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Home My WebLink About99-0761708/01/2000 15:12 7172495755 OBS LAW OFFICE PAGE 02 SENT 9y: AMATO AND WOLE, P.C.; 610 BOB 9155; AUO.1.00 11:38AL1; PAGE 111 - LAW OFFICES OF RONALD AJMTOt AMATO AND MARGLRS P.C. MICIIA?LL 1. IMNLYt'1 SUITE 100. COMMERCE SQUARE DAMPS). NARLCSY.YT 107 NORTH COMMERCE WAY RRISTOPHER T. SMULLI i BETIALl3HEM, PA 18017.8930 OV 011NSEL. TELEPHONE (610) 1166-0400 JEPFRSY H. LGVItI FACSIMILE (610) 0669155 ALI)N(l" MArunc r.a.rarAOr.IIAh.+..MI...1[K O,h .M. A. 1111 MApk I .I.Y: (IMI NiKnl O.MJ Almw . rA Illm M.,µ Y,M M.u (AM )MIAU ANDY 41-11JI: NW/.e.A?.l.w,(gll I FORWARDED VIA REGULAR MAIL AND FACSIMILE TO 1717) 701.3016 i August 1, 2000 ! Horace A. Johnson, Esquire _ Johnson. Duffy, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 Re: STANLEY WORKS V. MASTER MANUFACTURING INDUSTRIES INC. dolno business as M & M INDUSTRIES Coutt of Common Plus of Cumberland County Civil Aatbn No.: 98.7817 Our File #: 993272 Deer Mr. Berle: Please be advised that the parties have agreed for the voluntary entry of judgment by the Board of Arbitrators at the trial scheduled for tomorrow, August 2, 2000 at 10:00 em. Judgment Is to be entered in favor of the Plaintiff for $10,291.01 plus costs. Neither myself, as counsel for the Plaintiff not David Berlc, counsel for the Defendant, will be appearing tomorrow. It is understood the Defendant reservea its ri9htto appeal tha Board's determination ? in favor of the Plaintiff very truly yours, AMATO AND MAR .C. By: Ronald Amaro ? rtUt adaron I" cc: AGREED TO AND AC ED n AUO t+ 00 i David A. Boric, Esquire O'Brien, Boric & Scherer 17 West South Street Carlisle PA 17013 i By Facsimile Only: (7171 249-5755 i IERRY R. DUFFIE RICHARD W. STEWART C. ROY WEIDNER IR EDMUND G. MYERS DAVID W. DELUCE RALPH H. WRIGHT, IR. DAVID I. LA147A MARK C. DUFFIE KEIRSTEN WALSH DAVIDSON MICHAEL 1. CASSIDY LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation 301 MARKET STREET P. O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 WEBSITE: www.idsw.com TELEPHONE 717.761.4540 FACSIMILE 717-761.3015 E-MAIL malloldsw.com August 9, 2000 Jeffrey Yoffe, Esquire 214 Senate Avenue Camp Hill, PA 17011 Re: Arbitration Award Dear Jeffrey: HORACE A. IOHNSON OF COMM FILE COPY Enclosed is the Award in the matter of Stanley Works vs. Master Manufacturing Industries, Inc. This judgment was entered pursuant to the fax of August 1, 2000 from the attorney for the Plaintiff and the Defendant, which I have attached to the Award. Please sign the Oath and the Award and then promptly return this to me. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER Horace A. Johnson HAJ:ijm:137355 Enclosure L: z LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation JERRY R. DUFFIE 301 MARKET STREET RICHARD W. STEWART P. O. BOX 109 C. ROY WEIDNER. JR. LEMOYNE, PENNSYLVANIA 17043.0109 EDMUND O. MYERS WEBSITE: www.jdsw.com DAVID W. DELUCE RALPH H. WRIGHT. JP- DAVID 1. LANZA TELEPHONE 717-761.4540 FACSIMILE 717-761.3015 FILE MARK C. DUFFIE E-MAIL maiIQJdsw.cam KEIRSTEN WALSH DAVIDSON MICHAEL I. CASSIDY August 9, 2000 Jeffrey Yoffe, Esquire 214 Senate Avenue Camp Hill, PA 17011 Re: Arbitration Award Dear Jeffrey: HORACE A JOHNSON OF COUNSEL COPY Enclosed is the Award in the matter of Stanley Works vs. Master Manufacturing Industries, Inc. This judgment was entered pursuant to the fax of August 1, 2000 from the attorney for the Plaintiff and the Defendant, which I have attached to the Award. Please sign the Oath and the Award and then promptly return this to me. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER Horace A. Johnson HAJ:rjm:137355 Enclosure In The Court 'of Common Pleas of fi d/Yl? Cumberland County, Pennsylvania ; No '9 ? ot/ in aW Jag ' VC k OATH lie do solemnly swear (or affirm) that we will support, obey and defend t the Constitution of the United States and the Constitu tioA of this Common- ` wealth and that we will discharge the duties of o f icel-?h lid AWARD Arb itrat applicable.) /1? Date of Hearing: '?""" moo Date of Award: Z Q 4 ZoOU NOTICE OF ENTRY OF :SWARD Now, the day of award was entered upon the docket parties or their attorneys. Arbitrators' compensation to be paid upon appeal: 19_, at ?, .11., the above and notice thereof given by mail to the Prothonotary By: Deputy 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 .----- ---- 4--. 08/01/2000 15:12 7172495755 CBS LAW OFFICE BENT 9Y: AIATO AND MARGLE, P.C.; 810 858 9155; AU3•1.60 11:S8AU; f LAW 0M- CES OF AMATO AND MARGILE, P.C. SUITE 100, COMMERCV SQUARE 107 NORTH COMMERCE WAY BETRUHEM, PA 19017.6930 TELEPHONE (610) 666-0105 FACSIMILE (610 8669115 ALL4100" KARWO P.O. A 1111 MqM /,A,., o+lt 0101 M7.M70 AIIIR .rA 11107 Wryfi VM,. M•0, (41e 71,12a1 MW* a-{411: usrWOurJwpan PLRAtHS 515311`01M TO SEMNLEHOM FORWARDED VIA REGULAR MAIL AND FACSIMILE TO (717) 781.3015 PAGE 02 PAGE 1;1 RONALD AMA70t STANLEY 1 MARGL6. 1111 M CIIAM 1. IMNNCDY1 JAMT,S I. NARLESKYt KRISTOPHER T. SMMLt Or COUNSEL Jar•FRSY H. LUVItt r.M?J rA Odr 11AA.:rn M.+.M M o.y OwrY F,.u,O, wA/uuNltM August 1, 2000 Horace A. Johnson, Esquire Johnson, Duffy, Stewart & Woldner 301 Market Street Lemoyne, PA 17043 Re: STANLEY WORKS V. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES Court of Common Pleas of Cumberland County CIvN Action No.: 99.7017 Our Fite O: 993272 Deer Mr. Boric: Please be advised that the parties have agreed for the voluntary entry of judgment by the Board of Arbitrators at the trial scheduled for tomorrow, August 2, 2000 at 10:00 em. Judgment Is to be entered in favor of the Plaintiff for $10,291.01 plus costs. Neither myself, as counsel for the Plaintiff nor David Boric, Counsel for the Defendant, will be appearing tomorrow. It is understood the Defendant reserves Its rightto appeal the Board's determination in favor of the Plaintiff. Very truly yours, AMATO MAR C. By., Ronald Amara r1V1 adaron cc: AGREED TO AND AC ED Ut3 A 1/00 n David A. Boric, Esquire O'Brian, Boric & Scherer 17 West South Street Carlisle PA 17013 By Facsimile Only: (717) 249-5755 l TERRY P- DUFFIE RICHARD W. STEWART C. ROY WEIDNER. )F EDMUND C. MYERS DAVID W. DELUGE RALPH H. WRIGHT, IR. DAVID I. LANZA MARK C. DUFFIE KEIRSTEN WALSH DAVIDSON MICHAEL I. CASSIDY TELEPHONE 717.761.4540 FACSIMILE 717.761.3015 EMAIL mail®idsw.com August 2, 2000 Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 Re: Arbitration Award Dear Barb: HORACE A IOHN50N OF COUNSEL =ally Enclosed is the Award in the matter of Stanley Works vs. Master Manufacturing Industries, Inc. This judgment was entered pursuant to the fax of August 1, 2000 from the attorney for the Plaintiff and the Defendant, which I have attached to the Award. Please sign the Oath and the Award and then promptly return this to me. Very truly yours, LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporacion 301 MARKET STREET P. O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 WEBSITE: www.idsw.com JOHNSON, DUFFIE, STEWART & WEIDNER Horace A. Johnson HAJ:rjm:137094 Enclosure r , o ) In The Court of Common Pleas of Cumberland County, Pennsylvania ) 0 ) No??/:2 19 79?aa L ?J7 ?? .pvc.?ba ?7QLy.?vs OATH We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the ConstitutioA of this Common- wealth and that we will discharge the duties of , M? f ice th Eideli . AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or.affirmed), make the following award: Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: Z 7.0o0 Chairman Date of Award: Z ?o0u NOTICE OF ENTRY OF AWARD Now, the day of , 19_, at the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: Prothonotary $ By: Deputy (Note: If damages for delay are awarded, they shall be separately stated.) W/01/.?000 15:12 7172495755 OBS LAW OFFICE PAGE 02 SENT BY: AMATO AND MARGLE, P.C.; 810 868 9155; AUG•1.00 11:3846,1; PAGE 1/1 LAW OFFICES OF "ATO AND MARGLE, SUITE 100, COMMERCE SQUARE 107 NORTH COMMERCE WAY BETHI,HHEM, PA 18017.8930 TELEPHONE (610) 86644M FACSIMILE (610) 8669135 ALU41gMN MAK4K A A.., FA IIIJ1 M.ry4 Oi,.r, 1111 141M r "M ,I may V, 11W, (4M Oe HA/ 4rr1. N WN: y.WMu.W...y PLL%U aaastwm To wrli attmH RONALD AMATOt n P.C. WQtAr'LL r. 109NNeoYf It lAIL(RS A NARLESKYT KRISTo. HER T. SMLRLt orVOUNSEL )UPIMY H. Levitt '-O grAoyf 1M iw WW Kay FORWARDED VIA REGULAR MAIL AND FACSIMILE TO 1717) 701.3015 Horace A. Johnson, Esquire Johnson, Duffy, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 Re: STANLEY WORKS V. MASTER MANUFACTURING INDUSTRIES INC. doln9 business as M & M INDUSTRIES Court of Common Pleas of Cumberland County ClvN Action No.: 99.7417 Our File M 993272 Deer Mr. Barle: August 1, 2000 Please be advised that the parties have agreed for the voluntary entry of judgment by the Board of Arbitrators at the trial scheduled for tomorrow, August 2, 2000 at 10:00 am. Judgment Is tO be entered in favor of the Plaintiff for $10,291.01 plus costs. Neither myself, as counsel for the Plaintiff nor David Boric, counsel for the Defendant, will be appearing tomorrow. It is understood the Defendant reserves Its right to appeal the Board's determination in favor of the Plaintiff. r1V1 adaron cc: AGREED TO AND AC ED n AUG t?OO David A. Beric, Enquire O'Brien, Boric & Scherer 17 West South Street Carlisle PA 17013 By Facsimile Only: (7171 249-5755 Very truly yours, AMATO D MAR C. By: Ronald Amato LAW OFFICES OF AMATO AND MARGLE, P.C. SUITE 100, COMMERCE SQUARE 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017-8930 TELEPHONE (610) 866-0400 FACSIMILE (610) 866.9155 ALLCNTOWN MAILING P.O. Roe t i l l Marele Oirw, D.1: (6101 W-9 Allemw-. PA 18103 MarBle Yoke MA: 16101 366.24M M.& EM111: mugkIIawldaw.eom PLEASE RESPOND TO BETHLEHEM FORWARDED VIA REGULAR MAIL AND FACSIMILE TO 1717) 761-3015 Horace A. Johnson, Esquire Johnson, Duffy, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 s?F?o QGC ????F ?999yo ?RI G? yF9 Re: STANLEY WORKS V. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES Court of Common Pleas of Cumberland County Civil Action No.: 99-7617 Our File #: 993272 Dear Mr. Baric: RONALD AMATOt STANLEY J. MARGLE, flit MICHAEL I. KENNEDYt JAMES 1. NARLESKYt KRISTOPHE•R T. SMULLt OF COUNSEL: JEFFREY If. LEVItt iMlminN 1'AQOY ttAOminnf AlllaN OCOnIy Genrral 1961a11: emailIIrmadaw.nwn August 1, 2000 Please be advised that the parties have agreed for the voluntary entry of judgment by the Board of Arbitrators at the trial scheduled for tomorrow, August 2, 2000 at 10:00 am. Judgment is to be entered in favor of the Plaintiff for $10,291.01 plus costs. Neither myself, as counsel for the Plaintiff nor David Baric, counsel for the Defendant, will be appearing tomorrow. It is understood the Defendant reserves its rightto appeal the Board's determination in favor of the Plaintiff. Very truly yours, AMATO MAR C. By// G/I Ronald Amato r1\r1 adaron cc: AGREED TO AND ACCEPTED on AUGUST 1, 2000 David A. Baric, Esquire O'Brien, Baric & Scherer 17 West South Street Carlisle PA 17013 By Facsimile Only: (717) 249-5755 LAW OFFICES BARBARA SUMPLE-SULLIVAN 540 BRIDGE. STREET NEW CUDIIiERf.A.\D, YE\'\SYLVA.\IA 17070-19131 *104& X PHONE (717) 774-1445 "? FAX (717) 774-7050 glip 0 sT?t, y?,?s ?ppp aqp uFr U August 3, 2000 ?NF9 Horace A. Johnson, Esquire Johnson, Duffle, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 1 7043-01 09 Re: Arbitration Award Stanl0v Works v MUetP M.Innfleluring Indus ri c Inc Dear Horace: Enclosed is the executed Judgment entered per your correspondence dated August 2, 2000 and the joint stipulation of counsel for the Plaintiff and the Defendant as indicated by their fax dated August 1, 2000. BSS/Id Enclosure naroara 23umpte-Sullivan - go'l l t 08/01/2000 15:12 7172495755 OBS LAW OFFICE Law Offices O'BRIEN, BARK & SCHERER 17 West South Street Carlisle, Pennsylvania 17013 Robert L O'Brien David A. Boric Michael A. Scherer DATE: O^P' X 17 ROO PAGE 01 (WV j 6ww-y1V1!2 (7/7 App-3015 (717) 249-M73 FAX (717) 249-5755 E-mail obs@obslaw.com TO:l4UL// W/UTAA-1 7 wcck-c-i cacL. FROM: I NU VNItL'P-/ RE: Numba this transmittal page: IF YOU DO NOT RECEIVE ALL PAGES OR IF COPIES ARE NOT LEGIBLE PLEASE TELEPHONE: (717) 249-6873 IMPORTANT- THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED, AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT READING, DISSEMINATING, DISTRIBUTING OR COPYING THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE. THANK YOU. 08/01/2000 15:12 7172495755 OBS LAW OFFICE PAGE 02 SENT 8V: MATO AND MARGLE, P.C.; 610 868 9155; AUG.1.00 11:38AM; PAGE 111 LAW OFFICES OF AMATO AND MARGLE p.L RONALD AMATOt STANLEYI MAROLG. lilt , SUITE 100, COMMERCE! SQUARE MIQIALL I. KBNNLIDYt JAMES). NARLeSKYT 107 NORTH COMMERCE WAY KRISTOPHER T. SML'LLI BETHLHHEM, PA 18017.8930 TELEPHONE (610) 866-0400 oVr:oUNSEL FACSIMILE (610) 866-9111 JEFFREY H. LEVitr MAAJNG r M. A. 1111 MAMA, tlAa IW: 010) W."M AtM,.,y,, rA 11101 M.ryy V.Iw 1C.i, pM 0y},y r..Oa?J FA W, llMn Mn.W Ka o, 0,.,,Y R,. w,lo-46~1.,w Mq1, ?•N.II: urye0w,,,,1..,ea,n PMAM RSWO,NO To SIC17M.111my FORWARDED VIA REGULAR MAIL AND FACSIMILE TO 1717) 761.3015 Horso• A. Johnson, Esquire August 1, 2000 Johnson, Duffy, Stewart & Weidner 301 Market street Lemoyne, PA 17043 Re: STANLEY WORKS V. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES Count of Commas Pleas of Cumberland County Civil Actlan No.: 99.71317 Our Fits #r: 993272 Dear Mr. Barie: Please be advised that the Parties have agreed for the voluntary entry of judglnerll by ills Board of Arbitrators at the trial scheduled for tomorrow, August 2, 2000 at 10100 art,, Judgment la to be entered in favor of the Plaintiff for $10,291.01 plus costa. Nslther nlyself, as counsel for the Plaintiff nor David Saris, counsel for the Defendant, will he appearing tomorrow. It is understood the Defendant reserves Ito right to appeal the Boo id's deurmina lion in favor of the Plaintiff. rIXr1 adaron David A. Boric, Esquire O'Brien, Bartc & Scharer 17 West South Street Carlisle PA 17013 By Fscsimlle Only: 17171 249-5755 cc: AGREED TO AND Cj2C EO n AUG t/ a( Very truly yours, AMATO 6 MAN G, By: Ronald Amato 08/01/2000 15:12 7172495755 OBS LAW OFFICE PAGE 02 SENT 9Y: AMATO MO MAiIGLE, P.C.; 810 ass 9155; AUG. i•00 11:38AM; PAGE 111 LAW OFFICES OF AMATO ANY) MARGLE, P.C, SUnE 100, COMMERCE SQUARE 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017.8930 TELEPHONE (610) 866-0400 FACSBWRX (610) 866-9155 ALLVIM" NALING -.0. ft. till A 4ftm rA IIIOf N&qA eMSI .M: ale Won, N.,y4 Ydn LMN, eN) MlSY1 Llyll t.WN: uivtlee?Nl.w,ee,n PLRAtpt ReaPMD TO MTft AM M FORWARDED VIA REGULAR MAIL AND FACSIMILE TO 1717) 701.3015 Horace A. Johnson, Esquire Johnson, Duffy, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 Re: STANLEY WORKS V. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES Court of Coming" Pleas of Cumberland County Civil Action No.: 99.7017 Our File N: 993272 Dear Mr. Dario: RONALD AMATOt STANLEY) MAROLC. tilt WMAUL r. tIINNEOYt JAMES). NARLPIKYT KRISTOPHeR T. nfVLLt OFROONSEL. JHfFReY H. LGVItt rA QI, 11Ml.lwf MI,.?1MQy C-wo G,M August 1, 2000 Please be advised that the parties have agreed for the voluntary entry of judgment by the Board of Arbitrators at the trial scheduled for tomorrow, August 2, 2000 at 10:00 am. Judgment Is to be entered in favor of the Plaintiff for $10,291.01 plus coats. Neither myself, as counsel for the Plaintiff nor David Beric, counsel for the Defendant, will be appearing tomorrow. It is understood the Defendant reserves Its rightto appeal the Board's determination in favor of the Plaintiff, r1V1 adaron David A. Boric, Esquire O'Brien, Boric & Scherer 17 West South Street Carlisle PA 17013 By Facsimile Only: (717) 249-5755 cc: AGREED TO AND AC ED n AUG 1/Jt00 Very truly yours, AMATO MAR C. By., Ronald Amaro Ire{ G llv bit STANLEY WORKS, Plaintiff V. MASTER MANUFACTURING INDUSTRIES INC. d/b/a M & M INDUSTRIES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7617 CIVIL TERM CIVIL ACTION - LAW NOT/CE OFARB/TRATORS' HEARING TO: Ronald Amato, Esquire Amato and Margle, P.C. 107 North Commerce Way Bethlehem, PA 18017 Subodh Sharma, President Masters Manufacturing Industries, Inc. 441 Sioux Drive Mechanicsburg, PA 17055 v #.I AND NOW, this 15'h day of June, 2000, you are hereby notified that the arbitrators appointed in the above-captioned action will hold a hearing for the purpose of their appointment as follows: Date: Wednesday, August 2, 2000 Time: 10:00 a.m. Location: The Law Offices of Johnson, Duffle, Stewart & Weidner, 301 Market Street, Lemoyne, Pennsylvania CAVEATS: 1. THOSE PARTIES WISHING TO INTRODUCE VIDEOTAPE EVIDENCE WILL BE EXPECTED TO HAVE THE NECESSARY EQUIPMENT TO DISPLAY THE VIDEOTAPE PRESENT AT THE ARBITRATION LOCATION. 2. IN THE EVENT THAT DEPOSITION TRANSCRIPTS ARE TO BE USED AS EVIDENCE, TRANSCRIPTS SHOULD BE PROVIDED TO EACH ARBITRATOR AT LEAST ONE WEEK PRIOR TO THE HEARING. 3. PARTIES WISHING TO ARGUE LEGAL POINTS WILL BE EXPECTED TO HAVE ZPIES OF STATUTES, CASES, ETC., WITH RELEVANT PORTIONS HIGHLIGHTED FO ACH rfIRATOR AND OPPOSING COUNSEL AT THE COMMENCEMENT OF THE HEARING. , ,,A I Esquire Arbitrator Sullivan, Esquire, Arbitrator kkm:114334 c: Jeffrey N. Yoffee, Esquire Barbara Sumple-Sullivan, Esquire Court Administrator Bulletin Board, Prothonotary's Office STANLEY WORKS, V. Plaintiff MASTER MANUFACTURING INDUSTRIES INC. d/b/a M & M INDUSTRIES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7617 CIVIL TERM CIVIL ACTION - LAW NOT/CE OFARBI TRA TORS' HEARING TO: Ronald Amato, Esquire Amato and Margle, P.C. 107 North Commerce Way Bethlehem, PA 18017 Subodh Sharma, President Masters Manufacturing Industries, Inc. 142 Reno Street New Cumberland, PA 17070 AND NOW, this 151 day of June, 2000, you are hereby notified that the arbitrators appointed in the above-captioned action will hold a hearing for the purpose of their appointment as follows: Date: Wednesday, August 2, 2000 CAVEATS: Time: 10:00 a.m. Location: The Law Offices of Johnson, Duffie, Stewart & Weidner, 301 Market Street, Lemoyne, Pennsylvania 1. THOSE PARTIES WISHING TO INTRODUCE VIDEOTAPE EVIDENCE WILL BE EXPECTED TO HAVE THE NECESSARY EQUIPMENTTO DISPLAY THE VIDEOTAPE PRESENTAT THE ARBITRATION LOCATION. 2. IN THE EVENT THAT DEPOSITION TRANSCRIPTS ARE TO BE USED AS EVIDENCE, TRANSCRIPTS SHOULD BE PROVIDED TO EACH ARBITRATOR AT LEAST ONE WEEK PRIOR TO THE HEARING. 3. PARTIES WISHING TO ARGUE LEGAL POINTS WILL BE EXPECTED TO HAVE COPIES OF STATUTES, CASES, ETC., WITH RELEVANT PORTIONS HIGHLIGHTED FO CH 9RBITRATOR AND OPPOSING COUNSEL AT THE COMMENCEMENT OF THE HEARING. „ ,7/ kkm:114334 c: Jeffrey N. Yoffee, Esquire Barbara Sumple-Sullivan, Esquire Court Administrator Bulletin Board, Prothonotary's Office 7A. Johnson, Esquire, Chairman N. Yoffee, Esquire Arbitrator I Sumple-Sullivan, Esquire, Arbitrator ._ ir.u= ?_ ? _ _.. -- _n _ __ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW I, } STANLEY WORKS C : No. 99-7617 Plaintiff • IIIvs. `- MASTER MANUFACTURING CIVIL ACTION INDUSTRIES INC. doing business I as M & M INDUSTRIES Defendant NOTICE OF JUDGMENT BEEN ENTERED GIVEN NSTG TH IN THE ABOVE CAPTIONED (XX) MNOTICE is THAT A ATTER HASHEREBY aCLON • , 2000. IN THE AMOUNT OF $10,291.01 a ( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. D COUNTY PROTHONOTARY ; BERL /? If you have any questions concerning the above, please c tact the undersigned. AMATO AND ARRE, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 , _. I )F CUM IN THE COURT OF COMMON PCML ACTION BLAWND COUNTY, PENNSYLVANIA STANLEY WORKS Plaintiff VS. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES Defendant No. 99-7617 CIVIL ACTION NOTICE OF JUDGMENT (XX) MANOTICE IS TTER HASRBEEN EINTERED AGAIN T HE Al OV/E-NAMEOD DEFENDANT(s) 0CLON `? • , 2000. IN THE AMOUNT OF S10,291.01 a () FILED WITH THE PROTHONOTARY OF A COPY OF ALL DOCUMENTS U THE WITHIN CUMBERLAND SUPPORT OF IS/ARE ENCLOSED. D COUNTY PROTHONOTARY . ? CUMBERL /51 I If you have any questions concerning the above, pease c tact the undersigned. AMATO AND MAR E, P.C. By. r Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 `r i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff VS. MASTER MANUFACTURING : No. 99-7617 INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment by default for want of an answer in favor of Plaintiff and against the above-named defendant(s) only and assess damages as follows: Debt $10,227.10 Interest (from December 13, 1999 to January 27, 2000 at 6% per annum) 63.91 Court Costs Attorneys fees Total $10,291.01 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. Pursuant to RCP 237.1, I certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on January 13, 2000. Dated: January 26, 2000 AMATO AND MAR E, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 993272 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff : No. 99-7617 Vs. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 76 Batterson Park Road Farmington CT 06032 I do certify that the precise last known address of the within named defendant is: 441 Sioux Dr MECHANICSBURG PA 17055-2594 AMATO AND MA E, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 COURT OF COMMON PLEAS OF ACUMBER CTION L AND COUNTY, PENNSYLVANIA LAW CIVIL STANLEY WORKS Plaintiff No. 99-7617 VS. MASTER MANUFACTURING CIVIL ACTION INDUSTRIES INC. doing business as NI & M INDUSTRIES Defendant(s) TO: Master Manufacturing Industries Inc. doing business as M & M Industries 441 Sioux Dr MECHANICSBURG PA 17055 Date of Notice: January 13, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TO OR TELEPHONE THE NOT HAVE A LAWYER OR THIS NOTICE LAWYER AT FFIC TO FIND CANNOT AFFORD ONE, GO OUT WHERE YOU CAN GET LEGAL HELP. Cour-t Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 AMATO AND M I-E P/ By: ? Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866.0400 Attorney File# 993272 - I?eCln _ I?III?RI?I??fl?1?® COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW STANLEY WORKS Plaintiff No. 99-7617 CIVIL TERM vs MASTER MANUFACTURING INDUSTRIES INC., doing CIVIL ACTION business as M&M INDUSTRIES Defendant ANSWER TO COMPLAINT The above named defendant hereby answers Plaintiff's complaint and responds to each paragraph thereof as follows: 1. Neither admits or denies the allegations therein. 2. Denies the allegations therein set forth insofar as the allegation indicates the place of business of M&M Industries. The place of business of M&M Industries is 142 Reno Street, New Cumberland, PA, 17070. 3. Denies the allegations set forth in paragraph 3 in their entirety. 4. Denies the allegations set forth in paragraph 4, except that defendant neither admits or denies that the charges therein referred to are just and reasonable. 5. Denies the allegations set forth in paragraph 5 in their entirety. 6. Denies the allegations set forth in paragraph 6 in their entirety. 7. Denies the allegations set forth in paragraph 7 in their entirety. 8. Neither admits or denies the allegations in paragraph 8. 9. Neither admits or denies the allegations in paragraph 9. 10. Denies the allegations set forth in paragraph 10 in their entirety. il. Denies the allegations set forth in paragraph 11 in their entirety. 12. Denies the allegations set forth in paragraph 12 in their entirety. set forth in paragraph 13 in their entirety. set forth in paragraph 14 in their entirety. lemands that the instant complaint be dismissed, MASTERS MANUFACTURING INDUSTRIES, INC. by Su o h Sharma, Presi ent .1. % VERIFICATION SUBODH SHARMA, hereby states that he is President of MASTER MANU- FACTURING INDUSTRIES INC., doing business as M&M Industries, and verifies that the statements made in the attached Answer to Complaint are true and correct to the best of his knowledg V-- , C r it LJJ?.7 U (.j =J 4 ?J •^ -? 1• U n p lJ . ?Ln?''w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY FORKS Plaintiff : No. 99-7617 VS. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please vacate the judgment entered in the above-captioned case. AMATO AND M E P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 G w? Ll -• C> J i Li cV ._?> J _-JLU ]a. U p U co (9 !? 1 D C. (? STANLEY WORKS, Plaintiff VS. MASTER MANUFACTURING INDUSTRIES INC., doing business as M&M INDUSTRIES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7617 CIVIL 19 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: Ronald Amato, Esquire , counsel for the plaintiffs 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 $ 10,227.10 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. Respectfu s bmitted, ORDER OF COURT oneld Amato, Enquire AND NOW, 19 Z1117?, in consideration of the foregoing petition, ???//M Esq., and "fem.(, / fit, y sq., are app inted at/ atom Zc. above-captioned action (or actions) as prayed for. B J. pt,irqOMGLIOY ,ai 1 4 ? J7 ^ a > J ... N n ?Z L51 > i7CL IXICL Q O O V .17M f fill 9: 92 C??I?hCl'iiJ'i',? I,IJLJI\'i Y FEINAIISYL1/w\qq Q G ro ? Pa Q O f 44 L 7 SHERIFF'S RETURN - REGULAR CASE NO: 1999-07617 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STANLEY WORKS VS MASTER MANUFACTURING INDUSTRIE Sheriff or Deputy Sheriff of CPL. MICHAEL BARRICK Cumberland County, Pensylvania, who being duly sworn according to law, was served upon says, the within NOTICE & COMPLAINT Trar n/n/A M & M IND the DEFENDANT at 0016:23 HOURS, on the 22nd day of December , 1999 at 441 SIOUX DRIVE by handing to MECHANICSBURG, PA 17055 SHEILA SHARMA (MOTHER, BABYSITTER) of NOTICE & COMPLAINT together with a true and attested copy and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 R. Thomas Kline .00 29.10 12/23/1999 AMATO & MARGLE Sworn and Subscribed to before By: f Deputy Sh if m his day of `f tary COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff No. Z Q l ?c ?7 euu ( '7? Vs. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES Defendant : CIVIL ACTION 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 BYATTORNEYS 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 Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 AMATO AND "GLE, P.C By: Ronald P r"'ato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff C"- No. qq- 7( VS. MASTER MANUFACTURING INDUSTRIES INC. doing business : CIVIL ACTION as M & M INDUSTRIES Defendant(s) COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $10,227.10, with interest thereon as hereinafter stated, upon the following cause of action: 1. The Plaintiff, STANLEY WORKS, is located at 76 Batterson Park Road, Farmington CT 06032. 2. The Defendant, MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES, is a Pennsylvania corporation with its place of business located at 441 Sioux Dr, MECHANICSBURG PA 17055-2594. lc? 3. ll? The Plaintiff, at Defendant's special instance and request, sold to Defendant certain goods and merchandise in the amount and for the prices set forth in invoices referred to in a Statement of Defendant's Account taken from Plaintiff's books and records, a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "A". 4. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 5. Defendant received and accepted the goods described in the invoices referred to in Exhibit "A" and a total principal amount which became due as a result thereof, after allowance for all proper credits for payments and/or returned merchandise, if any, was $9,649.70. 6. Plaintiff is also entitled to receive interest on the above amount determined by applying the statutory interest rate of 6.00% per annum to the past due balance. As of December 13, 1999 the total amount of interest due to Plaintiff is $577.40. 7. Plaintiff is entitled to have the 6.00% interest charge continue to accrue as set forth above, from December 13, 1999 on down to the date of judgment in this matter. 8. The Plaintiff has made demand against the Defendant for the aforesaid sum, but Defendant failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against the Defendant for $10,227.10 together with the continually accruing interest charge at the statutory rate of 6.00% par annum from December 13, 1999, and cost of suit. COUNT II (Alternative to Count I - Unjust Enrichment) 9. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 10. The goods, wares, merchandise, and/or services, described in the exhibits attached hereto were purchased by the Defendant, and the Defendant received and accepted the benefit of such goods, wares, merchandise, and/or services provided by the Plaintiff. 11. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid goods, wares, merchandise, and/or services to Defendant, and that Plaintiff expected to be paid for such. 12. At all times material hereto, Defendant, with the aforesaid knowledge, permitted Plaintiff to provide and/or deliver said goods, wares, merchandise, and/or services, and to incur damages. 13. At all times material hereto, the Defendant was unjustly enriched by retaining the benefit of receiving said goods, wares, merchandise, and/or services without paying Plaintiff fair and reasonable compensation. 14. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's expense, an implied contract exists between the Plaintiff and the Defendant, and the Defendant is obligated to pay Plaintiff the quantum meruit value of the value of the goods, wares, merchandise, and/or services described in the exhibits attached hereto, in the amount of $9,649.70. WHEREFORE, Plaintiff demands judgment against the Defendant for $9,649.70 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from December 13, 1999, costs of suit and all other relief to which Plaintiff may be justly entitled. AMATO AND MARGLE, P By: 7 Ronald Mato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 VERIFICATION hereby states that he/she is the r{?c{iacG J `,, re /, of C/LZD,. /MNgva'x °? g-mnIt',V),IL5 Plaintiff in this action, and verifies that the statements made in the attached Complaint are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 PA C.S. §4904 relating to unsworn falsification to authorities. 67 AUG 25 199 09:33 FR STANLEY RCCTS RECV 860 409 1284 TO 917168324236 P.02/08 STATEMENT i?iCC{gigpiS.? isiT?T'DATP^ AC,1?=??9i a?: 2017545 08-2 1999 1 1 O M & M INDUSTRIES 142 RENO STREET NEW CUMBERLAND, SEND CORRESPONDENCE TO: THE STANLEY WORKS Credit Services PA 17070 76 Battereon Park Road Farmington, CT 06032 TELE: 1-860-225-5111 is &?'+YkSlICB ?,t90zm9R?2 3RBFER81QCfI ;'i ,.CUP-ME bATB 1fn?,?L78T. k, ,DpE't;DA'1'g,s k.'STO >x "°S. y;HDDffsEtt: ^; CV.STOMER' ?r 4 ORDHR., .. ...,. .s3QdQ?•'?S{'i S5 '??w .: i.. ,.c DIIE'4< .,'-`. DZ 000001575 12-29-1997 - - 265.53- RX 0091147296 08-11-1998 09-10-1998 002-97005 306.39 RX 0091368844 11-07-1998 12-07-1998 004-97005 2,581.08 RX 0091400136 11-20-1998 12-20-1998 012-90045 2,916.12 RX 0091400137 11-20-1998 12-20-1998 012-98045 67.50 RX 0091400138 11-20-1998 12-20-1998 010-98026 25.03 RX 0091402021 11-21-1998 12-21-1998 010-98026 128.94 RX 0091446886 12-10-1998 01-09-1999 004-98053 120.87 RX 0091458028 12-14-1998 01-13-1999 007-98038 3,269.05 RX 0091458030 12-14-1998 01-13-1999 OD7-98038 500.25 EXHIBIT a -Y r .c.. >?.. :{s;a:D^. >ri? IL1C.r,.?- :.¢z?°•.•?.s:s=ti..:PS;; ^sa:; 'r ;r;. :?152:C.F?4'.'•SY. ACC'- filA?ARC6 3.ti901-AA,Y83 :31.60:eDBXS.,'i52':91YAAY8.?91`+27,OiDAY `7:22??111AY&:?G078Rr. 0.00 0.00 0.0 .00 0.00 9,649, 9,649.70 •DOCUME-IT CODE RX/ZllZL2/Z9 = VOICE / C 'DIT MEMO 57L/LD/ZP/Z2 = PAYMENT / DEDU '!'lON DG/ZG/Y2/Y9 = CREDIT ADJUSTMENT DR/ZM = DEBIT MEMO t ... In The court of Common Pleas of a/b? ) Cumberland County, Pennsylvania ) ?. ) No 9 ?/oaXad. ?l ?Y?rTp.S p?rc.dba /194?jag OATH We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Consstt7 L io? this Comon- wealth and that we will discharge the duties of o t ice th fidelit airman 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 nenarately stated.) Arbitrat applicable.) Date of Hearing: 2- Date of Award: ZQ?r ZDOtJ NOTICE OF ENTRY OF AWARD Now, the 23 day of Au) u51 , A&C at Ib(Zd, --h-, the above award was entered upon the docKet and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: s d40'w ?L 3?\ Y -Itts 3 N 4- ?N<C S 4 L J L .? C=am CJ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff : No. 99-7617 VS. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) ORDER Upon consideration of Plaintiff's Motion for Summary Judgment and Defendant's Answer thereto if any it is ORDERED that judgment be and hereby is entered against the Defendant and in favor of Plaintiff in the amount of $10,227.10 together with continuing interest at the rate of 6.00% per annum and costs. it is .further ORDERED that the prothonotary shall mark the docket according to this order. J. dated this day of 2000 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff : No. 99-7617 Vs. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Plaintiff, STANLEY WORKS, files the within motion for summary judgment against the above-referenced Defendant, MASTERS MANUFACTURING INDIISTRIF..S INC. doing business as M & M INDUSTRIES, and in support thereof states the following: 1. Plaintiff filed suit against Defendant by Complaint on December 29, 1999. A true and correct copy of the docket entries are attached hereto, made a part hereof, and marked Exhibit "A". 2. Defendant filed a responsive pleading on or about January 13, 2000. A true and correct copy of which is attached hereto, made a part hereof, and marked Exhibit "B". 3. Plaintiff forwarded to Defendant a Request for Admissions on September 21, 2000. A true and correct copy of which is attached hereto, made a part hereof, and marked Exhibits "C". 4. To date, Defendant has failed to answer Plaintiff's Request for Admissions, which were due, pursuant to PA.R.C.P. No. 4014, on October 21, 2000. 5. Based on the Defendant's failure to answer Plaintiffs Request for Admissions, according to Pennsylvania Rule of Civil Procedure 4014(b), the facts in Plaintiffs Request for Admissions are deemed admitted. 6. The following are deemed admitted. a. In regards to Exhibits "1" through "9" attached to the requests which are the invoices at issue: i. The Defendant ordered the goods in the attached Exhibits from Plaintiff. ii. The Defendant received the goods in the attached Exhibits from Plaintiff. iii. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibits. iv. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. V. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibits. vi. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. b. Defendant received and accepted the goods described in the invoice referred to above Exhibits I through 9 and a total principal amount which became due as a result thereof, after allowance for all proper credits for payments and/or returned merchandise, if any, was $9,649.70. C. Master Manufacturing Industries Inc. had a place of business located at 142 2 Reno St. New Cumberland PA 17070 between July 1, 1998 and January 1, 1999. d. Plaintiff is also entitled to receive interest on the above amount determined by applying the statutory interest rate of 6.00% ner annum to the past due balance. As of December 13, 1999 the total amount of interest due to Plaintiff is $577.40. e. Plaintiff is entitled to have the 6.00% interest charge continue to accrue as set forth above, from December 13, 1999 on down to the date of judgment in this matter. f. The Plaintiff has made demand against the Defendant for the aforesaid sum, but Defendant failed or refused to pay the same or any part thereof. g. Defendant owes Plaintiff $10,227.10. h. As Defendant has admitted to the above facts Plaintiff is entitled to a judgment as a matter of law as there is no material fact at issue. WHEREFORE, Plaintiff respectfully requests that this Court grant Plaintiff's motion for summary judgment in favor of Plaintiff and against Defendant for $10,227.10 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from date of judgment, costs of suit and all other relief to which Plaintiff may be justly entitled. By: AND?[-E, P.C. AMATO v Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 3 :s:-'m COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff No. 99 'h /7 VS. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES Defendant CIVIL ACTION 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 ATTORNEYS 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 Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 AMATO AND M GLE, P.C. By: Ronald to TRUE COPY FROM RECORD Attorney I.D. No. 32323 In Testirnony whereof, I here unto set my hand Attorneys for Plaintiff and thro seal of said Cou ! at Carlisle, Pa. 107 North Commerce Way TiT1S -d' o' Bethlehem, 18017 (610) 866.040400 othanotary EXHIBIT COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff No. VS. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $10,227.10, with interest thereon as hereinafter stated, upon the following cause of action: 1. The Plaintiff, STANLEY WORKS, is located at 76 Batterson Park Road, Farmington CT 06032. 2. The Defendant, MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES, is a Pennsylvania corporation with its place of business located at 441 Sioux Dr, MECHANICSBURG PA 17055-2594. 3. The Plaintiff, at Defendant's special instance and request, sold to Defendant certain goods and merchandise in the amount and for the prices set forth in invoices referred to in a Statement of Defendant's Account taken from Plaintiff's books and records, a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "A". 4. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 5. Defendant received and accepted the goods described in the invoices referred to in Exhibit "A" and a total principal amount which became due as a result thereof, after allowance for all proper credits for payments and/or returned merchandise, if any, was $9,649.70. 6. Plaintiff is also entitled to receive interest on the above amount determined by applying the statutory interest rate of 6.00% per annum to the past due balance. As of December 13, 1999 the total amount of interest due to Plaintiff is $577.40. 7. Plaintiff is entitled to have the 6.00% interest charge continue to accrue as set forth above, from December 13, 1999 on down to the date of judgment in this matter. 8. The Plaintiff has made demand against the Defendant for the aforesaid sum, but Defendant failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against the Defendant for $10,227.10 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from December 13, 1999, and cost of suit. COUNT II (Alternative to Count I - Unjust Enrichment) 9. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 10. The goods, wares, merchandise, and/or services, described in the exhibits attached hereto were purchased by the Defendant, and the Defendant received and accepted the benefit of such goods, wares, merchandise, and/or services provided by the Plaintiff. 11. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid goods, wares, merchandise, and/or services to Defendant, and that Plaintiff expected to be paid for such. 12. At all times material hereto, Defendant, with the aforesaid knowledge, permitted Plaintiff to provide and/or deliver said goods, wares, merchandise, and/or services, and to incur damages. 13. At all times material hereto, the Defendant was unjustly enriched by retaining the benefit of receiving said goods, wares, merchandise, and/or services without paying Plaintiff fair and reasonable compensation. 14. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's expense, an implied contract exists between the Plaintiff and the Defendant, and the Defendant is obligated to pay Plaintiff the quantum meruit value of the value of the goods, wares, merchandise, and/or services described in the exhibits attached hereto, in the amount of 99,649.70. WHEREFORE, Plaintiff demands judgment against the Defendant for 99,649.70 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from December 13, 1999, costs of suit and all other relief to which Plaintiff may be justly entitled. AMATO AND M GLE, P By: Ronald A4fiato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 VERIFICATION hereby states that he/she is the M+G{t4CL J? re /, of CILZn +. 1tiFr?K ?''? ?? S-rnn/a, LUILS10 Plaintiff in this action, and verifies that the statements made in the attached Complaint are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 PA C.S. §4904 relating to unsworn falsification to authorities. 6? AUG 25 '99 09:33 FR STANLEY ACCTS RECU 860 409 1284 TO 917168324236 P.02i08 STATEMENT 3.AC'rMONS '19V3S8 -.. :$TAITY.... , ?••'}=i... s' 2017.55b 08-2 -1999 I l Of 1 M & M INDUSTRIES 142 RENO STREET NEW CUMBERLAND, SEND CORRESPONDENCE TO: THE STANLEY WORKS Credit Services PA 17070 76 Battereon Park Road Farmington, CT 06032 TELE: 1-860-225-5111 i*n-°•cGM5N?1:. Cpyg}xs-'i,.- as¢e[tEttes .,r140lf8$I{?? ?IiBPZReIQ?:? DOCO?Ati'L`rbAT3 ??arsT' , D'(TP,.jDA17?? ?;?Sxo'7n is ygs?iOFIDER +.::. cvsmoetERxrmZCa3isa' ? ORDSR liiLGIBER "',.. '..yn1a90tFF,`.?ws?r'' tnt+ .. DVE'g?;:?„?. DZ RX 000001575 0091147296 12-29-1997 08-11-1998 - - 09-10-1998 002-97005 265.53- 306.39 RX 0091368844 11-07-1998 12-07-1998 004-97005 9SO 5 21581.08 916 12 2 RX 0091400136 11-20-1998 12-20-1998 012- 4 012-98045 . , 67.50 RX RX 0091400137 0091400138 11-20-1998 11-20-1998 12-20-1998 12-20-1998 010-98026 25.03 RX 0091402021 11-21-1990 12-21.1998 010-98026 128.94 120 87 RX 0091446886 12-10-1998 01-09-1999 004-98053 007-98038 . 3.269.05 RX RX 0091458028 0091458030 12-14-1998 12-14-1998 01-13-1999 01-13-1999 007-98038 500.25 EXHIBIT W a A r. J. U 00T08E' ............, . t. ?4:.:'4?::: ?<'=:.fiir^???:: ie?..,t S"."•I ?ACCUiIN'PHRS71RC8: 3':i90'<IIRXS:: •31?.60;'DAXS:,..i •F,5]:'>90°.AtuC9.91+120".DAY '121?jD7%YS;9Rt.Og8127. 9,649.70 l 9,fi49. IV 0.00 0.00 0.0 .00 0.00 'DOCUMENT CODE RX/Zll Z2/Z9 = INVOICE / C IT MEMO D'LI'LD/ZP/ZZ = PAYMENT / DED "P1 DG/ZG/Y2/Y9 CREDIT ADJUSTMENT DR/ZM = DEBIT MEMO COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW STANLEY WORKS Plaintiff No. 99-7617 Vs MASTER MANUFACTURING INDUSTRIES INC., doing CIVIL ACTION business as M&M INDUSTRIES Defendant ANSWER TO COMPLAINT CIVIL TERM The above named defendant hereby answers Plaintiff's complaint and responds to each paragraph thereof as follows: 1. Neither admits or denies the allegations therein. 2. Denies the allegations therein set forth insofar as the allegation indicates the place of business of M&M Industries. The place of business of M&M Industries is 142- Reno Street, New Cumberland, PA, 17070. 3. Denies the allegations set forth in paragraph 3 in their entirety. 4. Denies the allegations set forth in paragraph 4, except that defendant neither admits or denies that the charges therein referred to are just and reasonable. 5. Denies the allegations set forth in paragraph 5 in their entirety. 6. Denies the allegations set forth in paragraph 6 in their entirety. 7. Denies the allegations set forth in paragraph 7 in their entirety. 8. Neither admits or denies the allegations in paragraph 8. 9. Neither admits or denies the allegations in paragraph 9. 10. Denies the allegations set forth in paragraph 10 in their entirety. 11. Denies the allegations set forth in paragraph 11 in their entirety. 12. Denies the allegations set forth in paragraph 12 in the EXHIBIT 13. Denies the allegations set forth in paragraph 13 in their entirety. 14. Denies the allegations set forth in paragraph 14 in their entirety. WHEREFORE, defendant demands that the instant complaint be dismissed, with predjudice. MASTERS MANUFACTURING INDUSTRIES, INC. Ty Su o h Sharma, Presi ent VERIFICATION SUBODH SHARMA, hereby states that he is President of MASTER MANU- FACTURING INDUSTRIES INC., doing business as M&M Industries, and verifies that the statements made in the attached Answer to Complaint are true and correct to the best of his knowledge, information and belief. SUBODH SHARMA Ct F M, r vim? c%) jg c.- C r J c Fi ?w u o o U LAW OFFICES OF GLE, P•C• AMATO AND MAR 107 NORTH C COMMERCE WAY BETHLEHEM, PA 18017-8930 TELEPHONE () 866400 FACSIMILE (610)866 ALLENYOWN MAILISG P.O. Boa 1111 Mule voice Did: 161013*24M ugle Allenmwn. PA 18105 Mfr{le E N,.,:ifmv{IrEfmnolaw.cam PLEASE RESPOND TO BETHLEHEM David A. Baric, Esquire O'Brien, Baric & Scherer 17 West South Street Carlisle PA 17013 RONALD A%lATOt STANLEY L PIARGLE, lilt NJICIIAEL J. KENNEDYt JA%IES1. NARLESKYt KRISTOPHER T. SNIULLt OF COUNSEL: JEFFREY it. LEVITY rASnimd PA OOY tfA iral\IO"a O1Y GeriN F.Jlul: emm18mnolfw.eom September 21, 2000 Re: STANLEY WORKS v. MASTER MANUFACTURING INDUSTRIES INC. doing business as M & INDUSTRIES Court of Common Pleas of Cumberland County Civil Action No.: 99-7617 Our File #: 993272 Dear Mr: Baric: Plaintiff's First Set of Request for Admissions Addressed to Defendant. Enclosed please find Please have your client answer these in the time require d pursuant to Rule 4014 oft he ' If your client is interested in discussing a reasonable Pennsylvania Rules of Civil Procedure.' settlement offer please feel free to call. Very truly yours, . AMATO AND ARGLE, P.C. By. Mjcae 4eiedy MJK\MJK • EXHIBIT errs -- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff No. 99-7617 VS. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) PLAINTIFF'S FIRST SET OF REQUEST FOR ADMISSIONS ADDRESSED TO DEFENDANT Plaintiff, request that the above-referenced defendant, admit the truth of the following facts and application of law to facts within thirty (30) days of the date of service pursuant to Rule 4014 of the Pennsylvania Rules of Civil Procedure. INSTRUCTIONS 1. In answering each Request, identify each document, communication or act: (a) relied upon in the preparation of each answer; (b) which forms all or part of the basis of that answer; (c) which corroborates the answer; or (d) the substance of which forms all or part of the answer. 2. If information furnished in answer to all or part of a Request is not within the personal knowledge of the affiant, identify each person to whom all or part of the informatiori furnished is a matter of personal knowledge and each person who communicated any part of the information furnished to the affiant. .3. If any request cannot be answered state the reasons why it could not be answered and any investigation made to determine if the answer was available or unanswerable. 4. In lieu of identifying any document or communication, you may attach a true copy of such document or communication as an Exhibit to your answers to these Requests along with an explicit reference to the Request to which each such Exhibit applies. 5. If you object to any portion of a Request, provide all information called for by that portion of the Request to which you do not object and state the reason for your objection. If any of the information requested cannot be provided in full, provide information to the extent possible and specify the reasons for the inability to provide the k f, remainder. 7. Defendant reserves the right to serve supplemental Requests on Plaintiff. B. Whenever the expression "and/or" is used in these Requests, the information called for should be set out both in the conjunctive and disjunctive, and wherever the information is set out in the disjunctive, it should be given separately for each and every element sought. 9. Whenever a date, amount or other computation or figure is requested, the exact date, amount or other computation or figure is to be given unless it is not known; and then the approximate date, amount or other computation or figure should be given, or the best estimate thereof; and answer shall state the date, amount or other computation or figure is an estimate or an approximation. 10. No answer is to be left blank. If the answer to a Request or subparagraph of a Request is "none" or "unknown" such statement be written in the answer. If the question is inapplicable, "N/A" must be written in the answer. If the answer is omitted because of the claim or privilege, the basis of privilege is to be stated. If an answer is omitted because of the claim that the question is objectionable, the basis of the objection is to be stated. 11. If you claim any privilege not to answer, identify each matter as to which the privilege is claimed, the nature of the privilege, and the legal and factual basis for the claim of privilege. 12. These Requests are continuing in nature. If after providing answers, you become aware of any further information which is responsive to these Requests or which is in any way inconsistent with your initial answers, or is secured subsequent to the service of your answers which would have been included in the answers had it been known or available you are required to supplement your initial answers with such information which must be served without further request or Requests by Plaintiff. DEFINITIONS The following definitions apply to words or terms used in these requests for admissions: "Identify" or "identity", when used with reference to a document, means to state: a. the identity of the person who prepared it; and b. the identity of the person who signed it and the identity of the person over whose name it was issued. 2. Whenever the word "you" or "your" appears herein and whenever the designation of the party served with these requests for admissions appears herein and whenever any person or entity is referred to herein, such word, designation, person or entity shall be construed to mean not only the party served with these requests, other person or entity in his, her, its, or their own right, but also his, her, its, or their agent, servants, workmen, representatives, employees, or attorneys. If the party to whom these requests are addressed is not an individual(s), "you" or "your" includes the entire entity, its divisions, its merged or acquired predecessors, its present and former officers, directors, agents, employees, and all other persons acting or purporting to act at the direction of or on behalf of it or its predecessors. 3. The word "representative" or "representatives" includes any consultant, surety, indemnitor, insurer, employee, agent, adjustor, or investigator for the party or party's insurer. 4. The term "Plaintiff" as used herein refers to Plaintiff and, where applicable in context, its employees, consultants, representatives, agents, heirs, assigns, and all other persons acting or purporting to act on its behalf. 5. The term "Defendant" as used herein refers to Defendant in the ensuing action, and, where applicable in context, its officers, directors, employees, consultants, representatives, agents, and all other persons acting or purporting to act on its behalf. 6. The term "document" or "documents" refers to written, transcribed, filmed, recorded, printed and graphic matter of every kind and description, however produced or reproduced, including, but not limited to, checks, bank drafts, invoices, memoranda, receipts, correspondence, photographs and drawings, graphs, charts, telegrams, letters, contracts, agreements, diaries, notes, reports, minutes, analyses, projections, work papers, photographs, diaries, sketches, drawings, calendars, minutes, tables, information stored in a computers memory, machine readable cards, discs, tapes or computer printouts of any board of directors or committee thereof, and records of any event, written or oral communication and recordings (tape, disc, or other) of events or oral communications and other data compilations in whatever form from which information may be obtained or translated through human, mechanical, or other means into a reasonably usable form including drafts, copies, transcripts, and summaries of any of the foregoing whether or not within the possession, custody or control of Plaintiff. As used herein, "document" or "documents" also refers to the originals of the materials listed as well as all copies, reproductions, and printouts of such documents which bear any notations or other alterations not found on the original or which differ in form or in substance from the original, whether or not written, in the possession, custody or control of Plaintiff or that of its subsidiaries, affiliates, divisions, or other organizations, units or their parent(s) or representatives(s). 7. As used herein, documents "relating to" or "which relate to" any given subject shall mean each document that constitutes, deals with, refers to, evidences, memorializes, or is in any way pertinent to that subject, including, without limitation, docu- ments concerning the preparation of other documents, transcripts, summaries, affidavits and statements. 3 S. "Person" or "individual" means and includes any natural person or individual (living or deceased), and also means and includes any trust, proprietorship, partnership or limited partnership, group of natural persons, corporation, unincorporated association, association, organization, joint venture, firm or other enterprise (whether or not for profit), and any governmental body, political subdivision, government or government agency, quasi-public entity, or other form of entity and also, where relevant, the individual representing such "person". 9. "Discussion" means oral communication. 10. "And" means "and/or" . "Or" means "and/or" 11. "All means "any and all". "Any" means "any and all" 12. "The incident or occurrence" refers to the matter at issue and all relevant transactions between the plaintiff and defendant. 13. "Relevant period" refers to that time period during which Plaintiff Defendant. 14. "Each" means "each and every". "Every" means "each and every". 15. The use of the masculine shall include the feminine and neuter and vice versa. The use of the singular shall include the plural and vice versa. ADMIT OR DENY THE FOLLOWING: 1. The Plaintiff is Stanley Works. 2. Stanley Works is located at 76 Batterson Park Road, Farmington CT 06032. 3. • The Defendant is Master Manufacturing Industries Inc. doing business as M & M Industries. 4. Master Manufacturing Industries Inc, is a Pennsylvania corporation. 4 .J f:w.w. 5. Master Manufacturing Industries Inc. had a place of business located at 142 Reno St. New Cumberland PA 17070 between July 1, 1998 and January 1, 1999. 6 Plaintiff. In regards to Exhibit "1 ": a. The Defendant order the goods in the attached Exhibit from Plaintiff. b. The Defendant received the goods in the attached Exhibit from c. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 7. In regards to Exhibit "2": a. The Defendant order the goods in the attached Exhibit from Plaintiff. 5 b. The Defendant received the goods in the attached Exhibit from Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 8. In regards to Exhibit "3": a. The Defendant order the goods in the attached Exhibit from Plaintiff. b. The Defendant received the goods in the attached Exhibit from Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. 6 d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 9. In regards to Exhibit "4": a. The Defendant order the goods in the attached Exhibit from Plaintiff. b. The Defendant received the goods in the attached Exhibit from Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. .d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. 7 f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 10. In regards to Exhibit "5": a. The Defendant order the goods in the attached Exhibit from Plaintiff. b. The Defendant received the goods in the attached Exhibit from .- j Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. . f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 11. In regards to Exhibit "6": a. The Defendant order the goods in the attached Exhibit from Plaintiff. 8 b. The Defendant received the goods in the attached Exhibit from Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 12. In regards to Exhibit "7": a. The Defendant order the goods in the attached Exhibit from Plaintiff. b. The Defendant received the goods in the attached Exhibit from Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. 9 d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 13. In regards to Exhibit "B": a. The Defendant order the goods in the attached Exhibit from Plaintiff. b. The Defendant received the goods in the attached Exhibit from Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. e. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. L 10 f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. 14. In regards to Exhibit "9": a. The Defendant order the goods in the attached Exhibit from Plaintiff. b. The Defendant received the goods in the attached Exhibit from Plaintiff. C. The Defendant used, sold, disposed of or retained possession of the goods in the attached Exhibit. d. Defendant agreed to pay to Plaintiff the amount as set forth in the Exhibit under invoice total. a. Defendant has failed to pay the Plaintiff for the goods set forth in the attached Exhibit. . f. The prices charged for the aforesaid items are just and reasonable and are those which Defendant promised to pay Plaintiff. x? 15. Defendant received and accepted the goods described in the invoice referred to above Exhibits 1 through 9 and a total principal amount which became due as a result thereof, after allowance for all proper credits for payments and/or returned merchandise, if any, was $9,649.70. 16. Plaintiff is also entitled to receive interest on the above amount determined by applying the statutory interest rate of 6.000% per annum to the past due balance. As of December 13, 1999 the total amount of interest due to Plaintiff is $577.40. 17. Plaintiff is entitled to have the 6.009/b interest charge continue to accrue as set forth above, from December 13, 1999 on down to the date of judgment in this matter. 18. The Plaintiff has made demand against the Defendant for the aforesaid sum, but Defendant failed or refused to pay the same or any part thereof. 19. Defendant owes Plaintiff $10,227.10 AMATO AND M E, P.C. By. - Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 12 XLLN t_ustotner support tnvtvun xtttag I:IYI .1: STANLFY -IA,'.DWARF 480 Myriv ctrl.- New Breton KIr15? INVOICE _ Sales Order. Number. 1568973 , Customer Order Vote Sales Terrltorv Numier 11/06/199 IS0677 Customer Order Number hi ig Vat-_H !y --- O. I2-980x5 , _.• _ - Concnrd,T- Bill To M & M INDUSTRIES 142 RFNO STREET NFW CUMBERLAND. I • Bill to No. 2017545 --•• -- -- j 5X4.5 HMGF ---- - -- - y$p {.5X45 HINGF 4_5X43_BML;E . -...-- 5 •' -'• - -241 a4V UM.: SPRING HMGF - • -• • - EXHIBIT 1 \G?1. nGllll\ • V. STANLEY HARDWARE ISYISY?•_- 914001 (? _ P091 Office Box W15970 invoi t Date ^barlotte NC 28275 l12 /I 8 Invoice Due I •_ 12/20/1998 al nvnice_Amount Ce er Currency _ >L¢..12. YELLOW PRE _ D_ Ms •, _ Hill o! IRftr F%ld H : Islner;IU 692 1,)/Aqllnt)R •-B• Prv umber _ . FhI Rale Policy .• 203-7418.@. _ pa-y Thjs--AAmt •• _ 2 857.8 Ship to : M & M INDUSTRIES MARMIOMEWOOD SUITES HO•TIA WYOMISSING PA 142 RENO STREET NEW CUMRP.RLAND, PA 17070 - - - Ship to No. 2017545 4F1d rf7Z r7O- d-Name. Td? A 0 78 -65 - 94 _• __ •_ _ _ Fax: 860 827-543 ••,._._•_ - --- .. US4 - __-2S11.19- .P._ NHTINFS... 4 1 1tiLM ._ _ - „usa _14.72 .. US4 ,_.8.51904 . _ 2.092 2i -- - - -- - 1 -4 ^?- N, Sub-Total S2.916.12 A!"10, =ia -A .2'i':n:? 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Number Bill of Ladin 1f lld An.... _ .; i 10/26/1998 IS 677 .,.. 2% vNLT jt: _ 590-00128346 _ 1122/1998 Customer Order Number Shippinlt Foeilrtv F.O.1 Ptro Number Pay This Moe Fre 004-97005 _•-._ _ Cpnunrd,N! i ht R41r_Pnllcy •. 0729126768_ S 2 529 461 Bill To : M & M INDUSTRIES Ship Tn : NC fC FIOUSING UNIT p 2 142 RENO STREET 0/0 BRF.CHBILL AND HEI MAN f'ONST -0 NEW CUMBERLAND, 1••, I SHEPHERD GRADE ROAD ROII'IF N IJOX 11166-UNIT p2 UlF.PIIF.RDSfOWN. Wv 75441 Bill to No. 2017545 Ship to No 2017545 5-17e Llnfl Arrnnnf N 1 h _ rl •_-- ___ ...-_._____. _ ._-?_- •?} ?. } 8 . to .. Tel: 800 782.6594 •_-- ... ,... t7 r aa: (960) 827-SM139 " 1- .--. 1494,4.}K4S HINC:P 76!1 • _• 9F?lNE'L._ .. _ __..-S 1 466. ;.. smit _-1 ,IJ1YlSXdS }IIN(iF __ _ - 20V _ R.61,2iR ._.. ?._? 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STANLEY HARDWARE 9114729 Pntl Office Box 0075970 invol e 1 Charlotte NC 28275 08/11119 r INVOICF. _SoIGS r r um cl 126594; ?L'uslamer Order &te Step _ (erritl ry_Num 08/07/1998 _ 1 67' _,.. Customer Order Nnmbcr Shl Int Fuel tv „. :_ ,002;97W5 . . __ . ._ .. (.onr•rn *: Bill To : tit k M INDUSTRIES 142 RENO STREET NEW CUMBERLAND, f, ' W Invoice Amnunt 1639 •--_-_- 'T 4 ,hi R,xtc Policy I Ship 1'o : NCTC !SOUSING, UNIT #2 C/O BRECHBILL & HELMAN CONS7 GO SHEPHERD ORADF. ROAD-ROUI'E n :IIEPIlERDS'fOWN. WV 25441 Bill to No. 2011.545 i • o __ --•-_------- - Ship to No. 2017545 S •?O ElAgr Inn Invnire Nt,mftpr Cmtomer Arrnml Number and Namr ummnrv Tel: 800 782-6594 ° r' m"' ...w 1 Fax: 860 1327-5439 _-- _ - 1Qicdei 1cKa1y len ,,, _•__ - _-_-,- Ilnll Prlee -- --- ??.-.---_ :T FRM Sr•T NFTINFT 46 limp ? '' _ ... 2924) - - - EXHIBIT - -- -----,- -I l -`?.• t114r ?'j •??).... I:.S: Vi1l'•rI•"y4deV':i'.f•5_.. 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Bill of Iadin - If ,PpId.14Y;-__ t2NiI1998 _,_ Terms... ztt Sn±F? eo - - _ 'prro No ber__ I uy, ;Itti: Awt , Fret I,q }t4ke Policy,_.._ - M & M INDUSTRIES OOD SUITES 140" 14 Ship Tt) MARK:}(DMEW WYOMISSING PA 147, RENO STREET (-UMBF.RLAND. PA 1 70;" ,VW r to urtth Tn m.rclw+>•r? Yft.E F 4r.at[ 4ear St.d.e. Act of 19as. n 4mMo ? Yb of rNYtN na n!u a _ ._......_. to Ship to No. 2017545 ?%( lv . J? - - l- _ Tel 800 782-6594 _ ax: 6 827_543 Fxialltd.. m . . _ -_ _ _-- ll . •• ?4 50000 `Ll=? lTh?. Tratupo nm.ru ar .t<t. 6. 7 !. t 7 G to Tues _. ?--? 1. 0llru?oorrWUW Ung.,14 to ?W- J_ ?JixYY.r Tntr.I ,¦ ustumer Support DivLston Selling Dlvt.n: STANLEY 1-*R 1WAR10. 480 Myrtle %I: e New Brital^ 14153 INVOICE Sines Ordcl Mlmber,_ _ 1675904 Customer Order Date- Soles Trrriuln .Nucmr ber 1210 9/ 1 9 9 8 IS0677 Cuttamer Order Number -ShjnPiny {•jB_11?-_ l .007.98038 Concorti.%, •-_--_ Rill '1.11 M & M INDUSTRIES 142 RENO STREET NEW CUMBERLAND PA Bill to No. 2017545 .IGU' 4YlJ I4YJ1 r'.V1, l.1 rteaw. HMO lo: 1nYOlae l STANLEY HARDWARE 9 4 802E Post Ollice Box 00'15970 nv ice I Chultitte NC 28275 1211411 Bell of I,edln II sNEi io 580-001453V 1 t Number__ F Io . _ ht?t?tr F?nhey _., ,,_ 13647178 ship Tu : M & M INDUSTRIES 142 RENO STREET NEW CUMBERLAND, PA 17070 Ship to No. 2017545/G3 Alr--nl Nlmher wnrl Namc.__ Snmmarv _-` 1 /0----- -••- _ _ Tcl: 8 782-6594 '?B •1 'ti affil . "' e, _ _, _ Fax: 18601 827.5439 M errinl Drserialiaa Mot wke Exlradee JWv aP1<0.W-IP 11.'1 DH cP.T 4 842 11 _• - - --' RPM-010-60 11 U DR CET ,- - r % - - - 511.% .i RP15 lLUf171 _B65.30 - ? EXHIBIT _- - -_ -? 5 .T?_?.___ ?. 1. 1. ry.. -cl.y. :,•': .?,..:x?yzSaiil'1:'•axis'?;;?".f:'':L;.Iiti,:F:•..c5:? Sab.Total,-_ :•:.-, .?._.g?c;_ : - .:. .;r'r- ":fir.: 3 ?.:'.A.:r.r'IrJc.•,F aua¢z r` I:?1yi{f.'.•5>> I:•t :. w l 11 IM Mfwgn "to x IN. Y 00. IW W. W'.e•^ H wnpl.rc. Ma Jt .gi,?nMl. O? wee n. I ? 1] W tti Toe, mnatllHdTs 1 ... l.lu 9w O tM A of 1])0, IS t'1W10. ]M 01 IbWII:OM Yq w" if tM UOII00 ate" West 01 LOUR: WNd u". ^I. 11 - - Tax" _ _ _ , :•-j . LI N OI W M01 tYYRt 10 W 000]l nld MM , Wu (WI 10 N1 4NY YOM dYNwY \0 CMW. 1 .. .. 111 .MY, - ?.y ,r ` .. • I-' T/Y '•I'1 --_?-_ n'"I 5.3,269.05., i _.T T P(i 1i21h':1 _ :i•Stt!•ra/ Y• Tnr.nree T[1181_ . .1 t ustotacr support-lnv'sio'n "'beilmB utvislun: STANLEY HARDWARE 480 Mynir Sbrec• New Briton C 16053 rm,ur nl:nul .o. ... • •. •. . STANLEY HARDWARE Post Office Box 0075970 r^urlotty NC 28275 ti .. Ij?ltc ,_ Cun INVOICE Sal Order Numh_ _ ta) Snvnicr. Amoun[ NA WA USC4nrr 1 29}, ,_ 25.03 -- s pill of Ladln Ie,gs.t gyp I ?domer Order Da Sales 'remtory_NuiLer To -& 2% 151 IM JU, 645.00225470 I?N-S/1998 --• o er de 'umber lli in Fagl?y „ . .,, F.O. Number Pav This AS .220 6 -•• --• _-_ .° San T)ia)al i=1--_•• Fleight Rafe Policy 009.996149 .. .24 Rill To M & M INDUSTRIES Ship To : M & M INDUSTRIES 142 RENO STREET 142 RENO STREET NEW CLIMBERL.AND, P' VFW CUMBERLAND, PA 17074' Bill to No. 2017545 Ship to No. 2017545 r- ' v l03• L4 29-- _ _:_ Mfo/rrb1 DcmpthnL _ I "MI MCC 139.41:120 AL r1R TRK _ EL_ -- I _ 12.2L EXHIBIT }Si Sa a:.LS.Ic'@elki.l'11 Y: '.. It . 7 • i.I.?YI x" i S•': Sub-Tn181_. _aiAK ,.:?+{.'Sx.. Ki<i'k.' ?.•n:?.•iC..?.?r?.;•f?.rl. •na.j't`,':i:';J.yt 10 10 -MY NI mMfiVYMH UIW M INO ImOK1 N1 WM MOEYt10 N ltlnpllwKl Mh N NWIIITUN a! 1K1. L,) 6 to 01 IM Tnn1p91uuaNHe16 - - L!2 L?COI ]IYNuL A[I al 1])if, p ynFbW, yd 0, ?IO?YIV^I MC tlOM YI IM VNIb SOIU WOL 01 WM IWIY WbM NO t? ?L •,1 1• .. nnomer %upport?umsion aemng tnsutul- STANLEY HARDWARE 480 Myrtle Street New Brilair.t•f 116053 INVOICE Sales Order Number _• 1600291 - _- I Customer Order Date - ales Tetrlton_Numbcr r ti/ 16/1998 15677. _. 2 4 Customer Order "umber h{ in FacllltV _- F 0.24@oZ.b. __ . ----- --?- Concord Nf F Bill 'rt, M & M INDUSTRI[S 142 RENO STREET NEW CUMBERLAND, PP rtc0. helm/ IU: - Illy Uttt STANLEY HARDWARE 9142(121 - Post Office Box 0075970 ! voice?? Marintte.. NC 28275 1121r;.pQ$_-_ Invoice Due D 12/21/1998 1-L01112ice Ainnunt r-arrler urrettes • - •94 - UNITED PAR USD _ ny -- - pill of I.adin L P. *d Hy3. SruBt in . - . 121CI6/I920- A Number Ito Pa _('his.- ttt , >ht Rate Policy • 126.} - Shit, '1'u : M & M INDUSTRIES 142 RENO STREET NEW CUMBERLAND, PA 1704' Bill to No. 2017545 Ship to No. 2017545 ?le? 0 16 ? S 1 rprnpLAventmt Number and C=r. Tel: 800 782-6594 Ytt t0" `ii' i. ., T2 Fax: 860 827-439 _-, Maria M,mS r 4r41 rial rlnedntton... r td.ZdSe NFT/NEr .-. 9,15000 •77 24 •o uoty_uew na cr•I. _ - --. -?3.ffi 3F -----3.0JU - ,1. enacts... _ .-2 60A411_iA.lffi_SL'LALTRli_ _-HS?OR. .. 1Zf9_.{ _73.1145+ .._ .. S.tl•`ll _. ...- - - ? EXHIBIT _.._.-- -•---_._...--- - ?_ { - t +.•:•!'..SS%i1•,st t / ??n,Fi .,jl r,Kr'. r?.l °ES/r/r '.'`{_ Tn[HI__ ... .. _ M.65 I s •t. :•: .°..-t n?'se .sµ.?.,.:••ry,u.:%l::i. w.... r Y t i 'Yr :C'... __. 29 n. a la .4nity N.t •weMnO•.• We4 ., troy N"Me. rn M• pOJatGa N camps.<. wlt? YI rpulrwnwN. of .yet a. 7 6 12 Of ft M TIWtAnellor?mals - • •' - _ +• t+0a St.n'1?4. 4: at 1038, M ?m,dM, W er ,rgJn?r. ud w6u at 1r 4M.e 61.1. O.1t..1 U80r 4.uW yd.r .K.. 14 Taaei nr.N. n8 rW N t.Y ..la r.w.cr le Iti pmd...t! h.r.W..Me ne. r J.. wm 14b1 ur..n fa 44otr. +.fi?VF':ralrlsf fp?i, •. '1 •..?'[i?iA`titTArY?^ ? :?%ilk?? -C?_? l' ?'?.. 5?: Tnvnirn Tntnl_ ?2a-9?-- 1:?1 1':. LCY'.'J bp•JA t.'nstnmer Support Division Selling t STANLEY HARDWARE 480 Myrtle Struct New Britain ('T 06053 INVOICE NLM er ,-- Customer Order Number Shi in Nadlity.._ OO4;p8053•._-.__. Concon?V(' _• Bill To : M. & ht INDUSTRIES 142 RF.NO STREET NEW CUMBERLAND, P/ Please Remit To: STANLEY HARDWARE Post office Box 0075970 Charlotte Nt: 28275 LY4JJlyr,{1 I)n. _._. ?44,¢3•L.6 ,I ,87 ll of Ladin If Paid B : 19 -" - - --- 1212511998 f-NFr u Chit A Pr AM B . _ o Number-..:PJ!Y_ Ship To : M & M INDUSTRIES 14.2 RENO STREET NEW CUMBERLAND, PA 17n'IO 2017545 S hip to No. 2017545 O ?y 17•70 l" I Bill to No. • •-- 1 --- - -- - Tel: 800 782.6 "3. f' Fax: 860 827.5439 ' J!rkc LC.. 1Y Sft!- -._ _ _MA1cd;kLlbxr4dLQa-......_ f U _. _ i 724.5%e s HENCE _. _.._. _l .. 5X9.5 MUM _ . 261) 4 ? FB1J191N1tP 3 P . --._• EMU- Z_. _ _ - . . •- ' . ? -' .. _ _ _ .. _. - -- - ? EXHIBIT •--..__ -• ---- 1¢ to r 1 .: SU TOt1l d 4z93 • ` 1 ?l?e d..xIft i`M!f L 1.1 ?t .i L J _.. _. M1 _ \.i!il _ _ .. ..1 {11A...? ... ..J, « \' t [ s.i:a'... a'{.«Y 9 PY y; A:: t} { 1 e Sv a ai:. - - - - 6.8C Et n M1 M tutda &M mfCIWMa9 "IM N It" W coo t.•. Men pMK•d N c"Paen•• ?+? a9 .pVYe"'a.A r •r\. e a n 1 a al m. Tf9L1tW1otloNHS T.{Ct el l.F.:uW wde. eeq \? co,, u Ism innee'dt Act of 1939. M M"Ad. Md al IAQ A., eM wd.f e1 tlr W..d slot" po,.f. N took a w..tu\ n.0•et to w O.W. e•u n.•v.d•r a"ell qu td tle• bw UNR 1• unfit. .. v.. •'?_..._ a 141: .. <$O/an9ni:trJo ??tl '!rF'.`'. invn' ? •Pntfill ..- ...` . Invglcc hn_, • ,? ?,,.,,, ?•.,< Please Remit To: 914@OS_._ customer Support Division Selling DtvtWtnr• STANLEY HARDWARE ?InvoZe_ late STANLEY HARPWARF Po,t Office Box 0075970 12114/ 460 Myrtle Street tlarimtc NC 28275 New Btitam t": tIM153 Invnice Due Pt ' 01113!1992 .. Ca 'er C?rrrcnce . Total Invelec rRPunl_,,,, INVOICE 1es Ertl. N_um6cr UNITE P pSC> - 5 6 9CW -- Bil of Lath CC Paid R _ er Order Date les Cnjo(Y .'Lumber Tema _ - •- - 12f2QIZ!><1_8-•- e umber Pay&ipt i 77 ..2% 151 C Olds No ber hi 'n Feeilif Frei hi wic Policy-._ . ........._..___._._---- 001-QAO Concord M1C -- Shia 'fn ' tit & M INDUSTRIES Bill '1'o . M & M INDUSTRI)S 142 RENO STREET 142 RENO STREET %FW ('tIMBERL.AND• PA 17010 NEW CUMBERLAND, Ph ' Bill to No 2017545 DPI5o DO 48 HD MME3.4 - Ship to No. 2017545 ?'1 S^ Te 800 7 •6594 ..._.._.....-- •--- 75? _500.-? - i .. ?? --•---- Sub-Total _ X500'25 ??. 't .. .. '..?. ..??'.: { ?.if sS ? _« :? :Ili! ...y.3i??'.1??-}(i '[•{LLi,.i tt; i! y?'?- -- -- t`lyl Q ( t v d . Ore rt Al Toni •- i " t.ryM t_'r't ?,... ?,t(?n:e=L? i r'•`N :t.. Lri r1: fl. 4rX •,Fr _.._.L .__...--. -... l Uu " •' '? ?" "' *4" 1n I W W YMnt1 of 1M. L. 7 L 126 M n to oNly W1111NNI?N 1151W N W. l'". Nt Owe yedu(YO In eomPtint+ _-_ le Tmos _- Y Vm 9.d4`00 Alt 411330 . M enWM, /d el ?n,^I.uue MO wdw el \M II?IW Ll.ln epl ?I l.Ow Itt?H 1/0/ MCI. - Y If?On NY'/W le GY1IN. -- its NY !. i:H.(?.: _ u.lw. M ,w a tow wM Mows to er avow ua Irw,Mer WI ew m tM lil'I ..+;•. :.:,.,.?'{i.,.,.. .. -, .e. ¦Le•',]' _..; 'Ya ?'Ec?.:.d7^. ,11......11e TnraL?__ _ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, -PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff : No. 99-7617 Vs. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE NAMED DEFENDANT(S) IN THE AMOUNT OF $10,291.01 ON 2000. () A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY-CUMBERLA COUNTY 1/4//01 Per: If you have any questions concerning the above, please contact the undersigned. Amato and Margie, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 (610) 866-0400 ;c } COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff : No. 99-7617 VS. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Pursuant to the attached Stipulation of Parties, kindly enter judgment in favor of Plaintiff and against the above-named Defendant as follows: Debt $10,291.01 Total $10,291.01 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE ATTACHED STIPULATION. Dated Amato and Margie, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 (610) 866-0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,-PENNSYLVANIA CIVIL ACTION - LAW STANLEY WORKS Plaintiff : No. 99-7617 Vs. MASTER MANUFACTURING CIVIL ACTION INDUSTRIES INC. doing business as M & M INDUSTRIES Defendant(s) CERTIFICATION OF ADDRESSES 1 do certify that the precise last known address of the within named Plaintiff is: 76 Batterson Park Road Farmington CT 06032 I do certify that the precise last known address of the Defendant is: 441 Sioux Or MECHANICSBURG PA 17055-2594 Amato and Margle, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 (610) 866-0400 *? .. « COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,'PENNSYLVANIA CIVIL ACTION - LAW v STANLEY WORKS Plaintiff : No. 99-7617 VS. MASTER MANUFACTURING INDUSTRIES INC. doing business CIVIL ACTION as M & M INDUSTRIES Defendant(s) STIPULATION OF PARTIES FOR ENTRY OF JUDGMENT IN FAVOR OF PLAINTIFF AGAINST DEFENDANT The Plaintiff, STANLEY WORKS by and through its counsel, Amato and Margie, P.C., and the Defendant, MASTER MANUFACTURING INDUSTRIES INC. doing business as M & M INDUSTRIES by and through counsel, O'Brien, Baric & Scherer, hereby stipulate this 4th day of December, 2000 as follows: 1. That judgment may be entered in favor of Plaintiff against the above named Defendant for $10;291.01 by agreement upon Praecipe by the Plaintiff. 2. Compliance with Pennsylvania Rule of Civil Procedure 237.1 is hereby excused. Amato and Margl , P.C. By: Ronald Amato Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 (610) 866-0400 O'Bri , Banc & Scherer ByiU r David A. Baric, Esquire Attorney for Defendant 17 West South Street Carlisle PA 17013 DEC 2 0 2000 A I . ?4 111' U Z LLI r V Z LLI w? a / a? z / Q Q Z ?LLz w ?tea ? _ Sofz O w W U .:I `-?- Z . a W o k' 3 o w o H o I oN 0> E W 6 w O Z Z w a w o a . qM w z 0 o z I x 0 i l i t _ L ` t m I i I i t I I I i .,??? ti?