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Home My WebLink About97-07136 ,I 1,1 ,,. 'I " . , , ' " of"~ ,,/ , " I"~ , I 'I I " " " ii}-L)i., ,;...b. .(j~' p"".1 ':,~' ;/II j' ;:j ,I ,I, 'I " " I, ,1' 'I,. I ;'1 , 1/" '/' " ,I I, I' ' " :,' .,1 , 'I I " I' 'I I' I I ': "I' ,I .1 " " (; " " il I, ,"I , ' " " " ,'-I " I 'Ii , " " " I " 'I " , 'I' " ,I , I , I 'I " il " ,I' I' I 'H , , "', I; . " " " " " , , If I' ''I " " I' J' " " ," , I, ,I " ," " 1,/ I" 'I , , " 1'1 " " , ' I I I " , I I' /, " 'd, I' i) 'I , ," I " 'ill 'q 'I :1 ,II , I f'i/l , ' , " 'I JI, q; I! , , ,I I! " " " ii, 'I I I' , " I , , , ,I " " , I , " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE SENTINEL, .. .. Plaintiff .. .. .. .. vs. .. .. .. .. BEN L. BRENEMAN, .. .. t/d/b/a CENTURY 21 .. .. BRENEMAN & .. .. ASSOCIATES, .. .. Defendant .. .. CIVIL ACTION-LAW NO. 97- 1/'1 (,.. CIVIL TERM .cOMPLAIl'fI: And now comes The Sentinel, Plaintiff in the above-captioned malter, and states the following cause of action: I. Plaintiff is The Sentinel, a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal place of business at 457 East North Street, P.O. Box 130, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Ben L. Bt'eneman, an adult individual, sui juris, whose present or last known address is 1447 Hillcrest Court, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff publishes a daily newspaper at its location in Cumberland County, including a Sunday edition and a free publication known as Pennysavcr, all of which are distributed throughout Cumberland County and elsewhere. 4. Plaintiffs business, in addition to the actual sale of its publications, includes the sale of advertising column space in said publications, commercial and classified, and in special sections of the paper devoted to particular interests such as real estate. 5. At all times relevant hereto, Defendant operated several real estate agency offices in Cumberland County, Pennsylvania, including ones at 801 South Hanover Street, Carlisle, Pennsylvania; and 5001 Carlisle Pike, Mechanicsburg, Pennsylvania. (On or about August 20, 1997, Defendant sold his business to another party, Coldwell Banker, which did not assume any of Defendant's obligations prior to those incurred prior to that date.) 6. As part of his efforts to market properties listed with his agency, Defendant purchased advertising space from Plaintiff on a regular basis, under an arrangement where Defendant would submit the advertising copy and be billed after its publication by the Plaintiff. 7. The prices charged to Defendant for the advertising space by Plaintiff were fair and reasonable, and were similar to that charged to other real estate agencies for advertising. 8. Defendant accepted the advettising space provided, and he promised and agreed to pay the amounts charged to him therefor. 9. Defendant did not raise any complaints about the advertising services provided to him by the Plaintiff, nor did he assert any objections to the amounts billed to him. 10. Despite bills being received by him from Plaintiff, and despite further demands made upon him for payment, Defendant has failed to pay, and continues to 2 YERlEICAT.lON I, Tony Corrao, the undersigned, hereby verify that the statements made herein 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 autqorities. I further verify that as Business Manager of The SeqtineI, I am authorized to make this verification. y~ Date: I \ / 14 /97 I ( ~ 4 , . ...' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE SENTINEL, .. .. Plaintiff .. .. .. .. vs. .. .. BEN L. BRENEMAN, .. .. tJd/b/o. CENTURY 21 .. BRENEMAN & .. ASSOCIATES, .. Defendnnt .. CIVIL ACTION-LA W NO. 97- 7136 CIVIL TERM TO: BEN L. BRENEMAN, t/d/b/a CENTURY 21 BRENEMAN & ASSOCIATES Date of Notice: January 28, 1998 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 THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MA Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A I.A WYER 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 HELP: . Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 FLOWER, MORGENTHAL, FLOWER & LINDSAY '-roy;.1IVJti1.h.....A- Roger M. Morgenmal. Esquire Attorney for Plaintiff 101117143 11 East High Street Carlisle, I' A 17013-3016 717-243-5513