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Home My WebLink About09-2287Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 CIVIL TERM HARITHA VANAM LLC, Defendant 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 Plaintiffs. 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 I I F:\FILES\Clients\11873 E&G Services\11873.9.com2/mah Created: 1110510109:49:53 AM Revised: 04/08/09 04:25:12 PM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. Plaintiff V. HARITHA VANAM LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - CIVIL TERM COMPLAINT AND NOW, comes the Plaintiff, E & G Services, Inc., by and through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers as follows: 1. Plaintiff, E & G Services, Inc., is a Pennsylvania corporation with a registered address at 300 West Suncrest Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Haritha Vanam LLC, is a Delaware limited liability company with an address of 4420 FM 1960 West, Suite 224, Houston, TX 77068. 3. Plaintiff is in the business of providing services, mainly electrical, to certain businesses and individuals. 4. Plaintiff has provided services to Defendant at College Park Apartments, 525 Third Street, Carlisle, Cumberland County, Pennsylvania 17013. 5. Defendant is the owner of College Park Apartments as identified in Paragraph 4 herein. 6. Plaintiff has provided services to Defendant for a total value of $4,618.80. True and correct copies of Plaintiff's invoices are attached hereto as Exhibit "A." 7. Defendant has failed to pay for such services and, therefore, is liable to Plaintiff for the amounts owed plus interest, costs and attorney fees. 8. Despite repeated demands, no payments have been made by the Defendant for amounts due nor has Defendant disputed this debt. COUNT I - BREACH OF CONTRACT 9. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 8 as if fully set forth. 10. Defendant has breached an expressed or implied agreement, directly or through agents, to pay for the goods and services provided to Defendant from Plaintiff and/or Plaintiff's agents. WHEREFORE, Plaintiff demands judgment against Defendant in the total amount of $4,618.80, plus interest at 18% per annum, costs, and attorney fees. COUNT II - QUANTUM MERUIT 11. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 10 as if fully set forth. 12. Defendant is liable to the Plaintiff and/or has been unjustly enriched in the amount of $4,618.80. WHEREFORE, Plaintiff demands judgment against Defendant in the total amount of $4,619.80, plus interest at 18% per annum, costs, and attorney fees. MARTSON LAW OFFICES By: C, /"r- s • ?-' Christopher E. Rice, Esquire ID Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: ?_ 9-0 Attorneys for Plaintiff EXHIBIT "A" 1'Z-'C5-'?8 14.58 FROM-E & G Services E&G Services, Inc. 300 W. Suncrest Dr. Carlisle, PA 17013 Co1ege Park Apartments f 525 Third Street Carlisle, Pa. 17013 i T-474 P003 F-451 Invoice Date 4/14/2008 Invoice # 415 P.O. S College Park Terms Net 30 Backical work for aft lights. Please ref attached quote for quoted work. This coat: $1200.00 7172586538 Due Date Additional work- due to improper underground splices and improper wire size installed prior. Additional trenching of approx 70ft, installing conduit, and wire. Removing of tight pole, rewire and remount with concrete. Rewiring of gage light pole. Removing of shrubs. Labor 10 man/hrs X545.001hr- $450.00 Materials: $243.80 Total invoice cost: $1893.80 Work completed on 4/11/2008 Terms as stated above. 1 1/2% monthly accrued interest after 30 days. Thank for your Business. jagaibQwmcast. net 717-258-3206 Fax 717-258-6538 5/14/2008 1,893.80 $1,893.80 10-05-'08 14;58 FROM-E & G Services ECG Services, Inc. 300 W. Suncrest Dr. Carlisle, PA 17013 miwge rerK Apartments 25 Thad Street ;arlisle, Pa. 17013 7172586538 Date 4/25/2008 Invoice * 425 P.O. * College Park Lighting Terms Net 30 Due Dab T-474 P004 F-451 invoice 5/25/2008 Eleebtal work for silo IigMing. College Park Apartments Carlisle, Pa 2,725.00 Work completed on 4/24!2008 Work consisted of 200ft of trenching, conduit, electrical quazite termination boxes,wire and weatherproof tap sokm- Installed beilset am bulb kit (400watt) for high pole light Removed and reku t Med lamp post light We with concrete. Materials and trencher: $1510.00 Labor 27marVhrs C$45.00/hru $1215.00 Invoice total: $2725.00 f Thank for your Business. --- -- - Terms as stated above. 1 1/2% monthly accrued interest after 30 days. -- ¦....... _. $2,725.00 , jagaito6comcest net 717-258-3206 Fax 717-258.5538 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. eph A. Gaito, President E & G Services FILED-Or "Fa OF THE MY HIONOTARY 2009 APR 13 PM I2* 5 4 08.50 p o RTT`/ C& ao88o E14 ?s8i I F:\FILES\Clients\11873 E&G Services\11873.9.affidavit.service2/mah Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - 2287 CIVIL TERM HARITHA VANAM LLC, Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Haritha Vanam LLC, 4420 FM 1960 West, Suite 224, Houston, Texas 77068, by certified mail, restricted delivery, return receipt requested, on April 14, 2009. Attached is the Post Office return receipt signed and dated April 17, 2009. MARTSON LAW OFFICES /L- By: ( - $7 Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Sworn to and subscried before me this 1 day of A44) '2009. t 0u? ?qldw ) No ary ublic COMMONWEALTH OF PENNSYLVANIA NOWW Seal Mary M. P ft NoWy Pubic Ca" Boro, Cw6w*nd Gm* My OwwWo ion EWNas A14 It 2M I Member, Pennsylvania AsswlstW s • Complete Items 1, 2, and 3. Also complete hem 4 H Restricted Delivery is desired. ¦ Print your name and address on the reverse 7 A. Sig so that we can return the card to you. • AA§bh card to the back of the mailpiece, ce permits. to: IF ff spa p LLC ly y l 9,0 U? JJv- X 0 Addre ? ? Printed NarrreJ C. of LL.I. 2.o Ctt- D. Is delivery address different from Item 1 ? If YES, enter delivery address below: No 3. ?S,errvic?e•.-T_ypJ-e Mall 0 Express Mall Registered 0 ? Return Receipt for Merchartdbe Insured Mail 0 C.O.D. 4. Rw111Mei 0~09dwFoo 2. Poll* Number fAwwwiliamawfteaw 7008 1140 0001 6163 3326 PS Form 3811, Febnmy 2004 _ Domestic Return Rece+Pt 1025s-0244-,sec U.S. Postal Service CERTIFIE D MAIL,,, RECEI PT (Domestic Only, Provided) M M I IB ..n r-q Postage $0.59 $ A 1 ?0 r-9 Certified Fee $2.10 ?? L Q Return Receipt Fee q ark C3 (Endorsement Required) 32•? re tL? 0 Restricted Delivery Fee (Endorsement Required) $4.31 6 J aC9 ob rR Total Postage a Fees $ $9,79 0 rq 03 sent T4 C3 3`treet, t. o.; POi3oxNo. -------------------------- I__6-i°__ 7 ) Q /J 7 ?ify sieie; ---- ?6 ti CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Haritha Varian LLC 4420 FM 1960 West, Suite 224 Houston, TX 77068 MARTSON LAW OFFICES By: M Price 10 E t High Street Carlisle, PA 17013 Dated: 7 4 OF -PHE FR [ t-4CAV ANOTARY, 2009 MAY 12 Pill '.': 2E ,P:\FILES\ClieMa\i 1873 E&G Services\11873.9.pradefauhVmah t Created: 1110510109-49:53 AM Revised: 06115109 12:59:44 PM 10883.8 Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. Plaintiff V. HARITHA VANAM LLC, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-2287 CIVIL TERM PRAECIPE Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Haritha Vanam LLC, in the amount of $4,619.80, plus interest at 18% per annum and costs of suit as prayed for in the Complaint, for failure to file an Answer to Plaintiff's Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on May 11, 2009, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES By Oz'l't'r. Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: 6 -? /$-- ? 1 F:\F1?.,ES\Clients\l 1873 E&G Services\l 1873.9.lOdaynotice2/mah a Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - 2287 CIVIL TERM HARITHA VANAM LLC, Defendant IMPORTANT NOTICE TO: Haritha Vanam LLC 4420 FM 1960 West, Suite 224 Houston, TX 77068 MARTSON LAW OFFICES YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST 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 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 DATE OF NOTICE: May 11, 2009 Christopher E. Rice, Esquire By: Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. Plaintiff V. HARITHA VANAM LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-2287 CIVIL TERM AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant's address is 4420 FM 1960 West, Suite 224, Houston, TX 77068. Christopher E. Rice, Esquire Sworn t and sul this _%day of N before me 2009. CpW- 001:kvi " ALTH OF P NNSYLVANIA --AIo1M1M W M Powt P?bMo MWdlanG Bop, o 1a 11 Member, Pe"M"anh Mroolaw Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. Plaintiff V. HARITHA VANAM LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-2287 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on May 11, 2009. S Christopher E. Rice, Esquire Sworn to and subscribed before me this day of 341,v , 2009. N ublic COMMONWEALTH OF PENNSYLVANIA Noto SON May M PAoe. NOWY Pubic cows em, 0ATIbed014 coi ty W Co nNeeb EOve Au8.18, 2011 Mombor, ~@Mo MOW~ of NoarfN CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Haritha Vanam LLC 4420 RM 1960 West, Suite-224 Houston, TX 77068 MARTSON LAW OFFICES By Ma/y K. Price Ten Ent High Street Carlisle, PA 17013 (717) 243-3341 Dated: /?1?/ 4 J? i .ao Pb M-rq coa.%M Z141- aaion,50 ate, Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs E & G SERVICES, INC. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. HARITHA VANAM LLC, Defendant : NO. 2009-2287 CIVIL TERM TO: HARITHA VANAM LLC, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the )5'k day of \d(, e , 2009, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $4,619.80, plus interest at 18% per annum and costs of suit as prayed for in the Complaint for failure to file an Answer to Plaintiffs Complaint. Date: 3 r r thonotary A ? I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Haritha Vanam LLC 4420 FM 1960 West, Suite 224 Houston, TX 77068