HomeMy WebLinkAbout03-2737CARL S. SOCOLOW T/D/B/A
SOCOLOW PHOTOGRAPHY,
PLAINTIFF
V.
CELTIC MOON PUBLISHING, INC.,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03 _ 2737
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
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 this 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 or property or
other rights important to you.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTICIA
LE HAN DEMANDO A USTED EN LA CORTE. Si usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plaza al partir
de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrito a en
persona o por obogado y archivar en la corte en forma escrita sus defensas o sus objectiones a
las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte
tomara medidas y puede entrar una Orden contra usted sin previo aviso o notificacion y por
cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o
sus propiedades o ostros derechos importantes para usted.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
THOMAS, THOMAS & HAFER LLP
By:
&rthFro Esquire
t
Harrisburg, P A 17108-0999
(717) 255-7647
CARL S. SOCOLOW T/D/B/A IN THE COURT OF COMMON PLEAS
SOCOLOW PHOTOGRAPHY, CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
No. 03 - .z73%
V.
CELTIC MOON PUBLISHING, INC., CIVIL ACTION -LAW
DEFENDANT JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the Plaintiff, Carl S. Socolow, t/d/b/a Socolow Photography,
who avers the following:
1. Plaintiff is an adult individual trading and doing business as Socolow
Photography, with a place of business at 2714 Dickinson Avenue, Camp Hill, PA 17011.
2. Defendant, Celtic Moon Publishing, Inc., is, upon information and belief, a
Pennsylvania corporation with a principal place of business at 4 Lemoyne Drive,
Lemoyne, PA 17043.
3. Plaintiff is in the business of providing professional services in the nature
of commercial photography, for which Plaintiff receives compensation on a time and
materials basis.
4. On or about December 4, 2000, Plaintiff and Defendant entered into a
written agreement (a true and correct copy of which is attached hereto and incorporated
herein as Exhibit A), pursuant to which Plaintiff agreed to Provide professional
commercial photography services to the Defendant, in consideration for Defendant's
payment to Plaintiff for the value of these services.
5. Plaintiff did, in fact, provide the agreed upon professional commercial
photography services to Defendant for a period of time up to and including April 10,
2003. Copies of the invoices evidencing the services rendered are attached here and
incorporated herein as Exhibit B.
6. The services rendered by Plaintiff to Defendant were at all times proper,
satisfactory and consistent with and in conformance with the agreement between the
parties.
7. Pursuant to the terms of the agreement entered into between Plaintiff and
Defendant, Plaintiff forwarded invoices periodically to Defendant upon completion of
work performed, and in addition thereto forwarded monthly statements of balances due
on account, showing balances due, together with any appropriate finance charges.
Said statements and invoices requested payments for services rendered in accordance
with the agreement of the parties.
8. For a period of time Defendant made periodic payments to Plaintiff on the
invoices, however, payment was habitually late. Defendant has failed to pay each
invoice in full as required by the agreement and has, since April 11, 2003, stopped
making any payments to Plaintiff.
9. Presently, Defendant is $5,405.59 (which includes finance charges) in
arrears in its payments to Plaintiff for services rendered by Plaintiff to Defendant.
Despite multiple demands by Plaintiff for payment, Defendant has failed and refused to
pay this amount.
10. Defendant's failure to remit to Plaintiff the $5,405.59 owed is a material
breach of the agreement between Plaintiff and Defendant.
11. There are no conditions precedent to payment, and Plaintiff has at all
times performed services in accordance with the agreement.
2
12. Defendant's breach, as aforesaid, has caused Plaintiff injury in the amount
of $5,405.59, plus ongoing and accrued interest.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$5,405.59, together with costs and interest from the date of demand, being the date
when the invoices were mailed to the Defendant.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
Dated: .2003
Attorneys for Plaintiff
3
Harrisburg, PA 17109-0999
(717) 255-7647
NOV-29-00 07:15 AM
i
A Cetic Moon
traditions
period style
antiques
architecture
history
Carl Socolow
2714 Dickinson Avenue
C:1n11) I till, PA 17011
Dear Carl,
As Per our discussion yesterday, here is our agreement between Socolow PhotogmPhy and Critic
Moon Puhlishing, Inc. This will be up for renewal in one year. If at any time either patty wishes
E0 break this agreement. there will be a 60 day notice given,
1. Celtic Moon will Pay $800 Per day for all shoots not in your audio or our offices.
2. Celt it Mown will Pay $600 Per day for all shoots in your studio and our ofr,,,
3. Celtic Moon will Pay "Penes for lodging/meals/tools.
4. Celtic Moon would Pay Socolow PhmogmPhy I ravel costsof % day of an eight
hour day fur a long day of travel and % of a ii day for shoe day of travel.
5. Soenlow• Photography, when available, will Provide an assistant to be included in
otn-ref--town shoots without charge.
6. Socolow Photography would waive n-use fees, retain copyrights on the
Photography, receive a credit Line, and be noticed before rr-use shots are used, Phis permission
also aPPhrs to rarlyarn ricanlife.eom websire and will provide a link to socphoto com,
7. Celtic Moon would gram Snaahow Photography an exclusive, fiat-right-of-refmal
for shouts in Pem sylvania. Maryland, Virginia, New Jersey, Delaware, Ohio, New York, and
ConnectinII.
Carl, I hope this envets our previous discussion. We at Ccltie Moon look forward to teaming
will, you ns we continue to grow,
lira regards,
a c V sid t/ n
?? r-11 S1It
Car' Socolow Darr
Sherry Yeariek Rachev
Date
207 HOUSE: AVIiNUE, SUITS 103, P.O. D(n( 739, CAMP HILL, PA 17011
PHONE: (717) 730-6263 0 FAX: (717) 730-7385
P.01
Soco/ow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Celtic Moon
Attn: Sherri Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
SHIP TO:
Invoice
DATE INVOICE#
3/3/2003 2003-59
P.O. NO.: Verbal: Shirk TERMS: Due on receipt SHIP DATE: 3/3/2003 SHIP VIA: Pick up
PROJECT DESCRIPTION: Game News
QUANTITY DESCRIPTION
RATE AMOUNT
1 Digital Photography time hourly rate
1 Digital Image Download Fee 110.00 110.00
1 Digital services: Write to CD; 1 or 2 CDs 10.00 10.00
PA Sales Tax 10.00 10.00
6.00% 7.80
t I r r
No rights are granted untll timely payment is made. Except as otherwise specifically provided, Cad
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of
the United States. Total
$137.90
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Celtic Moon
Attn: Sherri Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
P.O. NO.: Shirk
TERMS: NET 30 1.5% Monthly
PROJECT DESCRIPTION: PGN Covers
QUANTITY DESCRIPTION
1.5 Digital Photography time hourly rate
1 Digital Image Download Fee
1 Digital services: Write to CD; 1 or 2 CDs
PA Sales Tax
SHIP TO:
Invoice
DATE INVOICE#
2/412003 2003-26
SHIP DATE: 1/26/2003 SHIP VIA: Pick up
?J
RATE AMOUNT
110.00 165.00
10.00 10.00
10.00 10.00
6.00% 11.10
No rights are granted until timely payment is made. Except as otherwise specifically provided, Carl
SocolowSocolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use
requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights Is limited to one (1) year from the date hereof for the territory of Total
the United States.
$196.10
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Soco/ow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
SHIP TO:
invoice
DATE INVOICE#
10/25/2002 2002-290
P.O. NO.: Verbal TERMS: NET 301.5% Monthly SHIP DATE: 10/11/2002 SHIP VIA
PROJECT DESCRIPTION: Moorestown, NJ : Pick Up
QUANTITY DESCRIPTION
1 RATE
Photography Day rate AMOUNT
1 Travel time: Day rate
32 800.00 800.00
Polaroid black & white medium-format proofing film
5 Color transparency medium
f 400.00
2 400.00
8
-
ormat film & processing,
12 exposure rolls .00
22.00 0.00
110
00
1 Gasoline Purchase .
2 Tpk. Tolls
1 20.00 20.00
Bridge Tolls 3.05 8.10
3.00 3.00
?I
No rights are granted until limey payment is made. Except as otherwise specifically provided, Carl
Socolow/Socolow Photography retains copyright on
ll
h
a
p
otographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated
otherwise provided herein, any grant of rights is limit
Unleas
d t
.
e
the United States.
o one (1) year from the date hereof for the territory of Total $1,419.10
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment
.
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Soco/ow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
P.O. NO.: Leah
TERMS: NET 30 1.5% Monthly
PROJECT DESCRIPTION: Xmas Photos: Chalfont, PA
SHIP TO:
Invoice
DATE INVOICE #
12/13/2002 2002-371
SHIP DATE: 12/13/2002 SHIP VIA: Pick up
QUANTITY DESCRIPTION
1 Photography Day rate
0.5 Travel time: Day rate
29 Polaroid black & white medium-format proofing film
6 Color transparency medium-format film & processing,
12 exposure rolls
246 Mileage reimbursement per mile
RATE AMOUNT
800.00
400.00
2.50
22.00
0.37
1 17
No rights are granted until timely payment is made. Percept as otherwise specifically provided, Carl
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of Total
the United States.
800.00
200.00
72.50
132.00
91.02
$1,295.52
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax 10 0232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
SHIP TO:
Invoice
DATE INVOICE #
12/18/2002 2002-364
P.O. NO.: Leah TERMS: NET 30 1.5% Monthly SHIP DATE: 12/9/2002 SHIP VIA: Pick up
PROJECT DESCRIPTION: Xmas Collectibles:BridgeWater
QUANTITY DESCRIPTION
RATE AMOUNT
1 Photography Day rate
1 Travel time: Day rate 800.00 800.00
42 Polaroid black & white medium-format proofing film 400.00 400.00
7 Color transparency medium-format film & processing, 2.50 105.00
12 exposure rolls 22.00 154.00
1 Gasoline Purchase
24.00 24.00
f^!?SC^e?
No rights are granted until timely payment is made. Except as otherwise specifically provided, Carl
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of Total
the United States.
$1,483.00
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax ID $232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
P.O. No.: Leah TERMS: NET 30 1.5°x6 Monthly
PROJECT DESCRIPTION: Look 12/09102
QUANTITY DESCRIPTION
0.5 Photography Day Rate
1 Digital Image Download Fee
1 Digital services: Write to CD; 1 or 2 CDs
RATE AMOUNT
600.00
10.00
10.00
6
No rights are granted until timely payment is made. Except as otherwise specifically provided, Cad
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of Total
the United States.
SHIP TO:
Invoice
DATE INVOICE#
12/16/2002 2002-366
SHIP DATE: 12/9/2002 SHIP VIA: pick up
300.00
10.00
10.00
$320.00
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Statement
DATE
5/23/2003
AMOUNT DUE AMOUNT ENC.
$5,071.69
DATE TRANSACTION
AMOUNT BALANCE
07/31/2002 Balance forward
08/16/2002 INV #FC 67 - Finance Charge 4,146.04
08/27/2002 PMT #5109 - Payment
002-165 57.06 4,203.10
09/04/2002 INV #2002-257- . Frede Frederick
, MD -752.50
3,450.60
09/25/2002 INV #FC 68 - Finance Charge 1,117.50 4,568.10
10/03/2002 INV #2002-277 - Windsor
CT 68.07 4,636.17
10/15/2002 ,
INV #2002-296 - Look Products 1,942.50 6,578.67
10/15/2002 PMT #5383 - Payment 2002-188 320.00 6,898.67
10/25/2002 INV #2002-290 - Moorestown, wq , NJ -1,951.30 4,947.37
11/13/2002 PMT #5467 - Payment 2002-182; 183 11419.10 6,366.47
11/20/2002 INV #2002-330 - Lynchburg, VA 1,442.30 4,924.17
11120/2002 INV #2002-339 - Creo Washington Memorabilia 11817.50 6,741.67
12/06/2002 INV #FC 70 - Finance Charge 558.50 7,300.17
12/13/2002 INV #2002-371 - Xmas Photos: Chalfont
pA 75.21 7,375.38
12/18/2002 ,
INV #2002-364 - Xmas Collectibles:Brid NJ 1,295.52 8,670.90
12/18/2002 AIV #2002-366 - Look 12109/02 1,483.00 10,153.90
12/20/2002 PMT #5639 - Payment 2002"277; 2002-257 320.00 10,473.90
01/13/2003
INV #FC 72 - Finance Charge
Finance -3,060.00
7,413.90
02110/2003 INV #FC 73 - Finance Charge 64.47 7,478.37
02/19/2003 INV #2003-45 - Look Products 99.72 7,578.09
02/21/2003 PMT #5854 - Payment 2002-
296; 2002-339; 2003 45 320.00 7,898.09
03/24/2003 PMT #5970 - Payment
2002-330 -1,198.50 6,699.59
03/24/2003 AIV #FC 75 - Fi nceae
Finance Charge -1,817.50 4,882.09
04/10/2003 INV #2003-83 - Craft Issue 101.13 4,983.22
04/10/2003 INV #2003-95 - Look 3,219.64 8,202.86
04/11/2003 PMT - Payment 2003-83; 2003-95 170.00 8,372.86
04/29/2003 INV #FC 76 - Finance Char
e -3,389.64 4
983
22
g 88.47 ,
.
5,071.69
CURRENT 1-30 DDAys UE PAST 31-60
DAY
E PAST 61-90 DAYS PAST OVER 90 DAYS PAST
D
U
DUE DUE AMOUNT DUE
0.00 88.47 101.13
0.00
4,882.09
$5,071.69
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance
DATE
8/16/2002
Charge
INVOICE #
FC 67
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #2002-165 for 752.50 on 05/31/2002
Invoice #2002-182 for 474.00 on 06/17/2002
Invoice #2002-183 for 968.30 on 06/17/2002
Invoice 42002-188 for 1,951.30 on 06/28/2002
Total
AMOUNT
57.06
$57.06
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 HouseAve.,SWte 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance
DATE
9/25/2002
Charge
INVOICE #
FC 68
TERMS
DESCRIPTION
Finance Charges on overdue Balance
Invoice #2002-182 for 474.00 on 06/17/2002
Invoice #2002-183 for 968.30 on 06/1712002
Invoice #2002-188 for 1,951.30 on 06/28/2002
Invoice #FC 67 for 57.06 on 08/16/2002
Total
AMOUNT
68.07
$68.07
Socolow Photography
P.O.Box594 Finance Charge
2714 Dickinson Avenue
Camp Hill, PA 17001-0594 DATE INVOICE #
12/6/2002 FC 70
BILL TO
Early American Life
Attn: Sherry Ritchey,
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
TERMS
DESCRIPTION
Finance Chages r AMOUNT
on Overdue Balance Invoice #FC 67 for 57.06 on 08/16/2002 7511
Invoice #2002-257 for 1,117.50 on 09/04/2002
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice #2002-277 for 1,942.50 on 10/03/2002
Invoice #2002-296 for 320.00 on 10/15/2002
Total
$75.21
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE #
1/13/2003 FC 72
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #FC 67 for 57.06 on 08/16/2002
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice #2002-296 for 320.00 on 10/15/2002
Invoice #2002-290 for 1,419.10 on 10/252002
Invoice #2002-330 for 1,817.50 on 11202002
Invoice #2002-339 for 558.50 on 11/202002
Invoice #FC 70 for 75.21 on 12/06/2002
AMOUNT
64.47
Total
$64.47
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE #
2/10/2003 PC 73
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #FC 67 for 57.06 on 08/16/2002
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice #2002-296 for 320.00 on 10/15/2002
Invoice #2002-290 for 1,419.10 on 10/25/2002
Invoice #2002.330 for 1,817.50 on 11/20/2002
Invoice #2002-339 for 558.50 on 1120/2002
Invoice #FC 70 for 75.21 on 12/06/2002
Invoice #2002-371 for 1,295.52 on 12/13/2002
Invoice #2002-364 for 1,483.00 on 12/18/2002
Invoice #2002-366 for 320.00 on 12/18/2002
Invoice #FC 72 for 64.47 on 01/13/2003
AMOUNT
99.72
Total
$99.72
Socolow Photography
P.O.Box594 Finance Charge
2714 Dickinson Avenue DATE INVOICE #
Camp Hill, PA 17001-0594
3/24/2003 FC 75
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
TERMS
DESCRIPTION
Finance Charges on Overdue Balance AMOUNT
Invoice #FC 67 for 57.06 on 08/16/2002 101.13
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice #2002-290 for 1,419.10 on 10/25/2002
Invoice #FC 70 for 75.21 on 12/06/2002
Invoice #2002-371 for 1,295.52 on 12/13/2002
Invoice #2002-364 for 1,483.00 on 12/18/2002
Invoice #2002-366 for 320.00 on 12/18/2002
Invoice #FC 72 for 64.47 on 01/13/2003
Invoice #FC 73 for 99.72 on 02/10/2003
Total
$101.13
Socolow Photography
P.O. Box 594 Finance Charge
2714 Dickinson Avenue DATE INVOICE #
Camp Hill, PA 17001-0594
4/29/2003 FC 76
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
TERMS
DESCRIPTION
AMOUNT
Finance Charges on Overdue Balance
Invoice #FC 67 for 57.06 on 08/16/2002 88.47
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice #2002-290 for 1,419.10 on 10/25/2002
Invoice #FC 70 for 75.21 on 12/06/2002
Invoice #2002-371 for 1,295.52 on 12/13/2002
Invoice #2002-364 for 1,483.00 on 12/18/2002
Invoice #2002-366 for 320.00 on 12/18/2002
Invoice #FC 72 for 64.47 on 01/13/2003
Invoice #FC 73 for 99.72 on 02/10/2003
Invoice #FC 75 for 101.13 on 03/24/2003
Total
$88.47
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CL
VERIFICATION
I, Carl S. Socolow, state that I am familiar the facts and allegations set forth in
the foregoing COMPLAINT. I have read the foregoing document and hereby affirm that
it is true and correct to the best of my personal knowledge, information and belief. This
Verification is made pursuant to 18 Pa
authorities.
C.S. §4904 relating to unsworn falsification to
Carl S. kSoc-o
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2003-02737 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SOCOLOW CARL S TDBA SOCOLOW PH
VS
CELTIC MOON PUBLISHING INC
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
CELTIC MOON PUBLISHING COMPANY but was
unable to locate Them in his bailiwick
COMPLAINT & NOTICE ,
He therefore returns the
NOT FOUND , as to
the within named DEFENDANT
4 LEMOYNE DRIVE
LEMOYNE, PA 17043
, CELTIC MOON PUBLISHING COMPANY
SERVICE WAS ALSO ATTEMPTED AT THE FORWARDING ADDRESS OF
207 HOUSE AVENUE SUITE 103 CAMP HILL, WHICH IS VACANT.
Sheriff's Costs: So answe
Docketing 18.00
Service 20.01
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
53.01 THOMAS THOMAS HAFER
06/17/2003
Sworn and subscribed to before me
this ;Z0 I day of
,2&v,3 A.D. 777"'
Prot o otar- ?' ?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CARL S. SOCOLOW T/DB/A
SOCOLOW PHOTOGRAPHY,
PLAINTIFF
V.
CELTIC MOON PUBLISHING, INC.,
DEFENDANT
CIVIL DIVISION
NO.,Q?_ oM7
JURY TRIAL DEMANDED
MOTION FOR SPECIAL SERVICE PURSUANT TO Pa. R.C.P. 430
AND NOW, comes the Plaintiff, Carl S. Socolow T/DB/A Socolow
Photography, by and through its attorneys, Thomas, Thomas & Hafer, LLP, and files the
within Motion for Special Service pursuant to Pa.R.C.P. 430 as follows:
On or about June 5, 2003, Plaintiff filed its original Complaint against
Celtic Moon Publishing, Inc., at the Court of Common Pleas, Cumberland County.
2. Plaintiff directed the Sheriff of Cumberland County to serve the
Defendant, Celtic Moon Publishing, Inc., at 4 Lemoyne Drive, Lemoyne, Pennsylvania
17043. The Company had apparently "closed its doors" on June 1, 2003, according to the
West Shore Chamber of Commerce.
3. A forwarding address of 207 House Avenue Suite 103 Camp Hill,
Pennsylvania, was provided to the Sheriff. The Sheriff thereafter attempted to serve said
Defendant at that address as well and was unsuccessful because the premises was vacant.
4. Plaintiff's attorney received a Sheriff's Return - Not Found Document on
June 19, 2003. A true and correct copy of said Sheriff's Return is marked as Exhibit "A",
attached hereto and made a part hereof.
5. Celtic Moon Publishing had a listed phone number of (717) 730-6263,
which is no longer in service and has no new number to replace it.
6. A Search of the U.S. Postmaster's records and a request for information
pursuant to the Freedom of Information Act was returned to the Plaintiff giving a P.O.
Box address of Celtic Moon Publishing, P.O. Box 1246, Camp Hill, Pennsylvania 17001-
1246. The street address given to the post office was the address listed above that the
Sheriff found vacant. A true and correct copy of these documents is marked as Exhibit
"B" and attached hereto and made a part hereof.
An Internet Business Locator search provided no alternative address for
Defendant Company, Celtic Moon Publishing, Inc. A true and correct copy of same is
marked as Exhibit "C", attached hereto and made a part hereof.
8. An Internet Search on the Pacer System to determine if this business has
been a party to any other civil action, criminal action, or bankruptcy action has likewise,
been fruitless.
9. A search has revealed that the Company, Celtic Moon Publishing, Inc.,
has purchased two additional companies, respectively named, "Early American Homes",
and "Keystone Conservationist". Upon a detailed search, the addresses for the above
named companies was the same as the address that was left vacant and reported as such
by the Sheriff. A true and correct copy of the locator documents were attached as a prior
exhibit.
10. It is Plaintiff's belief that he, by and through his attorneys, Thomas,
Thomas & Hafer, has conducted a reasonable investigation to determine the whereabouts
of Defendant, Celtic Moon Publishing, Inc., but all sources indicate no alternative address
other than the last known forwarding address of 207 House Avenue Suite 103, Camp
Hill, Pennsylvania, and a P.O. Box that cannot properly be served. As stated earlier, the
premises at 207 House Avenue Suite 103 were vacant upon arrival by the Sheriff.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court permit
Plaintiff to serve Defendant, Celtic Moon Publishing, Inc., with the Complaint and
Notice, if necessary, by instructing the Cumberland County Sheriff's Office to POST a
copy of same on the vacated premises of 207 House Avenue Suite 103 Camp Hill, and on
the prior business address of 4 Lemoyne Drive, Lemoyne Pennsylvania, 17043. In
addition, this Plaintiff requests that service be accompanied with mailing the Process to
the last listed addresses of said company, and to the P.O. Box address provided by the
post office, with said service being valid and complete upon such posting and mailing in
accordance with Pa.R.C.P. 430.
Respectfully Submitted:
Thomas, Thomas, and Hafer, LLP
Katherine E. avoso, Esqu
Attorney I.D. 273
305 North Front Stree
Post Office Box 999
Harrisburg, Pennsylvania 17108
Attorneys for Plaintiff Carl S.
Socolow T/D/B/A Socolow Photography
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CARL S. SOCOLOW T/D/B/A CIVIL DIVISION
SOCOLOW PHOTOGRAPHY,
PLAINTIFF
V.
NO.,
CELTIC MOON PUBLISHING, INC., JURY TRIAL DEMANDED
DEFENDANT
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND SS:
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Katherine E. Bavoso, Esquire, of Thomas, Thomas,
and Hafer, attorney for the Plaintiff, who being duly sworn according to Law, deposes
and says that Plaintiff, or counsel for Plaintiff, conducted an investigation to determine
the whereabouts of Defendant(s), which included, but was not limited to searches of the
following records:
Records of the U.S. Postmaster attached to the foregoing Motion.
Internet Search, with no results.
Telephone Directory.
Civil Filing search through Pacer.
FINALLY, Affidavit deposes and says that if Defendant(s) is/are not located at the
address uncovered by this investigation, the whereabouts of Defendant(s) is/are unknown
to Plaintiff.
Katherine E. Bavo quire
Sworn to and subscribed before me this
day of 1-e , 2003.
r
Notary Public
C'OfW' nG ANEALIH OF PENNSYLVANIA
Notarial Seal
My Commission Expires: ChftlJ :e L. tWern^r. Notv es Public
(,< <'ri.. R< nn iJnupunCountj
SHERIFF'S RETURN - NOT FOUND
11 CASE NO: 2003-02737 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SOCOLOW CARL S TDBA SOCOLOW PH
VS
CELTIC MOON PUBLISHING INC
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
CELTIC MOON PUBLISHING COMPANY but was
unable to locate Them in his bailiwick. He therefore returns the
COMPLAINT & NOTICE ,
NOT FOUND , as to
the within named DEFENDANT , CELTIC MOON PUBLISHING COMPANY
4 LEMOYNE DRIVE
LEMOYNE, PA 17043
SERVICE WAS ALSO ATTEMPTED AT THE FORWARDING ADDRESS OF
207 HOUSE AVENUE SUITE 103 CAMP HILL, WHICH IS VACANT.
Sheriff's Costs: So answe -)
Docketing 18.00
Service 20.01
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
. .00
53.01 THOMAS THOMAS HAFER
06/17/2003
Sworn and subscribed to before me
this day of
A.D.
Prothonotary
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THOMAS, THOMAS & HAFER LLP
ATTORNEYS AT LAW
www.tthlaw.com
305 North Front Street, P.O. Box 999, Harrisburg, PA 17108
Phone: (717) 237-7100 Fax: (717) 237-7105
Katherine E. Bavoso
(717) 237-7152
kbavoso@tthlaw.com
GH OF
CJ
Q O
June 23, 2003 O Received
Q1(J Ni 3 0
Postmaster
665 Market Street
Lemoyne, PA 17043
Re: Freedom of Information Request
Dear Postmaster:
Please furnish our fine with the new address, if available, for the following individual or verify
whether or not the address given below is one at which mail for this individual is currently being
delivered.
Name: Celtic Moon Publishing Company
4 Lemoyne Drive, Lemoyne, PA 17043
Service was also attempted at the forwarding address of 207 House Avenue, Suite 103, Camp Hill, PA.
That address is vacant.
I certify that the address information for this individual is required for the performance of this
firm's official duties.
a<r -
Katherine E. Bav o, Eire
FOR POST OFFICE USE ONLY
[ ] MAIL IS DELIVERED TO ADDRESS GIVEN NEW ADDRESS
[ ] NOT KNOWN AT ADDRESS GIVEN
[ ] MOVED, LEFT NO FORWARDING ADDRESS
[ ] NO SUCH ADDRESS
[ ] OTHER (SPECIFY): BOXHOLDER'S STREET ADDRESS
243235VI
Lehigh Valley Office: 3400 Bath Pike, Suite 302, Bethlehem, PA 18017 • Phone: (610) 868-1675 • Fax: (610) 868-1702
Postmaster
` -,?- Pa
City, St e, Zip
Date: \Illnf CAR
7CY
Request for Change of Address or Boxholder
Information Needed for Service of Legal Process
Please furnish the new address or the name and street address (If a boxholder) for the following:
Name: Celtic Moon Publishing Inc.
Address: 4 Lemoyne Drive
Lemoyne, PA 17043
Service was also attempted at: 207 House Avenue, Suite' 03
Camp Hill, PA
which house was vacant.
The following information is provided in accordance with 39 CFR. 265.8(d)(8)ii). There is no
fee for providing boxholder information. The fee for providing change of address information is
waived in accordance with 39 CFR 265.8(d)(1) and (2) and corresponding Administrative
Support Manual 352.44a and b.
Capacity of requester.(e.g., process server, attorney, party representing himself):
Attorney
2. Statue or regulation that empowers me to serve process (not required when
requester is an attorney or a party acting pro se - except a corporation acting pro
se must cite statute:
3. The names of all known parties to the litigation:
Carl S Socolow t/d/b/a Socolow Photogaphy vs. Celtic Moon Publishing Inc.
4. The court I which the case has been or will be heard:
Commonwealth of Pennsylvania - County of Cumberland
5. The docket or other identifying number if one has been issued:
No.: 2003 - 02737 P
6. The capacity in which this individual is to be served (e.g. defendant or witness):
Defendant.
Page I of 2
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS
INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF
LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN
CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID
PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS,
OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be
used solely for service of legal process in connection with actual or prospective litigation.
x0*1 aI(A
Signature
Katherine E Bavoso, Esquire
Printed Name
P.O. Box 999
Address
Harrisburg, PA 17108-0999
City, State, Zip Code
FOR POST OFFICE USE ONLY
No change of address order on file.
or NEW ADDRESS: (Please provide street address. If no street address, then supply P.O. Box
number:
1Q ,v? N t k---L- 961 1- cC
243239v1
Not known at any address given
Moved, left no forwarding address
No such address.
Page 2 of 2
JUL
2
2003
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We were unable to find matches in category "Keystone Conservatiol
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Keystone Conservationist
207 House Ave Categories: Publishers I Television Station Representati
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Celtic Moon Publishing Inc
207 House Ave Categories: Publishers I Television Station Representati
Camp Hill, PA 17011-2308 Publishers Representatives I Business Consulting Servic
Phone: (717)730-6263 Publishing Consultants I Communications Consultants
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CARL S. SOCOLOW T/D/B/A
SOCOLOW PHOTOGRAPHY,
PLAINTIFF
IN THE COIJRT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
V.
CELTIC MOON PUBLISHING, INC.,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
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 this 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 or property or
other rights important to you.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTICIA
LE HAN DEMANDO A USTED EN LA CORTE. Si usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plaza al partir
de Ia fecha de la demanda y la notification. Usted debe presentar una apariencia escrito a an
persona o por obogado y archivar en la torte en forma escrita :sus defenses o sus objectiones a
las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte
tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por
cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o
sus propiedades o ostros derechos importantes pare usted.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
THOMAS, TTHHOMAMASS & HAFER LLP
By
',f Burke, MCLemO 4!F", , Esquire
-Nbrth Fro treet
Pos. ox 999
Harrisburg, PA 17108-0999
(71.7) 255-7647
CARL S. SOCOLOW T/D/B/A IN THE COURT OF COMMON PLEAS
SOCOLOW PHOTOGRAPHY, CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
NO.
V.
CIVIL ACTION - LAW
CELTIC MOON PUBLISHING, INC.,
DEFENDANT JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the Plaintiff, Carl S. Socolow, t/d/b/a Socolow Photography,
who avers the following:
1. Plaintiff is an adult individual trading and doing business as Socolow
Photography, with a place of business at 2714 Dickinson .Avenue, Camp Hill, PA 17011.
2. Defendant, Celtic Moon Publishing, Inc., is, upon information and belief, a
Pennsylvania corporation with a principal place of business at 4 Lemoyne Drive,
Lemoyne, PA 17043.
3. Plaintiff is in the business of providing professional services in the nature
of commercial photography, for which Plaintiff receives compensation on a time and
materials basis.
4. On or about December 4, 2000, Plaintiff and Defendant entered into a
written agreement (a true and correct copy of which is attached hereto and incorporated
herein as Exhibit A), pursuant to which Plaintiff agreed to provide professional
commercial photography services to the Defendant, in consideration for Defendant's
payment to Plaintiff for the value of these services.
5. Plaintiff did, in fact, provide the agreed upon professional commercial
photography services to Defendant for a period of time up to and including April 10,
2003. Copies of the invoices evidencing the services rendered are attached here and
incorporated herein as Exhibit B.
6. The services rendered by Plaintiff to Defendant were at all times proper,
satisfactory and consistent with and in conformance with the agreement between the
parties.
7. Pursuant to the terms of the agreement entered into between Plaintiff and
Defendant, Plaintiff forwarded invoices periodically to Defendant upon completion of
work performed, and in addition thereto forwarded monthly statements of balances due
on account, showing balances due, together with any appropriate finance charges.
Said statements and invoices requested payments for services rendered in accordance
with the agreement of the parties.
8. For a period of time Defendant made periodic payments to Plaintiff on the
invoices, however, payment was habitually late. Defendant has failed to pay each
invoice in full as required by the agreement and has, since April 11, 2003, stopped
making any payments to Plaintiff.
9. Presently, Defendant is $5,405.59 (which includes finance charges) in
arrears in its payments to Plaintiff for services rendered by Plaintiff to Defendant.
Despite multiple demands by Plaintiff for payment, Defendant has failed and refused to
pay this amount.
10. Defendant's failure to remit to Plaintiff the $5,405.59 owed is a material
breach of the agreement between Plaintiff and Defendant.
11. There are no conditions precedent to payment, and Plaintiff has at all
times performed services in accordance with the agreement.
2
12. Defendant's breach, as aforesaid, has caused Plaintiff injury in the amount
of $5,405.59, plus ongoing and accrued interest.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$5,405.59, together with costs and interest from the date of demand, being the date
when the invoices were mailed to the Defendant.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
Dated: 2003
Attorneys for Plaintiff
3
Harrisburg, PA 17109-0999
(717) 255-7647
N6W-29-00 07.15 AM
0
A Celtic Moon
traditions
period style
antiques
architecture
history
Carl Socolow
2714 Dickinson Avenue
Camp I till, PA 17011
Dear Carl,
As per our discussion yesterday, here is our agrconent between Soeolow Phu; agraphy and Critic
Moon Publishing, Inc. This will be up for renewal in one year. If at any time either party wishes
to break this agrectnent, there will be a 60 day notice given,
L Celtic Moon will pay $800 per dry for all shoots not in your studio or our offices.
2. Celt ie Moor will pay $600 per day for all shoots in your stud',, and our ofrwcs.
3. Celtic Mon,, will pay expenses for lodging/mrals/tools.
4. Cultic Moon would pay Soeelow Photogmphy, ttram costsof !4 day of an eight
hour day for a long day of tmvrl and 'n of a la day for short day of uavcL
5. Soenlow Photography, when available, will provide an assistant ua be included in
out-or-town shoots w ithout charge.
6. gocolom, photography would waive "-use fees, retain copyrighs+ on the
photography, receive a credit line, and be notified berate re-use shots are used. This permission
also applies to rarlyarvarrieanlifv.eom webahc and will Prardde a link to socydtoto.com,
'tirso-righo-ot-refusal
7. Celtic Moron would gnnt Socnlow Photography an exclusive,
for shows in Pcnmylaania, Maryland, Virginia. New Jersey-, Delaware, Ohio, New York, and
Con,urtin,t,
Carl, I hope this eovcrs our pmvious discussion. We at Critic Moon look forward to teaming
with you ns we continue to grow.
4eA-A,/--
207 HOUSii AvuNUE, Surge 103, P.O. Box 739, CAMP HILL, PA 17011
PHONE: (717) 730-6263 e FAx: (717) 730-7385
ShM Yeariek Ritchey
vo
Date
P.01
EXHIBIT
4
.L ATE LEGAL SUPPLY W.
lies( reganis,
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Celtic Moon
Attn: Sherri Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
P.O. NO.: Verbal: Shirk TERMS: Due on receipt
PROJECT DESCRIPTION: Game News
QUANTITY
DESCRIPTION
Invoice
DATE INVOICE#
3/3/2003 2003-59
SHIP TO:
SHIP DATE:3/3/2003 SHIP VIA: Pick up
RATE AMOUNT
1 Digital Photography time hourly rate 110.00 110.00
1 Digital Image Download Fee 10.00 10.00
1 Digital services: Write to CD; 1 or 2 CDs 10.00 10.00
PA Sales Tax 6.00% 7.80
r "
r? ,) Its . 5 `•^-?- si
No rights are granted until timely payment is made. Except as otherwise specifically provided, Cad
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of Total $137.80
the United States.
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
EXHIBIT
ML9rFlE lEIYL NIPV LV CO.
Invoice
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Celtic Moon
Attn: Sherri Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
P.O. NO.: Shirk TERMS: NET 30 1.5% Monthly
PROJECT DESCRIPTION: PGN Covers
SHIP TO:
DATE INVOICE#
214/2003 2003-26
SHIP DATE: 1/28/2003 SHIP VIA: Pick up
QUANTITY DESCRIPTION RATE AMOUNT
1.5 Digital Photography time hourly rate 110.00 165.00
1 Digital Image Download Fee 10.00 10.00
1 Digital services: Write to CD; 1 or 2 CDs 10.00 10.00
PA Sales Tax 6.00% 11.10
n
?J {
No rights are granted until timely payment is made. Except as otherwise specifically provided, Cad
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of
the United States.
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment
Total $196.10
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Invoice
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
P.O. NO.: Verbal TERMS: NET 30 1.5% Monthly
PROJECT DESCRIPTION: Moorestown, NJ
QUANTITY
DESCRIPTION
1 Photography Day rate
1 Travel time: Day rate
32 Polaroid black & white medium-format proofing film
5 Color transparency medium-format film & processing,
12 exposure rolls
1 Gasoline Purchase
2 Tpk Tolls
1 Bridge Tolls
??Ui? tlS?w?
r
800.00
400.00
2.50
22.00
20.00
3.05
3.00
No rights are granted until timely payment is made. Except as otherwise specifically provided, Carl
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless ,.
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of Total
the United States.
SHIP TO:
DATE INVOICE#
10/25/2002 2002-290
SHIP DATE: 10/11/2002 SHIP VIA: Pick up
RATE AMOUNT
800.00
400.00
80.00
110.00
20.00
6.10
3.00
$1,419.10
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Invoice
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
SHIP TO:
DATE INVOICE#
12/13/2002 2002-371
P.O. NO.: Leah TERMS: NET 30 1.5% Monthly SHIP DATE: 12113/2002 SHIP VIA: Pick up
PROJECT DESCRIPTION: Xmas Photos: Chalfont, PA
QUANTITY DESCRIPTION RATE AMOUNT
1 Photography Day rate 800.00 800.00
0.5 Travel time: Day rate 400.00 200.00
29 Polaroid black & white medium-format proofing film 2.50 72.50
6 Color transparency medium-format film & processing, 22.00 132.00
12 exposure rolls
246 Mileage reimbursement per mile 0.37 91.02
VV,"j 17
No rights are granted until limey payment is made. Except as otherwise specifically provided, Cad
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of Total $1,295.52
the United States.
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Invoice
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
SHIP TO:
DATE INVOICE #
1211812002 2002-364
P.O. NO.: Leah TERMS: NET 301.5% Monthly SHIP DATE: 12/9/2002 SHIP VIA: Pickup
PROJECT DESCRIPTION: Xmas Collectibles: Bridgewater
QUANTITY DESCRIPTION RATE AMOUNT
1 Photography Day rate 800.00 800.00
1 Travel time: Day rate 400.00 400.00
42 Polaroid black & white medium-format proofing film 2.50 105.00
7 Color transparency medium-format film & processing, 22.00 154.00
12 exposure rolls
1 Gasoline Purchase 24.00 24.00
I r t;?c?
No rights are granted until timely payment is made. Except as otherwise specifically provided, Carl
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of Total
the United States.
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
$1,483.00
Tax ID #232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Invoice
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
P.O. NO.: Leah TERMS: NET 30 1.5% Monthly
PROJECT DESCRIPTION: Look 12/09/02
SHIP TO:
DATE INVOICE#
12118/2002 2002-366
SHIP DATE: 1219/2002 SHIP VIA: Pick up
QUANTITY DESCRIPTION RATE AMOUNT
0.5 Photography Day Rate 600.00 300.00
1 Digital Image Download Fee 10.00 10.00
1 Digital services: Write to CD; 1 or 2 CDs 10.00 10.00
6
rl-j U ?j? v S ?`
No rights are granted until timely payment is made. Except as otherwise specifically provided, Cad
Socolow/Socolow Photography retains copyright on all photographs and all rights therein are reserved. Any
additional use requires the prior written agreement of Socolow Photography on terms to be negotiated. Unless
otherwise provided herein, any grant of rights is limited to one (1) year from the date hereof for the territory of
the United States.
If exempt from sales tax, please provide tax exempt certification and deduct sales tax from total payment.
Total $320.00
Tax ID 0232427285; MASTERCARD, VISA, AMERICAN EXPRESS ACCEPTED
Statement
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
TO:
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suitc 103
P.O. Box 739
Camp Hill, PA 17001.0739
DATE
5/23/2003
AMOUNT ENC.
DATE TRANSACTION 7
J BALANCE
07/31/2002 Balance forward 4,146.04
08/16/2002 INV #FC 67 - Finance Charge 57.0
6 4,203.10
08/27/2002 PMT #5109 - Payment 2002-165 -752.50 3,450.60
09/04/2002 INV #2002-257 - Frederick, MD 1,117.50 4,568.10
09/25/2002 INV #FC 68 - Finance Charge 68.07 4,636.17
10/03/2002 INV 92002-277 - Windsor, CT 1,942.50 6,578.67
10/15/2002 INV #2002-296 - Look Products 320.00 6,898.67
10/15/2002 PMT 45383 - Payment 2002-188 -1,951.30 4,947.37
10/25/2002 INV #2002-290 - Moorestown, NJ 1,419.10 6,366.47
11/13/2002 PMT #5467 - Payment 2002-182; 183 -1,442.30 4,924.17
1120/2002 INV #2002-330 - Lynchburg, VA 1,817.50 6,741.67
11/202002 INV 42002-339 - Geo Washington Memorabilia 558.50 7,300.17
12/06/2002 INV #FC 70 - Finance Charge 75.21 7,375.38
12/132002 INV #2002-371- Xmas Photos: Chalfont, PA 1,295.52 8,670.90
12/18/2002 INV #2002-364 - Xmas Collectibles:Bridgewater, NJ 1,483.00 10,153.90
12/18/2002 INV 92002-366 - Look 12/09/02 320.00 10,473.90
12/202002 PMT #5639 - Payment 2002-277; 2002-257 -3,060.00 7,413.90
01/132003 INV #FC 72 - Finance Charge 64.47 7,478.37
02/102003 INV WC 73 - Finance Charge 99.72 7,578.09
02/19/2003 INV #2003.45 - Look Products 320.00 7,898.09
02/212003 PMT 95854 - Payment 2002-296; 2002-339; 200345 -1,198.50 6,699.59
03/24/2003 PMT #5970 - Payment 2002-330 -1,817.50 4,882.09
03/2412003 INV #FC 75 - Finance Charge 101.13 4,983.22
04/10/2003 INV #2003-83 - Craft Issue 3,219.64 8,202.86
041102003 INV 02003-95 - Look 170.00 8,372.86
04/112003 PMT - Payment 2003-83; 2003-95 -3,389.64 4,983.22
04/292003 INV #FC 76 - Finance Charge 88.47 5,071.69
1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS PAST AMOUNT DUE
CURRENT DUE DUE DUE DUE
0.00 88.47 101.13 0.00 4,882.09 $5,071.69
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE #
8/16/2002 FC 67
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #2002-165 for 752.50 on 05/31/2002
Invoice #2002-182 for 474.00 on 06/17/2002
Invoice #2002-183 for 968.30 on 06/17/2002
Invoice #2002-188 for 1,951.30 on 06/28/2002
AMOUNT
Total
57.06
$57.06
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE #
9/2512002 FC 68
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #2002-182 for 474.00 on 06/17/2002
Invoice #2002-183 for 968.30 on 06/17/2002
Invoice #2002-188 for 1,951.30 on 06/28/2002
Invoice #FC 67 for 57.06 on 08/16/2002
AMOUNT
Total
68.07
$68.07
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE#
12/6/2002 FC 70
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice AFC 67 for 57.06 on 08/16/2002
Invoice 42002-257 for 1,117.50 on 09/04/2002
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice #2002-277 for 1,942.50 on 10/03/2002
Invoice #2002.296 for 320.00 on 10,15/2002
AMOUNT
Total
75.21
$75.21
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE #
1/13/2003 FC 72
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #FC 67 for 57.06 on 08/16/2002
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice 42002-296 for 320.00 on 10/1512002
Invoice #2002-290 for 1,419.10 on 10/25/2002
Invoice #2002-330 for 1,817.50 on 11/2012002
Invoice #2002-339 for 558.50 on 11/2012002
Invoice #FC 70 for 75.21 on 12/06/2002
AMOUNT
Total
64.47
$64.47
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE#
2/10/2003 FC 73
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #FC 67 for 57.06 on 08116/2002
Invoice #FC 68 for 68.07 on 09/25/2002
Invoice #2002-2% for 320.00 on 10115/2002
Invoice #2002-290 for 1,419.10 on 10/25/2002
Invoice #2002-330 for 1,817.50 on 11/20/2002
Invoice #2002-339 for 558.50 on 11120/2002
Invoice #FC 70 for 75.21 on 12/06/2002
Invoice #2002-371 for 1,295.52 on 12/13/2002
Invoice #2002.364 for 1,483.00 on 12/18/2002
Invoice #2002-366 for 320.00 on 12/18/2002
Invoice #FC 72 for 64.47 on 01/13/2003
AMOUNT
Total
99.72
$99.72
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Eariy American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE#
3/24/2003 FC 75
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #FC 67 for 57.06 on 08/16/2002
Invoice #FC 68 for 68.07 on 09125/2002
Invoice #2002-290 for 1,419.10 on 10/25/2002
Invoice #FC 70 for 75.21 on 12/06/2002
Invoice #2002-371 for 1,295.52 on 12/13/2002
Invoice 02002-364 for 1,483.00 on 12/18/2002
Invoice #2002-366 for 320.00 on 12718/2002
Invoice #FC 72 for 64.47 on 01/13/2003
Invoice #FC 73 for 99.72 on 02/10/2003
AMOUNT
Total
101.13
$101.13
Socolow Photography
P.O. Box 594
2714 Dickinson Avenue
Camp Hill, PA 17001-0594
BILL TO
Early American Life
Attn: Sherry Ritchey
207 House Ave.,Suite 103
P.O. Box 739
Camp Hill, PA 17001-0739
Finance Charge
DATE INVOICE#
4/29/2003 FC 76
TERMS
DESCRIPTION
Finance Charges on Overdue Balance
Invoice #FC 67 for 57.06 on 08/16/2002
Invoice #FC 68 for 68.07 on 09/252002
Invoice #2002-290 for 1,419.10 on 10/25/2002
Invoice #FC 70 for 75.21 on 12106/2002
Invoice #2002-371 for 1,295.52 on 12/13/2002
Invoice #2002-364 for 1,483.00 on 12/1812002
Invoice #2002-366 for 320.00 on 12/182002
Invoice #FC 72 for 64.47 on 01/13/2003
Invoice #FC 73 for 99.72 on 02/10/2003
Invoice #FC 75 for 101.13 on 03/24/2003
AMOUNT
Total
88.47
$88.47
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VERIFY
allegations set forth in
I, Carl S. Socolow, state that I am familiar the facts and affirm that
I have read the foregoing document and hereby
the foregoing COMPLAINT.
personal knowledge, information and belief. This
it is true and correct to the best of my p 4904 relating to unsworn falsification to
verification is made pursuant to 18 Pa. C.S. §
authorities. /
Carl S. Socolow
Certificate of Service
I, Katherine E. BavosO, Attorney for Defendant, does hereby certify that I served a copy of
2003,
this ?h day of
document upon the following
the foregoing addressed as
by placing a true and correct copy in the U.S. mail, first-class, postage pre-paid,
follows:
Celtic Moon Publishing
P.O. Box 1246
Camp Hill, PA 17001-1246
Also posted by Sheriff to:
Celtic Moon Publishing, Inc.
207 House Avenue, Suite 103
Camp Hill, PA 17011
Celtic Publishing, Inc.
4 Lemoyne Drive,
Lemoyne, PA 17043
THOMAS, THOMAS & HAFER, LLP
245574.1
r
r=_ `rn
JUL U 9 2003
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CARL S. SOCOLOW T/D/B/A CIVIL DIVISION
SOCOLOW PHOTOGRAPHY,
PLAINTIFF
3? ?? v. ?? h'?
NO., _C2--
V.
CELTIC MOON PUBLISHING, INC., JURY TRIAL DEMANDED
DEFENDANT
ORDER OF COURT
AND NOW, this /y' day of - !Z4 , 2003, upon consideration of
Plaintiff's Motion for Special Service, it is hereby ORDERED, ADJUDGED, AND
DECREED, that Plaintiff shall serve its Complaint and Notice, if necessary, on
Defendant Celtic Moon Publishing, Inc., by instructing the Cumberland County Sheriff's
Office to POST a copy of same on the vacated premises of 207 House Avenue Suite 103
Camp Hill, and on the prior business address of 4 Lemoyne Drive, Lemoyne
Pennsylvania, 17043. In addition, this Plaintiff requests that service be accompanied with
mailing the Process to the last listed addresses of said company, and the P.O. Box address
provided by the post office, with said service being valid and complete upon such posting
and mailing in accordance with Pa.R.C.P. 430.
BY THE COURT:
tIO
0
,t_lh! NlIV1??l,?S?N??
n0
h5 :tl k1§y ?? I ?1flf' F:
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-02737 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SOCOLOW CARL S TDBA SOCOLOW PH
VS
CELTIC MOON PUBLISHING INC
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within ORDER OF COURT was served upon
CELTIC MOON PUBLISHING INC
the
RESPONDANT , at 1430:00 HOURS, on the 16th day of July 2003
at 207 HOUSE AVENUE SUITE 103
CAMP HILL, PA 17011
by handing to
POSTED PROPERTY AT 207 HOUSE AVENUE SUITE 103
a true and attested copy of ORDER OF COURT together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service 10.35
Posting 6.00
Surcharge 10.00
.00
32.35
Sworn and Subscribed to before
me this 5"- day of
)cv3 A.D.
. 0 &K
rProthonotary
So Answers: ?j
R. Thomas Kline
07/17/2003
THOMAS THOMAS FER
By:
e u Sheriff
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-02737 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SOCOLOW CARL S TDBA SOCOLOW PH
VS
CELTIC MOON PUBLISHING INC
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within ORDER OF COURT
CELTIC MOON PUBLISHING COMPANY
RESPONDANT , at 1905:00 HOURS, on the 16th day of July
was served upon
the
2003
at 4 LEMOYNE DRIVE
LEMOYNE, PA 17043
by handing to
POSTED PROPERTY AT 4 LEMOYNE DRIVE SUITE 203
a true and attested copy of ORDER OF COURT together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Posting 6.00
Surcharge 10.00
.00
44.35
Sworn and Subscribed to before
me this day of
2fiDlt? A.D.
"" A
Prothonotary
47
So Answers:
-- --O -
R. Thomas Kline
07/17/2003
THOMAS THOMA"FER
By: iff
Curtis R. Long
Prothonotary
Office of the Vrotbonotarp
Cumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
03 - .2-737 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT;
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573