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Home My WebLink About08-5099 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IMPERIAL INTERNATIONAL I CIVIL DIVISION I I I Plaintiff(s), I No. 2008 V. I SARAGO ENTERPRISES LLC d/b/a I SARAGO'S BIG UGLY WAREHOUSE, I I I Defendant(s), I I I COMPLAINT I I I Code No. I I Filed on Behalf of: I I PLAINTIFF I i I 1 ATTORNEY OF RECORD FOR THIS PARTY I I Louis B. Swartz I I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 %81137 e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION IMPERIAL INTERNATIONAL Plaintiff(s), No. 2008 V. SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE, Defendant(s), 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 days (20) 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 claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 NOTDEFCU.PLE 81137 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION IMPERIAL INTERNATIONAL V. Plaintiff(s), No. 2008 .50gg SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE, Defendant(s), COMPLAINT 1. Plaintiff(s) is IMPERIAL INTERNATIONAL. Plaintiff's address is 429 Fourth Avenue, Suite 1600, Pittsburgh PA 15219. 2. Defendant(s) is SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE,. Defendant's address is 5267 Simpson Ferry Road, Mechanicsburg, PA 17050. 3. Beginning on or about August 22, 2006, and from time to time therafter, at Defendant's oral instance and requests, Plaintiff sold and delivered goods and merchandise to Defendant, which were accepted by Defendant, as more fully set forth on the documents of account which were prepared in the ordinary course of Plaintiff's business and rendered to Defendant, true and correct copies of which are attached hereto as Exhibit "A" and are incorporated herein by reference as though herein set forth at length. 4. By reason of the foregoing, Defendant is indebted to Plaintiff in the sum of $21,854.52 which, despite repeated demands, has been overdue, owing and unpaid ever since February 28, 2008. WHEREFORE, Plaintiff demands Judgment against Defendant(s) in the amount of $21,854.52 plus interest from February 28, 2008 and costs. Louis Swartz Attorney for PLAINTIFF 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 89411 Mar, Lv. 3-j?erlal?J?S Imperial International ** IMPNo 4752;r?RP:,-hNAL 621 W. RTE 46 HASBROUCR HEIGHTS, NJ 07604 621 W. ROUTE 46 A/R STATEMENTSBROUCK HTS., N! 07604 SOLD TO: 17104010 SARAGO'S BIG UGLY WAREHOUSE 5267 SIMPSON FERRY RD MECHANICSBURG PA 17050-3507 INVOICE REFER # CODE PURCHASE ORDER# INV-DT 0212982 0500230 CURRENT 1 - 30 CHRIS/N'IK/STEVEBCA DUE-DT 8/22/06 9101106 8/28/07 8/28/07 BALANCE DUE 9166.05 1000.00 31 - 60 61 - 90 91 - 120 OVER 120 10166.05 TOTAL DUE 10166.05 // I Mar. 3. 2008 1:51PM Imperial International No-4752 P. 2 r N 01 O O ?P. a r? r ro m .a MIJ*A01 N 1 0 4 1 1 1 , NWHwwwwWM11 r CIWOaV.tymvO „? ooooeoooo0 a maaaaaaaau? p oogp000ooo '• ?D?O?OW WNIUIbbm O+o?tnmmwwwo?D to rp C y WMWWFAWPWY Uw C ! b Oj ioatiou w AOW& a,?y 1 WQCWWMWMA-j a.. y w mo0M;Aw&w%jw CSC!!! I 00 ? NN rAwo ?] yy r'c4 ro w 7E LMk MIN NN H 01 N N N 99 o o N ? 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IlM agm to pay aril =t of caWOM W WOV reeov We rft cow Ond et<omey tow MW fi d?rgre„ & IN ? 1t11TI0N OF VVWAL Rnw# 71004 Ii'S SU95.tGdARW OR ==IV MMMM i =MY AND SWWALY Q4 PMOIWUY SW-WM Y, 4T ALL T TO ""-'41 ?iRNA11?ONN rM SU!W RW AFFUMTEB OR DN1SMS 10E PAYMMT OF IVpBYMNSS OR SAL mCl Olr AID OF TM V TMM iMWW MM. Print pft PNra't 'd-001 ON 10011VN831NI @11?7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION IMPERIAL INTERNATIONAL Plaintiff(s), v. SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE, Defendant(s), No. 2008 VERIFICATION The undersigned, I 'SA IQE1D , avers that he she s the EDIT HANA6f-f-of Plaintiff, is authorized to make this verification on behalf of Plaintiff, the statements of fact contained in the attached Complaint are true and correct to the best of his/her information, knowledge and belief, and are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Section 4904 relating to unsworn falsification to authorities. O ? d 8 ??'"?- cP VF.RIFCOM.PLE Date .49. N ? w J n G+ t f: s ?a r.a E G-) N Cn rn? V? J1 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-05099 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IMPERIAL INTERNATIONAL VS SARAGO ENTERPRISES LLC D/B/A 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: SARAGO ENTERPRISES LLC D/B/A SARAGO'S BIG UGLY WAREHOUSE but was unable to locate Them deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On September 25th , 2008 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co Postage 18.00 9.00 10.00 49.25 cn 86.84 ? 09/25/2008 LOUIS SWARTZ So answers;-- R Thomas Kline Sheriff of Cumierland County jolvqbf C).-. Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. 1,r,,. TI e O'ourt of Common Pleas of Cumberland County, Pennsylvania ._ h Imperial International VS. Sarago Enterprises LLC d/b/a No. 08-5099 civil Sdrago's Big Ugly Warehouse ___September 2, 2008 her. eby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, __ within upon. _ at by handing to a and made known to So answers, the contents thereof. Sheriff of COSTS Sworn and subscribed before SERVICE $ me this _ day of , 20 MILEAGE - AFFIDAVIT 20 at o'clock M. served the copy of the original County, PA mtfir.¢ of e ?04orfff Mary Jane Snyder R 1 Estate Depu y William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick sheriff Commonwealth of Pennsylvania County of Dauphin IMPERIAL INTERNATIONAL VS SARAGO ENTERPRISES LLC D/B/A SARAGO'S BIG UGLY WAREHOUSE Sheriff s Return No. 2008-T-1920 OTHER COUNTY NO. 08-5099 And now: SEPTEMBER I8, 2008 at 6:18:00 PM served the within COMPLAINT upon SARAGO ENTERPRISES LLC DB/A SARAGO'S BIG UGLY WAREHOUSE by personally handing to KEN SARAGO 1 true attested copy of the original COMPLAINT and making known to him/her the contents thereof at 1418 RED HILL ROAD DAUPHIN PA 17018 FATHER OF CHRISTOPHER (OWNER) Sworn and subscribed to before me this 19TH day of September, 2008 A#i NOTARIAL SEAL, Y JANE SNYDEP, Notary Publi Highspire, Dauphin County M Commission Expires Sept 1 2010 So Answers, Sheriff of Da n ty By Deputy Sheriff Deputy: G MILLER Sheriffs Costs: $49.25 9/5/2008 r' r' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IMPERIAL INTERNATIONAL Plaintiff(s), v. SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE, Defendant(s), CIVIL DIVISION I I I I I No. 2008-5099 I I I I I I I I I PRAECIPE FOR DEFAULT JUDGMENT I I I Code No. i Filed on Behalf of: I PLAINTIFF I I I ATTORNEY OF RECORD FOR THIS PARTY I Louis B. Swartz I PA. ID # 00242 I I ISWARTZ, LOVEJOY & ASSOCIATES 116th FLOOR LAW AND FINANCE BUILDING (PITTSBURGH, PENNSYLVANIA 15219 I I 1(412) 288-0300 %81137 '78 1137 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION IMPERIAL INTERNATIONAL Plaintiff(s), v. SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE, Defendant(s), No. 2008-5099 PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter judgment against Defendant(s) and in favor of Plaintiff in Default of an Answer or a Notice of Intention to Appear as follows: AMOUNT CLAIMED IN COMPLAINT $ 21,854.52 PLUS INTEREST FROM 02-28-2008 TO: 10-27-2008 $ 869.39 TOTAL $ 22,723.91 I certify that I mailed a notice of default to the defendant(s) in the form attached hereto on the date stated thereon which was more that ten (10) days he/fore filing this praecipe. Louis B. S r z Attorney f LAINTIFF SWARTZ, LOVE OY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 r' 6 r k91137 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION IMPERIAL INTERNATIONAL Plaintiff(s), No. 2008-5099 V. SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE, Defendant(s), DEFAULT NOTICE TO THE DEFENDANT: SARAGO ENTERPRISES LLC d/b/a SARAGO'S BIG UGLY WAREHOUSE, 1418 Red Hill Road Dauphin, PA 17018 IMPORTANT NOTICE IMYOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR 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 (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 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.--P 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. Pennsylvania Lawyer Referral Service 100 South Street, P.O. Box 186 Harrisburg, PA 17108 j 1101n 1-800-692-7375 Date Louis B. Swartz Attorney for PLAINTIFF SWARTZ, LOVEJOY & ASSOCIATES 16th FLOOR LAW AND FINANCE BUILDING PITTSBURGH, PENNSYLVANIA 15219 (412) 288-0300 NOTE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE defnote/defnotex E ? 40 -Fn R> (N 0 n' 60 m -?