The URL can be used to link to this page

Home My WebLink About03-2470BAY STATE SUP, FACE TECHNOLOGIES, INC. A SUBSIDIARY OF AIMTEK, INC. Plaintiff CALABRESE AND SONS, INC. Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL DIVISION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITrEN APPEARANCE PERSONALLY OR BY AN A'ITORNEY 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 JUDG~ MAY BE ENTERED AGAINST YOU BY THE COURT wrrHoUT 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 SHOUt. JD 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 WHE~ YOU. CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 1701Z (717) 249-3166 BAY STATE SURFACE TECHNOLOGIES, INC. A SUBSIDIARY OF AIMTEK, INC. Plaintiff CALABRESE AND SONS, INC. Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL DIVISION - LAW COMPLAINT The Plaintiff, BAY STATE SURFACE TECHNOLOGIES, INC., A SUBSIDIARY OF AIMTEK, INC., by its' attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit again~ the Defendant to recover the sum of THIRTEEN THOUSAND, SIX HUNDRED AND THIRTY-TWO DOLLARS ($13,632.00), along with cost ofthi.~ suit and interest thereon at the rate of 21% per annum from March 17, 2002 upon a cause of action of which the following is a statement: 1. Tho Plaintiff, BAY STATE SURFACE TECHNOLOGIES, INC., A SUBSIDIARY OF AIMTEK, INC., is a corporation organiTcd and existing under tho laws of the Commonwealth of Massachusetts, having its principal office and place of business at 201 Washington Street, Auburn, MA 01501. 2. The Defendant, CALABRESE AND SONS, INC., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 406 Brandy Lane, Mechanicsburg, Cumberland County, pennsylvania 17055. 3. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiff's books of entry/invoice hereto attached, made a part hereof and marked Exhibit "A", Plaintiff, at tho special instance and request of the Defendant's Purchase Order as set forth on Exhibit "B", sold and delivered goods, wares and merchandise of the kind and description set forth in the mount of ELEVEN THOUSAND, THREE HUNDRED AND SIXTY DOLLARS ($11,360.00)· F:\USERW. ATH~CMPIAINTO.9345.wpd:20May03 4. The prices charged for said goods, wares and merchandise were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant promised and agreed to pay Plaintiff therefor. 5. Due to the default of Defendant, and pursuant to the terms and conditions of the Credit Application executed by Defendant, a copy of which is herein above referenced at Exhibit "C", attorney's fees in the total amount of TWO THOUSAND, TWO HUNDRED AND SEVENTY-TWO DOLLARS ($2,272.00) have been added to said account. 6. The balance due and owing by Defendant to Plaintiffis the sum of THIRTEEN THOUSAND, SIX HUNDRED AND THIRTY-TWO DOLLARS ($13,632.00). 7. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of THIRTEEN THOUSAND, SIX HUNDRED AND THIRTY-TWO DOLLARS ($13,632.00), together with cost ofthis suit and interest thereon at the rote of 21% per annum from March 17, 2002. Respectfully submitted, Robert D. Kodak 407 North Front Street Post Office Box/ti 1848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney ID No. 18041 Attorney for Plaintiff F:\USERXKATHYXCMPLAINTC29345 .wpd:20May03 2 FROM A ! MTEK TO 17725~2~0~2 P. 02/0~ INVOIcE .', ' ; .... ;- ,...: ..,*.w* ~'*~* '~: ........... PAGE: 20a ~HINGTON: ST~T .' A~U~, ~ 01501-3224 (508) '832-5043' F~ (508) 832-5035. -'. [ ' '406 B~~~~-'?:::-:,, .' .:. . . ..~.~::,......~ .:.{~ ~ '~:~' CONFIRM TO: iNVOICF. NUMBER: 0001905-iN · ;~::: i',:~ORDElti~,~"~4BER:';-'. 0000878 . . S~ESPE~-,' 0000 ~R~-~E :i :.SONS. tNC ~ ~C~ICSB~G PA 170'35 pi~Y ~ THiS INVOiC~ UNPAiD iNVOICES OVeR 10 DAMS WILL BE ~ 1.75% PER MONTH.-(21%-PER ANNUM) . I.~"VOICE TOTAL: II, 360.00' .00 11,360.00 N0¥--20--82 84:23 PM BAY STATE SURF. 588 36G 7315 P.02 C LABRESE & SONS, Inc. PmciMo~ IIi~chln~ Product~ 4~ Bmndy Lm P.O. Box 16~7 Mec~,nlc~burll, Penneylvlmla 17055 PHONE: (717) ?~'/'1 FAX: (717) ~97.~4~ eNOICE TO ADDRESS ABOVE Vendor 12 UNION ST. SUITE 31 WESTBOROUGH, MA 01581 I I PRIORITY RATING: DO/kB Purchase Order Number This numb~ m~ qq~ m Imm Tm'nm Ship F.O.B. Po,,"tt Quote No. Quote By for National Oelense Under DMS Rqulationa 1. You ~ required te ~ provisions et Olds Reeuialion I and al dl other ~ reSubtiofls and orders of BI)SA in ~ controlled materials and other products and materials needed to ~l this order, it ¢~mtains · DO and/or I~C pciority mtin~. I I Il i Il I Illll I I II I I 'l · GA DRUM. Ay, PiN 4eS4el}o FIEV. I) $1.~1~{20.00 EA DIPAC C-¶ COAT~ SHALL BE APPLIED AND ~ TO THE SPECiF[EO ~ CO~ENTP,~m% AND .a SU~ACE F~N~ CERTS REQUIRED MUST ACCOMPANY MATERIAL. F~, TRUCK: PLEASE USE NEW PENN ONLY ~SE & 80NS, INC. CiO GATEWAY LOGISTICS SERVICES, INC, 717-697-47"c~ e375.8 BASESttORE ROAD , i -; ....... PA , ! 0CT-23-2~2 13:11 FROM AIMTEK :- ~ J~N-~I-~J~ 1~:~-~ FI¢I~I AIHTEK TO 17725629062 TO 171759765~ P. 04/09 AulaJm, IdA 01 Phone: (SOB] OWNERS ()F AIN~UCANT i$ A ~ PROPRIETORSHtP OR PARTNERSHIP) OR OPFICERS (IF A CORPORATION) ~ oR SAVI~S Mm LOAN ~SOe~ APPtJCA/~T'8 IJJ~a~'~Ul~Ul!RS ~at,. ,LI.~T_THI~EI FEB-O1-2EIS~ 14:S9 yERIF!CATION I, ROBERT D. KODAK, state that I amnot a party to the action but that, at the request ofthe Plaintiff, BAY STATE SURFACE TECHNOLOGIES, INC., A SUBSIDIARY OF AIMTEK, INC., and based upon knowledge, information, records and documents supplied to me by the Plaintiff, the averments set forth in Plaintiffs Complaint are tree. A Verification executed by the Plaintiff can be supplied at time of trial or upon-request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Robert D. Kodak, Esq. F:\USER~4L~kTHY~CMPLAINT~9345.wpd:20May03 BAY STATE SURFACE TECHNOLOGIES, INC., A Subsidiary of AIMTEK, INC. V. CALABRESE AND SONS, INC. Defendant · In the Court of COMMON PLEAS of · CUMBERLAND County, Pennsylvania · NO. 2003-02470 CIVIL · CIVIL DIVISION -LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter as settled and discontinued with prejudice. TO CUMBERLAND County Prothonotary Dated: June 20, 2003 Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041 SHERIFF'S RETURN - CASE NO: 2003-02470 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BAY STATE SURFACE TECHNOLOGIES VS CALABRESE AND SONS INC REGULAR ROBERT BITNER , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE CALABRESE AND SONS INC DEFENDANT , at 1642:00 HOURS, at 406 BRANDY LANE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 2nd day of June MECHNAICSBURG, PA 17055 by handing to RICHARD RIGGLEMAN, SHOP SUPER- INTENDENT, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE the , 2003 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this /~ day of ,_ ~ A.D. ~ ,Prothonotary ' So Answers: R. Thomas Kline 06/03/2003 KNUPP KODAK IMBLUN ~Deputy Sheriff