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Home My WebLink About04-1555FEDEX FREIGHT EAST NZMP (USA), INC. Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL DIVISION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, yott 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 yon 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/nay 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 \USER\STACY\CCP COMPI,AINTS\WORK~29870.wpd: IgFeb04 FEDEX FREIGHT EAST NZMP (USA), INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O : CIVIL DIVISION - LAW Defendant : COMPLAINT The Plaintiff, FEDEX FREIGHT EAST, by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of TWO THOUSAND, FIVE HUNDRED EIGHTY-FIV E DOLLARS AND FIFTY-SEVEN CENTS ($2,585.57), along with interest thereon from February l, 2004 upon a cause o faction of which the following is a statement: 1. The Plaintiff, FEDEX FREIGHT EAST, is a corporation organized and existing under the laws of the State of Illinois, having its principal office and place of business at 4103 Collection Center, Chicago, Illinois 60693.. 2. The Defendant, NZMP (USA), INC. , is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 635 North Twelfth Street, Suite 101, Lemoyne, Cumberland County, Pennsylvania 17043. 3. On the dates, in file amounts, and for tile prices set forth in a true and correct copy of the Plaintiff's Invoices hereto attached, marked Exhibit "A" and made a part hereof, Plaintiff, at the special instance and oral request of the Defandant, provided shipping services as set forth on said Exhibit to the total amount of Two Thousand, Five Hundred Eighty- Five Dollars and Fifty-Seven Cents ($2,585.57). 4. The prices charged for said services provided were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay to Plaintiff. :\USER~,STACY\CCP CO M P LAINTS\WORK\29 g 70.wpd:09Apr04 5. 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 of any part thereof. WHEREFORE, Plaintiffbrings fl~is suit to recover from Defendant the sum of TWO THOUSAND, FIVE HUNDRED EIGHTY-FIVE DOLLARS AND FIFTY-SEVEN CENTS ($2,585.57), along with interest thereon from February 1, 2004. Respectfully submitted, Robert D. Kodak 407 North Front Street Post Office Box # I 1848 Harrisburg, PA ! 7108-1848 (717) 238-7151 Attorney IDNo. 18041 Attorney for Plaintiff \USER\STAUY\CCP COMPLAINTS\WORK\29870.wpd: 18Feb04 .~,-~o-~uU3 13:16 LOWTHER LAM OFFICE 85826994&0 P.13 · DUPL I'CATE ,Senti Pi~¥m~[ ~; [NDRTH ANERZCA) ZNC USF LO~ZSTZC$ NORTH TOPPZN6 AVE K~NSAS CZTY IN'YoIC~ PA~E ox OF 0X FedEx Freigh! East, 4103 Collection Center Drive. C~icago,l~ 6~g3 P~one 8~,741,Q~ F~,~0,~4t.3~3 ToII-F~e ~.874,47~ NZMP NORTB AMERZ~ I~ SUZTE 101 &SE N I~TH STREET LEMOYNE, 112 616 588 DATE ORIGIN I DI/~T KCY PNX 8~8~,0~70 CONSIGNEE ULTRA HEALTH PRODUCTS 2026 ~ LONE CACTUS DR PHOENZX 85056808 P,O.~'I~I~MBEP. I B.I.,. NUNIBEI~ ~91&77 I 3W.~OO P~ 17 FOODSTUFF DRIED N~LK SOLIDS 1 SKID STC 17 PCS ~ EDIBLE PRODUCTS ~-~ 9g~O6& 001581 FUEL SURCH~ LTL SHPT N M F c CI,,AE~ RATg 850 O?$ZET-QO O&O 68.918 REV. ~ 601.5~ TOTAL CHARG~ ~, 58~.74 17 YOUR SCHEDULED, ALL-POINTS INTRASTATE, REGIONAL AND INTERREGIONAL CARRIER Remltta~ce Advice Please Return This Portion With Your Payment Terms Net 15 Days PA',~NGr~arn' 8~s~o~o NZNP NORTH AMERICA 6~5 N 12TH STREET LEHOYNE PA l?O~S Sene Payment m: FedEX Freight East 4'/03 CoNection Center Drive, TEANK YOU g F REIG[.I~I~ BILL NUMBER 112 616 588 DA,TI~, PLEASE PAY THIS AMOUNT 601,55 [] gl illilllllllli[llllllllli II D, UPL I'CATE SHIPPER NZHP (NORTH A~ERZCA~ Z USF LOG[$TZCS 18¢3 NORTH TOPPZNG AVE KANSAS LOWTHER LAW OFFICE CONSIGNEE BR;STOL HYER$ S~U~B~ C0 ZEELAND ~76808&1 INVOICE .AGE Oi OF O~ FedEx Freight East, 4103 Collection Center Drive, Chicago,IL P.O, ~ ~ Haffison, AR N~P NORTH AHER~CA SUITE 1~01 6S5 N I~TH STREET ~097¢~2 ~o~ 6 SKIDS STC 120 PCS ~ EDZ~LE PRODUCTS ~ KCY ZNSFECTZN~ TERN~NAL OOEO00 OR~GZIC~L WE~GHT 000185154 OR~GSNAL REVENUE 00&$58 FUEL SUECHO LTL SNPT ~ARFW 5000 08/06/01 08982 077. 9?2 139 T~CKIN~ N UMB~q. DAT~ 09/28/0~ OR:GIN KCY ~BqO~7D 6 TERHS PPD &~O ~ 198q.02 YOUR SCHEDULED, ALL~OINTS INTRASTATE, REGIONAL AND INTERREGIONAL CARRIER Remittance Advice Please Return This Portion With Your Payment Terms Net 15 Days PAYING PAKT~ SUZTE l~l 6~ N 12TH STREET LE~OYNE PA FedEx Freight East 410,3 Celtectlon Center Drive, Chicago, iL ~rH,4ArK rOD' # lllJl Illli llllilIHI! Jill 071 972 I~9 DAT~ ~9~.~ III HIHIIIIHIHIIilIIlllIIlililllJlI ~AR-17-2OO4 05:23 P,06 YER/F[CATION understand that false state~ea~s h~reia ar~ made subject to a~e ~enalties of 1S Pa. C. S. §4904, rdafing to uns,wom fak*~cadon to authorities. FEDEX By: FAU$~$TACY~CP COM PLA Eq T~V/Olg, X~9~70,wpd ~ 1 ~Feb04 [IEIGHT EAST ,~q~ .- ~0~ 8I a~L~ TOT&L P,06 SHERIFF'S RETURN - CASE NO: 2004-01555 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLJtND FEDEX FREIGHT EAST VS NZMP(USA) INC REGULAR SHANNON SHERTZER , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE Sheriff or Deputy Sheriff of who being duly sworn according was served upon to law, NZMP (USA) INC the DEFENDANT , at 1640:00 HOURS, on the 19th day of April , 2004 at 635 NORTH 12TH STREET SUITE 101 LEMOYNE, PA 17043 by handing to TERESA SMART, EXECUTIVE ASSISTANT, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.04 Affidavit .00 Surcharge 10.00 .00 39.04 Sworn and Subscribed to before me this 2/~ day of ~ ~2~ A.D. Pr6thonotary -- So Answers: R. Thomas Kline 04/20/2004 KNUPP KODAK IMBLU~4 ~ /~ FEDEX FREIGHT EAST NZMP (USA), INC. Plaintiff Defendant In the Court of COMMON PLEAS of : CUMBERLAND County, Pennsylvania NO. 200,4-01555P CIVIL DIVISION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter as settled and discontinued with prejudice. TO CUMBERLAND County Prothonotary Dated: November 29, 2004 Robert D. Kodak Attorney I.D. No. 18041 Attorney for Plaintiff