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Home My WebLink About08-6997Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. DOCKET No. pg -69q? 0'-'V a (erw- ALLURE BRIDAL & FLORIST, LLC CIVIL ACTION - LAW and DOUGLAS MCCALL JURY TRIAL DEMANDED Defendants NOTICE TO DEFEND TO: Allure Bridal & Florist, LLC and Douglas McCall 850 High Ridge Road Stamford, CT 06905-1911 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 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, TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Dated: November 26, 2008 By; / Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : DOCKET No. 0 9- 6 9 17 e4?? 7-L,-- ALLURE BRIDAL & FLORIST, LLC CIVIL ACTION - LAW and DOUGLAS MCCALL JURY TRIAL DEMANDED Defendants COMPLAINT Plaintiff, Allegro Designs, LLC, by and through it's undersigned counsel, Archer & Archer, P.C., files the following Complaint against Defendants, Allure Bridal & Florist, LLC, and in support thereof avers as follows: 1. Plaintiff, Allegro Designs, LLC ("Plaintiff'), is a Pennsylvania Limited Liability Company with a principal place of business located at 95 Eastgate Drive, Camp Hill, Pennsylvania 17110. 2. Defendant, Allure Bridal & Florist, LLC, through information and belief, is a Connecticut Limited Liability Company with it's principal place of business located at 850 High Ridge Road, Stamford, Connecticut 06905. 3. Defendant, Douglas McCall, is an adult individual, through information and belief, the sole member of Allure Bridal & Florist, LLC and maintains a place of business located at 850 High Ridge Road, Stamford, Connecticut 06905. 4. At all relevant times, Plaintiff is in the business of manufacturing and wholesale distribution of children's formal wear and dresses. 5. Through information and belief, Defendant, at all relevant times, is 1 engaged in the retail sale of formal wear and dresses. 6. At all relevant times, Defendant maintained a regular stream of business and contact with the Commonwealth of Pennsylvania, in particular within Cumberland County, as a result of Defendants' regular and repeated business contacts with the Plaintiff and others. 7. Plaintiff and Defendant had an ongoing business relationship whereby Plaintiff distributed dresses for sale that were purchased by the Defendant. On or about August 14, 2008, Defendant executed Plaintiff's "Terms and Conditions" to be applicable to and govern all subsequent transactions between the parties, which are attached hereto and incorporated herein by reference as Exhibit "A." 9. Pursuant to the Terms and Conditions, Defendants agreed to personal jurisdiction of the Commonwealth of Pennsylvania for all disputes with Plaintiff. 10. At Defendants' request, Plaintiff processed orders for merchandise more fully described in Plaintiff's invoice number 873, attached hereto and incorporated herein as Exhibit "B." 11. The principal amount due for the above-referenced invoices if $432.00 for merchandise, shipping and handling charges. 12. Defendants failed to accept delivery of Plaintiff's merchandise upon delivery, causing the merchandise to be returned to the Plaintiff. 13. Despite Plaintiff's efforts, Plaintiff has been unable to resell the custom items that were ordered by the Defendants. 14. Pursuant to the terms and conditions agreed to by the Defendants, Defendant agreed to pay Plaintiff the sum of $50.00 for all refusals. 15. Pursuant to the terms and conditions agreed to by the Defendants, Defendants agreed to pay storage fees, as well as reasonable attorney's fees and interest 2 for all refused merchandise. 16. The total sum of refusal fees due from the Defendant to the Plaintiff is $50.00 on the invoices. The total sum of interest due and owing from the Defendant to the Plaintiff is $77.12 to date. 17. Pursuant to the Terms and Conditions signed by Defendant, Douglas McCall, agreed to the personally liable for all charges incurred by Allure Bridal & Florist, LLC. 18. Pursuant to the Terms and Conditions signed by Defendant, Douglas McCall, Plaintiff is entitled to costs and attorney's fees. 19. Despite Plaintiff's repeated demands for payment, Defendant refuses to pay Defendant the sums due and owing. FIRST COUNT - BREACH OF CONTRACT 20. The allegations of the proceeding paragraphs 1-19 are incorporated herein by reference as though set forth herein at length. 21. Defendants' request for goods and services provided herein and Plaintiff's agreement to provide those goods for valuable consideration constitute a valid and binding contract between the parties. 22. The Terms and Conditions were applicable to and governed each of the transactions alleged herein. 23. Despite Plaintiff's complete performance under the contract between the parties, Defendant has breached the contract by failing to tender payment thereon. 24. By reason of the facts aforesaid, Defendant has materially breached its obligations under the contract between the parties, all to the damage of the Plaintiff in the amount of $559.12, plus continuing accrued interest thereon. WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $559.12 plus continuing accrued interest and costs of this action; and b. for attorney's fees; and c. any other relief deemed appropriate and just by the Court or to which the Plaintiff is entitled as a matter of law. SECOND COUNT - QUANTUM MERUIT 25. The allegations of the proceeding paragraphs 1 - 24 are incorporated herein by reference as though set forth at length. 26. Defendant, as stated herein, requested the custom goods from the Plaintiff. 27. The Plaintiff fully filled the orders requested by the Defendant, who knew Plaintiff would expect payment therefore. 28. The market value of the goods and services ordered by Defendant is $432.00. 29. It would be unjust for Plaintiff not to be paid for the value of its goods, together with the service charges and interest alleged herein. WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $432.00 plus continuing accrued interest and costs of this action; and b. for attorney's fees; and c. any other relief deemed appropriate and just by the Court or to which the Plaintiff is entitled as a matter of law. 4 THIRD COUNT - ACCOUNT STATED 30. The allegations of the proceeding paragraphs 1 - 29 are incorporated herein by reference as though set forth herein at length. 31. Plaintiff maintains a book account regarding Defendants' purchases. According to the records, Defendants owe Plaintiff the sum of $559.12 for goods and services requested by Defendant. 32. The funds due and owing Plaintiff by the Defendant are fair and reasonable for the goods and services provided. 33. Although demands for payment have been made, Defendant continues to refuse to pay the amount due and owing Plaintiff. WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $559.12 plus continuing accrued interest and costs of this action; and b. for attorney's fees; and any other relief deemed appropriate and just by the Court or to which the Plaintiff is entitled as a matter of law. Dated: November 26, 2008 Respectfully Submitted, Archer & Archer, P.C. By: / --? Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiff 5 Exhibit "A" 10/02/2003 02:37 7177612343 THE IAD?TUJ ??_?F vTF1 Twmmwcnmakm M?Aw ?V DMOV4 LL(! "& IUI, Q L ? M L am? .r...._ ?_, rw?sa? wYfirrrrrAlr ?? ?••riu rind i?? M ?? t wwr?+wr<?r?Mrr??s? i IM Wft Al 3p ?????awr+irw?w?rr?t?s?w ??rMeMwMs 4 7MIt?NM?11w's?s?ir?wMar? ? i???iw wNnr.?.Mwlr4wr??' 7Y11a ?Mrw ? ???. 11f III ea?*Nl?r r# a MwisrsMki?rtwo 11 WON I i stomps t??wtlrwrtws,iw U. + ww ------ 11M?a a+w?rs rirs oit ? ? i ?+++??M?w?t?Ir?rMMIrMMRwA K ?¦N?t?MrllAMrrtw?wM rrMM???~Mwglra IL 7igiswrl??rtrlrR?III?sMirsrrNNltMMf/IIIS-ablri ommo m +u?w?Itir:?rar?irt?r?rrriwwl?r? ? ??MR`?t?M+ff?+Mlai??wMM?Mi?awwM S10h? -...C?.r. Mrx 44?i X kow4bo a ea+we. #UArM.?#tsMit a r?awt+rwbsa NNW sue.. "so*? ? ?'MMAruwrrMwrlrt lso ???arlr ?eM rW aa41w? ??Ae ? A R?tA1?IR. rowMdola waftw b a al ee rsr*AdbwW IWMd away snowla sm ombimaopomm"4aw a m%eiirnmpd uaw??., wry L aarrjftM1M FA 1 11 F , 7 &'d WMII @L-ow ? UPOMMOI dw7A 80 n &W 10-02-2008 14:28 ARCHER AND ARCHER PC 7172338675 PAGE10 Exhibit "B" q/R2/2008 02:37 7177612343 ;te 7 `U?+bon P.O. BOX 734 Camp HUI, PA 17001 Allure Bridal 850 high Ridge Road Stamford, CT 06905 Dab 9272008 Invoke # 873 Akft BrkW 850 tligh Ridge Road Stwnford, CT 06905 Phone. FAX: 203-322-7673 Saks Rep Skip Dab 927/2008 P.U. # T stock d r-^-? JL ? Due Dab 927/2008 erms oo , 1022 Nory! me 2 99.00 99.00 1040 INOry "M oft 3 96.00 95.00 1099 derrlpegne wNh dIq ab size 8 96.00 96.00 1059 Sable wllh dwmpogns trim and tl mn size 5 99.00 99.00 coo coo 9.00 9.00 8hiWn8 and- Shipping and Handling 13.00 13.00 Refusal Refusal Fee 50.00 50.00 COD COD 9.00 9.00 Shipping and ... StSp "pfd Handling 13.00 13.00 Interest 10% 77.12 77.12 CdlecUons1" 40% 223.68 223.68 Attention: Please make checks payable to ALLEGRO DESIGNS info(cr Wybu8coriec dw.com Phone$ (717) 761-2344 www.la$ybugc0118c6on.corrl FAX # (717) 761-2343 THE ORDER AND REFUSED THIS CRY / RETURNED TO 10MIrA p8 1:43 P.M. THE RECEn" DID MDT VWNT THE ORDER AND RERMED THIS DELIVERY 101012008 418&M. OUT FOR DELIVERY NNORW LLK. 09gordwe M P.M. DESTINATION SCAN CTI US a) Total $782.80 PaprrrentWCredits $0.00 Balance Due $782.80 THE LADYBUG COLLECTO PAGE 02/10 hues://wwwaM-uP&oom/WebTr .kinesummary 10/2?2008 10-02-2008 14:26 ARCHER AND ARCHER PC 7172332675 PAGE2 VERIFICATION I, William Jupitz, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: 1112 o /6,5 ? ? o0 9u O D `r ii r.? tj.1 -rt R O Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, Plaintiff, Defendants V. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET No.: 08-6997 Civil Term ALLURE BRIDAL & FLORIST, LLC CIVIL ACTION - LAW and DOUGLAS MCCALL JURY TRIAL DEMANDED TO THE PROTHONOTARY: PROOF OF SERVICE The following Defendants were served by certified and regular mail with the Complaint: Allure Bridal & Florist, LLC and Douglas McCall, 850 High Ridge Road, Stamford, CT 06905-1911. A copy of the green card is attached hereto as Exhibit "A". Dated: February 10, 2009 By: omas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiff Exhibit "A" ¦ Complete Items 1, 2, and 3. Also complete 13 Agwit Item 4 if Restricted Delivery Is desired. X 0 Addressee , i? • ¦ Print your name and address on the reverse so that we can return the card to you. B. Received by ( Printed Name) C. Date ¦ Attach this card to the back of the madpiece, or on the front if space permits. D. Is delivery address different from Rem 17 Y 1. Article Addressed to: 411LA'{ ?3Ytd?l 9 Fl0lt5?, If YES, enter delivery address below: 0 No 1 Lt,C and OD??v CLLaII ? '}so ? y ? O U q 05- la ?1 ,,vj+o,(d, C 3. Service 1W, ' CarWW Ma 0 Express mail O 0 Registered 2rRetum Receipt for Merdwidiee O Insured mail 0 C.O.D. 4. Reetrkted DeBveryT (Extra Fee) ? 1Ns z• 7006 0810 0006 7590 7781 f r tm service w" (transfer from PS Form 3811, February 2004 Domestic Retum Receipt 102595-424&15e0 -.-./ . .. CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: Allure Bridal & Florist, LLC and Douglas McCall 850 High Ride Road Stamford, CT 06905 Date: February 10, 2009 At? 4; - ls? U Jessica R. Porter, Paralegal r..,i Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, 95 Eastgate Drive Camp Hill, PA 17011 Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v ALLURE BRIDAL & FLORIST, LLC and DOUGLAS MCCALL, 850 High Ridge Road Stamford, CT 06905 Defendants. DOCKET No. 08-6997-Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS, AND NONMILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for Plaintiff and against Defendants above- named only and assess damages certified to be calculated as a sum certain from the Complaint, as follows: Principal $423.00 Refusal fees: $50.00 Interest $77.12 TOTAL: $550.12 Understanding that false statements made herein are subject to penalty under 18 Pa. C.S.A. § 4904, Unsworn Falsification to Authorities, I verify that: 1. The above are the precise last known addresses of the parties. 2. The annexed notices(s) of intention to file a Praecipe (Exhibit "A") were mailed to all parties Defendants and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this Praecipe. The said Defendants are not in the military service of the United States or otherwise within coverage of the Soldiers and Sailors Relief Act and are over 18 years of age (Exhibit `B"); THIS 17* DAY OF b , , 2009, JUDGMENT IS ENTERED IN FAVOR OF PLAINTIFF AND AGAINST DEFENDANTS BY DEFAULT FOR WANT OF AN ANSWER AND DAMAGES ASSESSED AT THE SUM OF $1,293.83 AS PER THE ABOVE CERTIFICATION. NOTICE GIVEN PURSUANT TO Pa.R.C.P. 236. Respectfully submitted, By: PR HONOTA ARCHER & ARCHER, P.C. e-;? Thomas A. Archer, Esquire PA ID# 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-0056 717.233.8676 Attorney for Plaintiff • a , Exhibit "A" . A. LAW OFFICES ARCHER & ARCHER, P.C. THOMAS A. ARCHER, ESQ. - NEW JERSEY OMCE: Adm&ed PA & NJ 2515 NORTH FRONT STREET - JENNIFER BUSH ARCHER, ESQ. P.O. BOX 5056 37 MOUNTAIN BOULEVARD AdMided PA & N! HARRISBURG, PENNSYLVANIA 1711040% SUITE 1 WARREN NJ. 070" (717) 233-8676 (stl 945-2000 FAX: (717) 233-8675 FAX: (908)995-2104 www.archerandercber.com January 28, 2009 Allure Bridal & Florist, LLC c/o Douglas McCall 850 High Ridge Road Stamford, CT 06905 RE: Allegro Designs, LLC v. Allure Bridal & Florist, LLC and Douglas McCall Cumberland County CCP Docket No.: 08-6997-Civil Term Dear Mr. McCall: Enclosed please find a Ten (10) Day Notice of Default regarding this matter because you have failed to take action with respect to a Complaint that was served upon you via certified and regular mail on December 2, 2008. This is a serious matter. If you fail to take action with respect to the afore-- mentioned Complaint, the Plaintiff may take a Default Judgment against you and you could lose rights or property as a result of your inaction. Please be guided accordingly. Very truly yours, T (.?"--- Thomas A. Archer TAA/jrp Enc. Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, DOCKET No. 08-6997-Civil Term ALLURE BRIDAL & FLORIST, LLC CIVIL ACTION - LAW and DOUGLAS MCCALL JURY TRIAL DEMANDED Defendants IMPORTANT NOTICE TO: Allure Bridal & Florist, LLC and Douglas McCall 850 High Ridge Road Stamford, CT 06905 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A RESPONSE TO THE COMPLAINT THAT WAS SERVED UPON YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LWAYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATED: January 28, 2009 By: 4 Thomas A. Archer, Esquire 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-0056 (717) 233-8676 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: Allure Bridal & Florist, LLC and Douglas McCall 850 High Ride Road Stamford, CT 06905 Date: January 28, 2009 d4L?) -T? . Tot-t7F Jessica R. Porter, Paralegal <<B? v . Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 FEB-10-2009 07:19:16 Last Name First/Middle Begin Date Active Duty Status Service/Agency MCCALL DOUGLAS Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. n?,a Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www defenselink mil/faq/pis/PC09SLDR html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: COBGEWVHPA https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 2/10/2009 CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: Allure Bridal & Florist, LLC and Douglas McCall 850 High Ride Road Stamford, CT 06905 Date: February 10, 2009 At4? -R TCL--= Jessica R. Porter, aralegal U- -- r-.a * 000 IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENSYLVANIA CIVIL DIVISION ALLEGRO DESIGNS, LLC, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : DOCKET No. 08-6997-Civil Term ALLURE BRIDAL & FLORIST, LLC CIVIL ACTION - LAW and DOUGLAS MCCALL : JURY TRIAL DEMANDED Defendants Notice is hereby given that a V 1)80men in the above-captioned matter has been entered against you in the amount of 5M. /A on A copy of all documents filed with the Prothonotary in support of the within judgment is / are enclosed. By: A?Urt Long Prothonotary Deputy If you have any questions regarding this Notice, please contact the filing party: Thomas A. Archer 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 717-233-8676 (This Notice is given in accordance with Pa.R.C.P. No. 236.) .. , LAW OFFICES ARCHER & ARCHER, P.C. IUOMM A. A*CVRX; ESQ. NEW JERSEY OFFICE: A I AN?adPA &-W 2515 NORTH FRONT STREET JFNMWM BUSH ARCHER, M. P.O. BOX 5056 37 MOUNTAIN BOULEVARD Ado mWed PA NI HARRISBURG, PENNSYLVANIA 17110-00% SUITE 1 WARM, NJ 87059 (717) 233-8676 (9031995-2800 FAX: (717) 233-8675 FAX: (908) 495-2104 www.archerandarcher.com January 28, 2009 Allure Bridal & Florist, LLC C/o Douglas McCall $50 High Ridge Road Stamford, CT 06905 RE: Allegro Designs, LLC v. Allure Bridal & Florist, LLC and Douglas McCall Cumberland County CCP Docket No.: 08-6997-Civil Term Dear Mr. `McCall: Enclosed ple find a Ten (10) Day Notice of Default regarding this matter because.you have failed to take action with respect to a Complaint that was served upon you via certified aid regular retail on December 2, 2008. This is a serious matter. If you fail to take action with respect to the afore- mentioned Complaint, the Plaintiff may take a Default Judgment against you and you could lose rights or property as _a result of your inaction. Please be guided accordingly. Very truly yours, Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street PO Box 5056 Harrisburg, PA 17110-5056 717.233.8676 ALLEGRO DESIGNS, LLC, Plaintiff, v ALLURE BRIDAL & FLORIST, LLC and DOUGLAS MCCALL Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No. 08-6997-Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED IMPORTANT NOTICE TO: Allure Bridal & Florist, LLC and Douglas McCall 850 High Ridge Road Stamford, CT 06905 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A RESPONSE TO THE COMPLAINT THAT WAS SERVED UPON YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LWAYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 DATED: January 28, 2009 By: A t/ Thomas A. Archer, Esquire 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-0056 (717) 233-8676 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Jessica R. Porter, Paralegal, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, via U.S. First Class Mail, addressed as follows: Allure Bridal & Florist, LLC and Douglas McCall 850 High Ride Road Stamford, CT 06905 Date: January 28, 2009 A?N? -? Jessica R. Porter, Paralegal ?"? ?? ;'? c4? ?::? rs _? ._..s . - w 9 -f -h `.?. w? -.; ? { '. -'.. ?? kA ../ w