robert Nelson ,I , ~ i i I CAD: her .. .... ..~.**..**..**************..***.***.~.*..***..*...*..**....***.*.* \ - ,~ P. 01 'I · TRfltlSACT I 011 REPORT . * JUN-24-97 TUE 15:47 . . . * DATE START RECEIVER TX TIME PAGES NOTE * * --- -- ,I * JUN-24 15:45 16103728E71 1'14" 2 OK . * * ***************.*.**..*.*.***********..**.***..*********...*...... ~ ~ ~ l' ~ ~ ~ ,l)..\:. ~J. d . ~ ~ ';;) . '-" - .lib 0' -' .... C l,~ i:~ \1)(-! U. 11:: ,'- Lr"\:, C. , -' L" I. ~: '1\ . 'I_ I I' U \- ," .." 0.' _\ . ~'. ".j . " ,0! .co . ~~, '- r- O' "' o !i! Iii ~ !!! ~ if ~ ~ z ~ ~ " ~~~ ~;~1;~ ~ l:5 ~ o ~ en 1; ~ ~;: ~ u:~~~u. l!i ~ ~ ~ ~ J!';;: ~ .J ~~1; '" J ,. .' . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROFESSIONAL RESOURCE GROUP, INC., Plaintiff No. 97-220 Civil Term va. COMPSOURCE, INC., Defendant PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Craig A. Diehl, counsel for Plaintiff in the above action, respectfully represents that: 1. The above captioned action is at issue. 2. The claim of the plaintiff in the action is $ 13,303.80 plus interest from June 30, 1995 at the legal rate of 6% per annum and costs of suit, $113.50 (Arbitration, $15.00, Complaint, $45.00, and Sheriff, $53.00). The following attorneys are interested in the case as counsel: Craig A. Diehl, Esquire LAW OFFICES OF CRAIG A. DIEHL 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Kevin A. Moore BASKIN LEISAWITZ HELLER & ABRAMOWITCH, P.C. Berkshire Commons, Suite 400 2201 Ridgewood Road WY8misq;n~, p~ 19610-1393 (610) 372-8671 WHEREFORE, Petitioner prays for this Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. By: c~~ tc(~t Crai A. Diehl, Esquire Attorney for the Plaintiff SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1997-00220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND P_RIW~::?SION~I~ Rl':SOURCE GROUP VS. CllMPSllURCE. IN.G _H. _ Tht;lJ1!;;IJL_It\.t!1lL ' Sheriff. who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: COMPSOURCE INe ~. ------ --- ---------- ---.- but was unablp. to locate Them tn his bai liwick. He therefore County, Pennsylvania. deputized the sheriff of BERKS to serve the within COMPLAINT On January 27th. 1997 . this office was in receipt of BERKS County, Pennsylvania. the attached return from Shp.riff's Costs: So answers: Docketing 18.00 - Out of County 9,00 -.. . "''''~ -- Surcharge 2.00 H. Ihomas 1\11.ne, ::;her111 Berks County 24.00 $53.00 CRAIG A, DIEHL 01 /27/1997 Sworn and"" sUbscrtbetJ~Lo before this .) C, - . day of ~ 19 '11_ A.D. me Ci C- ~ 'J -r~ ProthOriot.ar1~ I SHERIFF OF BERKS COUNTY 633 Court Street Reading, Pennsylvania 19601 BARRY J, JOZWIAK SHERIFF PHONE (810) 478-8240 FAX (810) 478.8222 ANDREW G. HUGHES CHIEF DEPUTY SHERIFF'S RETURN DOCKET NO.97-220 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BERKS :55: Personally appeared before me, CINDY TOOLE, Deputy for Barry J, Jozwiak, Sheriff of Berks County, Pennsylvania, who being duly sworn according to law, deposes and says that on JANUARY 21, 1997 at 2.52 P.M., she served the annexed COMPLAINT & NOTICE upon COMPSOURCE, INC, within named defendant, by handing to BEVERLY HINNERSHITZ, ADMINISTRATOR, and person in chargeCOPIES THEREOF,at 546 PENN AVE., WEST READING BOROUGH, BERKS COUNTY, PA and made . known to defendant the contents thereof. PA subscribed before me day of J UARY, 1997 CO., PA Service made as set forth above, NOTARIAL SEAL .nmt M GAqOECKl, Nou'y Pu~" BERN",,' PA Readtng. Ber1csCounty,. M MyCOfOOlI,SionElo"'" t.-." So Answers, o F BERKS Sheriff's Costs in Above Proceedings $ 75.00 $ 24.00 $ 51. 00 DEPOS IT ACTUAL COST OF CASE REFUND ATTACHED Refund check II: All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all unpaid sheriff's fees on the Same before he shall be obligated by law to make return thereof. _Sec. 2, Act of June 20, 1911, P.L. 1072 h. luser.lou.anlkev;n. mlpleadinglcmp.rcan.12/27107Irjw PROFESSIONAL RESOURCE GROUP, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. No. 97-220 CIVIL TERM COMPSOURCE, INC., Defendant DEFENDANT'S ANSWER WITH NEW MA TIER TO PLAINTIFF'S COMPLAINT AND NOW, Defendant, Camp Source, Inc. Va Microage Computer Centers by and through its counsel, Charles J. Phillips, Esquire, Kevin A. Moore, Esquire, and Baskin Leisawitz Heller & Abramowitch, files the within Answer to Plaintiff, Professional Resource Group, Inc.'s ("Plaintiff') Complaint and in support thereof avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part and Denied in part. It is admitted that Plaintiff and Plaintiffs employee kept some itemized time records of hours incurred on behalf of the Defendant. It is denied that Plaintiff and Plaintiffs employee kept itemized time records of all hours incurred on behalf of Defendant, and it is further denied that Plaintiffs employee performed any services on behalf of Defendant during all the hours averred by Plaintiff. To the contrary, Plaintiffs employee who initially submitted itemized time records to Defendant gradually ignored these requirements and would load up his time 1 l t , I ,. h :Iu serslsusanlllevIn. mlpleadinglcmpsrc ansl2/27/97Irjw sheets and invoices at the end of the parties' relationship, seeking payment for unapproved and unreviewed work. 6. Denied. It is specifically denied that invoices were timely and continually mailed to Defendant itemizing said individuals time incurred for professional services rendered without dispute by Defendant. To the contrary, invoices were neither timely nor continually mailed to Defendant, nor did said Plaintiffs employee perform professional services during the total amount of time set forth in the Plaintiffs invoices. It is further denied that Defendant did not dispute said hours, to the contrary Defendant repeatedly questioned and challenged the invoices and time sheets submitted by Plaintiff for various reasons, including but not limited to, non-performance of work for the hours listed, non-attendance at the client's facilities during the hours listed, and failure to accurately report hours. 7. Admitted. 8. Admitted in part and Denied in part. It is admitted that Plaintiff has made payments to Defendant. It is further admitted that an outstanding balance on Defendant's account exists, It is specifically denied that said payments were made sporadically and it is further denied that the outstanding balance owed to Plaintiff in the amount of Thirteen Thousand Three Hundred Three Dollars and Eighty Cents ($13,303.80). To the contrary, Defendant properly asserted charge backs to Plaintiff on account of improper, inadequate, and fraudulent billing statements submitted by Plaintiffs employee. By way of further answer, Defendant speCifically denies that the information set forth in Exhibit "B" accurately reflects the outstanding balance on its account as set forth more fully above andlor Plaintiff has failed to properly credit Defendant's account. 2 h :Iuserslsu.anlkevin. mlpleodlnglcmpsrc onsl'2/27/97Irjw VERIFICATION ,. I, RUSSELL HINNERSHITZ, President of COMP SOURCE, INC. verify that the attached Answer with New Matter is based upon information which I have furnished to my counsel and information which has been gathered by counsel in the preparation of the prosecution of the within lawsuit. The language of the Answer with New Matter is that of counsel. I have read the attached Answer with New Matter and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the attached Answer with New Matter is that of counsel, I have relied upon counsel in making this verification. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. (c~m)ourCe,\I,n~. : '. j'Y,~Li.I!lcLt / Russell Hinnershitz President qtY"7 5 h :\userslsusanlkevin. mlpleadinglcmpsrC.cerl2/27/g7lrjw ~ r PROFESSIONAL RESOURCE GROUP, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. No. 97-220 CIVIL TERM COMPSOURCE, INC., Defendant BY: ,///'."...- //-,' /_'n . n, ./ //---:__ ~. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the "Defendant's Answer with New Matter to Plaintiffs Complaint" was this day served via Facsimile upon the following: Craig A. Diehl, Esquire Law Offices of Craig A. Diehl 3464 Trindle Road Camp Hill, PA 17011 I understand that statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Respectfully Submitted: BASKIN LEISAWITZ HELLER & ABRAMOWITCH, P.C. CHARLES J. PHILLIPS, ESQUIRE Attorney 1.0. No. 39260 KEVIN A. MOORE, ESQUIRE Attorney 1.0. No, 75068 Attorneys for Defendant 2201 Ridgewood Road, Suite 400 Wyomissing, P A 19610-1193 610-372-8427 Dated: February 27, 1997 1 ..... In -- t" " c-; '. .. lJ)c Ul ~ (:1- LJ. . C l!. C " :i I ' "n -, r , " (',,: "- r , ~ r J I. I '. '0 I. r- C 'J' l) - PROFESSIONAL RESOURCE GROUP, INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff I NO. 97-220 CIVIL TERM i. " v. CIVIL ACTION - LAW COMPSOURCE, INC., Defendant TO: CompSource, Inc. c/o Kevin A. Moore, Esquire BASKIN LEISAWITZ HELLER & ABRAMOWITCH, P.C. Berkshire Commons, Suite 400 2201 Ridgewood Road Wyomissing, PA 19610-1193 DATE OF NOTICE: February 17, 1997 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM i .\ I , I 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 Lawyer Referral Service Cumberland County Courthouse Third Floor Carlisle, PA 17013 (717) 249-1133 or (717) 697-0371 LAW OFFICES OF CRAIG A. DIEHL ~ By: Craig 'A. Diehl, Esquire Attorney ID No. 52801 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Attorneys for Plaintiff PROFESSIONAL RESOURCE GROUP, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, !I;G - Q~. .nn CIVIL TERM v. CIVIL ACTION - LAW COMPSOURCE, INC., Defendant NOTICIA Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siquinetes, usted tiene viente (2) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defenses 0 sus objectiones 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 privio aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero a sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI TO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAiA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONeE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY COURT ADMINISTRATOR Cumberland County Courthouse Third Floor Carlisle, PA 17013 (717) 249-1133 or (717) 697-0371 PROFESSIONAL RESOURCE GROUP, INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~-97.;l:lCI CIVIL TERM CIVIL ACTION - LAW v. COMPSOURCE, INC" Defendant COMPLAINT AND NOW, this ~ day of January, 1997, comes Professional Resource Group, Inc. ("Plaintiff"), by and through its counsel, Law Offices of Craig A. Diehl, and files this Complaint against CompSource, Inc. ("Defendant") of which the following is a statement: 1. The Plaintiff is Professional Resource Group, Inc., a Pennsylvania corporation, whose principal address is Southpoint Offices, Suite E, 1001 South Market Street, Mechanicsburg, Pennsylvania 17055. 2. The Defendant is CompSource, Inc., a Pennsylvania corporation, whose principal address is 546 Penn Avenue, West Reading, Pennsylvania 19611. 3. Beginning on or about March, 1995 through August, 1996, the Defendant contracted with Plaintiff to utilize Plaintiff's employee, Anthony Seo, to perform programming and other like services for Plaintiff. (See Exhibit IlAII for copy of Subcontractors Agreement) . 4. The Defendant contracted Mr. Seo to work on specific projects for its own clients including, but not limited to, Penn Treaty Life Insurance Company. 5. The Plaintiff and Plaintiff's employee kept itemized time records of hours incurred on behalf of Defendant. 6. Invoices were timely and continually mailed to Defendant itemizing said individual's time incurred for professional services rendered without dispute by Defendant. 7. Defendant formally notified Plaintiff of a dispute over the billing subsequent to Plaintiff's counsel writing Defendant on September 17, 1996 demanding payment of any outstanding balance. 8. Although some payments have been made sporadically by Defendant, there still is a delinquent outstanding balance owed to Plaintiff in the amount of $13,303.80 as shown by the statement of account, a copy of which is attached hereto, marked Exhibit "B" and incorporated herein by reference. 9. Demand for payment on this account has been made on September 17, 1996. In spite of this demand, Defendant has refused to pay said balance of $13,303.80 plus interest at the legal rate. WHEREFORE, Plaintiff demands judgment against Defendant in the sum of $13,303.80 plus interest from June 30, 1995 at the legal rate of 6\ per annum and costs of suit. Pursuant to Cumberland County Local Rules, the amount claimed falls within the jurisdictional amount requiring arbitration. LAW OFFICES OF CRAIG A. DIEHL By: C~ l;:A.f Craig A. D1ehl, Esqu1re 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 Attorney ID No. 52801 Attorneys for Plaintiff 1 ~ PROFESSIONAL RESOURCE GROUP, INC., IN THE COURT OF COMMON PLEAS OF CUMBERUAND COUNTY, PENNSYLVANIA Plaintiff o No. 96- CIVIL TERM v. COMPSOURCE, INC., Defendant I CIVIL ACTION - LAW VERIFICATION I, THE UNDERSIGNED, VERIFY that the statements set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false . I .. Dated: 1:<'/,;2..::1/9l. . _ ~..;f?/~ Robert P. Nelson, President Professional Resource Group, Inc. I I I -\ r , ! statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unsworn falsification to authorities. Exhibit A SUBCONTRACTORS AGREEMENT In consideration of remuneration provided by ComllSource Inc.. 546 Penn Avenue. West ReadlnQ, PA 19611 (hereinafter called the COMPANY), for services provided by ProfessloMI Resource Groull. Inc.. Southllnlnt Offices Suite e, 1001 S. Market Street, MechanlcsburQ, PA 17055 [hereinafter called the SUBCONTRACTOR) at the facility of Penn Treatv Life Insurance Comllanv CUSTOMER), [hereinafter called the located at 3440 LehlQh Street. Allentown, PA 18103 the SUBCONTRACTOR agrees, warrants and covenants the following: 1. SUBCONTRACTOR agrees to be responsible' for the Worker's Compensation Insurance on Its employees. If any direct claim for Worker's Compensation benefits or awards Is asserted against the COMPANY by any of said employees or, In the event of death, by their personal representallve(s), then SUBCONTRACTOR shall Indemnify and hold the COMPANY harmless from and against any such clalm[s)to the extent of all benefits and awards, cost of litigation, disbursements and reasonable allorney fees the COMPANY may Incur In connection therewith. Upon written notice, SUBCONTRACTOR may defend the COMPANY, with COMPANY's approval, against such clalrn(s). 2. SUBCONTRACTOR agrees to Indemnify and hold the COMPANY harmless from any and all liability or expense Ihe COMPANY may Incur by reason of bodily Injury [Including death] to any person, or property damage, or both, solely and proximately caused by the act(s] of SUBCONTRACTOR and or SUBCONTRACTOR's employee(s] while performing work or services for you. 3. SUBCONTRACTOR agrees to provide, at Its own expense, an Indemnity Bond or I.,......"......... ...hl...... .""..... ..... rc'''':rod ~" tho "U"TC".u:t':' ~.' ~\' -.."" ~u.'nil thel '..O'ft' "'f 'h'. ".........11...__ f. "...., I.....'...... "'..... ~J ..... ~ I .."Co." 1.11 I.Il .,. ',J 10 I ''''tlll "" .. I.,) . I agreement. .r'N./</"'''NUO t1nvnv TNII'" w..I(~..S' c.-,. -/~t i',,~o'I.? NO" A~..n> 7i v""~U J"P~UPIt:A/'" y #4'Gon,.nn> 'i'R'DR To .f.,.1I "T ",,; Go<Im..cr; 1ZPJ1, c."i_. 4. SUBCONTRACTOR agrees to pay any and all Federal, State and miscellaneous taxes which are required to be paid by law, pursuanlto the employment of SUBCONTRACTOR by the COMPANY, and the SUBCONTRACTOR further agrees to Indemnify and hold the COMPANY harmless from any and all liability litigation or claims made by any Federal or Slate Revl!nue agency or any other entity for the payment of said taxes. S</{JJor~r r. A GR.al>fIf>oJ'r t,,; FFF4"crBi!7Wa7IJ "1<4- __4 SUBt:~""m"CTl/X) /IVDIIIIDlhf'. 1?l/lt, ~'~'J- 5. SUBCONTRACTOR agrees not 10 disclose, divulge, copy or reproduce any confidential malerlals or Information enlrusted to him, It or lis employees during the term of this agreement. 6. SUBCONTRACTOR agrees that any Invention, Improvement, or discovery, Including but not IImlled to all software, all documentation and all programs conceived or first actually reduced to practice by SUBCONTRACTOR or SUBCONTRACTOR's employees during the term of this agreement and In performance and provision of SUBCONTRACTOR's services thereunder, shall be assigned and shall become and remain the property of the CUSTOMER. 546 PENN AVENUE' WEST READING, PENNSYLVANIA 19611 . (610) 375-4231 . FAX (610) 375-6213 301 PENN AVENUE' SUITE 100 . WEST READING, PENNSYLVANIA 19611 . (610) 208-0510' FAX (610) 208-0516 dba MlcroAge Computer Centers I f .' \ SUBCONTRACTOR Agrotmonl Peg. 2. 7, SUBCONTRACTOR further agrees, covenants, and warrants Ihat all malerials, Including but wllhoul IImllatlon, all reports, programs malerials, tapes, card decks, listing, and any olher documentation prepared, crealed, wrilten or reduced to human readable fonn by the SUBCONTRACTOR during the term of this agreement and In perfonnance of sold services provided thereunder, shall remain the property of and belong exclusively to the CUSTOMER. 8. SUBCONTRACTOR agrees, covenants, and warrants that the SUBCONTRACTOR, lis employees, servants, or agents will not accepl employment dlroctly or Indirectly 01 the CUSTOMER, which would circumvent or olhelWlse destroy the contractual arrangement between the COMPANY and SUBCONTRACTOR, nor will the SUBCONTRACTOR, nor will the SUBCONTRACTOR st'!I~lIthe CUS;OM!:!R 0: place other ~mploye~e at tl10 CUSTOMER, lis subdivisions or subsidiaries during the term of employment pursuant to the tenns of this agreement and will continue to refrain from performing these prohlblled acts for a period of six ~ 3 [5] months fOllowing tennlnatlon of services provided purnuantlo this agreement. JJO": J'.rtr"".Ttr1 ... ; ~",vl 9. SUBCONTRACTOR agrees to bill the COMPANY bl.weekly by Invoice for services rendered during the past week. In addition, SUBCONTRACTOR agrees that it Is required to supply a verined statement, executed by and authorized signatory 0' the CUSTOMER or Company evidencing and veri'ylng lhe actual hours provided by the SUBCONTRACTOR In accordance wllh lis bl-weekly Involceo SUBCONTRACTOR agrees that COMPANY Is not required to pay any Invoice which Is not supported and accompanied by the a'orementloned verlned slalement supplied by the CUSTOMER. ~: J'L'Z"NoM:'".2. .,... 'P:J 3:.!!!!f, ~'6111 10. SUBCONTRACTOR agrees to adhere to CompSource, Inc.'s quality standards and reporting requlremenls Including, bul nol IImlled to, Weekly Time and Expense Report, and Project Workorder Document. I acknowledge that I have received copies of these documents and I understand how they are to be applied. Other projecl and time reporting fonns are 1?P1f acceptable I' approved 'or use by both the Com~any and the Subconlractor. P",,"U",,!7vrr- llJ,tr"R.r>:~vcrJ, ~ p'OJ".srmA~<~prrovod'" n) ~~."'..u. -1lI.rAGIZ.f!?"n To. ~/,J" 11. SUBCONTRACTOR agrees that II will be paid only 'or actual serviceS provided to the CUSTOMER, and that the SUBCONTRACTOR Is NOT enlltled to compensallon for over. time, sick days, holidays and CUSTOMER's closing 0' Its business 'or any reason. 12. SUBCONTRACTOR agrees that the provision 0' services pursuant to this agreement Is subject to tlnal approval by the CUSTOMER, and the SUBCONTRACTOR agrees to hold the COMPANY ha,.mless 0' all liability " tne CUSTOMER rejecls SUBCONTRACTOR for any reason. 13. The term SUBCONTRACTOR, 'or the purpose 0' Ihls agreement, shall mean the SUBCONTRACTOR, the SUBCONTRACTOR's company and the SUBCONTRACTOR's employees, servants, agents and any other pernon or enllty that the SUBCONTRACTOR uses or employs In any manner or 'orm In connecllon wllh the services provided pursuant to the tenns of this agreement. 14. SUBCONTRACTOR agrees and acknowledges that this agreement shall remain In full force and errect during lhe durallon 0' lis contraclual arrangement with the COMPANY and that II shall terminate al lhe complellon 0' lis performance 0' services 'or the CUSTOMER or upon term/nallon by ten [10J days written nollce. 15. SUBCONTRACTOR acknowledges that the CUSTOMER has estimated said assignment, work or project purnuant 10 this agreement, will require aporoxlmatetv 12 ~ to complete and the SUBCONTRACTOR agrees, covenants and warrants to provide exhibit B t '" CompSource Inc, " Outstanding Invoices December 17, 1996 Inl'Oice Finance Total Invoice note Invoice No. Amotlnt Cltarl!e Amotlnt nile 05/31/95 1537 2,115.00 0,00 2,115.00 06/28/95 1556 1,207.50 0.00 1,207.50 08/23/95 1586 1,650.00 0,00 1,650.00 11/15/95 1633 720.00 0.00 720.00 12/01/95 1638 562.50 0.00 562.50 01/25/96 1665 1,800.00 222.01 2,022.01 , 02/08/96 1675 1,770.00 202,95 1,972.95 l. 02/21/96 1682 900.00 95.40 995.40 i 04/03/96 1701 420.00 32,76 452,76 I 06/26/96 1737 480.00 10.88 490.88 I 07/10/96 1743 180.00 2.40 182.40 07/25/96 1752 720.00 2,40 722.40 08/07/96 1755 210.00 0.00 210.00 TOTAL 12,735.00 568.80 13,303.80 , e l " arranged between counsel. Further, to the extent any additional response beyond the ,. production of documents is made or required. the Requests are to be responded to in writing and served upon the undersigned within thirty (30) days of service on you. Objections must be made in writing, signed by the person making them and served upon the undersigned within thirty (30) days of service of these Requests on you. You must furnish such documents as are available to you. your employees, representatives, agents and attorneys, These Requests are deemed to be continuing in nature. in accordance with the provisions of the Rules of Civil Procedure, as amended. If between the time you originally furnish documents and/or respond to these Requests, and the time of trial of this matter, you or anyone acting on your behalf learn of additional discoverable documents, then vou shall oromotlv furnish those documents to the undersianed and suoolement vour oriainal resoonses. 2. If any document(s) is/are no longer in your possession or subject to your control, then identify the document(s), state what disposition was made of it, the reason for such disposition, the date thereof, and the identity of its current or last known location or custodian. 3. If any document has already been supplied to date, then identify the document, the date supplied, and the circumstances surrounding the surrender of the document including to whom it was supplied to. 4. Where exact information cannot be furnished, estimated information is to be supplied. Where an estimate is used, it should be identified as such and an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. 5. Where knowledge, information, or documents in the possession of a party ") are requested, such requests includes knowledge, information or documents in possession of the parties agents, representatives, employees and attorneys. CLAIM OF PRIVILEGE With respect to any claim of privilege or immunity from discovery, you must first identify the privilege or immunity asserted and provide sufficient information to substantiate the claim. If you claim that the subject matter of the documents or oral communication is privileged, you need not produce a document. You shall, however, "identify" such document or oral communication and shall state each ground in which you claim such document or oral communication is privileged. DEFINITIONS 1. "Plaintiff' - as used herein, refers to Professional Resource Group, Inc. 2. "Defendant" - as used herein, refers to CompSource, Inc. 3. "Person" or "Persons" - as used herein, means a natural person, partnership, association, corporation or government agency. 4. "Concern", "Concerned" or "Concerning" - as used herein, means referring to or relating to, or pertaining to, commenting on, or connected with in any manner whatsoever. 5. "You", "Your" and "Yours" - as used herein, means Professional Resource Group, Inc., their officers, employees, representatives, affiliates, agents, and attorneys, or any person working for such persons. 6. "Identify" or "Identity" - as used herein, means when used in reference to: (1) a natural person, his or her: a. full name; and b. present or last known address and employment address 3 (including street number, name, city or town, and state or country); (2) a document; a. its description (e.g., letter, memorandum, report, etc.), title and date; b. its subject matter; c. its author's identity; d. its addressee's identity; e. its present location; and f. its custodian's identity. (3) an oral communication; a. its date; b. the place where it occurred; c. its substance; d. the identity of the person who made the communication; e. the identity of each to whom such communication was made; and f. the identity of each person who was present when such communication was made. (4) a corporate entity; a. its full corporate name; b. its date and place of incorporation; and c. its present address and telephone number. (5) any other context; a description with sufficient particularity that the thing may thereafter be specified and recognized including relevant dates and places, .j REQUESTS 1. All statements, including but not restricted to those defined by Pennsylvania Rules of Civil Procedure 4003.1-5, signed statements, transcripts or recorded statements or interviews, or any memoranda or summary of transcripts of statements or interviews of any party, person or witness, or their agent or employees, who have any knowledge or information of the facts concerning or pertaining to the subject matter, the claims, the damages, or any other matter involved in or concerning this case. 2. All documents or exhibits which you intend to offer or identify as exhibits and/or evidence at any deposition in this case, or in the Pre-Trial Memorandum of the Defendant, or at the trial of this matter. 3. Any and all copies of the invoices referred to in Plaintiffs Complaint. 4. Any and all copies of timesheets or any document describing the time and services Plaintiffs employee, Mr. Seo provided to Defendant's client. 5. Any and all copies of any written reports made pursuant to any investigation conducted concerning the allegations set forth in Plaintiffs Complaint. 6. Any and all documents or things concerning the cause of action alleged in Plaintiffs Complaint which either proves or disproves any claims in Plaintiffs Complaint or proves or disproves any of the defenses alleged by the Defendant. 7. Any and all documents relating to this civil action containing the names and (, '. home and/or business addresses of all individuals known, identified or contacted by or on behalf of the answering Plaintiff. as potential fact witnesses whether or not they will be used as witnesses at trial and all copies of all written correspondence with any and all such persons, 8. Product all documents which support Defendant's contention that the prices charged were not fair, reasonable and market prices. I J Dated: July~, 1997 BY: _~O./ ~,-- CHARLES J. PHilLIPS, ESQUIRE KEVIN A. MOORE, ESQUIRE Attorneys for Defendant 2201 Ridgewood Road, Suite 400 Wyomissing, PA 19610-1193 610-372-8427 9, Product all documents which reflect Plaintiffs understanding of its agreement with Defendant. 11. If any document or statement (oral or written) is withheld on any claim of privilege, or otherwise, set forth the following: A. The basis of the privilege claimed; B. The author of the document or parties to the statement; C. The date of the document or statement; D. The recipient or intended recipient of the document or statement; E. A brief description of the substance of the document or statement; F. All persons who received copies of the document or who were shown copies of the document, or was a witness to the communication or statement along with the identification of each such person. BASKIN LEISAWlTZHELLER & ABRAMOWlTCH. P.C. 7 >- --'" , f1~ LJ: ~'.; t~. ,,':-' lLI(.' l.)' , , IL I.. 1 <..:: ('-." :.., Lc C'. , : I Ci".- - , ". i '" , lL r- " v U' U >- O. no , ~l' '''' l - '-~":' . L": . ,... ( I. r - :'-: ( , eLJ ,~: J , , .. . l I C' '. c' ; ... __J ,., (,I).II" ',) 1''')'~~1 'Z', ... W A \lNE F. SUA!)E ^r111KNI\'MI^W l.1 WI SII~IMIKII SIKIII ('AKLlSI 1', i'I'NNS\'I.V^NI^ 1701.1 (7171 nW120 (MUU) 2".\.U220 I^X 171712l~~N)17 October 26, 1999 HAND DELIVERED Ilonorable George E. I loiTer. P.J. Cumberland County Courthouse Carlisle. Pennsylvania 17013 Re: Professional Resource Group. Inc. v. CompSource. Inc. No. 97-220 Civil Tenn Dear Judge Hofler: On June 16. 1997. I was appointed Chainnan of the Board of Arbitrators in the above matter. When I attempted to schedule a hearing. I received copies of correspondence between counsel in the case which reflected procedural disputes and the ultimate agreement for further discovery. Copies of those lellers arc included in the liIe. We heard nothing further Irom the parties until we n:eeivcd a leller IrOJn the Office of the Court Administrator on July 16 of this year. Upon receipt of that letter. we inquired of the parties as to the status of the case. Lellers in response to that inquiry indicated selllement of a case with the same parties. However. the docket number on the Praecipe to Discontinue was 98-6039 Civil Tenn rather than the 97-220 Civil Tenn of this case. Enclosed in the liIe is a kller Irom Kevin A. Moore. Esquire. which endeavors to explain the situation. The rclereneed leller to Tom Placey was not allaehed to the original of the lellcr that was sent to this office. It would scem that the appointment of arbitrators should be vacated. i':~ ".' -:J' t.-; , I'": .' I' 11'( I t, " ' ( ./ (~ ~; ; ~ .;~ \ ~.. t', _',.J ';1 ! I ~ .-, '" - , i, , ' -- I, L' ( , l',' f. r--, (..-\ .-t!...' :::j u ... Ifj ~ i5 ~~~ is ffiul~ cC~~~ ~~~&I (J ~ g: Ii. - II) o f':' 1II ~ W ~ _ t:. " ~ ~ Ii: ~::! u.; ~ ~ ~ Ie 3: z ::f ~ :5ii& . , I'ROFESS10NAL RESOURCE (,ROl))', INC., IN TilE COURT OF COMMON !'LEAS OF CUMDERLANU COUNTY, I'ENNSYLVANIA l'llllntlff v. NO, 97-220 CIVIL TERM COMI'SOURCE, INC., Ucfcnllllnt CIVIL ACTION - LAW CEIHIFICATE OF SERVICE The undersigned hereby eertilies thaI on the date hereof, a eopy of the foregoing t I ,. I , I'RAECIPE TO SETTLE AND SATISFY CASE was served to all parties of interest by way of United States first class mail, postage prepaid, addressed as follows: .. LA W OFFICES OF CRAIG A. DIEHL Kevin A. Moore, Esquire BASKIN LEISA WITZ HELLER & ABRAMOWITCH, P.C. Suite 400 220 I Ridgewood Road Wyomissing,l'A 19610-1193 Dated: December ~, 1999 By: jilt{ ;; Helen E. Rasmussen, Legal Assistant 3464 Trindle Road Camp Hill. PA 17011 (717) 763-7613