HomeMy WebLinkAbout04-2290IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.
Civil Action- (
(
PINNACLE SEARCH ASSOCIATES,INC.: B & M PLASTICS, INC.
17 E. EPPLEY DRIVE
CARLISLE, PA 17013
Plaintiff(s) &
Address(es)
: 2300 Lynch Road
: Evansville, iN 47711
versus
2004-- ~O ~,'l
) Law
) Equity
Defendant(s) &
Address(es)
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue writ of summons in the above captioned acti. pn.
Writ of Summons shall be issued and forw/ar, de/q[.,~
Stephen J. Hoqq, Esquire
19 S. Hanover Street, Ste. 101 Signature of A
Carlisle, PA 17013 /
(717~ 245-2698 Supreme Cour(
)~) Attorney ( ) Sheriff
D No. 36812.
Names/Address/Telephone No.
of Attorney
Date:
WRIT OF SUMMONS
05/17/04
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED
AN ACTION AGAINST YOU.
Date:
~r~thonotary _ ~,/
Deputy
( ) Check here if reverse is issued for additional information
PROTHON. -55
LAW OFFICES OF
STEPH~N j. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
PINNACLE SEARCH ASSOCIATES,
ASSOCIATES, INC.,
Plaintiff
V=
B&M PLASTICS, INC.,
Defendant
: IN THE COURT
: OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
:
: CIVIL ACTION-LAW
: NO. 2004-2290
:
: J[JRY TRIAL DEMANDED
MOTION TO COMPEL DEFENDANT TO
COMPLY WITH DISCOVERY' REQUEST
Plaintiff by its attorney, Stephen J. Hogg, Esquire, moves for an
Order compelling compliance with its discovery request as follows:
1. Plaintiff filed a Writ of Summons against Defendant on or
about May 20, 2004.
2. Plaintiff then filed written interrogatories on Defendant on or
about June 4, 2004.
3. On or about June 12, 2004, Defendant returned Plaintiff's
written interrogatories with insufficient answers.
4. Based on correspondence between the Plaintiff and
Defendant, Plaintiff requested more information regarding
the business relationship between Plaintiff and Defendant
yet Defendant denied any relationship existed.
Wherefore, Plaintiff respectfully requests an Order compelling the
Defendant to comply with giving full and complete answers to Plaintiff's
interrogatories.
Date: ,,,,~;"~'~'~' u,y',,,,~/
gtephen ,J,~l'~)~g, Esquire
Attorney f(~r Plaintiff
19 s. Ha~,over St., Ste. 101
Carlisle, PA 17013
(717) 245-2698
Attorney ID# 36812
PINNACLE SEARCH
ASSOCIATES, INC.,
Plaintiff
B&M PLASTICS, 1NC.,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 04-2290 CIVIL TERM
ORDER OF COURT
AND NOW, this 13th day of July, 2004, upon consideration of Plaintiff's Motion
To Compel Defendant To Comply with Discovery Request,
conference/hearing is scheduled for Thursday, August 26, 2004, at
Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania.
BYTHECOURT,
7esl~y Oler, 2~, ' J.
Stephen J. Hogg, Esq.
Suite 101
19 S. Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff
B&M Plastics, Inc.
2300 Lynch Road
Evansville, IN 47711
Defendant, pro se
:rc
a discovery
10:30 a.m., in
PINNACLE SEARCH,
ASSOCIATES, INC.
Plaintiff
B&M PLASTICS, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:
: NO. 04-2290 CIVIL TERM
PRETRIAL CONFERENCE
AND NOW, this 26th day of August, 2004, upon
consideration of Plaintiff's Motion To Compel Defendant To Comply
with Discovery Request, and following a discovery conference held
in the chambers of the undersigned judge on August 26, 2004, at
which Plaintiff was represented by Stephen J. Hogg, Esquire, and at
which no attorney appeared on behalf of the corporate Defendant,
and it appearing from the attached response to Plaintiff's
interrogatories that Defendant through its corporate president is
denying having had any contact whatsoever with Plaintiff in
connection with the matters sub judica, and that the response of
the corporate representative contains no proper verification as
required by the Pennsylvania Rules of Civil Procedure, Plaintiff's
motion is granted to the extent that Defendant is directed to serve
upon Plaintiff's counsel within 20 days a proper verification for
the response to interrogatories, and a clarification of the
responses, in verified form, to the extent that the Court's
interpretation of the responses is incorrect.
Defendant is advised that under Pennsylvania law, any
appearance in court on behalf of a corporation must be by an
attorney licensed to practice in the Commonwealth of Pennsylvania,
and that a corporate officer may not represent a corporation in a
court proceeding.
Stephen J. Hogg, Esquire
Suite 101
19 S. Hanover Street
Carlisle, PA 17013
For the Plaintiff
William Gillenwater
President
B&M Plastics, Inc.
2300 Lynch Road
Evansville, IN 47711
Defendant Pro Se, Esquire
By the Court,
-J~ Wesley O~r~Jr.~ J-
pcb
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 10!
CARLISLE, PA 17013
PINNACLE SEARCH
ASSOCIATES, INC.,
Plaintiff
B&M PLASTICS, INC.,
Defendant
IN THE COURT
OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
NO. 2004-2290
JURY TRIAL DEMANDED
PRAEClPE
TO THE PROTHONOATARY OF SAID COURT:
Plaintiff by its attorney, Stephen J. Hogg, Esquire, wishes to
withdraw its Petition for Appointment of Arbitrators regarding the above
matter.
Date:
/S'tephen J. Ho~l/~,/E[squire
Attorney for,P~tf~iff
19 S. Hano~e-rSt., Ste. 101
Cadisle, PA 17013
(717) 245-2698
Attorney ID# 35812
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
PINNACLE SEARCH
ASSOCIATES, INC.,
Plaintiff
B&M PLASTICS, INC.,
Defendant
: IN THE COURT
: OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
.,
: CIVIL ACTION-LAW
: NO. 2004-2290
:
: JURY TRIAL DEMANDED
COMPLAINT
Plaintiff is Pinnacle Seamh Associates, Inc., Patrick Anders
owner, a Pennsylvania Corporation doing business at 17 E.
Eppley Drive, Carlisle, Pennsylvania 17013.
Defendant is B&M Plastics, Inc., 2300 Lynch Road,
Evansville, Indiana 47711-2851.
On or about November 20, 2003, as a result of a third
person referral Plaintiff and Defenclant talked by telephone to
discuss filling a polymer chemist position at Defendant's
plant in Indiana.
Defendant and Plaintiff engaged in a series of
correspondences, attached hereto as Exhibit 1, in regard to
a fee agreement for Plaintiff's services and then with regard
to referrals of candidates for the polymer chemist position.
Plaintiff submitted a fee agreement to Defendant attached
hereto as Exhibit 2.
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
10.
11.
12.
Plaintiffs fee agreement states it.,; referral fee is 25% of the
candidate's base salary for the first year.
Plaintiff referred a candidate named Kevin Gildea on or
about January 22, 2004 through an email attached hereto as
Exhibit 3.
Plaintiff also referred a candidate named Ann Mendel on or
about February 16, 2004 through an e-mail attached hereto
as Exhibit 4.
Defendant negotiated the fee agreement down to 20% but
Defendant never signed or returned the agreement.
The fee agreement does state that the fee is payable if a
candidate referred by Plaintiff is hired whether or not the fee
agreement was signed.
To the best of Plaintiff's knowledge and belief Defendant has
employed either Kevin Gildea or Ann Mendel as a result of
Plaintiff's referral effort.
Plaintiff asserts it is due its standard referral fee of 25% of
Plaintiff's base salary. Plaintiff believes the salary to be
$70,000.00. In addition, Plaintiff believes that Defendant
paid either relocation fees, school loans or other similar
inducement to the candidate in the approximate amount of
$10,000.00.
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
13. Based on the salary package of $80,000.00 as set forth
above, PlaintifFs referral fee would be $20,000.00.
Wherefore, Plaintiff requests damages in the amount of $20,000.00
plus interest and costs from February 16, 2004.
Respecffully Submitted,
19 S. Hanover Street, Ste. 101
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
VERIFICATION
I verify that the statements made in this Complaint to the Court
of Common Pleas of Cumberland County, Pennsylvania, are true and
correct. I understand that false statements I~erein are made subject to
the penalties of 18 Pa. Section 4904, relating to unsworn falsifications
to authorities.
Date:
PATRICK ANDERS
EXHIBIT 1
Page 1 of 1
Pat Anders
From:
To:
Cc:
Sent:
Attach:
Subject:
"Pat Anders" <panders~pinnaclesearch.com>
"Craig Lucas" <craig.lucas@bmplastics.com>
"Blake Ruddle" <blake.ruddle{~bmplastics.com>
Monday, November 24, 2003 11:53 AM
FEE AGREEMENT_.doc
FEE AGREEMENT
Craig,
Thanks for your time and consideration during our phone conversation of late last week. Always enjoy talking
with another fellow Marine!
Attached is the Fee Agreement as discussed ( sorry about the delay...my, hard drive crashed flor the flint time
ever shortly after our conversation ). Please review, and if agreeable, sign and fax back to (717) 245-8585. If you
have any questions...please call or send an e-mail, whichever is most co:nvenient.
To tell you a little more about myself....I have been recruiting since 1984 when I started my career in HR
management. Immediately prior to founding Pinnacle Search Associates I was the HR Director of a Little Tikes
plant for 5 years and therefore have alot of experience recruiting in the plastics industry. I feel confident of my
ability to assist B&M Plastics in this search.
I look forward to hearing back from you.
Sincerely,
Patrick Anders
(717) 245-9985
Pinnacle Search Associates
3/16/2004
Page 1 of 2
Pat Anders
From:
To:
Sent:
Subject:
Craig,
"Pat Anders" <panders~pinnaclesearch.com>
"Lucas, Craig" <Craig.Lucasll~bmplastics.com>
Tuesday, November 25, 2003 7:52 PM
Re: FEE AGREEMENT
I can grant a USMC discount of 10% down to 22.5% Does that work?
I have already started sourcing and have some resumes thai: look good on
paper.
Look forward to hearing back from you.
Regards and Semper Fi,
Pat
Pat Anders
Pinnacle Search Associates
(717)245-9985
panders@pinnaclesearch, com
www. pinnaclesearch.com
--- Original Message ---
From: "Lucas, Craig" <Craig. Lucas@bmplastics.com>
To: "Lucas, Craig" <Craig. Lucasi~bmptastics.com>; '"Pat Anders'"
<panders@pinnaclesearch.com >
Cc: "Ruddle, Blake" <Blake. Ruddle(~.bmplastics.com>
Sent: Tuesday, November 25, 2003 12:09 PM
Subject: RE: FEE AGREEMENT
> Pat,
> I've been advised 25% is high.., is this negotiable?
> Thanks.
> Semper Fi,
> Craig Lucas
> > From: Pat Anders[SMTP:panders~pinnaclesearch.com]
> > Sent: Monday, November 24, 2003 10:53 AM
> > To: Craig Lucas
> > Cc: Blake Ruddle
3/16/2004
Page 1 of 1
Pat Anders
Fl'om,'
To:
Sent:
Attach:
Subject:
"Pat Anders" <panders@pinnaclesearch.com>
"Craig Lucas" <craig.lucas~bmplastics.com>; "Blake Ruddle" <blake.ruddle@bmplastics.com>
Monday, December 08, 2003 4:35 PM
FEE AGREEMENT .doc
Revised FEE AGR~'EMENT
Craig/Blake,
Attached please find a revised 20% Fee Agreement as discussed. Please review, and if agreeable, sign and fax
to (717) 245-8585. If you have any questions.., either shoot me an e-rmlil or call me at (717) 245-9985. I will call
and touch base dudng the first week of January, 2004 to monitor the results of your i ntemal seamh and see if
external recruiting assistance is desired. Thanks!
Pat Anders
www.pinnaclesearch.com
3/16/2004
Page 1 of 1
Pat Anders
From:
To:
Sent:
Attach:
Subject:
"Pat Anders" <panders<~pinnaclesearch.com>
"Craig Lucas" <craig.lucas~}bmplastics.com>; "Blake Ruddle" <blake.ruddle@bmplasfics.com>
Monday, December 08, 2003 5:30 PM
log0 .doc
Information Request
Gentlemen,
The attachment requests most of the information necessary for Pinnacle Search Associates to assist in your
staffing assignment, The more specific information that you are able to provide will help me narrow my search to
ensure that I can meet your company needs. Thanks!
Pat Anders
www.pinnaclesearch.com
(717) 245-9985
3/16/2004
Company profile (sales, culture, size)
See website
company website - www.bmvlastics.com
# of employees -45 employees
union/non-union
position recruiting -Polymer Scientist
skills required
Please provide position description. This is what has been provided
thus far;
BS/M/PhD -Polymer Science with QA lab experience, strong
materials (plastics) background, batch technology experience,
excellent analytical and communication skills, resin manufacturing
experience preferred.
preferred attributes
hiring process
benefits summary
salary range
comments
shi~s/hours
relo package
reports to
supervises #/type
why position available
position growth opportunity
prio~ty (~/c)
directions
co. recruiting efforts
EXHIBIT 2
FEE AGREEMENT
The following is an agreement between Pinnacle Search Associates, Inc. and B&M
Plastics, Inc., Inc. as of November 24z,· 2003 engaging the services of Pinnacle Search
Associates, Inc. for the purpose of conducting a search to find employees for B&M
Plastics, Inc.
Our service fees are payable if, and only if, you engage the services of a candidate that has
been referred to you through our efforts. The fee is payable should you or your affiliate
engage such a candidate for any position within one year afhx our most recent
communication relating to such candidate. If the terms and conditions contained in this
agreement do not reflect your understanding, please call us immediately.
Our service fees will be computed as 25% of the total base compensation to be earned by
the candidate that you employ during such candidate's first twelve (12) months of
employment.
We will replace at no extra charge any employee hired through our services who within
sixty (60) days of employment, voluntarily leaves your employment without cause or is
discharged for cause, if we are notified in writing within five (5) working days of
employee's termination.
Our terms for payment of service fees are net due fi~een (15) days from the date the
candidate marts employment. After the employee begins employment the standard
guarantee stated in paragraph four above will apply. The guarantee referred to above is
valid only if we receive payment of our service fee, in full, within fifteen (15) days from
the date the candidate starts employment. Additionally, any fee 30 days past due will
incur a 1.5 % monthly finance charge on any outstanding delinquent balance
Your acceptance of referrals from us shall be conclusive proof of your acceptance of our
schedule of charges, terms and conditions, unless we have signed a written modification.
Craig Lucas Patrick Anders
EXHIBIT 3
Page 1 of 1
Pat Anders
From:
To:
Sent:
Attach:
Subject:
"Pat Anders" <panders~}pinnacleseamh.com>
"Craig Lucas" <craig.lucas~bmplastics.com>; "Blake Ruddle" <blake.ruddle~bmplasfics.com>
Thursday, January 22, 2004 9:29 AM
logo .doc
Kevin Gildea - QA Chemist - Resins
Craig & Blake,
Attached please find the resume of Kevin Gildea to consider for the position of QA Chemist - Resins, Kevin has a
degree in Microbiology with a minor in Organic Chemistry and over 15 yesrs of laboratory experience in resin
R&D and quality assurance. Very knowledgeable in the use of laboratory equipment/instrumentation and familiar
with ISO, SPC and SOP's. Experienced in reformulation and customization to meet specific customer needs.
Seeks a resin QA lab position with growth potential. Currently in Texas with a 55k income in 2003. Seeks 60k.
Willing to relocate to Indiana and available in 4 weeks. Please review Kevin's qualifications and let me know your
thoughts.
Sincerely,
Patrick Anders
Pinnacle Search Associates
(717) 245-9985
3/16/2004
EXHIBIT 4
Pat Anders
Page 1 of 1
From:
To:
Cc:
Sent:
Attach:
Subject:
"Pat Anders" <panders~pinnaclesearch.com>
"Craig Lucas" <craig.lucas{~bmplastics.com>; "Blake Ruddle" <blake.ruddle{~bmplasfics.com>
"Gib Armstrong" <gibe1991 .usna.com>
Monday, February 16, 2004 11:20 AM
logo .doc
Ann Mendel - Polymer Chemist
Craig & Blake,
Attached please find the resume of Ann Mendel to consider for the Polymer Chemist position. Ann is a local
candidate (Evansville) with a BS in Chemistry and a MS in Management and 4 years of commercial resin
manufacturing QA/R&D laboratory experience. Ann currently is a product development chemist for a company
manufacturing polypropylene consumer products. Ann has worked with PP, Nylon, ABS, PET and Polycarbonate
resins and is proficient with in-process melt ltow, tensile and flexural testing, and impact testing among other
testing procedures. Knowledgeable in ISO and very computer literate. Very articulate and possesses very good
analytical skills. Seeks a varied position that can utilize her skills where she can make a significant conthbution.
Currently at 50k + bonus. Seeks 60k+ with career growth potential contingent upon her performance. Please
review Ann's qualifications and let me know your thoughts. Thanks!
Pat Anders
(717) 245-9985
3/16/2004
LAW OFFICES OF
STEPI-IEN J. I-IOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PINNACLE SEARCH
ASSOCIATES, INC.,
Plaintiff
B & M PLASTICS, INC.,
Defendant
CIVIL ACTION LAW
NO.: 2290-04
JURY TRIAL DEMANDED
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE
ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT
WITHIN TEN DAYS FROM THE DATE OF 'FHIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINS'r' YOUWITHOUT 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
FOLLOWING OFFICE TO FIND OUT WHEIRE YOU CAN GET
LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166 .
P · t~O~lFg, ~'squ e
Attorney for Plaintiff
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
CERTIFICATE OF SERVICE
I, Stephen d. Hogg, Esquire, Attorney for the Plaintiff, hereby
3ertify that I did on this day serve one true and correct copy of the
attached IMPORTANT NOTICE by United States Mail, postage pre-paid,
addressed to the following:
B&M Plastics, Inc.
2300 Lynch Road
Evansville, Indiana 47711-2851
Std'phen J. Hogf~, ~squire
Attorney for Plaintiff
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2(398
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PINNACLE SEARCH
ASSOCIATES, INC.,
Plaintiff
B & M PLASTICS, INC.,
Defendant
CIVIL ACTION LAW
NO.: 2290-04
JURY TRIAL DEMANDED
AFFIDAVIT OF SERVICE
TO PROTHONOTARY OF SAID COURT:
The Plaintiff in the above captioned actions avers that service of
the Complaint was made and accepted by Defendant on November 1,
2004 as evidenced by the attached Track/Confirm statement from the
United States Post Office.
Respectfully Submitted,
Date:
Stephen ,I.~
lg, Esquire
Attorney fl~r Plaintiff
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
1!/38/2804 17:06 7172435998
Direct Query - hutranet o "Quick" Search
P'OSTOFFICE
P~GE
Pag~ 1 of l
Track/Confirm - lntranet Item Inquiry - Domestic
Item: 7002 2410 0007 8506 9333
,,
IlzIP Co e:
[O'ri~l,!n IIZIP Code: 17105
Date/Time Malted: 1012712004 09:51
][City: EvANSvILLE "l[$tate: IN ,
Class: First Class
I Anticipated Delivery Date: 1013012004
'Weight: lb: 0 oz: 3
F , Special Services
ICERTIFIED MAIL
'RETURN RECEIPT
Associated Labels
]1f6°2 24~0 0007 aso6 9333
Event Date Time Location Scanner ID
DELIVERED 11101/2004 11:31 EVANSVILLE! UN 47711 Kl15420
,~!~.D/~_~!e'~r~ ~ ~r~, ~,s,,]
10/27/2004 09:51 HARRISBURG PA 17105
ACCEPT OR PICKUP
Enter Request Type and Item Number:
Quick Search ~e': Extensive Search ''r ,.'':
Submit
Inquire on multiple,.items.
Go to the Product Tracking System Home Page.
http://pts,usps.gov/netdata-cgi/db2www/cbd_2 42.d2w/OL-TPUT 11/30/2004
Direct Query - lmtranet
POSTOFFICE
PAGE 82
Page l of 1
Track/Confirm - lntmnet Item Inq;uiry
Item Number: 7002 2410 0007 8506 9333
This item was delivered on 11/0112004 at tl :31.
Enter Request Type and Item Number:
Quick Search ,~: Extensive Search ,~i'
.Explenation of Quick a~ Extenai,,e S~=.Arche
!' Submit
Inquire on multiple ite. m8..
Go to the Product Tracking System Home
h ttp : //pts. usp s. gov /r~etdata-c gi/ db 2www /cbd_2 4 2.d2w/iM G 11/30/2004
LAW OFFICES OF
STEPHEN J. HOGG
19 S. HANOVER STREET
SUITE 101
CARLISLE, PA 17013
CERTIFICATE OF SERVICE
I, Stephen J. Hogg, Esquire, Attorney fOr the Plaintiff, hereby
certify that I did on this day serve one true and correct copy of the
attached Affidavit of Service by United States Mail, postage pre-paid,
addressed to the following:
Date:
B&M Plastics, Inc.
2300 Lynch Road
Evansville, Indiana 47711-2851
AS t~eoPrnhee: f Jo r ~, i¢re
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
PINNACLE SEARCH
ASSOCIATES, INC.,
Plaintiff
Va
B&M PLASTICS, INC.,
Defendant
IN THE COURT
OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
NO. 2004-2290
JURY TRIAL DEMANDED
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOATARY OF SAID COURT:
Please enter Judgment in favor of the Plaintiff and against the
Defendant in the above captioned matter for failure of the Defendant to
file an Answer. Assess the damages as follows:
Damages:
Interest from February 16, 2004 @ 6%:
$20,000.00
$ 1,023.20
Total $21,023.20
It is certified that a written notice of intention to file this praecipe
was mailed by certified mail to the Defendant after the default occurred
and at lease ten days prior to the date of filing this praecipe as
LAW OFFICES OF
['EPHEN J. HOGG
) S. HANOVER STREET
SUITE I01
CARLISLE, PA 17013
evidenced by the attached green card noting service of the default
judgment notice on December 9, 2004.
Respectfully Submitted,
Date:
Attorney for Plaintiff
19 S. Hanover Street. Ste. 101
Carlisle, PA 17013
(717) 245-2698
Atty ID# PA36812
Judgment entered and damages assessed as above.
Prothonotary
LAW OFFICES OF
EPI-IEN j. ItOGG
HANOVER STREET
SUITE 101
~RLISLE, PA 17013
!N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PINNACLE SEARCH
ASSOCIATES, INC.,
Plaintiff
B & M PLASTICS, INC.,
Defendant
CIVIL ACTION LAW
NO.: 2290-04
JURY TRIAL DEMANDED
LAW OFF~C ES
HEN J. HOGG
ANOVER ~TREET
SUITE 101
.ISLE. R~ 17013
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE
ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT
WITHIN TEN 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
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PEN NSYLVANIA 17013
(717) 249-3166 .
Stephen J. t';l'6g~, Esquire
Attorney for Pliintiff
19 S. Hanover Street, Ste. 10-1
Carlisle, PA 170'13
(7'17) 245-2698
CERTIFICATE OF SERVICE
I, Stephen J. Hogg, Esquire, Attorney for the Plaintiff, hereby
certify that I did on this day serve one true and correct copy of the
attached IMPORTANT NOTICE by United States Mail, postage pre-paid,
addressed to the following:
B&M Plastics, Inc.
2300 Lynch Road
Evansville, Indiana 47711-2851
Steph~n d. Hog~,'.~squire
Attorney for Plaintiff
19 S. Hanover Street, Ste. 101
Carlisle, PA 170.13
(717) 245-2698
LAW OFFICES OF
?I-IFN j. HOGG
HANOVER STREET
SUITE I 0 I
RLISLE. PA 17013
· Complete items 1,2, and 3. Also complete
item 4 if Restricted Delivery is desired.
· Print your name and address on the ~'everse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
(Transfer from service label)
PS Form 3811, March 2001
eived by (Plee~P, rint ~learly) B. Date of Delivery
D. Is deliver~ address different from ite~n ¥ ? [] Yes
3. Service TyiSe
~~ .rtified Mai~ [] F_~press Mail
~-t~F-'~J..' ~[r-I.~eturn Receipt for Merchandise
~la~,,~ C.O.D.
4. RestnE~,d [/~tivery? (Extra Fee) [] Yes
Domestic Return Receipt -.~--n~ ~'~(~'~L~.- 102595-01-M-1424
UNITED STATES POSTAL SERVICE~ Firu~-~.looo Malt
~' PM ~ ~ I-'u~l.~,u~(l. reesPa,o
· Sender: Please print,*j~~dress, ar~ ZIP',--4 in I.I,is box '
CERTIFICATE OF SERVICE
I, Stephen J. Hogg, Esquire, Attorney for the Plaintiff, hereby
certify that I did on this day serve one true and correct copy of the
attached PRAECIPE TO ENTER DEFAULT JUDGMENT by United
States Mail, postage pre-paid, addressed to the following:
B&M Plastics, Inc.
2300 Lynch Road
Evansville, Indiana 47711-2851
19 S. Hanover Street, Ste. 101
Carlisle, PA 17013
(717) 245-2698
LAW OFFICES OF
~,PHIgN J. HOGG
· HANOVER STREET
SUITE 101
IRLISLE, PA 17013