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Home My WebLink About09-0758K COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Cumberlar-d County JUDICIAL DISTRICT FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No.'q'qr 75f LJI'yj `l K W NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Dis- trict Justice on the date and in the case mentioned below. NAME OF APPELLANT ADDRESS OF APPELLANT CITY STATE ZIP CODE 53 South Old Fard '! oad la ?e Zurich I-?' 5047 1/3/09 :allegro Designs CV YEAR LT YEAR NOTICE OF APPEAL MAG. DIST. NO. OR NAME OF D.J. This block will be signed ONLY when this notation is required under PA. If appellant was Claimant (see PA R.C.P.J.P. R.C.P.J.P. No. 10088. This notice of Appeal, when received by the District Justice, will operate as No. 1001(6)) in action before district Justice, he A SUPERSEDEAS to the Judgment for possession in this case. MUST FILE A COMPLAINT within twenty (20) days after` filing his NOTICE of APPEAL. a ry or PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see PA R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon s Negro Designs , appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. within twenty (20) days after service of rule or (suffer entry of jud men1tof ryn pros. Signature of appellant or his attorney or agent ize1issa M. ,,eber, Esquire RULE: To Allegro Designs , appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED tAumii rut, UPON PRAECIPE. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: ??? l , Year t White - Prothonotary Copy Green - Court File Copy Yellow - Appelant's Copy Pink - Appellee Copy Gold - D. J. Copy vs.Deanna Dea:i d/b/a Voiles 3ridal OF APPS OR HIS ATTORNEY OR AGENT Sin fh notary or Deputy Proth. - 76 PROOF OF SERVICE OF NOTICE OF APPEAL,A14D RULE TO FILE COMPLAINT (This prof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby swear or affirm that I served a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on (date of service) , year , []by personal service !b' (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name , on , year , Elby personal service E] by (certified) (registered) mail, sender's receipt attached hereto. E] and further that I served the Rule to Fite a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on , year , []by personal service []by (certiff ad) (registered) mail, sender's receipt attached hereto. -n .sa SWORN (AFFIRMED) ANDSUESCRIBED BEFOREME W THIS DAY OF YEAR ?- :Wewre ' Somb rs of oftW before whom aAdavd was made "- C ' .`• '? r7I :;?j .Z" Tid f f llkl CT% e o o a My commission expires on year J 4 -V. COMMONWEALTH OF PENNSYLVANIA r0I INTY nr:- CUMBERLAND No.: 09-3-04 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rALLEGRO DESIGNS 95 EASTGATE DRIVE C/O WILLIM JUPITZ LCMP HILL, $A 17011 J VS. DEFENDANT: NAME and ADDRESS rDEANNA DEAN? D/B/A VOLLSS BRIDAL 53 SOUTH OLD RAND ROAD LAKE ZURICH; IL 60047 L J Docket No.: CV-p000861-07 Date Filed: 12/14/07 MDJ Name: Hon. THOMAS A. PLACEY Address: 104 S SPORTING HILL RD MECHANICSBURG, PA Telephone: (717 ) 761-8230 17050 ATTORNEY DEF PRIVATE s MELISSA H. WEBER 1023 FAYETTE ST 925 HARVEST DA BLUE BELL, PA 19422 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF ® Judgment was entered for: (Name) ALLEGRO DESIGNS ® Judgment was entered against: (Name) DEANN]? DEAD D/B/A VOLLES BRIDAL in the amount of $ 2, 508.9 0 Defendants are jointly and severally liable. ? Damages will be assessed on Date & Time This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 1,752.56 Judgment Costs $5-O Interest on Judgment $ 280.4 Attorney Fees $? Total $ 2,508.96 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL D'VISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEASy ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE, JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. T aY Date , A agistenai District Judge 1 certify that this is a true an correct copy of th6 r6 o.rd of the p/ceedings containing the judamei it. fill Date Magisterial District Judge My commission expires first Monday of January, 2010 AOPC 315-07 (Date of Judgment) 1/13/09 -.-- --W-- 7 /7 A IAA ^_9^-AA Tv SEAL COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Cumb &l [51SWT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. O l w 75 G 6'Yi'l ' 'W NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Dis- trict Justice on the date and in the case mentioned below. NAME OF APPELLANT CITY MAG. DIST. NO. OR NAME OF D.J. ZIP CODE vs. CLAIM NO. SIGNATURE OF APPELLANT OR HIS ATTORNEY OR AGENT CV YEAR ?Q ?r..•.?? M1-.. LT YEAR v This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No. 10086. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case. If appellant was Claimant (see PA R.C.P.J.P. No. 1001(6)) in action before. district Justice, he MUST FILE A COMPLA(N& ''w'n twenty (20) days after riling his NOTIF of SEAR U.1 PRAECIPETO ENTER RULE TO FILE COMPLAINT AND MULE ?'O FI ca (This section of form to be used ONLY wh6h appellant was DEFENDANT (se )'¢ R.C.P,J.P. No. 10b (7) in action ie District Justice,' IF NOT USED, detach from copy of notice of appeal to lie`sl3 6d'upoh'Wpe ' : - PRAECIPE: To Prothonotary Enter rule upon AliegDesigns , appellee(s), to file a complafr"Yin thl"'s appeal Name of appellee(s) (Common Pleas No. within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attomey or agent RULE: To ' ; \, ` `. Melissa,M.- Weber, Esquire'-, - ;re appellees)' (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twegty(20),daya,- after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NOt4 PROS' 1( i?fz 6NT? J _GAINS YOU UPON PRAECIPE. K . ?.' (3) The date of service of this rule if service was by mail is the date of the 1,14414 Date: Year T at or eputy White - Prothonotary Copy , ,- Green - Court File Copy *? a y Yellow - Appelant's Copy Pink - Appellee Copy Gold - D. J. Copy Proth. 76 ¦ Complete items 1, 2, and 3. Also coffgr item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reN so that we can return the card to you. ¦ Attach this card to the back of the mail or on the front if space permits. 1. Article Addressed to: Allegro Designs 95 Eastgate Drive Camp Hill, PA 17011 L.J Z3 a COPY OF 910 MM of Agtepi, CAtttrtctrn I-MM No. (dal of servim) February 17, , yew 2009 rsoW aftched herelo, and upon the sppolleei, (name Allegro February 14 , year 2009 , ? by perawawd servico ¦ Complete items 1, 2, and 3. Also complete item 4 if 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 mailpiece, or on the front it space permits. 1. Article Addressed to: District Justice Thomas Placey 104 Sporting Hill Road Mechanicsburg, PA 17050 3. Service Type AS Certified Mali ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number - - (}? ban arvky ?) 7099 ? 2. Article Number (Transfer fromservlceftW 7099 3220 000:7 9975 5088 Ps Form 3811, February PS Form 3811, February 2004 Domeaft MNtuM ft"pt 102595-02-M-1540 PROOF OF ONWAMOF NOTIC9,90 .444WININJ TO FILE COURANT Mft proof of service MUST BE FILED'VVITAN TEN' (1b) DAYS AFTER ding the notice of appeal. Clack apphcoMe boxes) COt1IMONWEALTH OF PENNSYLVML4k COUNTY OF Cumberland .ss AFFIDAVIT: I hereby wow or aft m Inset I served 09-758 Civil Term X "'1XLIf*? Agent C. Date of Delivery D. Is delivery address different from item 1? 0Yes If YES, enter delivery address below: ? No upon the District Justice dos led t1wela on wvIce J]by (oerdlliet!) (registered) mail, sender's on (owVtod) (mgjstered) mail, sender`s receipt attached hereto. and;AaW ttat l served tM Ruda bF6* s CampWM a cwmp rnAV the abovo Nvyoeof ApPatd.upon the app eltee(s) to whom the Rule was addressed on . Yew by personal service []by (certified) (registered) mall, ssndeirs rarrsipt attached her!elo. SWORN (AFFIRMED) AND Sl>f SM13ED SWORE ME TNl 20th DA OF Februar VyAR 2009 SYerNYirrara?0lrrfA? alwNh#tNSrMrN Notary Public 1111. daffidef My commission expk" on September or 2012 31pnMwp CfAfReru 002ma Cow* .TN OF PEtVNSY rill asi Dorothy M. Soo14 t+otsry PubNc aer of 11, ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the cans to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Allegro Designs 95 Eastgate Drive Camp Hill, PA 17011 A. Signature 13 ? Add X Addressee B. Receiv y #,14 60 N ) C. Date of.,Deliv,V D. Is delivery address different from (tern 17 ? Yes If YES, enter delivery address below: ? No 3. Service Type IN Certified Mail ? Express Mail ? Registered ? Retum. Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? iExha Fee) ? Yes 2. Article Number (11nnsfa.parrar WW h64 7099 3220 0007 9975 5101 PS Form 3811, February 2004 Domestic Return Receipt 102la5-02-*1sa0 PROOF OF SERVICE OF NOTICE OF APPEAL.AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland :ss AFFIDAVIT: I hereby swear or affirm that I served E3 a copy of the Notice of Appeal, Common Pleas No. 09-758 Civil Term, upon the District Justice designated therein on (dated service) February 17, , yw 2009 , [:]by personal service ®by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name Allegro Designs on February 14 . year 2009. ? by personal service &Iby (certified) (registered) mail, sender's receipt attached hereto. and A rther that I served the Rule to Fite a Complaint accompanying the above Noticed Appeal upon the appellee(s) to whom the Rule was addressed on ,year O by personal service Oby (certified) (registered) mall, senders receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THI 20th DA OF Februar YEAR 2009 sr mb" of A a I l I I alNdn* wa made Notary Public T11108 Of offlow My commission expires on September Now 2012 CONMg_"ff AI,TH OF PENNSYLVANIA Notarial sow Dorothy M. Scott, Notary Public Cif of Hrdlil "a, countl _ tt4airtMMisrt Sept. 1t, X12 Member, Assod0wof Notaries IL. signature ofARiant 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. DEANNA DEAN, Individually and d/b/a VOLLES BRIDAL Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET No. 09-758-Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Deanna Dean, Individually and d/b/a Volles Bridal c/o Melissa Murphy Weber, Esquire 925 Harvest Drive P.O. Box 3010 Blue Bell, PA 19422 You are hereby notified to file a written response to the enclosed Complaint within twenty (20) days from service hereof or a judgment may be entered against you. Dated: March 4, 2009 By: Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 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. DEANNA DEAN, Individually and d/b/a VOLLES BRIDAL Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET No. 09-758-Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED COMPLAINT Plaintiff, Allegro Designs, LLC, by and through it's undersigned counsel, Archer & Archer, P.C., files the following Complaint against Defendant, Deanna Dean, Individually and d/b/a Volles Bridal, 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 17011. 2. Defendant, Deanna Dean, individually and d/b/a Volles Bridal ("Defendant"), is, through information and belief, an adult individual with a place of business located at 53 South Old Rand Road, Lake Zurich, Illinois 60047. 3. At all relevant times, Plaintiff is in the business of manufacturing and wholesale distribution of children's formal wear and dresses. 4. Through information and belief, Defendant, at all relevant times, is engaged in the retail sale of formal wear and dresses. 5. At all relevant times, Defendant maintained a regular stream of business 1 and contact with the Commonwealth of Pennsylvania, in particular within Cumberland County, as a result of Defendant's regular and repeated business contacts with the Plaintiff and others. 6. Plaintiff and Defendant had an ongoing business relationship whereby Plaintiff distributed dresses for sale that were purchased by the Defendant. 7. On or about September 30, 2007, 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." 8. Pursuant to the Terms and Conditions, Defendant agreed to personal jurisdiction of the Commonwealth of Pennsylvania for all disputes with Plaintiff. 9. At Defendant's request, Plaintiff processed orders for custom manufactured merchandise more fully described in Plaintiff s invoice numbers 12361 and 12528, attached hereto and incorporated herein as Exhibit "B." 10. The principal amount due for the above-referenced invoices if $973.00 for merchandise, shipping and handling charges. 11. Defendant failed to accept delivery of Plaintiff s merchandise upon delivery, causing the merchandise to be returned to the Plaintiff. 12. Despite Plaintiffs efforts, Plaintiff has been unable to resell the custom items that were ordered by the Defendant. 13. Pursuant to the terms and conditions agreed to by the Defendant, Defendant agreed to pay Plaintiff the sum of $50.00 for all refusals. 14. Pursuant to the terms and conditions agreed to by the Defendant, Defendant agreed to pay storage fees, as well as reasonable attorney's fees and interest for all refused merchandise. 2 15. The total sum of refusal fees due from the Defendant to the Plaintiff is $150.00 on the invoices. The total sum of interest due and owing from the Defendant to the Plaintiff is $214.07 to date. 16. Pursuant to the Terms and Conditions signed by Defendant, Deanna Dean, agreed to the personally liable for all charges incurred by Volles Bridal. 17. Pursuant to the Terms and Conditions signed by Defendant, Deanna Dean, Plaintiff is entitled to costs and attorney's fees. 18. Despite Plaintiff's repeated demands for payment, Defendant refuses to pay Plaintiff the sums due and owing. FIRST COUNT - BREACH OF CONTRACT 19. The allegations of the proceeding paragraphs 1-18 are incorporated herein by reference as though set forth herein at length. 20. Defendant's request for goods and services provided herein and Plaintiffs agreement to provide those goods for valuable consideration constitute a valid and binding contract between the parties. 21. The Terms and Conditions were applicable to and governed each of the transactions alleged herein. 22. Despite Plaintiff s complete performance under the contract between the parties, Defendant has breached the contract by failing to tender payment thereon. 23. 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 $1,337.07, plus continuing accrued interest thereon. WHEREFORE, Plaintiff demands judgment against the Defendant: a. for compensatory damages in the amount of $1,337.07 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 24. The allegations of the proceeding paragraphs 1 - 23 are incorporated herein by reference as though set forth at length. 25. Defendant, as stated herein, requested the custom goods from the Plaintiff. 26. The Plaintiff fully filled the orders requested by the Defendant, who knew Plaintiff would expect payment therefore. 27. The market value of the goods and services ordered by Defendant is $973.00. 28. 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 $1,337.07 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 CQUNT - ACCOUNT STATED 29. The allegations of the proceeding paragraphs 1 - 28 are incorporated herein by reference as though set forth herein at length. 30. Plaintiff maintains a book account regarding Defendant's purchases. According to the records, Defendant owes Plaintiff the sum of $1,337.07 for goods and services requested by Defendant. 31. The funds due and owing Plaintiff by the Defendant are fair and reasonable for the goods and services provided. 32. 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 $1,337.07 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. Dated: March 4, 2009 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" Aar* agoug ZQI& "L91- Terms and Conditions The following terms and conditions apply to all transactions between you (herein, "RetailerBuyW ), the undersigned, and Allegro Designs, LLC d/b/a The Ladybug Collection (herein, "Allegro'): 1. TERMS: Allegro reserves the right to place any account on a C.O.D.-basis at anytime without notice, We do offer credit card terms and prepayment. 2. ORDERS: All orders are considered made to order. Orders must be faxed; phone orders will not be accepted. Please allow 6-8 weeks for delivery. Rush delivery under 6 weeks is available for an additional charge. A confirmation will be faxed within 2 days of all orders placed. No confirmations will be sent for orders without fax numbers on them. If you do not receive a confirmation, the order should be considered not placed. 3. REFUSISA : Absolutely No Refusals! In the event of refused merchandise upon delivery, Retailer/Buyer's account will automatically be placed on hold status and no orders will be shipped until the matter is resolved. There will also be a refusal fee of $50.00 and freight charges applied. In the event of refusal to accept delivery of merchandise, Retailer/Buyer will be responsible for cost of merchandise and any necessary reasonable collections costs, including interest calculated at 16% per annum, court costs and attorney's fees incurred by Allegro. 4, RETURNED CHECKS/COLLECTIONS: There will be a $45.00 charge for each returned check. The Retaile Buyer will be responsible for the full balance of any invoice and all fees accrued including, but not limited to, interest calculated at 16% per annum, as well as any necessary reasonable collections costs, including court costs and attorney's fees incurred by Allegro. Allegro reserves the right to refer any returned checks to authorities for prosecution. 5. RETU SS: A.) Upon delivery, Retailer/Buyer is responsible for the inspections of all merchandise. Any problems must be reported within three (3) days after the receipt of said merchandise. The Ladybug Collection is not responsible for any dye lot or fabric variations. The Ladybug Collection is not responsible for any returns if not notified within the 3-day grace period. B.) No merchandise will be accepted for return without our given Return Merchandise Audxmization (RMA) number. No exceptions will be made. C.) There will be no refunds or exchanges on special orders. 8. CANCELLATIONS: All orders are considered made to order. The Retailer/Buyer has the right to cancel any order within 72 hours from the time it was placed in writing. Verbal cancellations will not be accepted. 9. SHIPP,M: All orders will be shipped UPS-ground unless otherwise specified on your order confirmation. insurance, shipping and handling charges are the customer's responsibility. No discounts for freight will be accepted. 10. In order to maintain the image of The Ladybug Collection, no store is to ever advertise our merchandise on the Internet at discounted prices. We do not support stores who sell directly over the Internet. This practice undermines our full-service retailers. 11. All completion dates must be honored as stated on the order or sooner. The Ladybug Collection is not responsible for any delays due to shipping, manufacturing, or natural disasters. 12. The Ladybug Collection reserves the right to refuse to do business with any Buyer or Retailer at any time. 13, The Ladybug Collection reserves the right to close any account without any reason at any time. 14. The person or persons signing this contract gives permission to be held personally responsible for all outstanding debt. This may result in a lien against personal or real property. 15. The Retailer/Buyer agrees to be governed by the laws of the Commonwealth of Pennsylvania. Retailer/Buyer consents to the jurisdiction of the Commonwealth of Pennsylvania for any transactional disputes w'ithp Alllegro..? Date: Wq/3 2 Store Name: I) ? w' 1 V J Name: T p yy sl Address: Jr 3 ? YA 00--"?O 11120/2007 00:12 7177612343 P.O. BOX 734 Camp Hilt PA 17011 NC?I.I.E8 BRIDAL. DEANNA DEAN 53 S OLD RAND ROAD LAKE ZURICH IL 80047 Phone: FAX: 847-438-7603 847-438-7686 P.Q.0 STOCK Terms cod 1009 1128 THE LADYBUG COLLECTO PAGE 02/02 Sales Rep x0 PERLWINKLE AND MULTI SIZE 4 COD COD Shipping a'd ... 8hippktg and Handling Rok" Refusal Fee COD COD Shipping and ... Shipping and Handling 10129MT Refusal Refusal Fee COD COD Shipping and ... Shkgft and Handling Rditil Reft" Fee COD COD Shipping and ... Shipping and Handling info( >adybu?olle vn.G= Awns M (717) 761-2344 WWW.iadyb ffection.com FAX 4 (717) 761-2343 Dab 10/A=7 fnvoics * 12361 VbLLE8 BRIDAL DEANNA MM 53 8 OLD RAND ROAD LAKE ZURICH, IL 80047 Ship Data Due Deb 10=007 101'312007 99.00 9.00 13.00 60.00 9.00 13.00 !50.00 9.00 13.00 60.00 0.00 13.00 Tai Psymsnls/Croci is Bakw oo DUO 09.00 99.00 99.00 9.00 13.00 50.00 9.00 13.00 50.00 9.00 13.00 50.00 0.00 13.00 pop 1 111/20/2007 00:12 7177612343 THE LADYBUG COLLECM PAGE 01/02 ?? Cl'??7G4taCU?J !L F.O. BOX 734 Csmp MIN PA 17011 vOUa=s BRIDAL DEANNA DEAN 53 8 OLD RAND ROAD LAKE ZURICH IL 80447 Phono: PAX; 847-438-7603 847-438-7686 Do" involm f 10/3/2007 12381 VOLL M BRIM DEANNA DEAN 53 8 OLD RAND ROAD LAKE ZURICH, IL 00047 styes Rep Ship Dais 10/31 W P.O. d STOCK Due Olklm 10J3=7 1[!6 Tones ood Storage Fee 30.00 30.00 lrftr" 74.58 74.68 info@ladybugcolleWon.com rbous # (717) 761-2344 www.ladybugaollectiKm.com PAX # (717) 761-2343 Rape 2 Total $544.56 Paymmnts/Cmdks $0.00 Baum" Due $5#0.56 P.O. BOX 734 Camp Hilt PA 17011 VOLLES BRIDAL DEANNA DEAN 53 S OLD RAND ROAD LAKE ZURICH IL 60047 Phone: FAX: 847-438-7603 847-438-7686 P.O. # stack Terms cod 1049 white size 8 Extra Size sizes 7-14 1162 Champagne size 4 1125 Pink with ivory size 5 . 1143 Ivory pink champagne size 5 1124 Solid Ivory size 6 1152 ! White with blue size 7 Extra Size sizes 7-14 1059 Sable with pink size 3 COD : COD Shipping and ... Shipping and Handling nvoi. ce Date 10/29/2007 Invoice # 12528 VOLLES BRIDAL DEANNA DEAN 53 S OLD RAND ROAD LAKE ZURICH, IL 80047 Ship Date 10/29/2007 Due Date 10129/2007 Sales Rep KE info@ladybugcollection.com Phone # (717) 761-2344 www.ladybugcollection.com FAX # (717) 761-2343 95.00 } 5:00 99.00 89.00 95.00;, 99.00 79.00 5.00 99.00 9.00' 13.00 Total Payments/Credits Balance Due 95.00 ! 5.00 99.00 89.00 95.00 i 99.00 79.00 5.00 99.00 9.00 13.00 $_6_87.00 $0.00 $687.00 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: ?? 141 D I 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: Melissa Murphy Weber, Esquire Elliott, Greenleaf & Siedzikowski, P.C. 925 Harvest Drive, Suite 300 P.O. Box 3010 Blue Bell, PA 19422 Date: March 4, 2009 Jessica R. Porter, Paralegal rt 1 51