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Home My WebLink About07-3196J -& ma-y COMMONWEALTH OF PENNSYLVANIA I COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial Diatrict, County Of FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT Cumberland COMMON PLEAS No. n ! r r r NOTICE OF APPEAL 2erial Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the MagDistrict 1 Judge on the date and in the case referenced below. NAME OF APPELLANT MAG. DIST. NO. NAME OF MDJ Intermove. LTD. 109-2-01 ADDRESS OF APPELLANT CITY -- R2-132 42 G9 FS "A ZIP CODE C/o Amato and Associated 107 North Commerce Way Bethlehem PA 18017 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant) May 21, 2007 lIntermove, LTD vs. Ace DOCKET No. SIGNATURE OF APPELL ATTORN ;rake GENT CV-053-07 J1 / This block will be signed ONLY when this notation is required under Pa. R.C.P.D. J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature of Prothonotary or Deputy was before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellee(s) appellee(s), to file a complaint in this appeal (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellee(s) Name of appellee(s) OWNER (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date May 24 , 2007 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT)TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 COURT FILE TO BE FILED WITH PROTHONOTARY 1? ? ?ta v C= a ss ?: 0 COMMONWEALTH OF PENNSYLVANIA =--o,i mrrv nc. CUMBERLAIff>D Mag. Dist. No.: 09-2-01 MDJ Name: Hon. PAULA P. CORREAL Address: 2,260 'SPRING RD SUITE #3 CARLISLE, PA Telephone: (717 ) 218-5250 17013-0000 ATTORNEY FOR PLAINTIFF : NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS r-INTER'IIOVE, LTD 10 7 N COMMERCE WAY C/O AMATO A ASSOC PC LBETHLEMM, PA 18017 J VS. DEFENDANT: NAME and ADDRESS riCE !LOVING & STORAGE CORPORATION ? 4 CAVE HILL ROAD CARLISLE, PA 17013 RONALD AMATO L J 107 N COMMERCE Docket No.: CV-0000053-07 _ AMATO AND ASSOCIATES PC Date Filed: 4/11/07 BETHLEHEM, PA 18017 THIS IS TO NOTIFY YOU THAT: Judgment: FOR DEFENDANT (Date of Judgment) 5/21/07 Judgment was entered for: (Name) ACE (LOVING & STORAGE CORPORATION ® Judgment was entered against: (Name) INTERMOVE, LTD in the amount of $ ' 0 ? Defendants are jointly and severally liable. F] Damages will be assessed on Date & Time ? This case dismissed without prejudice. F] Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ .60 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ 00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES.OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COM NP H 1?, 1 I JJ r~?IT?Q?nt on?'rnuunAC?AUVn7J? f1(ITC?CCTCII IwI'TNC II111/_`IIAGLIT ?IIA Cll Dafe M?gjterfal''District ,Judge i"certlfy,'that this 15 a true art' rre copy oft ec r'`_ fthe proce, . in contain g the udglrient:` -kl f Date k%r ?a ,.Mag%erial District Judge t "T , 2012 My commission expires, first Monday of January, eAL s AOPC 315-06 DATE PRTNT'Rn - r,/21 /e7 11-97-nn am r XX May 31, 2007 May 31, 2007 NOTA U1.8EA? pEY O SCHOENECK HANd?p TDwMSP NORTHAMPTON CNTY 9.2005 My Cgstpn Expires mar', 07-3196 Civil X Ace Moving and Storage Corporation X ? c N o a rn.- ? ' C) 1:10 7C -'.?".-.';._..'r??.'k7"??,•?"' ,_klS1^M;'v'iG?A#+!^""r.? ?:?%.,-??+?..?-. ,-?.?-r.'°..° ."..."'Ip _ i! r ?L X2..9 a-7 COMMONWEALTH OF PENNSYLVANIA f COURT OF COMMO EAS NOTICE OF APPEAL Cumberland COMMON PLEAS No, 07 -,31 6 t I NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. IYHIVIt Ur ArrtLLAr41 MAG. DIST. NO. NAME OF MDJ Irit.erMOVe. LTD. 09-2--01 pA11 7 A P Cos?aa;? ADDRESS OF APPELLANT CITY STATE ZIP CODE c/c Amato -and As:iuciaced 107 North Commerce -ay detlllehem PA 1C9U17 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant) hay lei, 2007 lIntermove, LTD vs. Ace M in al' DOCKET No. SIGNATURE OF APPELL ATTORN AGENT .iichael Ke na ,,)A tv Yor Anuellat This block will be signed ONLY when this notation is required under Pa. If appelfent was Claimant (see a. R.C.P.D. J. No. 1001(6) in action R.C.P.D. J. No. 1008B. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty Judicial DiArict, County Of A (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To Name of appeffee(s) appellee(s) OWNER (1) You are notified that a rule is hereby entered upon you, t6 file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date ZLaY 24 2007 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT AAA ?/1T r.? r Tu m Tr .N o O O 0 m m r.± s 0 ti Tr In no N D- S D- ru 0 0 . O O W) W) 3:516 IPM File: G ? m m 0 N Tr Ln so rq T? PosTAGE W.41 POS TE URN RESTRICTED DELIVERY FEE - Q VICE cERnRED FEE :REECEIPT RETURN RECEIPT FEE ? ^ o' Cr j - I SENTTO-o TOTAL POSTAGE AND FEE'S j C 5/3 f 3:56 PM File: S ACE MOVING AND STORAGE CORPORATION 4 CAVE HILL ROAD CARLISLE, PA 17013 PS FORM 3800 alUNITEDSTATES RECEIPT FOR CERTIFIED MAIL PROVIDED vST? X/7YI?,Err NO INSURANCE COVE.no,AL MAIL NOT FOR INTERNATION (SEE OTHER SIDE) POSTAGE *U•41 POSTM ATE RETURN RESTRICTED DELIVERY FEE , PALE V A RECEIPT SERVICE CERTIFIED FEE ?? RETURN RECEIPT FEE $ 2 _ ? C4) SEjjT0: 5. 1 TOTAL POSTAGE AND FEE'S J ° ? SpS HONORABLE PAULA P. CORREAL MAG. DIST. CT. 09-2-01 2260 SPRING ROAD, SUITE 3 CARLISLE, PA 17013-3322 PS FORM 3800 STATES RECEIPT FOR CERTIFIED MAIL OMID KEr NO INSURANCE COVERAGE PROVIDED NOT FOR INTERNATIONAL MAIL SERI/ (SEE OTHER SIDE) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD. Plaintiff : No. 07-3196 Civil vs. ACE MOVING AND STORAGE CORPORATION CIVIL ACTION Defendant NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND ASSOCIATES, P.C. By: nald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD. Plaintiff No. 07-3196 Civil vs. ACE MOVING AND STORAGE CORPORATION CIVIL ACTION Defendant(s) COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $1,727.11, with interest thereon as hereinafter stated, upon the following cause of action: 1. The Plaintiff, INTERMOVE, LTD. , is located at 3 Simm Ln, Unit 211, Newtown Ct 06470. 2. The Defendant, ACE MOVING AND STORAGE CORPORATION , is located at 4 Cave Hill Road, Carlisle PA 17013. COUNT I 3. Plaintiff, at Defendant's special instance and request, provided to Defendant a shipping container in the amount and for the prices set forth in its invoice to Defendant, 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 shipping container described in the invoice referred to above, 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 $1,600.00. 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 June 1, 2007 the total amount of interest due to Plaintiff is $127.11. 7. Plaintiff is entitled to have the 6.00% interest charge continue to accrue as set forth above, from June 1, 2007 on down to the date of judgment in this matter. 8. Plaintiff has made demand against Defendant for the aforesaid sum, but Defendant failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against Defendant for $1,727.11 together with the continually accruing interest charge at the statutory rate of 6.00 % per annum from June 1, 2007, 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 Defendant, and Defendant received and accepted the benefit of such goods, wares, merchandise, and/or services provided by 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, 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 Plaintiff and Defendant, and 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 $1,600.00. WHEREFORE, Plaintiff demands judgment against Defendant for $1,600.00 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from June 1, 2007, costs of suit and all other relief to which Plaintiff may be justly entitled. AMATO AND AS CIAT , P.C By: nald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM VERIFICATION I, Ronald Amato, Esquire, hereby state that I am the attorney-in-fact for Plaintiff in this action and, as such, am authorized to make this verification on behalf of Plaintiff, that the statements of fact made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief based upon the information and documentation provided by Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. onald Amato, Esquire Attorney for Plaintiff Dated: June 5, 2007 iNT Mav9 weldm?Ahimmw Z004 3 simm lane. unit 2h rrewtoWrl, ct 06470 (203)270-0282 (i3b0) M5655 fax (203)270.908i mail: moveolntermuve.com httWlwww. l ntermove. cbm a in* American Chm*d =4 Operated. Sold To., Ace Movlhg Co. A Cave Hill Rand Carlisle, PA. Mal Attn: Peter Kan Invoice Nn: E- :1 "4111 Referenaa: Ad 1 NagamAnsid INVOICE := AVtg NACU ORZANSK{ $11.00 VVENT Y FODt CONTAINS BOOKED, -I-RANSPORTED FROM PORT NEW YORK Tc', $b .i10 TO 51.611b.00 ? r 277 ?`"? •? - 's C? ?. ? ryits I S!S£ RNAi10 NAl AIX L + rotavek ag/jq?2008 14:50 FAX 2032709311 Cl C'. r-N ° O 7;7 m ?' - W =t COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD. Plaintiff No. 07-3196 Civil VS. ACE MOVING AND STORAGE CORPORATION Defendant(s) CIVIL ACTION CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of Plaintiff's Complaint was served via first class mail, postage prepaid on June 12, 2007: Ace Moving and Storage Corporation 4 Cave Hill Road Carlisle PA 17013 AMATO AND ASSOCIATES, C. By: onald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM n rv 1 _ ; L.r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD., Plaintiff, vs. ACE MOVING AND STORAGE CORPORATION. Defendant No. 07-3196 CIVIL ACTION ANSWER The Defendant, ACE MOVING AND STORAGE CORPORATION (hereinafter "ACE") by and through its counsel, FREDERICK W. ALCARO, ESQUIRE, hereby makes Answer to Plaintiff's Complaint and aver as follows: 1. Admitted upon information and belief. 2. Admitted. i COUNTI 3. Denied. It is denied that Defendant requested Plaintiff to provide a shipping container in the amount and for the prices set forth in its invoice marked as Plaintiff's Exhibit A. To the contrary, said invoice which was prepared after the fact does not set forth any such terms and/or prices nor was there ever any agreement or discussion by between the parties relative to potential charges if the job was cancelled. 4. Denied. ACE is without sufficient information upon which to form a belief as to the truth or falsity of the averments set forth in this paragraph and, such being the case, said averments are deemed denied and strict proof thereof is demanded at trial. 5. Denied. It is denied that Defendant ever received or accepted said shipping container. To the contrary, Defendant advised Plaintiff that the shipper had cancelled the move and that the shipping container was, therefore, not needed. As to whether the "total principal became due as a result thereof', said averment sets forth a conclusion of law to which no responsive pleading is required. 6. The averments contained in this paragraph set forth a conclusion of law to which no responsive pleading is required. 7. The averments contained in this paragraph set forth a conclusion of law to which no responsive pleading is required. 8. Admitted. COUNT II 9. Admitted and denied for the reasons set forth at length above. i 10. Denied. ACE is without sufficient information upon which to form a belief as to the truth or falsity of the averments set forth in this paragraph and, such being the case, said averments are deemed denied and strict proof thereof is demanded at trial. 11. Denied. It is specifically denied that Defendant was aware that Plaintiff expected to be paid for the shipping container where, as here, the shipper cancelled the move. Furthermore, it is customary within the industry that no such charges are levied or expected under such circumstances of a cancelled shipment. 12. Denied. ACE is without sufficient information upon which to form a belief as to the truth or falsity of the averments set forth in this paragraph and, such being the case, said averments are deemed denied and strict proof thereof is demanded at trial. 13. Denied. ACE is without sufficient information upon which to form a belief as to the truth or falsity of the averments set forth in this paragraph and, such being the case, said averments are deemed denied and strict proof thereof is demanded at trial. 14. The averments contained in this paragraph set forth a conclusion of law to which no responsive pleading is required. WHEREFORE, Defendant moves your Honorable Court to dismiss Plaintiffs Complaint. Res 11 submitt F RI ARO, ESQUIRE 590 Rutter Avenue Kingston, PA 18704 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD., Plaintiff, VS. ACE MOVING AND STORAGE CORPORATION. Defendant No. 07-3196 CIVIL ACTION CERTIFICATE OF SERVICE I, FREDERICK W. ALCARO, ESQUIRE, do hereby certify that I did serve a true and correct copy of Defendant's ACE MOVING AND STORAGE CORPORTATION'S, Answer relative to the above matter, upon counsel for Plaintiff, at the address noted below by forwarding the same via First Class Mail, postage prepaid, this 19'h day of June, 2007, and further, that I mailed the original for filing to the Prothonotary in and for Cumberland County, Pennsylvania, at the following address: Ronald Amato Suite 100, Commerce Square 107 North Commercy Way Bethlehem, Pa. 18017-8930 Prothonotary - Cumberland County 17013 ERICK W. ALCARO, ESQUIRE Attorney for Defendant, Ace Moving & Storage Attorney I.D. # 17221 400 Third Avenue, Suite 109 Kingston, PA. 18704 (570) 288-7799 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD., Plaintiff, VS. ACE MOVING AND STORAGE CORPORATION. Defendant No. 07-3196 CIVIL ACTION VERIFICATION I, FREDERICK W. ALCARO, ESQUIRE, hereby certify that I am counsel for the Defendant, ACE MOVING & STORAGE, CORP.,; that I am authorized to make this verification on behalf of the Defendant; and that the facts set forth in the foregoing Answer to the Complaint in the above captioned matter, are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of I authorities. to unsworn falsification to 9CK W. ALCARO, ESQUIRE, for ACE MOVING & STORAGE CORP Date: n "? c? COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD. No. 07-3196 Civil Plaintiff VS. CIVIL ACTION ACE MOVING AND STORAGE CORPORATION Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly substitute of record the enclosed Verification of Kenneth Mercado for the Verification previously filed with the Complaint, in the above matter. AMATO AND ASSOCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Jun. 12.. 2007 9:44AM AMATO AND ASSOCIATES PC D-2 r 2i2 YFRIFtCA*nMd ? states Thai hetshe is the ? ? ? of z - , ftirAfff In €hit *C-do , mid vvifies that ft aunts nude In tha Attached Cwuc Wm mm ate aat the best of h )w knowledge, Infarrrmtion and b*W. The undersigned undamterd that the statements herein are Taxk vjb*t to In pwwkies of 19 FA C.S. 64W4 *f oc+ iv %%AuiI4v'k%Oi+i 1wsv ?wv??+rr?t w autberlties_ 0 ?' Intermove, LTD. VS. - Ace Moving and Storage Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3196 CIVIL 19 RULE 1312-1, The Petition for Appointment of Arbitrators shall be substantially in the following form; PETITION FOR APPOINTKENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Ronald Amato, Esquire , counsel for the plaintiff=/dam 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 $ $1,727.11 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: Frederick W. A learn, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectf y s ted, ORDER OF COURT Ronald Amato, Esquire AND NOW, , 19 , in consideration of the foregoing petition, Esq., Esq., and ,Esq., are appointed arbitrators in the above-captioned action (or actions) as prayed for. By the Court, P. J. "?° ? ?? ? ? ?? 9.?. d A 0 V(?Y_•w Yw R T V V v?ri ?`r ? ? -;; r`. r t..?'h, .w+ ?i` ? /` AUG 882D07r" Intermove, LTD. VS. Ace Moving and Storage Corporation . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3196 CIVIL 19 RULE 1312-1t 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 plaintiff/dam 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 $ $1,727.11 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: Frederick W. Alcarop Faguire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectf y s wed, rAl ORDER OF COURT Ronald Amato, Esquire AND NOW, in consideration of the 4? Ae A-r3 foregoing petition, &Lfde?& . -0-Aw Esq., Esq., and ,Esq., are appointed arbitrators in the above-captioned action (or actions) as prayed for. the Co , ,, ?? CAI P. J. 40- d V V jO &As tile 4. fl-b L CIS- a L CZ 30 Alm COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INTERMOVE, LTD. Plaintiff No. 07-3196 Civil VS. ACE MOVING AND STORAGE CORPORATION CIVIL ACTION Defendant(s) JOINT PRAECIPE TO DISCONTINUE WITH PREJUDICE TO THE PROTHONOTARY, CUMBERLAND COUNTY: Please discontinue the above-captioned case with prejudice. Amato and Associates, P.C. By: Ronald Amato Attorney ID #32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 Alcaro & Maguire Bv: Frederick W. Alcaro, Esquire Attorney for Defendant 590 Rutter Ave KINGSTON PA 18704 570/288-7799 <", ?-.?, _ .. :°.1 :_ a ,. C. ,? 'Cf