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HomeMy WebLinkAbout08-4645D Y 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 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 OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH, DEPARTMENT OF LABOR AND INDUSTRY, BUREAU OF BUREAU OF LABOR LAW COMPLIANCE o/b/o Donna Rozycki, Plaintiff V. DELAWARE VALLEY COUNCIL OF AMERICAN YOUTH HOSTELS INC. and TA'JUANNA D. ANDERSON, individually, Defendants CQMPLAINT CIVIL ACTION - LAW DOCKET NO. W. y G %45 & a ?^ 1. Plaintiff is the Bureau of Labor Law Compliance (Plaintiff) of the Commonwealth of Pennsylvania, Department of Labor and Industry, responsible for enforcement of the Pennsylvania Wage Payment and Collection Law (WPCL), act of 1961, P.L. 637, No. 329, 43 P.S. §§ 260.1-260.12. 2. Defendant Delaware Valley Council of American Youth Hostels Inc. (DVC) operates as a Pennsylvania non-profit corporation with a business address located at 1210 Sansom Street, Philadelphia County, Philadelphia, PA 19107. 3. Defendant Ta'Juanna D. Anderson is an adult individual who, at all times relevant to this Complaint, was Executive Director and served as an agent for Defendant DVC with respect to the matters alleged in this Complaint. 41 4. Defendant Anderson is a statutory employer pursuant to the definition of "employer" as set forth in Section 2.1 of the WPCL, 43 P.S. § 260.2a, and is individually liable for the alleged wages and statutory liquidated damages. 5. Plaintiff brings this action against Defendants DVC and Anderson on behalf of their former employee Donna Rozycki (Claimant Rozycki), who is an adult individual with an address of P.O. Box 1324, Harper's Ferry, West Virginia 25425. COUNT I (Wage Claim of Donna Rozycki) 6. Paragraphs 1 through 5 are realleged and incorporated by reference. 7. Under section 9.1(e) of the WPCL, 43 P.S. § 260.9a(e), Claimant Rozycki executed and delivered to Plaintiff an assignment of her wage claim against Defendants. A true and accurate copy of this assignment is appended as Exhibit "A ". 8. Defendants employed Claimant Rozycki as a hostel manager at the Ironmaster's Mansion Hostel HI, located at 1212 Pine Grove Road, Cumberland County, Gardners, PA 17324, from August 2004 through February 7, 2008. 9. Under the agreed-upon terms and conditions of this employment, Claimant', Rozycki earned $5.65, $6.75, and $10 an hour. 10. For the pay periods beginning with September 26, 2005 and endingi February 7, 2008, Claimant Rozycki worked a total of 3,360 hours. 11. Defendants failed to pay Claimant Rozycki her wages from September 26, 2005 to February 7, 2008, for unpaid wages of $24,570.00 {(1,000 hours x $5.65 per' hour = $5,650.00) + (1,440 hours x $6.75 per hour = $9,720.00) + (920 hours x $10 per' hour = $9,200) = $24,570). A true and accurate copy of the Bureau's audit of the 2 t September 26, 2005 to February 7, 2008 payroll summary showing wages owed by Defendants is appended as Exhibit "B. " 12. Defendants are liable to Claimant Rozycki for unpaid wages totaling $24,570.00 under Section 3 of the WPCL, 43 P.S. § 260.3. 13. These wages have remained unpaid for more than 30 days beyond Claimant Rozycki's regular paydays or more than 60 days after proper claim was made without the existence of any good-faith contest or dispute that they are due and owing to Claimant Rozycki. Therefore, Defendants are additionally liable to Claimant Rozycki for statutory liquidated damages in the amount equal of $6,142.50, under Section 10 of the WPCL, 43 P.S. § 260.10 (25% x $24,570.00 = $6,142.50). 19. The total amount of damages and statutory liquidated damages for which Defendants are liable under the WPCL on behalf of Claimant Rozycki is $30,712.50. WHEREFORE, Plaintiff Bureau of Labor Law Compliance requests judgment against Defendants Delaware Valley Council of American Youth Hostels Inc and' Ta'Juanna D. Anderson, individually, on behalf of Claimant Rozycki in the amount of $30,712.50 due under the WPCL, or such other sum as this Honorable Court may determine to be due said Claimant, together with costs of suit and reasonable attorney's' fees under section 9.1(f) of the WPCL, 43 P. S. § 260.9a(f). The amount claimed does not exceed the jurisdictional amount requiring arbitration referral by local rule. Respectfully submitted, Dated: oZ d0? d nifer errier Assistant Counsel 3 Attorney Registration No. 204444 Commonwealth of Pennsylvania Department of Labor and Industry Office of Chief Counsel Labor Law Compliance Division Tenth Floor, Labor and Industry Bldg. 651 Boas Street Harrisburg, PA 17121 Telephone: (717) 787-4186 Counsel for Plaintiff 4 EXHIBIT 64A91 MAR 0 5 2008 FORM BLLC WAGE COMPLAINT ' JUN 2 7 2008 Office use only: WPBC MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and including the reverse side, that are applicable lete all parts ld com h , p ou Collection Law. Persons returning this form s to the specific law or laws under which a complaint is made. RETURN TO: Bureau of Labor Law Compliance J 1301 Labor & Industry Building U Q V o1Q 7Fr Seventh & Forster Streets Harrisburg, PA 17121 ` rl S C Telephone: 717-705-5969 or 1-800-932-0665 , owl 3 FAX: 717-78787--0 0517 PLEASE PRINT: Name of Person Filing Complaint Address - 0 . STREET CITY STA ZIP CODE Date of Birth _ c Y/ Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. 4 1 / (INCLUDE AREA CODE) E-mail Address Nc>L?? Fax Number Type of Work Performed GL ., (- dy'C/ Z2S ??{'u,? e ??? vim! I?e Syr?Cr1i? Location of Employment 7P`/Ke STREET CITY C UNTY STATE ZIP CODEiI va l1 e -LWC-r 1 ? Telephone (?/S ) ?- Company Name ? , if any e•r" t G S? Ski - ?i-?r o t, Contact Person (Against whom Wage Claim is f' ed) ??G1Zyt-? 1 Cl?ldSr?/? Address /a-IC? SaGi 'o V ?`r'2?t ?DAr1 l 12.E f?c? • / ??O STREET CITY COUNTY STATE ZIP CODE Date Hired Are you still employed by the named employer? ? Yes Q No If No, the last date worked i-e-,6 - `L7 Was your termination: dVoluntary Involuntary 1 . Was there a written contract of employment between you and the named employer? ? Yes Vo If Yes, please attach copy. 2. What was your regular payday to be? (check one) ? Weekly N/Bi-Weekly ? Monthly ? Other ? No ? Other (cash) ? v?t? ?!?? 3. Were wages paid to you in a form other than a check. ?"? Yes GLL P.Gl4 L Ly?? To 4. What was the latest rate of pay agreed upon between you and the named employer? V ? Hourly $ J? Weekly $ Other, please explain -77 rl" - What are the TOTAL wages claimed by you? $ _-2-b ;2 4Jam,., _ COMPLETE REVERSE SIDE LLC-9 REV 11-07 (Pagel) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPLIANCE WAGE COMPLAINT FORM Office use only: WP&C MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: PLEASE PRINT: Name of Person Filing Complaint_ Address P- C-> - / 3 STREET V CITY STATE ZIP CODE Date of Birth Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. 1 l 1 - 67 ?44 (INCLUDE AREA CODE) E-mail Address l2.oP4--e- Fax Number ( ) Type of Work Performed 'TI Location of Employment / 2! "z ! (?? ?O1`? /'? STREET CITY COUNTY STATE ZIPMP Company Name, if any VC, C( Cvuu?a /? ?/? L Telephone Contact Person (Against whom Wage Claim is filed) i a ' ?/ r-cu ??a1? a??.?'T4f--?''°?t??? rr Address / ?/O c L Y± "e STREET CITY COUNTY STATE ZIP CODE Date Hired T- - --2 l -? Are you still employed by the named employer? ? Yes [?/No if No, the last date worked I eb ! ?-oo Was your termination: 29/Voluntary ?? Involuntary 1 . Was there a written contract of employment between you and the named employer? El Yes L?1/No If Yes, please attach copy. 2. What was your regular payday to be? (check one) ? Weekly EiBi-Weekly ? Monthly ? Other r ? d'?t 3. Were wages paid to you in a form other than a check? E?I`Yes ? No El Other (cash) 4. What was the latest rate of pay agreed upon between you and the named employer? Hourly S&) , C0 Weekly $Other, please explain What are the TOTAL wages claimed by you? $ ';?- S, --f COMPLETE REVERSE SIDE Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-0665 FAX: 717-787-0517 LLC-9 REV 11-07 (Pagel) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW CO WAGE COMPLAINT FORM Office use only: WP&C MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-0665 FAX: 717-787-0517 PLEASE PRINT: ' Name of Person Filing Complaint C77/L^c 1O Address ) /I STREET CITY STC E ZIP CODE Date of Birth Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. (c7D (INCLUDE AREA CODE) E-mail Address l/11? P Fax Number Type of Work Performed fea I ;I- Location of Employment ( 7i1 2 tlz STREET CITY un c STATE ZIP CODE 7 ,q Company Name, if any a?? Telephone Contact Person (Against whom Wage Claim is filed) Address ?-lD GZ?YLc?d STREET CITY COUNTY STATE ZIP CODE Date Hired Are you still employed by the named employer? ? Yes [!?/No If No, the last date worked 7_C7z _1' Was your termination: EV Voluntary ? Involuntary 1. Was there a written contract of employment between you and the named employer? ? Yes WNo If Yes, please attach copy. 2. What was your regular payday to be? (check one) ? Weekly 4Bi-Weekly ? Monthly ? Other 3. Were wages paid to you in a form other than a check? 4 Yes ? No ? Other (cash) o? L.? 4AIt> 05L C Tl„L,r 4. What was the latest rate of pay agreed upon between you and the named employer? Hourly $ Weekly $Other, please explain What are the TOTAL wages claimed by you? $ d'?? 0I" '7? COMPLETE REVERSE SIDE ;a14.l 7_tlls LLC-9 REV 11-07 (Pagel) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPLIANCE WAGE COMPLAINT FORM Office use only: WP&C MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-0665 FAX: 717-787-0517 PLEASE PRINT: Name of Person Filing Complaint Address ?C) k 3? tf? t''A C^'? r? L(?>PS2L" 1/! -%;-L-t ZrcS?1?f;?_s CITY I STATE ZIP CODE STREET Date of Birth Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. (6d j) - 6 (INCLUDE AREA CODE) E-mail Address _z- q4 P Fax Number ( ) - h? Type of Work Performed k A?t?(a1 J Location of Employment 1 ?17i 1?1Yt-? ?-d?`< ?,:? e?Y'! CY?IL- STREET CITY C NTY STATE ZIP CODE' .7 t7 l` !J f_- Gt wct oe_ ; /j Telephone Company Name, If any -?/ (t ( 4r G Contact Person (Against whom Wage Claim is filed) Address STREET fi CITY COUNTY STATE ZIP CODE Date Hired Are you still employed by the named employer? ? Yes No If No, the last date worked -?_e6' Was your termination: Voluntary ? Involuntary 1 . Was there a written contract of employment between you and the named employer? ? Yes U No If Yes, please attach copy. 2. What was your regular payday to be? (check one) ? Weekly WBi-Weekly ? Monthly ? Other 3. Were wages paid to you in a form other than a check? A Yes ? No ? Other (cash) Gt-4 01 7P 4. What was the latest, rate of pay agreed upon between you and the named employer? Hourly $ Weekly $ Other, please explain What are the TOTAL wages claimed by you? $ IS COMPLETE REVERSE SIDE LLC-9 REV 11-07 I1'age1) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPLIANCE (60, Office use only: WP&C WAGE COMPLAINT FORM MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-0665 FAX: 717-787-0517 PLEASE PRINT: D? Name of Person Filing Complaint 041%k1<:;G Address c> Luc / 3 34L ?? r? Gd?? l=e v?j LUG/` vll2G?u as?5`%? STREET CITY STATE ZIP CODED Date of Birth z/ Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. (3G7/ ) -V "71- 6 / '71'1- (INCLUDE AREA CODE) E-mail Address ivZszc? Fax Number ( ) A?VAle?-. Type of Work Performed Location of Employment Zl Y??-? n(dam L? c G4 ?° STREET CITY COUN Y STATE Company Name, if an T ?J /f ?H cG Telephone (- 4/5?) Contact Person (Against whom Wage Claim is filed) c / Au Lnl_ ZIP CODE / -2 ??v^?iI CTtI„ o?'?e??GUt. ?-2 Address 1-440 Ja LL?rr^?u ?? t-:Y1 c- STREET CITY COUNTY STATE ZIP COD?4o Date Hired E- Z1 Q Are you still employed by the named employer? ? Yes If No, the last date worked Was your termination: 4Voluntary ? Involuntary 1 . Was there a written contract of employment between you and the named employer? ? Yes V_(No If Yes, please attach copy. 2. What was your regular payday to be? (check one) ? Weekly L" Bi-Weekly ? Monthly ? Other 3.- Were wages paid to you in a form other than a check? Yes ? No ? Other (cash)- W?/?35 < T 4. What was the latest rate of pay agreed upon between you and the named employer? Hourly $ w or Weekly $Other, please explain What are the TOTAL wages claimed by you? $ COMPLETE REVERSE SIDE LLC-9 REV 11-07 (Pagel) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPLIANCE Office use only: WP&C WAGE COMPLAINT FORM MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-0665 FAX: 717-787-0517 PLEASE PRINT: J? Name of Person Filing Complaint Address I!> G ? r?r rte'', a,c' -s STREET CITY STATE ZIP CODE' Date of Birth Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. 1 01:?9l) 6 (INCLUDE AREA CODE) E-mail Address STREET CITY V COUNTY STATE ZIP CODE -7 3y'{jy ?(?- 'if 1Jo` ?(? t Company Name, if any C: Telephone (°,-16) YjoZb_ S Contact Person (Against whom Wage Claim is Iled) Address ! ?!?c?.l/4 ?'l i o? 1 L?/T''`21v1 /`7? - /?O STREET CITY COUNTY STATE ZIP COD,E? Date Hired ?C y Are you still employed by the named ployer? ? Yes U No Involurhtary If No, the last date worked C,6 ?? Was your termination: ' VoluntaryPNo 1. Was there a written contract of employment between you and the named employer? E:1 Yes No Fax Number ( 1 Type of Work Performed Location of Employment If Yes, please attach copy. 2. What was your regular payday to be? (check one) ? Weekly Bi-Weekly [_1 Monthly El Other 3. Were wages paid to you in a form other than a check? I(Yes ? No ? Other (cash) 4. What was the latest rate of pay agreed upon between you and the named employer?? Hourly $ Weekly $ Other, please explain What are the TOTAL wages claimed by you? $ >? ?r f 3- COMPLETE REVERSE SIDE LLC-9 REV 11-07 (Pagel) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPLIANCE Office use only: WP&C MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-0665 FAX: 717-787-0517 PLEASE PRINT: WAGE COMPLAINT FORM Address i??n - / 3 ? Name of Person Filing Complaint STREET Q CITY Date of Birth ?C,,.??i? Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. E-mail Address 40401 ? Fax Number ( ) Type of Work Performed 12v,• '4' STREET CITY COUNTY STATE ZIP CODE Date Hired a--( Are you still employed by the nam7voluntary ployer? ? Yes ?`Nn If No, the last date worked tSZt?i? 7., -2?'Y Was your termination: ?? I nvoluntary 1 . Was there a written contract of employment between you and the named employer? ? Yes J No If Yes, please attach copy. 2. What was your regular payday to be? (check one) ? Weekly IV] Bi-Weekly ? Monthly ? Other 3. Were wages paid to you in a form other than a check? DJ/yes ? No ? Other (cash) 4. What was the latest rate of pay agreed upon between you and the named employer? Hourly $ Je - ov Weekly $ Other, please explain ,/ What are the TOTAL wages claimed by you? $ 6I, 'q_-/' C ` V STATE ZIP CODE ?? T 6 (ate l ) Z/ 7 (INCLUDE AREA CODE) Location of Employment / -2-1 ?Gr.>C?- ?Z? 4????• . / (_??,,/??c?ar?y? STREET CITY COUNTY STATE ZIP CODE Pa, Company Name, if any f` a !zz I r Telephone 4;2-/ S?) / 7 a T- Contact Person (Against whom Wage Claim is filed) Address ,/pct yc ??ll? a ?GL v>?-LGyI mot. `?c? / / O? COMPLETE REVERSE SIDE 9 LLC-9 REV 11-07 (Pagel) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW CO l?J WAGE COMPLAINT FORM Office use only: WPBC MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: PLEASE PRINT: Name of Person Filing Complaint Addresses 131 3 STREET CITY Date of Birth 'y/ Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m E-mail Address I -OL-t- Fax Number ( ) Type of Work Performed 61 etzZ, ,? `Yl?issi _ Location of Employment 1 'z_j '2.- plu STREET V, STATE ZIP - It-'4w Company (mil)x-16 (INCLUDE AREA CODE) CITY `/ COUNTY STATE ZIP CODE / t, ?C_Telephone Ih/S ) i'y5 Gc?S / Contact Person (Against whom Wage Claim is filetl) Address !ld / STREET CITY COUNTY STATE ZIP CODV1140 Date Hired z-?Are you still employed by the named ployer. q+tt7 L? Yes If No, the last date worked Was your termination: I___, Voluntar y 1nvolunt8ry 1. Was there a written contract of employment between you and the named employer? E Yes i,.VI? No If Yes, please attach copy. 2. What was your regular payday to be? (check one), Wee I i_IjBi-Weekt Y Y -? Monthly D Other 3. Were wages paid to you in a form other than a check? [f Yes ? No ! Other (cash) G, r ?'c'CX- Ili z? 4. What was the latest rate of pay agreed upon between you and the named employer? lL?e 7`?'? C?-G Hourly $/Q 'd Weekly Other, please explain What are the TOTAL wages claimed by you? $ v S? Z COMPLETE REVERSE SIDE LLC-9 REV 11-07 (Pagel{ COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPI ?aN} F Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-9324)665 FAX: 717-787-0517 Office use only: WP&C WAGE COMPLAINT FORM MW C LL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: PLEASE PRINT- Name of Person Filing Complaint Address ;??o - 'i5 t / 3 _?)? C14" - - - vc C - yt/a 6 STREET Date of Birth CITY STATE ZIP CODE ' Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. 45e?P1 ), - Z (INCLUDE AREA CODE) E-mail Address Ae vk Fax Number Type of Work Performed Location of Employment Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-0665 FAX: 717-787-0517 J Cu-v?t 5 - STREET 0 CITY COUNTY STATE ZIP CODE ?? A- Company Name, if any lo f Telephone S j ?ozcS ? «b Contact Person (Against whom Wage Claim is filed) ?? Address / 161 Z r e-y STREET CITY - COUNTY STATE ZIP CODE Date Hired Are you still employed by the named employer?"Yes i No If No, the last date worked - ?• 7,? ???? Was your termination: 11oluntary r j Involuntary 1. Was there a written contract of employment between you and the named employer? 171 Yes [4o If Yes, please attach copy. -/ 2. What was your regular payday to be? (check one) Weee y i 1! gi-Weekly ?i Monthly Other _ 3. Were wages paid to you in a form other than a check? {' Yes No D Other (cash) ?-i vte- - 4. What was the latest rate of pay agreed upon between you and the named employer? Hourly $ jO - Weekly $ Other, please explain What are the TOTAL wages claimed by you? $ COMPLETE REVERSE SIDE LLC•9 REV 11-07 (Pagel) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPLIANCE i WAGE COMPLAINT FORM Office use only: WP&C MW CLL This form is used for complaints under the Pennsylvania Minimurn Wage Act of 1968 and the Wage Payment and Collection Law. Persons returning this form should complete all parts, including the reverse side, that are applicable to the specific law or laws under which a complaint is made. RETURN TO: PLEASE PRINT: Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-8W-932-0665 FAX: 717-787-0517 Name of Person Filing Complaint Address ac) - f / 3?- STREET 16ITY STATE IP CODE Date of Birth Telephone Number where you can be reached between 8:30 a.m. and 5:00 p.m. (6<J-/) 1'7 f (INCLUDE AREA CODE) E-mail Address ?2vu a Fax Number ( ) Type of Work Performed Location of Employment / Co? / Company ame, 1 an? ' Contact Person (Against whom Wage Claim is filed) ,Telephone e-6-Z_ ?v Address % Z/? stir 1D__ Q?j" 'ems ;?a % 2./ d ?] STREET CITY COUNTY STATE ZIP CODE Date Hired - ll)SG Are yoouu still employed by the named employer? [1] Yes LVJ1No If No, the last date worked S Was your termination: EY Voluntar 7_1 Y :-Involuntary 1. Was there a written contract of employment between you and the named employer? Yes ?__, No If Yes, please attach copy. 2. What was your regular payday to be? (check one) L Weekly _'?/Bi-Weekly i_ Monthly Other 3. Were wages paid to you in a form other than a check? LJ/Yes L No ..? Other (cash) r-Lt 4. What was the I#=,rate of pay agreed upon between you and the named empio}Ar?he- Hourly $ 'J C7 Weekly $ Other, please explain What are the TOTAL wages claimed b by you? $ COMPLETE REVERSE SIDE Lt-C-9 REV 11-07 (Paget) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY BUREAU OF LABOR LAW COMPLIANCE 40 WAGE COMPLAINT FORM Office use only: WPBC MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act Collection Law. Persons returning this form should complete all parts, including the?reevverse side, ? Peapplicable to the specific law or laws under which a complaint is made. RETURN TO: Bureau of Labor Law Compliance 1301 Labor & Indus Vy Building Seventh & Forster Streets Harrisburg, PA 17131 Telephone: 717-705-W9 or 1-M-9324MS FAX: 717-787-0517 PLEASE PRINT: Name of Person Filing Complaint ??e' ?/LjiLc 1 Address l ?G .c LL1.>?? ar -,? Date of Birth STATE --A ? / q ? F" Telephone Number where you can be rea h C ed between 8:30 a.m. and 5:00 p.m. Ec e/) L"-- (INCLUDE AREA CODE) / E-mail Address G) Fax Number ( ) _ Type of Work Performed Location of Employment i Zl Z 01 r p ? ? STREET CITY Company Name, if any '?t t'- Contact Person (Against whom Wage Claim is fi 1 ---M 1 T STATE ZIP CODE .Telephone (0210 I3 - G7Z> 6_?' C JO _ Address STREET ?L?t'cG ?y CITY COUNTY cx- 9( Date Hived/1 STATE ZIP CODE / Are you still employed by the named player? r---. Y i + No If No, the last date worked 2or ----? Was your termination: 1_-_, Voluntary ^? 1 • Was there a written contract of employment between you and the named employer? FL--,'yeS ` Involuntar y If Yes, please attach v /No 2 3 4. COPY. What was your regular payday to be? (check on U Wee Y /r-Bi-Weekly L; Monthly 0 Other Were wages paid to you in a form other than a check? Z Yes L? No i I ,r ? L? Other (cash) cxt ?,e? 1 What was the latest rate of pay agreed upon between you and the named empioyer? ?' `rte ? (7, Hourly $ 9c5 . ?? Weekly $ Other, please explain What are the TOTAL wages claimed by you? COMPLETE REVERSE SIDE ••aY + 1-ur 41"0") C WEALTH OF PENNSYLVANIA OEPAR TAIENT OF LAROR '3<c, 6uREAU Of LAaaR - I.AW COWILIANCE WAGE COMPLAINT FORM Office use only: WpBC MW CLL This form is used for complaints under the Pennsylvania Minimum Wage Act of 1968 and the Wage Pa Collection Law. Persons returning this form should complete all parts, including the reverse side, thatarey a to the specific law or laws under which a complaint is made, me t and ppli able RETURN TO: Bureau of Labor Law Compliance 1301 Labor & Industry Building Seventh & Forster Streets Harrisburg, PA 17121 Telephone: 717-705-5969 or 1-800-932-M65 FAX: 717-787-0517 PLEASE PRINT: Name of Person Filing Complaint ? Address STREET CITY I C iN L S 5 Date of Birth STATE ZIP CODE Telephone Number where you can be reached between 8:30 a.m. and 5:00 . E-mail Address L (INCLUDE AREA CODE) - -r Fax Number Type of Work Performed Location of Employment ?! Z pzcz _ ` STREET a an/ e CITY [ECG Company Name, if ' COUNTY STATE ZIP CODE Telephone Contact Person (Against whom Wage Claim is filed) Address 1-240 l:' STREET CITY COUNTY ! fd Date Hired , STATE ZIP CODE Are you still employed by the named mployer? `J Yes 4 No If No, the last date wor ed Was your termination: L-- Voluntary F Involuntary 1. • Was there a written contract of employment between you and the named employer? ;? oluntary If Yes, please attach copy. Yes 'No 2. What was your regular payday to be? (check one 3• Were wages ) u Wee IY Bi-Weekly 0 Monthl paid to you in a form other than a check? Lvj Yes No ; J y 0 Other _ 4• What was the latest rate of Other (cash pay agreed upon between you and the named em ployer? l-U?- Hourly $ %A c Weekly $ d Other, please explain 'c?z-ae?_ ??.• What are the TOTAL wages claimed by you? $ COMPLETE REVERSE SIDE LLC-9 REV 11-07 (Paga11 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABO & INDUS RY BUREAU OF LABOR LAW COMPLIANCE EXHIBIT 66][399 -- Summary of Wages Owed to Donna Rozycki ? - 1 - - -- Week Ending Hours Worked Amount Under aid/Hr. Wages _ Due -fi - I I ? 7 -09/29/2005 - 40 _$5.65 $226.00 I- --- --- $5.65 10/27/2005-- _ 40 --- 11/03/2005 4p $226 00 11/24/2005 40 12/01 /2005 40 01 /26/2006 40 .65 - -- --- $226.00---- .65 - -- $226.00 .65 ---- --- s22a nn 02/02/2006 - - - - -40 - -- $5.65 $226.00 -- -- - - -- -- $226 00 02/09/2006 40 $ 5.65 $226 00 02/16/2006 40 - _ $5.65 . _ $226 00 02/23/2006 40 _ $5.65 . $226 00 - 03/02/2006 40 - _ _ $5.65 . $226 00 03/09/2006 40 - $5.65 . $226 00 03/1612006 03/23/2006 40 40 $5.65 . - U26-00 - 03/30/2006 - _ - -- - 40 -- -- - - ?----- -- - $5.65 026.00 _ 00 _ $2 2 6 04/06/200_6 --- - 40 - - -- $5.65 _ _ . 00 - $226 04/13/2006 - - -- 40 -? - - - $5.65 . { $226 00 04/2_0/2006 40 - $5.65 . 00. _ $226 04/27/2006 - -- 40 - $5.65 _. $226 00 05/04/2006 1 40 t - - - $5.65 -- --- . - $226 00 05/11 /2006 - - 4_0 - - -- - $ 5.65 ._ - $226 00 06/01/2006 -- 01/ 40 - -- -- -- _ 5.65 $ . $226 00 06/08/2006 - - - 07/06/2006 6 -C - 40 46- 0 i - - - _ - $5.65 65 -- $5 . -? $226.00 - - ---- - _____ - 07/13/2006 - --- 40 - - --- r . 5 - - $ 5.6 -- $226.00 $226 00 08/03/2006 8/03/200_6 - - - 40 - _ _ - $6.75 . -- $270 00 08/10/2006 40 -- $6.7 75 . t $270 00 _ 08_/17/2006 - - - 40 - - - $6.75 . -- - - -- 08/24/2006 40 $6.75 $270 00 08/31 /2006 40 $6.75 _. 00 - j $270 09/07/2006 --- a 40 -- - ----- $6.75 . - - $270 00 09/14/2006 - - -- 40 _ __ _ ? - - _ -- $6.75 . _1 ------ - $270 00 09/21/2006 40 _ $6.75 . 270 09/28/2006 - i28 40 $6.75 r --- -- 00 - - _ $2 70 1 006 - - ? 40 - i - - . $27 0 00 10/26/2006 - 40 $6.75 _ . $270 00 1 1/02/2006 - 40 - - - - - $6.75 . - ; '? $276 00 _1/09/2006 1 - 11 /16/2006 - 40 - - - - -- --- - - _-- - - . r $270.00 40 $d - ----- -__ $270.00 11/23/2006 - _ 40 $6.75 $270.00 _- --- 11/30/2006 40 $6.75 $270.0 0 12/07/2006 ?- ---- 40 ____ _ -- _ ----- $6.75 _ - - - $ 270.00 12/14/2006 - --- 40 -$6.75 _ - - - $270.00 12/21/2006 - - 40 $6.75 - $270.00 01126/2007 - 40 } $6.75 $270.00 02/02/2007 40 $6 .75 $270.00 02123/2007 - 40 _ $6.75 $270.00 03/02/2007 40 $6.75 $270.00 03/09/2007 - 03/16/2007 - 40 _ 40 - - - $_6.7_5 - $6.75 -- -- $270.00 - - - $270.00 _- 03/23/2007 40 - -- - ---$6.75 $270.00 -- - 03/30/2007 40 $6.75 -- - - $270.00 - - 04/06/2007 40 $6.75 ___ $270.00 04113/2007 40 - --- -- $6.75 -- _ $270.00 04/2012007 - - 40 - - - - - -- - - - $6.75 ---- - -- -, - -- $270.00- -- 04127/2007 40 - 6.75 - $ - - $2 70.00 - 05/04/2_0_07 40 - - -- _ $6.75 _ $ 270.00 05/11/2007 40 $6.75 _ $270.00 0511812007 40 $6.75 $270.00 05/25/2007 40 $6.75 $ 270.00 06101/2007 - 40 - - -- - - - 75 _ - - -- $270.00 06/2212007 40 - - --- 0 - $10.0 - - - $400.00 07/06/2007 ---- 40 -- --- _ $10.00 -- -$400.00 07/13/2007 40 $10.00 - - $400.00 - -- - -07/20/2007 - - - , - -- 40 - -- -- -- - - - -- $10.00 $400.00 0_7/27/2007 -- - - 40 - --- -- - ?_ - -$10.00 - -- --$400.00 - 08/03/2007 40 - $10.00 $400.00 - 08/24/2007- -- - 40 - - - - - $10.00 $400.00 08/31/2007 40 - $10.00 -- - $400.00 09/07/2007 ? 40 -- - r -- - $10.00 -$400.00- 09/14/2007 - _ _ - --- 40 _ $10.00 $400.00 09/21/2007 40 r _ _ 00.00 - r--- $400.00- - 09/28/2 007 - ---- - 40 - - $10.0 0 - - -$400.00 _ 10/05/2007 - -- 40 - 4 - _ - $10.00 - $400.00 10/1212007 + 40 $10.00 $ 400.00 - 10/19/2007 _ -- -- - - -- 40 - - L _ $10.00 -- _ $400.0 0 10126/20 07 40 - - - - $10.00 _ $400.00 11/02/2007 40 - - - - $10 700 - - $400.00 11/23/2007 -_ 0 -- -- - - +- , $10-00 -- - $400.00 11/30/2007 12/07/2007 40 _ _ 40 - - $10.00 - $10 .00 - $400.00 $400.00 01/2512008. I 40 --- $10.00 - $400.00- - 02/01/2008 40 $10.00 $400.00 A R • v?rviiLUVif _ 40 _ $10.00 j -- -- ------ - ------ - -- t -- -$400.00 Total Hours--- 3360 -?? - -L----_- ? --- ? -----L -- - Total Due $24,570.00 ?R y VERIFICATION I, A. ROBERT RISALITI, hereby state that I am the Director of the Bureau of Labor Law Compliance, Department of Labor and Industry; that I am authorized to make this statement on behalf of the Plaintiff; that I have read the foregoing Complaint; and that the facts alleged therein are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: p Bureau of Labor Law Compliance ?. dk.-t- 'Zx- A. Robert Risaliti Director Bureau of Labor Law Compliance .? -?-? - , -?' , _ jN ,? Y ... ? ? , ? ` , }L, ? ?'3 , \ y., .. U . O ? °? - V' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-04645 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMMONWEALTH DEPARTMENT OF LAB VS DELAWARE VALLEY COUNCIL OF AM R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DELAWARE VALLEY COUNCIL OF AMERICAN YOUTH HOSTELS INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of PHILADELPHIA County, Pennsylvania, to serve the within COMPLAINT & NOTICE On September 9th , 2008 , this office was in receipt of the attached return from PHILADELPHIA Sheriff's Costs: So a Docketing 18.00 Out of County 9.00 Surcharge 10.00 T mas Kline Dep Philadelphia 136.00 r ff of Cumberland County Postage 4.65 n-v 177.65 ? G/bi b8 !' 09/09/2008 COMMONWEALTH OF PENNSYLVANIA Sworn and subscribe to before me this _ day of , A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-04645 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMMONWEALTH DEPARTMENT OF LAB VS DELAWARE VALLEY COUNCIL OF AM R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and w r T-. inquiry for the Tr r??T mT . TTTT T.TT.TT T within named DEFENDANT to wit: but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of PHILADELPHIA County, Pennsylvania, to serve the within COMPLAINT & NOTICE On September 9th , 2008 , this office was in receipt of the attached return from PHILADELPHIA 1-17 Sheriff's Costs: Docketing Out of County Surcharge So 6.00 \ .00 .00 16.00 ? 9/!+? 09/09/2008 COMMONWEALTH OF PENNSYLVANIA 10.00 as Kline .00 er' f of Cumberland County Sworn and subscribe to before me this day of , A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Carnionwealth, Department'of Labor & Industry etc vs. Delaware Valley Council of American Youth Hostels Inc et al No. 08-4645 civil SERVE: same Now, August 4, 2008 hereby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Philadelphia deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. D Affidavit of Service { n6tl Now, /? , 20, at _ o'clock _ M. served the within up at by handing to a and made known to the contents thereof. 6r- ?i lan e,? -5 0, do Xd# ?f { S ASS o answers, k9flop-4-Q. li), i) o3 03 30 ?n cl?? Sher"1''"Tr'0 CrR,.SS 5aN County, PA '?e.r F to we.( ?5 ho P NLx,+ dov t r b Sworn and sybscribed me this ;UP day of (?- iL fi'. 2006 copy of the original coSTs SERVICE _ MILEAGE _ AFFIDAVIT 10TARIAL SEAT. MEL! =c" H. KAPLAN, Notori Public C iv a-r Dhlladol0i9; PhiW :,.our! In The Court of Common Pfeas of Cumberland County, Pennsylvania Contionwealth, Department of Labor & Industry etc' vs. Delaware Valley Council of American Youth Hostels Inc et al No. 08-4645 civil SERVE: Ta'Juanna D. Anderson Now, August 4, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Philadelphia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Please mail return of service to Cumberland0Co unty Sheriff. Thank you. Affidavit of Service ?? M0 Now, , 20at o'clock M. served the within upon `f(Q, \ And-Q-omo at / 1-l U by handing to a and made known to the contents thereof. ?--CaM agt"q"' t w U7m? 0-5 lyd l I UU5 ? Gw L? g)11I o a®3fm - ?b I13I?`,S 9 3om??° Si?ellffof County, PA ??ss5 er F1e 94 b COSTS r? COSTS orfi s bscribed before SERVICE $ SW me this day of t-A 66 , 20 OF MILEAGE I/"\ A .. 1 1,/ / AFFIDAVIT NOTARIAL SEAL MELISSA H, KAPLAN, Notary Public 0iri of PhilsdNphla, Phlis,.ounty copy of the original IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH, DEPARTMENT OF LABOR AND INDUSTRY, BUREAU OF BUREAU OF LABOR LAW COMPLIANCE o/b/o Donna Rozycki, Plaintiff v. DELAWARE VALLEY COUNCIL OF AMERICAN YOUTH HOSTELS INC. and TA'JUANNA D. ANDERSON, individually, Defendants CIVIL ACTION - LAW DOCKET NO. 08-4645 PRAECIPE TO REISSUE COMPLAINT A Complaint in this matter was filed with the Cumberland County Prothonotary on August 5, 2008. The Sheriff in Philadelphia and Cumberland Counties were unable to effectuate service on the Defendants. Since 30 days has passed since the initial filing, Plaintiff is requesting the Prothonotary to reissue the Complaint so that Plaintiff may again attempt service on the Defendants. ? nn #nnifer L Berrier Counsel or Plaintiff Attorney I.D. No. 204444 Office of Chief Counsel 10`}' Floor, L & I Building 651 Boas Street Harrisburg, PA 17121 Date: September 18, 2008 -V co 7 1r O SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-04645 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMMONWEALTH DEPARTMENT OF LAB VS DELAWARE VALLEY COUNCIL OF AM R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: DELAWARE VALLEY COUNCIL OF AMERICAN YOUTH HOSTELS INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of PHTLAnFT,PNTA serve the within COMPLAINT & NOTICE County, Pennsylvania, to On October 28th , 2008 , this office was in receipt of the attached return from PHILADELPHIA Sheriff's Costs: So answer Docketing 18.00 - --'?? Out of County 9.00 Surcharge 10.00 Thomas Klin Dep Philadelphia 272.00 Sheriff of Cumberland County Postage 5.40 314 .4 0 l0?30?o S ?» 10/28/2008 COMMONWEALTH OF PA Sworn and subscribe to before me this day of A.D. ' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-04645 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COMMONWEALTH DEPARTMENT OF LAB VS DELAWARE VALLEY COUNCIL OF AM R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: ANDERSON TA'JUANNA D but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of PHILADELPHIA County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 28th , 2008 , this office was in receipt of the attached return from PHILADELPHIA Sheriff's Costs: So answers Docketing 6.00 -'? Out of County .00 Surcharge 10.00 R. Thomas Kline .00 Sheriff of Cumberland County .00 16.00 10/28/2008 COMMONWEALTH OF PA Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of Cumberland County, Commonwealth, Department of Labor and Industry et lPennsylvania vs. Delaware Valley Council of American Youth Hostels Inc et al SERVE: same No. 08-4645 civil Now, September 22, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Philadelphia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, pA Please mail return of service to Cumberlan County Sheriff. Thank you. _6 Affidavit of Service Now, ,/ ?do L 20 at __L_1 o'clock M. served the within upon at by handing to a and made known to copy of the original the contents thereof. So veers, °f ? ?ad4.? .? t Q-Cou y, PA t?fDCQSS ?.IU? ? Sworn and subscribed bef e COSTS me this y of 2 SERVICE $ MILEAGE COMMON AVIT MATERIAL SEAL SUSAN L. RpgENFELD, City of Philadel NP?ry PUblic Mir Cemmission F Pi in, Ma ch 11. y P 2012 • ? ' In The Court of Common Pleas of Cumberland Count,, Penns lvania Commonwealth, Department of tabor and Industry et al, y VS. Delaware Valley Council of American Youth Hostels Inc et al SERVE: Ta'Juanna D. Anderson No. 08-4645 civil Now September 22, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Philadelphia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Please mail return of service to Cumberland Coy?nty Sheriff. Thank you. rjo Affidavit of Sem Now, 20? at o'clock M. served the within upon at by handing to a and made known to copy of the original s vo?e?n Swdrn and subscribed me this -c,21 day o?_? So / Hof ?>lbcQ.SS ?2 /YQ COSTS SERVICE the contents thereof. MILEAGE ROSENFELD, Notary Public City of Philadelphia, Phila. County w cemr-.issiQn_ExpimsMaNh-Lt.= X2 fah c aCounty, . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH, DEPARTMENT OF LABOR AND INDUSTRY, BUREAU OF BUREAU OF LABOR LAW COMPLIANCE o/b/o Donna Rozycki, Plaintiff V. CIVIL ACTION - LAW DOCKET NO. 08-4645 DELAWARE VALLEY COUNCIL OF AMERICAN YOUTH HOSTELS INC. and TA'JUANNA D. ANDERSON, individually, Defendants PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter as settled, discontinued and ended. Respectfully submitted, Dated: d ifer L, errier Assistant Counsel Attorney Registration No. 204444 Commonwealth of Pennsylvania Department of Labor and Industry Office of Chief Counsel Labor Law Compliance Division Tenth Floor, Labor and Industry Bldg. 651 Boas Street Harrisburg, PA 17121 Telephone: (717) 787-4186 Counsel for Plaintiff CERTIFICATE OF SERVICE I, JENNIFER L. BERRIER, hereby certify that I have this 13th day of February 2008, served the foregoing Praecipe upon the persons and in the manner indicated below, which service satisfies the pertinent rules of court: Service First-Class Mail, Postage-Prepaid, Addressed as follows: Delaware Valley Council of American Youth Hostels Inc. 1210 Sansom Street Philadelphia, PA 19107 Ta'Juanna D. Anderson 1210 Sansom Street Philadelphia, PA 19107 J NNIF L. BERRIER ssistant Counsel Attorney Registration No. 204444 Commonwealth of Pennsylvania Department of Labor and Industry Office of Chief Counsel Labor Law Compliance Division Tenth Floor, Labor and Industry Building Seventh and Forster Streets Harrisburg, PA 17120 Telephone: (717) 787-4186 --Counsel for Plaintiff 2 r-? ,:"? ?',+ ? ?' ? '.Yj` «....b ? ' -^CJ F wi 1 mss- - i ?'1 G!.7 ? .. ? _.. 4 .? ?„?