The URL can be used to link to this page

Home My WebLink About08-0900ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7159 Attorney for Plaintiff TRI COUNTY BUSINESS SERVICES, IN THE COURT OF COMMON PLEAS INC. d/b/a Manpower CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA NO. J)$- 90f7 lerm VILLAGECRAFT FACTORY DIRECT, INC. d/b/a VILLAGECRAFT ;CIVIL ACTION -LAW CONTRACT FURNISHINGS, L.P. Defendant(s) NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. 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 suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 TRI COUNTY BUSINESS SERVICES, INC. d/b/a Manpower Plaintiff v VILLAGECRAFT FACTORY DIRECT, INC. d/b/a VILLAGECRAFT CONTRACT FURNISHINGS, L.P. Defendant(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0P- ?ro .l _Z CIVIL ACTION - LAW COMPLAINT The Plaintiff, TRI COUNTY BUSINESS SERVICES, INC. d/b/a Manpower, by its 1 2 attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of EIGHTEEN THOUSAND SIX HUNDRED TWENTY-TWO DOLLARS AND FIFTY-FIVE CENTS ($18,622.55), along with interest thereon at the statutory rate from January 26, 2008, upon a cause of action of which the following is a statement: The Plaintiff, TRI COUNTY BUSINESS SERVICES, INC. d/b/a Manpower, is a foreign business corporation authorized to do business in the Commonwealth of Pennsylvania, having its principal office and place of business at 5301 North Ironwood Road, Milwaukee, WI 53217. The Defendant, VILLAGECRAFT FACTORY DIRECT, INC. d/b/a VILLAGECRAFT CONTRACT FURNISHINGS, L.P., is a corporation organized and existing underthe laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 1446 Holly Pike, Carlisle, Cumberland County, PA 17015. F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\MANPOWER 33964.wpd 2 3. On various dates and for various amounts Plaintiff, at the special instance request of the Defendant, provided temporary employment services to Defendant and for Defendant's benefit, to the total amount of Sixteen Thousand One Hundred Ninety- Three Dollars and Fifty-Two Cents ($16,193.52) as set forth on Plaintiffs Statement of Account, a true and correct copy of which is attached hereto, marked Exhibit "A" and made a. part hereof. 4. The prices charged for said labor performed and services provided were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant promised and agreed to pay to Plaintiff. 5. Due to Defendant's default in payment of said amount due and owing as aforesaid, interest has been added to said account in the total amount of Two Thousand Four Hundred Twenty-Nine Dollars and Three Cents ($2,429.03), as shown on Exhibit "A" hereto. 6. The balance due and owing by Defendant to Plaintiff is the sum of Eighteen Thousand Six Hundred Twenty-Two Dollars and Fifty-Five Cents ($18,622.55), as appears by Exhibit "A" hereto. 7. Plaintiffs Invoices are not attached to this pleading due to the voluminous nature of same and have previously been provided to Defendant. F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\MANPOWER 33964.wpd 3 8. Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of EIGHTEEN THOUSAND SIX HUNDRED TWENTY-TWO DOLLARS AND FIFTY-FIVE CENTS ($18,622.55), together with interest as set forth herein. Respectfully submitted, KODAK & IMQL-UVI. P.C. Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney ID No. 18041 Attorney for Plaintiff F:\ USER\ ROBIN\CCP&DJ CMPS\ CCP COMPLAINTS\ MANPOWER 33964.wpd 4 JAN 2 5 2008 STATEMENT FROM: Manpower Inc Milwaukee, WI TO: Contract Furnishing LP 144 Holly Pike Carlisle, PA 17015 PRINCIPAL: $16,193.52 INTEREST: $2,429.03 ATTY/COLL COSTS: $0.00 SUB TOTAL: $18,622.55 PAYMENTS: TOTALFOR PAYMENTS: $0.00 GRAND TOTAL: $18,622.55 VERIFICATION I, ROBERT D. KODAK, state that I am not a party to the action but that, at the request of the Plaintiff, TRI COUNTY BUSINESS SERVICE, INC. D/B/A MANPOWER, and based upon knowledge, information, records and documents supplied to me by the Plaintiff, the averments set forth in Plaintiffs Complaint are true. A Verification executed by the Plaintiff can be supplied at time of trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Robert D. Kodak, Esquire Dated: 3 coo A' ?? 0 0 U lJ e D ?,, , r, SHERIFF'S RETURN - REGULAR CASE NO: 2008-00900 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TRI COUNTY BUSINESS SERVICES VS VILLAGECRAFT FACTORY DIRECT IN TIMOTHY BLACK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VILLAGECRAFT FACTORY DIRECT INC DBA VILLAGECRAFT CONTRACT the DEFENDANT , at 1455:00 HOURS, on the 14th day of February-, 2008 at 1446 HOLLY PIKE CARLISLE, PA 17015 by handing to HARRY HELM, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge / .2l9 010 F' `?,,, 18.00 4.80 .58 10.00 .00 33.38 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 02/15/2008 KODAK & IMBLUM By : Deputy Sheriff of A. D. TRI COUNTY BUSINESS SERVICES, IN THE COURT OF COMMON PLEAS INC. d/b/a Manpower Plaintiff ENNSY VANIAOUNTY, v NO. 08-900 CIVIL TERM VILLAGECRAFT FACTORY DIRECT, INC. d//b/a VILLAGECRAFT CIVIL ACTION - LAW CONTRACT FURNISHINGS, L.P. Defendant(s) TO. PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT TUDGMENT Please enter judgment in favor of Plaintiff and against Defendant(s) VILLAGECRAFT FACTORY DIRECT, INC. d/b/a VILLAGECRAFT CONTRACT FURNISHINGS, L.P., named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint $18,622.55 Interest at the statutory rate of 6 % per annum from January 26, 2008 5M.66 Total = $19,181.21 I hereby certify that a written Important Notice of the intent to file this Praecipe was mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice is attached. KODAK & IMBLUM, P.C. By Robert D. Kodak, Attorney for Plaintiff DATED: 8101108 Judgment entered and damages assessed as above. 62?? rothonotary LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION Robert D. Kodak 407 NORTH FRONT STREET Gary J. Imblurn POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 www.kodak-imblum.com July 8, 2008 VILLAGECRAFT FACTORY DIRECT INC DBA VILLAGECRAFT CONTRACT FURNISHINGS 1446 HOLLY PIKE CARLISLE PA 17015 Telephone 717.238.7152 Facsimile 717.238.7158 FILE COPY RE: Tri County Business Services, Inc. d/ b/ a Manpower VS: Villagecraft Factory Direct, Inc. d/b/a Villagecraft Contract Furnishings, L.P. Our File No. 33964 No. 08-900 Civil, Court of Common Pleas Cumberland County, Pennsylvania Gentlemen: In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed a responsive pleading to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter judgment against you in the amount as set forth in the Complaint. Very truly yours, RDK/rdk enclosure cc PAUL HOSSE DIST SUPERVISOR EULER HERMES UMA PO BOX 1672 LOUISVILLE KY 40201-1672 KODAK & IMBLUM, P.C. Robert D. Kodak robert.kodak@kodak-imblum.com 126665 TRI COUNTY BUSINESS SERVICES, INC. d/b/a MANPOWER Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-400 CIVIL VILLAGECRAFT FACTORY DIRECT, INC. d/b/a : CIVIL ACTION - LAW VILLAGE CRAFT CONTRACT FURNISHINGS, L.P. Defendant FILE COPY IMPORTANT NOTICE TO: VILLAGECRAFT FACTORY DIRECT. INC. d/b/a VILLAGECRAFT CONTRACT FURNISHINGS, L.P. , Defendant(s) DATE: July 9, 2008 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLYOR 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 MAYBE ENTRED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE STE FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAYWER, 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 NOT FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, PA 17013 717.249.3166 Q ?Q ? Q 9u C7 -n ?a 1 d .- ?3 cn c:) TRI COUNTY BUSINESS SERVICES, IN THE COURT OF COMMON PLEAS INC. d/b/a Manpower CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA v NO 08-900 CIVIL TERM VILLAGECRAFT FACTORY DIRECT, INC. d/b/a VILLAGECRAFT CA71L ACTION - LAW CONTRACTFURNISHINGS, L.P. Defendant(s) TO: F RY DIRECT, C. dlhia)MLAGECRAFT C NTRA FURNISHINGS L.P., Defendant(s) You are hereby notified that on ADA + _ . 204 the following (judgment) has been entered against you in the a ve-captioned case. judjneut pntmd in the amount of SMM.21, DATE: 0. a thonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: VILLAGECRAFT FACTORY DIRECT INC D/B/A VILLAGECRAFT CONTRACT FURNISHINGS LP 1446 HOLLY PIKE CARLISLE PA 17013