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Home My WebLink About01-0014 FX N' , OLIN, NEIL & HAL TRECHT By: Burton Neil, Esquire Identification No. 11348 . 26 South Church Street West Chester, PA 19382 610-696-3030 Attorney for Plaintiff GRlNNELL FIRE PROJECTION SYSJEMS COMPANY 9640 Garwig Lane, Columbia, Maryland Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. MATI CORPORATION 2016 Yale Avenue, Camp Hill, Pennsylvania Defendant NO 0(-14 Cll)'l \ CIVIL ACTION - LAW COMPLAINT 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 (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 claim 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 TIIE OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone No. 800-990-9108 '''-< ~ II ~ ~~, c .. ' . OLIN, NEIL & HAL TRECHT By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 Attorney for Plaintiff GRINNELL FIRE PROTECTION SYSTEMS COMPANY 9640 Garwig Lane, Columbia, Maryland Plaintiff IN THE COURT OF COMMON PLEAS v. MATT CORPORATION 2016 Yale Avenue, Camp Hill, Pennsylvania Defendant CUMBERLAND COUNTY, PENNSYLVANIA No.81-14 Ct0l\ CML ACTION - LAW Complaint 1. The plaintiff is Grinnell Fire Protection Systems Company, a business corporation, with place of business located at 9640 Garwig Lane, Columbia, Maryland. 2. The defendant is Matt Corporation, a business corporation, with place of business located at 2016 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania. 3. At the instance and request of the defendant, the plaintiff provided labor and materials to defendant at the times, of the kinds, in the quantities, for the prices and pursuant to the terms set forth in plaintiff's invoice to defendant a copy of which is attached hereto, made a part hereof and is marked Exhibit A. 4. The prices plaintiff charged defendant were fair and reasonable and were the prices defendant had agreed to pay plaintiff. 5. From time to time, plaintiff sent to defendant statements reflecting a balance due plaintiff in the sum of$8,415.00, which statements defendant received without protest. 6. Although demand was made by plaintiff upon defendant to pay the sum of$8,415.00, the defendant failed and refused to pay all or any part thereof 8. Plaintiff is entitled to interest at 6% per annum from September I, 1999. Wherefore, plaintiff demands judgment against defendant in the sum $8,415.00 together with interest at 6% per annum from September I, 1999 and the costs ofthis action. C ;O~ECH~ Burton Neil, Esquire Attorneys for Plaintiff """'fir ,-, I-I -, 03/06/00 08:56 NO. 639 (;102 INVOICE POBOX 360721M PITTSBURGH, PA 15251 Ole INvOrCE PAtE DUE O,ll,U TICKET # -1 07/22/99 08/01;99 083-452907 TO: POBOX 901 CAMP HILt., PA .1.7001-0901 P.O.' STATE BUILDING POR: 500 NORTH 3RD STREET we: HARRISBURG DATE: 07/23/'39 BLACK 1'1' B H. NO P.EFEREHCE DESCRIPTION UlUTS FIXED co::;r SUB TOTAL - MATERIAL 1. SA RATB 8415.000 .."J40 U NT 1 8,415.00 8,415.00 INVOICE TOTAL 8,'115.00 INVOICE COMMENTS: LABOR ASD MATERIAL TO ADD ANO RELOCATE HEADS PER OUR APRIL 16, 1999 QUOTB TO YOU Thank you for your business, t~..c~ A MAIL ALL PAYMENTS TO THE ABOVE REMITTANCE ADDRESS A 'fuca INTERNATIONAL LTD. C:OMPAN1 .,'w ""r-~''''''- 11- "~- _. ~.J ,.,,", ' . Verification UEe,o€AH A. )..J,q LL is bSTR.Ic.., LREDIT tl..1IWIMS2- (Title or Position) (Name of autllOrized representative) for, (Jl2lNAllbLL ~~ ~=-.JIOJ (Name of Company) , the within Plaintiff, and makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: /D/21../m I I ~~C/~ ~~ ,,1. 7it0 ~~ - D en ~ S. -r:l \) qJ ,.I~~ ',~ . -~ ..~. H ,._. '~M ~ ..J:::::' C)J ce .. (J G - -.. z. 2:' ~~ ~ ~= -+ -:"\ P1 ~ , $ "..~ ','.'. -'" ,.. ~ (') ~: 'Ui'._"c flli'< z-.::; 21:, c';,,"" r-,"-- <\" ~~ M'< . '- c') , i-""'J ,In '. ' !,..."'l , :tl1 ~~-:) C) _'_J _c ~ ~~, ,,~~"'"~,~ I'i':"lIfl(JJJt~ ..~~~ifflW'!l'f<r;1""~';{ij"~"'~;f?"P";'":i1~Mjl~~~ftl!lHl1m~~:1!ff"'~~'M?1~~~~_ '~rl'%'~;J SHERIFF'S RETURN - REGULAR CASE NO: 2001-00014 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRINNELL FIRE PROTECTION SYSTE VS MATT CORPORATION RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MATT CORPORATION the DEFENDANT , at 0014:35 HOURS, on the 3rd day of January ,2001 at 2016 YALE AVE CAMP HILL, PA 17011 by handing to CHARLES DAVIS (PRESIDENT) 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 So Answers: 18.00 9.30 .00 10.00 .00 37.30 -r; ~ ~<~ ,. R. Thomas Kline .., ":' Ol/04/2001 OLIN, NEIL Sworn and Subscribed to before By: me this 10 ~ day of q~ kv( A.D. 9;:~~n~/~ '"""''''_.=T'''' - II -~ , " GRINNELL FIRE PROTECTION SYSTEMS COMPANY 9640 Garwig Lane, Columbia, MD IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-14 MATT CORPORATION 2016 Yale Avenue Camp Hill, PA 17011 Defendant : CIVIL ACTION - LAW PRAECIPE FOR DEF AUL T JUDGMENT TO THE PROTHONOTARY: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant(s), and assess damages as follows: Principal: Interest: $8,415.00 $800.93 BALANCE DUE: $9,215.93 Understanding that false statements herein made are snbjectto penalty under 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at leastten days prior to the date of the filing of this praecipe. ::<~:Z)HT ~__v~ Burton Neil, Esquire Attorney for Plaintiff LD. #11348 POBox356, W. Chester,PA 19381 JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDE PA.R.CIV.P.236 ."" , 't-'.",-c/ . -,^, <o'--~ '.,__,",__Il"'I., "- ".". ,,-, ~,,~~-, " -' ~ aLIN, bffiIL &.HALTRECHT BY: ~urton Neil, Esquire , Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 ATIaRNEY FaR: Plaintiff GRINNELL FIRE PRaTECTION SYSTEMS caMP ANY Plaintiff : IN THE caURT aF caMMaN PLEAS : CUMBERLAND CaUNTY, PENNSYLVANIA VS. MATI CaRPaRATIaN : NO.. 01-14 . Defendant : CIVIL ACTION - LAW NOTICE OF INTENTION TO FILE PRAECIPE FOR DEFAULT JUDGMENT TO: Matt Corporation 2016 Yale Avenue Camp Hill, PA 17001 DATE OF NOTICE: January 24, 2001 . . IM!,aRTANT NOUCE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or obligations to the claims set forth against you. Unless you act within ten (10) days from 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 your 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 CaUNTY BAR ASSaCIATION 2 Liberty Avenue, Carlisle, PA 17013 Telephone: 800-990-9108 OLm~TREC~ BY ) .. . ~". urton Neil, E~;;ire '. Attorney for Plaintiff ~)"'1l". . ,1'1 i,'" '.t., ,,"~ ,lIIIl~~, l"l!'I~,~,_ ," -. , t i p -4Q ~ ..0 0 ("..) \ c S;? 8 .:~. .. vft :z ~1 mr"'--, ):;.u .... ..... z':-.i', ;:::; ;"..:", () ~ ~~.-, I'c> &J ~-~!., c;2~ ~ ~ ~~~~ <::;:) (' r ~c:- IV ~ ~:o ;:::; --'-- ... 6"- :~c.::., .~) ;.~! ~ J Pc ~'7 '. ; S~ r:5fT"j ~ 2: :::-1 -I ,;:.) ~.,. -< c::n ::v -< ~,lf!l ,'~ .~.~~-j1j:~~.'I'i"-"""" "N"'ljjn\,~;r,~.-o;:;r:''''~'\'''<W\~:'!'!!'II1,~~~~;~~lm'l1llJli1~~:~~~I!lI~.11! PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) PaRC.P. ~ 3103 to 3149 GRINNELL FIRE PROTECTION SYSTEMS COMPANY : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-14 MATT CORPORATION Defendant : CNIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. 3. against Matt COI:poration and against , Defendant(s) , Garnishee( s) 4. and index this writ ( a) against (b) against Defendant( s) Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) All personal property located at: 2016 Yale Avenue, Camp Hill, PA 17011 Amount Due Interest from 3/20101 Total *Plus writ costs Dated: October 4, 2001 5. $9,215.93 $ 303.35 $9,519.28* ( //1- 6 '" Burton Neil, Esquire .k!. Attorney for Plaintiff NOTE: Under paragraph I when the writ is directed to sherifI of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as anthorized by Rule 3104(a}. When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b}. Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). j,)" I': ,.,"--- "1-1-- "1rl ...[ N ::-\..r: o t (' I 'r Vl ~p [ ~""rS' ::, ". '" _J t l1.,.,.." , -, " . ~ ,,~'>< "' '"". . ..,.,~ '~- ".~-'"h>io~ "''''' +,;,-',n:, 1.1' '''''''~k '''''''~'''n "r.'~" ,.~c:iJ"%,""" ,;, ~;Y._"fi\~': "",.~,'""i;",__r'",-,,,.., ......".IIIII!!!! r ~ ~ Q ~ .... ..... C:) ..... "- ~ ~ v, . " c l..; ~. " \. (:1"1 ~ .... ~ ~ ., ~ .... '" -l:; w .. ~ - '<> . .'\ :--') ,.:l ~, ~ ~ t.,., ~'0 a '" ~ " " "- ~ ~f) )'-. ~~ t .".~ " ,".. W'Il!!Il'!!f>m ," __ """".:4-~,,,. "., . ~~J. " .,~ -. <.,.., ' ,,,' II ~..".".f~~ I!llm~~ r""'~ ,-:W" ,.,...,." IJi!J ~ liE: ~ j~>;lJi , r R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Advance Costs: Sheriffs Costs: 150.00 106.69 43.31 Docketing $ Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale 15. 00 Garnishee 18.00 2.09 10.00 .50 1.00 20.10 Refunded to Atty on 1/30/02 106.69 Sworn and Subscribed to before me This ~ay of q,m'Aj 2002 A.D. qa.y-z:.......Q ~,j(J""' ,~- rothonotary so~~e~.' // . ~~r~e' ~ , '- ~ R. ThO. ~as Kline, Sheriff. . By Q 111/ ~o. Ci-,--t1~VsJi( "'[ , (... ~ I !,)":l d VI q'd f.. \ ~ ~', ~l-, t,.':1 - 'I T ,:', 1\." ~ -,'. ","- '~-:' lu. ~\~ lE b \ \ 1:10 _,,' . ~,,} 11\\8 ).1h.'.",.. L',,;j:,ldJO H1UjM\' ,n -, - . "sO <:-Ii- J~-z,'/:l..J f!...v. 12/.21. 3 -"'.-- 1""1 .n'lJr ~ ~ 9jt. ~, . , . "~"V' '6'M""" "";' ~, "-i.'>"~ -',,", ~ - 'r~_;;_">~""-"-"--,,,w-~'''~nIl~'r( ':~~']''' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-14 CIVILJRr 'IERM CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland To satisfy the debt, interest and costs due COUNTY: Gri nn.. 11 Fi rf' FTnt..r.ti on S,ystffilS Cannanv PLAINTlFF(S) from Matt COrPOration 2016 Ya].. Avent]... Camp Hill. Fa. 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell All personal propertv located at: 2016 Yale Avenue. CAmp Hill. Pa. 17011 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) iSfare enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. L.L. $0.50 Due Prothy 1 .00 Other Costs Amount Due ~9.215.93 INterest fran /20/01 Interest 101.1') Atty's Comm % Atty Paid 109.30 Plaintiff. Paid Date: October 10, 2001 Curtis R. Lonq Prothonotary, Civil Division by: q..'r" () ~'p;,__ Deputy REQUESTING PARTY: Name BlIrton Nei 1. Esqtd re Address: 26 South Church Street West Chester, Pa. 19382 Attorney for: Plaintiff Telephone: 610-696-3030 Supreme Court ID No. 1_,_ ~~~~~.~~~mII!1\l1~f'_~a"W'i"1"'-l_~-!'-f'f'~~""'."''''-",~0'"'-'.,i'1-''"'1'<,:;rm'J~~lfl!~t"flirlfffilJ",>!;~~