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Home My WebLink About01-2796 FX """,_.~-~- L,", ,.1 '- ;,,' ,--.'J,'''-''';'" "~~i'~t\ ,- <It, ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- -;;2. 7 9(p CIVIL TERM RICHARD GREER TRUCKING, INC., Defendant 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 of 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 (717) 249-3166 II ,;-~. "1. < . 1,1 ,I ,~.'- , .--,. .,~~ " ~ ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.01- .119t.p CIVIL TERM RICHARD GREER TRUCKING, INC., Defendant COMPLAINT 1. Plaintiff, All American Plazas, Inc. is a Pennsylvania business corporation with a registered address of P.O. Box 657,1181 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, Richard Greer Trucking, Inc. is presumably a Missouri corporation with a last known address of 8888 B Hall Street, St. Louis, Missouri, 63147. 3. At all times relevant hereto, Plaintiff, All American Plazas, Inc., hereinafter All American, was in the business of providing diesel fuel and truck repairs to the Defendant and other similarly situated businesses. 4. From 1999 to the present the Defendant, Richard Greer Trucking, Inc., did utilize the services of All American at various locations owned by the Plaintiff for both the purchase of diesel fuel as well as truck repairs,. 5. At some point in the year 2000, the Defendant fell seriously behind in it's account with the Plaintiff and the President of the company, Richard Greer, indicated to the Plaintiff that he would make lump sum payments to in order to bring the account current. 6. Based on such assurances the Plaintiff did continue to extend the credit of the I Defendant which credit continued through the year 2001. 7. As a result of these assurances the Plaintiff did extend credit to the Defendant of the purchase of diesel fuel and other services in an amount of $76,231.57 with a credit for payments of $255.48 and a net balance due of $75,976.09. II - . -~ ,I, ..-1 I ',J ' d ,- '~'t~ .-' ,""',,,,-" 1, ~ ;-'~ -''''''"~~1 8. Despite repeated demands, the above sum has remained unpaid as of the date of this Complaint. WHEREFORE, for all the above reasons, the Plaintiff, All American Plazas, Inc., request judgment in its favor in the amount of $75,976.09 plus interest and costs of suit. Respectfully Submitted TURO LAW OFFICES c;- / ~!o/ Date on ur, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II ^'~~-~~ L J. -, ' "-," ,- - '"I - , _, 1:,,' " _ ~ . "-'~''-- -.. '-''''--;;; ~" VERIFICATION I, Ron lura, Esquire, am the attorney for All American Plazas, Inc. and am I familiar with the facts concerning the above Complaint against Defendant, Richard Greer Trucking Company, Inc. and I swear and affirm that the facts set forth in the Complaint are true and correct to the best of my knowledge, information and belief which have been provided to me by my client or gathered by myself during the preparation of this Complaint. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. ~!?ilo/ Date n Turo Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 H Jl~gl~~~t~iWi!;~I~~~M'.j""~":&l';t~i;"""q"";"';"'"','",";M',,,~"",'~r-",r~iWw~*ff1 ~~", .t ~<'u.: Z~ " ,,<'- '\"'- .. ~> -". '1 ,-", ~ili.J!iilHar ...." 'H i(~_if:.lKi.IltllllID [~ .. Ii i~ I: ! 0 Ci C :?' "Jfi"]- ~~,.. DJfT; " .<.:_ =r' -_.- 2"'r-': , ,--, 0))7'- \D .-:c -<~ . ~'" ~:cj ~ ~.} ~:() , :'f:c! >'c LO (') rr 2-.:: .::;> ~,::-I :< ~ (;:) -L.' -< @) ~ Jr ~ ... -C. ~, ..c. !'i c ~ ~ ~ r r ", . [-" _L " ~ , " .1 , nr f.I l:tlJ!;i'g(- ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.01- ~79~ CIVIL TERM RICHARD GREER TRUCKING, INC., Defendant AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Complaint filed in the above captioned case upon Richard Greer Trucking, Inc., by certified mail, return receipt requested on May 10, 2001 addressed to: Richard Greer Trucking, Inc. 8888 B Hall Street S1. Louis, MI 63147 and did thereafter receive same as evidenced by the attached Post Office receipt card dated May 14, 2001. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES 4t/ol Date on Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff H / ... 4U ftmBV. CAJ0 LoJVlPUJ1/JT' Z- 452 476 225 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail 'See reverse Postage Certified Fee Special Delivery Fee Restricted Delivery Fee '" ~ Retum Receipt Showing to ..- YVhom & Date Delivered ~ RetumReceiptShowingtoWhom, <( Date, & Addressee's Address Q ~ TOTAL Postage & Fees en Postmark or Dale E ~ (f) a.. (,60 $ ~ MliY /D1 eDOI ......- ~ SENDER: "C Ul CI Complete items 1 and/or 2 for additional services. tlI Complete items 3, 4a, and 4b. _ t Cl Print your name and address on the reverse of this form so-that we can return this > cardloyou. ~ 0 Attach this form to the front of the mailpiece, or on the back if space does not Q) permit __ :5 0 Write "Retum Receipt Requested' on the mailpiece below the anicle number. t:;: 0 The Return Receipt will show to whom the article was deliverm'and Ille dale o delivered. . _, ~ 'g 3. Article Addressed to: _, ~ ._n 4a. Article Number f 1(IClf/g-rt:b q/Z.fEt- n:llW05; 452. 41LP 2.25 ~ YO'Wb tlHLL ::iilZtt;'T ~ m 31- L LAIS, Ml [/3/4"1 =~ '.k~ ~ I also wish to receive the follow- ing services (for an extra fee): 1, 0 Addressee's_Address 2. 0 Restricted Delivery c c .. Z l!: ~ertifled o Insured DeOD ~ 5. R w , Receipt oi u 1: '" '" - c. 1l " l!: E " ;; l!: '" c ;;; " ~ .E " o ,.. '" c m ~ I- , . , ~~~i~1;""M:!lli;1",:-.:,,>,,,;i,;~",,.l:lI&t:llcit,,j;"'~'*"!<f<iliij;;.iJ:~.'-'iI(1liltr~-'fr't""> ~Iil --aiiIo'L ",;,,~"" ~ .! ","~,'- ,. ,~ .",,, ~>,","'""_..N_""__'"'''''''' .-" ~ ~ -, ."" n+ ""~..--,,,, ! " "'"~~tmW""""""""~~~'IF1l!W..._L () ,- ;,? -pi-,-. nir~_ ~S~': !~) ~1 -< ... " c::! ~:!;: ,'" :---',) ;:':::.-" 7':' -~-~ :'-i-~{ ~J ',- ", ~Jl '0 .::<..;: -<, h , ~ ,I I . ~, . ~. '..1'--,,-, ~- .~~oi..;~";";"~' -~, ~. '"-''''-'''''1k.''~,'''-, , i;\M~~l, ,-," . ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYVLANIA v. : NO. 01-2796 CIVIL TERM : CIVIL ACTION - LAW ~~1-+- PRAECIPE FOR ENTRY OF JUDGMENT RICHARD GREER TRUCKING, INC. Defendants TO: Prothonotary Cumberland County Courthouse 1 Courthouse Square / Carlisle, PA 170~y Please ente~~gment in favor of Plaintiff, All American Plazas, Inc. and against Defendant, Richard Greer Trucking, Inc. in the amount of $69,976.09. Defendant was served with a 10 Day Notice dated and served March 1, 2002, as evidenced by the attached copy of the Notice and Certificate of Service attached hereto and incorporated herein as Exhibit "A". a. Principal $69,976.09 b. Interest $ 0.00 c. Late charges $ 0.00 d. Attorney's fees $ 0.00 Total Amount: $69,976.09 Plus additional interest at the legal rate for every day after entry of judgment up to and including the day the judgment debt is fully liquidated. Respectfully Submitted TURO LAW OFFICES ~/z..11 0 d- o . Date II . , ~" - II " 1- . ~ ~ ">""'-'-~i\-~,~ , ( ALL AMERICAN PLAZAS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-2796 CIVIL TERM RICHARD GREER TRUCKING, INC., Defendant TO: Richard Greer Richard Greer Trucking, Inc. 8888 B Hall Street St. Louis, MO 63147 DATE OF NOTICE: March 1, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Respectfully Submitted TURO LAW OFFICES 3/. I D;J. Date I~' " ~. " __,," ~, I , '. -""\~I'i . CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Default Notice upon i Richard Greer clo Richard Greer Trucking, Inc., by depositing same in the United States I Mail, first class, postage pre-paid on the 1st day of March, 2002, from Carlisle, I I Pennsylvania, addressed as follows: ! Richard Greer Richard Greer Trucking, Inc. 8888 B Hall Street St. Louis, MO 63147 TURO LAW OFFICES J ~li"..m""JJ<l>,J:i:,~J,~",_;"j~""~'H" ,""",;,""""1-1&i<;,'"",%\k<kf,~",,,j,,,;:, ,S<,j',_','c,"",,,.h,',:'o'';"_' ,;*,'i""',<4,~"""",,.g,i,j;~j,;1J&~ilIfJI!!!lM-~~fil"W$,,''''_~''''"''''*''''li~_~ ~~ . t ~ ~ ~ n c' 0 It :-0 ,- f'" --n ~~ l'; .... -~ ..t & i:P {;'1~jJ IT' -om - - ':SJ rv :,1'1'9 F ~ &C 1~" (...0 06 ;U )...-,..,. f:! -'<'6 :::;j-r-; ~ .J ......-n ~ N v 95 1~() ~ 5rn ~ "'0 --0 "9 ':c.. It. ;;c 0- ~ - ~ RJ' -V 0" '< ...... 58 [:" ~ if /-.v ~f Hf~ J" t r ~ J]tu.,..~.,... ., _~~~_"'_'=~' ''"_._,~"_" 0 _~ ~"'~,~ -., ,~ ~ , "