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Home My WebLink About08-4465Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, Plaintiff, V. HOUSE OF JONLI BRIDALS and GIGI T. WILLIAMS Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No. O$ 1414 (05 CIVIL ACTION -LAW JURY TRIAL DEMANDED COMPLAINT 0,;V1 I `,(erg Plaintiff, Allegro Designs, LLC, by and through it's undersigned counsel, Archer & Archer, P.C., files the following Complaint against Defendants, House of JonLi Bridals, and Gigi T. Williams, and in support thereof avers as follows: 1. Plaintiff, Allegro Designs, LLC ("Plaintiff'), is a Pennsylvania Limited Liability Company with a principal place of business located at 94 Eastgate Drive, Camp Hill, Pennsylvania 17110. 2. Defendant, House of JonLi Bridals, through information and belief, is a Maryland company with it's principal place of business located at 3287 Plaza Way, Waldorf, Maryland 20603. 3. Defendant, Gigi T. Williams, is an adult individual, through information and belief, the sole member of House of JonLi Bridals and maintains a place of business located at 3287 Plaza Way, Waldorf, Maryland 20603. 4. At all relevant times, Plaintiff is in the business of manufacturing and wholesale distribution of children's formal wear and dresses. 5. Through information and belief, Defendant, at all relevant times, is 1 engaged in the retail sale of formal wear and dresses. 6. At all relevant times, Defendant maintained a regular stream of business and contact with the Commonwealth of Pennsylvania, in particular within Cumberland County, as a result of Defendant's regular and repeated business contacts with the Plaintiff and others. 7. Plaintiff and Defendant had an ongoing business relationship whereby Plaintiff distributed dresses for sale that were purchased by the Defendant. 8. Pursuant to the Terms and Conditions, Defendants agreed to personal jurisdiction of the Commonwealth of Pennsylvania for all disputes with Plaintiff. 9. On or about October 22, 2007, Defendant executed Plaintiff's "Terms and Conditions" to be applicable to and govern all subsequent transactions between the parties, which are attached hereto and incorporated herein by reference as Exhibit "A." 10. At Defendant's request, Plaintiff processed orders for merchandise more fully described in Plaintiff's invoice numbers 12801, 12844, 12893 and 12905, attached hereto and incorporated herein as Exhibit "B." 11. The principal amount due for the above-referenced invoices if $853.00 for merchandise, shipping and handling charges. 12. Defendants failed to accept delivery of Plaintiff's merchandise upon delivery, causing the merchandise to be returned to the Plaintiff. 13. Despite Plaintiff's efforts, Plaintiff has been unable to resell the custom items that were ordered by the Defendants. 14. Pursuant to the terms and conditions agreed to by the Defendants, Defendant agreed to pay Plaintiff the sum of $50.00 for all refusals. 15. Pursuant to the terms and conditions agreed to by the Defendants, Defendants agreed to pay storage fees, as well as reasonable attorney's fees and interest 2 for all refused merchandise. 16. The total sum of refusal fees due from the Defendant to the Plaintiff is $250.00 on the invoices. The total sum of storage fees due from the Defendants to the Plaintiff is $120.00 on the invoice. The total sum of interest due and owing from the Defendant to the Plaintiff is $70.83 to date. 17. Pursuant to the Terms and Conditions signed by Defendant, Gigi T. Williams, agreed to the personally liable for all charges incurred by House of JonLi Bridals. 18. Pursuant to the Terms and Conditions signed by Defendant, Gigi T. Williams, Plaintiff is entitled to costs and attorney's fees. 19. Despite Plaintiff s repeated demands for payment, Defendant refuses to pay Defendant the sums due and owing. FIRST COUNT - BREACH OF CONTRACT 20. The allegations of the proceeding paragraphs 1-19 are incorporated herein by reference as though set forth herein at length. 21. Defendants' request for goods and services provided herein and Plaintiff s agreement to provide those goods for valuable consideration constitute a valid and binding contract between the parties. 22. The Terms and Conditions were applicable to and governed each of the transactions alleged herein. 23. Despite Plaintiff s complete performance under the contract between the parties, Defendant has breached the contract by failing to tender payment thereon. 24. By reason of the facts aforesaid, Defendant has materially breached its obligations under the contract between the parties, all to the damage of the Plaintiff in the amount of $1,293.83, plus continuing accrued interest thereon. 3 WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $1,293.83 plus continuing accrued interest and costs of this action; and b. for attorney's fees; and c. any other relief deemed appropriate and just by the Court or to which the Plaintiff is entitled as a matter of law. SECOND COUNT - QUANTUM MERUIT 25. The allegations of the proceeding paragraphs 1 - 24 are incorporated herein by reference as though set forth at length. 26. Defendant, as stated herein, requested the custom goods from the Plaintiff. 27. The Plaintiff fully filled the orders requested by the Defendant, who knew Plaintiff would expect payment therefore. 28. The market value of the goods and services ordered by Defendant is $853.00. 29. It would be unjust for Plaintiff not to be paid for the value of its goods, together with the service charges and interest alleged herein. WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $853.00 plus continuing accrued interest and costs of this action; and b. for attorney's fees; and c. any other relief deemed appropriate and just by the Court or to which the Plaintiff is entitled as a matter of law. 4 THIRD COUNT - ACCOUNT STATED 30. The allegations of the proceeding paragraphs 1 - 29 are incorporated herein by reference as though set forth herein at length. 31. Plaintiff maintains a book account regarding Defendants' purchases. According to the records, Defendants owe Plaintiff the sum of $1,293.83 for goods and services requested by Defendant. 32. The funds due and owing Plaintiff by the Defendant are fair and reasonable for the goods and services provided. 33. Although demands for payment have been made, Defendant continues to refuse to pay the amount due and owing Plaintiff. WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $1,293.83 plus continuing accrued interest and costs of this action; and b. for attorney's fees; and c. any other relief deemed appropriate and just by the Court or to which the Plaintiff is entitled as a matter of law. Respectfully Submitted, Archer & Archer, P.C. Dated: July 21, 2008 By: 1 Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiff Exhibit "A" 2' I°:.l2PPS ?3: 2S 7177512343 I--. WV W -W" -1 ? Iffa r er or Tennis and Conditions The Mowing tex x and enditions aply to all traloteactioas between you (herein, " 1Etelaiier/Buyer"), the undersigned, and Allegro Designs, LI,C d/h/a The Ladybug Collection (herein, "Allegro's): 1. 1El3C•1iF: Alkgto reserves the right to place any soeount on a C.O.D.-basis at anytime without notice. We do offer edredit card tertm and prepayment, 2, r All orderm are considered made to order. Orlon must be (axed; phone orders will not be aoaepted. Please allow 6-8 weeks for delivery. leash delivery under 6 weeks is available for an additional charge. A-t nation will be faxed within ays o a art ors ph" N one w If you rho not m-m- v t fPlBtltlh;'tlne order should be consideted not planed. 3. REFUSALS: Absolutely No Rotusals! In the event of refused menehandlse upon delivery, RetailerBuyesr's aoxouat will aatmutlatly he placed on hold status sad no crden wilt be shipped until the mutter is resolved, There will also be a refusal fee of S50.00 and freight charges appliod• Ir+ the event of refuses to accept delivery of mera- an hse, Retailer/lluysr will be meponsible for cost of muchandise and any necessary reasonable collections costs, Including intmst calculated at 16% per annum, court coats and attomey'a films Incurred by A11W, 4, RETURNED CMff9XS&QLUCT1QNS a There will be a $43.00 charge for each returned ohwL The Retailer/Rnyer will he responsible fbr the full balance of any invoice and all feed accrued Includin& but not limited to, Inmost calculated at 16% per annum, as well AS any naeea6ary reasonable collections costs, including court costs and attorney's fees incurred by Allegro. Allegm rororvas the eight to refer any returned checks to authWties for prosecution. S. Rte: A.) Upon delivery, Retaier/Buyer is ttesmsible for the Inspections of all merchandise, Any'probkrns must be ropttrtarl wide W float (3) days after ifte receipt of said ma thandise. flu Ladybuo CoMecrkn is not responsible for any dye lot or fabric variations. The Ladybug Cvflectian is nut responsible for any returns if not notified within the 3-day grace period. S.) No merchandise will be accepted for retum without our 8ivan Return Merchandlse Authorization TMA) number. No exceptions will ba mede. C.) Them will be no tench or excl onges on special odds, `_. e, CANCELtr.A'r r All onions arc wroldered made to order. The Ratallen'Buyer has the right to cancel any Order within 72 boars from the time it we placed in writing. Verbal cancellations will not be accepted. 9. SRI : All orders will be shipped UPS-ground unless otherwise specified on your ofder confirmation. Insurance, sbipping and handling ehargn an the customer's responsibility. No discounts for freight will be occq ed. 10. In order' to maintain the Image of The Ladybug Collection, no stop is to aver advertise our muchandise on the internal at discounted pricer. We do not stnott stones who sell directly over the Irate et. This pmtlae undertalm our full-service Mullen. I I. All completion dataa trust be battered as stated on the order or sooner. The Ladybug Collection is not fmpnncihae for any delays due to shipping, nianufactraing, or natural disasters. 12. The Ladybug Collection reserves the right to refuse to do business with any Buyer or Retailer at any title. 13. Tlw Ladybug Collactim reserves tits right to close any amoont without any reason at any rims. 14. The person or persons signing this contract gives permission to be held personally responsible for all outstanding debt. This may tntult in a lien against passo nal or red property. 13. The Retailerll'fuyer agrees to bs governed by the laws of the Commonwealth of Pon nsylvania. R WterBuyw consents to dta juti*& don of the Commonwealth of Pennsylvania for any traotactionai dispa with Allegro. Date! Store Narrle! ?i Nana: GAI'T. W gV6VVC - e7 0_ 1-1 Address: r X 02/06 01-31-2008 15:31 ARCHER AND ARCHER PC 7172338675 PAGE2 Exhibit "B" T2: 3S 7177612343 ? ? ?lpr P .O. BOX 734 Camp Hill, PA 17001 house of JonU 3287 Plate Way Waldorf MD 20803 house of Joni Gigi Williams 3287 Plan Way Waldorf, MD 20503 Phone. FAX: 301-396-8555 301-396-8558 Sales Rep Ship Date 1212712007 P.O. # Stock Otis Dab 12/27/2007 Terms cod Lxowe 1071 Cha rnpagne with Brown size 3 95.00 95.00 COD COD 9.00 8.00 Shipping and ... Shipping and Handling 13.00 13.00 Refusal Refusal Fee 50.00 50.00 1082 Ivory with chocolate organza sash size 2 95.00 95.00 1078 ivory sire 5 20.00 20.00 COD COD 9.00 9.00 Shipping and ... Shipping and Handling 13.00 13.00 Refusal Refusal Fee 50.00 50.00 Storage Fee 30.00 30.00 Collections Fee 163.60 163.60 Interest 88.02 88.02 Total $623.62 info WybugcolloctioMC;0M Phone # (717) 761-2344 PaymenbJCradits $0.00 Www,)24ybu8C011eCd0n,C0M FAX # (717) 761-2343 Balance Due $623.62 01-31-2008 15:31 ARCHER AND ARCHER PC 7172338675 THE LADtTL* COLLECTO PAGE 03/06 Dab 12/2712007 Invoice ll 12801 PAGE3 ?' /c^^".r'2P?'° ??: ?6 7177612343 THE LADY9-6 COLLECTO PAGE 04/06 /rfw G P.O. BOX 7.34 Camp Hill, PA 17001 house of JonU 3287 Plate Way Waldorf MD 20603 Phona: PAX: 301-396-8555 301-396-8558 P.O.8 stock Terms cod 1059 sWWpink sits 4 1141 pink size 4 1030 ivory/sable size 8 COD COD Shipping and ... Shipping and Handling Refusal Refusal Fee Storage Fee COD COD Shipping and ... Shipping and Handling Collections Fee Interest Daft 1/1012008 Invoice S 12844 house of JonLi Gigi Wars 3287 Plaza Way Waldorf, MD 20803 Shlp Dote 1110/2008 Dw Date 1/10/2008 Sales Rep ?.I.ovre 99.00 99.00 95.00 95.00 95.00 95.00 9.00 9.00 13.00 13.00 50.00 50.00 30.00 30.00 9.00 9.00 13.00 13.00 185.20 186.20 92.51 92.51 Toted $670.71 Payments/Credits $0.00 Bananas Due $670.71 info@1ugoo cn.com Phow 0 (717) 761-2344 www.1sdybugco11= ion.com FAX # (717) 761-2343 01-31-2008 15:31 ARCHER AND ARCHER PC 7172338675 PAGE4 1l?./2?'O X3:35 7177612343 , 01 laVAC&In lei 13,0- BOX 734 Camp Hill, PA 17001 house of JonU 3287 Plaza Way Waldorf MO 20803 Phone: 301-396-8555 P.Q. lit stock Terms cod FAX: 301-396-8558 THE ?-ADYRUG M-LECTO PAGE 05/06 Date 1/13/2008 invoice 0 12893 house of Jonl-l Gigi Williams 3287 Plaza Way Waldorf, MD 20503 some Rep Ship Data Duo Data LlJowt 1/13/2008 1/13/2008 1052 Perlwinkle/White Size 5 89.00 89.00 COD COD Shipping and ... Shipping and Handling Refusal Refusal Pee Storage Fee COD COD Shipping and ... Shipping and Handling Collactions Fee Interest info@ladybugcollcction.com Phone # (717) 761-2344 WWW-Ia y S Uecdo>a.com FAX # (717) 761-2343 01-31-2008 15:32 ARCHER AND ARCHER PC 7172338675 9.00 9.00 13.00 13.00 50.00 50.00 30.00 30.00 9.00 9.00 13.00 13.00 86.20 85.20 47.71 47.71 4b Total $345.91 Paymonts/Crodits $0.00 9aiance Due $345.91 PAGE5 ?;.l?:.l22?° ?':35 7177612343 cs?u? Q P.O. SOX '734 Camp Hill, PA 17001 house of JonU 3287 Plus Way Waldorf MD 20803 house of JonU 0191 Williams 3287 Pinta Way Waklorf, MD 20603 Phone- FAX: 301-396-8555 301-396-5558 Sala Rep Ship Deb 1/14/2008 P.O. * stook Due Date 1/1412008 LTowo Terms cod 1163 Ivory/Champagne Size 3 89.00 89.00 GOD COD 9.00 9.00 Shipping and... Shipping and Handling 13.00 13.00 Refusal Refusal Fee 50.00 60.00 Storage Fee 30.00 30.00 COD COD 9.00 9.00 Shipping and ... Shipping and Handling 13.00 13.00 Coles Fee 85.20 86.20 Interest 47.72 47.72 info@ladybugcollecdom.com Phone 0 (717) 761-2344 www.l3dybu9C0Iieat 0n-cGM FAX # (717) 761-2343 01-31-2008 15:32 ARCHER AND ARCHER PC 7172338675 THE LADYBUG M-LECTO PAGE 06/06 Dab 1114/2008 Invoice" 12905 Total PaymenWCmdlb Balance Due $345.92 $0.00 $346.92 PAGE6 VERIFICATION I, Thomas A. Archer, Esquire, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: July 24, 2008 I (? 1 Thomas A. Archer, Esquire 0 ° ? ? U1 C c-- cil ._ . Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. DOCKET No.: 08-4465-Civil Term HOUSE OF JONLI BRIDALS : CIVIL ACTION -LAW and GIGI T. WILLIAMS JURY TRIAL DEMANDED Defendants PRAECIPE TO PROTHONOTARY: Please replace the Verification of Plaintiff's counsel with that of the Plaintiff, attached, to Plaintiff s Complaint in this matter. Respectfully Submitted, Date: September 2, 2008 Archer & Archer, P.C. By: I_ T 1 Y Thomas A. Archer, Esquire Pa Atty. ID # 73293 2515 North Front Street PO Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiff 217-2Q•-200L 14:15 ARCHER AND ARCHED PC 7172338675 /yE3 VERIFICATION 1, William Jupitz, hereby verify that the statements made in the foregoing Complaint arc true and correct to the best of my lmowledge, information and belief. I undem, tend that false statements herein are made subject to the penalties of 18 Pa. C, S. §4904, mlating to unswom falsification to authorities. Date: July 24, 2008 CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: House of JonLi Bridals and Gigi T. Williams 9108 Overlook Trail Fort Washington, MD 20744 Date: September 2, 2008 Jessica R. Porter, Paralegal C:J C Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, 95 Eastgate Drive Camp Hill, PA 17011 Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. HOUSE OF JONLI BRIDALS and GIGI T. WILLIAMS, 9108 Overlook Trail Fort Washington, MD 20744 Defendants. DOCKET No. 08-4465-Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS, AND NONMILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for Plaintiff and against Defendants above- named only and assess damages certified to be calculated as a sum certain from the Complaint, as follows: Principal $853.00 Refusal fees: $250.00 Storage fees: $120.00 Interest $70.83 TOTAL: $1,293.83 Understanding that false statements made herein are subject to penalty under 18 Pa. C.S.A. § 4904, Unworn Falsification to Authorities, I verify that: 1. The above are the precise last known addresses of the parties. 2. The annexed notices(s) of intention to file a Praecipe (Exhibit "A") were mailed to all parties Defendants and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this Praecipe. 3. The said Defendants are not in the military service of the United States or otherwise within coverage of the Soldiers and Sailors Relief Act and are over 18 years of age (Exhibit `B"); THIS ?^A DAY OF ?Ut , 2008, JUDGMENT IS ENTERED IN FAVOR OF PLAINTIFF AND AGAINST DEFENDANTS BY DEFAULT FOR WANT OF AN ANSWER AND DAMAGES ASSESSED AT THE SUM OF $1,293.83 AS PER THE ABOVE CERTIFICATION. NOTICE GIVEN PURSUANT TO Pa.R.C.P. 236. Respectfully submitted, ARCHER & ARCHER, P.C. By: Thomas A. Archer, Esquire PA ID# 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-0056 717.233.8676 Attorney for Plaintiff PpZiTHONOTAff 7 Exhibit "A" i nUM" A. ARI nER, LbQ. NEW JERSEY OFFICE: Admitted PA A NJ 2515 NORTH FRONT STREET JENNIFER BUSH ARCHER, ESQ. P.O. BOX 5056 1011 ROUTE 22 WEST, ST. 100 Admitted PA A NJ HARRISBURG, PENNSYLVANIA 17110-0056 P:O. BOX 6402 BRIDGEWATER, NJ 08807 (717) 233-8676 (908) 995-2000 FAX: (717) 233-,8675 FAX: (908) 995-2104 www.archerandarcher.com October 6, 2008 House of JonLi Bridals and Gigi T. Williams 9108 Overlook Trail Fort Washington, MD 20744 RE: Allegro Designs, LLC v. House of JonLi Bridals and Gigi T. Williams Cumberland. County CCP Docket No.: 08-4465-Civil Term Dear Ms. Williams: °Enclosed please find a Ten (10) Day Notice, of Default regarding this matter because you have failed to take action with respect to a Complaint that was served upon you via certified and regular mail on August 21, 2008. This is a serious matter. If you fail to take action with respect to the afore- mentioned Complaint, the Plaintiff may take a Default Judgment against you and you could lose rights or property as a result of your inaction. Please be guided accordingly. Very truly yours, Thomas A. Archer TAA/jrp Enc. Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. DOCKET No.: 08-4465-Civil Term HOUSE OF JONLI BRIDALS CIVIL ACTION -LAW and GIGI T. WILLIAMS JURY TRIAL DEMANDED Defendants IMPORTANT NOTICE TO: House of JonLi Bridals and Gigi T. Williams 9108 Overlook Trail Fort Washington, MD 20744 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A RESPONSE TO THE COMPLAINT THAT WAS SERVED UPON YOU. UNLESS YOU ACT WITHIN TEN (10) 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 THIS NOTICE TO A LWAYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATED: October 6, 2008 By: Thomas A. Archer, Esquire 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-0056 (717) 233-8676 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: House of JonLi Bridals and Gigi T. Williams 9108 Overlook Trail Fort Washington, MD 20744 Date: October 6, 2008 A Ai?) ?O? U Jessica R. Porter, Paralegal Exhibit "B" Request for Military Status Department of Defense Manpower Data Center AN& Military Status Report Pursuant to the Servicemembers Civil Relief Act NOW Page 1 of 1 OCT-24-2008 07:43:54 * Last Name First/Middle Begin Date Active Duty Status Service/Agency WILLIAMS GIGI T Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 41 1w Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USCS Appx. §§ 501 et seq) (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BSONERHJOIM https://www.dmde.osd.mil/scra/owa/scra.prc_Select 10/24/2008 CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: House of JonLi Bridals and Gigi T. Williams 9108 Overlook Trail Fort Washington, MD 20744 Date: January 27, 2009 Jessica R. Porter, Paralegal 142 ?,, , - , 4 IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENSYLVANIA CIVIL DIVISION ALLEGRO DESIGNS, LLC, Plaintiff, v HOUSE OF JONLI BRIDALS and GIGI T. WILLIAMS Defendants : DOCKET No.: 08-4465-Civil Terns : NOTICE OF FILING JUDGMENT Notice is hereby given that a .in the above-captioned matter has been entered against you in the amount of (+ ) A copy of all documents filed with the Prothonotary in support of the within judgment is J are enclosed. C g Prothonotary By: Deputy If you have any questions regarding this Notice, please contact the filing party: Thomas A. Archer 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 717-233-8676 (This Notice is given in accordance with Pa.R.C.P. No. 236.) r "6 Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, Plaintiff, V HOUSE OF JONLI BRIDALS and GIGI T. WILLIAMS Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No.: 08-4465-Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED PROOF OF SERVICE The following Defendants were served by certified and regular mail with the Complaint: House of JonLi Bridals and Gigi T. Williams, 9108 Overlook Trail, Fort Washington, Maryland, 20744. A copy of the green card is attached hereto as Exhibit «A" Dated: January 27, 2009 By: Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiff 1 Exhibit "A" r -? complete a Cmitpide items 1, 2, and 3. Also item 4 It Restricted D*4wY b d@Wmd. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the book of the mailpieoe, or on the front If space permits. 1. Article Addressed to: eIgiT. VU)lcArr5 and Rouse o-F,)oin1,i OfICuis alo8 Ovc+?loo?-_i"?all AL C3 APM I& ...- by (Rlnted Nome) I C. Dan of Delivery D. Is ddmy eddnasIN60 ! 14 O Yes ` K YES, enter delivery aft!'" 0 No 10(+ WO-5t11 rVOOV1 MO 2-0 -M 3. o Wand MIA 4. Reetrbnd DOM 2. Ardde"umber (na nfsrnommvk o 7008 0500 0002 0476 PS Form 3811, February 2004 Domeatic Return Receipt O Mau um Racelpt for McR.itandhe 0 C.O.D. ry7 (Exda reel ? Yes 4407 toz-at•t?o S , r CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: House of JonLi Bridals and Gigi T. Williams 9108 Overlook Trail Fort Washington, MD 20744 Date: January 27, 2009 AaQ - -10? Jessica R. Porter, Paralegal ,^ j t'' rV c .z i ` ' ' 1