HomeMy WebLinkAbout08-6203WIREHEAD BUSINESS
TECHNOLOGIES, INC.,
Plaintiff
V.
THOMAS HASHEM d/b/a
GOODFELLAS PIZZA,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08 - 166103
Civil Term
IN ARBITRATION
NOTICE
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
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
32 S. Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
PLEAS WIREHEAD BUSINESS IN THE COAURT OF
COUNTY, YLVANIA
TECHNOLOGIES, INC., :CUMBER
Plaintiff
NO.
THOMAS HASHEM d/b/a
GOODFELLAS PIZZA, :
Defendant IN ARBITRATION
COMPLAINT
Plaintiff Wirehead Business Technologies, Inc., by and through its attorneys,
McNees Wallace & Nurick LLC, hereby files this Complaint against Defendant Thomas
Hashem d/b/a GoodFellas Pizza and avers the following:
The Parties
1. Plaintiff Wirehead Business Technologies, Inc. ("Wirehead") is a
Pennsylvania corporation with a principal place of business at 148 Reno Avenue, New
Cumberland, Pennsylvania 17070.
2. Wirehead is engaged in the business of providing services and equipment
to the hospitality industry, and specifically is a dealer and servicer of the Digital Dining
system, an integrated restaurant management system.
3.
Defendant Thomas Hashem d/b/a GoodFellas Pizza ("Hashem") is an
adult individual residing at 348 North Rebecca Avenue, Scranton, Pennsylvania 18504.
Upon information and belief, GoodFellas Pizza is a restaurant located at 1326-328 N.
Webster Avenue, Scranton, Pennsylvania 18510.
Jurisdiction and Venue
4. This Court has jurisdiction over this matter this matter pursuant to 42
Pa.C.S.A. § 931(a).
5. This Court is the proper venue for this matter pursuant to 42 Pa.C.S.A.
§931(c) and Pa.R.C.P. No. 1006 because a transaction or occurrence out of which the
cause of action(s) arise took place in Cumberland County, Pennsylvania.
Factual Background
6. On or about December 12, 2007, Hashem entered into an Agreement with
ad for Wirehead to program and install a custom-designed Digital Dining system
W irehe
at GoodFellas Pizza. A true and correct copy of this Agreement is attached hereto as
Exhibit "A."
7. On or about December 12, 2007, Hashem also accepted Wirehead's
terms for the scope of work that it intended to provide Plaintiff relating to the installation
of the Digital Dining system. A true and correct copy of the System Implementation
Services Scope of Work ("Scope of Work Terms") is attached hereto as Exhibit "B."
g. Pursuant to the Scope of Work Terms, Hashem agreed to have Wirehead
perform the following duties relating to the Digital Dining system: System Staging &
Integration; System Configuration; System Installation; and, System Training. See
Exhibit B.
9. Additionally, Hashem agreed to have Wirehead perform a full installation
of the Digital Dining system at the GoodFellas Pizza location. A true and correct copy
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shem's agreement to have Wirehead perform a full installation of the Digital Dining
of Ha
system is attached hereto as Exhibit "C."
. On or about January 10, 2008, Hashem issued a check to Wirehead in the
10
amount of $21,418.50 as a down payment for Wirehead's services in programming and
installing the Digital Dining system at GoodFellas Pizza. A true and correct copy of this
check is attached hereto as Exhibit "D."
11. From February 14, 2008 through approximately June 12, 2008, Wirehead
delivered and installed a Digital Dining system that it custom-designed and programmed
for GoodFellas Pizza.
12. Wirehead issued five invoices to Defendant for its installation of the Digital
Dining system: 1) Invoice No. 0000060015, dated February 14, 2008, in the amount of
$39,229.94; 2) Invoice No. 0000064041, dated April 29, 2008, in the amount of
$26500; 3) Invoice No. 0000060023, dated May 15, 2008, in the amount of $6,148.00,
4 Invoice No. 0000065134, dated May 22, 2008, in the amount of $26.50; and, 5)
Invoice No. 0000065956, dated June 12, 2008, in the amount of $70.28. True and
correct copies of these invoices are attached hereto as Exhibit "E."
13. The total cost of Wirehead's configuration, delivery, installation, and other
services that Wirehead performed for Defendant that remain unpaid was $45,739.72.
See Exhibit E.
14. Pursuant to the terms of the Agreement, Hashem agreed to pay for the
goods and services provided by Wirehead related to the installation of the Digital Dining
system within fifteen days from the receipt of any invoice provided by Wirehead. See
Exhibit A, $1
-3-
15. The Agreement also provides that "[a]ny and all invoices not paid within
Net 15 days will be subject to an interest charge of 1.5% per month, 18% per annum."
Exhibit A, ¶ 1
16. Aside from its initial payment of $21,418.50 paid to W irehead on or about
10, 2008, Hashem has failed and refused to pay Wirehead for the outstanding
January
balance of $24,321.22 for Wirehead's delivery and installation of the Digital Dining
system at GoodFellas Pizza.
17. Despite repeated demands, Hashem has refused to pay the outstanding
balances due on the invoices for the goods and services related to the installation of the
Digital Dining system provided by Wirehead under the Agreement.
18. The total amount due and owing to Wirehead for the goods and services
provided under the Agreement for the installation of the Digital Dining system is
$24,321.00.
1 g. Additionally, interest at a rate of 18% is accruing on the unpaid balance
due and owing to Wirehead. See Exhibit A, ¶ 1
20. Pursuant to the terms of the Agreement, Wirehead is also entitled to
reasonable attorneys' fees and costs incurred in connection with the collection of
collect
any amount due and owing from Hashem to Wirehead. See Exhibit A, $ 8.
COUNT I
Breach of Contract
21. Wirehead incorporates herein by reference Paragraphs 1 through 20,
above.
-4-
22. Wirehead and Hashem entered into a written Agreement whereby
W irehead agreed to program, deliver, and install a Digital Dining system at GoodFellas
Pizza in exchange for payment by Hashem. See Exhibit A.
for the
23. The written Agreement provided that Hashem was required to pay
goods and services provided by Wirehead related to the installation of the Digital Dining
system within fifteen days from the receipt of any invoice provided by Wirehead. See
Exhibit A, 11 -
24. Pursuant to the written Agreement, from approximately February 14, 2008
through June 12, 2008, Wirehead delivered and installed a Digital Dining system that it
custom-designed and programmed for GoodFellas Pizza.
25. The total cost of Wirehead's configuration, delivery, installation, and other
services that Wirehead performed for Defendant was $45,739.72. See Exhibit E.
26. Beginning on February 14, 2008, Wirehead issued invoices to Hashem for
the value of the goods and services that Wirehead provided to Hashem for the delivery
and installation of the Digital Dining system at GoodFellas Pizza. See Exhibit E.
27. Aside from its initial payment of $21,418.50 paid to Wirehead on or about
January 10, 2008, Hashem has failed and refused to pay Wirehead for the outstanding
balance of $24,321.22 for Wirehead's delivery and installation of the Digital Dining
system.
28. Despite demand, Hashem has failed and refused to pay Wirehead the
$24,321.22 balance due on the invoices from February 14, 2008 through June 12, 2008.
29. Wirehead complied with all terms of the written Agreement by
programming, delivering and installing the Digital Dining system at GoodFellas Pizza.
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30. Hashem has breached the contract between him and Wirehead by
n to a Wirehead for the goods and services provided by Wirehead under the
refuse g p y
Agreement.
te cause of Hashem's breach of the Agreement,
. As a direct and Proxima
31
Wirehead has suffered damages.
Hashem is required to pay Wirehead for the goods and services provided
32.
head under the written Agreement, in the amount of $24,321.22 together with
by W ire
interest, costs and reasonable attorney's fees.
WHEREFORE, Plaintiff Wirehead Business Technologies, Inc. demands
judgment in its favor and against Defendant Thomas Hashem in the amount of
$24,321.22 together with costs, attorneys' fees, interest at 18% and such other relief as
this Court deems just.
COUNT II
Uniust Enrichment
(Alternative County)
33. Wirehead incorporates herein by reference Paragraphs 1 through 32,
above.
34. Hashem benefited by receiving the Digital Dining system from Wirehead
without paying Wirehead for programming, delivering, and installing the Digital Dining
system at GoodFellas Pizza.
35.
Wirehead provided the goods and services to Hashem related to the
Digital Dining system in reliance on Hashem's promise to pay for those goods and
services.
-6-
36. Hashem has failed and refused to perform as promised by refusing to pay
in full for the goods and services provided by Wirehead related to the Digital Dining
system.
37. As a result, Wirehead has been unjustly enriched in the amount of
$24,321.22.
WHEREFORE, Plaintiff, Wirehead Business Technologies, Inc. demands
judgment in its favor and against Defendant Thomas Hashem in the amount of
$24,321.22, together with costs, interest and such other relief as this Court deems just.
McNEES WALLACE & NURICK LLC
By
Date: October 16, 2008 Cla on W. Davidson
I.D. No. 79139
Kimberly A. Selemba
I.D. No. 93535
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff,
Wirehead Business Technologies, Inc.
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A
Terms & Conditions
1. Payment Terms. Wirehead Business Technologies, Inc. (conditions") agrees t and provide conditionsthe goods and the
services ordered herein pursuant to the following terms and
terms and conditions contained herein or provided by Wirehead, shall be binding upon Wirehead unless
accepted by it in writing. You agree that the terms and conditions of sale as set forth herein, and that to the
extent any terms and conditions proposed by You in any writings you originated which are different from,
conflict with or add to Wirehead's shall be deemed to materially alter the terms and conditions of our agreement
and are hereby objected to and rejected by Wirehead. You Igr e o payln for the the event ds and you fail services provided
by Wirehead to you within Net 15 days from receipt of any to make any
payment to Wirehead when due, your entire account(s) with Wirehead shall become immediately due and
payable without notice or demand and Wirehead shall no longer be legally required to provide any future goods
or service to you. Any and all invoices not paid within Net 15 days will be subject to an interest charge of
1.5% per month, 18% per annum. Your credit card on file will be charged for any amounts due and owing by
you to Wirehead that are more than 15 days and remain unpaid within 30 days from the date of any invoice.
2. Force Majeure. Wirehead shall have no liability to You or Your customers or users, and shall have the right
to suspend shipments and/or service hereunder, in the event of war, riot, flood, acts of God, fire, court order,
strike, work stoppage, act of governmental authority or other causes beyond Wirehead's control.
3. Warranty. Wirehead warrants to the original buyer that the goods manufactured or sold by Wirehead are
free of defects in material and workmanship. If you notify Wirehead within 30 DAYS of any such defects (the
"Warranty Period"), and returns the goods to Wirehead at your sole expense, Wirehead shall, at its option, repair
the goods or replace them with goods of comparable value. In either case, the Warranty Period for the repaired
or replaced goods shall extend after the date of repair or replacement for a time equal to the original Warranty
Period. If buyer does not notify Wirehead of such defects, whether patent or latent, within the Warranty Period,
Wirehead shall have not further liability or obligation to buyer therefore. In no event shall Wirehead's liability
under this warranty exceed the original purchase price of the goods which are the subject of a proper notice of
defects. EXCLUDED FROM THIS TRANSACTION ARE ALL IMPLIED WARRANTIES,
INCLUDING WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY
AND FITNESS FOR A PARTICULAR PURPOSE OR USE. BUYER FURTHER DISCLAIMS ANY
RIGHT TO ANY INDIRECT, SPECIAL I PROFITS, DAMAGES,
EVNEUEDIOR, BUSINESS
IIMITATION, ANY CLAIM FOR LOST
INTERUPTION.
4. Title; Risk of Loss. Wirehead warrants that it is the lawful owner of and has the right to sell the goods under
this contract. The risk of loss due to casualty or destruction shall be borne by you upon Wirehead Business
Technologies tender of the goods.
5. Inspection. You shall have the right to inspect the goods delivered under this contract and agree to promptly
notify Wirehead of any nonconformity,. defective condition or breach of warranty, and unless you give prompt
written notice to Wirehead of such breach of warranty, your rights and remedies under this contract shall be
deemed to have been waived. No claim for breach of warranty involving the sale of goods may be made by you
more than 30 DAYS after date of delivery of such goods to you hereunder.
6. Termination. Wirehead may cancel this contract, at anytime for any reason, including, but not limited to
the following: (a) you become insolvent; (b) you cease to conduct your operations in the normal course of
business; (c) you are unable to meet your obligations as they mature, or admit in writing such inability; (d) you
file a voluntary petition in bankruptcy; (e) you suffer the filing of an involuntary petition in bankruptcy and the
same is not dismissed within thirty days after filing; (f) a receiver, custodian or trustee is appointed for you or
For a substantial part of your property; (g) you fail to make payment on the terms and within the time specified
executed an assignment for the benefit of your creditors, or (i) Wirehead reasonably believes, in.
herein; (h) you past, resent or future goods or services.
its sole discretion, that You will not be able to pay for any p P laws of 7. Governing Law. This contract shall be governed and construed
are definedrbynthe Un form Commercial
Commonwealth of Pennsylvania. Terms used in this contract
Code as adopted and in force in of the Commonwealth of Pennsylvania shall have the meanings contained
therein.
8. Remedies. You agree to indemnify and hold Wirehead harmless
e colle tion o an yamount due and owi geby
costs and court costs incurred by Wirehead in connection rewith sent or future right of setoff or recoupment against
You to Wirehead. You further agree to waive any past, p
Wirehead.
Network Errors, or Processing Errors are Your
9. Credit Card Processing. Credit Card Batches,
responsibility and that of Your selected processor and bank. You warrant that all connections and information
provided to Wirehead are accurate and free from error. Wirehead will not be responsible for any errors in Your
upload charge.
CREDIT WIREHEAD
credit card batches. Any changes to the processor will resolute in $400.00
BATCH
MAKES NO REPRESENTATIONS OR WARRANTIES ANY REQUESTS ARE OR WILL BE FREE FROM ERROR. CTUOR FURTHER SPECIALWAIVE
DAMAGES,DISCLAIM
INCLUD NG,
AND ALL PRESENT OR FUTURE DIRECT, INDIRE
WITHOUT LIMITATION, ANY CLAIM FOR LOST PROFITS, LOST REVENUE OR BUSINESS
INTERUPTION AS A RESULT OF ANY FAILED OR INCORRECT ARE LOADED CARD BAT PROPERLY
REQUEST. WIREHEAD WILL NOT WARRANT THAT YOUR BATCHES AND YOU MUST ENSURE THAT YOUR BATCHES CRED LOADED ? PROPERLY
CH REQUESTS FAIL DUE
YOUR ACCOUNT. YOU RUN THE RISK THAT YOUR
TO INPUT ERROR OR ANY TRANSMISSION PROBLEMS.
10. Computer viruses and spyware. You are responsible for any computer virus and spyware protection
programs on your own computer as well as maintaining current updates, monitoring internet use and good
business practices are critical in maintaining a proper functioning system. Removal of un-wanted spyware,
computer viruses and software is always a billable support call.
11. Phone Line. You will need to provide one dedicated Phone/Internet connection for the support
modem and one dedicated PhonelInternet line for the credit card processing.
12. Misc.
Wirehead is Available 24 hours, 7 days a week via phone, dial-in or onsite. Contract Customer will receive
support as per any support agreement. Calls outside of Support Program and Onsite Labor is Always Billable!
Non Contract Customers will be billed for every phone, dial-in and onsite call. Service Contracts start when
equipment is delivered to location and can be renewed annually. Wirehead Business Technologies reserves the
right to refuse service to clients who have balances over 30 days from the date of invoice.
Annual Help Desk Software warranty includes all phone, modem and onsite support; Monday to Friday; 8: 00
AM. To 5:00 PM for a period of 12 months. 8 to 8 Support Contract includes all phone, modem and onsite
support; Monday to Friday; 8: 00 AM. To 8:00 PM for a period of 12 months. 24 Hour Help Desk Support
contracts cover phone support Monday to Saturday, 8:00 am to 7:59 am. Installation is included and is
considered complete upon the completion of Wirehead Business Technologies Signoff Book.
After Hours & On- Site Service and Support is always billed at thhestandard rate
e of tan 0 pRate: 155 NonU/hour)
for the length of the support contract. Phone Support is billed at standard
billed at $155.00 on-site & phone at $65.00. Above rates are for "A" credit customers. "B" or
"C" credit will be billed at a higher rate.
THE UNDERSIGNED, INTENDING TO BE LEGACY L BOUND,
TO THE TERMS AND CONDITIONS
PURCHASE AGREEMENT, INCLUDING, BUT NO
STATED ABOVE.
Name: -F11 Q -ov) cwt
Authorized Signature: ,--- ' ------
Company Name:
Address: 3'4R
Title: >
Date: 1 2,-
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Phone: "? Ar5 ZC????
Fax: 5 -7*** Required for billing information and dial-in support ***
Email: 6r?
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S stem Implementation Services Scope of Work
This document outlines the Scope of Work covered by the System Implementation Services included in the System Purchase Agreement. system
wid Wirehead Business Technologies has defined a confident they based on our experience implementing adequate to provide sufficient nt gratis n, installation, and tra ning on the
array of restaurant and/or bar operations and f Y are
Digital Dining system. However, our experience also tells us that the only way to ensure a smooth and successful system implementation is
through teamwork and communication. To facilitate this, Wirehead Business Technologies will assign a Project Manager to your
implementation upon execution of this Scope of Work document. The Project Manager will be your main point of contact for all project
coordination including project schedule, project resources, etc.
To effectively deliver your system, our team requires adequate lead time to configure, integrate, and test your system. To that end, this Scope
of Work document defines the services that are included under the System Implementation Services line item of the system configuration as
well as required lead times for all project phases. It also outlines project adjustments (either time and/or fee based) in the event lead times are
not met. Wirehead Business Technologies will use best efforts to accommodate project schedule changes, but cannot guarantee available
resources for schedule changes that are made inside of our required lead times. Finally, the success of the system implementation also
depends heavily on operation specific information to be provided to your Project Manager in a timely fashion. This document outlines those
requirements as well.
System Staging &Integration
Wirehead Business Technologies will order all required Equipment & Software to ensure adequate time to integrate, stage, and test
the system in our corporate office. Wirehead Business Technologies will load all required software on the system to support the
Digital Dining system. Additionally, Wirehead Business Technologies will install a limited-time anti-virus software application. It
will be Customer's responsibility to re-new the anti-virus software or choose an alternative virus protection software application
upon expiration of the limited time application installed by Wirehead Business Technologies.
System Configuration
Wirehead Business Technologies will configure the Digital Dining system specifically to your restaurantibar operation based
-
menu items, pricing, and print routing supplied to us by you. We will enter all menu items into the system, apply your prig, and
set up print routes based on your preferences. Wirehead Business Technologies will also configure the system to comply with your
operational procedures including order flow, server/cashier operation, cash management & reporting, and time of day or day of
week pricing specials (i.e. happy hour, etc.) according to the information you provide to us. Please note two very important aspects
of this portion of the System Implementation Services:
1. The information we enter into the system will only be as complete and/or accurate as the information you provide to us.
This means that all menu items, all pricing, and all print route information must be provided to us for the configuration to
be complete. Pay particular attention to menu item modifiers (i.e. add pickles, no sauce, etc.) and menu items you sell but
might not formally appear on the menu such as kids meals, half portions, etc. Finally, take time to consider substitutions
that you allow but again may not be on the menu (i.e. mashed potatoes instead of French fries) and any up-charges
associated with these substitutions. This information is critical to the system configuration process and will greatly ease
the implementation if it is complete, tested, and reviewed prior to go-live.
2. Wirehead Business Technologies requires a two week lead time to effectively program & test your system configuration.
Additionally, it is most efficient for us to program the system all at the same time. While we encourage you to send us
information as you have it, we will not begin system configuration until we have all information from you. If we do not
have all information two weeks prior to the scheduled go-live date, we will inform you of such and work with you to either
reschedule the go-live date or we may apply a Configuration Expedite Fee to configure the system in a shorter time frame
than our standard. It will be at Wirehead Business Technologies discretion to maintain the existing schedule. Our ability
to maintain the existing schedule will be based on resource availability, complexity of the menu, extent of the information
not received, etc.
System Installation
Your System Implementation Services include one day of on-site time to properly install the system. Your System Implementation
Services also include travel related expenses associated with this on-site work. System Installation includes placement of the
equipment in its permanent location, connecting all electrical equipment to appropriate electrical outlets, networking all components
together, and testing.system functionality.
l resources for stem - We
lsubmitted to W reheadyBu ness Tlechnologies
Wirehead Business Technologies requires a two s completed tand in some cases
also require that certain project data and information ct Man
rk with two weeks prior to the System Installation date. tem Installationtdate.o This sdate lmay be changed othr urghemu ualaagreementowith out
you It determine a mutually agreeable Sy heduled Sy penalty provided that the Channstalla on date, your Project Managertwillcconntact youstem
to confirm the installation date. Once a made at least two weeks prior to before the scheduled System plan System Installation date has been confirmed at this time,
em Installationtdatmay not b e and will hcoordinate althresouBrcesnasssuehhnPleaste note t at all
tem
to Sys ion for a
install the system on the agreed on Sys
co pleted ands Wirehead tBusiness
activities detailed t the Site Preparation To the uextenttthatctheset things areo noleted
complete and successful System Installation. your Technologies unable to complete tfothe System insllation in the r System Installat on will be billed at our Gold Plan ttravea phone support, and/orpon s t t rat s
Services, additional visits to the Y
as the case may be.
Note: Your System Installation does not include cable runs that are necessary to connect the POS terminals and printers. These runs can
in advance of Sse to engage the services of a third party. In any
Requirements separately
ystem Installation to avoid additional event, al charges.
provided by be runB cccordingtc he i Site Preparation billed
Gold
event, cables will
e et
rates Any time required by Wirehed Business Technologies ton lServicesedo not Inc dehthe in taat our llation of broad band an
for travel and Ton-site his support. Additionally, your System ImPlementa
connecti connectivity. This service may provided by Wirehead Business Technologies to be billed separately or you may choose to order an
install the broad band internet connectivity on your own. If you choose to do it yourself, connectivity and the appropriate connectivity
equipment (as per the Site Preparation Requirements) must be in place prior to System Installation to avoid additional fees. Any time
spent by Wirehed Business Technologies related to broad band connectivity will be billed at our Gold Plan rate for travel, phone, and/or
on-site support as the case may be.
SVOem Training
Training associated with the implementation of your Digital Dining system comes in four separate, but related sessions. Please
note that Digital Dining is a very comprehensive system and it is therefore impossible to cover each and every function of the ion Serv
. We've
gned the system during the System
all operations protvided that wetget
beanclusie associated
Sys em Training thae is appropriate for nearlyices
Implementation Services to
dedicated time from you and your staff. It is also critical that we have appropriate lea time for all training activities to ensure
proper resource availability. Regardless, we understand that learning curves, availability of dedicated time from management staff,
and desired level of system knowledge can change from operation to operation. If additional training time is required outside of the
scope of the System Implementation Services purchased with your system due to lack of dedicated time from your management
team and/or your desire to become versed in more advanced functions of the system, hourly, '/z day, and/or full day training sessions
can be arranged through the Wirehead Business Technologies' Account Services team. Travel time, on-site, and/or phone support
time associated with additional training sessions will be billed at our Gold Plan rates. These additional training sessions must be
planned in advance to ensure the appropriate resources are available.
The following sections describe each of the four training sessions and the required timeframe for each:
1. Game of Business Classes - Every Monday Wirehead University runs a game of business class to review the functions
and features of Digital Dining. We will review reports, POS features, adding menu items and staff. Clients may attend
these classes as many times as necessary to feel comfortable with Digital Dining. Pre-Live will not be scheduled until
menu and staff have been fully programmed and tested.
2. Pre-Live Training - This is the first training session and will take place at the same time as the System Installation. Prior
to the System Installation, your Project Manager will schedule a specific time of day for the Wirehead Business
Technologies System Analyst to perform Pre-Live Training while he is on-site installing the system. It is critical that you
have the appropriate management/ownership staff on-hand for this dedicated training session. This training session
typically lasts about one hour. Please note, this is not intended to be "server" training in the sense that your servers will
attend this session in a class like setting. This is designed to give your management team the knowledge necessary to
perform server training sessions during the period between the System Installation and the Go-Live. During this training
session, the following important topics will be covered:
a. Adding Staff Members - This back office function will allow you to enter all of your staff members into the
system prior to go-live. This is a critical function to ensure a smooth go-live, but it also is important for on-going
maintenance of your system.
b. Clocking in/out and associated time keeping functions - Knowledge of this feature will allow you to begin
using the Digital Dining System for time & attendance tracking prior to using the system in a live environment.
This is particularly useful in a new restaurant when employees are "on the clock" for training and preparation
purposes.
c. Standard Check Processing - This will include opening a check, applying items to the check, closing the check
out to various payment methods (i.e. cash, credit card, house account, Gift Card, etc.). It will also include
training on the process associated with voiding items, discounts, etc.
d. Cashier/Server Check Out - We will review our "standard" procedure for closing out a shift for a server, bar
tender, and/or cashier.
e. Menu Item Maintenance - While this training won't cover the intricate details of adding new menu items, it
will cover basic menu maintenance so you will be able to find items, modify prices, etc.
Management Training - This training session is ideally performed after the System Installation but prior to the go-live
training (see below). During this training session we will cover a myriad of operational processes and procedures that are
system based or system oriented. During this training session, the Wirehead Business Technologies Project Manager will
be reviewing key system functions with you and interactively working with the appropriate management team to make key
operational decisions. Becoming familiar with these key processes and making specific decisions prior to the go-live
training is a critical step towards achieving a smooth implementation. Logistics associated with this training session may
vary from site to site, but it is quite often most effective to conduct this training session through a remote "webinar". In a
webinar format, your Project Manager will remotely access your system through the internet and then conduct the class
over the phone with you looking at the system that he is actually "connected" to. In this way, he can show you things,
perform certain activities himself, and/or instruct you to take certain actions. Through this method, we find the greatest
attention to detail and the greatest ability for knowledge transfer which is our ultimate goal. The exact functions covered
during this Management Training session will vary depending on the nature of the business (i.e. sit down restaurant, quick
service restaurant, bar only, bar & restaurant, size of operation, etc.), but will typically include the following:
a. Review of check processing functions / Check Transfer procedures
b. Tip Management - This will include commissions on tips, tip pooling, tip out procedures, etc.
c. Special pricing - Happy hour, special events, etc.
d. Front of House Management Functions - This will include a variety of key management functions including
discount application, tip adjustment, re-opening a check, etc.
e. Sales Tax - This will not only include a review of tax rates, but it will cover alcohol taxing with and without
food on the ticket, etc.
f. Cash Reconciliation / System Reporting /End of Day Procedures
g. House Account Functions / Back Office Management Functions = This includes re-opening a past business
day, review of staff maintenance and menu maintenance.
4. Go-Live Training -"This is the on the job training that occurs during live operation of the system, It is required that this
training happen on the first days of operation with real customers and real money changing hands. Wirehead Business
Technologies requires two weeks advanced notice of your go-live date so we can properly align our resources to
provide you with Go-Live Training. 'The System Implementation Services includes two days of Go-Live Training for
sites with fewer than five POS terminals and three days for sites with five or more POS terminals. Travel related expenses
(i.e. transportation, lodging, and meals) for either the two or three day period (as the case may be) are included in your
System Implementation Services fee. During the Go-Live Training session, a Wirehead Business Technologies system
expert will be on-site and available to help with any unusual circumstances, make minor system adjustments that may be
necessary, and/or provide reinforcement of the functions covered in the Pre-Live Training & Management Training. The
Wirehead Business Technologies representative will also be available to help reconcile the paperwork at the end of each
business day and work with the system reporting to help you realize the value of the business intelligent available through
the Digital Dining System. A review of time & attendance functions will also occur at this time to prepare you for payroll
processing and help ensure accurate time & attendance transactions on an on-going basis.
Please note that the two days of Go-Live training included in your System Implementation Services is for Monday through
Thursday only. Friday, Saturday, and/or Sunday Go-Live Training may carry additional fees.
Fees
Additional fees, if any, will be documented by your Project Manager on the Wirehead Business Technologies Site Survey
document. They will be payable to your Project Manager through Customer company check or though credit card authorization at
the end of the Go-Live Training period.
Acceptance
Through signature below, Customer & Wirehead Business Technologies acknowledge acceptance and understanding of the System
Implementation Services Scope of Work. Both companies agree to work cooperatively together to ensure a smooth and successful
system implementation. 6-C ?//? `
Restaurant Name: " I
Customer Acceptance
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Installation. Process
Installing a computer system in a restaurant is a challenge: Consider that every transaction must be processed by
the restaurant system and by a large number of people. The best installations have tense periods. Please be
prepared.
Wirehead Business Technologies offers two different installations processes to help you implement your new
business tool and new business processes. When any change is made in your business, there will be decisions that
you will need to make and new processes to implement with everyone on your staff. Wirehead Business
Technologies' goal is to teach you make any changes to your menu, staff and report layouts. It is not reasonable
to think that you will be able to understand every facet of the software in the beginning. Wirehead Business
Technologies will provide on-going software support via Help Desk and Wirehead University Classes which we
encourage you to take advantage of as you need more information.
Option One (Recommended): Shared Installation
The Shared Installation allows the end user to program all of their menu items, staff and basic layout in a
classroom type setup. The Shared Install always starts on a Monday with the I" day (10:00 to 5:00) of Digital
Dining Training and POS Layout. Classes are held at the Wirehead Business Technologies offices. The following
days, customer will program and setup their Digital Dining System with support help as needed. After the system
is complete, we will schedule your on-site portion of the installation. A support technician will be on location for
3 business days. The I' day onsite is planned for configuration of the hardware and staff POS training. The 2
day onsite, we will provide One (1) Full Live Day Coverage (Open until Midnight). The final onsite day is
reserved for Reports Review and additional training. This day is One (1) Business Day (9:00 am until 5:30 pm).
Additional week days may be purchased for further onsite support. It takes around 60 to 80 hours to
program a full system from menu, staff, AR to the printers and registers. The shared install
allows the end user to learn and train while entering their menu and staff. Customers should
budget 30 to 40 hours depending on the size, number of items and complexity of the operation. (s
Hours / Menu ie. Breakfast, Lunch)
Option Two: Full Installation
The main difference with the Full Installation is that Wirehead Business Technologies programs the menu items
and POS Windows Portion of the Installation. Two additional days at the customer's location are included for the
customer to test every menu item and make changes to the layout. Wirehead Business Technologies will only
program menus that are provided. Additional menu items become the responsibility of the end user. The Full
Install starts on a Monday and ends with a Business Days Live Coverage on Friday.
We, Good Fellows Pizza, understand the installation processes and have selected the following installation option
for our business:
Wirehead Full Install
If
Customer's Initials:
Wirehead Business Technologies will only start the installation process after all data collection has been completed, all
financial arrangements are finalized and payments for the system are complete. Non Refundable Deposits are required for
Lease & Cash Payment Options.
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148 Reno Avenue
New Cumberland, PA 17070
Phone. 717-214-4000
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MYirehead Business T'echrr,"ies
148 Reno Avenue
New Cumberland, PA 17070
Phone: 717-214-4000
Fax- 717-214-4003
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1326-328 N Webster Ave
Scranton, PA 18510
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Wireheod $usiness `technologies
148 Reno Avenue
New Cumberland, PA 17070
Phone: 717-214-4000
Fax: 717-214-4003
Good Felias Pizza
i,326328 N Webster Ave
Scranton, PA 18510
Page 4
INVOICE
2/1412008 0000060015 0000148
A!1 Customer Termer are C_O.D_
Good Felias Pizza
1.3 6-328N Webster Ave
Scranton, PA 18510
INVOICE
Wirehead Business Technologies
148 Reno Avenue
New Cumberland, PA 17070
Phone: 717-214-4000
Fox: 717-214-4003
GWA Pellas Pizza
1326-328 N Webster Ave
Scranton, PA 18510
412912008 0000064041 0000148
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1326-328 N Webster Ave
Scranton, PA 18510
Wirehead Business Technologies
148 Reno Avenue
New Cumberland, PA 17070
Phone: 717-214-4000
Fax: 717-214-4003
Good Fellas Pizza
1326-328 N Webster Ave
Scranton, PA 18510
INVOICE
811512008 y0000060023 0000148
All C?siomer Terms are C.G.D.
Good Fellas Pizza
132628 N Webster Ave
Scranton, PA 18510
Wirchead Business Technologies
148 Reno Avenue
New Cumberland, PA 17070
Phone: 717-214-4000
Fax: 717-214-4003
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1326-328 N Webster Ave
Scranton, PA 18510
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1326-328 N Webster Ave
Scranton, PA 18510
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SUBTOTAL 125.00
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Wireheod Business Technologies
148 Reno Avenue
New Cmberiand, PA 17070
Phone: 717-214-4000
Fox: 717-214-4003
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Good Fellas PIZZO
1326-328 N Webster Ave
Scranton, PA 18510
VERIFICATION,
Subiect to the nenatties of 18 Pa. C.S. 644014, relating to unsworn falsification to
authorities, 1, Andrew Rill, President of Wirehead Business Technologies, Inc., certify
that I am authorized to execute this verification on its behalf and have reviewed the
foregoing Comolaint and that the facts set forth therein are true and correct. to the best
of my knowledge, information and belief.
joll-+S
Andrew Rill as President of
Wrehead Business Technologies, Inc.
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-06203 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WIREHEAD BUSINESS TECHNOLOGIES
VS
HASHEM THOMAS D/B/A GOODFELLAS
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:
HASHEM THOMAS D/B/A GOODFELLAS PIZZA
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of LACKAWANNA County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On December 3rd , 2008 , this office was in receipt of the
attached return from LACKAWANNA
Sheriff's Costs: So answers:
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kli
Dep Lackawanna Cc 28.40 Sheriff of Cu _erland County
Postage 1.69
67.09 ? :z?n??6b.,
12/03/2008
MCNEES WALLACE NURICK
Sworn and subscribe to before me
this day of
A. D.
In The Court of Common Pleas of Cumberland County, Pennsylvania
Wirehead Business Technologies Inc
vs.
Thomas Hashem d/b/a Goodfellas Pizza 08-6203 civil
No.
Now, October 21, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Lackawanna 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 County Sheriff. Thank you.
Affidavit of Service
Now,
within
upon
at
by handing to
a
copy of the original
and made known to the contents thereof.
So answers,
Sheriff of County, PA
COSTS
Sworn and subscribed before SERVICE $
me this day of , 20 MILEAGE
AFFIDAVIT
20 , at o'clock M. served the
.
SHERIFF'S RETURN - REGULAR ,.
CUM?c I nd G.0r"?
CASE NO: 2008-00625 T of??
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF LACKAWANNA `
WIREHEAD BUSINESS TECH.INC.
VS
HASHEM THOMAS D/B/A GOODFELLAS
CPL. BRENDA GOOSLEY , Deputy Sheriff of Lackawanna County
County, Pennsylvania, who being duly.sworn according to law,
says, the within NOTICE AND COMPLAINT was served upon
HASHEM THOMAS D/B/A GOODFELLAS PIZZA the
DEFENDANT , at 0009:45 Hour, on the 6th day of November-, 2008
at 348 N REBECCA AVE
SCRANTON, PA
HIM PERSONALLY
by handing to
a true and attested copy of NOTICE AND COMPLAINT together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 00 John Szymanski, Sheriff
Service q?jl 00
Affidavit 5 .00
Surcharge .00 eZ A?
.00 eputy Sheriff
.00 00/00/0000
Sworn and Subscribed to before
me this day of
A. D.
Notary
.11
WIREHEAD BUSINESS IN THE COURT OF COMMON PLEAS
TECHNOLOGIES, INC., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 08-6203 CIVIL
THOMAS HASHEM d/b/a
GOODFELLAS PIZZA,
Defendant IN ARBITRATION
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
Please discontinue the above captioned action without prejudice.
McNEES WALLACE & NURICK LLC
Date: February 2, 2009 By:
Clayto . D idson
Attorney I.D 79139
100 Pine Street - P.O. Box 1166
Harrisburg, PA 17108-1166
Direct Fax: 717-260-1678
Phone: 717-232-8000
cdavidson(ab,mwn.com
Attorneys for Plaintiff,
Wirehead Business Technologies, Inc.
CERTIFICATE OF SERVICE
The undersigned hereby certifies on this day that a true and correct copy of the attached
Praecipe to Discontinue without prejudice was served by first-class United States mail, postage
prepaid, addressed as follows:
Kevin J. Dempsey, Esquire
Roth & Dempsey, P.C.
436 Jefferson Avenue
Scranton, PA 18510-2448
Date: February 2, 2009
57
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4 V
C
WIREHEAD BUSINESS
TECHNOLOGIES, INC.,
Plaintiff
V.
THOMAS HASHEM d/b/a
GOODFELLAS PIZZA,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-6203 CIVIL
: IN ARBITRATION
AMENDED PRAECIPE TO DISCONTINUE ACTION
Please discontinue the above captioned action with prejudice.
Date: February 17, 2009
McNEES WALLACE & NURICK LLC
By: 5David Clayto W.Attorney I.100 Pine Street - P.O. Box 1166
Harrisburg, PA 17108-1166
Direct Fax: 717-260-1678
Phone: 717-232-8000
cdavidson(&,mwn.com
Attorneys for Plaintiff,
Wirehead Business Technologies, Inc.
CERTIFICATE OF SERVICE
The undersigned hereby certifies on this day that a true and correct copy of the attached
Amended Praecipe to Discontinue Action was served by first-class United States mail, postage
prepaid, addressed as follows:
Kevin J. Dempsey, Esquire
Roth & Dempsey, P.C.
436 Jefferson Avenue
Scranton, PA 18510-2448
Date: February 17, 2009
Clayton . Davidson,
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