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Home My WebLink About97-04229 ~, ~ l' \l '.. Cl ~ ~ ( '.. ~~ ~ ~. H . If :t . =.: c '" .~ ~ S " ~ ~ ~ '- :I ~ - \. . .$ .... . .~ .. <:.J ao- rt "'l ' ,,; , , t"'" <:3" . ~ / , . . ~ a. 1= tr. .. ,>: w2 9 .J-A () ,~.~ ~~. -- t ......... ;.1 .......i ~~.',") ": ~ , ' ..,,:i".~ (0, <:1' " '''. .., ~ &.1... '. j ---.!"t-e .J fff" :r ' ~' ",,1 .L -~: .;c.. ,- -'j -.;;, II. C:l :t:... U -, Cl'\ U . . . 10. Admitted with qualification. The defendant made it clear that it was entering into this agreement with Worldwide on a contingency basis only, and would not consider changing carriers during its contract with Express Tel. 11. Admitted. 12. Denied as irrelevant. 13. Denied, The contract speaks for itself. 14. Denied. Worldwide did not provide an agreement which would save American $1,167.00 per month. 15. Denied. Mr. Shaner was informed that the defendant was still under contract with Express Tel and was not interested in making any changes prior to the termination of the contract with Express Tel. In addition, the defendant began to negotiate rates on its own, to see if a lower rate could be obtained than what Worldwide had claimed it could deliver, and defendant was successful in doing so. At that time, Shaner claims he was entitled to a share of the savings which were obtained by the defendant without the efforts of Shaner, and Shaner was informed that American was in fact successful in obtaining a rate lower than Shaner could deliver. 16. Denied. To this date, the defendant has not entered into a contract with MeI. 17. Denied. The defendant continues to purchase their long distance service through Express Tel. 18. Denied. The defendant has not changed carriers, nor have they implemented any of Worldwide's recommendations. 19. Denied. After reasonable investigation, the defendant is unable to determine the truth of the averment. Proof thereof is demanded 20. Denied as irrelevant. 21. Denied as irrelevant. NEW MA ITER 22. T1w d~fmdant hereby asserts any and all defenses a\'allable pUl'5uant to Pa. RC.P. uno. n '" 0 c ~ ',. ",,:,,' :., " '" t) OJ ':.~>1 , ., f\.: .:.J :6 ...., -', ." ~.~ , ,. . ")nJ .,',.:, - "" -': - :Q - ...... FL(fJ r-~".. ...i;"(,,,,t " H,." ' -,;/1'0'( ,-.,.r~l c~ i. C? f:'''' ... 3" fl' !;'). t::~ 1./ _: f'.'. h1. .'''' "'\Y ~_;.I - .. ." ",' ; WILLIAM P. DOUGLAS, ESQUIRE ATIY. 1.0. # 37926 DOUGLAS, DOUGLAS & DOUGLAS 27 W. HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 717-243-1790 A TIORNEY FOR DEFENDANT WORLDWIDE TELE. COMMUNICATIONS, INC. V. AMERICAN MOULDING & MILLWORK CO. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 97 - 4229 CIVIL TERM JURY TRIAL DEMANDED AMENDED ANSWER WITH NEW MA TIER 1. Denied. After reasonable investigation, the defendant is unable to determine the truth of the averment. Proof thereof is demanded. 2. Admitted. 3. Denied as stated. The contract speaks for itself. 4. Denied. After reasonable investigation, the defendant is unable to determine the truth of the averment. Proof thereof is demanded. 5. Denied as staled. No payments were due and owing Worldwide. 6. Denied as stated. The contract speaks for itself. 7. Denied. After reasonable investigation, the defendant is unable to determine the truth of the averment. Proof thereof is demanded. 8. Denied. After reasonable investigation, the defendant is unable to determine the truth of the averment. Proof thereof is demanded. 9. Denied. After reasonable investigation, the defendant is unable to determine the truth of the averment. Proof thereof is demanded. - 10. Admitted with qualification. The defendant made it dear that it was entering into this agreement with Worldwide on a contingency basis only, and would not consider changing carriers during its contract with Express Tel. 11. Admitted. 12. Denied as irrelevant. 13. Denied. The contract speaks for itself. 14. Denied. Worldwide did provide a rate proposal from MCI at a savings of approximately $1.167.00 per month. However, that rate expired before the Express Tel contract, by which the defendant was bound, could terminate in the Spring of 1997. 15. Denied. Mr. Shaner was informed that the defendant was still under contract with Express Tel and was not interested in making any changes prior to the termination of the contract with Express Tel. In addition, the defendant began to negotiate rates on its own, to see if a lower rate could be obtained than what Worldwide had claimed it could deliver, and defendant was successful in doing so. At that time, Shaner claims he was entitled to a share of the savings which were obtained by the defendant without the efforts of Shaner, and Shaner was informed that American was in fact successful in obtaining a rate lower than Shaner could deliver. 16. Denied. To this date, the defendant has not entered into a contract with MCI. 17. Denied. The defendant continues to purchase their long distance service through Express Tel. 18. Denied. The defendant has not changed carriers, nor have they implemented any of Worldwide's recommendations. 19. Denied. After reasonable investigation, the defendant is unable to determine the truth of the averment. Proof thereof is demanded 20. Denied as irrelevant. 21. Denied as irrekvant. NEW Mb.nER 22. ~ defendant hereby asserts any and aU defenses available pursuant to Pa. R.C.P. 1000, LAW Offld!S yOfFE <\ yOffE. P.C. SU1Tl' 2tl3 . 2ttSENAn AVENUE CAMP HILL. P A '70\1 (717) 915-183& : . .:;.,'1' ,!...;,.";:..",,,,~;.;J;...iiij,iij.r'S-'~~':l1~~"<i.~ .,. ;"--.- . .. . ~ . , " I \ , , , ! . . - ......:,~ WORLDWIDE TELECOMMUNICATIONS. INC.. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97-4229 CIVIL TERM CIVIL ACTION' LAW AMERICAN MOLDINGS AND MILLWORK COMPANY Defendant JURY TRIAL DEMANDED PLAINTIFF'S COMPLAINT FOR DAMAGES Comes now the Plaintiff herein, WORLDWIDE TELECOMMUNICATIONS, INC. (hereinafter referred to as "Worldwide" or "the Plaintiff"), by counsel and its complaint against American Moldings and Millwork Company (hereinafter referred to as "American") herein alleges that: COUNT I: BREACH OF INTERSTATE CONTRACT JURISDICTION AND VENUE 1. Worldwide is a Corporation incorporated under the laws of the State of Pennsylvania and has its principal place of business located in the town of Enola in Cumberland County, Pennsylvania. 2. American is a Corporation with its principal place of business located in Stockton, California. 3. The parties hereto entered into a contract attached hereto as Exhibit A which recites that it was .,0 be governed by the laws of Pennsylvania. 4. Worldwide was to perform its obligations under the contract entirely within the state of Pennsylvania. 5. Payment on the contract was to be IlIade to Worldwide located in Cumberland County, pennsylvania. 6. American agreed to a Cumberland County, pennsylvania venue in the event either party nee<Hd to resort to a civil Court for enforcement. THE PARTIES 7. Worldwide is an independent consultant who makes a business of analyzing a client's communications expenses with a view towards proposing similar communications services from the same carrier or another carrier at a lower rate. 8. Worldwide utilizes computer proqrams, a tariff data base, industry contacts and other facilities and assets to ensure that it can serve its clients with efficiency and thoroughness. 9. To recover these expenses, it claims a proprietary interest in these assets and in the data it provides its clients. STATEMENT OF THE CASE 10. Worldwide and American entered into a contract, a true copy of which is attached hereto as Exhibit "A" and incorporated by reference. 11. Several weeks prior to August 6. 1996, Worldwide and American had been communicating with each other in reference to the services which were eventually provided pursuant to the Auqust 6, 1996 contract. 12. Durinq the weeks before it signed, American had ample opportunity to request or neqotiate chanqes in the contract, changes in the service Worldwide proposed, or changes in the fee Worldwide would expect under the contract. American asked for no changes in the writing attached hereto. ll. The wri tten aqreement between the partie. requit.. that Worldwide would receive one half of the first t~1V. tllOfttha lavinqa realized by American. 14. Worldwide performed as agreed, providing American with copioua d.ta on available lonq dlltance ratea and tec(lllllMnded . 10C111 diltanee plan that would lave American 11.167.00 per tllOftth over iu the" current lonq distance plan. I. Worfdwkh rllecClflllllun,caUonl, Incorpot'lllld 2" w... DhotIln I"" EIIo1l1, PA nOI. ou....~ ~ ""Io~, ConIIngIMJ Only C;DltlllhlnAht.AortIIIJIlll DII, Wortdwlclt TllecOflllllUnlcltlonl: , . W. Milby Ippolnt you to Iud" Our local Ind long e11l111nee '-'ICllft1mUnlClllonl vlndor InvolUI In orde, to, 'au to 11II'" COlt IA~Inll' recommenClltlonl to ou, nnn. II Is agree<! you wll' an.'"l our l.jltll!4lS In lhelr entirely Ind ,.,81rch In delsU Ih. Feder.' Communl~lIons CommlS5lon 10CII Ana long disllnce camer II"If, or our local Phone company 1M th. rll'Vlnt long dislance c:ampl'I. 1\ Is Igreld ,Oil will provld. us wllh fllellmlnlry nndlngs 'M 11111 . detailed ~seal'Ch ~pol1 orr.rino 'hi br(J-.l..~1 anll most r.omprenenslv. IInge or t.'ICOnllnUOlCltlons Slvlngs Ind lit. rllCOfl\m.ndlllon. possible uttliZlng our choice 01 lanlfs, Clnt.~. soecllllnOwlnc:a.. rabatl$, ",runds Ind cost redUdlons, It I' llnderstaod Ind 10tlld thlt you wtll be wort.no an . Ittlc1 noofflll contingency,.. D..II Ind 'hll your conlu"lng tee will be an !lalt of.,.. monthly 'IvlnOI 'Iv. accrue t'lIIll Uta ~_m.ndltion. In your repartl to,. perlod of ani ""' f,ont the dll. of ImplMtentltlan. Aner Ihe lirst twelve months. 100% or lit.. lono 'Irm Uvings are oun to keep SInea "vlng. 1111 gu,"nteed by JllU ro oc:cur. If Ihe.. Ire no .Ivingl rlllirld br UI, tllare II W tee due to ,au. One.tlme relunds Dr PlSt larirr ov.rtlInings ""'" be shlted on II SO/'IQ bl.1s U\lOn Collldlan Ynur OlIgOIng Ilrt" monnottng "",IClIftll bill audltillg wiN ~ provide<! to "' "I no 3c11tnlnrull alsl Colt 'IvlnOI wtll be calcullted from the olll.cIM ltIn4a,., or our current co,I. '1 thl linle of Iud" Iccordlng to till tollowing tOl'lllulal: eft.' DAIL.HiGn ..... t:.~t"'. n t,entscunwnt COlt pet m'""". ,09 cents new COlt ptrllllltUlI. 13 cents", mHluta otott living. ,13 unll per IIIlnut'lIl'Oll IAvlnOI 118,000 minutes of ca'"", tit IIIonth . "NO OM-4IIOnth ....""1 $1040.5011. . ...10 due lllontll _. fttfUftd~ ........! I. 11500 IlIl\IrId C/lack to rou.... -1750 _1rIpIofte ttme fM. AIIIt )'OUt WllIll II fIl!Ifonned, 'Irttf ~Itloftt 11I11 we ~ ... 'lfIlOImIld III be due 10 rallf' """" TIII"f~. II is 1lQ1le.J 11I11 .ny recommtndatian in )'OU/' IIPGlb IIItt ... /mpIIrnenf .. c1umed lCCePled a..d .... own not ullIIle III. IIC'Al111/1l1lldllionl in your llpoIlS during ,he I,"" wllIlout pe)'lllent of pO\Il'H and noIltlCltlOll , lu you ThItt nDn-cirtumVltltlon prowisions Ire lFllevrtllo IIUt IQIH.'nenI 8fId "'.. \It elffdhl for I two yur " Ptf10d after InI dllltv.,., 01 your IIntI1ngs L..". lilt lICnlcl '"" UllClIrMo..d IIIlIt liltS COIIlI..:l11 00\IIIIIId br Ille lit.. of Ptnntrt.1l\IlI and any Ic1tOl\ cammendnO lllINunder SIIIIl be IIro"ON In lhe caunly of CurnbeMtld 1"ulUlt1lllClre. we rapr...... Ihlll IIIe f*1IM' IiUrIInlI 11 lIUlflOrtlld to InClIOt yaur IetW.It We ~ Dno ...~ *-itIt of . COllY of 1/111 1QfeemIIll. and If WI llr_acI1lhtt contrac:l, we . Plr all ..alClnlble lllMllt IIld "'11 00-. you InOll dul! to IlIIdl MIdl, Aa:Cl'~" 'Y': GIIIIIt ,., 1ll4t......... If bt.r.lHy"J ......Wlw., ..1'1t~~~-1T CeMIet"-e: ;t.?lUCNq __.,.. v;'l- c.r:'L ~~~~:~~~;';:~c.~'_~" .......: W'n:t ~ DAUPtIN ST. PA t702S Oete EXHIBIT "A" "\ C) .~ "') ~ " .- , , :1 " - , -- ~ .... ~ "..:" - .. . h) ,," ., .. ,~ ~ ~~ ~ ~ . ~~ ~ '. ~\ .. .0 0 , -1 -n " -.. , , . 'i :.~ t~ If'- I ,l1 G~ ,,;) '0 - .. , -., .- ~ ~.) -- "..91 " ~ .. ':! :.r, , , . 1.#1. :{ ,. , I I , , I , , , I >~i"'>c..,>( !O- ~~if ~~'"'I~ , , r1'-.I "'r1'lDO I , ~~I~ , f:i .]~~ ,< I '.... I '" , - fC I'D If-' l<' .... -.I I ~ ~~& ~ ~ r1'~ 0 . lB ~ , , , I~ r g '< ~ , ,. I , , ;er1' Ii' I ,'" , U1f-'r1' 2:>( 'r1' . I'" >, I-f , .. (I H'i. 0 '.... (l) J f-'lii' , lu II 0'" 0.... '8 fHl , ~el;eI'1a:l;' - c;ia I " f-'O I , CD 't2 ....... .... '" r1' I I~ . f-' r" , ~ UI .... -.I I'D'll ii 'fiI ~~~ I , UI 016 .. I , S' I I~ I N....... n "'CIl I , '" f-' r1'j' I Ii" B. ~i:' I , ... ~l:;; , Iii I ... I I ......... '" , II I UI ~ r1'il , I .. , , '" . I r , , 0 ! , '" , co I 0 I I , ... , WORLDWIDE TELE- COMMUNICA TIONS,INC. V. AMERICAN MOULDING & MILLWORK CO. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A CIVIL ACTION - LAW NO. 97 - 4229 CIVIL TERM JURY TRIAL DEMANDED DEFENDANT'S MOTION TO COMPEL ANSWERS TO REOUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO PLAINTIFF Defendant, American Moulding & Millwork Co., moves this Court, pursuant to 4019 of the Pennsylvania Rules of Civil Procedure, for an order compelling the plaintiff to provide full and complete answers to Defendant's Request for Production of Documents. 1. The defendant served Interrogatories on plaintiff's allorney, Jeffrey N. Yoffe, Esquire, dated October 19, 1998. A copy of said Interrogatories is attached hereto. The date was changed pursuant to paragraph 3 of this Motion. 2. In response to a follow-up leller, on August 23, 1999, Jeffrey N. Yoffe, Esquire, informed defendant's counsel that he withdrew his appearance and new counsel entered an appearance on June 23,1998. 3. On August 24,1999, defense counsel served a copy of Defendant's Request for Production of Documents on Lawrence S. Coven, Esquire, new counsel for plaintiff. 4. The information reqUl'sted by counsel for the defendant is both relevant and material to the issue of liability in this mailer and/or may lead to other admissible evidence. 5. The information requested by counsel for the defendant is not available from any other source. 6. In excess of twenty-one (21) months have elapsed since the dale of service of the discovery on original counsel, Jeffrey N. Yoffe, Esquire, and in excess of eleven (11) months have elapsed since the date of service of the discovery upon plaintiff's lalest munsel. Lawrence S. Cll\'Cn. Esquire, and answers have not yg been provided. WORLDWIDE TELE- COMMUNICATIONS, INC. V. AMERICAN MOULDING & MILLWORK CO. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PA CIVIL ACTION - LAW NO. 97 - 4229 CIVIL TERM JURY TRIAL DEMANDED DEFENDANT"S REOUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF To: Worldwide Telecommunications, Inc. c/o Lawrence S. Coven, Esquire 314 U.s. Highway 22 West Suite E Greenbrook, New Jersey 08812 PLEASE TAKE NOTICE that pursuant to Rule 4009 of the Pennsylvania Rules of Civil Procedure, Defendant requests that Plaintiff produce the documents hereinafter described and permit Defendant, through their attorneys, to inspect them and copy such of them as they may desire. Defendant requests that the documents be made available for this inspection at the offices of Defendant's attorneys located at 27 West High Street Carlisle, PA. within thirty (30) days of the date of service hereof. Defendant's attorneys will be responsible for these documents as long as they are in their possession. Copying will be done at Defendant's expense and the documents will be promptly returned after copying has been completed. This request is intended to cover all documents in the possession, custody and control of Plaintiff, their agents, employees and attorneys and is considered to be continuing. Plaintiffs response to the Request should be modified or supplemented as Plaintiff, and/or their attorneys, obtain further or additional documents up to the time of trial. Requested documents are more particulArly itemized and described as folloWS, but not limited theteto: 1. All statements, signed statements, transcripts of recorded statements or interviews of any person or witness relating to, referring to or describing any of the events described in the Complaint. 2. All expert opinions, reports, summaries or other writings in your custody or control, or your attorneys, which relate to the proposed testimony of the preparer of such opinicn, report, summary or other writing. 3. AU writings in your control or custody or your attomeys, which relate to the subject matter of this litigation. 4. All documents prepared by you, or by any representative, agent, or anyone acting on your behaU, except your attorney(s), during the investigation of the incident in question or any of the events or allegations described in the Complaint. Such documents shall include any documents made or prepared up through the present time, with the exclusion of mental impressions, conclusions, or the opinions respecting the value or merit of the claim or defense or respecting strategy or tactics. 5. All statements as defined within Pa. R.c.P.94Q03. 6. All statements and/or transcripts of interviews of fact witnesses obtained in this matter. 7. All documents identified in your Answers to any set of Interrogatories propounded by any party in this litigation. 8. All documents which you intend to rely upon or introduce at trial of this litigation. NOTE: As referred to herein, "document" includes written, printed, typed, recorded, or graphic matter, however produced or reproduced, including correspondence, telegrams, other written communications, data processing storage units, tapes, contracts, agreements, notes, memoranda, analyses, projections, indices, work papers, studies, reports, surveys, diaries, calendars, films, photographs, diagrams, drawings, minutes of meetings, or any other writing (including copies of any of the foregoing, regardless of whether you are now in possession, custody, or control of the original) now in your possession, custody, or control. your former or present counsel agents, emplo)'ftS, officers, or any other person acting on your behalf. . ;';~;. ..~::~" , '~'~~r!' .: 7'ic-to.o- E-'~";".i.';'; ~"'j,;" . ',' ., 5-. \:', <; ,.::.:' ','>' ;\'~:.':, ,;'.", !,::, _t.f .:.;:' ,:[~i '.'. 4' ,: ~A ~:-.' . :'i::~;' .', . .~: '[ .., .:,', I:: f: '; .':.:::t::.. ,.C.,,' ~-',,':: :~: ";~i'" J ~: }, ~.:"} 'c~' '.7~. ~ ~,5 ?J: 'f". ',;0',..;. ",.- .... i:~.: ,. r :".. ,.; - - '. ; ",'-' ":";: '. .. --"""",- - , . . .:........ ":'~:<;;;-;:'.::,'~~' . "){:i,e.: '\:"i;:: ~:: ~;~~::: F.L:'f}.()I=Ft:~ '.' 'U"C ",. :'i ~,'} :.~ ",; J ':j.";,' . O~ Tl'- .\ ',~.. " .""tly '. .... _ "~"::i~': .~..: ~"" : . ",'VI . ,'..: "'.C.- :L:i.<'/':. . ". '. " ." j.t), " '00 ABC ~!4 All JO; 2.5. .;., .....: ':,::.' ::.: .:. '<. , .. '.': .,'.,. :". ".' ~.i~;.' :'j :::,'/-. Cl:Ji~j~.vli'.1J QOUNTY , . _\.: ....:.:.: ".' '-".: .._ ;':" ," :, y'; : . P5'\Nsi'l.W'\'.~ . . :>: .:' fi:.. :::"::':'.' "". _ :, }.:.,.....:: .:'{<.'.",' . . ..... .....:<..:>, "' ,;' 'ti::, .' ; ;0' ;~f(" >,::,;/. . . . '. - . "', :;":.. ......._>...... :.,.: :;:,,:." ........... -.. . '-';" 'C,.;. ':it':." ''''::);'.~, ~7 ';'.i . .. '~:;:::\ FJ<j.;<. . ..' .. '. .' . ,':.<... ....:::.;~.~~i': ~;;::::::: -. .' . - ." .~<:.\ 't:;.::: ;.-, i_', :' :;':' .:::":.,,;'.",.:, ~~;~~(' ""',C;.'::;.':;, ('. .'~,,: "'.' .';." Y:;:~i~'" '.', ':,.: . ."~-"'''{.~ ::..' '... ,,{'.., '. -. " :. .: c,. .' :, ':. '. - '.' 0, ..... ;,,:. -. c" .:o. . ',,: " ........ .... ".~' . "'.: ....:". :..:::';';':,"" ,'''' ".:. ',;::'. ..::....;;., ..:.}"...:. '0" L '<<'_'" :::,!'::\,..."'j:""\\:" c'" \:;i"".,<> .....,... .' . ":;:,,, ;. ':,,:: . ;;: 'i:' " " .' q:; ~ ':" (, ",' ,e:..,"?".__ '. '. " ),: :;:~:: .. ::. ':~:.; .;j~':~:" ,':; " :;,:'L:,::;, ....: ..,:;:;:, '.' 'i"'. ;':..:". .... :., . ...; . ~ ~~~ .:~ftf -~~~~II ~}j;i~~ '~~~~ ~~iki ~~1~ ri ~Jj~~J:j . ",." ..... ,. ;; ..,' :~2: ,nO .', .~',.' - '!!I"~"",. ,....;\R, .., ~~..... "'-~ -... .. Lawrence S. Coven. Esq. 314 U.S.lIighway 22 West SuiteE Green Brook. New Jersey 08812 (732) 424.1000 Attorney for the Plaintiff, Worldwide Telecommunicarions. lnc Attorney 10# WORLDWIDE TELECOMMUNICATIONS, INC., : IN THE COURT OF COMMON : PLEAS Plaintiff v. : CUMBERLAND COUNTY, : PENNSYLVANIA AMt.:RICAN MOULDING & MILLWORK CO. : NO. 97-4229 CIVIL TERM Defendant WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly \\ithdraw the appearance of Lawrence S. Coven. Esq.. on behalf of Plaintiff. Worldwide Telecommunications. Inc.. in the above-captioncd civil action. ~"lIy...... itt, cdr: /J \ DATE: 'j ,'q{"I.Af'{"/V( CL/{../ - LAWRENCE S. COVEN. ESQ. 314 U.S. Hwy 22 West Suite E Green Brook. New Jersey 08812 ENTRY OF APPEARANCE TO TIlE PROTIlONOT ARY: Kindly enter the appearance of Stephen M. Beaudoin. Esq.. on behalf of Worldwide Telecommunications, Inc.. in the above-captioned ch'iJ action. ~--., .---./ BY: - -/ I ~ . , tt...!-" ~'~)<1.'I(r;<. STEPHEN M. BEAU . ESQ. Parhicw Tower Suite 250 Date: \ THE LAW OFFICE OF JANET B. COVEN, P.C. Attorney ID 1163214 314 U.S.llighway 22 West Suite E Green Brook. N.J. 08812 (732) 424-1000 Attorneys for Plaintiff, WORLD WIDE TELECOMMUNICATIONS, INC. WORLDWIDE TELECOMMUNICATIONS, INC.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-4229 Civil Term CIVIL ACTION.LA W Plaintiff. v. AMERICAN MOLDING AND MILLWORK COMPANY Defendant. WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly \\ithdraw the appearance of Stephen Beaudoin. on behalf of Plaintiff. World",ide Telecommunications, Inc.. in the above-captioned civil action. DATE: JUNE 20. 2002 Respectfully submitted. /~~~~~~ REGER & RIZZO II SO Fint Ave Kini of Prussia, P.A. 19406 ENTRY OF APPF.ARANCE TO mE PRomONOT ARY: Kindly enter the appearance of Janet 8. Coven. on behalf of WorId\\ide Telecommunications. Inc.. in the above-caplioned civil action. DATE: JUNE 20. 2002 BY: ~7UL:4 ~"-'" , ANET B. COVEN. ESQ. Attlll"nCy for the Plaintiff. Wocidwide Telecommunications. Inc, --flUdftl.................'*'*'....,..~.....~a ,tII\l\..____..... '* THE LAW OFFICE OF JANET B. COVEN, P.c. Attorney II) 1163214 314 U.S. Highway 22 West Suite E Green Brook. N.J. 08812 (732) 424-1000 Attorneys for Plaintiff, WORLDWIDE TELECOMMUNICATIONS, INC. WORLDWIDE TELECOMMUNICATIONS, INC., Plaintiff. IN THE COURT OF COMMON PLEAS OF CUl\I\JE1U.AND COUNTY. PENNSYLVANIA .m'! NO. 97~ Ch'i1 Term CIVIL ACTION-LAW . . . . . . : v. AMERICAN MOLDING AND l\lILLWORK COMPANY . . . Defendant. CERTIFICATION OF SERVICE 1 hereby certify that I served an Original and one copy of the enclosed Interrogatories, upon defendant's attorney. via regular mail, on September 19,2002. DATED: September 19,2002. ~ JANET B. COVEN (Attorney 10 No. 63214) 314 V,S. Highway 22 West Suite E Green Brook. N.J. OSS12 TilE LAW OFFICE OF JANET D. COn:N. P.c. ATrDR.!IIF.Y FOR PI.All'frlFF, WORLDWIDE TEI.ECo:\lMUNIC A TIONS. INC. r..p';.' d 0 ~ N CI) -.... ~ :~ r.; N :~C ,- c1~1 l~', -.- ,-.,.1 ~ . ).~ .0 ~ 'f! ~'....nl ...;~ ~ =- '" VI ~