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Home My WebLink About04-2088 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO, 04 - ;)c?F c.;()~ C 1E.n-:r>J ANIXTER BROS" INC I STRUCTURED Plaintiff ST ARNET TECHNOLOGIES, INC, Defendant CIVIL DIVISION - LA W NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 appeaTance personally or by an attorney and fil ing 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 reJiefrequested 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 LA WYER, THlS 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 ANIXTER BROS., INC / STRUCTURED Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 64 - ;;J.OIF Clul'L letL.j ST ARNET TECHNOLOGIES, 1Ne. Defendant CIVIL DIVISION - LA W COMPLAINT The Plaintiff, ANIXTER BROX., INC./STRUCTURED, by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of NINETEEN THOUSAND, EIGHT ffiJNDRED SIX DOLLARS AND EIGHTY-THREE CENTS ($19,806,83), along with interest thereon from May J, 2004 upon a cause of action of which the following is a statement: 1, The Plaintiff, ANIXTER BROS., INC./STRUCTURED, is a corporation organized and existing under the laws of the State of Illinois, having its principal office and place of business at 320] Patriot Boulevard, Glennville, Illinois 60025, 2, The Defendant, ST ARNET TECHNOLOGIES, INC., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 1845 Market Street, Camp Hill, Cumberland County, Pennsylvania] 70 J J, 3. Plaintiff, at the special instance and oral request of the Defendant, sold and delivered goods, wares and merchandise to the Defendant. 4, Plaintiffs Invoices are not attached to this pleading due to the voluminous nature of same, Said Invoices will be made available to Defendant or Defendant's Counsel for inspection and copying in Plaintiffs attorney's offices upon written request by Defendant or Defendant's Counsel to Plaintiffs Counsel. F:\USER\ST ACY\CCP COMPLAINTS\ WORK\30309, wpd:07May04 5, The prices charged for said goods, wares and merchandise were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay to Plaintiff. 6, The balance due and owing by Defendant to Plaintiff is the sum of Thirty Five Thousand, Three Hundred Six Dollars and Eighty-Three Cents ($35,306.83), as appears by Plaintiff's Aged Trial Balance hereto attached, marked as Exhibit "A" and made a part hereof. 7, The Defendant paid to Plaintiffon account of sum of Fifteen Thousand, Five Hundred Dollars and Zero Cents ($15,500,00) thereby reducing the balance to Nineteen Thousand, Eight Hundred Six Dollars and Eighty-Three Cents ($ J 9,806,83), 8, Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount of any part thereof, WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of NINETEEN THOUSAND, EIGHT HUNDRED SIX DOLLARS AND EIGHTY-THREE CENTS ($19,806,83), along witb interest thereon trom May 1,2004 Respectfully submitted, KNUPP, KOD MBLUM, P.c. ~ Robert D, Kodak 407 North Front Street Post Office Box #] 1848 Harrisburg, PAl 7108. 1848 (717) 238-7151 Attorney ID No, 18041 Attorney for Plaintiff F:\USER\ST ACYICCP COMPLAINTSI WORK130309, wpd:07May04 3 ~FILE 11I0.470 08/2.8 '0323:48 IJJ:ANIXTER CR CIl.:LE;1ION F~X :;224 521 8'5420 PAGE 2' IQ~':Pl<N'j' AGED TRr~ BAt~~CE 082903 10:53 PAGE 1 S11686 STARNE! TECBNOtoGIES IRe LINCOW mTERMEDIATE JOB PHONE, (717) 731-0780 YTD SALES 1845 MARKET ST-ACCTS PAYABLE CAMP HILw FA 17011 PRIO~ YEAR SALES CREDIT LOCA~IONS SOLD 39,656.02 13 01 UNAPPLIED CASH: INVOICE INVOICE: ORDJ;:R CUSTOMER ORIGINAL PAYMENTS BALANCJ!: DAYS NlJMSER OATS NO PURCHASE ORDER: AAOI.INT OLD 610355243 OS/23/03 30!H7 SN1-26 13007.06 9165,40 9S 610,55350 OS/27/03 30997 SNT-U 1071..73 3772 ,11 94 61035%$2 OS/28/03 30720 SNT-~.5 1780B.OO J.780<l.00 93 H0355164 06/02/03 30997 SN'T-26" 4SL 16 461.18 S8 610357209 06/26/03 32341 SNT-26 R~PL 1968.0J. 19ae,Ol 64 610)57299 06/'27/03 32347 SNT-26 /();;l':(' 1492,13 1492 .l3 <$3 AIR BALA,'lCE CURRENT 30 DAYS 60 !JAYS 90 DAYS 120 + OVER 35,306,83 3, 961. 32 31,HS.51 EJ'JD OF INVOICES INVOICE COUN1' I; I'J..G5 COUNT 1 :.. FilE No.OS7 05/07 '0401:53 ID:ANIXTER CR COLLECTION ,~ AF'R 26 '04 01: 17PM KNUPP & KODAK PC FAX:224 521 85420 PAGE 4 P.S ~ 371. ;:;r"j.. VER!IFICA TION , I. -AN DflfA UJ pet.- e...;) . 0UeytuM ~ (dIU' ~Ltj sf ---' of ANIXTER BROS. INCJSTRUCTURED verifY that the ItItements made in tbe ~oin& doeulnent are true and conect, I understand that false ~e!1t. + are made subject to the penalties of 18 PI. C. S. i49114, , relating to IIIIIWOm talsifi~OD to authorities. ANIXTER BROS., INC./STRVCTtlRED Dated: 5" - 7-oy By: _~tUtlL.~ ' Title:' Cojl.trrLB,ll1t~ kahr /7 r - f.--'~ .-....__....,"1 OFFICIAL - ~ OF!:LIA .. .5J-7 ~RV PI.9UC 8TIlrE 01' 1U.ItOt: · ~ _ ~':~~"!!..~IO!' ~~~~~, j. . 1 ~9 Y I':ItlSSAISTACY\CCP COM/'LAlNTSlWONtI30309,wpd:UApt04 -p ~ ~ ~ frl. Ul ('-~ '"'" ..: r~::_") . c:~;.) 0 0- '" -""" " 8 - ;'''= -i Crt - () ~.. ..:, ~ Q -.,-' hi ~o~J 0 V'l - ~ ~ -J CJ 0 .....::z C> p- "I", ~ ~-' J () ,--' - .fll ~ " (..) -- - :,~ r.-..J -< SHERIFF'S RETURN - REGULAR CASE NO: 2004-02088 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ANIXTER BORS INC/STRUCTURED VS STARNET TECHNOLOGIES INC KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STARNET TECHNOLOGIES INC the DEFENDANT , at 1610:00 HOURS, on the 11th day of May 2004 at 1845 MARKET STREET CAMP HILL, PA 17011 by handing to JAMES SIMON, ESTIMATOR, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.35 .00 10.00 .00 38.35 .r~~ R. Thomas Kline 05/12/2004 KNUPP KODAK IMBLUM Sworn and Subscribed to before me this 1.3 f::I.,. day of ~ o?--.,t A.D. 1f-'. ",,". ~., - .11.4_ -:- {J prothonotar)J -~ By: p4,( - ANIXTER BROS., INC. I STRUCTURED Plaintiff : In the Court of COMMON PLEAS of : CUMBERLAND County, Pennsylvania v. NO. 2004-02088 STARNET TECHNOLOGIES, INC. Defendant CIVIL DIVISION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter as settled and discontinued with prejudice. TO CUMBERLAND County Prothonotary Dated: Julv 8.2005 ~~~ Robert D. Kodak Attorney I.D. No. 18041 Attorney for Plaintiff o ~~ ,...., "'" g:; '-- c ,- - N ~ -.,,' _',.t. o -n :1, rr1F -01":'9' :9 o c,.9 ~{~~ .~;,.j ~':I ...z;, <2 0J -'