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HomeMy WebLinkAbout10-1103Fit_ l_• r 2010 FEB 16 l l By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 24 W. Maplewood Ave Mechanicsburg, PA 17055 (717) 579-4215 q!^ !4'"I CU :v: Attorneys 'PWhti' f" Waveline Direct, LLC. WAVELIKE DIRECT, LLC. Plaintiffs vs. GOODRICH & COMPANY PROMOTIONS, INC. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 - n a3 l BREACH OF CONTRACT - LAW JURY TRIAL DEMANDED TO: GOODRICH & COMPANY PROMOTIONS, INC. Defendant 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 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 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 (800) 990-9108 ( D" f9a.o6 eK? ssc.a 436764-I AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o po abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier dinero reclamado en la demanda o po cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 436764-! By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 24 W. Maplewood Ave Attorney for Plaintiff Mechanicsburg, PA 17055 Waveline Direct, LLC. (717) 579-4215 WAVELINE DIRECT, LLC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. NO. 10 - l l v 3 u 1 ?r GOODRICH & COMPANY- BREACH OF CONTRACT - LAW PROMOTIONS, INC., Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Waveline Direct, LLC., by and through its attorney, Francis J. Lafferty, IV, and respectfully represent the following: 1. Plaintiff Waveline Direct LLC. (hereinafter "Plaintiff'), is a limited liability company organized under the laws of the Commonwealth of Pennsylvania. It maintains a place of business and its Registered Office at 192 Hempt Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Goodrich & Company Promotions, Inc. (hereinafter "Defendant"), is a corporation organized under the laws of the Commonwealth of Pennsylvania. Its Registered Office at 335 Southview Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. On numerous occasions, between January 1, 2009 and April 14, 2009, Plaintiff and Defendant entered into contracts whereby Plaintiff provided various printing-related products and services, and Defendant ultimately was to pay Plaintiff a sum equal to $42,945.96 for its labor, products and services. Attached as Exhibit "A" and made part of this complaint as if 436764-1 fully set forth herein are photocopies of the unpaid invoices for work completed and delivered pursuant to the agreement between the parties. Also, see correspondence dated December 9, 2009, attached as Exhibit "B". 4. Plaintiff fully performed its duties as required by the contract. 5. On numerous occasions, in the form of letters and invoices, Plaintiff demanded payment from Defendant for the labor, products and services it received pursuant to the terms of the contract. As of the date of filing this complaint, Defendant has refused to pay for the labor, products and services it received and accepted. COUNTI BREACH OF CONTRACT 6. The allegations of Paragraphs 1 through 5, above, are incorporated herein by reference as if fully set forth. 7. Defendants' willful failure to pay constitutes a breach of the contract between Plaintiff and Defendant. WHEREFORE, Plaintiff, Waveline Direct, LLC., respectfully requests this Honorable Court to issue an Order: (a) Granting Judgment for Plaintiff and against Defendant in the amount of $42,945.96, exclusive of interest and costs; (b) Granting Plaintiff its expenses, including reasonable attorney fees incurred in connection with this action; and (c) Granting such other relief as the Court deems appropriate. 436764-1 COUNT II UNJUST ENRICHMENT 8. The allegations of Paragraphs 1 through 8, above, are incorporated herein by reference as if fully set forth. 9. Defendant has accepted the labor products and services of Plaintiff and received the benefit thereof. The fair market value of said labor, products and services is $42,945.96. 10. Defendant has refused and continues to refuse to pay $42,945.96, the fair market value for such labor, products and services. WHEREFORE, Plaintiff, Waveline Direct, LLC., respectfully requests this Honorable Court to issue an Order: (a) Granting Judgment for Plaintiff and against Defendant in the amount of $42,945.96, exclusive of interest and costs; (b) Granting Plaintiff its expenses, including reasonable attorney fees incurred in connection with this action; and (c) Granting such other relief as the Court deems appropriate. Respectfully By: F?Ancis J. Laffertr, IV, Esquire Attorney I.D. No. 84009 24 W. Maplewood Ave Mechanicsburg, PA 17055 (717) 579-4215 Attorney for Plaintiff Dated: ) NO 436764-1 VERIFICATION The undersigned hereby certifies that he is the attorney for the Plaintiff, Waveline Direct, LLC., and that the facts in the foregoing Plaintiff's Complaint are true and correct to the best of his knowledge, information, and belief, and that said matters relating to the Plaintiff, Waveline Direct, LLC., as known to the undersigned and as to the client, Plaintiff, Waveline Direct, LLC., said knowledge being based upon information contained in the attorney's file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: 4NO - 436764-1 , ? A 01/14/2010 @02:122M Waveline Direct LLC Page 1 CUSTOMER CARD REPORT CUSTOMER ID GOODRICH NAME Goodrich & Company Promotions BILL ADDRESS P 0 Box 1577 Mechanicsburg PA 17055 SHIP ADDRESS CONTAC'T' PHONE SALESPERSON SALES ACCT COMMENTS Bob, Lisa & Karen 130 Gettysburg Pike Mechanicsburg 17055 (717) 796-2380 4000-01 Sales - House CUSTOMER TYPE ACCOUNT TYPE SALES TAX ID SALES TAX EXEMP TERMS: DUE DISCOUNT DISCOUNT FINANCE CHARGE CREDIT LIMIT HIGH CREDIT CREDIT STATUS SALES LAST YEAR SALES THIS YEAR H OPEN ITEM PA 0 15 DAYS 0 DAYS 1.00 PERCENT 0.00 PERCENT 0.00 44,355.94 23,812.53 0.00 AGING: CURRENT OVER 30 OVER 45 OVER 60 TOTAL DUE --------- -------------- ----------0.00 0.00 0.00 0.00 0.00 CUSTOMER HISTORY DATE -------- T - REF # - AMOUNT 01/06/09 S ------- 10896 ------------ 4,860.54 01/09/09 I 26364 550.30 01/09/09 1 26376 1,590.00 01/09/09 I 26333 4,110.55 01/09/09 I 26334 4,392.22 01/19/09 S 10927 4,778.94 01/22/09 X 26333 1,060.00- 01/29/09 I 26463 7,817.50 01/29/09 I 26414 10,388.00 01/29/09 I 26421 6,248.70 02/11/09 P 10967 6,250.85- 02/18/09 I 24556 371.00 02/24/09 I 26662 265.00 02/26/09 1 26619 371.00 03/05/09 I 26675 1,590.00 03/09/09 P 11078 3,332.22- 03/12/09 I 26672 5,724.00 03/17/09 I 26638 1,908.00 03/17/09 I 26726 1,378.00 03/25/09 I 26739 567.26 03/25/09 I 26740 4,00-L.50 03/25/09 I 26780 901.00 03/25/09 I 26740pos 2,824.98 03/26/09 P 11066 4,324.98- 04/09/09 I 26850 1,590.00 04/13/09 P 1063 265.00- 04/14/09 I 26912 1,590.00 09/10/09 X BadDebt 0.00 12/31/09 X BadDebt 0.00 12/01/09 X BadDebt 42,945.96- - Goodrich & Company Promotions SLS DUE --- ----- DISC ----- DISC AVL ------- TAKEN - 0.00 -------- 0.00 01/24 01/09 5.19 0.00 01/24 01/09 15.00 0.00 01/24 01/09 38.78 0.00 01/24 01/09 41.44 0.00 0.00 0.00 02/06 0.00 0.00 02/13 01/29 73.75 0.00 02/13 01/29 98.00 0.00 02/13 01/29 58.95 0.00 0.00 0.00 03/05 02/18 3.50 0.00 03/11 02/24 2.50 0.00 03/13 02/26 3.50 0.00 03/20 03/05 15.00 0.00 0.00 0.00 03/27 03/12 54.00 0.00 04/01 03/17 18.00 0.00 04/01 03/17 13.00 0.00 04/09 03/25 4.75 0.00 04/09 03/25 37.75 0.00 04/09 03/25 8.50 0.00 04/09 0.00 0.00 0.00 0.00 04/24 04/09 15.00 0.00 0.00 0.00 04/29 04/14 15.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 OPEN BAL 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Goodrich & Company Promotions INVOICE NUMBER: 26414 P O Box 1577 INVOICE DATE: 01/29/09 Mechanicsburg PA 17055 DUE DATE: 02/13/09 INVOICE 5500 Winter Buyers Guide - 36 page 80# mohawk matte 4/4 + Peppered Bronze Cover 4/4 color Print, die cut, saddle, shrink wrap individually for mailing - Cass certify & deliver to PostOffice 4977 Mailing - actual postage $4778.94 Check 10927 SUBTOTAL Sales TAX 9,800.00 9,800.00 588.00 TOTAL 10,388.00 $98.00 Discount if paid by 01/29/09 Goodrich & Company P O Box 1577 Mechanicsburg PA Promotions 17055 INVOICE INVOICE NUMBER: INVOICE DATE: DUE DATE: The Designer Cratsmen Show of Philadelphia 3000 7x9 24 pg 80# Mohawk Matte + 80# Peppered Bronze Cover - Both 4/4 color saddled. Cover die cut. Delivered to Office. SUBTOTAL Sales TAX 26421 01/29/09 02/13/09 5,895.00 5,895.00 353.70 TOTAL 6,248.70 $58.95 Discount if paid by 01/29/09 Goodrich & Company Promotions P 0 Box 1577 Mechanicsburg PA 17055 INVOICE Market Square Winter Program - Pick up @ Waveline INVOICE NUMBER: INVOICE DATE: DUE DATE: 3000 80# Mohawk Matte 40 page 4/4 color + 80# Peppered Bronze Die Cut Cover 4/4 color 7x9 saddled SUBTOTAL Sales TAX 26463 01/29/09 02/13/09 7,375.00 7,375.00 442.50 TOTAL 7,817.50 $73.75 Discount if paid by 01/29/09 Goodrich & Company Promotions P O Box 1577 Mechanicsburg PA 17055 INVOICE INVOICE NUMBER: INVOICE DATE: DUE DATE: 3000 3.5 x 8.5 100# glenn eagle natural dull cover 1/1 invitations SUBTOTAL Sales TAX 26638 03/17/09 04/01/09 1,800.00 1,800.00 108.00 TOTAL 1,908.00 $18.00 Discount if paid by 03/17/09 Goodrich & Company Promotions P O Box 1577 Mechanicsburg PA 1.7055 INVOICE INVOICE NUMBER: INVOICE DATE: DUE DATE: 150 Invitations 100# Glen Eagle Cover Natural Dull 4/0 SUBTOTAL Sales TAX 26662 02/24/09 03/11/09 250.00 250.00 15.00 TOTAL 265.00 $2.50 Discount if paid by 02/24/09 Goodrich & Company Promotions INVOICE NUMBER: 26672 P O Box 1577 INVOICE DATE: 03/12/09 Mechanicsburg PA 17055 DUE DATE: 03/27/09 INVOICE 8000 MidAtlantic Garden 16 pg 80# 4/4 + 100#t gloss 4/4 SUBTOTAL Sales TAX 5,400.00 5,400.00 324.00 TOTAL 5,724.00 $54.00 Discount if paid by 03/12/09 Goodrich & Company Promotions P O Box 1577 Mechanicsburg PA 1.7055 INVOICE INVOICE NUMBER: INVOICE DATE: DUE DATE: 4000 Folk Art & Antique Show 8.5x16.5 80# Mohawk 1/1 folded to 8.5x5.5 SUBTOTAL Sales TAX 26675 03/05/09 03/20/09 1,500.00 1,500.00 90.00 TOTAL 1,590.00 $15.00 Discount if paid by 03/05/09 Goodrich & Company Promotions INVOICE NUMBER: 26726 P 0 Box 1577 INVOICE DATE: 03/17/09 Mechanicsburg PA 17055 DUE DATE: 04/01/09 INVOICE 800+ Sturbridge Directory 4/4 color 14 x 9 folded to 7 x 9 SUBTOTAL Sales TAX 1,300.00 1,300.00 78.00 TOTAL 1,378.00 $13.00 Discount: if paid by 03/17/09 Goodrich & Company Promotions INVOICE NUMBER: 26739 P O Box 1577 INVOICE DATE: 03/25/09 Mechanicsburg PA 17055 DUE DATE: 04/09/09 INVOICE 2500 12pt C1S 4x9 5/1 color "The Gallery of Designer" 475.00 SUBTOTAL 475.00 Sales TAX 28.50 SHIPPING 63.76 TOTAL 567.26 $4.75 Discount if paid by 03/25/09 Goodrich & Company Promotions INVOICE NUMBER: 26740 P O Box 1577 INVOICE DATE: 03/25/09 Mechanicsburg PA 1.7055 DUE DATE: 04/09/09 INVOICE 15500 100#t gloss 16x9 5/5 color folded to 4x9 3,250.00 Sturbridge Brochure 11572 Mailing 525.00 Actual postage $2824.98 SUBTOTAL 3,775.00 Sales TAX 226.50 TOTAL 4,001.50 $37.75 Discount if paid by 03/25/09 Goodrich & Company Promotions P O Box 1577 Mechanicsburg PA 1.7055 INVOICE INVOICE NUMBER: INVOICE DATE: DUE DATE : 500 80# Mohawk 14x9 4/4 color Directory folded to 7x9 SUBTOTAL Sales TAX 26780 03/25/09 04/09/09 850.00 850.00 51.00 TOTAL 901.00 $8.50 Discount if paid by 03/25/09 Goodrich & Company Promotions INVOICE NUMBER: 26850 P'O Box 1577 INVOICE DATE: 04/09/09 Mechanicsburg PA 1.7055 DUE DATE: 04/24/09 INVOICE Sturbridge Brochure 100#t gloss 16x9 - rerun w/change 1,500.00 SUBTOTAL 1,500.00 Sales TAX 90.00 TOTAL 1,590.00 $15.00 Discount if paid by 04/09/09 Goodrich & Company Promotions INVOICE NUMBER: 26912 P O Box 1577 INVOICE DATE: 04/14/09 Mechanicsburg PA 1.7055 DUE DATE: 04/29/09 INVOICE 2000 Sturbridge Directory 16 pg 60#t 1/1 + 100#t gloss cover 5/4 color 7x9 SUBTOTAL Sales TAX 1,500.00 1,500.00 90.00 TOTAL 1,590.00 $15.00 Discount if paid by 04/14/09 k.. 22/?^12?:.? 1:2e- ?7958896 'nA'JELINE DIRECT 529452 DEC 9, 2009 ACT WT LTR #PK i SERVICE IDA BILL SIT LTR TRACKING# 125294520167583082 ALL, CURRENCY USD REF 1: REF 2., HANDLING CHARGE 0.00 SHIPMENT NR RATE CHARGES: DV 0.00 Coo DC 0.00 DOD AN 6.00 PR TOT NR CHG 8.97 TOT PUB CHG 15.74 December 9, 2009 Mr. Robert Goodrich Goodrich & Company Promotions 130 Gettysburg Pike P 0 Box 1577 Mechanicsburg PA 17055 Good day Bob, FRT: SHP SVC 8.97 USD 0.00 Rs 0.00 0.00 0,00 ROD 0.00 NR+HANDLING 8,97 PUO+HANDLING 15.74 I aria hoping this letter finds you doing much better than the last time we spoke. Mr. Taylor and I were going over your account and he brought to my attention that you have been, having shows. My understanding is that you were going to start paying down the $42,945.96 balance that you owe Waveline Direct LLC. Please contact me 717-7958830 within ten days, (December 21St), to tell me of your plan. With the large amount of money owing, without a plan, I will have to pursue a Collection, Attorney. Best regards, PAGE 01101 Lynn F. Prosser Controller SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp SOi1CltOr ~~,~y~t+' of ~sitr~#fr1'(,~~~ ~IL~~--±'r~=~~F rl'= 'i'~ it t~r„1_f. ~n", t(~`~"r,aV ZGlCFEc3 22 ~~~ 9~ 4~ W @ , + \ Waveline Direct, LLC vs. Goodrich & Company Promotions, Inc. Case Number 2010-1103 SHERIFF'S RETURN OF SERVICE 02/18/2010 02:07 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February 18, 2010 at 1407 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Goodrich & Company Promotions, Inc., by making known unto Heather Rea, Web Designer for Goodrich & Company Promotions, Inc. at 5 Kacey Court, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.44 February 19, 2010 (c;' CamrySu':te :hen~F. Teba^£L. 6?c. SO ANSWERS, '-~.. O Y R ANDERSON, SHERIFF 1 BY Deputy eriff By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 24 W. Maplewood Ave Mechanicsburg, PA 17055 (717)579-4215 i^r ~f ~, ~t .. L I Attor~i~~~c~~'Yai~t~ff ~~ ~~ ~ 1 Waveline Direct, LLC. 7~/ GUE~: .~ . .:'Ji~~ 1 ! ,. WAVELIKE DIRECT, LLC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. GOODRICH & COMPANY PROMOTIONS, INC., NO. 10-1103 BREACH OF CONTRACT -LAW Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter default judgment in favor of the Plaintiffs and against the Defendant for failure to file an answer or enter an appearance within twenty (20) days of the service of the complaint or ten (10) days of the notice of intention to enter default judgment. A copy of the latter notice is attached hereto as Exhibit "A". Enter judgment in the following amount: Amount of Demand and Complaint TOTAL $42,945.96 $42,945.96 plus interest to be determined /~ By: F ands J. Laff y, V, squire Attorney I.D. No. 84009 24 W. Maplewood Avenue Mechanicsburg, PA 17055 (717) 579-4215 Dated: ~ / ~ ~~ Attorney for Plaintiffs ~I`~~ 0 ~~ Q Ai'r`/ CIL 4419~~-~ ~,# a~aa~q (~o~ee, I~lou-(~r,~ By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 24 W. Maplewood Ave Mechanicsburg, PA 1705 (717) 579-4215 Attorney for Plaintiff Waveline Direct. LLC. WAVELIKE DIRECT, LLC., Plaintiffs vs. GOODRICH & COMPANY PROMOTIONS, INC., Defendants TO: Manager, Officer or Authorized A ent Goodrich & Company Promotions Inc Defendant DATE OF NOTICE: March 23, 2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1103 BREACH OF CONTRACT -LAW JURY TRIAL DEMANDED IMPORTANT NOTICE 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 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 LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 440075-1 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 METZGER, HAM, KNAUSS & ERB, P.C. By: ancis J. erty, Esquire Attorney I.D. No. 84009 24 W. Maplewood Avenue Mechanicsburg, PA 17055 (717) 579-4215 Dated: March 23, 2010 440075-/ CERTIFICATE OF SERVICE I, Francis J. Lafferty, N, Esquire, do hereby certify that on the date set forth below, I did serve a true and correct copy of the foregoing document upon the following persons at the following addresses indicated below by sending same in the United States mail, postage prepaid, as follows: CERTIFIED MAIL AND REGULAR MAIL Goodrich & Company Promotions, Inc. 335 Southview Drive Mechanicsburg, PA 17055 By F ncis J. Laffe , I ,Esquire Dated: March 23, 2010 440075-1 CERTIFICATE OF SERVICE AND NOW, I, Francis J. Lafferty, IV, Esquire, attorney for Plaintiffs, hereby certify that I served the foregoing Plaintiff's Praecipe for Entry of Default Judgment against Defendant Goodrich & Company Promotions, Inc. this day by depositing the same in the United States mail, first class, postage prepaid and certified mail, in Harrisburg, Pennsylvania, addressed to: Goodrich & Company Promotions, Inc. 5 Kacey Court Mechanicsburg, PA 17055 Dated: ~ Y ~~_ 44198/-/ C~ ^' -, ~_ C i O -~ ~ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL~A-NIA ~ _ - r-.: - CIVIL DIVISION "`~ PRAECIPE FOR WRIT OF EXECUTION ~ ~ __ . . ^/ Confessed Judgment Waveline Direct, LLC ~ ~. Plaintiff ^ Other V S. Goodrich & Company Promotions, Inc. Defendant Address: 5 Kacey Court Mechanicsburg, PA 17055 File No. 10-1103 Amount Due $42,945.96 Interest t/b/d Atty's Comm t~b~d Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all property owned by Goodrich & Company Promotions, Inc. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the sa (Indicate) Index this writ against the garnishee (s) as a lis defendant(s) described in the attached exhibit. Date 7/19/10 Signature: Print Name: ~ a~• oo P~ Q~rl ~~ 4~ Ci3l~ Address: qa. oo ~~ i~! • 00 d. c..~D ~~ Attorney for: ~` l78.4~f - P° ATM Telephone: Fr,6ncis J. ~,a~rty, IV ~4 W. Maplewood Ave. Mechanicsburg, PA 17055 Waveline Direct, LLC (717) 579-4215 Supreme Court ID No: 84009 02.00 QUE~ • 60 t.t,. C~ lo(~ ~~ ay ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-1103 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WAVELINE DIRECT, LLC, Plaintiff (s) From GOODRICH & COMPANY PROMOTIONS, INC., 5 Kacey Court, Mechanicsburg, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all property owned by Defendants . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $42,945.96 L.L.$.50 Interest Atty's Comm % Due Prothy $2.00 Atty Paid $178.94 Other Costs Plaintiff Paid Date: 7/20/10 avid D. Buell Prothonotary (Seal) BY~ Deputy REQUESTING PARTY: Name FRANCIS J. LAFFERTY, IV, ESQUIRE Address: 24 W. MAPLEWOOD AVENUE MECHANICSBURG, PA 17055 Attorney for: PLAINTIFF Telephone: 717-579-4215 Supreme Court ID No. 84009 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson t t ?1 ED - - 01 Jody S Smith Chief Deputy a jt r Richard W Stewart Solicitor , I. l E f i l_ 6 Waveline Direct, LLC vs. Case Number Goodrich & Company Promotions, Inc., 2010-1103 SHERIFF'S RETURN OF SERVICE 08/18/2010 03:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2010 at 1450 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Goodrich & Company Promotions, Inc., by making known unto Robert and Lisa Goodrich, Adults in Charge, at 1595 W Lisburn Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to them personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 08-19-10. 03/11/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $72.69 SO ANSWERS, March 11, 2011 RON R ANDERSON, SHERIFF B ron R. Lantz L? rd - 66 - a SG 0/9 c vruntgSuite St;erdf. T?;iwoft. I.u.