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HomeMy WebLinkAbout03-2162COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON LEAS No. 21 2 ¥,,,', I Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. NAME OF APPELLANT ADDRESS OF APPELLANT CITY DATE OF JUDGMENT IN THE CASE OF (PLAINTIFF) CLAIM NO. CV YEAR LT YEAR This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No. 1008B. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case. MAG, DIST. NO. OR NAME OF D.J. STATE ZIP CODE / ?//o (DEFENDANT) If appellant was Claimant (see PA R.C.P.J.P. No. 1001(6)) in action before district Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Sk2nature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see PA R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAEClPE: To Prothonotary Enter rule upon ---~ ~3 L~2,.~'. ~_ Z. t//~ L ~'"/"~3/z.. __, appellee(s), to file a complaint in this appeal · I Narr~ of appellee(s) (Common Pleas No. O3-o~,' (~,~ (~'lv;~')within twenty (20)days after service of rule~~ RULE: To _-~'-~ ~/) ~. 7,~ ~/.. ~,z.,d./-/')~ ,appellee(s) /- Signature of appellant o"~his attorney oragent I l~la~ne of appellee(s) - (1) (2) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this rule upon you by personal service or by certified or registered mail. If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECIPE. Date: (3) The date of service of this rule if service was by mail is the date of the mailing. Year °~-~--~ ~ ~~,,i~ Si~natUre-of Prothono~-~/or~eputy White Green - Yellow - Pink - Gold Prothonotary Copy Court File Copy Appelant's Copy Appellee Copy D. J. Copy Proth. - 76 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF .; ss AFFIDAVIT: I hereby swear or affirm that I served []a copy of the Notice of Appeal, Common Pleas No. ., upon the District Justice designated therein on (date of service) year ., [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name on ., year , [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. ]and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on , year , [] by personal s~rvice [] by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF , YEAR Signature of Affiant Signature of official before whom aft"~lavit was made Title of official My commission expires on , year__ COI91MONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERI~ID Mag. Dist. No.: 09-2-01 DJ Name: Hon. PAULA p. COP, PJ~ Address: I COGRTHOUSE SQUARE CARLISLE, PA Telephone: (717) 240-6564 17013-0000 G.ROBINSON %ROBINSON & GERALDO, P.C. 4407 N FRONT STREET P.O. BOX 5320 HAP~EISB[IRG, PA 17110-5320 THIS IS TO NOTIFY YOU THAT: Judgment: NOTICE OF JUDGMENT/TRANSCRIPT PLA,NT,FF/JU DGUE yEI ro ..ASE F-CHERTOK · NAME and A~RESS STEPHANIE -q 61 W [&)UTHER ST CARLISLE, PA 17013 VS. DEFENDANT/JUDGMENT C~4J~ laTngBDRESS I-G.ROBTNSON %ROBTNSON & GEI:tALDO, P. c-l. 4=4=07 N :FRONT STREET P.O. BOZ 532O ~P~EISBU~G, PA 17110-5320 Docket No.: CV-0000027-03 Date Filed: 1/24=/03 FOR PLATNTIFF J-~ Judgment was entered for: (Name) J-'~--J Judgment was entered against: (Name) in the amount of $ I: ~R4 _ R13 ~-J Defendants are jointly and severally liable. J---J Damages will be assessed on: --]This case dismissed without prejudice. J---J Amount of Judgment Subject to Attachment/Act 5 of 1996 $ on: (Date of Judgment) 4/07/03 (Date & Time) Amount of Judgment $ 1,316.00 Judgment Costs $. 68.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 1,384=.50 Post Judgment Credits $.. Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER pRocEss MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 4/8/03 Date~ , District Justice ----------- ~.____ I certify that this is a true .a~'%"0rrect c~y o¢,.tl~'~'re~ord of~Jl~roceedin/~'ntaining the judgment.' , 4,8/03 Date_ ('"->~/~.~'~w/<~:..,~..~/ ,District Justice My commission expires first Monday of January, 2006 . SEAL AOPC 315-03 Postage Certified Fee Return Receipt Fee (Endorsement Required) _ri Postage $ r-R Certified Fee Postmark Here ~ Postmark --1- Return Receipt Fee t-'l (Endorsement Required) Here ~ Restricted Dglivery Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) ~ Total Postage & Fees r'-I Total Postage & Fees :~' Sent To. ~ ,- I .............................. ....... .I ~ ~'~i;~g~r'p~. No.; (~__ '~C~Z~/_-~ ~ ;=7~-- ~ ~ t ~ ........ :-:---=:--=~-'- ..... ~ ......... ~'~' T~'~ ;'~ .............../ ~ IorPOB°xN°' __~.~~-~'-~'~J ...................... I ICI'~St~;:'F+~ - *'";, ....... ; ........... = cOMM~NWEAETH. OF P~NSYLV~IA COUN~ OF . . ._, ss AFFIDAVIT: I hereby ~ear or ~irm that I ~ed a copy of the Notice ~f ~pp,I, Common Pleas No.. ~."~/~. , u~e D~t j~e d~t~h?~' ~ (date of se~ce) ~ /~ , ~, Y"r ~ ~Y ~l:~e ~by~(r~istered) ma,I, sene on ~ / ~ , y~r ~ , ~ by peru°hal sewice ~by (cedifi~) (r~ister~) ~'ail, sender's r~eiPt a~ach~ hereto. , ~nd fudher that I sew~ the Rule to File~ Complaint a~mpanying the above Notice of Appel u~n the appellee~s) to , ~ ;ham t"e .U~e'--S.U"r...~ °n' '~ / ~ ~ea, ~, · mail, sender's receipt attached hereto. SWORN (AFF RMED) AND SUBSCRIBED BEFORE.ME THis~EAR ,~ 00~' .. Signature of official before whom affidavit was made Title o! official My commission eXPires onO~-_~L_ _,,~-~' a,~, year ~.' Signature of A g{' STEPHANIE E. CHERTOK, Plaintiff V. GERALD ROBINSON Defendant V. ROBINSON & GERALDO, P.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O 3 -- Z. IG .. C;v,') CIVIL ACTION - LAW AND EQUITY 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 o~: 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 STEPHANIE E. CHERTOK, Plaintiff GERALD ROBINSON Defendant ROBINSON & GERALDO, P.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AND EQUITY COMPLAINT 1. Plaintiff is an individual, a sole-practitioner, operating Law Offices at 61 West Louther Street, Carlisle, PA 17013. 2. Defendant Robinson and Geraldo, P.C., (Defendant Corporation) is a Corporation, believed to be incorporated in Pennsylvania, and with its principal place of business at 4407 N. Front Street, Harrisburg, PA 17110. 3. Defendant Gerald Robinson is a Principal of Defendant Corporation, with his offices located at Defendant Corporations principal place of business. 4. Plaintiff has owned the building her law offices are in for nine years. 5. Plaintiff was assigned telephone line-number (717) 249-1177, by Sprint, in 1994. 6. Plaintiff uses this line for her office's internal telephone network. 7. Plaintiff was assigned telephone line-number (717) 249-4514, by Sprint, in 1994. 8. Plaintiff uses this line for her office's facsimile machine and for intemet access. 9. In, or around, April of 1998, Plaintiff and Defendant Corporation entered an agreement under which, Defendant Corporation would have use of office space at Plaintiff s place of business, in exchange for which, Defendant Corporation would pay PlaintiffS400.00 per month. (Agreement attached as Exhibit A.) 10. Defendant Corporation's use of office space was for the limited purpose of meeting with clients. 11. Defendant's agents, servants, or employees were required to call Plaintiff to schedule such meetings as Defendant's agents, servants, or employees were not issued a key. 12. At no time during Plaintiff's and Defendant Corporation's business relationship did Plaintiff, express or imply that Defendant Corporation had permission to use Plaintiff' s address or telephone lines on Defendant Corporation's business cards, letterhead, or advertisements. 13. At some unknown time after Plaintiff and Defendant Corporation entered into the 1998 agreement, Defendant Corporation began publishing Plaintiff's address and telephone numbers on its business cards and company letterhead. 14. Defendant Corporation disseminated these business cards and the letterhead to the public. 15. At some time after Plaintiff and Defendant Corporation entered into the 1998 agreement, Plaintiff began to receive telephone calls and mail for Defendant Corporation and Gerald Robinson, at her place of business. 16. On, or about, May 25, 1999, the parties entered in to a new agreement under which, Defendant Corporation would have use of office space at Plaintiff' s place of business, in exchange for which, Defendant Corporation would pay Plaintiff $200.00 per month. (Agreement attached as Exhibit B.) 17. The 1998 agreement stated "that termination of this agreement may be done by either party, but both parties agree that reasonable notice will be given." (Exhibit A.) 18. The 1999 agreement defined reasonable notice -- "[a]ny change or cancellation of our agreement will be done with at least a one month notice, which we both agree is a fair and reasonable time frame." (Exhibit B.) 19. Defendant Corporation paid its monthly fee under the 1999 agreement until October, 2002. 20. No payments were paid for November or December 2002 and Plaintiff called Defendant Corporation on December 18, 2003 to inquire about the November and December payments. 21. An agent, employee, or servant of Defendant Corporation's told Plaintiff that Gerald Robinson, the Principal who had signed the contracts on behalf of Defendant Corporation, was unavailable, but that she would have Principal, Gerald Robinson return Plaintiff s call. 22. Throughout the months of December and January, Plaintiff made many additional calls to Defendant Corporation in order to discuss, with Gerald Robinson, the Principal who had signed the contracts on behalf of Defendant, the failure of Defendant Corporation to pay under the agreement. 23. An agent, employee, or servant of Defendant Corporation's told Plaintiff on separate occasions, that Gerald Robinson would "call her back", that a "message would be left for Gerald Robinson stating that he should call" Plaintiff, and that Plaintiff "should call back Wednesday at 4:30 p.m. in order to talk with Gerald Robinson." 24. These are a sampling of the responses Plaintiff received from Defendant, the other responses being similar. 25. Defendant Corporation's Principal, Gerald Robinson never returned Plaintiff's phone calls. 26. Plaintiff sent Defendant Corporation a letter on December 5, 2002, addressing the delinquent November and December payments. (Attached as exhibit C.) 27. Defendant Corporation failed to respond to the letter. 28. Defendant Corporation did, however, mail to Plaintiff a "Season's Greetings" card on December 25, 2002. 29. Plaintiff was compelled to retain counsel because Defendant Corporation ignored her contacts and failed to respond. 30. Plaintiff' s Attorney called Defendant Corporation in January requesting to speak with Principal, Gerald Robinson. 31. Principal, Gerald Robinson did not return Plaintiff's attorney's calls. 32. On January 24, 2003, Plaintiff filed a Civil Complaint in Magisterial District Number: 09-2-01 against Defendant. 33. A hearing was set for March 3, 2003. 34. During the interim time, Defendants made no efforts to discuss this matter or negotiate with Plaintiff or Plaintiff' s Attorney. 35. Defendant's Principal, Gerald Robinson appeared on the day of the hearing and insisted that the parties could work something out and that the hearing was unnecessary. 36. The parties agreed to settlement terms and Principal, Gerald Robinson himself hand wrote the agreement that he then signed. (Attached as exhibit D.) 37. The terms of the agreement granted Defendant Corporation ten days to pay $868.50 and six months to discontinue use of Plaintiff's address and telephone numbers. 38. Plaintiff s attorney advised Defendant's Principal, Gerald Robinson that Plaintiff would not withdraw the Complaint until payment had been made and that Defendant should, as a precaution enter a defense in the matter. 39. Defendant's Principal, Gerald Robinson, agreed, entered a defense for Defendant Corporation, and accordingly a new hearing date of April 7, 2003 was set by the District Justice. 40. March 13, 2003, came and went and no $868.50 payment was made to Plaintiff. 41. The March 3, 2003, handwritten and signed promise was valueless. 42. Later that month on the fifteenth, Defendant's Principal, Gerald Robinson, signed a check for the amount of $880.00 made payable to Plaintiff. (Copy attached as exhibit E.) 43. That check, like the handwritten and signed promise, was valueless. 44. On March 26, 2003, Plaintiffpresented the $880.00 check to her bank for deposit. 45. The check was dishonored; it bounced. 46. The check was returned to Plaintiff because of insufficient funds. 47. Plaintiff's bank account was charged $10.00 for Defendant Corporation's dishonored check on April 4, 2003. 48. Defendant Corporation was notified within thirty days by its bank that the check had been dishonored. 49. On April 7, 2003, Plaintiff appeared at the hearing that had been rescheduled due to Defendant Corporation's entering a defense. 50. The Defendant Corporation, its counsel, and its Principal failed to appear. 51. District Justice Paula Correal entered a judgment for Plaintiff in the amount of $1384.50, on April 8, 2003. (Attached as Exhibit F). 52. The thirty-day appeal period from the District Justice's decision was to end on May 8, 2003. 53. On May 7, 2003, an Official Check from Citizens Bank of Pennsylvania, made out to Plaintiff for the amount of $880.00, was mailed by Defendant Corporation. 54. On the same day, Defendant's Principal, Gerald Robinson filed an appeal from the District Justice's Judgment. 55. From March 3, 2003, through May 7, 2003, neither Defendant Corporation or Defendant Gerald Robinson made any attempts to contact Plaintiff or Plaintiff's Attorney to resolve this matter. CLAIM ONE: Breach of Contract 56. Paragraphs 1-55 are incorporated herein by reference as if fully set forth at length. 57. Defendant Corporation entered into a contract signed by Defendant Principal of the Corporation 58. Defendant Corporation failed to make monthly payments as required under the terms of the contract. 59. Defendant breached the contract. 60. As a result of Defendant Corporation's breach, Plaintiff suffered damages including, but not limited to, missed monthly payments and attorney's fees and costs, which were made necessary by Defendant's breach. CLAIM TWO: Fraud 61. Paragraphs 1-60 are incorporated herein by reference as if fully set forth at length. 62. Defendant Corporation made a material misrepresentation of fact when it made Plaintiff a holder in due course of the March 15, 2003, draft, purportedly valued at $880.00. 63. Defendant Corporation made this misrepresentation with knowledge of its falsity or recklessness as to whether it was true or false. 64. Defendant Corporation intended to mislead Plaintiff into relying on the misrepresentation because Defendant Corporation expected Plaintiff to present the draft to Plaintiffs bank for deposit in Plaintiffs account. 65. Plaintiff suffered damages as a result of Defendant Corporation's fraud, including, but not limited to, the $10.00 charge Plaintiff incurred as a result of Defendant Corporation's dishonored draft, as well as Attorney's fees and costs, which Attorney's fees and costs were made necessary by Defendants' own actions. CLAIM THREE: Commercial Fraud 66. Paragraphs 1-65 are incorporated herein by reference as if fully set forth at length. 67. Defendant Corporation has publicized Plaintiffs address and phone numbers as if they were its own. 68. Defendant Corporation has held Plaintiff's place of business out as its own Office. 69. Defendant Corporation has caused the likelihood of confusion or of misunderstanding as to the sponsorship and approval of its services. 70. Defendant Corporation has caused the likelihood of confusion or of misunderstanding as to its affiliation, connection, and association with Plaintiff. 71. Defendant Corporation has used deceptive representations and designations of geographic origin in connection with its services. 72. Defendant Corporation has represented that its services have Plaintiff's sponsorship and approval, which they do not have. 73. Defendant Corporation has represented that its attorneys have a sponsorship, approval, status, affiliation, and connection, of and with Plaintiff, that they do not have. 74. Defendant Corporation has made false or misleading statements regarding Plaintiff's place of business. 75. Plaintiff has suffered damages as a result of these actions of Defendant's, including, but not limited to the $10.00 charge Plaintiff incurred as a result of Defendant's dishonored draft as well as attorney's fees and costs, which attorney's fees and costs were made necessary by Defendants' own actions and potential damages not yet known pursuant to Defendants' misrepresentations. CLAIM FOUR: Trespass to Chattels 76. Paragraphs 1-75 arc incorporated herein by reference as if fully set forth at length. 77. Plaintiff had and has an interest in her address and telephone numbers superior to Defendant Corporation's interest. 78. Defendant Corporation exercised dominion over Plaintiff's address and telephone numbers in a manner inconsistent with Plaintiff's interest. 79. Defendant Corporation did so without Plaintiff' s consent. 80. Plaintiff has sustained damages due to Defendant Corporation's actions. CLAIM FIVE: Intrusion Upon Seclusion 81. Paragraphs 1-80 arc incorporated herein by reference as if fully set forth at langth. 82. Defendant Corporation intentionally intruded, physically and otherwise, upon the solitude and seclusion of Plaintiff in her place of business. 83. These intrusions were above and beyond what was planned in the 1998 and 1999 agreements. 84. Plaintiff has answered phone calls for Defendant Corporation and received mail for Defendant Corporation, to the extent that it has, on occasion, interfered with Plaintiff's work. 85. Plaintiff has answered phone calls for Defendant Corporation and received mail for Defendant Corporation, to the extent that Plaintiff has, on occasion, incurred expenses on Defendant Corporation's behalf. 86. Defendant Corporation has made no effort to compensate Plaintiff for these expenses. 87. Defendant Corporation has avoided responding to all of Plaintiff' s communications regarding these intrusions. 88. Such intrusions have been highly offensive to Plaintiff, as they would to a reasonable Plaintiff. CLAIM SIX: Appropriation of the Commercial Value of a Person's Identity: The Right of Publicit~ Under the Restatement 3d of Unfair Competition 89. Paragraphs 1-88 are incorporated herein by reference as if fully set forth at length. 90. Defendant Corporation has appropriated the commercial value of Plaintiff's identity by using Plaintifff s address and phone numbers. 91. Defendant Corporation has done so without Plaintiff' s consent. 92. Defendant Corporation has done so for the purposes of trade. 93. This appropriation has resulted in injury to both Plaintiff's commercial and personal interests. CLAIM SEVEN: Publicity Placing Plaintiff in False Light 94. Paragraphs 1-93 are incorporated herein by reference as if fully set forth at length. 95. Defendant Corporation has publicized Plaintiff's address and phone numbers to the public. 96. Defendant Corporation made such publication with knowledge of, or acted in reckless disregard as to the falsity of the publicized phone numbers. 97. Defendant Corporation made such publication with knowledge of, or acted in reckless disregard as to the false light in which Plaintiff would be placed. 98. Defendant Corporation's publication has suggested to the public that Plaintiff is associated with Defendant Corporation, or the reverse. 99. Defendant Corporation's publication has suggested to the public that Plaintiff is an agent, servant, employee, or subdivision of Defendant Corporation or the reverse. 100.Such publication represents a false position on Defendant Corporation and/or Plaintiff's part. CLAIM EIGHT: Dilatory, Obdurate, and Vexatious Conduct 101. Paragraphs 1-100 are incorporated herein by reference as if fully set forth at length. 102. Defendants' actions throughout the pendency of this matter have been dilatory, obdurate, and vexatious. WHEREFORE, Plaintiff seeks from this Honorable Court immediate injunctive relief prohibiting Defendants from using Plaintiff s address and telephone numbers in the future, and damages, attorney's fees, and costs within the jurisdictional limits for mandatory arbitration. Date: Jo , Esquire Attorney for Plaintiff PA Sup. Ct. ID# 90152 61 West Louther St. Carlisle, PA 17013 (717) 249-1177 VERIFICATION I veri~y that the statements made in this Petition are true and correct. I understand that false statements made herein are subject to the penalties under 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. EXHIBIT A 61 West Louther Street Carlisle, PA 17013-2936 Stephanie E. Chertok, R.N., Esq. ATTORNEY AT LAW (717) 249-1177 FAX (717) 2494514 April 17, 1998 Tama Curtis Legal Administrator Robinson & Geraldo P. O. Box 5320 Harrisburg, PA 17110 Re: Office at 61 West Louther Street, Carlisle, PA 17013 Dear Tama, Please accept this eonfu'mation of our agreement regarding the use of our office by members of your law firm. As we discussed, Robinson & Geraldo would prefer not to enter into'a formal lease agreement whereby the firm would be bound for one year increments: It is your preference that the terms of our agreement be month to month in. We also agreed that there would be flexibility with regard to the amount of the monthly rem. Beginning on May 1, 1998 RobinsOn & Geraldo will pay $400.00 per month for the shared use of the office. The rent will be due On the first of each month therea/~er. Depending on the average number of times per month that members of your firm make use of the office, it may be necessary to adjust the amount of rent accordingly. This may be reevaluated from time to time. Increases or decreases/n rent or complete termination ofth/s agreement may be done by either party, but both parties agree that reasonable notice will be given. The use of the office by members of the law firm of Robinson & C-eraldo will include useOf the conference room, restroom, kitch/n~ work area and reception area. Included will be electric, heat, water, one off street parking space, cleaning -service, trash removal, and reasonable use of the copier and fax machines. The office will be available during business hours which are Monday through Friday 9:00 a.m. to 5:00 p;m.. During these hours the receptionist will typically be present. In the event of an appointment · outside of business:hours ex~ery effort will be made to have the office open and available for'.you~-nse.: ~ti:s~wo~ld best~be accomplished by.simply.providing:notice of.the day:and Please be assured that we will make every effort to see to it that members of your firm feel comfortable while working at this location. We are all looking forward to working with you and as I told you previously, I will be quite pleased to place the rum's name plate on our door in order to direct your clients. If there is anything further that you would like to discuss please contac~ me. If the terms that I have set forth in this letter are in accordance with your understanding, please acknowledge your agreement in the space provided below and return this letter to me at your earliest convenience. A signed copy is enclosed for your files. I look forward to speaking with you soon. Very truly yours, Stephanie E. Chertok Acknowledged and agreed this ff_, [ ~'~ Tama Curtis Legal Administrator Robinson & Geraldo day of April 1998. EXHIBIT B 61 West Louther Street Carlisle, PA 17013-2936 Stephanie E. Chertok, R.N., Esq. ATFORNEY AT LAW (717) 249-1177 FAX (717) 249-4514 May25,1999 Gerald Robinson Robinson & Geraldo P.O. Box 5320 Harrisburg, PA 17110-5320 Dear Mr. RobinSon, Pursuant to your response we will begin a new arrangemem with regard to your firm's occasional use of our Carlisle office. As before, we will provide you with a staffed, fully equipped facility where you can meet with your clients. Experience shows that this works best when you call in advance to advise of your appointment if possible. The rent will be two hundred dollars per month beginaing June 1, 1999 and will be subject to change ia the event that the frequency of use changes. Further, the rent will be due on the first day of each month and will actually be paid on or before the due date each month. There will no longer be a parking space reserved for your use but you will find ample parking on the street and in the municipal lot across the stxe~t at the Post Office entrance. Any change or cancellation of our agreement will be done with at least a one month notice, which we both agree is a fair and reaSOnable time frame. We have made every effort to make this agreement worthwhile for you and for us. To date, we have been inconvenienced and many times we have been embarrassed by the efforts that we have had to make each month in reminding someone to pay, asking them to pay, and begging them to pay the rent. I look forward to a new beginning and in fact I only have agreed to the lesser mount of rent in order to assist you in your efforts.to make the agreement into one that will better meet your needs. Please advise if you feel that there are any additional terms to be discussed. We look forward to seeing you here. Please sign and remm one copy for my records: I agree to the terms of our agreement for the use of office space at 61 West Louther Street, Carlisle, PA 17013 as stated above. Date: Gerald Robinson Robinson & Geraldo EXHIBIT C Stephanie E. chertok, R.N., Esq. ATTORNEY AT LAW 61 West Louther Street Carlisle, PA 17013-2936 (717) 249-1177 FAX (717) 249-4514 Gerald Robinson, Esquire Robinson & Geraldo P.O. Box 5320 Harrisburg, PA 17110 Re: Carlisle office December 5, 2002 Dear Gerry: When we last discussed your standing with regard to our rental agreement, I told you that I . understood your need to delay payment, but I would appreciate it if you would keep me apprised of your status. I have not heard from you. despite the fact that you are way behind on payments. The October rent was due on October 1. Your check arrived during the na0nth of November. The rent for November was due on November 1, and the rent for December was due on December 1. i have not received payment to date for November or December. I have mail here for you. and IJeft you a message about that but I have not heard back from you. In the past I have forwarded your mail, but I will not continue to do so while you remain behind on payments and you do not even bother to call me to discuss the situation. At this time, I would be willing to continue with our arrangement however you will need to contact me in order to let me know your intentions, and you will need to bring your account up to date as well. In the event that you have decided to discontinue our arrangement, you will need to contact me and advise me of your intentions. Further, if you are discontinuing your contract you will need to pay the amount due, which is November rent, December rent and at this point you will also owe January rent because you have not given a 30 day notice of your Intention to quit in a timely manner. In addition, you will need to remove my address and phone number from your letterhead, which was placed on them without my knowledge or permission. Gerry, I believe that you have been well intentioned and sincere in our contractual relationship, however, it seems that things have deteriorated and must be discussed before we can go any further, regardless of which way you may choose to go with this. Please contact me at your earliest convenience to discuss this matter. Very truly yours, Stephanie E. Chenok EXHIBIT E EXHIBIT F COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMB~ 09-2-01 PAULA P. COP~.EAL COURTHOUSE SQUAP, E CAELISLE, PA 240-6564 17013-0000 8TEPHANIE E. C,~ts~TOK 61 W LOu'r,~'~ ST CAELISLE, PA 17013 NOTICE OF JUDGMENT/TRANSCRIPT 61 ~ LOu'J.'u=~. ST CAELISLE, PA 17013 !- VS. DEFENDANT/JUOGMENT C~IaTnoO[~I~ORESs FG.ROBiNSON ~[OBINSON a GEP~T.*no, P.C~. 4407 N FROICT STREI~ P.O. BOX 5320 ~ISBURG, PA 17110-5320 Docket No.: CV-0000027-03 I ~ Date F ed: 1/24/03 THJS IS TO NOTIFY YOU THAT: Judgment: [~ Judgment was entered for: (Name) ~-~'[ Judgment was entered against: (Name) in the amount of $ 1 _- '4RA _ R~J on: '--]Defendants are jointly and severally liable. ~ Damages will be assessed on: '-[This case dismissed without prejudice. ~--~ Amount of Judgment Subject to Attachment/Act 5of 1996 $ FOR pT.~TI~IFF ~_~nR'r~'gn~ ~gnRT~gn~ s (OateofJudgment) 4/n~/n~ (Date & Time) Amount of Judgment $ i 316.00 Judgment Costs $ 68.50 interest on Judgment $ .00 Attorney Fees $ .00 Total $ 1,384.5( Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ' ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED iN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IFTHE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THECOURT OF c0MMO.N PLEA~ ALL FURTHER "ROCE~? ,M~ST C~ME F~OM,T.H. OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT I$ ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SE'I-I'LES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 4/8/03 Date My commission expires first Monday of January, 2006 , SEAL AOPC 315;03 STEPHANIE E. CHERTOK, Plaintiff GERALD ROBINSON Defendant V. ROBINSON & GERALDO, P.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2162 CIVIL CIVIL ACTION - LAW AND EQUITY CERTIFICATE OF SERVICE I, John C. Porter, counsel for the Plaintiff, Stephanie E. Chertok, hereby certify that true and correct copies of the Complaint and Notice to Defend in the above captioned case were served to the Defendant, Robinson & Geraldo, P.C. in the following manner: Certified Mail, return receipt requested, to: Robinson & Geraldo, P.C. P.O. Box 5320 Harrisburg, PA 17110-5320 on this 6th day of June, 2003. John (~P-orter, Esq. Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 STEPHANIE E. CHERTOK, Plaintiff V. GERALD ROBINSON Defendant ROBINSON & GERALDO, P.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2162 CIVIL CIVIL ACTION - LAW AND EQUITY CERTIFICATE OF SERVICE I, John C. Porter, counsel for the Plaintiff, Stephanie E. Chertok, hereby certify that tree and correct copies of the Complaint and Notice to Defend in the above captioned case were served to the Defendant, Gerald Robinson in the following manner: Certified Mail, return receipt requested, to: Gerald Robinson, Esquire P.O. Box 5320 Harrisburg, PA 17110-5320 on this 6th day of June, 2003. John. P~o~er, Es~q.''~' Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 STEPHANIE E.CHERTOK, Plaintiff, GERALD ROBINSON AND ROBINSON & GERALDO, PC Defendant. :COURT OF COlVlMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2162 : : CIVIL ACTION NOTICE TO PLEAD TO: STEPHANIE CHERTOK: YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN 20 DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. GERALD S. ROBINSON STEPHANIE E.CHERTOK, Plaintiff, GERALD ROBINSON AND ROBINSON & GERALDO, PC Defendant. :COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2162 : CIVIL ACTION ANSWER WITH NEW MATTER COMES NOW, the Defendant through its undersigned attorney to answer the Complaint and in support thereof states as follows: Paragraph 1 is admitted. Paragraph 2 is specifically denied. To the contrary, Robinson & Geraldo, PC is incorporated in the District of Columbia and has its principal place of business in the District of Columbia. Paragraph 3 is admitted insofar as Defendant Gerald Robinson having an office located at Defendant Corporation's principal place of business. Paragraph 3 is denied as to the Defendant Corporation's location. Paragraph 4 is admitted. Paragraph 5 is admitted. After reasonable investigation the Defendants are without knowledge to form a belief as to the truth of the averments of Paragraph 6. After reasonable investigation the Defendants are without knowledge to form a belief as to the truth of the averments of Paragraph 7. 8. After reasonable investigation the Defendants are without knowledge to form a belief as to the truth of the averments of Paragraph 8. 9. Paragraph 9 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 10. Paragraph 10 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 11. Paragraph 11 is admitted as to Defendant Robinson only. Paragraph 10 is denied as to Defendant Corporation. To the contrary Defendant Corporation only has an office in the District of Columbia. 12. Paragraph 12 is admitted. 13. Paragraph 13 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 14. Paragraph 14 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 15. Paragraph 15 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 16. Paragraph 16 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 17. Paragraph 17 is admitted. 18. Paragraph 18 is admitted. 19. Paragraph 19 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 20. Paragraph 20 is admitted. 2 21. Paragraph 21 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 22. Paragraph 22 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 23. Paragraph 23 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 24. Paragraph 24 is denied. To the contrary Defendant ,Corporation only has an office in the District of Columbia. 25. Paragraph 25 is specifically denied. To the contrary Defendant Robinson did return Plaintiff's phone calls. 26. Paragraph 26 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 27. Paragraph 27 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia and did not receive a letter from Plaintiff.. 28. Paragraph 28 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 29. Paragraph 29 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 30. Paragraph 30 is denied. To the contrary Defendant C, orporation only has an office in the District of Columbia. 31. Paragraph 31 is denied. To the contrary, Defendant Robinson called Plaintiff's counsel and was advised that he was not available. 32. Paragraph 32 is admitted. 3 33. Paragraph 33 is admitted. 34. Paragraph 34 is denied. To the contrary, Defendant Robinson called Plaintiff's counsel and was advised that he was not available. 35. Paragraph 35 is admitted. 36. Paragraph 36 is admitted. 37. Paragraph 37 is admitted. 38. Paragraph 38 is admitted. 39. Paragraph 39 is admitted. 40. Paragraph 40 is admitted. 41. Paragraph 41 is denied in that Defendant Robinson lendered and Plaintiff accepted a Certified Check in the amount of $880.00. 42. Paragraph 42 is denied. To the contrary, the check i:n question was signed by a third party using a signature stamp. 43. Paragraph 43 is denied but it is admitted that the check was returned. 44. Paragraph 44 is admitted. 45. Paragraph 45 is admitted. 46. Paragraph 46 is admitted. 47. After reasonable investigation the Defendants are without knowledge to form a belief as to the truth of the averments of Paragraph 47. 48. Paragraph 48 is admitted. 49. Paragraph 49 is admitted. 50. Paragraph 50 is admitted. 51. Paragraph 51 is admitted. 4 52. Paragraph 52 is admitted. 53. Paragraph 53 is admitted. 54. Paragraph 54 is admitted. 55. Paragraph 55 is specifically. To the contrary, Defendant Robinson sent a certified check to Plaintiff, ordered new stationary, and contacted the telephone company for the purpose of revising the address and telephone numbers for its advertising. CLAIM ONE: BREACH OF CONTRACT 56. Paragraphs 1-55 are incorporated herein by reference. 57. Paragraph 57 is denied. To the contrary Defendant ,Corporation only has an office in the District of Columbia. 58. Paragraph 58 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 59. Paragraph 59 is a conclusion of law and no responsive pleading is required. 60. Paragraph 60 is a conclusion of law and no responsive pleading is required. CLAIM TWO: FRAUD 61. Paragraphs 1-60 are incorporated herein by reference. 62. Paragraph 60 is a conclusion of law and no responsive pleading is required. 63. Paragraph 63 is denied. To the contrary, the check in question was signed by a third party using a signature stamp. 5 64. 65. Paragraph 64 is denied. To the contrary, the check in question was signed by a third party using a signature stamp. After reasonable investigation the Defendants are without knowledge to form a belief as to the truth of the averments of Paragraph 65. CLAIM THREE 66. 67. 68. 69. 70. 71. 72. 73. Paragraphs 1-65 are incorporated herein by reference. Paragraph 67 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 68 is denied. To the contrary Defendant Corporation only has an office ~n the District of Columbia. Paragraph 69 is denied. To the contrary Defendant Corporation only has an office ~n the District of Columbia. Paragraph 70 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 71 is denied. To the contrary Defendant Corporation only has an office ~n the District of Columbia. Paragraph 72 is denied. To the contrary Defendant Corporation only has an office ~n the District of Columbia. Paragraph 73 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 6 74. Paragraph 74 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 75. Paragraph 75 is a conclusion of law and no responsive pleading is required. CLAIM FOUR: TRESPASS TO CHATTELS 76. 77. 78. 79. 80. Paragraphs 1-75 are incorporated herein by reference. Paragraph 77 is admitted. Paragraph 78 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 79 is denied. To the contrary Defendant ,Corporation only has an office in the District of Columbia. Paragraph 80 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. CLAIM FIVE: INTRUSION UPON SECLUSION 81. Paragraphs 1-80 are incorporated herein by reference. 82. Paragraph 82 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 83. Paragraph 83 is denied. To the contrary Defendant C, orporation only has an office in the District of Columbia. 7 84. 85. 86. 87. 88. Paragraph 84 is denied. To the contrary Defendant Corporation only has an office in 'the District of Columbia. Paragraph 85 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 86 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 87 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 88 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. CLAIM SIX 89. Paragraphs 1-88 are incorporated herein by reference. 90. Paragraph 90 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 91. Paragraph 91 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 92. Paragraph 92 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 93. Paragraph 93 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. 8 CLAIM SEVEN 94. 95. 96. 97. 98. 99. 100. Paragraphs 1-93 are incorporated herein by reference. Paragraph 95 is denied. To the contrary Defendant ,Corporation only has an office ~n the District of Columbia. Paragraph 96 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 97 is denied. To the contrary Defendant Corporation only has an office ~n the District of Columbia. Paragraph 98 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 99 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. Paragraph 100 is denied. To the contrary Defendant Corporation only has an office in the District of Columbia. CLAIM EIGHT 101. 102. Paragraphs 1-100 are incorporated herein by reference. Paragraph 100 is denied. To the contrary DefendantC~orporat~on' only has an office in the District of Columbia. It is also denied that Defendant Robinson's conduct has been dilatory, obdurate, and vexatious. 9 WHEREFORE, for the foregoing reasons, the instant Complaint should be dismissed. NEW MATTER 103. Paragraphs 1-102 are incorporated herein by reference. 104. Defendant Robinson complied with the provision o f the Agreement reached by the parties by tendering a certified check in the amount of $880.00 and discontinuing the use of Plaintiff's address and phone numbers in its advertising and stationary. 105. Plaintiff has retained the certified check issued by Defendant Robinson on or about May 7, 2003. 106. There are two corporations, ROB1NSON & GERALDO- A PROFESSIONAL CORPORATION which maintains its principal place of business in Harrisburg, Pennsylvania and Robinson & Geraldo, PC which maintains a principal place of business in the District of Columbia and does not operate or do business in Pennsylvania. 10 WHEREFORE, for the foregoing reasons, the instant Complaint should be dismissed. Respectfully submitted, ROBINSON & GERALDO Date: June 28, 2003 By: Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street ]?.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 For all Defendants VERIFICATION I verify that the statements made in this pleading are true and correct. I understand that false statements made herein are subject to the penalties under 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Gerald S. Robinson CERTIFICATE OF SERVICE This is to certify that a copy of this ANSWER WITH NEW MATTER has been sent to John C. Porter, Esquire, 61 West Louther Street, Carlisle, PA 17013 by first class mail on June 30, 2003. Gerald S Robinson 11 STEPHANIE E. CHERTOK, Plaintiff GERALD ROBINSON Defendant Vo ROBINSON & GERALDO, P.C. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~lO. 2003-2162 IIVIL ACTION - LAW AND EQUITY 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 (2;0) 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 Plaintiffs. 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 ()NE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 STEPHANIE E. CHERTOK, Plaintiff GERALD ROBINSON Defendant ROBINSON & GERALDO, P.C. Defendant IN THl~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-2162 CIVIL ACTION - LAW AND EQUITY PLAINTIFF'S ANSWER TO DEFENDANTS' NEW MATTER 103. Paragraph's 1-102 of Plaintiff's Complaint are incorporated herein by reference. 104. Denied. The Agreement of the parties is misstated, o~ad as it is a writing attached to the Complaint, it speaks for itself. In addition, as of Augustl, 2004, a year after the agreement was signed by Defendant Gerald Robinson and Defendant Robinson & Geraldo, P.C., a.k.a. Defendant Robinson & Geraldo, A Professional Corporation, are still advertising Plaintiff's business address on Defendants' website. 105. Denied to the extent that the certified check is in the custody of Plaintiff's Attorney. 106. Denied in that both of these corporations represent to the public and advertise on the world wide web that they not only conduct business in Pennsylvania, but do so at Plaintiff's business address. See printouts from websites attached as Exhibit A www.rglaw.net last visited August 1, 2004; See printouts from websites attached as Exhibit B www.robinson-geraldo.com last visited August 1,2004. WHEREFORE Plaintiff seeks from this Hom>rable Court immediate injunctive relief prohibiting Defendants from using Plaintiff's address and telephone numbers in the future, and damages, attorney's fees and costs within the jurisdictional limits for mandatory arbitration. Date Respectfully submitted, Jo~. Porter, 'Esq. Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisl~e, PA 17013 717-249-1177 VERIFICATION I, John C. Porter, verify that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. §4904 relating to tmsworn falsification to a'athorities. % - 7_-oq Date jAotth~q !!Yd!°~ ePr I ainti ff EXHIBIT ~A Rol}inson and Geraldo - Attorneys at Law - Home Page Page 1 of 1 · Page 1 of 1 Locations tions Loca , , ~,~ EXHIBIT Page 1 of 1 Rol~inson and Geraldo Attorneys at Law · Our lrixa# · Practice A~eas 'cl ROBINSON & GERALDO is a multi-practice firm lc in personal injury and medical malpractice cases. We are de , concern, sensitivity, and understanding. This assures o · Direcfio~s/I-Iovrs · · Fee(U~ack · · O~ Webslte · Copyright© 2004 Robinson & prepared for informat onal purposes only. without seeking professional counsel. Use of th s website does not establish an attorne~jient relationship. Directions And Hours of Robinson and Geraldo Attorneys At Law Page 1 of 1 · Home · · Our Firm · · PracticeA~e~s · · Our Website · Directions and Hours have three offices to serve your legal Harrisburg Office [MAP] 4407 North Front Street Harrisburg, PA 17110 Phone: 717.232.8525 Toll Free: 800.571.2727 Fax: 717.232.5098 Washington, DC Office [MAP] Capitol Hill 1316 Pennsylvania Avenue, SE Washington, DC 20003 Phone: 202.544.2889 Fax: 202.547.8342 Carlisle Office [MAP] 61 V~st Louther Street Carlisle, PA 17013 Toll Free: 800.571.2727 We are located in Pennsylvania at both East and W~st Shore Harrisburg areas, and in V?ashington, D.C., just one block from the Potomac Metro stop. In Harrisburg, we offer convenient off street parking. W~ekday hours are 9:00 a.m. to 5:00 p.m. Evening and Saturday hours are available by appointment only. Copyright© 2004 Robinson & Geraldo Attomeys at Law. Revised and updated: June 8, 2004. Th,s materials provided in our website have been prepared for informational purposes only. V~ do not intend for it to be legar advice. VVe advise that you do not act upon the provided information without seeking professionar counsel. Use of this website does not establish an attome~ent relationship. STEPHANIE E. CHERTOK, Plaintiff GERALD ROBINSON Defendant Vo ROBINSON & GERALDO, P.C. Defendant CERTIFICATE OF SERVICE_ IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNSYLVANIA NO. 20021-2162 I, John C. Porter, counsel for the Plaintiff, Stephanie E. Chertok, hereby certify that true and correct copies of the Plaintiff's Answer to Defendant's New Matter and Notice to Defend in the above captioned case were served to Attorney Robinson, Attorney for the Defendant's, in the following manner: PLEAS OF First Class Mail to: Robinson & Geraldo, P.C. P.O. Box 5320 Harrisburg, PA 17110-5320 on this 2nd day of August, 2004. Counsel for Plaintiff PA Sup. Ct. ID//90152 61 West Louther Street Carlisle, PA 17013 717-249-1177 STEPHANIE E. CHERTOK, Plaintiff Vo GERALD ROBINSON Defendant ROBINSON & GERALDO, P.C. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-2162 CIVIL ACTION - LAW AND EQUITY PRAECIPE TO DISMISS To the Prothonotary: Kindly mark the above captioned action Settled and Discontinued. Robinson & Geraldo 4407 North Front Street Harrisburg, PA 17110 Respectful submitted: ~p~ie E. L'~-~ertok, Esqulr'"'~ Sup. Ct. ID #52651 61 West Louther St. Carlisle, PA 17013 (717) 249-1177