HomeMy WebLinkAbout01-05603«::
Johnson, Duffie, Stewart & Weidner
By: David W. DeLuce
I.D. No. 41687
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717)761-4540
KEYSTONE STAFFING SERVICES, INC.,
Plaintiff
v.
INTERCONTINENTAL SERVICE
AGENCY, INC.
Defendant
NOTICE TO DEFEND
To the Defendant:
CIVIL ACTION -LAW
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 defense 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, Pennsylvania 17013
Telephone: (717) 249-3166
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001- $'(eQ3 CIVIL TERM
Johnson, Duffie, Stewart & Weidner
By: David W. DeLuce
I.D. No. 41687
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717)761-4540
Attorneys for Plaintiff
KEYSTONE STAFFING SERVICES, INC., IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO.2001- S6C.~ CIVIL TERM
v.
CIVIL ACTION -LAW
INTERCONTINENTAL SERVICE
AGENCY, INC.,
Defendant
COMPLAINT
1. The Plaintiff, Keystone Staffing Services, Inc., is a Pennsylvania corporation with a principal
place of business at 360 Market Street, Lemoyne, Cumberland County, Pennsylvania 17043.
2. The Defendant, Intercontinental Service Agency, Inc., is a Pennsylvania corporation with a
place of business at 4455 North Front Street, Harrisburg, Dauphin County, Pennsylvania 17110.
COUNTI
Breach of Contract
3. Plaintiff incorporates the averments of Paragraphs 1 and 2 above as if fully set forth herein.
4. On or about May 11, 2001, Plaintiff, an employment services agency, was contacted by an
authorized agent of Defendant who contracted Plaintiff to find a full time placement for an insurance agent
to be employed by Defendant.
5. Upon this express authorization, the Plaintiff performed its services and found an employee
who was hired by the Defendant.
6. Plaintiff had initially invoiced the Defendant at it usual and customary charge for full time
placement, which is based upon the salary of the hired employee, in the amount of $5,000.00, less a
discount of $1,000.00 if timely paid according to the terms negotiated, plus sales tax. A true and correct
copy of the aforesaid invoice is attached hereto as Exhibit "A."
7. Defendant had also signed an agreement with Plaintiff setting forth payment terms which
provides for Defendant to pay Plaintiff its attorney's fees and interest at 1'/2% percent per month on any
charges remaining unpaid after thirty (30) days, together with all other expenses of collection to enforce
payment of these charges. See Exhibit "B" attached hereto and made a part hereof.
8. Defendant failed to make any payment on this invoice, thereby revoking the discount and
Plaintiff is due and owing $5,000.00, plus sales tax of $300.00 from the Defendant.
9. Plaintiff is entitled to recover principal and interest due from Defendant in the amount of
$5,548.30, calculated as follows:
Unpaid Principal $5,000.00
Sales Tax $300.00
Interest at 18% per annum from
6/15/01 thru 9/20/01 248.30
Total:
$5,548.30
10. Plaintiff has demanded the aforesaid sums from Defendant but Defendant has refused and
neglected and continues to refuse and neglect to pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $5,548.30, together
with all attorney's fees spent by Plaintiff in connection with this collection matter which will be determined at
the time of trial, plus court costs and interest at the rate of 18% per annum from September 20, 2001.
COUNT 11
Breach of Contract
11. Plaintiff incorporates the averments of Paragraphs 1 and 2 above as if fully set forth herein.
12. At the request of the Defendant, Plaintiff provided a temporary employee to provide
secretarial services for the Defendant at times and for rates agreed upon by Plaintiff and Defendant.
13. At the completion of each work week, a time card was completed by the temporary employee
evidencing the days and hours worked.
14. The Defendant, through it agents, signed each weekly time card agreeing that the temporary
employee worked on the dates and hours so designated, and returned them to Plaintiff for the employee to
be paid accordingly.
15. The signed time card was also used by Plaintiff to invoice the Defendant for the hours and
days worked by the temporary employee for the Defendant.
16. Plaintiff has issued to Defendant its Invoice #12702 for temporary employee services, all of
which were authorized and agreed upon in writing by an authorized agent of Defendant in the amount of
$579.46. A true and correct copy of the aforesaid Invoice is attached hereto as Exhibit "C."
17. Defendant has failed and refuses to pay the balance due or any part thereof on the aforesaid
invoice.
18. Each employee time card contains language authorizing Plaintiff to charge Defendant interest
at the rate of 1%s% per month on any charges remaining unpaid after thirty (30) days, and that Plaintiff is
entitled to reasonable attorney's fees, together with all collection costs, to enforce payment of these charges.
19. Defendant also executed an agreement (See Exhibit "B") on or about February 15, 2001 with
Plaintiff outlining the payment terms which included a provision for interest to be charged on any charge
remaining unpaid thirty (30) days after the invoice date and the collection of attorney's fees.
20. Plaintiff is entitled to recover principal and interest due from Defendant in the amount of
$627.18, calculated as follows:
Unpaid Principal $ 579.46
Interest at 18% per annum from
4/6/01 thru 9/20/01 $47.72
Total: $627.18
21. Plaintiff has demanded the aforesaid sum from the Defendant, but Defendant has refused and
neglected and continues to refuse and neglect to pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $627.18, together
with all attorney's fees spent in connection with this collection matter which will be determined at the time of
trial, plus costs and interest at the rate of 18% per annum from September 20, 2001.
STEWART & WEIDNER
~ Z~~ ~
Date: By.'
avid W
:150023
e. _ _
:~ ,
VERIFICATION
I, Sherry L. Shumaker, President of Keystone Staffing Services, Inc, verify that I am authorized to make
the statements herein and that the statements made in the foregoing Complaint are true and correct to the best
of my knowledge, information and belief. I understand that false statements made herein are subject to the
penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Sherry L. Shumaker
Dated: September 25, 2001
EXHIBIT "A"
4 .~e ~tatt~ng ~erv~ces, Inc. Co~~~ ~~ ~~~
360 Market Street I ,v U b I C r= _
Lemoyne, PA 17043-1632
(717)761-5860
(717) 761-5459 FAX
_ IN VViC,t
73877 ' 05/15!2001 13451 05/13/2001
INTERCONTINENTAL SERVICE AGENCY, IN
4455 N FRONT ST -
HARRISBURG, PA 17710-
Attn: George Nimesna}cer _
tandard fee
iscount` ~
HOCKENBERRY, DEIDRE P
HOCKENBERRY DEIDRE P s
55,000.00
5-1,000.00
TOTAL CHARGES - 54,000.00
TAXABLE AMOUNT 54,000.00
~TATE SALES TAX 6.0000 % 5240,00
POSITION: Insurance CSR
START DATE: May 21, 2001 _ _
COORDINATOR: Illy A. Beatty
TELaNS: $1000 upon acceptance $1000 every 30 days
until paid_
* DSSCZxmt and guarantee applies only i.f paid
accor7iing to teacts above.
e 7 Nat taxed: Wages
bonuses
salaries
benefits
expen es
payroll and withholding taxes
Pa Tota( Due-
,
,
,
,
,
g 5a.zao.oo
Please return thrs portion with your payment. Disregard this notice if payment has been made.
~ •~ .-~
TERMS: Pay this amount within 3t days or a 1.500% 73877 -
charge will be added to your account.
• - t, a ' ~ ~
t2EMJT TO: osn5tzool 73451 05!1312001
Keystone Staffing Services, Tnr_
360 Market Street
Ianoyne, PA 17043 _
~ E4,240.00
EXHIBIT "B"
I
~ ..v • - v... r.~.. rte.. p-
- V 02I13lOl 11:30 FAR T11 T81 5430 AEYSTONE STAFF - taJ 02
i .~ ^
0
EYSTOAiE S7AFFI~TG SERVICES, ItvC. F¢ ff ,E~SSI~CIATES
369 Mael,ra Sdm • Lrmoynt,
aeyauY5ta1MO5eruica, Inc and KlYStOrfe fie
Our aymuradaer m he or me tugt~t 4uatitK Tae m
try KeylOOne when untiring Our services. Neasr bn
m use awy KeyRane M `~>n4 ttdsaglee
L bvuaemeee far Seratoes fMovlaeC
~.Otrc4 Xhe Phtmttatt (PPirdaeteetAh
if our wtdWle tsmumus n~ empegmE
Olrsare5s a 00tnDtillY) wiMin 90 Gays tram the
dl.,rx your. Tnls guaranty n+rago ady K 9
8. TempeymO phcemetlt
aeYSrak o0ers a a-naw guarantee on elf I
~etperrauars, KMtmcraa net iraAiEt-yentas
w ac me protpdn wahin the Test a rquea of ou
C 1:mPlaYaa COttversiwt ReaUrlb MIre.A
safswne's guaramee on Tmtlp m rare g the
tenpaary fixa5 an 5nploywre Comeesfon, u
hoursrriatxdfRttl.`
1TOa3 • ETIT)75LSB69~ Fax-E.A7~I61-Sa39 • wweeelteyssogeaaaf3lbginrrnm
s5 (hereea rrfarM ro as ~Klyatane') guarantees tl1e pm/estatal ptd'naKnt SaMree d
i Orfarmaoan n prOVmed as a means dexplanaam at Ole ~xrvky5 and guarantees aRerW
t it is out Intp4ion m asD# you m me hest ar Our alnTilies and that you are In ro way
Keystare ken E4aal ~or9lnaY timPioYer.
y.eeasortitemaclaaa.fadtaLwagr,vwdw+accspuFBaaE-or~srnilaFdts~lan of ne
of ernpiayelrtylG IlevStarle will replace me employee Mm anOtlter grraOflM apptiCard Of
41vN[E pmvtCeg nY Kg51Dt1e was paW ar fr8 aewrdmg m Ole terms d the irnAim.
5 WE era as~led. If fM arty reason out temporary b not weekbrq aeR.M yar
-Aparsaf serSkr. ~tswaa,gphtrf'yartanraer KeYRane's ollkr! m ade~
ry commerWng Ox as9gnmela
xwr gwranlee ORered as 4atM ahwe (ar a temporary. U tll0e dws m repkrt a
on an g7dMOttal basis, it witi a at Keystone's OISOetlOrt Io dehamrine U any patR of .
•ADare nom rfeysnvre Hass 9-l+ownwxmpm fOranY ti'+aparsrYas
31. EaplanatieeofSmriro less - .
LTampetary placement ~
tlBUlt palls the hOwW tF0 eate4eete4 Pot tnea~Eatl~FaFeonesweeMe9neydtblr'a'k."Eefttpomry'aEO LBmt
Thee wal tK a d~9e rot alrr Keysmne temporary emplOYee need by a Client rmnbany wOJen 6 rnoMts from rna last day of ast assl¢artmtt
ay0f Oient This drorge wi0. nGinvviceLL.aLdlatf.or 196Pe[ tll01mo16ased.on11~3eossY6ady?M"'+n`.T~"'..="~"~;SSI.000.Y 15%x;3,250.
uany enMWae(s) of tteystOrle is tthetl by Ore~rtor any diui5ipn an0)af depaeOrlent a Oammerdal erfap Of Qiers; iNla]NG ale first iZ wwis
ItM 12 weeks muA mta1980 hours) of employee's assigrmrent wah mSt,mer, eusmma ran 9aY m Keystone tlla mnveRlon drar9e that wfT
a4 4oE„yi Q7~FIGTION. eakuWml at a ra0c ~ i% per IhailmW -this Marge witl ae 1/49g'" of the slardaN Ket9mne penrwer,t
pA~CeIE tab tatalate0 u 1% pee raC/-twucrP~oalp~Ja-We-4BdtrD~~TO-aYpYi14, tako Owlaa-ammlaa; 6v[da bl' AO
t~ tlmtl ax remaf+an9 txwrs arM 9re wi0~epual ale pa>+ated 18x.
dy+~ tlatc of natKaallan m ar Oame ate cedes 12 weeks ar employment a1 %ay.Atxu:§ payroN Me.12 webs must tda{
990 Wows} aisle m11 he lro fuller charge.
G DN'act Nln t'r StlledWa
s G' :a
;1~9D m 10,999.99 ,~ ~~- 70% ;16,000 tit 16,999.99 a 18%^ v ;131500 x 339a = ;753.p0 ~'
;Il.oap~to-11,999?/9-• rtl%- sr3 aeaeri):99999• pr7% ~ ;le;'79ox-SE%~=;?36~90 .
;12,000 m 12,999.99 = 12% 519.000 m 18,999.49 = 10% 524,300 x ZO% =;9,860A0
;I3,000 m 33,999.99 = 13% ;19,000 m 19,999.99 = l9%
314,000 m 14,999.99 = 14% f2D,000 and above: a 20% wrs b% oA safes ax.
35400m35994.99 =]5% ~ watimt 29%
]II'. Paynlenttarms
A All ImWCes are due vyon retetpt.
D. bagel, Colketemr and timrrea Fees
Ueysmne b matted m reavMaWe tees rot e
owing for arOritletl to accounlsdda
(ta% per mualm) an any charges remaiNn9
Yart sgreaee al6ms your receipt and undersbn
txainessaprees m pat Ox: ~acemrnt tee !or acct
airy ieaaoes Keys>Dnesenas aextjor referrals that
Tab Odnpd4e9 Ole full and CnnHIIeM guarartke a
rsiarg, rm otlle<guaranroe Is unfired twr Staten.
. Complete [omparry
P.o.Bycae~89
P~j s~ wl ~~~+'~'4ar : ~ w sS
y,clri:
an atmmey; N ad0itlgn m ap carer e%penses Moxred as a reAat of alledloe of lulls
-oaymeac.uaa9r~t6at wl~we wlD.twtge huertmFaFaw~r~ W 1 'h% per manor
130 t1aYS after me ilwoice date.
l Die aforementlanM fee ShcedleG and terms a5 wdt aE9lgNMng..yar a1SYptarlQ alatYma
kd appOCant(s) tared Inm yarrfum, ar atry ttarxtl M suRSfdiary of yaw fnm as a resat Or
uq.makes Otat teNY6In a daea tyre as well as ati inrOitR$ fa teelry~arias a~pned.
OY R'eystbne Sb01h9 Services, Inc. and'ICevsmrx tl"Rspaates. unksS oaxrwlse decafed m
x al/i3Te/
re twn e' rpany rya 9sta
~> ~dr
ry~ ~ T
'f1 pj ytto
EXHIBIT "C"
08/.27/2001 09:55 7177fi15459 KEYSTONE STAFFING PAGE 02(02
Keystone Staffing Service inc. INVOICE
360 Market Street '
Lemoyne, PA 17043-1632
(717) 761-5860
(717) 761-54.59 FAX
73877 ~ 03/06f2001 127~[~I-4dZ001 t
INTERCONTINENTAL SERVICE AGENCY, iN ,
4455 N FRONT ST
FdA,RRISBURG, PA 17190-
28101
/27701
28/07
/1Po1
/2101 BROWN-SANCWIn,Z, TONYA
GROWN-SANCHE.Z, TONYA
BROWNSANCHF2, TONYA
BROWN-SANGHEZ, TONYA
GROWN-SANGHEZ, TONYA R
R
ft -
R
R' 8.OOHRS fffi
~ S.OOHRS r,~
B.OOWRS Q
B.OOHRS Q
B.OOHRS 14.40 =
14.40 =
1A.40
14.x0 =
94.40 = $195.20
$115.20
$115.20
$115.20
$195.20
T07AL CHARGES - - - - -- $576.00
NON TAXABLE AMOUNT $618.40
TAXABLE AMOUNT ~ 357.60
STATE SALES TAX 6.0000 % - $3.46
Pagel Not taxed: Wages, bortusas. salaries, benefis, exoenses, payroll and wtthho(ding taxes Total bue 3579.46
Please return this portion i-vith yvrJr payment. Disregard dlis notice if payment has been made.
TERMS: Pay this amount within 31 days or a 1.500?~O 73877
charge will he added to your aceAUnt.
~~
~~~~ r 03/0612001 12702 03/04/2001
,..Cpt1NF IS ASSISNEO'0: tS OSVNEu F.Y ,
nN0 ~~S Pa1'RBt,>r'ro OUR F.4CYORS
l B ti? & T F.IOTOFS CGI~PGRATIGN
' ! !~,C. SOX 8900!1, Ct1AR!.OTT~ NG 28267-00!1
pAYh4EMT OT}1EA T1'IAN 1'0 B 8 ~ T FAOTOSS OOES MOT
OUMS17iUTE Pt,YlAF79T. t70TiFY B 8 ~T fACTORu
OF PNY O.l~OREPY}9CY Wfi}lIM 10 DAYS 5579. ae
~,s CEA REGEg'i OF :Ii`ICICE
' (336) f389-34355
a... .,,iii,., ~_. ,_.
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t ~fl ,. fish .~"'.. ~~.• ^~'~+t4v~4~=ezia rrnz rk a .aick~~b +d.a a
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SHERIFF'S RETURN - OUT OF COUNTY
~_
CASE NO: 2001-05603 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KEYSTONE STAFFING SERVICES INC
VS
INTERCONTINENTAL SERVICE AGENC
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
INTERCONTINENTAL SERVICE AGENCY INC
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On October 9th 2001 this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answe
Docketing 18.00
Out of County 9.00 ~~ _
Surcharge 10.00 R. homas Kline ,
Dep Dauphin Co 29.25 Sheriff of Cumberland County
.00
66.25
10/09/2001
JOHNSON DUFFIE STEWART WEIDNER
Sworn and subscribed to before me
this /4 ~ day of (~P~„/,-~
o'~fl-U ~ A . D .
~~• ,, C~ P`D ,t,Pw~"
~ Prothonota '
:~ .
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717)255-2660 fax: (717)255-2889
Jack Lotwick
Sheriff
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistatd Chief Deputy
COmmOnWealYh Of PCttnSylVaRis KEYSTONE STAFFING SERVICES INC
vs
COUIIty®fD211ph1Il INTERCONTINENTAL SERVICE AGENCY INC
Sheriff's Return
No. 2814-T - - -2001
OTHER COUNTY NO. 2001-5603
AND NOW: October 2, 2001 at 1:26PM served the within
NOTICE & COMPLAINT upon
INTERCONTINENTAL SERVICE AGENCY INC by personally handing
to GEORGE NUNEMAKER, OWNER 1 true attested copy(ies)
of the original - NOTICE & COMPLAINT and making known
to him/her the contents thereof at 4455 NORTH FRONT ST.
HARRISBURG, PA 17110-0000
Sworn and subscribed to
before me this 2ND day of OCTOBER, 2001
~~ ~- ~
PROTHONOTARY
(~~~ixQ ~~ ~e ~~Pxrff
So Answers,
,~'~°J~~
Sheriff of Dauphin C~.
By
epu Sheriff
Sheriff's Costs: $29.25 PD 10/02/2001
RCPT NO 154884
COOK
Now, September 28, 2001 ; I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of ~u~"-'~ Coua~ty to execute this Writ, this
deputation being made at the request and risk of'the Plaintiff.
~~;~
Sheriff of Cumberland County, PA
Now, , 20_, at o'clock M. served the
within
upon
at
by handing to
a copy of the original
acid made lazown to the contents thereof.
So answers,
Sheriff of
Sworn and subscribed before
me this day of , 20
COSTS
SERVTCE _
MILEAGE _
AFFIDAVIT
County, PA
:~; ~ _
,.
,;
Johnson, Duffie, Stewart & Weidner
By: David W. DeLuce
LD. No. 41687 Attorneys for Plaintiff
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
KEYSTONE STAFFING SERVICES, INC.,
Plaintiff
v.
INTERCONTINENTAL SERVICE
AGENCY,. INC.
Defendant
NO. 2001-5603 CIVIL TERM
CIVIL ACTION -LAW
PRAEC/PE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment by default in favor of the Plaintiff, and against the Defendan>: Intercontinental
Service Agency, Inc. , in the amount of $7,675.48, together with interest from September 20, 2001st the rate of
18% per annum, plus costs, by reason of the failure of the Defendant to enter an appearance or to file an
answer within twenty (20) days of the date of service of the Complaint endorsed with a Notice to Defend.
It is hereby certified that written notice of intention to file this Praecipe was mailed to the Defendant at
its last known address on October 24, 2001, said Notice being mailed after the default occurred and at least ten
(10) days prior to the date of the filing of this Praecipe. A true and correct copy of the aforesaid Notice, together
with the Certificate of Mailing, are attached hereto and made a part hereof.
Pursuant to Rule 206-6, the name and address of the Defendant required to be notified is
Intercontinental Service Agency, Inc., 4455 North Front Street, Harrisburg, F~nnsylvania 17110.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JO O , DUF I T W & WEIDNER
B:
avid . De
151666
±.
Johnson, Duffle, Stewart & Weidner
By: David W. DeLuce
LD. No. 41687
301 Mazlcet Sheet
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717)761-4540
KEYSTONE STAFFING SERVICES, INC.
Plaintiff
v.
INTERCONTINENTAL SERVICE ,
AGENCY, INC.
Defendant
TO: Intercontinental Service Agency, Inc.
4455 North Front Street
Harrisburg, PA 17110
DATE: October 24, 2001
IMPORTANT NOTICE
CIVIL ACTION -LAW
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
OBJECTIONS 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 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, Pennsylvania 17013
Telephone: (717) 249-3166
JO ,DUFF , S EW~~/& WEIDNER
y: ~~~
David . DeL ce
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0. 2001-5603 CIVIL TERM
:150023-7
~ ~ '>•+.
U.S. POSTAL I
CERTIFICATE
OCT 24`0[ 6'-? :~1 e~ $ g _
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aw ole<e oe omm,ry m.ll .w..a.a m: W 2~
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MAV EE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE
FOR INSURANCE -POSTMgSTER
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