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Home My WebLink About07-3825 CLASSIC INTERIORS BY LAVERNE d/b/a CLASSIC INTERIORS, Plaintiff v. JOHN F. MIRA and CENTRAL PENN PSYCHIATRIC ASSOCIATES P.C., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLANIA CIVIL ACTION -LAW NOTICE TO DEFEND AND CLAIM RIGHTS 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 Defendant. 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 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas quese presentan mas adelante en las siguientes paginas, debe toma accion dentro de los proximos veinte (20) dias despues de la notification de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra soya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier soma de dinero reclamada en la demanda o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en constra soya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE F,STA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Date: ~011~(~200`~ Gregory R. Reed, Esquire Attorney for Plaintiffs 3120 Parkview Lane Harrisburg, PA 17111 (717) 238-0434 Attorney I.D. No. 23705 CLASSIC INTERIORS BY : IN THE COURT OF COMMON PLEAS LAVERNE d/b/a : OF CUMBERLAND COUNTY, PENNSYLANIA CLASSIC INTERIORS, . Plaintiff :CIVIL ACTION -LAW v. . No. 07 - 3P2.S' ~~~L~~il... JOHN F. MIRA and . CENTRAL PENN PSYCHIATRIC ASSOCIATES P.C., . Defendants COMPLAINT NOW COMES, Classic Interiors by Laverne d/b/a Classic Interiors, by its Attorney, Gregory R. Reed, Esquire, and files the following Complaint: COUNTI Classic Interiors v. John F. Mira Breach of Contract 1. Plaintiff is Classic Interiors by Laverne d/b/a Classic Interiors, a Pennsylvania Corporation, with its principal office located at 5610 Derry Street, Harrisburg, Dauphin County, Pennsylvania 17111. 2. Defendant, John F. Mira, is an individual who resides at 2401 Ascott Way, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred to as "Defendant Mira"). 3. Defendant Mira placed orders with Classic Interiors for carpet, furnishings and merchandise on or about October 24, 2005, December 6, 2005, December 13, 2005 and January 2, 2006 and delivered to Classic Interiors a deposit in the amount of Three Thousand Two Hundred and 00/100 ($3,200.00) Dollars. 4. Defendant Mira agreed to pay Plaintiff s standard rates for labor, consulting services, materials and merchandise. 5. The aforesaid work was completed by Classic Interiors and the merchandise delivered at various times through January 2, 2006. 6. All work was completed in a workmanlike manner. 7. To date Defendant Mira has failed to pay Thirteen Thousand Seven Hundred Forty Seven and 00/ 100 ($13,747.00) Dollars for labor, consulting services, materials and merchandise. 8. Despite Plaintiff's reasonable demands Defendant Mira has failed to pay the balance due and owing. WHEREFORE, Plaintiff demands that judgment be entered against the Defendant Mira and in favor of Plaintiff in the amount of Thirteen Thousand Seven Hundred Forty-Seven and 00/100 ($13,747.00) Dollars, together with said service charges of two (2%) percent per month plus the costs of this action, which amount does not exceed the jurisdictional requirement for compulsory arbitration in Cumberland County. 2 COUNT II Classic Interiors v. Central Penn Psychiatric Associates P. C. Breach of Contract 9. Plaintiff incorporates paragraph 1 hereof by reference thereto. 10. Defendant, Central Penn Psychiatric Associates P.C. is a Pennsylvania professional corporation, with a registered address of 115 South St. John's Drive, Camp Hill, Cumberland County, Pennsylvania (hereinafter referred to as "Defendant Psychiatric Associates"). 11. Defendant Psychiatric Associates placed orders with Classic Interiors for carpet, furnishings and merchandise on or about October 24, 2005, December 6, 2005, December 13, 2005 and January 2, 2006 and delivered to Classic Interiors a deposit in the amount of Three Thousand Two Hundred and 00/100 ($3,200.00) Dollars. 12. Defendant Psychiatric Associates agreed to pay Plaintiff's standard rates for labor, consulting services, materials and merchandise. 13. The aforesaid work was completed by Classic Interiors and the merchandise delivered at various times through January 2, 2006. 14. All work was completed in a workmanlike manner. 15. To date Defendant Psychiatric Associates has failed to pay Thirteen Thousand Seven Hundred Forty-Seven and 00/100 ($13,747.00) Dollars for labor, consulting services, materials and merchandise. 3 16. Despite Plaintiff's reasonable demands Defendant Psychiatric Associates has failed to pay the balance due and owing. WHEREFORE, Plaintiff demands that judgment be entered against the Defendant Psychiatric Associates and in favor of Plaintiff in the amount of Thirteen Thousand Seven Hundred Forty-Seven and 00/100 ($13,747.00) Dollars, together with said service charges of two (2%) percent per month plus the costs of this action, which amount does not exceed the jurisdictional requirement for compulsory arbitration in Cumberland County. COUNT III Classic Interiors v. John F. Mira Quantum Meruit 17. Plaintiff incorporates paragraphs 1 through 8 hereof by reference thereto. 18. The carpet, furnishings and merchandise were delivered to Defendant Mira at the request of Defendant Mira and they continue to be in Defendant Mira's custody, possession and control. 19. Defendant Mira has benefited from Plaintiff's work and the carpet, furnishings and merchandise in the total amount of Thirteen Thousand Seven Hundred Forty-Seven and 00/100 ($13,747.00) Dollars. 20. The balance due Plaintiff for all work done is Thirteen Thousand Seven Hundred Forty-Seven and 00/100 ($13,747.00) Dollars plus service charges of two (2%) percent per month. 4 21. Defendant Mira has neither complained of the quality of the workmanship, carpet, furnishings and merchandise nor of the prices charged for them. 22. Despite Plaintiff's reasonable requests, Defendant Mira has failed to satisfy his debt. WHEREFORE, Plaintiff demands that judgment be entered against Defendant Mira and in favor of Plaintiff in the amount of Thirteen Thousand Seven Hundred Forty-Seven and 00/100 ($13,747.00) Dollars, together with said service charges of two (2%) percent per month plus the costs of this action, which amount does not exceed the jurisdictional requirement for compulsory arbitration in Cumberland County. COUNT IV Classic Interiors v. central Penn Psychiatric Associates P. C. Quantum Meruit 23. Plaintiff incorporates paragraphs 9 through 16 hereof by reference thereto. 24. The carpet, furnishings and merchandise were delivered to Defendant Psychiatric Associates at the request of Defendant Psychiatric Associates and they continue to be in Defendant Psychiatric Associates' custody, possession and control. 25. Defendant Psychiatric Associates has benefited from Plaintiff's work and the carpet, furnishings and merchandise in the total amount of Thirteen Thousand Seven Ht-ndred Forty-Four and 00/100 ($13,747.00) Dollars. 26. The balance due Plaintiff for all work done is Thirteen Thousand Seven Hundred 5 Forty-Seven and 00/100 ($13,747.00) Dollars plus service charges of two (2%) percent per month. 27. Defendant Psychiatric Associates has neither complained of the quality of the workmanship, carpet, furnishings and merchandise nor of the prices charged for them. 28. Despite Plaintiff's reasonable requests, Defendant Psychiatric Associates has failed to satisfy its debt. WHEREFORE, Plaintiff demands that judgment be entered against the Defendant Psychiatric Associates and in favor of Plaintiff in the amount of Thirteen Thousand Seven Hundred Forty-Seven and 00/100 ($13,747.00) Dollars, together with said service charges of two (2%) percent per month plus the costs of this action, which amount does not exceed the jurisdictional requirement for compulsory arbitration in Cumberland County. Date: ~~I`~~41 Gregory R. Reed, Esquire Attorney for Plaintiff 3120 Parkview Lane Harrisburg, PA 17111 (717) 238-0434 Attorney I.D. No. 23705 6 JUN-06-2007 16:21 GREG REED LAW OFFICE VERCFICATION 717 238 8459 P.13 I, L.~vr~a..,z G'~r.~ President of Classic Interiors by Laverne d/b/a Classic Interiors hereby verify that the statements in the foregoing Complaint are based upon information which I have provided to my attorney. I have read the Complaint and the allegations are true and cameo to the best of my knowledge, information, and belief. Howcver, the language of the Complaint is that of counsel; and z~ot my own. To the extent that the contents of this Complaint are that of our attorney, I have relied upon him in makiaa this verification. I understand that the statements therein are made subject to the penalties of IS Pa_ C.S.A. Section 4904, relating to unswom falsification to authorities. Date ~`~ a ~ ~- - resident of Classic Interiors by Laverne d/b/a Classic Interiors TOTAL P.13 +~.. "64 ~ ~ 1/-~~ I C? _. `-! i ! i' i ~ 4 .' ~ _' , ~' r`-i .{ ra ~a f'"J ~' ~''J ~~ .,~ `~ ~ ~k`) ~~ --1 SHERIFF'S RETURN - REGULAR ~ LASE NO: 2007-03825 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLASSIC INTERIORS BY LAVERNE VS MIRA JOHN F ET AL RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MTRA ,T(~HN F the DEFENDANT at 1636:00 HOURS, on the 27th day of June 2007 at 115 SOUTH ST JOHNS DRIVE CAMP HILL, PA 17011 by handing to NANCY RIDER, OFFICE MANAGER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Postage .58 Surcharge 10.00 .00 ~10~'~~ 42.98 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 06/28/2007 CLASSIC INTERIORS BY: ~ i Deputy S riff A.D. ,~ `VASE N0: 2007-03825 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLASSIC INTERIORS BY LAVERNE VS MIRA JOHN F ET AL RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon C''F.NTRAT, PENN PSYCNTATRTC ASSOCIATES PC the DEFENDANT at 1636:00 HOURS, on the 27th day of June 2007 at 115 SOUTH ST JOHNS DRIVE CAMP HILL, PA 17011 by handing to NANCY RIDER, OFFICE MANAGER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 $)09~e~~ 16.00 Sworn and Subscibed to before me this day of , So Answers: R . Thomas Kline `~ 06/28/2007 CLASSIC INTERIORS By : ~ ~i~z~~~~~ Deputy Sheriff A.D.