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Home My WebLink About09-0479Archer & 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 FIREFLIES & FAIRY TALES, INC. and AMBER KUEHN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No. QQ q'r? CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Fireflies and Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 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: January 27, 2009 By: / Thomas A. Archer, Esq ire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 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. 8. On or about June 12, 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 Plaintiffs invoice number 1107, attached hereto and incorporated herein as Exhibit "B." 11. The principal amount due for the above-referenced invoice is $447.00 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 invoice. The total sum of interest due and owing from the Defendant to the Plaintiff is $17.37 to date. 17. Pursuant to the Terms and Conditions signed by Defendant, Amber Kuehn agreed to the personally liable for all charges incurred by Fireflies & Fairy Tales, Inc. 18. Pursuant to the Terms and Conditions signed by Defendant, Amber Kuehn, 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 $514.37, plus continuing accrued interest thereon. WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $514.37 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 $447.00. 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 $447.00 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 $514.37 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 $514.37 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. Respectfully Submitted, Archer & Archer, P.C. Dated: January 27, 2009 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" . i : 23Wd SZ88££2LTL Dd N3 )NU 04U UNDW £tb=2T 8002-S2-TT aG Terms and Conditions 'rite followlod mum and coadltMus apply to all ftmaedom between you (held, " i1ar/Bu?ee"), the undwtrdiped, add Allep0 De fca, LLC Wa The L» dlbty Coffeelfon 0mvia, "if&ro" )t 1. MM' ADW reeervee ft till t to Pisa say aooamt as a CAD.-Wit a myabas withaa u6tiae. We do oft avot wW teats and proptgn I. 2. PA=b All Aden nr coaddaad made to ondar. Orden mw be hied; phone ordees wi11 amt be Oro vb& rAw allow 64 wodn for delivery. Rueb deRvary andee 6 weelu u trisdlabb !Orr an sddldartd ebM A cadkmaion wi11 be fluted wid" 2 deys of a>i a*m Ow'St6 No omdfMW cw will be sold far cddm witlum k oAtrrbers on dtela. R you do aamdw a eonlirmsdat, the ads should be ocaddessd not plus d, 3. $ f, U., N:Wasely No Rcftmkl in do swat ot ro ued mwMAdhe open ddlvay. RAW1n4tBeyer's account wW wtumrlwdfy be placed oo hold swu and no otdns will be shipped antil the mamer k tsealvsd. 'ftrere will ahw be a refbsd he of 650.00 sod Qeipht obarges applied. m doe evwA o[sa1BW m atmept deh?r of nlMebarrdisa, Rstsileo?0eejaee wiU be tcepoaaible uaroaa ottawthendlsa watt any noMMY msuonikk mill-d rr eash broi AAS lntersa aeleuiased a 1611 per MOM *MR era end wousi 'a fees ineureed by Adrap& 4. :Thera sill be a 343RD chsrOe ear eeah renreued atesdt. =I-MMrMMMjjP=WJ The)teMUWBayw wM be reepop" far dta aattryry invcloe sad a8 hes NOW incbtdfnS. but not Mead IN itmamet adoekaed a 16% per somas as wall M sqy aeoesssry eassateebit talbotlaos cops, iao uft Doan Will and amraey's teas fawnod by AUapro. AIIOVO Ywavas the right w low amy r hMw shacks Ore am*edtbu for proeeauwL 3. t A.) Upon delivy. RtatdWBnyar is r Pmuibb for dm impeceoas of sU tna buWir- Aoy peawwM mace bs tepoeeed vddda d,raa (3) days Steer dra teedpt of add mrscbts?dlsa. 771. LsdybM* C.p(lwA0a is wA twporulbk ibr axw dya lot ar fabric wistiaw 7bt leelybatx Colltcdorr b aot tetrpooeirle Atr airy i+etlfYlla n Rot nntlAed wiahln Ohs 3?dey ? p+ri? B.) No marabpe" will be aoespud for.stela witltettt our 0"6 RetM Mnelandite Atrlhasiratkn (itMA) Aneseer. No aceptim wM bo made. C.) Mw& will be no tefande or aiduq a on gmdal Orders. 8. ?LLAMM: All olden am oeutdered wads m alder. 1b RshilemrBuya[ hSe she rlSl?t to tmnoel any order winds 72 boon 6tMtr f--? the nrre !C vwa ptaead >a writtnS. Vstbal tur:oeUedws wW not be atrespead. b athOtvViN apaafied OB yowl older ooo8rmsdoe itmwaea. rhtpply sad 9. MMMrg All alas wilt be shipped UPSIMMd Ualoss S AMW amen ouatot deo taeyoa Mlky. No dlaoora? thr dnl?wt caul hs +wwuptad. to. in ads to roakastn toe imspe of 7tu L** q CoilarN^ no SUM k to aver advaedm war r sink r>dlaa on the barn at at 46m*tsd prices. Ws do sot support mm who Soil dkmdy oval dW kawA . Ibis ptaetloe undetmireee oat W4a wm soilless. ii, All oompletioa dares mum be hwaid a cared on dw ardet or sower. 77u Ia44sit CDMlmon is na pgooullob for any datays awe to Shipp ft roaa hwhalup. of fisawd dl mwL 12. The IRetelaYBuyw aMi nw& aenust a p1m stook order per divistas Is tine Or n6 epWW Orders will b? looepeed. 13. Ow Ladybug Collodion maorvet do rilM to osim to d6 bmisuas wilk any eteyw or VAW iar at any time. 14. Vw la )*q dolbalas rraerl/a the A* to oloa any aa0ermt without Sny alma to any dma. 15. Tbt I i , or persona tipbs Ais Ocand Siva paralsda+ to be held PaSOOdly aspwillik /et all moto dint debt. nis rosy rtanh in it lien epw pomw or tool Ptopury. Id. The Rgod dBuyw perm Lobe pvw and by dic taws of the CommanweaM ath onayivank. Readlac%gw *w~w m dw rtdSd ad*n of tM Comnamsalih of P?'crud)4vania for Say oumsaiaasl disputes with AUep . Dace: ??19 Stow Nome: #i r,&z:4A A#j ` 41rte! M Maw: _A MDer ?.?.f LA Address: Q?Ae -_ ? AY#nuc X K•- r n roll gnu ? n ? r.???nn nr+++..+u?+ ? i ? w?...? rn ? ? ?? ? ..n ...., ...,..? ...? .. ? Exhibit "B" s i L?JVO izaww ld% ? or ol P.O. BOX 734 Camp HM. PA 17001 flnefllea and fah*hw 2132 Arlington Avenue Upper Arlington, OH 43221 phoaa: FAX: 614487-7885 P.O. a smock Terms cod SZ98££2LTZ Jd 83H36H OMH MHOW £b:2T BOW-S2-TT Dolt 14027/2008 bwOiaw P 1107 1k and fairm s 2132 Aligbn Awsrnw Upper Atli VWn, OH 43221 3slee Rep Ship Deb ?- LLOWO ? D" Dabs 1012712008 1012711'008 •• ' • ., •r '• ... .' ?} , rt% ....r.y,??Ni 1L'?tY• '?!•r:?L'?-.}J ::•'4r .•.t?.?y.?a•rr:1 1101 pink *ft dtaoohld? alas 10 89.00 88.00 Extra Site aims 7-14 10.00 10.00 1082 dim mnd Willa *W 4 06.00 D&D0 updwMe QwW bead bodice with cxyotaIs 20.00 20.00 l im wlths wMh pink"3 00.00 00.00 1171 Ivory 0oldsn brown aim 8 90.00 99.00 COD COD 9.00 9.00 ShipphV and,.. Shipping and NmW&V 15.00 13.00 Shippktp NO... Shlppkig and HoWng 13.00 13.00 Reflual Rek*W Fee W.00 50.00 ftmge Fee 30.00 30.00 Cd oa&m Fie 4006 210.80 210.80 Int~ 10% 118.06 118.06 t h&b@bdybugc Uwdomoom Ph=& a (717) 761-2344 w'wwJadybugvoll0W0n-o0m PAX # (717) 761-2343 r_ n Jcn -Jews n i nr?nn rvtn .YU--r r Toni $855.85 PaymNtbr recobt $0.00 Bohmes Due $855.85 -zz n ?v C=l Y? ? V C) C, , -<; l?l A 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. FIREFLIES & FAIRY TALES, INC and AMBER KUEHN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No.: 09-479-Civil Term CIVIL ACTION -LAW : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE I HEREBY CERTIFY that a true and correct copy of the Complaint was served with original process by United States Mail, postage pre-paid, and by certified delivery (No. 7006 0810 0006 7590 8009) to the following Defendant pursuant to Pa. Rules of Civil Procedure No. 404. A true and correct copy of the certified mail, return receipt requested card is attached hereto as Exhibit "A." An original return receipt card will be provided upon request by the Court or any party: Fireflies & Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 Dated: March 4, 2009 By: .7_" 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 Exhibit "A" ¦ Complete Hems 1, 2, and 3. Also complete. Item 4 H Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the msilplece, or on the front H space permits. 1. Article Addressed to: Fir-t-Citts I Carly T14Us, Inc. o to d Awt let ( 11,w-Rh vi ZI3Z ArliTon Av-e.ow-A 13 Agent B. Recent by (P?Inted A** I C. Date of Delivery D. Is del" address dMOrent from Item 11 0 Yes If YES, enter delivery address beiww. 0 No Ulwev Af l i ngr , 0 4 4-327-1 3. Mail E03 9pess MaN 0 Registered ITPAurn ReoslM for MstciwWhw 0 Insured Mail 0 C.O.D. 4. Restricted DeNvery? F-Ow Fey 0 Yes z. Article Munster rrom ftmf se?vlee 4w Mar?sl 7006 0810 0006 7590 8009 PS Form 3811, February 2004 Domestic Return Receipt 1025e6-02-M-1e40 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: Fireflies & Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 -A jz?t? Date: March 4, 2009 Jessica R. Porter, Paralegal C? ? '?'' ° p -art ?,. ? , ?? t d?a : ? . ?i ?r? . ?? ? . ? 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, v : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No. 09-479-Civil Term FIREFLIES & FAIRY TALES, INC. . and AMBER KUEHN CIVIL ACTION -LAW 2132 Arlington Avenue JURY TRIAL DEMANDED Upper Arlington, OH 43221 Defendants 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 $447.00 Refusal Fees: $50.00 Interest: $34.58 TOTAL $531.58 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. 3. 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 _10 4k DAY OF JL)ne , 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 $531.58 AS PER THE ABOVE CERTIFICATION. NOTICE GIVEN PURSUANT TO Pa.R.C.P. 236. Respectfully submitted, ARCHER & ARCHER, P.C. By: 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 PROTHONOTARY Exhibit "A" LAW OFFICES ARCHER & ARCHER, P.C. THOMAS A. ARCHER, ESQ.. NEW JERSEY OFFICE: A&nWed PA A N? 2515 NORTH FRONT STREET JENNIFER BUSH ARCHER, ESQ. P.O. BOX 5056 37 MOUNTAIN BOULEVARD Admitted PA A N1 HARRISBURG, PENNSYLVANIA 17110-0056 SUITE 1 WARREN, NJ 07059 (717) 2334676 (908) 995-2000 FAX: (717) 233-8675 FAX: (908) 995-2104 . www.archerandarcher.com 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.: 09-479-Civil Term FIREFLIES & FAIRY TALES, INC. CIVIL ACTION -LAW and AMBER KUEHN JURY TRIAL DEMANDED Defendants IMPORTANT NOTICE TO: Fireflies & Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 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: March 4, 2009 By: 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: Fireflies & Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 Date: March 4, 2009 Jessica R. Porter, Paralegal Exhibit "B" Request for Military Status Department of Defense Manpower Data Center 4D Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAY-26-2009 12:56:33 < Last Name First/Middle Begin Date Active Duty Status Service/Agency KUEHN AMBER 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. 14 14. A?M_ 4but V"4_ 6 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: hftp.//www.defenselink.mil/faq/ p is/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: EEBEYV,4QNX https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/26/2009 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the Praecipe for Entry of Judgment for Want of an Answer, Assessment of Damages, Verification of Address, and Nonmilitary Service was served via U.S. first-class mail, postage prepaid, upon the following: Fireflies and Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 Dated: June 3, 2009 ay: ) I w?) -4;. U Jessica R. Porter, Paralegal FELFD-OFFiGF QF THEE PR7'Fn',?'7TARY 2069 JUN 10 pi'l 121: C; 'I $??•00 rl_'r??' Q,1'' 0101a504 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.: 09-479-Civil Term FIREFLIES & FAIRY TALES, INC. CIVIL ACTION - LAW and AMBER KUEHN JURY TRIAL DEMANDED Defendants IMPORTANT NOTICE TO: Fireflies & Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 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: March 4, 2009 By: 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: Fireflies & Fairy Tales, Inc. and Amber Kuehn 2132 Arlington Avenue Upper Arlington, OH 43221 Date: March 4, 2009 A-)-D6? --P) - ---Plx?z7D Jessica R. Porter, Paralegal ALED- ? -) 'r luE P€?^Tt r,?'1?pRY OF THE 2009 JUN 10 Ph 12: 17