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LAW OFFICES OF
KNUPP & KODAK, P.C.
• CAMERON MANSION
407 NORTI/ FRONT S"IREF.-I
P.O. BOX 11845
IIARRISRUR(:, PA 171011.1848
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SIMPSON TACOMA KRAFT COMPANY
Plaintiff
V.
STEPHEN R. ZENTMEYER Individually
and Trading As ZENTMEYER PAPER SALES
COMPANY
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9l.73j GGIftiC
CIVIL DIVISION - LAW
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH
IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS
COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR
BY AN 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 MI PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE. .O TO OR TELEPHONE TH . OFFICE ET FORTH BELOW TO FIND OUT
WHERE YOU CANT LEGAL HELP,
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
SIMPSON TACOMA KRAFT COMPANY
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
. NO.
STEPHEN R. ZENTMEYER Individually : CIVIL DIVISION -LAW
and Trading As ZENTMEYER PAPER SALES :
COMPANY
Defendant
COMPLAINT
The Plaintiff, SIMPSON TACOMA KRAFT COMPANY, by its attorneys, KNUPP, KODAK &
IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of THIRTY-
FOUR THOUSAND, EIGHT HUNDRED AND FIFTY-FOUR DOLLARS AND FORTY-NINE CENTS
($34,854.49), along with costs of this suit and interest thereon at the rate of ten percent (10%) per annum
from November 18, 1998 upon a cause of action of which the following is a statement:
The Plaintiff, SIMPSON TACOMA KRAFT COMPANY, is a corporation organized and
existing under the laws of the State of Washington, having its principal office and place of business at Post
Office Box 2133, Tacoma Washington 98401.
2. The Defendant, STEPHEN R. ZENTMEYER is an adult individual, trading and doing
business as ZENTMEYER PAPER SALES COMPANY and has an office and place of business at 613
Somerset Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the
Plaintiff's Invoices hereto attached, made a part hereof and marked Exhibit "A", Plaintiff, at the special
F:\USER\KATHY\CMPLAINT\25107
instance and request of the Defendant, sold and delivered goods, wares and merchandise of the kind and
description set forth on said Exhibit to the total amount of SIXTY-SEVEN THOUSAND, FIVE
HUNDRED AND THIRTY-SEVEN DOLLARS AND SIXTY-ONE CENTS ($67,537.61).
4. The prices charged for said goods, wares and merchandise were just and reasonable, were
the legal and market prices therefor and were the prices which the Defendant promised and agreed to pay
Plaintiff as set forth in a true and correct copy of the Defendant's fax transmittal hereto attached, made
a part hereof and marked Exhibit "B".
5. The Defendant paid to Plaintiff on account of the aforementioned charges certain sums of
money as more particularly set forth on Exhibit "C" attached hereto and made a part hereof, in the total
amount of THIRTY-TWO THOUSAND, SIX HUNDRED AND EIGHTY-THREE DOLLARS AND
TWELVE CENTS ($32,683.12).
6. The balance due and owing by Defendant to Plaintiff is the sum of THIRTY-FOUR
THOUSAND, EIGHT HUNDRED AND FIFTY-FOUR DOLLARS AND FORTY-NINE CENTS
($34,854.49), as appears by the Statement of Account hereto attached, made a part hereof and marked as
Exhibit "C".
7. Plaintiff has frequently demanded payment from Defendant of said amount due and owing
as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount
of any part thereof.
F:\USER\KATHY\CMPLAINT\25107. 2
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of THIRTY-FOUR
THOUSAND, EIGHT HUNDRED AND FIFTY-FOUR DOLLARS AND FORTY-NINE CENTS
($34,854.49), along with costs of this suit and interest thereon at the rate of ten percent (10%) per annum
from November 18, 1998.
Respectfully submitted,
KNUPP, KODAK & IMBLUM, P.C.
Robert D. Kodak
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney ID No. 18041
Attorney for Plaintiff
F:\USER\KATHY\CMPLAINT\25107
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ZEPAC
ZENTMEYER PAPER SALES COMPANY
613 Somerset Drive
Mechanicsburg, PA 17055
Phone/.Fax (717) 697-7838
FAX TRANSMMAL
Date: December 8, 1997
To: I& Dick Gallagher
Simpson Paper Co.
Number of Pages Including This One: 1
Deaf Dick:
I have reviewed my account with Simpson and I have a total of 3 and a partial,
outstanding invoices, which make up the 557,537.61.
Involve 051101 $17,683.12 April 02, 1996 p
Invoice 051100 517,034.30 April 02, 1996 p00 1 033
Involoe 051598 $16,207.42 April 23, 1996
Invoioe 051849 $16,612.77 April 30, 1996
Minus the $10,000.
As you know the best laid plans can go in the tank much quicker than anyone can know,
but I am committed to paying this bill off.
I have an appointment with my bank to get a home equity loan to raise the necessary funds
to pay of Simpson. I,the mean time I'm sending you an additional 57,683.12 which will
completely retire Invoice 051101.
Since I am finally back on the job I owe you the courtesy of a call which I plan to do later
this aRemoon (my time) to discuss this Sather.
Best Regards,
:t ,IT B
SIMPSON TACOMA KRAFT COMPANY
Statement of Account for Zentmeyer Sales, Stephen
Account Number 30000-100313
Date Activity Debit Credit Balance
4/2/96 Invoice #051101 $17,683.12 $17,683.12
4/2/96 Invoice #051100 $17,034.30 $34,717.42
4/23/96 Invoice #051598 $16,207.42 $84,387.61
4/30/96 Invoice #051849 $16,612.77 $51,330.19
11/17/96 Invoice #044395 $16,074.00 $67,404.19
12/8/96 Invoice #045056 $16,469.60 $83,873.79
2/24/97 Invoice #050172 $16,850.00 $84,254.19
2/26/97 Payment invoice #045056 $16,469.60 $67,784.59
4/7/97 Payment invoice #044395 $16,074.00 $68,180.19
4/29/97 Payment invoice #050172 $16,850.00 $67,537.61
10/14/97 Partial payemnt $10,000.00 $57,537.61
12/15/97 Partial payemnt $7,683.12 $49,854.49
11/18198 Partial payemnt $15,000.00 $34,854.49
EXHIBIT
-' TO PHONE NO. : 12062245220
FROM : JUN. 9. 1999 1:43PM P 2
JN 08 199 63;16W
lv
Y"LLJ C A T 10
P16
I, - ep`-) -t-'A. - t • d????i? !%!t?JZ% ???U'?, of SIMPSON TACOMA KRAFT
COMPANY, verify that the statmneon rapde in the store8oing document ere true and correct. I
understand that fobs statements herein are made suhjact to the penalties of 18 Pa. C. S. 14904, relating
to unsworn falsification to authorities.
S?M?iPSON TACOMA KRAFT COMPANY
By:
Title: .?r112 P? r 2
Datod:... yalila
F:\USEH\KAIHY\rMVLAINtt1610
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04739 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SIMPSON TACOMA KRAFT CO
VS.
ZENTMEYER STEPHEN R ET AL
CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT was served
upon ZENTMEYER STEPHEN R the
defendant, at 20:10 HOURS, on the 10th day of August
1999 at 613 SOMERSET DRIVE
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to DEBRA ZENTMEYER (WIFE)
a true and attested copy of the COMPLAINT
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 6.20
Affidavit .00
Surcharge 8.00 1?1 omas ine, 5 eriTz-
$32-Z0-KNUPP, KODAK & IMBLUM
08/11/1999
,r
by
epu y er
Sworn and subscribed to before me
this // ? day of
19_yg_ A.D.?? y
ro ont z o arN 7-
CASE NO: 1999-04739 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SIMPSON TACOMA KRAFT CO
VS.
ZENTMEYER STEPHEN R ET AL
CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT _ was served
upon ZENTMEYER STEPHEN T/A ZENTMEYER PAPER SALES COMPANY the
defendant, at 20:10 HOURS, on the 10th day of August
1999 at 613 SOMERSET DRIVE
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to DEBRA ZENTMEYER (WIFE)
a true and attested copy of the COMPLAINT
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
6.00 ?i
.00
.00
8.00 r r Momas (Cline, s neriff
$j-4?uu I( PP, KODAK & IMBLUM
08/1171999
by
Sworn and subscribed to before me
this _(J 6r- day of
19 n? A.D.
-/-'-F'ro ono r
pu y e
SIMPSON TACOMA KRAFT CO.
Plaintiff
V.
STEPHEN R. ZENTMEYER Ind. and
t/a ZENTMEYER PAPERS SALES CO.
Defendant
In the Court of COMMON PLEAS of
CUMBERLAND County
NO. 99-4739 CIVIL
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned matter as settled and discontinued with out
prejudice.
TO Cumberland County
1
Prothonotary
Dated: September 17. 1999 ?.
Robert D. Kodak Attorney for Plaintiff
Attorney I.D. No. 18041
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