The URL can be used to link to this page

Home My WebLink About99-07580E LAWrFIRM OF N GEPHART Ie PING 6MgCT - {, CE RTI FI ED'COPY P O eox eee 'ENNSYLVANIA 17108.0886` - SIGNAL GRAPHICS PRINTING Plaintiff V. IKON OFFICE SOLUTIONS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 49 - *7T?6 TO: THE PROTHONOTARY OF SAH) COURT PRAECIPE WRIT OF SUMMONS Kindly issue a Writ of Summons in favor of Plaintiff, Signal Graphics Printing, and against Defendant, IKON Office Solutions, 6360 Flank Drive, Harrisburg, PA 17112. Respectfully submitted, KILLIAN & GEPHART Dated: December 16, 1999 Paula J. McDermott, Esquire Attorney I.D. #46664 218 Pine Street P. 0. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 cl, C _ Commonwealth of Pennsylvania County of Cumberland Signal Graphics Printing VD. Ikon Office Solutions 6360 Flank Drive Harrisburg, PA 17112 Court of Common Pleas No. _____99_7580_Ci_v_il_Tertn --------- 19 In _____ Civil_ Action --Law - ------------------------------ To -Ikon Oj:iCQ_ S.41AX.t4nS.------------------ You are hereby notified that .----Signal- Graphics- PriELinq .......-_ the Plaintiff has commenced an action in ___C3Y_UACk.LQO__J,avL against you which you are required to defend or a default judgment may be entered against you. (SEAL) Curtis R. Iong °----------------------------------------------- Prothonotary Date ----- EenM gr 20i ----------- 19-99 ?g - D- eputy I C i rll ? ? W N of i m; G)1 { i i t W ro m G ° t a r r-I ? r Ol rl r-i c9ia w? O W m Y M (C I--I ?O S .p O L CO w 10 0 J41 r?r-I V S aria 4J 110 vnW i NM 00 w h G kk A tv? roarA •H N" r?M6 rc aNa;??1-=1 a t SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-07580 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SIGNAL GRAPHICS PRINTING VS IKON OFFICE SOLUTIONS R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: IKON OFFICE SOLUTIONS but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within WRIT OF SUMMONS On January 11th , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 8.00 DEP. DAUPHIN CO 30.50 .00 65.50 01/11/2000 KILLIAN & GEPHART So an ers:i y _ W., Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this ..LB day of A.D. Q )e4 Low' Prothonotary (pffice of the *4priff Mir% Jane Snyder Rcul Estate DclX11e William T. Tully Solicitor Dauphin Counq' Harrisburg. PennsN.hnnia 17101 ph: (717) 255.26611 too: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania SIGNAL GRAPHICS PRINTING vs County of Dauphin IKON OFFICE SOLUTIONS Sheriff's Return Ralph G. NtIcAlli,ter Chicr Ikputy Michael W. Rinehart Assistant Chier Ikpuq No. 2582-T - - -1999 OTHER COUNTY NO- 99-7580 AND NOW: December 23, 1999 at 12:25PM served the within SUMMONS IN CIVIL ACTION upon IKON OFFICE SOLUTIONS by personally handing to PETE FOLLEY-MKT VP 1 true attested copy(ies) of the original SUMMONS IN CIVIL ACTION and making known to him/her the contents thereof at 6360 FLANK DRIVE HARRISBURG, PA 17112-0000 Sworn and subscribed to before me this 29TH day of DECEMBER, 1999 PROTHONOTARY So Answers, zAlc- t? ?Sher i-f£ of Dauphin County, Pa. By `1V Deputy Sheriff Sheriff's Costs: $30.50 PD 12/23/1999 RCPT NO 131595 DK/WC In The Court of Common Pleas of Cumberland County, Pennsylvania Signal Graphics Printing VS. Ikon office.Solutions No. 99-7580 Civil Now, 12/21/99 -,19_,I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA COSTS Sworn and subscribed before SERVICE $ me this _ day of , 19 _ MILEAGE AFFIDAVIT S 19_, at o'clock M. served the SIGNAL GRAPHICS PRINTING : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99-7580 IKON OFFICE SOLUTIONS Defendant : CIVIL TERM ORDER OF COURT AND NOW, this 6'` day of June, 2000, IT IS HEREBY ORDERED AND 41?rCya) DECREED that Defendant shall answer Plaintiff's interrogatories within ten-(-19) days of the date of service of this Order or suffer appropriate sanctions. By The Court: i 10-9-Oo 10 ti ? ? U`"1 R ? ?' .? z . '+=. O i? ?.? -fi=r ii , ?) r .? n ` rjPCr 2 `j Q S C1 ?, ``I/?? ...: ,o?.n..?.? {'-I?. _. SIGNAL GRAPHICS PRINTING : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99-7580 IKON OFFICE SOLUTIONS Defendant : CIVIL TERM MOTION TO COMPEL AND NOW, comes Plaintiff, Signal Graphics Printing, by and through its attorneys, Killian & Gephart, and in support of this Motion To Compel avers the following: 1. Plaintiff filed a Writ of Summons in the above-captioned matter on December 20, 1999. 2. The Sheriff served the Writ of Summons on Defendant on December 29, 1999. 3. On December 22, 1999, Plaintiff's interrogatories in aid of filing a complaint were served on Defendant's attorney, Michael Walsh, Esquire at 70 Valley Stream Parkway, Malvem, Pennsylvania 19355. 4. Attorney Michael Walsh has never asked for an extension of time or responded to the interrogatories. Y 1 i 5. Defendant should be required to respond to the interrogatories, copies of which are attached hereto as Exhibit "A". 6. Defendant's counsel does not concur in this Motion To Compel. WHEREFORE, Plaintiff respectfully requests this Honorable Court to sign the Order in the form attached requiring Defendants to answer the interrogatories attached hereto as Exhibit "A" or suffer appropriate sanctions. Respectfully submitted, KILLIAN & GEPHART Dated: May 31, 2000 p cam... D, ?W Paula J. M ermott, Esquire Attorney I.D. #46664 218 Pine Street P.O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 r u' 'uSra _-41 ' ? SIGNAL GRAPHICS PRINTING : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-7580 IKON OFFICE SOLUTIONS Defendant : CIVIL TERM TO: Mr. Peter Foley IKON Office Solutions 6360 Flank Drive Harrisburg, PA 17112 NOTICE These Interrogatories are to assist in the preparation of a Complaint which will be filed by the above-captioned Plaintiff against IKON Office Solutions. These Interrogatories are to be . answered within thirty (30) days of today's date. Dated: December 22, 1999 Respectfully submitted, KILLIAN & GEPHART Paula J. M ermott, Esquire Attorney I.D. #46664 218 Pine Street P.O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 EXHIBIT "A" ?f r ? :e, maintenance and repair records maintained by IKON E'. gnal Graphics Printing. ...A- , . 2. State the identities of any and all employees of IKON Office Solutions who have performed service, maintenance or repairs at Plaintiff's place of business. ANSWER: 3. Identify any and all records which IKON Office Solutions, or any of its agents or employees has which relate to IKON Office Solution's contract with Signal Graphics Printing. As to such documents, state: (a) the date of the document; (b) the author of the document; (c) describe the contents of the document; and (d) the custodian of the file. ANSWER: 4. As to IKON Office Solutions, state the employee who supervises service work on the Signal Graphics Printing account. ANSWER: I 5. As to such supervisory employee, state the employee's name, position and years of service with IKON Office Solutions. ANSWER: ..'V. . 6. As to the Model CLC 700 leased by IKON Office Solutions to Signal Graphics Printing, state the number of such copiers your company has leased to other companies, and identify the companies. ANSWER: .wP- ? 7. Describe any and all documents or other records, including electronic mail and files possessed by you and your agents, of communications by and about the Model CLC 700 which you lease to Signal Graphics Printing between IKON Office Solutions and Signal Graphics Printing. ANSWER: II.-- I .. 8. Copy any and all documents referenced in any answers to these Interrogatories to avoid the formal request for production of same documents. ANSWER: 9. As to service performed on Signal Graphics Printing's copier, state the amount of time in which you are aware that the copier was inoperable or not functioning properly. ANSWER: .w- 10. Describe any and all manuals, protocols and company documents pertaining to the repair and maintenance of the copier that you have leased to Signal Graphics Printing. r C7 i ANSWER: - .. 11. Disclose any and all manuals or protocals Nvhich your company has relating to maintenance and repair services it offers its clients. ANSWER: 12. Describe any and all documents transmitted between your company and Canon relating to service and repair of the Canon copiers. ANSWER: 13. Identify any and all communication in your files, or those of any of your agents or employees, not privileged, relating to Signal Graphics Printing. ANSWER: Respectfully submitted, KILLIAN & GEPHART Dated: December 22, 1999 p? ? • 11 i &'att Paula J. McDermott, Esquire Attorney I.D. 946664 218 Pine Street P.O. Box 886 Harrisburg, PA 17108-0886 (717)232-1851 CERTIFICATE OF SERVICE On this 22nd day of December, 1999, I hereby certify that I served the foregoing document on the following by depositing a true and correct copy in the United States Mail, postage prepaid, addressed to: Mr. Peter Foley IKON Office Solutions 6360 Flank Drive Harrisburg, PA 17112 Michael Walsh, Esquire 70 Valley Stream Parkway Malvern, PA 19355 (courtesy copy) KILLIAN & GEPHART Paula J. McDermott, Esquire Attorney I.D. #46664 218 Pine Street P. 0. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 CERTIFICATE OF SERVICE On this 31" day of May, 2000, 1 hereby certify that I served the foregoing document on the following by depositing a true and correct copy in the United States Mail, postage prepaid, addressed to: Michael Walsh, Esquire 70 Valley Stream Parkway Malvern, PA 19355 KILLIAN & GEPHART Pa. a. tt'L Paula J. Mc ermott, Esquire Attorney I.D. #46664 218 Pine Street P. O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 i+ Cif 7 l 1 t f l If C o ? v U --1..0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SIGNAL GRAPHICS PRINTING Plaintiff V. IKON OFFICE SOLUTIONS Defendant NO. 99-7580 Civil Action - Law PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for Defendant "IKON Office Solutions" in the above-captioned case. ?_D" Z? Dino .C Ross Attorney I.D. 44746 John P. Neblett Attorney I.D. #8003 Reed Smith Shaw & 213 Market Street, 9' P.O. Box 11844 Harrisburg, PA 17K (717) 257-3047 4 CEIRTIFICATF OF SERVICE I, Dino A. Ross hereby certify that I have this 2816 day of June, 2000 served a true and correct copy of the within Praccipe for Entry of Appearance, first class mail postage pre- paid, addressed as follows: Paula J. McDermott, Esquire 218 Pine Street P.O. Box 886 Harrisburg, PA 17108-0886 J n A?-? Dino A. Ross -M: vo4n. T _,_ ___ ,: ,. j I I :, I? a :? i 'r 17 cr i =' C . J C 1 r . , ( i '.- C. ?J ? i _ Ut c1J C` = s ? I ?:. "J ?. :_ ?? i II 1 i c: c: U I' f i {' 1! L' rv ? I Jo `'1 PRAECIPE, Kindly mark the above-captioned matter discontinued and satisfied with prejudice. Respectfully submitted, SIGNAL GRAPHICS PRINTING Plaintiff V. IKON OFFICE SOLUTIONS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 99-7580 CIVIL'TERM TO: THE PROTHONOTARY OF SAIU COURT Dated: January 31, 2001 KIL.LIAN & GEI'IIART Paula J. McDermott, Esquire Attorney I,D. 1146664 218 Pine Street P.O. Box 886 Harrisburg, PA 17108-0886 (717)232-1851 CERTIFICATE OF SERVICE On this 31" day of January, 2001, I hereby certify that I served the foregoing document on the following by depositing a true and correct copy in the United States Mail, postage prepaid, addressed to: Michael P. Walsh, Esquire 70 Valley Stream Parkway Malvern, PA 19355 KILLIAN & GEPHART `? .r?* Cr - Paula J. McDermott, Esquire Attorney I.D. 946664 218 Pine Street P. O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 -- >- C` 1 _ Cf_ G -/ :(` s N ? ` ::)q. i i _ • ? ?_i: ?. _! ='7 f-,. ? iv - :`i:'.u `: ?;? ?.. ° U r'i C, V