HomeMy WebLinkAbout99-02905COMMOVVVEALTH OF PENNSYLVANIA
., COURT OF COMMON PLEAS
Can erland
JUDICIAL DISTRICT
Pennsylvania
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEASNo. 99-,296,4- CIVIL TERM
NOTICE OF APPEAL
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.
m.r. no. oN NAM[ or o.i.
IPS Limited/RVhrerls Sfra soli 09 1 01-C7larles Clement
..........
r. [ L L 11 n r
nTV srwr[ xv cco[
1302 Slate 1.3.11 Road Cane? )fill PA 17@11
owr[ or ,u oaM [nr ' n rN[ cA.[ orleo.,•?n,l
lao-.mn/
4/28/99 Xeystone Staffing' C-ervi.ces, Inc. v. IP$ iimite3/RDllrer's Straeboli
Vs.
CLAIM n0.
_ Ir L T _, fV a f,[NT
CV 19 125-99 I .D. J o. 600-266
LT 19
This block will be signed ONLY when this notation is required under Pa.
R.C.P.J.P. No. 10080. If appellant was Claimant (see Pa. R.C,P.J.P.
This Notice of Appeal, when received by the District Justice, will operate as No. 1001(6) in action before District Justice, lie
a SUPERSEDEAS to the judgment for possession in this case. MUST FILE A COMPLAINT within twenty (20)
days after filing his NOTICE of APPEAL.
Signature a/Pmthonotary 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).
PRAECIPE: To Prothonotary
Enter rule upon Xeystcale Staffing Services, NC.
appellee(s), to file a complaint in this appeal
Name a/ appelteets)
99-a9 Civil Term
(Common Pleas No. ) within twenty 120) days after service of?ule or suffer entry of judgment of non loross..
RULE To Icy St.OIle Staf ilx) Services Iiic. Signature of appellant or his attorney or agent
i , appellee(s) I
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty 120) days after the date of
service of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS VVILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mailing. J 1
May 13, 99
Date: ..M- , 19 _.
-J"j- Signature / rorhonorpry o Orp ry
AOPC 312-90
i..
PR0101- OF SHIVIC E- 01' NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(1 n1:7 proof tN sen is I. AIIISI I if f !l. f_f) ,4vaI I!N lit-N(10) GAYS AFTER filing the notice of appeal, Chock applicable boxes) '
A
COMMONYJI:AL.1&011NN!;Y /On.
COON IV OI. } AFPIDAVI'I ..
I Ir r?l ih, r ulI/AI l, Cun?n?? Iris No???-_ Ilp??n I it Uistrie r?.,, Icsiqnated Lhe lcln oil,
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?,?"LV1 ?L• I'I j IIr? ? nd uvicc i {I ul ?I, In?f el's receih attached here 'id'
nJ twill?II Ih I I I,clvi.I Ih•• Rr.L (ll„ a I' n Iamt lccol Iymll ti"! n« Notice of Appeal upon tale nppellec(s) to
r ?' nl l r.' i II ,•,,Mi ll ln'? ,,.?/? ??- )? ??11Y pi 1"joZo, SCIVIfn ? I by CC 11111' i (RRJfr"LT{Lr'?
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of ull:. iii '
Nolanal Sept
Luroa D Davan, Notary Public
llar""rp, bauphln Ccw ity
My Cornrrusum f kTams Feb. 25.200p
Membit 11ennyvarga ASSOmanon of Notaries
C
Signalure of
rt
!I
t.
COMMON PLEAS NO. 99.-2905 Civil Term
•oompkt.Item CVW , a a, and z for additional service,.
I also wish to receive the
"Pampa your Nome a, a, e ab following services (lor an
" "Print your name and address on are rewree of Ws to= eo that we can return Ihie
cord to you. extra fee):
Attach mis farm to the frond aline mellpleco, «on the beck it apace does not
gg •Wdte?Refum Roca/pt Requesfed'on the mellpiace beiowthe article number. T, 11 Addrricted 9Addr089
d "The Return Receipt will Show to Whom the article was delivered and the date 2• 11 Restricted Delivery
delivered. Consult
3 Artlcie Addressed to: postmasterfor tee.
It. A ? fritter
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C
a
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`MISS '
t1???j?, ?EupinssMall ?Insured ,?I
1v?u??C:QIJ_y(_yljJ?A W^??J(? m Receipt for Merchandise 0 COD 3
11KX 1 / 1 ` (V 11 7. D etlvery ',
5. Received By. (Pdnf Name)
8. Addressee's Address (Onlyllrequested
and lee is paid)
g s. nature: (Address. rAgent)
-?
PS FoRR 3811, Dec bar 1994 102595.97-60179 Domashr Uatr rat M7..m
SEND"i*
•comalCa trnu, arw'« z nor saatonel aervlC.a
.
•Complate Item. 3,4a, and.b.
I also wish recoive the
be
°Pdnf your rani. std addrsw on tlro rov.ro. of iN. Conn eo mat w. Can rot um tld.
Card to you (ollOWing sBMC9s (for an
.
•An.U1 Ud. brat to the from of the mNlpNp, «on IN beck N.paCa does not
•wpermit. extra fee):
Addre35
I. 13 RO
p
y eturn Ram/pt RequestW m tM menpkpa below the article number.
¦The Return Recalls wtn show to whom IN, arty. wu danv.red And the date
li
d stdCle D
2• Restdded Delivery
e
vered. -
e • Article Addre to• Consult postriumfer for lee.
3tV,1FV YC ?cw Cb Cep
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Alaf Sb?? PA 1111c
s. Sign
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PS Form
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* WA.Ty?p.5
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end lo')
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'..ngNWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
Ctutlberland
JUDICIAL DISTRICT
Pennsylvania
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. 99-.2965 CIVIL TERM
NOTICE OF APPEAL
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.
IFS Limited/Rohrer's Stranboli 109-1-01-Charles Clement
•oono• oe wr?uenT
,T?T• si• coo:
1302 Slate Hill Road Cann Hill PA 17011
4/28/99
Inc. v. IS Limited/Rohrer's Stranboli
CV 19 125-99 LD. 66266 - -
LT 19 -,_?aa c?QJI\na?co?Jv?c+ Q rte/
This block will be signed ONLY when this notation is required under Pa.
R.C.P.J.P. No. 10088. If appellant was Claimant (see Pa. R.C.P.J.P.
This Notice of Appeal, when received by the District Justice, will operate as No. 1001(6) in action before District Justice, he
a SUPERSEDEAS to the judgment for possession in this case. MUST FILE A COMPLAINT within twenty (20)
days after filing his NOTICE of APPEAL.
Signature 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).
PRAECIPE: To Prothonotary
Enter rule upon Keystone Staffing Services, INC.
Name ofappelleelsl , appellee(s), to file a complaint in this appeal
99-,29&5 Civil Term
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Keystone Staffing Services,' Inc. Signature of appellant or his attorney or agent
RULE: To , appellee(s)
Name of appellee(s)
(1) 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.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service wa, by mail is the date of mailing.
May 13, 99
Date: M- 19_.
onnta O p y
Signatur Plot"
AOPC 312.90 (--C(,!!iT FI' F T(-. ;?F F'LFiD WI T i-i PIROTf-10helARY
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_ 013104 Paynelle W pow s,Japuas'I!ew
(paJalsrtiaJ) (paygJnn) Aq r_j aOIAMS leIJOSJad Aq ? '--GL -u0 POSedJ ppe Senn aln8 ayl wognn
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uo'--------------._.---- ----...--------------(nuJCU/'aapadde ayl uodn pue. olaJay pOC{Oei1e ldianeJ
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uO waJayl paleu6iSap a311911F 101WIO ny1 uodn ---•oN scald uowwn0 'WaddV to 131ION ayl to Adoo e
panJas 11cy1 wJyle JO Jeams AgOJay I :lIAV01ddV
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1NIV1dW00 3114 01 3111H ONV 1V3ddV d0 30110N d0 301AH3S d0 d00EId
C011NTY r1F• CUMBERLANn
Na;
09-1-01
DJ Name: Han.
CHARLES A. CLEMENT, JR.
1106 CARLISLE ROAD
CAMP HILL, PA
Talepe°na:(717) 761-4940 17011
ATTORNEY DEF PRIVATE :
VS. J
NAME an0 ADDRESS
)/ROHRER`S STROMBOLI
HILL ROAD
PA 17011
CUNNINGHAM & CHERNICOFF, P.C. L J
3320 N. SECOND ST. DocketNo.: CV-0000125-99
PAIGE MC DONALD-MATTHES Date Filed: 3/01/99
HARRISBURG, PA 17110
4 f'.
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLA=.Fg
® Judgment was entered for: (Name) xRvg *p q pAFFTw% 4F.RVTr!Rq TM
Lx] Judgment was entered against: (Name) TFG LTMT'1'Rn/ROHRRR , q STROMROT T
in the amount of $ S,375 gD on
7 Defendants are jointly and severally liable.
Damages will be assessed on:
This case dismissed without prejudice.
07 Amount of Judgment Subject to
Attachment/Act 5 of 1996 $-
El Levy is stayed for days or ? generally stayed.
Date: Place:
Time:
NU I ICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAMEaWADDRESS _
rkEYSTONE STAFFING SERVICES, INC.
360 MARKET STREET
LEMOYNE, PA 17043
L
DEFENDANT:
f=FS LIMITEI
1302 SLATE
CAMP HILL,
(Date of Judgment) _ 4/2R/qq
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total $
? Objection to levy has been filed and hearing will be held:
- 414111199, Date / t>---? -'• ???',? - . 'strict Justice
I certify that this is a true and correct copy of the record of the proceedings contai ng the judgment.
Date _ , District Justice
My commission expires first Monday of January, 2002 SEAL
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OFJUDGMENT 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 JUDGMENVI RANSCRIPT FORM WITH YOUR NOTICE OF.APPEAL.
AOPC 315-99
Keystone Staffing Services, Inc.
vs
IFS Limited
Rohrer's Stromboli
IN THE COURT OF COMMON PL-nAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL 19
99-2905
RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially
in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Richard E. Guida , counsel for the
Ypdxzttotu&/deiendant in
the above action (or actions), respectfully represents that:
1. The above-captioned action (or actions) is (are) at issue.
2. The claim of the plaintiff in the action is $ 5,236.40
The counterclaim of the defendant in the action is -
The following attorneys are interested in the case(s) as counsel or are other-
wise disqualified to sit as arbitrators:
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
Richard E. Guida n-4
ORDER OF COURT
AND NOW, 8 , 19?, in consideration of the
foregoing petition, 0"&41 0&4,t,
so., UG1?t'?E?`'
Esq., and ,Esq., are appointed ar itrators in the
LIP
above-captioned action (or actions) as prayed for.
R.ED-CrFICE
;F %., 1OF TF ;r<OTAfY
99 JUL -9 PP4 3: 32
CUPJSERL< \0 COUMY
PENNSYLVA,\iA
7
KEYSTONE STAFFING SERVICES,
INC.
VS
IFS LIMITED
ROHRER'S STROMBOLI
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-2905
PLAINTIFF'S ANSWER TO DEFENDANTS' NEW MATTER
AND NOW, this 9 day of June 1999 comes Keystone
Staffing Services, Inc., above-named plaintiff, by and through
its attorney, Richard E. Guida, Esquire, and respectfully avers
the following:
9. Admitted.
10. Denied. William Keller did not have contact with
Defendants until October 1, 1998.
11. Denied. William Keller did not have contact with
Defendants until October 1, 1998.
12. Denied. William Keller did not have contact with
Defendants until October 1, 1998.
13. Denied. William Keller did not have contact with
Defendants until October 1, 1998.
14. Denied. William Keller did not have contact with
Defendants until October 1, 1998.
15. Admitted.
16. Admitted that William Keller filled out an
application with Plaintiff.
3.7. Denied. On or about September 30, 1998, Plaintiff
informed William Keller that Plaintiff had set up an interview
for him with Rohrer's Stromboli.
18. Denied. Plaintiff told Mr. Keller that the
interview was with Rohrer's Stromboli.
19. Denied. William Keller never said anything to
Plaintiff about his alleged previous contact with Defendants
until after Plaintiff filed a civil complaint against Defendants
in District Justice Court. Defendants never contacted Plaintiff
about the alleged previous contact with William Keller.
70. Admitted that Plaintiff invoiced Defendants
pursuant to the contract. Denied that there was any error and
denied that William Keller had any previous contact with
Defendants.
21. Denied. Defendants specifically requested
Plaintiff's employment services, and Plaintiff provided such
services pursuant to a contract.
WHEREFORE, Plaintiff respectfully requests that
judgment be entered in favor of Plaintiff and against Defendants
in the amount of $5,236.40 and costs.
Respectfully submitted,
Richard E. Guide
Guide Law Offices
503 North Front Street
Harrisburg, PA 17101
717-236-6440
Identification #62405
Attorney for Plaintiff
06/03/1999 .15:3(
Jun-03-99.03:4
INC.
7177615459
Guida Law Offices
STArPXNO SERVICES,
vs
KEYSTONE STAFFING SV
236 9899
PAGE 09
P.10
IN Praz COURT or Comm plaks
CUMDZRLAND COUM, PMMBTLV=rA
CIVIL ACTION - LAN
99-2905
Irs AIINIirmn
RONRER'8 5T7WKBOLX
TAU!
bum
VBRMCATION
I VERIFY THAT THE BTATENMTS MDR IN TEI8 CCWZJ?IR"1' ARE
CORRECT. I UNDERBTAWD THAT THZ BTATEIMTS mmzxN ARE
ZMCT TO TAE PRURLTIES OF 18 PA.C.S.A. SECTION 9904
TO UNSHORN TAL917ICATIONN TO AUTHORITIES. //JJ
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Sigaat
air
ZE'rr ?. J(74inGJC P?
prints Nate
?? eS ic/'t?.•t
Title
?4tiP >/99S
Date
KEYSTONE STAFFING SERVICES, IN THE COURT OF COMMON PLEAS
INC. CUMBERLAND COUNTY, PENNSYLVANIA
VS
CIVIL ACTION - LAW
IFS LIMITED
ROHRER'S STROMBOLI 99-2905
CERTIFICATE OF SERVICE
I, Richard E. Guida, Esquire, hereby certify that I
served a true and correct copy of Plaintiff's Answer to
Defendants' New Matter served upon the following parties by
regular U.S. Mail, postage prepaid, this 9 day of June 1999,
addressed as follows:
Paige Macdonald-Matthes, Esquire
PO Box 60457
Harrisburg, PA 17106-0457
Richard E. Guida
i
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KEYSTONE STAFFING SERVICES,
INC.
VS
IFS LIMITED
ROHRER'S STROMBOLI
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-2905
NOTICE TO DEFEND
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
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.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, PA 17013
717-240-6200
KEYSTONE STAFFING SERVICES,
INC.
VS
IFS LIMITED
ROHRER'S STROMBOLI
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-2905
COMPLAINT IN RESPONSE TO APPEAL BY DEFENDANTS
AND NOW, this 21 day of May 1999 comes Keystone
Staffing Services, Inc., above-named plaintiff, by and through
its attorney, Richard E. Guida, Esquire, and respectfully avers
the following:
1. Plaintiff is a corporation having offices at 360
Market Street, Lemoyne, PA 17043.
2. Defendants are corporations having offices at 1302.
Slate Hill Road, Camp Hill, PA 17011.
3. On or about September 29, 1998, Defendants placed
an order with Plaintiff for Plaintiff to provide an employee for
Defendants. Exhibit A.
4. On or about September 29, 1998, Plaintiff and
Defendants signed a contract. Exhibit B.
5. On or about September 30, 1998, Plaintiff set up
an interview by Defendants of William Keller.
6. On or about October 1, 1998, Defendants hired
William Keller.
7. Pursuant to the contract, Plaintiff invoiced
Defendants in the amount of $5,236.40 for the placement of
William Keller. Exhibit C.
8. Although repeatedly requested to do so by
Plaintiff, Defendants have willfully failed and refused to pay
the aforesaid balance or any part thereof to Plaintiff.
WHEREFORE, Plaintiff respectfully requests that
judgment be entered in favor of Plaintiff and against Defendants
in the amount of $5,236.40 and costs.
Respectfully submitted,
J
Richard E. Guida
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
717-236-6440
Identification #62405
Attorney for Plaintiff
Keystone Staffing Services, Inc. JOB ORDER FORM N p 10p522
Sours: ? Marketed ? Brought in Called in By: ? . ? f o-er: Today's Date: L [ /
Com'-an"'fnforinati""eb'rt•?.`-f +. ,); ,? ?x+,? ? l?,.,,a.?
Correct Company Name:
err Q, L'G V,, S, 5. 7
lu`J<' Pho a #: xt:
l 3 - / e5 Fax #:
Contact NameM08: Omni/0B #: .
Other Divisions? ? Yes ? No
Address:
1.30 ...
. !... -. ! .. Ra .............
.......... Existing
Mew Who?
Who? Dept?
Dept?
Slat / ^ Zip Code:
bt- jU Cre 't information:
Company Sae WJC Coda: Was another agency called? Yes
W101 When? No - -
F(?J(L
?E --(-(?-•-"((?jJ????
OD ?"/"7'""'-""""
VV
Exempt on6%sales taxl
If yes, tax t is: '(es No who? When?
Is company running own ad? ? Yes
? No ti
•
?--------- ................
"LJ
-
. Ptisitioe?lfrfortiriatlon ??;'.r.. _•? -? .. ? -
....s
Title: emt ? Temp
? FJC ? Payroll o,
Essential functlon and ,o of job to be performed:
Duties: ? wpm
......... ................. ? Admin Asst _ % Sitting _ % Standing _ % Lifting
-7/
........................................ /__//7 rG^? ? Secretary
- .............. ? EURecp
--% Bending _%Other.
•
........?..=??/.1?-'
!:-.
.........
-• G``?. ? Data Entry
? Insurance
.T'7?-.. ....... Education/Degrees Required:
v
. ._
P I
. ?
-°-.... .... .. - -- °--..v'-=..V.......-
? Bookkeeping
°........---°-• ? Legal
Smoking office? Yes No
Drug screen? ? Yes ? No
?Medical Company Atmosphere:
'
............................................................... ?Lt. Industrial
.................
? Technical Dress Code:
? Computer
Benefits (when permanent): cox'. ?, I I -/
[3 Medical [I Hospitalization # sick days --F BC1BS HMO ? PPO Profit Sharing ? Pension ? Credit Union
? Life ? Dental # holiday day; ?.f/E2r?q F ..?? ?t I L
? Other. # vacation'Says _ ILJ Other. ? Tuition Reimb ? 401(k) ? Other.
Adv pport 'id Parking Provided: 11 Yes ? No Lunch Facilities:
} r
? Paid ? Unpaid ? Cafeteria ? Lunch room ? Bring own lunch
starts, /?
Sq # 61 temps needed: Hours: // ••77
E3 F/1' ? P/r from (17 // A /PM to , 7, 701 AM/PM with minutes for lunch
Report to: Duration: EEC L-1 Indefinite P-qerm Detailed job descnpj ?7on file?
(#)
..
....
. _ ? Days ? Weeks ? Months ? Yes 1A No
.
...
..........••••......................- Comments:
iew7
Compan wish
t
Name: Department: ? No
es
Billing lnfonnation 4 ? - • • ? z
Billing Address (if different than above): TemplPayroll: Dept #:
.............................................. .. ;
Purchase Order
BiR: S P!R: S '- MN: 11.
Ciry: State: Zip Code: Perm:
Years Salary:, ; Fee Amount:
j .Full Fee ?• - •/• - (+ sales tax) =
COdIaG Nameftitle: OR
5 ; ? Disgeu t ee - S i or _ % (+ sales tax) = $
CaadidatalEm to ee Information .. •- ?? :-:' A a 3 E:.
Candidate Name: Fax/interview: Gate: I Time Emcio ee Ae icnetl : i Phone #? Start Date: I End Date: I Arrival
Resume taxed
Interview
L'
t i { IN
-
? Resume taxed lit
i?
?. ,
? Interview a
? Resume faxed
? Interview
' ? Resume faxed I (?i ?' '? •?%yI ' 1y? vJ ?,?
? Interview I
? Resume faxed -
? Interview -
? - b?
WHITE- ORIGINAL 'YELLOW - ECCKKEEPING PINK - SHERRY'S COPY
A
09/28/1998 21:27 7177615459 KEVSTONEESTAFFING PAGE 02
eystone StafioLing Services, Inc. ova
360 Market Sbeet, Lemoyne, PEA 17043 (717)761-5860 Fax (717)761.5459
LK11
KEYSTONES GUARANTEE POLICY lk SERVICE AGREEMENT CONI'RA& M
Keystone Statling Services, Inc. guarantees the professional placement services d our organisation to be of
the Nghest quality.
If our candidate terminates his/her employment for any reason (other then lack of work, workplace shutdown
or similar dissolution of the business or company) within ten (10) weeks from within the first day of
employment. Keystone's guarantee to as follows:
e If said termination occurs within four (4) weeks from the first day of employment, Keystone will fully
refund the professional services placement fee or, alternatively, replace the employee with another
qualified applicant of the client's choice.
e If said termination occurs within the next six (5) remaining weeks of the above-described ton (10) week
period, Keystone will replace the employee with another qualified applicant of the client's choice.
Any refunds resulting from this guarantee due to client companies from Keystone Staffing Services, Inc, shell
be paid promptly upon receipt of a written statement from the client company detailing the reason for said
termination and specific dates of employment; provided the original Invoice presented by Keystone Staffing
Services, Inc. was paid in full within thirty (30) days from the first day of our candidate's employment.
This comprises the full and complete guarantee offered by Keystone Staffing Services. Inc., unless otherwise
detailed In writing, no other guarantee Is Implied nor stated.
KEYSTONES PEE SCHIEDULE oe
M<YEARIa' ANNIN _& Sh
$1,00 to 10,999.99 n1_SAL) Iz QU6B
10% r ,
$11,000 to 11,999.99 11% ENWLEsOF5MUteCtJunaa-
$12,000 to 12,999.99 12% $13500 x 13% 1,755.00
$13,000 to 13,999.99 13% $18.700 x 18% a $3,388.00
$14,000 to 14,999.99 14% $24,300 x 20% ¦ $$§444,880.00
$15,000 to 15,999.99 15%
$18,000 to 16,999.99 18%
$17,000 to 17,999.99 17% Plus 6% PA sales fix which Is not
$18,000 to 18,999.99 18% Included In the des schedule.
$19,000 to 19,999.99 19%
$20,000 and above: the servi ce charge will not exceed 20%
Your signature atRrms your recelpt and understanding of the aforementioned fee schedule and terms as well
as signifying your acceptance that your business agrees to pay the placement fee for any qualified applicant
hired Into your firm, or any branch or subsidiary of your firm, as a result of any resumes Keystone Staffing
Services, Inc, sends s tprrals thj tayittgne Staffing Services, Inc, mikes that results In a direct hire.
In so:ordance wdrl Federal, State b Loot taws, It 4 Keyetone Sta@Ing Services, Inv.'s polcy to extend professional services to oil
qvaeeed employed and unemployed epplloante reganrlou of raw, odor, weed, Nx, age, religion, neeoner orloln, enoesby, Inwme, Ierei
or nayob related handicap.
s9 We can't tpeu S CC,t'$ W(hout U1 (V
RECEIVED DATE : 09/29/98 09:26 FROM :7177615459
c.I,,e.I
.j(one Staffing Services, Inc.
366 Market Street
Lemoyne, PA 17043=1632
(717) 761-5860
(717) 761-5459 FAX.
INVOICE
s,
FRE
I ,
9? . ar$? e D .. , ' ;
0053 '(0/06/1998 2987
10/04/1998
S S LIMITED'
I S S LIMITED 1302 SLATE HILL ROAD
1302 SLATE HILL ROAD CAMP HILL, PA 17011-
CAMP HILL, PA 17011- BOB MLYNECK
Bob MLyneck
TOTAL CHARGES S4 940.00
NON TAXABLE AMOUNT 40.00
TAXABLE AMOUNT T$$4.9407.00
STATE SALES TAX 6.0000 % 98.40
POSI
TION: Maintenance
START DATE: October 2, 1998
COORDINATOR: Cinde Holste
•
TEEM: Due
Total Due
Please return this portion with your payment. Disregard this notice if payment has been made.
• ?. a • I
REMIT TO: t t i1 2987
,Kegstcne Staffing Services, Inc.
360 Market Street
IeWYne, PA 17043
•
$5,236.40
a
EL:
r ..... P..7 ?" .
May-18-99 11:55A Guida Law Offices 236 9599 P.Oq
KEYSTONE STAFFING SERVICES
vs
IFS LIMITED
ROHRER'S STROMBOLI
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAN
99-2905
VERIFICATION
I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE
TRUE AND CORRECT. I UNDERSTAND THAT THE STATEMENTS HEREIN ARE
MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S.A. SECTION 4909
RELATING TO UNSNORN FALSIFICATION TO AUTHORITIES.
Signatu e
Sherry L. Shimiaker
Printed Name
President
T?t1e
May 18, 1999
Date
KEYSTONE STAFFING SERVICES,
INC.
VS
IFS LIMITED
ROHRER'S STROMBOLI
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-2905
CERTIFICATE OF SERVICE
I, Richard E. Guida, Esquire, hereby certify that a
true and correct copy of the Complaint In Response To Appeal By
Defendants served upon the following parties by regular U.S.
Mail, postage prepaid, this 21 day of May 1999, addressed as
follows:
Paige Macdonald-Matthes, Esquire
PO Box 60457
Harrisburg, PA 17106-0457
?-? E 4,
Richard E. Guida
W
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KEYSTONE STAFFING SERVICES IN THE COURT OF COMMON PLEAS
INC., CUMBERLAND COUNTY, PENNSYLVANIA
V.
IFS LIMITED/ROHRER'S NO. 99-2905
STROMBOLI,
CIVIL ACTION-LAW
Defendant
TO: Keystone Staffing Services Inc Plaintiff
and
Richard E. Guida, Esquire
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
(Attorneys for Plaintiff)
YOU ARE HEREBY NOTIFIED TO
PLEAD TO THE ENCLOSED
NEW MATTER WITHIN TWENTY
(20) DAYS FROM THE DATE OF
SERVICE HEREOF OR A DEFAULT
JUDGMENT MAY BE ENTERED
AGAINST YOU.
Paige Macdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. BOX 60457
Harrisburg, PA 17106-0457
(717) 238-6570
(Attorneys for Defendants)
KEYSTONE STAFFING SERVICES
INC.,
V.
IFS LIMITED/ROHRER'S
STROMBOLI,
Defendant
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-2905
CIVIL ACTION-LAW
DEFENDANT'S REPLY'- TO PLAINTIFF'S COMPLAINT TOGETHER WITH NEW
MATTER
AND NOW, comes the Defendant, IFS Limited/Rohrer's
Stromboli, by and through its counsel, Cunningham &
Chernicoff, P.C., and files its Answer to the Plaintiff's
Complaint and in support thereof avers as follows:
1. Admitted.
2. Denied as stated. By way of further reply, IF
Services, Ltd, d/b/a Rohrer's Stromboli has offices located at
1302 Slate Hill Road, Camp Hill, PA 17011.
3. Admitted in part and denied in part. It is admitted
that an employe of IFS Limited contacted Plaintiff to request
Plaintiff's assistance with hiring needs. It is denied that
Plaintiff's Exhibit "A" is an application completed by
2
Defendant.
4. Admitted.
5. Admitted in part and denied in part. It is admitted
that on or about September 30, 1998, Plaintiff set up an
interview for Defendant IFS of William Keller. It is denied
that William Keller had not already been interviewed by
Defendants. By way of further reply, William Keller was
interviewed by telephone by Leo Bloom, President of IFS, Ltd,
and Harold Rhodes a/k/a "Sonny", Plant Manager, on September
11, 1998 for a position with IFS Limited.
6. Denied. It is denied that on or about October 1,
1998, Defendant hired William Keller. By way of further
reply, William Keller was offered a position with IFS Limited
on September 11, 1998 at the conclusion of Mr. Keller's
interview with Leo Bloom, President.
7. Admitted in part and denied in part. It is
admitted that Plaintiff invoiced Defendant in the amount of
$5,236.40 for the alleged placement of William Keller. It is
denied that Plaintiff placed William Keller in a position with
3
Defendant.
8. Admitted in part and denied in part. It is
admitted that Plaintiff has requested payment. It is denied
that Plaintiff is entitled to any payment from Defendant. By
way of further reply, William Keller was already hired by the
Defendant prior to Plaintiffs scheduling the interview on
September 30, 1998.
WHEREFORE, Defendant respectfully requests that this
Honorable Court enter judgment in its favor and against
Plaintiff, and dismiss the Plaintiff's Complaint and further
award Defendant all such other relief as is proper and just.
NEW MATTER
9. The averments set forth in Paragraphs 1-8 are
incorporated herein as if more fully set forth at length.
10. On or about September 'l1, 1998, William Keller
submitted an application and resume to IF Services, Ltd d/b/a
Rohrer's Stromboli for consideration for employment. A true
and correct copy of William Keller's application is attached
4
hereto and is marked as Exhibit "A"
11. On or September 11, 1998, upon the recommendation of
John Kurtinetcz, the gentleman who William Keller would
eventually replace, William Keller was interviewed by Leo
Bloom, President of IFS Limited, and Harold Rhodes, a/k/a
"Sonny", Plant Manager.
12. At the conclusion of the telephonic interview on
September 11, 1998, and upon the overwhelmingly positive
recommendation of John Kurtinetcz, William Keller was offered
a position with IF Services, Ltd.
13. William Keller did not immediately begin working for
IF Services, Ltd. or. September 11, 1998, because he had his
arm in a cast.
14. Notwithstanding the fact that William Keller had
already been offered a position with IF Services, Ltd.,
William Keller continued to look for alternative employment
positions in the area.
15. On or about September 30, 1998, William Keller
5
entered the business premises of Plaintiff for the purpose of
inquiring employment possibilities in the area.
16. On or about September 30, 1998, William Keller
filled out an application with Plaintiffs. A true and correct
copy of the William Keller's application with Plaintiffs is.
attached hereto and marked as Exhibit "B".
17. On or about September 30, 1998, Plaintiffs informed
William Keller that Plaintiff had set up an interview for
William Keller with a company by name of IIISS Limited".
Further evidence that Plaintiff informed William Keller that
he would be interviewed by a corporation known as IIISS
Limited", is the invoice forwarded to IF Services, Ltd., (a
copy of which has been marked as Plaintiff's Exhibit "C"),
which refers to IF Services, Ltd. as to IIISS Limited."
18. William Keller attended the interview on October 1,
1998 at Defendant's place of business, because he thought he
was being interviewed by a company by the name of IIISS
Limited".
19. Upon Mr. Keller's realization that he had arrived at I,
6
the same company at which he had already been interviewed and
had already been offered employment, both Mr. Keller and
Defendant notified Plaintiff of the error.
20. Notwithstanding the fact that Defendant notified
Plaintiffs of the error, and notwithstanding the fact that
Plaintiff was aware that Mr. Keller had already been hired by
Defendant prior to the interview being arranged by Plaintiff,
Plaintiff still invoiced Defendant for the placement.
21. Defendant hired Mr. Keller independent of any
services offered or rendered by Plaintiff.
7
WHEREFORE, Defendant respectfully requests that this
Honorable Court enter judgment in its favor and against the
Plaintiff and dismiss the Plaintiff's Complaint with prejudice
and further award Defendants all such other relief_ as is
proper and just.
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: May 27, 1999 By:Q aw?col>rv?-h?c?Yl?.?
Paige Macdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box. 60457
Harrisburg, PA 17106-0457
(717) 236-6570
(Attorneys for Defendants)
8
I, Leo Bloom, Preeident of I.F. Services, Ltd., verify
that the etataments made in the foregoing Reply with New
Matter are true and correct to the beat of my knowledge,
information and belief. I understand that false etatemente
herein are made su:?jAet to the penalties of unsworn
falsification to authorities. /-)
Preeident, I.F. Services, Ltd.
Date: May 26, 1999
i
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E X H I S I T "A"
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/ ROHRER'S STROMBOLI
application for employment
We are an equal opportunity employer, dedicated to a
policy of non-discrimination in employment on any basis
Including race, color, ape, sex, religion or national nam_
PERSONAL INFORMATION Date: _ 9r Social Security Number:
420
Lest Name:
{ First Name:
Middle Initial: s
Address: L9r Y
ocu ae 1??I Spouse's Name:
City: C/.S State: Zip: I7 /
Home Phone: ?, as7
Daytime Phone: Date of Birth: $':io-7 /
EMPLOYMENT DESIRED Position:
Referred By:
Full Time. Part Time ? Temporary 0 Date You Can Start: Salary Desired:
Shift Desired: / sa Occupational Goal: T?
he ti
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02r
er
icir
Why are you interested in this particular job and hours?
Are You Employed Now? f> D If So May We Contact Your Present Employer?
Have You Ever Applied To This Company Bofore? Where: f
l p When:
Do You Have Any Friends or Relatives Working For This Company? 0 If So, Please Name:
Have You Ever Been Convicted of a Crime? n b If Yes, please explain.
EDUCATION Name and Location of School Circle Last Year Did You Graduate? Subject Studied/Degree
Completed
High School
, 9 10 11 Q 'Er-YES O NO
College IiA , Z d q „^ (J 2 3 4 EI-YES ? NO 6"ern Mn?1. e.«
Trade/Bus School - 1 2 3 4 O YES ONO
FORMER EMPLOYERS List below your last four Employers, Starting with the Current or Last one First
Dates - Month and Year Name, Address/Phone of Employer Salary Position Reason For Leaving
From To
-
From To
From To
From To
REFERENCES List below the Names of Three Persons not related to you, whom you have known at least three years.
Name
RA\ Address Daytime Phone Years Acquainted
sr_? e. cr' v ocr. 3$ (.s/9 010
{.or' Qorn[
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In case of Emergency Notify: fr,e sr} 1-Nen C ` Phone: S3?-? SS 7
1 authorize investigation of all statements contained in this application. I understand that misrepresentation or omission of
facts called for is cause for dismissal. Further, I understand and agree that my employment is for no definite period and may
,
regardless of the date of payment of my wages and salary, be terminated at an time without any previous notice.
Data: _ Signature: ?/•,j/
OFFICE USE ONLY Hired? OYES ONO Position Start Date Wage
Comments: .N?
C?1Srn
0 w% Interviewed By:.41
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EDUCATION: Ploase PRINT CLEARLY
a..oulu nrgnest graue completea: 6 7 6 9 10 tI J 12 College 1 2 3 4 5 6 Technical 1 2 3 4 GED? Oye
Name, CI ,Slate:
H, hSChooR
completea?
Malor/Minor: s O
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ploma/CeNfirate/Degrea:
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College or Trade; _
College or Trade:
OrIT OP/T dD-ays ZEvenings Check days you can work:
Are you available for same day assignments? Ayes ONo
Please check areas you can work in:
M IAT ®1N E1Th .OF US rdSu Shift4ls' 02nd f
I am available to work from AM/PM to - 1. AM/:
OCadisle ODowntown Harrisburg ??OEast Shore OHarrisburg OHershey OPerry Co. w9s"t Sh.
Do you have reliable transportation available to you?efYes ONO If so, the transportation you Intend to use is:
wn car OFriend/Relative's car OBus route OBicycle OWalking OTaxi
How soon can you begin? _tLI ?j May we call you at night (after 9 PM40r in the morning (before 8 AMW</eekend;
If you are an applicant seeking a full-time position, would you consider temporary work0 or a temp-to-hire position0?
MISCELLANEOUS: Please PRINT CLEARLY.
Tax information: Warded mangle OExempt 9 of Dependants, Township/Municipality'you pay taxes to: 4=6421
How did you hear about us? Ad OSmoker ONon-Smoker OWill A
OYes l1J0 Is there any type of work which your physical or mental condition prohibits, even with special effort by you or
accommodation? If yes, please explain:
OYes fdtJo
Oyes 6-No
Have you ever pleaded guilty to or been convicted of any crime other than a traffic offense? If yes, explain in full, c
of conviction and the offense. Please note: criminal convictions are not necessarily an automatic disqualification o
employment; all relevant circumstances will be considered.
Have you worked for Keystone before? If so, when?
Are you fluent in any recognized language other than English? If so, what?
Are
ou cur
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Have you ever had a security clearance? OYes ONo Do you have a current resume?
Are you a Notary of Public? Oyes S 0 Are you in high school?
Oo you have a valid driver's license? O'Pes ONo Are you in college?
Are you bonded? Oyes Emo Are you a full-time student?
Ara YOU a VS. citizen? .@Yes ONO Are you a part-time student?
Please list three areas of employment opportunities you are looking for
OSpeak ORead OY
`SYes 0No
Oyes 5No
Oyes '9No
Oyes bNo
Oyes `9Wo
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Comments on' Sen
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•.aa nvuw grvem U Yes ONO oN/A
If so, how much? ^
y , more comments:(,-/what applies
e Peso
naomed _ Ambitlqus
FCasual/neat
neat - E nergetic
untidy -Outgoing
onal ,_ Pleasant
riate _ Relaxed
-Humorous
ative _ Shortrrude
Comm
i
Was notice given? p Yes O No
Ifl s.-G much?
O N/A
_ m
atlon• ftoonsivena•s
-Articulate _ Enthusiastic
_ Easy to talk to _ Assertive
_ Speaks slowly _ Inquisitive
-Hesitant Contributes
-Poor Grammar -Reserved
V - Indistinct _ Needs Prompted
-Inappropriate -Indecisive
_ Overly talkative _ Vague
_ Soft spoken Nervous
Was notice given? O Yes O No
If so, how much?
rlt
??!
`-'v''r????
O N/A -Speaks rapidly _ Indifferent
- Loud Candid
_ un a scale of 011 (4 = best), please rate:
Appearance _-
Personality
Attitude --
Aggressiveness
Maturity
--
as notice given? 0 Yes ONO
)N/A Ability to answer questions
Knowledge of Job
Knowledge of industry
i
......1..•:-Pt-1..... V_} ............. jr/
noen70Yes ONO ON/A •••••- . ...................
how w muc much?
Special comments:
n
1 Reference Questions
Please answer the following by stating the names
previous employers as well as the contact information of th,
to speak with regarding your reference. Note: the refere
someone other than the person you listed.
1) Company name/phone number
and phone numbers of
preferred individuals w
0
Name/position of individual giving reference: S, P,1.1 Nr) I __4Z
2) Company name/phone number: ?, , Iq n al ,1 L? S? (S1 y? ?- r19?y
Name/position of individual giving reference: ! IAgr a?,r,b C?cr- re am.N ?G?
Any or all of the following questions may be asked of your former employer(s) as
a condition of being considered for- ,work assignments through Keystone Staffing
Services, Inc.
Name of person giving reference. Z
• How long was applicant employed there? ?^p ?y
• When was applicant hired? UU
• When/why did applicant leave?
• What was applicant's position/salary?
• Did you work with the applicant directly?
• Was applicant usually on time?
• How was applicant's attendance?
• What were applicant's duties???t%4 LCZ/y?(2?ct C
• Did applicant's personal life interfere with work?
r?
• Did applicant cooperate with supervisors/co-workers?
• Did applicant take work home very often?
• What was applicant's quality of work?
• Would you rehire applicant?
" I authorize Keystone Staffing Services, Inc. to obtain information concerning me from
former employers and other persons that may be contacted as references and
furthermore release all concerned from any liability in connection therewith."
X
Applicant Signature
Date
eystone Staffing Services, Inc. cQ
360 Market Street, Lemoyne, PA 17043 (717) 761-1860 Fax (717) 761-5459
so We can't spell S CCESS without U! cal
Keystone Staffing Services, Inc.
Temporary/Full-time Placement Aareement and Contra t
The Supreme Court of the United States on Personnel Consultants:
?he service rendered in acting as the paid representative of another to find a position in which to earn an honest living is useful,
commendable and in great demand." 244 U.S. 500, 61 L ed 1335
!'ALL PLACEMENT FEES,ARE.PAIO EiY`T1iE.CL1ENT CO{VIFANtES'-'NOT: THE. APPLICANT,.
• I hereby warrant that Information given to Keystone Staffing Services, Inc. concerning my employment background, education,
health, and personal life Is true and complete to the best of my knowledge and is given for the purpose of inducing Keystone
Staffing Services, Inc. to assist me to secure employment. In addition, I certify that the information in my resume is the full truth in Its
entirety and furthermore, I grant Keystone Staffing Services, Inc. permission to submit it to prospective employers. I agree that if I
am employed and it is found to be false in any way, I may be subject to dismissal. I further agree that if employed, I will work
faithfully and diligently, and I will report to work promptly as assigned and I will work safely. I understand that employment as a
temporary worker with Keystone Staffing Services, Inc. does not guarantee regular, full-time employment and that I am an
employee at will
• 1 understand that not notifying Keystone about the completion of an assignment, not completing a scheduled assignment or
otherwise not fulfilling the stated assignment, may result in my voluntary resignation from Keystone. Moreover, it is understood that
my earned wages may be rolled back to the federal minimum wage in the event I walk off an assignment without sufficient prior
notification to Keystone Staffing Services, Inc. I agree that I shall not use or be under the influence of alcohol or any narcotic while
on assignment for Keystone, nor will I possess any such controlled substance while on Keystone and/or client company premises.
• I agree that I shall comply with and abide by all confidentiality clauses provided to me by Keystone, Keystone's client
companies and any and all potential employers introduced to me through Keystone Staffing Services, Inc. It is understood that I will
not at any time divulge documents, secured information, and industry (trade) secrets to non-applicable personnel or to any
competitor. It is further understood that breaching this confidence may result in reprimand and/or termination.
• No guarantee or representation of employment for any length of duration is made through this application process, it being
expressly understood that any employment hereunder may be as an intermittent temporary assignable to companies as a contract
temporary employee with the exception of full-time placement. If an employment relationship is established, I understand that my
employment will be "at will; that I will have the right to terminate my employment at any time provided that the required notice is
given, and that Keystone Staffing Services, Inc. will retaill, a similar right to terminate my employment at any time with or without
cause.
1. I authorize Keystone Staffing Services, Inc. to assist me in obtaining employment.
2. 1 am not obligated to accept any employment to which Keystone Staffing Services, Inc. suggests or refers me.
3. The term "accept" as used in this contract when obtaining full-time employment shall be construed to mean agreement
verbally or otherwise by me with the employer to begin work on a specific date, having reached a definite agreement
concerning salary and duties.
4. 1 agree to keep all Information concerning employment opportunities received from Keystone Staffing Services,
inc. strictly confidential and for my exclusive use and benefit and to report Immediately to Keystone Staffing
Services, Inc. the results of any Interview arranged by them as well as any and all follow-up communications
between the potential employer and myself.
5. 1 understand that Keystone Staffing Services, Inc. does not guarantee to arrange Interviews or to find me employment nor
does it guarantee the permanence, payment of salary, or suitability of working conditions of any full-time employment that
I may accept.
6. Staffing coordinators are not authorized to arrange or become party to contracts between employers and employee
clients, or to enter into any agreement contrary to the terms of this contract without approval of the President of Keystone
Staffing Services, Inc.
7. TERMS. Full service charge to be paid by client company upon your acceptance and subsequent arrival at said position.
8. Gross yearly earnings include salary, drawing accounts, commissions, bonuses, etc. In the event gross yearly earnings
are based upon commissions, in whole or in part, the same fee schedule shall apply and the parties shall agree upon a
reasonable estimate of earnings when obtaining full-time employment.
I acknowledge that I have read and understand this contract/agreement and concur with the stipulations and provisions
stated by Keystone Staffing Services, Inc. Moreover, I am in agreement with the mandatory terms for assistance by Keystone
Staffing Services, Inc. in any and all phases of my employment search and any consequent employment.
X `6(.U,,L.
Applicant Signature of Acknowledgment Date
Keystone Repro. dove's Signa ure / Oate i
J
In accordance mth Federal, State and Local laws, it is Keystone's polity to extend professional service to all qualified employed and unemployed i
applicants regardless of race, color, creed, sex, age, religion, national origin, ancestry, income level or non-job related handicap, !
eyst®ne Staffing Services, Inc. cQ
360 Market Street, Lemoyne, PA 17043 (717)761-5860 Fax (717)761-5459
Pre-Applicati®n 'Questionnaire
Are you phone accessible?
Do you have reliable transportation?
Do you have two valid forms of 1-9 information with you?
(Example: driver's license and social security card)
Yes ? No
l0/Yes 0 No
m Yes ? No
What geographical areas are you willing to work in? Please circle areas.
East Shore
Harrisburg ershey
Carlisle Perry County
What hourly pay rate are you willing to accept?
Are you willing to submit to Drug/Alcohol screening in
accordance with the hiring policies outlined by Keystone?
Are you willing to release your background history including
your criminal records, if applicable?
him 1<?QUe? q-30
Applicant signature ?„-
d 'Yes ? No
ZYes ? No
,so We can't spell S CCESS without U.r rat
11 KEYSTONE STAFFING SERVICES
INC.,
V.
IFS LIMITED/ROHRER'S
STROMBOLI,
Defendant
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-2905
CIVIL ACTION-LAW
II CERTIFICATE OF SERVICE
I, Paige Macdonald-Matthes, Esquire, do hereby certify
that a true and correct copy of the Defendant's Answer to
Plaintiff's Complaint, together with New Matter in the above-
captioned matter was placed in the United States Mail,
certified return receipt delivery, postage prepaid in
Harrisburg, Pennsylvania on May 27, 1999, on the following:
Richard E. Guida, Esquire
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
(Attorneys for Plaintiff'
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: May 27, 1999 By: LLa ??E ?? r.r.?? _ r?'.JV1aSSl•.a7
Paige Macdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
(Attorneys for Defendant)
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//?G? QN •SJ/7?r?//>? J '? U/ unnTThe Court of Common Pleas of
Cumberland County, Pennsylvania
ms `s L??n? <-??? i vo.?, 9G,? 19-
OATH 4/
Tie do solemnly swear (or affirm) that we will support, obey and defend
the Constitution of the United States and the Con n of this Common-
wealth and that we will discharge the duties oo o?7f r w? th fidelity.
0.
AWARD
We, the undersigned arbitrators, having been duly appointed and sworn
(or affirmed), make the following award:
(Note: If damages for delay are awarded, they shall be
separately stated.) / 4 / J
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na
me if
. Arbitrator, W-,
applicable.) /y
Date of Hearing:/ / ?//7? / ?,,?
Date of award: l'L
l Li. ?
NOTICE OF ENTRY OF AWARD
Now, the.2/ S+day of CC--115 19at (?jL,
award was entered upon the docket and notice thereof given by mail
parties or their attorneys.
Arbitrators` compensation to be
paid upon appeal:
the above
to the
-- ? _ 'rothonot
By: C-
Dep tv
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KEYSTONE STAFFING SERVICES,
INC.
Plaintiff
VS
IF SERVICES, LTD.
ROHRER'S STROMBOLI
Defendant
To Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-2905
Please enter judgment in favor of plaintiff and against
defendants in the amount of $5,236.40 plus interest and costs.
Date: December 21, 1999
Respectfully submitted,
Richard E. Guida
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
717-236-6440
Identification #62405
Attorney for Plaintiff
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KEYSTONE STAFFING SERVICES,
INC.
vs
IF Services, Ltd
Rohrer's Stromboli
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA.
CIVIL ACTION - LAW
NO. 99-2905
NOTICE OF ENTRY OF JUDGMENT
Notice is hereby given that a judgment in the above-captioned
?ter has been entered against you in the amount of $5,236.40
1 )C C. 0 a , 1999.
Copies of all documents filed with the Prothonotary in support of
the within judgment are enclosed.
Potho/n/o//tary
By.
/J rJ 0A
If you have any questions regarding this Notice, please contact
the filing party:
Richard E. Guida, Esquire
503 North Front Street
Harrisburg, PA 17101
717-236-6440
This Notice is given in accordance with Pa.R.C.P. 236.
NOTICE SENT TO:
IF Services Ltd.
Rohrer's Stromboli
C/o Paige MacDonald-Matthes, Esquire
PO Box 60457
Harrisburg, PA 17106-0457