HomeMy WebLinkAbout10-0426JAMES KEYS and DEBORAH KEYS,
Plaintiffs
V.
TAYLOR MADE STAFFING, LLC
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10- 4010 (2tvilTerm
CIVIL ACTION - LAW
CONFESSION OF JUDGMENT
C)
U?
Pursuant to the authority contained in the warrant of attorney, a copy of which is attached to
the Complaint filed in this action, I appear for the Defendant and confess judgment in favor of
Plaintiffs and against the Defendant as follows:
Unpaid Rent, Heating Oil, Late Fees
through December, 2009
$31,534.00
Attorney's collection fee (10%)
TOTAL:
3,153.40
$34,687.40
THE LAW OFFICES OF MICHAEL CHEREWKA
BY: Awowjzii-?'
Michael Cherewka
Attorney I.D.# 35073
624 North Front Street
Wormleysburg, PA 17043
(717) 232-4701
Attorney for Defendant
In Accordance with
Warrant of Attorney
+M.50 P P ATW
CO 44.53
a3( 4(of
JAMES KEYS and DEBORAH KEYS,
Plaintiffs
V.
TAYLOR MADE STAFFING, LLC
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
l0 - y? I
CIVIL ACTION - LAW
COMPLAINT PURSUANT TO Pa.R.C.P. 2951(b)
(Confession of Judgment)
1. The Plaintiffs, are adult individuals with offices and a principal place of business at
3720 Trindle Road, P. O. Box 396, Camp Hill, Cumberland County, Pennsylvania 17001-0396.
2. Defendant, TAYLOR MADE STAFFING, LLC, is a Pennsylvania Limited Liability
Company with a place of business at 3710 Trindle Road, Camp Hill, PA 17011.
3. A true and correct photostatic copy of the original instrument duly executed by the
Defendant is attached hereto as Exhibit "A" and is made a part hereof.
4. This judgment is not being entered by confession against a natural person in
connection with a consumer credit transaction.
5. The aforesaid instrument has not been assigned.
6. Judgment on the aforesaid instrument has not been entered in any jurisdiction.
7. The Defendant is in default in that it has failed to pay when due amounts payable as
called for in the written instrument, a copy of which is attached hereto as Exhibit "A."
8. As a consequence of the foregoing, the Defendant is liable to the Plaintiff as follows:
Rent through December, 2009
Attorney's collection fee (10%)
TOTAL:
$31,534.00
3,153.40
$34,687.40
WHEREFORE, Plaintiffs, James Keys and Deborah Keys, demand judgment in the sum of
Thirty Four Thousand Six Hundred Eighty Seven Dollars and Forty Cents ($34,687.40) against the
Defendant, Taylor Made Staffing, LLC, in accordance with the Lease, plus costs, as authorized by
the warrant of attorney in the instrument, a copy of which is attached hereto as Exhibit "A".
Respectfully submitted,
LAW OFFICES OF MICHAEL CHEREWKA
BY:GGG
Michael Cherewka
Attorney I.D.# 35073
624 North Front Street
Wormleysburg, PA 17043
(717) 232-4701
Attorney for Plaintiff
LhASE
THIS LEASE, made this .177y4-' day of October, 2008 by and between James and
Deborah Keys, having offices at 3720 Trindle Road, Camp Hill, PA 17011 (hereinafter
called "Lessor"); and 75y1vR t4de 5&M-ty, Ue- with its principal place of business
currently located at Lewisburg, PA 17 (hereinafter called "Lessee"):
WMESSETH;
In consideration of, and under and subject to, the mutual covenants, conditions and
consideration herein recited, Lessor and Lessee, intending to be legally bound hereby,
agree as follows:
1. LEASED PREMISES: Lessor hereby lets and demises to Lessee who hereby
takes from Lessor that part of the premises situate in Cumberland County,
Pennsylvania, more particularly described as follows: 3710 Trrindle Road,
Camp Hill, PA 17011, Hampden Township ("Premises"). The leased
premises shall consist of the first and second floors only with no access to the
basement. In addition, Lessee shall have the use of the three (3) most
northern parking spaces on the ad;oining paved parking lot and additional
overflow parking in the gravel lot behind the building.
2. TERM: Lessee shall have and hold the Premises for a term of three (3) years,
said term commencing November 1, 2008 and shall continue up to and
including October 3 T, 2011.
Page 1 of 15
3: RENT:
a. Base Rent: Lessee shall pay Lessor as rent for the use of the Premises
the sum of $,509.00 payable fg ow
'yy.5ei..v
The Rent shall be paid according to the o owing terms and conditions:
a. The first month's Rent shall be paid on or before taking possession of the
leased premises, but no later than November t, 2008.
b. Rent subsequent to the first month shall be paid in the aforesaid monthly
installments, in advance, on or before the first day of each calendar month
during the term without demand, deduction or abatement. For the first
twelve (12) months, the rent shall be $1,200.00 per month, subject to three
percent (3%) annual escalation. For the second twelve (12) months, the
rent.shall be $1,236 per month, For the third twelve (12) months, the rent
shall be $1,273.08 per month.
c. Lessee shall pay Lessor a late charge of five percent (5%) of any rental
payment received more than five (5) days after payment was due.
I Lessee shall, in addition, pay Lessor the sum of $1,200.00 to be held as a
security deposit upon execution of this Lease. Said sum shall be held
without interest.
4. INDEMIv'ITY AND EXCULPATION/INSURANCE:
a. Exculpation:
Page 2 of 15 .
i. Exculpation of Lessor. The Lessor shall not be liable to the Lessee
for any damage to the Lessee, its agents, servants, employees or
invitees, or to Lessee's property, from any cause except Lessor's
negligence or willful misconduct.
ii. Exculpation of Lessee. The Lessee shall not be liable to the Lessor
for any damage to the Lessor, its agents, servants, employees or
invitees, or to Lessor's property, from any cause except Lessee's
negligence or willful misconduct.
b. Indemnity:
i. Indemnity of Lessor. The Lessee shall hold Lessor harmless from
any damage arising out of injury to any person or property in, on or
about the Premises. The Lessee's obligation under this paragraph
to indemnify and hold the Lessor harmless shall include attorneys'
fees and the costs of defense. This subparagraph shall be read in
conjunction with subparagraph (C) of this subsection dealing with
the duty of the Lessee to maintain public liability and property
damage insurance.
ii. Indemnity of Lessee. The Lessor shall hold Lessee harmless from
any damage arising out of injury to any person or property in, on or
about the common areas of the Premises. The Lessor's obligation
under this paragraph to indemnify and hold the Lessee harmless
shall include attorneys' fees and the cost of defense. This
subparagraph shall be read in conjunction with subparagraph (C)
of this subsection dealing with the duty of the parties hereto to
maintain public liability and property damage insurance:
Page 3 of 15
C. Public Liability and Property Damage Insurance
i. Lessee's Insurance Covenant. As Rent, in addition to base rent,
Lessee shall pay for and maintain public liability and property
damage insurance with liability limits of not less than One Million
Dollars ($1,000,000.00) per person and One Million Dollars
($1,000,000.00) per occurrence, insuring against all liability of the
Lessee and its authorized representatives arising out of and in
connection with the Lessee's use or occupancy of the Premises.
Lessor shall be named as additional insured, and the insurance
required by this subparagraph shalI, in part, guarantee performance
by Lessee of the indemnity provisions of the preceding paragraph.
Lessee further agrees to provide Lessor with a copy of the
insurance endorsement naming Lessor as an additional insured.
ii. Lessor's Insurance Covenant. Lessor hereby promises and
covenants to peep a general liability policy, commercially
reasonable in amount and scope of coverage, in force at all times
during the term of the Lease.
5. MAINTENANCE REPAIRS AND UTILITIES:
a. Lessor shall maintain in good condition and repair the structural
portions of the Premises and the exterior thereof. Lessor shall hP
responsible for real estate taxes, property, casualty and general liability
insurance, water, sewer, trash and snow removal lawn maintenance.
It shall be the duty of the Lessor to make repairs within a reasonable
period of time unless such repairs or replacements are due to the
negligence or willful act or omission of the Lessee, sublessees,
licensees, invitees, agents, servants or employees.
Page 4 of 15
b. Lessee shall, in addition, be responsible for all electric and heating oil
utilities, as well as cable, internet, telephone and any other services
that Lessee requires. Lessee agrees to reimburse Lessor for the
existing heating oil in the tank.
C. Lessee, at its own cost and expense, will maintain and keep in good
condition and repair its interior portion of the Premises, including but
not limited to all plumbing repairs, HVAC maintenance, repairs to
existing appliances, regular janitorial service with necessary supplies
and light bulbs, reasonable wear and tear excepted. Lessee shall be
responsible for compliance with recycling regulations and payment of
all associated fees.
CL Lessee may install a sign on the premises at Lessee's expense, with
Lessor's prior approval and subject to compliance with all municipal
regulations.
e. Lessee shall be responsible for interior decorating, including
installation. of new carpeting and floor covering and painting as
needed. Lessor grants Lessee an allowance of up to three (3) months
rent (or $3,000.00 maximum) for the documented cost of said
redecorating, but subject to prior approval by Lessor.
i Lessee shall not perform any acts or carry on any practices which may
injure Premises or be a nuisance or menace and shall keep those
portions of the Premises which are under its control clean and free
from rubbish and dirt at all times and shall not store trash or garbage in
such places as to constitute a nuisance.
6. POSSESSION: Possession of the Premises and the parking space shall be
given on or about November 1, 2008. Rent shall be payable in accordance
Page 5 of 15
with Paragraph 3 of this Lease. Lessee shall provide evidence of insurance at
the time of taking possession of the Property.
7. COMPLIANCE WITH LAW: Lessor and Lessee agree to observe and
comply with all statutes, ordinances, rules, orders, regulations, requirements
and laws now in effect or which may be enacted during continuance of this
Lease or any renewal thereof by any municipal, county, state or federal
authority or other public body or agency having jurisdiction over the Premises
or over any business Lessee conducts upon the Premises,. and Lessee and
Lessor shall indemnify and save harmless the other from noncompliance with
the same.
8. USE OF PREMISES: Except as otherwise provided, Lessee shall use the
Premises for professional office purposes only and for no other purpose. The
Premises shall be used and occupied in a safe, careful and proper manner and
no trade or occupation which is known in the insurance trade as extra or
especially hazardous activity shall be permitted therein. Lessee shall not
conduct any activity which either shall make void or voidable any insurance
on the Premises or increase the rate of premium therefore.
9. ALTERATIONS: Lessee shall made no alterations or additions or
improvements to the Premises or install any signs or business identification
without the prior written consent of the Lessor. Furthermore, all such
alterations or improvements made by Lessee (even with the consent of the
Lessor) shall, at the option of the Lessor, become the property of Lessor at the
termination of the Lease without cost to Lessor. Should Lessor notify Lessee
in writing that Lessor does not want said additions and improvements, they
MH be removed at the expense of Lessee. Lessee shall repair any damage
cause to the Premises by the installation or removal of alterations, additions or
improvements by or for Lessee.
Page 6 of 15
Lessee shall neither do nor permit nor cause to be done any act or thing which
shall create any mechanics' or other lien or claim against the Premises, or any
part thereof, and Lessee, for Lessee, Lessee's successors and assigns,
contractors, subcontractors, laborers, materialmen and all persons
whomsoever, hereby waives, releases and disclaims any and all claims and/or
rights to any mechanics' or other lien for work, labor or material, for the
furnishing or doing of any matter or thing permitted or required by law,
ordinance or regulation (now or hereafter in force) or by the terms of this
Lease or otherwise. Furthermore, Lessee hereby agrees to indemnify and save
harmless Lessor against any and all such liens and claims and all costs,
expenses and attorneys' fees in connection therewith. This covenant shall
survive the expiration or termination of this Lease.
Lessor shall neither do nor permit nor cause to be done any act or thing which
shall create any mechanics' or other lien or claim against the Premises, or any
part thereof, and Lessor, for Lessor, Lessor's successors and assigns,
contractors, subcontractors, laborers, materialmen and all persons
whomsoever, hereby waives, releases and disclaims any and all claims and/or
rights to any mechanics' or other lien for work, labor or material, for the
furnishing or doing of any matter or thing permitted or required by law,
ordinance or regulation (now or hereafter in force) or by the terms of this
Lease or otherwise. Furthermore, Lessor hereby agrees to indemnify and save
harmless Lessee against any and all such liens and claims and all costs,
expenses and attorneys' fees in connection therewith. This covenant shall
survive the expiration or termination of this Lease.
10. SUBLETTING: Lessee shall not assign, underlet, sublet or mortgage the
Premises or any part thereof or permit any party, person, firm or corporation
to occupy the Premises or any part thereof without the prior written consent of
Lessor, which consent shall not be unreasonably withheld.
Page 7 of 15
Any assignment by operation of law, attachment or assignment for the benefit
of creditors shall, at Lessor's option, be inoperative. Notwithstanding any
subletting or assigning, Lessee shall remain obligated for the full and faithful
performance of all terms and conditions of this Lease. If Lessee sublets the
Premises or assigns this Lease upon terms which result in Lessee's receiving
compensation in excess of Lessee's rental obligations hereunder to the Lessor,
Lessor and Lessee agree that Lessor shall receive one-half of such excess
compensation as and when received by Lessee.
11. SUBORDINATION: Lessee agrees, in the event the mortgagee under any
mortgage which Lessor has or may give against the Premises shall so require,
to subordinate the lien and priority of this Lease in favor of such mortgage and
to execute any instruments which Lessor or such mortgagee may deem
necessary and/or appropriate to accomplish that end.
12. ACCESS AND REPAIRS: Lessor, or Lessor's representatives, at all times
may go upon and inspect the Premises only after providing reasonable notice
to Lessee and/or, at Lessor's option, make repairs, alterations and additions to
the Premises or the property of which the Premises is a part. If there is no
response from Lessee within twenty-four (24) hours of Lessor's notice, Lessor
or Lessor's representatives may enter the Premises if necessary, provided that
Lessor shall employ its best efforts to avoid disruption in and to Lessee's
normal business operations. Lessor shall also have the right to relet the
Premises upon the expiration or termination of the Lease and shall have the
right to market the Premises and to show the Premises to potential buyers,
tenants, etc., at any time, after reasonable notice to Lessee, provided there is
no disruption in or to Lessee's normal business operations and to place signs
advertising and announcing the same about the Premises.
13. DAMAGE OR DESTRUCTION: If the Premises shall be so injured by :ire,
storm or other cause as to become untenable by Lessee, then Rent shall abate
Page 8 of 15
and shall be apportioned to the date when the Premises became untenable. If
and unless Lessor, within one hundred twenty (120) days thereafter, shall
repair such damage, either party may terminate the Lease.
If the Premises are rendered untenable only in part so that the Premises shall
remain usable for Lessee's purposes and so that Lessee is able to conduct its
normal business operations, the Lease shall continue but the rental shall be
equitably reduced.
14. DEFAULT:
a. Lessee's Default. The occurrence of any of the following shall
constitute an event of default by Lessee:
i. Failure to pay Rent or any other sum of money when due if the
failure continues for five (5) days after notice has been given to
Lessee.
ii. Failure to perform any other provision of this lease if the failure to
perform is not cured within thirty (30) days after notice has been
given to Lessee. If default cannot reasonably be cured A4
thi
n
thirty (30) days, Lessee shalt not be in default of this Lease if
Lessee commences to cure the default within the thirty (30) day
period and diligently and in good faith continues to cure the
default.
Notices given under this paragraph shall specify the alleged default
and shall demand that Lessee perform the provisions of this Lease
or pay the Rent that is in arrears, as the case may be, within the
applicable period of time.
Page 9 of 15
b. Bankruptcy. If a petition in bankruptcy shall be filed by the Lessee, or
the Lessee shall be adjudicated bankrupt, or if the Lessee shall make a
general assignment for the benefit of creditors, or if in any proceeding
based upon the insolvency of the Lessee a receiver of all the property
of the Lessee shall be appointed and shall not be discharged within
ninety (90) days after such appointment, then the Lessor may
terminate this Lease by giving written notice to the Lessee of its
intentions so to do.
15. LESSOR'S REMEDIES: Lessor shall attempt to mitigate any and all claims
against Lessee in the event of Lessee's default. Lessor shall have the
following remedies if Lessee commits an event of default. These remedies are
not exclusive; they are cumulative in addition to any remedies now or later
allowed by law or equity.
a. Lessee's Right to Possession Not Terminated. Lessor can continue
this Lease in full force and effect, and the Lease will continue in effect
as long as Lessor does not terminate Lessee's right to possession, and
Lessor shall have the right to collect Rent when due. After the
occurrence of an event of default, Lessor may enter the Premises and
re-let it, or any part of it, to third parties for Lessee's account. Lessee
shall be liable immediately to Lessor for all reasonable costs Lessor
incurs in re-letting the Premises, including, without limitation,
brokers' commissions. Re-letting can be for a period shorter or longer
than the remaining term of this Lease. Lessee shall pay to Lessor the
Rent due under this Lease on the dates the Rent is due, less the Rent
Lessor receives from any re-letting.
b. Termination of Lessee's Rights to Possession. Lessor can terminate
all of Lessee's rights hereunder, including Lessee's right to possession
of the Premises, by giving Lessee notice of election to terminate this
Page 10 of 15
Lease, specifying a day not less than twenty (20) or more than ninety
(90) days after the giving of such notice when the term shall end, and
upon the giving of such notice when the term shall end, and upon the
day so specified in the notice the term shall expire and Lessee shall
then quit and surrender the Premises to the Lessor. No act or omission
by Lessor other than giving notice to Lessee shall terminate this Lease.
On termination, Lessor has the right to recover from Lessee
immediately the unpaid rental, and any other amounts, and court costs
and reasonable attorneys' fees, relating to Lessee's default.
C. Suit for Rent. Lessor can declare due and payable and sue to recover
unpaid Rent and all other charges due and payable by Lessee to
Lessor, including Rent for the unexpired term of this Lease, and all
costs and commissions provided or permitted by law.
d.. Confession of Judgment for Money. Lessor can confess judgment on
behalf of Lessee in favor of Lessor for all amounts due hereunder with
interest, costs and attomeys' commission of ten percent ('10%) using
this Lease or a copy hereof as authority for such action.
e. Amicable Action in Ejectment. Lessor can enter an amicable action
and judgment in ejectment against Lessee, using this Lease or a copy
hereof as authority and causing a "writ of possession" to be issued.
f. Miscellaneous. The exercise of any remedy or remedies provided
herein by Lessor shall not preclude Lessor's exercising, concurrently
or successively, one , or more other remedies provided herein or
authorized by law. Lessee hereby empowers any attorney of any court
of record to appear for it one or more times and to take on its behalf
any or all of the actions described in (d) and (e) immediately above,
provided Lessor gives Lessee fifteen (15) days' prior written notice,
Page 1 i of 15
including the entry of judgment by confession, agreement or
otherwise.
16. ACCEPTANCE OF NOTICE: Lessee hereby accepts notice to quit, remove
from and surrender up possession of the said Premises to Lessor at the
expiration of the term hereof.
17. CONDEMNATION:
a. Total Taking. If the property of which the Premises constitutes a part
is totally taken by condemnation, this Lease shall terminate on the date
of taldng of possession by the condemning authority.
b. Partial Taking.
i. Effect on Lease - If any portion of the property of which the
Premises constitutes a part is taken by condemnation, this Lease
shall remain in effect, except that Lessee can elect to terminate this
Lease if the remaining portion of the building or other
improvements is rendered unsuitable for Lessee's continued use of
the Premises.
ii. Effect on Rent - If any portion of the Premises is taken by
condemnation and this Lease remains in full force and effect, on
the date of taking of possession by the condemning authority, the
monthly Rent shall be equitably reduced.
G. Award Distribution. The entire award shall belong to and be paid to
Lessor except that Lessee shall receive from the award:
Page 12 of 15
i. A sum attributable to Lessee's improvements or alterations made
to the Premises by Lessee in accordance with this Lease, which
Lessee's improvements or alterations Lessee has the right to
remove from the Premises pursuant to the provisions of this Lease,
but elects not to remove; and,
ii. A sum attributable to that portion of this award constituting
Lessee's relocation costs.
18. NOTICES: All notices or other communications pursuant hereto to any party
shall be in writing and shall be deemed given when delivered personally or
deposited in the United States mail, postage prepaid, return receipt requested,
addressed to the parties at the addresses set out below, or at such other address
as provided for by a notice complying with this paragraph:
If to Lessor: 3720 Trindle Road, Camp Hill, PA 17011
If to Lessee: At the Premises.
19. HOLDING OVER AS RENEWAL: Holding over by the Lessee beyond, the
term of this Lease, or any hereinafter duly authorized additional terms, shall
be deemed on a month-to-month basis, and only with the Lessor's approval in
writing, said renewal being under and subject to all of the provisions
contained in this Lease except Rent. As a precondition to holding over,.
Lessee must obtain Lessor's permission or consent {which may be withheld at
Lessor's sole discretion} to hold over in writing at least ninety (90) days prior
to the expiration of the term hereof.
20. HEADINGS: Any heading preceding the text of the several paragraphs and
subparagraphs hereof are inserted solely for convenience of reference and
shall not constitute a part of this Lease, nor shall they affect its meaning,
construction or effect.
Page 13 of 15
21. MODIFICATION: This Lease may not be modified, discharged or terminated
orally or in any other manner than by written agreement signed by both parties
hereto.
22. PENNSYLVANIA LAW: This Lease shall be construed according to, subject
to and be governed by the laws of Pennsylvania
23. LESSOR'S DEFAULT: If Lessor fails to perform or observe any material
provision or condition of this Lease and fails to dire or undertake reasonable
action to cure the default within fifteen (15) business days after Lessee's
written notice to Lessor sustained by Lessee as a direct, proximate and
consequential result of Lessor's breach, including reasonable attorneys' fees
and expenses actually incurred if suit is entered by Lessee and Lessee prevails
in said action. Lessee may invoke any additional remedies at law or in equity.
24. ENTIRE AGREEMENT: This instrument contains the entire agreement
between the parties hereto and shall be binding upon the parties hereto, their
heirs, successors and assigns. This Lease and options shall not be recorded in
any public office.
Page 14 of 15
IN WITNESS WHEREOF, the parties hereto have executed these premises the day and
year first above written.
WITNESS:
By
LESSEE:
By
Page 15 of 15
VERIFICATION
I, James Keys, do verify that I am authorized to make the statements herein and that the
statements made in the foregoing Complaint are true and convect to the best of my knowledge,
information and belief. I understand that false statements made herein are subject to the penalties of
18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
DATED: 04 JANUARY 2010
JAMES KEYS and DEBORAH KEYS,
Plaintiffs
V.
TAYLOR MADE STAFFING, LLC
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10 14o1(v l?tVtl `?qt ,?,
CIVIL ACTION - LAWS
-r 1711
0
CERTIFICATION OF ADDRESSES
I hereby certify that the following is the address of the defendant(s) stated in the
Retail Lease Agreement:
TAYLOR MADE STAFFING, LLC
3710 Trindle Road
Camp Hill, PA 17011
I hereby certify that the following is the address of the plaintiff(s) stated in the Retail
Lease Agreement:
JAMES AND DEBORAH KEYS
3720 Trindle Road, P. O. Box 396
Camp Hill, Pennsylvania 17001-0396
Attorney for Plaintiff
V t %
JAMES KEYS and DEBORAH KEYS,
Plaintiffs
VS.
TAYLOR MADE STAFFING, LLC
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ib - 'fatly l,tvil -ter ry
CIVIL ACTION -
To Taylor Made Staffing, LLC, Defendant(s)
You are hereby notified that on January 0,2010, judgment by confession was entered against
you in the sum of $34,687.40 in the above-captioned case.
'), ? zt/ -
DATE: ) 1 Protho tart'
YOU SHOULD TAKE THIS PAPER TO YOUR 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 LAWYER REFERRAL SERVICE
2 Liberty Avenue
Carlisle PA 17013
(717) 249-3166
I hereby certify that the following is the address of the defendant(s) stated in the
Retail Lease Agreement:
TAYLOR MADE STAFFING, LLC
3710 Trindle Road
Camp Hill, PA 17011
skd M 44 ?
Attorney for Plaintiff
A TAYLOR MADE STAFFING, LLC, Demandado(s)
Por este medio sea avisado que en el dia 4 de enero de 2010, un fallo por
admision fue registrado contra usted por la cantidad de $34,687.40 del caso antes escrito.
Fecha: el dia 4 de enero de 2010
Protonotario
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO
TIENE ABOGADO O SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELEPHONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
2 Liberty Avenue
Carlisle PA 17013
(717) 249-3166
Por este medio certifico que to siguoiente es la direccion del demando dicho en el
certificado de residentia:
Taylor Made Staffing, LLC
3710 Trindle Road
Camp Hill, PA 17011