HomeMy WebLinkAbout03-0469IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
EXPANETS
Plaintiff(s) No. (,_33- A/t~
vs. COMPLAINT
RIS PAPER COMPANY, INC., Formerly
Known as QUAKER CITY PAPER COMPANY, INC.
Defendant(s)
FILED ON BEHALF OF
Plaimiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
NICHOLAS D. KRAWEC, ESQUIRE
PA I.D. #38527
JON A. MCKECHNIE, ESQUIRE
PA I.D. #36268
Bemstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL: (412) 456-8114
BERNSTEIN FILE NO. C0024359
JFH001269V001
1/24/2003
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
EXPANETS
Plaintiff
VS.
RIS PAPER COMPANY, INC., Formerly
Known as QUAKER CITY PAPER COMPANY, INC.
Civil Action No.
Defendant
NOTICE AND COMPLAINT
NOTICE TO DEFEND
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 are served upon you,
by entering a written appearance personally or by attorney and filing in writing with the Court your
defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case
may proceed without you and a Judgment may be entered against you by the Court, without further
notice, for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff.
You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
PA BAR ASSOCIATION
P.O. BOX 186
HARRISBURG, PA 17108
1-800-692-7375
JFH001269V001
1/24/2003
COMPLAINT
1. Plaintiff is a corporation having offices in Brandon, FL.
2. Defendant is a corporation having its offices and place of business at 435 Independence Avenue,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
On or about October 19, 2001, Defendant requested certain goods, wares, merchandise and services
from Plaintiff, as is more specifically shown by Defendant's Purchase Order, a copy of which is
attached hereto, marked Exhibit "1" and made a part hereof.
In accordance with the aforementioned Purchase Order, Plaintiff sold and delivered to Defendant
various goods, wares, merchandise and services, as is more specifically shown by Plaintiffs invoice,
a copy of which is attached hereto, marked Exhibit "2", and made a part hereof.
5. Defendant received and accepted the aforementioned goods, wares, merchandise and services.
6. The prices charged by Plaintiff were the fair, reasonable, and market prices that prevailed at the time
of the transaction.
7. The prices charged by Plaintiff were the prices that Defendant agreed to pay.
8. Plaintiff avers that the balance due amounts to $3,509.93.
JFH001269V001
!/24/2003
9. Plaimiffclaims legal interest as damages on the liquidated debt from December 22, 2001.
10. Plaintiffavers that interest amounts to $229.64 to January 24, 2003.
11. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to
pay the aforesaid balance, interest, or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of $3,739.57, with
continuing legal interest thereon at the rate of 1/2% per month and costs.
BERNSTEIN LAW FIRM, P.C.
::? ,,/:: ./Y ........
Affomey for Plaintiff(z~
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
BERNSTEIN FILE NO. C0024359
412-456-8100
JFH001269V001
1/24/2003
~_~CT 19 '~i 10t44 FR RIS ~P~EI~
I
1
!
1
?l? ~5 70~ TO 1800613gi89.~
l~randon, FI. 113510
IQ'
{ Lease Tc-m~
~ Moad~ly P~yn'~n~ "--"'~" (~.,~lqOi~l~Tl~(1
j Buv~r Ootim~
TOTAL
c~,TT OF New York
COUNTY OF Erie
Richard Marinaccio , being duly sworn according to law,
deposes and says that he is Authorized Agent
of the
D!alnt~ff corporation and duly authorized to make this affidavit: that
those facts contained in the for~oin~ ComDlalnt which are within his
own know!edKe are true and correct, and those facts of which he is
informed, he believes, and therefore avers are true and correct to the
best of his knowledqe~ information and belief, and expects to be able to
prove the same upon the trial of this cause.
SWOR:~ TO and SUBSCRIBED
before me this .~r2 day
/ No6-ary Public
/
~ Commission E×~Ires:
Quaiified in Erie ~ounty ~.~
SHERIFF,s RETURN _ REGULAR
CASE NO: 2003-00469 p
COMMONWEALTH OF
COUNTy OF PENNSYLVANIA:
CUMBERLAND
EX_~P~ETS
VS
RIS PAPER COMpANy INC FKA QUAK
BRYAN WARD
_, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the Within COMPLAINT & NOTICE
~ was served upon
Rig PAPER COMpANy INC F/K/A QUAKER CITY PAPER COMpANy INC_~q~ the
DEFENDANT , at 1028:00 HOURS, on the
at 435 INDEPENDENCE AVE ~ day of ~, 2003
NUE ~
MECHANICSBURG, PA 17055
K~THy STEPHENS, RECEPTIONIST by handing to
ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together With
and at the same time directing He_~r attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
7.59
.00
10.00
35.59
Sworn and Subscribed to before
me this ~ day of
So Answers:
~. Thomas Kline'-.
02/04/2003
BERNSTEIN LAW FIRM
By :~
IN THE COURT
PENNSYLVANIA
OF
COMMON
PLEAS
OF CUMBERLAND
COUNTY,
CIVIL DIVISION
EXPANETS
Plaintiff(s)
No. 03-469
VS.
iRIS PAPER COMPANY, INC. formerly known
As QUAKER CITY PAPER COMPANY, INC.
Defendant(s)
PRAECIPE TO SETTLE, DISCONTINUE
& END
FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
NICHOLAS D. KRAWEC, ESQUIRE
PA I.D. #38527
JON A. MCKECHNIE, ESQUIRE
PA I.D. #36268
Bemstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
DIRECT DIAL: (412) 456-8103
BERNSTEIN FILE NO. C0024359
iN THE COURT
PENNSYLVANIA
OF COMMON
PLEAS
OF 'CUMBERLAND
COUNTY,
EXPANETS
CIVIL DIVISION
Plaintiff
VS.
RIS PAPER COMPANY, INC.,
formerly known as QUAKER CITY
PAPER COMPANY, INC.
Civil Action No. 03-469
Defendant
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Settle, discontinue and end the above-captioned matter upon the records of the
Court and mark the costs paid.
Sworn to and subscribed
before me this
day of ]gttbtd.~ ,2003
Notary l~blic
BERNSTEIN LAW FIRM, P.C.
Suite 2200 Gulf Tower
Pittsburgh, iPA 15219
(412) 456-8100
BERNSTEIN FILE NO: C0024359