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HomeMy WebLinkAbout00-07215 l"", ~"""U, "', "'~_l.;j.tlio;,'," CSH Industries, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000-7215 CIVIL TERM Cumberland Services, Defendant NOTICE OF HEARING BY BOARD OF ARBITRATORS YOU ARE HEREBY NOTIFIED that the Board of Arbitrators appointed by the Court in the above-captioned case will sit for the purpose of their appointment in the above-captioned action on Wednesday, November 28, 2001 at 2:00 p,m, in the 2nd Floor Hearing Room of the Old Cumberland County Courthouse, Carlisle, Pennsylvania, CAVEATS: I, Those parties wishing to introduce videotape evidence will be expected to have the necessary equipment to display the videotape present at the arbitration location, 2, In the event that deposition transcripts are to be used as evidence, transcripts should be provided to each arbitrator at least one week prior to the hearing, 3, Parties wishing to argue legal points will be expected to have copies of statutes, cases, etc" with relevant portions highlighted for each arbitrator and opposing counsel at the commencement of the hearing, ohn Broujos, Esquire, Chairman I lam p, Douglas, Esquire, Arbitrator Thomas E, Flower, Esquire, Arbitrator October 29,2001 cc: Jeffrey N, Yoffe, Esquire Attorney for Plaintiff Dennis J. Shatto, Esquire Attorney for Defendant --, ~ ...i.!fih, { , CSH Industries, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 07215 CIVIL H2000 vs. Cumberland Services, Defendant RULE 1312~1. The Petition for Appointment of Arbitrators shall be substantially in the following form; PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: .Jeffrey N. Yoffe, Esquire . counsel for the plaintiff~ in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ 20,381.39 The counterclaim of the defendant in the action is The following attorneys are interested in the wise disqualified to sit as arbitrators: case(s) as counselor are other- Dennis .J. Shatto, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ORDER OF COURT AND NOI., ,~lM1(hM~..2<1 , , X2001, in consid~ra~ion of the 17 foreg01ngpetit~ Esq., tt/t/.t~AW~~' Esq., and ~ . Esq., are appointed arbitrators in ~e above-captioned action (or actions) as prayed for. ~".~., ~{:"-"-j~~!g~bt~--;r~-I$l~~1~~~8i"j%"''''-'''''''''I'-'UMi~it:a~llISi ,",w ,~ ;IIU,rIM!' Jj Ulii~ oW. cC^ ~ ,.,~,,' ~ \fIN\I/\1~SNN3d 'thin!";/"< rn,V1\-QR!A'n" J\.U'l \.)1,) 1",.''-''_' ,,_,_"_,~'l ..) , E" I "'"I ~ \,! ,"! "' . I';" :IZ d3S 10 I U\,jl"\',:C ^U ~.,~Ui ;,',_:, :Oi.:L:(j {,E"'i!:::1 .:jO " _ p ,"~ ,z", "~,, "=_/",, ~'" ^" n ~~~ , ~" ( ., . " , ". . ,~ ;,,,, CSH INDUSTRIES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS, NO, 2000-07215 CUMBERLAND SERVICES, Defendant CIVIL ACTION-LAW CERTIFICATE OF SERVICE The undersigned certifies that on the date indicated below, he served a true and correct copy of the foregoing Petition for Appointment of Arbitrators on Dennis J, Shatto, Esquire. Service was accomplished by depositing the same in the United States Mail, first class, postage prepaid and addressed as follows: Dennis J, Shatto, Esquire III Locust Street Harrisburg, PA 17101 Dated: 9/20/01 YOFFE & YOFFE, P,C. tJ:/b; f7 yi, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 CSH\cumberland\certsvc2 ~l\!;_I!tl~~f;,~\&j~~"~;iw,~W4;,~,*,'l&1ljli!~~~I1im~~'__N "~"-- ""''''' "-,-,~,--, , ,-,,=~"",""'''' --', "" - ~, - ~~ , --~ "~'"-'~~-',~' -" "A p ~ fl ~ ~ ~ B ~~ 1- ~ f' ~ If'- ,'"""-,,,,' ., ~ .., i' " , (') 0 0 c: ""' "q -o~ c-') mrr! 1''T1 z~' V -71 ::z:~: N .-, ,-~" w>, db -<2.-- :'.) (L, r-: r--, -:< "--' ""D ~i~:J~ )>~, zu :l;:: c~::C5 S>C) c w Pin1 Z "=i =< d;:; {"" =< . ~'~~,~",. .~~ '.~"" SHERIFF'S RETURN - REGULAR CASE NO: 2000-07215 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CSH INDUSTRIES VS CUMERLAND SERVICES CPL, MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CUMBERLAND SERVICES the DEFENDANT , at 0016:25 HOURS, on the 24th day of October 2000 at 3 S 40TH ST CAMP HILL, PA 17011 by handing to JOHN BLAIN (GENERAL MANAGER) 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 18,00 8,68 .00 10.00 ,00 36.68 So Answers: ~~ ~-f:~~ R. Thomas Kline 10/26/2000 YOFFE & YOFFE Sworn and Subscribed to before By: me this 31,,0- day of (])~ ~ A.D. ~L C' )n,PO,^" ~ r thonotary I ,~~ I, I:, ~ . biii- .', " ,~ ~il-_o'_' , CSH INDUSTRIES, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 2000-07215 CUMBERLAND SERVICES, Defendant CIVIL ACTION-LAW RESPONSE OF CSH INDUSTRIES TO NEW MATTER OF CUMBERLAND SERVICES 78. After reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of paragraph 78. The same is therefore denied. By way of further response, if Defendant properly disclosed to Plaintiff that Defendant was going to resell the product then no sales tax is owing. To date, Plaintiff is under the impression that Defendant was the end user of the product referred to in paragraphs 5, 19 and 56 through 60 and therefore Plaintiff feels it is obligated under the law to charge sales tax, 79. After reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of paragraph 79. The same is therefore denied. By way of further response, if Defendant properly disclosed to Plaintiff that Defendant was going to resell the product then no sales tax is owing. To date, Plaintiff is under the impression that Defendant was the end user of the product referred to in paragraphs 38, 63 through 68, 70, 74 and 75. 80. Denied. The first Plaintiff heard of the complaint about sales taxes was when Defendant raised it in New Matter. 81. Denied. Even if Defendant did spend the time alleged, as a matter of law, Defendant is not legally entitled to recover damages for that time via a set off or otherwise. By way of further response, " _'l --.w............."""" " Plaintiff is without knowledge or information sufficient to form a belief as to how much time Defendant spent reviewing and auditing invoices to determine whether sales tax is owing. That a significant amount of time was spent is therefore denied. WHEREFORE, CSH Industries requests judgment against Cumberland Services in accordance with the complaint filed in this case. YOFFE & YOFFE, P.C. BY~~ {:JEFFREY . YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 csh\cumberland\response - ~">ll" F.ILE, No. 421 08/11 '01 10:05 ID:YOFFE & YOFFE P.C. 717 975 1912 PAGE 2 V~~[l.IFIC7\rION I hereby state that l am an aclule indivj,Qual who is author;,2ed to make th:i.s veri.,flcation and that the facts set f(l,r.th In the f()rego.i.ri.9 cesponse to New Matter are I:rue co the l)est of my knowl.edge, information, and belief. I undo1.'stand that false s'catemencs herein arc made subject to the penalties of 18 I?a. (:.S, S4904 relating to unswol'n Calsiflcation to authorities. Dated: TITLH:: /fe'S ....,~"_~. _""~ m~__ ~ , ~';1_ CSH INDUSTRIES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS, NO, 2000-07215 CUMBERLAND SERVICES, Defendant CIVIL ACTION-LAW CERTIFICATE OF SERVICE The undersigned certifies that on the date indicated below, he served a true and correct copy of the foregoing Response to New Matter on Dennis J, Shatto, Esquire. Service was accomplished by depositing the same in the United States Mail, first class, postage prepaid and addressed as follows: Dennis J. Shatto, Esquire 111 Locust Street Harrisburg, PA 17101 YOFFE & YOFFE, P,C, Dated: 8/17/01 By J. FFREY Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No, 52933 CSH\cumberland\certsvc "~'" lJ'Jilln'iJij,~r",_eS:~iHi~~,,~1l:llJt:ijIJ{.-ClIf"'0li!JG~~' ,,,,," "",,,,,";d',,,o<_-*-iJ:'J;f'-'i:'t~..._tH!liQ~!itlll.lliat1iijidl ,]',,"9 _,w,~"",' " ,."", -. ''', '''-r",.-''''''"' ," .0', " ""-, ","'_',-_ ,~ "., ~,',"'" ," " - ,,~ ,,", n'," ~........ 2 I~ f':;' ?:: DJ> uCi} c: rTlr,' :.7) Z::-u zc ''0 (f),'" -<,~ ,.~. '-0 J <: :D'" ;I~=:.: "">--. zt.J - ::.-;:c) ---=0 (5[1'; >c --1 Z :::> :;r:.-.'- :< :rJ -< r I. ',," ,-, --"'-" CSH INDUSTRIES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 00-7215 CUMBERLAND SERVICES, Defendant CIVIL ACTION - LAW NOTICE TO: CSH INDUSTRIES c/o Jeffrey N. Yoffe, Esquire YOFFE & YOFFE, P.C. 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 You are hereby notified to plead to the within New Matter within twenty (20) days from service hereof or a judgment may be entered against you. By nis J. Shatto, Esq PA Attorney ID 25675 111 Locust Street p, O. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 Attorneys for Defendant I ' ~ ~ CSH INDUSTRIES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-7215 CUMBERLAND SERVICES, Defendant CIVIL ACTION - LAW ANSWER TO COMPLAINT WITH NEW MATTER 1-3. Admitted. 4-6. Admitted in part and denied in part, It is admitted that the products were sold. It is denied that there is any unpaid balance. The invoices were paid by check dated July 18, 2000, 7-8. Admitted. 9-13. Admitted in part and denied in part, It is admitted that the products were sold. It is denied that there is any unpaid balance. The invoices were paid by check dated July 18, 2000, 14-16, Admitted. 17-19, Admitted in part and denied in part. It is admitted that the products were sold_ It is denied that there is any unpaid balance. The invoices were paid by check dated July 18, 2000. 20. Admitted, 21-23. Admitted in part and denied in part. It is admitted that the products were sold. It is denied that there is any unpaid balance, The invoices were paid by check dated July 18, 2000, 24-29, Admitted. 30-35, Admitted in part and denied in part, It is admitted that the products were sold. It is denied that there is any unpaid balance. The invoices were paid by check dated July 18, 2000, , 0 = ,c, 0 " ',I . ;):, .- -ci.,~J- ,', - , -"-~ " H~.',- , ""- H,,,, 36-41. Admitted. 42, Admitted in part and denied in part, It is admitted that the products were sold. It is denied that there is any unpaid balance. The invoices were paid by check dated July 18, 2000. 43. Admitted, 44-60. Admitted in part and denied in part. It is admitted that the products were sold, It is denied that there is any unpaid balance, The invoices were paid by check dated July 18, 2000, 61, (Invoice 003598- 00) Admitted. 61, (Invoice 003519-01) Admitted in part and denied in part, It is admitted that the products were sold. It is denied that there is any unpaid balance. The invoices were paid by check dated July 18, 2000. 62-75. Admitted. 76. Denied. Many of the invoices have been paid. The answers to paragraphs 3-75 are incorporated herein by reference, 77. Denied, Many of the invoices have been paid. The answers to paragraphs 3-75 are incorporated herein by reference, WHEREFORE, Defendant requests that the relief demanded by Plaintiff be denied, NEW MATTER 78, Plaintiff improperly charged sales tax on the invoices identified in paragraphs 5, 19 and 56 through 60 in the total amount of $86.98, which is a set-off against any amounts owed to Plaintiff. 2 .' :l_-, ,>_ i- , ," l_~ '. ~.A;.,;,< 79, Plaintiff improperly charged sales tax on the invoices described in paragraphs 38, 63-68, 70, 74 and 75, in the total amount of $l09.41, which is a set-off against any amounts owed to Plaintiff. 80, Despite numerous requests, Defendant has failed and refused to properly calculate sales taxes and to properly credit for sales taxes which should not have been charged, 8l, Defendant expended considerable time and effort in reviewing and auditing invoices to determine whether or not sales taxes were improperly charged, and claims a monetary set-off for the reasonable value of the time and effort expended. WHEREFORE, Defendant requests that the relief demanded by Plaintiff be denied. Respectfully submitted, CLECKNER AND FEAREN By d1AAJJ& Dennis J, Shatto, Esquire Attorney rD No. 25675 III Locust Street P. 0, Box ll847 Harrisburg, PA l7l08-l847 (7l7) 238-l73l Attorney for Defendant, Cumberland Services 3 --,I ~ ~i<-o , , , . CERTIFICATE OF SERVICE I, DENNIS J. SHATTO, hereby certify that I served a true and correct copy of the foregoing document upon the person (s) indicated below, by depositing same in the United States mail, posta::; County, Pennsylvania, this '3 a~arriSbUrg, Dauphin ,A tj , 2001. prepaid day of Jeffrey N. Yoffe, Esquire YaFFE & YaFFE, P.C. 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 By Dennis J, Shatto, Esquire PA Attorney ID #25675 111 Locust Street P. O. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 ,~",; ,', .-..' .,,~, ~, ,~ ~- ,~ hll!~ . ' ~w -"(HO' ~~~,,4#r' --," ^>" '..,,-" ,'" -~~ -" ~,,, ,,~" ,""..:; . . ,,,' "'"'''''' -,-, , , ~ ",,'~ ~ ^ " ...,..... " ._."..... ""H... .... 0 (,-:J- C ~--;;~ "T) C~;! .-'..", m ten, .;..c<l' Z -"," -< 2~ ". GO )-.~ , .. -< .;. ~~_:I ~Q :=~ ~,," . ~-C j -~-:- >c t.J C) Z ~~l :< 0 :D -< . . I .. . ~ ',-,+~,; >:'l1'"c' ~" ~~' , CSH INDUSTRIES, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NO. 00 - 7J.JS G'ud.. {~ CUMBERLAND SERVICES, .. Defendant CIVIL ACTION-LAW 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 are served, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 or (717)249-3166 NOT I C I A Le han demandado a usted en la corte. si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presenter una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defenses 0 sus objeciones alas demandas en contra de su persona. Sea avisado gue 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 INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 or (717)249-3166 csh\cumberland\complaint '0 .,. ..:;.. , -": ~4 J CSH INDUSTRIES, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA M_ -1.uS ~ ~ NO. vv Plaintiff VS. CUMBERLAND SERVICES, Defendant CIVIL ACTION-LAW COMPLAINT I. Plaintiff is CSH Industries located at 2500 Old Gettysburg Road, Camp Hill, PA 17011. 2. Defendant is Cumberland Services located at 3 S. 40th Street, Camp Hill, PA 17011. 3. On December 28, 1999 CSH Industries sold to Cumberland Services various commercial products at invoice No. 001998-00. The unpaid balance owing to CSH Industries for those products is $616.63. 4. On February 17, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002793-00. The unpaid balance owing to CSH Industries for those products is $13.33. 5. On March 10, 2000 CSH Industries sold to Cumberland Services various commercial products at invpice No. 003197-00. The unpaid balance owing to CSH Industries for those products is $621.58. 6. On March 20, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003317-00. The unpaid balance owing to CSH Industries for those products is $65.32. 7. On April 6, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003560-00. The unpaid balance owing to CSH Industries for those products is $237.44. ,~~ 8. On April 28, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003934-00. The unpaid balance owing to CSH Industries for those products is $200.61. 9. On February 3, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002491-00. The i I i unpaid balance owing to CSH Industries for those products is $76.11. 10. On February 7, 2000 CSH Industries sold to Cumberland I i Services various commercial products at invoice No. 002650-00. The unpaid balance owing to CSH Industries for those products is $306.54. 11. On March 2, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003078-00. The unpaid balance owing to CSH Industries for those products is $45.26. 12. On February 7, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002652-00. The unpaid balance owing to CSH Industries for those products is $306.54. 13. On March 2, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003079-00. The unpaid balance owing to CSH Industries for those products is $45.26. 14. On April 5, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003585-00. The unpaid balance owing to CSH Industries for those products is $121.65. 15. On April 6, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003624-00. The unpaid balance owing to CSH Industries for those products is $107.27. ~~ ~ M "" 16. On April 6, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003626-00. The unpaid balance owing to CSH Industries for those products is $45.26. 17. On February 23, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002955-00. The unpaid balance owing to CSH Industries for those products is $40.07. 18. On March 16, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003295-00. The unpaid balance owing to CSH Industries for those products is $177.56. 19. On March 30, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003491-00. The unpaid balance owing to CSH Industries for those products is $79.61. 20. On April 5, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003595-00. The unpaid balance owing to CSH Industries for those products is $42.87. 21. On March 2, 2000 CSH Industries sold to Cumberland Service various commercial products at invoice No. 003012-00. The unpaid balance owing to CSH Industries for those products is $118.88. 22. On March 15, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003012-01. The unpaid balance owing to CSH Industries for those products is $28.54. 23. On March 21, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003335-00. The unpaid balance owing to CSH Industries for those products is $28.89. I ..',~, 24. On April 3, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003553-00. The unpaid balance owing to CSH Industries for those products is $69.80. 25. On April 3, 2000 CSH Industries sold to Cumberland Service various commercial products at invoice No. 003554-00. The unpaid balance owing to CSH Industries for those products is $5.63. 26. On April 10, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003637-00. The unpaid balance owing to CSH Industries for those products is $40.70. 27. On May 15, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003515-00. The unpaid balance owing to CSH Industries for those products is $87.76. 28. On April 10, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003674-00. The unpaid balance owing to CSH Industries for those products is $26.92. 29. On April 24, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003855-00. The unpaid balance owing to CSH Industries for those products is $143.63. 30. On February 22, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002783-00. The unpaid balance owing to CSH Industries for those products is $519.40. 31. On February 23, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002956-00. The unpaid balance owing to CSH Industries for those products is $46.22. ..~ . .I '-"~it .' 32. On March 9, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003193-00. The unpaid balance owing to CSH Industries for those products is $111.66. 33. On March 13, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003224-00. The unpaid balance owing to CSH Industries for those products is $76.26. 34. On March 21, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003347-00. The unpaid balance owing to CSH Industries for those products is $553.85. 35. On March 24, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003381-00. The unpaid balance owing to CSH Industries for those products is $60.23. 36. On April 19, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003809-00. The unpaid balance owing to CSH Industries for those products is $31.27. 37. On April 28, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003947-00. The unpaid balance owing to CSH Industries for those products is $41.37. 38. On May 3, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004041-00. The unpaid balance owing to CSH Industries for those products is $78.72. 39. On May 5, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004074-00. The unpaid balance owing to CSH Industries for those products is $17.74. . "~IC , 40. On May 16, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004207-00. The unpaid balance owing to CSH Industries for those products is $40.53. 41. On May 16, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004208-00. The unpaid balance owing to CSH Industries for those products is $81.94. 42. On September 17, 1999 CSH Industries sold to Cumberland Services various commercial products at invoice No. 039216. The unpaid balance owing to CSH Industries for those products is $404.51. 43. On December 28, 1999 CSH Industries sold to Cumberland Services various commercial products at invoice No. 001997-00. The unpaid balance owing to CSH Industries for those products is $569.48. 44. On January 31, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002569-00. The unpaid balance owing to CSH Industries for those products is $130.46. 45. On February 8, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002668-00. The unpaid balance owing to CSH Industries for those products is $840.97. 46. On February 15, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002781-00. The unpaid balance owing to CSH Industries for those products is $755.65. 47. On February 17, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002847-00. The unpaid balance owing to CSH Industries for those products is $225.82. '~" ,. 48. On February 22, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002916-00. The unpaid balance owing to CSH Industries for those products is $854.37. 49. On February 25, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 002959-00. The unpaid balance owing to CSH Industries for those products is $62.33. 50. On February 29, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003031-00. The unpaid balance owing to CSH Industries for those products is $52.70. 51. On February 29, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003022-00. The unpaid balance owing to CSH Industries for those products is $762.30. 52. On March 6, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003124-00. The unpaid balance owing to CSH Industries for those products is $994.04. 53. On March 8, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003099-00. The unpaid balance owing to CSH Industries for those products is $138.22. 54. On March 10, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003194-00. The unpaid balance owing to CSH Industries for those products is $235.25. 55. On March 15, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003250-00. The unpaid balance owing to CSH Industries for those products is $503.19. ,1,- _. I "-~!- . . 56. On March 15, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003263-00. The unpaid balance owing to CSH Industries for those products is $288.47. 57. On March 21, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003342-00. The unpaid balance owing to CSH Industries for those products is $1,036.46. 58. On March 27, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003415-00. The unpaid balance owing to CSH Industries for those products is $398.84. 59. On March 30, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003519-00. The unpaid balance owing to CSH Industries for those products is $604.28. 60. On March 30, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003453-00. The unpaid balance owing to CSH Industries for those products is $108.88. 61. On April 6, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003598-00. The unpaid balance owing to CSH Industries for those products is $370.16. 61. On April 10, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003519-01. The unpaid balance owing to CSH Industries for those products is $26.81. 62. On April 10, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003644-00. The unpaid balance owing to CSH Industries for those products is $511.86. - , ~ .. l ~1\ ~ 63. On April 14, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003717-00. The unpaid balance owing to CSH Industries for those products is $567.52. 64. On April 24, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003644-01. The unpaid balance owing to CSH Industries for those products is $165.36. 65. On April 24, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003598-01. The unpaid balance owing to CSH Industries for those products is $110.24. 66. On April 24, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003830-00. The unpaid balance owing to CSH Industries for those products is $932.20. 67. On April 25, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003876-00. The unpaid balance owing to CSH Industries for those products is $382.28. 68. On May 2, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003997-00. The unpaid balance owing to CSH Industries for those products is $423.37. 69. On May 3, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004031-00. The unpaid balance owing to CSH Industries for those products is $152.06. 70. On May 4, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004057-00. The unpaid balance owing to CSH Industries for those products is $856.59. ~i;F.' . . 71. On May 11, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 003830-01. The unpaid balance owing to CSH Industries for those products is $35.25. 72. On May 11, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004129-00. The unpaid balance owing to CSH Industries for those products is $572.47. 73. On May 16, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004202-00. The unpaid balance owing to CSH Industries for those products is $347.83. 74. On May 18, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004129-01. The unpaid balance owing to CSH Industries for those products is $74.09. 75. On May 19, 2000 CSH Industries sold to Cumberland Services various commercial products at invoice No. 004274-00. The unpaid balance owing to CSH Industries for those products is $528.23. 76. CSH Industries has requested that Cumberland Services pay the aforesaid balances set forth above, however, Cumberland Services has not paid the same. 77. The total amount owing to CSH Industries by Cumberland Services is $20,381.39. "--., ~'t'--: , . . WHEREFORE, CSH Industries requests judgment against Cumberland Services in the amount of $20,381.39 plus whatever interest or late charges may accrue up until the date of judgment. YOFFE & YOFFE, P.C. FFRE N. OFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 CSH\cumberland\complaint -' .. -~ir r . VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Complaint are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. CSH Industries Dated: B~ MELINDA A. ORT 0 ~"!i!lMru:lJMJl'~F.~!~~J~&l;~':ilc;~~LIei.:J,,;"~,HS'~~I~jI~i~i"~I~""-'~ IlJi ~. -"CO', "-'<- . '~ ~! . (0 ~ ~ '6q, f'. ~ 1t- It.. ~ !'t .)J 8 0 CI) (') (~ 13\ c coo. 8 0 (). -..,. - ,~ }oJ l'I"l I ;:R ~:':;;' --j "^~1 r- 5"- fP ?' ~ Z ~ ,'-'-, c' \.;".' r-~ ~ _'e"{'''. -" 5:~';:: c.:J ; , ~ ~, .' , :.n -< (II ~~ ,. OM -"., ~ '^'".~~ CO', ,~, n ,_, ___ '1,-,-' .-._-,;,;~,,,,;,,, ,,~, CSH INDUSTRIES : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 00-7215 CIVIL TERM CUMBERLAND SERVICES IN RE: ARBITRATION ORDER OF COURT AND NOW, November 28, 2001, the Court having been informed that the above-case has been settled, the panel of arbitrators previously appointed is vacated and the chairman, John H. Broujos, Esquire, shall be paid the sum of $50.00. By the Court, P.J. Court Administrator .~0 i(~ t:- ~ ~C\ John H. Broujos, Esquire Chairman '~--'~~'~kti'Iim]i!J~~._;jJ':J;jjl~:i'~~~~.'''' "-iIitIiI!jj.("'-~"'~-'''"W'~"'" "-I'lft '""c. 'c-' " u /) J \i!r<WI1ASNN3d , "'r.rv', ,p. tcr,u:]Qif"n" ~l\ ',I~),., \;"-'l,' ",-,,;<.;,1 IV ~ 6 :t: J 8:: !lON 10 .:-", o ~;_, "'r", ;,~, ^' ,-",^, ""'",-~' .,-~ "';<"~ ,-", 'f-,_ oj" h _'~'''_'' " _ .".~ " .~" ?/'I',""~~','_,~~._" ~"~"--"-:C ,~" -,'-,~. ~rw ~', ,-," iC I ! , 't " ,u,~ ;:; - -~" i'-,L!~i\C,' .:I CSH INDUSTRIES : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 00-7215 CIVIL TERM If" CUMBERLAND SERVICES IN RE: ARBITRATION ORDER OF COURT AND NOW, November 28, 2001, the Court having been informed that the above-case has been settled, the panel of arbitrators previously appointed is vacated and the chairman, John H. Broujos, Esquire, shall be paid the sum of $50.00. By the Court, P.J. John H. Broujos, Esquire Chairman Court Administrator