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Home My WebLink About01-6915MI HOME PRODUCTS, INC. Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ¥. : COMMONWEALTH ARCHITECTURAL SUPPLIES, INC. : CIVIL DIVISION - LAW : Defendant NOTICE RT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET vnlI I4AVE BEEN SUED IN COU .......... , ~-n~ DAYS AFTER THIS COMPLAINT A FOLLO~[~ ~GES, YOU MUST TAKE ACTION WITHIN lwe,~ ~ ~ t,~'J SERVED, BY ENTERING A WRITFEN APPEARANCE PERSONALLY ORBY AN ATTORNEY AND FILING Iix THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR F CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY IMPORTANT TO YOU. 5~]~NRTH IN THE OTICE ARE WRITING WITH THAT YOU ANY OTHER RIGHTS ~FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 MI HOME PRODUCTS, INC. Plaintiff COMMONWEALTH ARCHITECTURAL SUPPLIES, INC. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, pENNSYLVANIA : : No. : CIVIL DIVISION - LAW C__~ Mp L A! N T The Plaintiff, MI Home Products, Inc., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this against the Defendant to recover the sum of SIX THOUSAND, FOUR HUNDRED EIGHTY ($6,400.00) thereon from February 5, 2001, upon a cause of action of which the following is a statement: 1. The Plaintiff, MI Home Products, Inc., is a corporation organized and existing under having its principal office and place of business at 850 West Market Street, Post Office Box 370, 2. The Defendant, Commonwealth Architectural Supplies, Inc., the Commonwealth of Pennsylvania, having its principal office and place of business at 102A West Main Mechanicsburg, Cumberland County, Pennsylvania 17055-8807. 3. On or about November 19, 1995, in order to induce Plaintiff to extend credit to it, Plaintiffs Credit Application. A true and correct copy of said Credit Application is attached hereto, marked as part hereof. 4. Defendant did, at various times, avail itself of Plaintiffs services, thereby creating a of Five Thousand ($5,000.00) Dollars, as set forth on Plaintiffs Accounts Receivable Aging Report attached! "B" and made a part hereof. of Assumpsit with interest of California, 17030-0370. under the laws of Office Box 807, and execute "A" and made a owing in the amount as Exhibit Due to Defendant's default in payment of said amount due and owing as aforesaid, a added to said account F:\USER\BONNIE JO\COMP\WORKL27301 CoM'WPD:04Dec01 in the total amount of Two Hundred ($200.00) Dollars, and made a part hereof. Due to Defendant's default in payment of said amount due and owing as aforesaid, as shown on Plaintiffs Statement of Account, marked as Exhibit 6. Due to Defendant's default in payment of said said account in the total amount of One Thousand, Two Hundred ($1,200.00) Dollars, as shown on Plaintiffs as Exhibit "C" and made a part hereof. amount due and owing as aforesaid, attorney's fees 7. The balance due and owing by Defendant to Plaintiff is the sum of Six Thousand, as appears by the Statement of Account hereto attached, made a part hereof and marked as Exhibit "C". 8. Plaintiff has frequently demanded payment from Defendant of said amount due has refused and neglected and still refuses and neglects to pay said amount of any part thereof. to said account attached hereto been added to , marked 400.00) Dollars, but Defendant WHEREFORE, Plaintiffbrings this suit to recover from Defendant the sum of SIX THOUSAND, FOUR DOLLARS, together with interest thereon from February 5,2001. Respectfully submitted, Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff F:\USER\BONNIEJO\COMP\WORK~27301 cOM'WPD:07N °v01 12/15/1999 10:52 7777 l~ 18:32 7172308747 >/I I~".l I I P.O. ,ox 3?0. e~ I~ ~ p~ P~, ~ ipp~- ~ ~ el Co~ TRADE REF~NCE: (~IVE NAME80~ ~O~E YOU 8U ~. ~mI _ p~No.( ) , F~( ) ~. N~ ~MK RIPERENCE~: :ROM ON OPEN ACCOUNTS.) p~GE o2 P. 02 Ties 16:~7:17 ~ta] Ieddstrie~ Thc. RF..CE ! V~BI.~ 'OrE [PILL ~jed as of 041~1{1 - Includes itel{ ps~ aging Ate Report I~GIN6 REPORT ~ut-off balanc~ due: Cut-~ff agie§ p~iod: Current Docueen% types: I · Invoi~ P ~ Payaent C -- Cr seco D ~ DP esso 8 -' Be]ante foruaed F · Finance dAarDe Notes*. Types I, 6 and F are aged by their due date. [ypes P, C and O are aged by due date of the docutent to uhic --' 6alan~ ~_..----------~jed custoeeP balances-- __ -~Custoae~-- -- [eres 31-G~ days t Note/Conta~ DUl-i~h Phoned CR-lieit Cu~en~ 1-38 days tlJnltd c1~ ~ .M EXHIBIT B p~eee81 hey apply. 61-96. days 61-9~ days 16,139. 78 .~ 139. 78CR ~,~ii. MCR STATEMENT ~XHIBIT G of MI ItOl~ ?F, ODUCTS, I~C., v~ri_~ that ~ s~a~=t~ ~ in gae af~r~otn~ do~me~ ~'~ Ir~e snd ~ ttateralmts h~rein are made subject to the penalties of 18 Pa. C. S. §1904, r~latin~ to unshorn fal~iftoatkm to autl MI HoME PRODUCTS~ INC, LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. c~N MAN$IDN 407 NORTH FRONT STREET P.O. BOX 11848 HARRISBURG, PA 17108-1848 MI HOME PRODUCTS, INC., Plaintiff VS. COMMONWEALTH ARCHITECTURAL: SUPPLIES, INC., : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6915 CIVIL TERM CIVIL DIVISION -LAW PRAECIPE Please enter our appearance on behalf of Commonwealth Architectural Supplies, Inc. in the above-captioned matter. Date: January 25, 2002 WiX, WENGER & WEIDNER David R. Getz, Esquire Supreme Court I.D. No. 34838 508 North Second Street Post Office Box 845 Harrisburg, PA 17101 (717) 234-4182 MI HOME PRODUCTS, INC., Plaintiff VS, COMMONWEALTH ARCHITECTURAL SUPPLIES, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6915 CIVIL TERM CIVIL DIVISION - LAW CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was sent via first- class, postage-prepaid mail this day to the following: Robert D. Kodak, Esquire Knupp, Kodak & Imblum, P.C. 407 North Front Street Post Office Box 11848 Harrisburg, PA 17108-1848 DATE: January 25, 2002 Respectfully submitted, WIX, WENGER & WEIDNER By: _ _ . David R. Getz, Esquire I.D. #34838 508 North Second Street Post Office Box 845 Harrisburg, PA 17108-0845 (717) 234-4182 F:~rg\1527 - Commonwealth Architectural Supplies, Inc\10822 - General.Corporate~Documents\Praecipe to Enter Appearance-MI Home Products.doc MI HOME PRODUCTS, 1NC. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-6915 CIVIL COMMONWEALTH ARCHITECTu'RAL SUPPLIES, INC. : CIVIL DIVISION - LAW Defendant : TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant, COMMONWEALTH ARCHITECTURAL SUPPLIES, INC.,, named for failure to file within the required time an Answer to the Complaint in the above- captioned case and assess the Plainti~'s damages as follows: Amount claimed in Plaintiffs Complaint Interest from February 5, 2001 at the legal rote of 6% per annum Total $6,400.00 $992 00 $7,392.00 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant(s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & iB attached. DATED: Robert D. Kodak, Attorney for Plaintiff Judgment entered and damages assessed as above. Prothonotary Robert L. Knupp Robert D. Kodak Gary J. Imblum Of Counsel Mark A. Mateya LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.e. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 7171238-7158 emaih kki.law~verizon.net August11,2003 FILE (1909oi 976) Robert H. Maurer (1923-1998) COMMONWEALTH ARCHITECTURAL SUPPLIES INC P O BOX 807 MECHANICSBURG PA 17055-8807 RE: VS: MI Home Products, Inc. Commonwealth Architectural Supplies, Inc. No. 01-6915 Civil Term, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 27301 Greetings: In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Off[ce of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P.C. RDK/kqb enclosure Robert D. Kodak, Esq. CC: PAUL G HOSSE DISTRICT SUPERVISOR UNITED MERCANTILE AGENCIES INC 600 SOUTH 7TM STREET LOUISVILLE KY 40201-1672 DAVID R GETZ ESQ WIX WINGER & WEIDNER POST OFFICE BOX 845 HARRISBURG PA 17108-0845 #863310 FILE MI HOME PRODUCTS, 1NC. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-6915 CIVIL COMMONVvVEALTH ARCHITECTURAL SUPPLIES, INC. : CIVIL DIVISION - LAW Defendant : IMPORTANT NOTICE TO: COMMONWEALTH ARCHITECTURAL SUPPLIES~ INC. , Defendant(s) DATE OF NOTICE: AUGUST 11, 2003 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WYII-IIN 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 NOTICIA IMPORTANTE A: COMMONWEALTH ARCHITECTURAL SUPPLIES, INC. , Demandado(s) FECHA DE NOTICIA: AUGUST 11, 2003 USTED NO HA COMPLIDO CON EL AVISO ENTERIOR PORQUE HA FALTADO EN TOMAR MEDIDAS REQUERIDS RESPECTO A ESTE CASE. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSIBLE QUE UN FALLO SEIA REGISTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU PROPIEDAD O OSTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE ABOGADO O NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA O LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE OBTENER LA AYIJDA LEGAC: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 MI HOME PRODUCTS, INC. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-6915 CIVIL COMMONWEALTH ARCHITECTURAL SUPPLIES, INC. : CIVIL DIVISION - LAW Defendant : To COMMONWEALTH ARCHITECTURAL SUPPLIES. INC., Defendant(s) You are hereby notified that on (Judgment) has been entered against you in the above-captioned case. DATE: 20_, the following Judgment entered in the amount of $7,392.00. Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: COMMONWEALTH ARCHITECTURAL SUPPLIES, INC. 102A WEST MAIN STREET MECHANICSBURG PA 17055 A/COMMONWEALTH ARCBI'IECTURAL SUPPLIES. INC.. Defendido/a Defendidos~as Por este medio se le esta notificando que el de del 20_, el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. Protonotario Certificao que la siguiente direccion es la del defendido/a sagun indicada en el cetificado de residencia: COMMONWEALTH ARCHITECTURAL SUPPLIES, INC. 102A WEST MAIN STREET MECHANICSBURG PA 17055 Abogado del Demandante