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Home My WebLink About10-2879MATTLEMAN, WEINROTH & MILLER, P.C. BY: Alison B. Weinroth-Shaw, Esquire Attorney I.D. No.: 84407 Suite 2226, Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 Attorneys for Plaintiff Our File Number: 00-75617-0 Fl ED-1 ' - CT CF TI J.° rl -. tY4R i 2010 APR 29 AN H: 29 cr t, M, ?_ Plaintiff YELLOW BOOK SALES & DISTRIBUTION COMPANY, INC. 2201 Rennasaince Boulevard King Of Prussia, PA 19406 vs. Defendant(s) FLOYD ALLAMON 329 Bahama Circle Leiby's Parkway Carlisle, Pennsylvania 17015 FLOYD ALLAMON Va F & R Property Maintenance and/or d/b/a F A R Property Maintenance 329 Bahama Circle COURT OF COMMON PLEAS Cumberland County No.: 10 -0?S7? (.: t v c L eQ--kn "ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED" Leiby's Parkway Carlisle, Pennsylvania 17015 CIVIL ACTION COMPLAINT CIVIL ACTION: (1. CONTRACT) 1060 - Contracts for Goods, Enforcement of Accounts NOTICE 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 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. AVISO Le han demandado a usted en la corte. Si usted quiere defenders de estas demandas expuestas en las paginas siguientes, usted tiene veinte (2) dias de plazo al partlr de la fecha de la demanda y la notificacion. Hace fatta ansentar una comparesencia escrita o en persona o con un abogado'y entragar a la corte wn forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la coret tomar' medidas u puede continuar is demanda en contra suya sim previo aviso o notificacion. Ademas, la corte puede decidir a favor del emandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importsntes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO. Cumberland County Bar Association 7 S Q?'Uf? (?7 32 S. Bedford Street Carlisle, PA 17013 y813 Tel: 717-249-3166 MATTLEMAN, WEINROTH & MILLER, P.C. BY: Alison B. Weinroth-Shaw, Esquire Attorney I.D. No.: 84407 Suite 2226, Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 Attorneys for Plaintiff Our File Number: 00-75617-0 Plaintiff YELLOW BOOK SALES & DISTRIBUTION COMPANY, INC. 2201 Rennasaince Boulevard King Of Prussia, PA 19406 vs. Defendant(s) FLOYD ALLAMON 329 Bahama Circle Leiby's Parkway Carlisle, Pennsylvania 17015 FLOYD ALLAMON t/a F & R Property Maintenance and/or d/b/a F & R Property Maintenance 329 Bahama Circle Leiby's Parkway Carlisle, Pennsylvania 17015 COURT OF COMMON PLEAS Cumberland County No.: CIVIL ACTION COMPLAINT Plaintiff, YELLOW BOOK SALES & DISTRIBUTION COMPANY, INC., with an office located at 2201 Rennasaince Boulevard, King of Prussia, Pennsylvania 19406, by way of Complaint against the above named Defendants says that: 1. Defendant, FLOYD ALLAMON, is an adult individual residing at 329 Bahama Circle, Leiby's Parkway, Carlisle, Pennsylvania 17015. 2. Defendant, FLOYD ALLAMON t/a F & R Property Maintenance and/or d/b/a F & R Property Maintenance, is an adult individual residing at 329 Bahama Circle, Leiby's Parkway, Carlisle, Pennsylvania 17015. 3. Defendants executed and delivered to Plaintiff an Advertising Agreement (herein "Agreement") under account number XXX1191. Advertising services in the sum of $6,842.00 were provided as per the Agreement. 4. Under the terms of the Agreement, a copy of which is attached hereto and made a part hereof, the Defendants were required to make prompt and regular payments. 5. The Defendants are in default under the terms of the Agreement for failure to make monthly payments as they become due and owing and in accordance with the terms of the said Agreement are obligated to pay attorney's fees incurred in collection proceedings. The following amounts are due: Principal + $ 6,842.00 Interest @ 18% per annum to 6/24/09 + $ 1,026.30 Attorney's Fees + 2 596.54 TOTAL $10,464.84 Plus interest from 6/25/09 at $3.37 per day. WHEREFORE, Plaintiff demands Judgment against the Defendants, FLOYD ALLAMON and FLOYD ALLAMON t/a F & R Property Maintenance and/or d/b/a F & R Property Maintenance in the amount of $10,464.84 together with interest from 6/24/09 at $3.376 per day and costs of suit. MATTLEMAN, WEINROTH & MILLER, P.C. Date: March 29, 2010 BY: Our File Number 00-75617-0 Al-\,Jvk ison 13. Weinroth-Shaw, Esquire Attorney for Plaintiff NOTICE PURSUANT TO FAIR DEBT COLLECTIONS PRACTICES ACT This communication is from a debt collector. 2. This is an attempt to collect a debt and any information obtained will be used for that purpose. 3. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of the notice, the debt will be assumed to be a valid by other offices. 4. If you notify our offices in writing within (30) days of the receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such certification or Judgment will be mailed to you by our office. ' states that he/ she is the for * ELLOW BOOK SALES & DISTRIBUTION COMPANY, INC. P intiff erein; that hefsWs acquainted with the facts set forth in the foregoing Complaint; that the same are true and correct to the best of his/hw knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa.C.A. section 4904 relating to unswom falsification to authorities. F F w PI i No M mom { - - --- - ------ ------ ------ ---- ' w i s f i 01 al ?? £1 t LL o y?ts W N V ---- ----- - - -- I W N ? o o Y _ 11 _ ------ - ---- - ------ - ------ -. ._ . -- _. LY L _ ? ? yy s J r ? ? J h T _ }gill r• 31 1 V :5 tl al u (r C? 73 Egli z 0 L G U c '' LL S e +1 t t Gt Q c G ., ^C u L $I 0 L 0 ? c C 1 Cl 0 C r ? s 'IA ? u v ° El i 1p - ? . IRwM p a Q 0 a ? o Sapp •. amum Zan= u 14 Im 4j X Q ? fN a ?+ ii T- F x` tIL C 'tt 1 c' S dx 1-1 47'0-t Landscape Maintenance rtilization Control t 001 e 66" . il?•d ,?s°?.ctd,?? s all I&VO jnj-C pla.14 Plants and flowers tit >'?'KJ tl Pot Servicing East & West Shores I s sxx 814E 5Ht v 41 NINE t v INS X _ `7 An 1 HIM 347 A g QUA ?- -xi 71 a - 5 y ,? v A is HOOT SAY 41 2 E __ Z; j 79 VIA fit Hi S L y 101 J t. ?S t ^ L _ _ rx G? _ °3f zy -251= xP:J? ? p•? S?? ? ?a 72 -all a 0192 Kj SAME! Yk scz t????? x 2 u r k m _?'? 1. u%Zt }, ?e lot Awn c- G .,5 A •"• z v 5 v N =Z 4 C v t nog its! 3 C K yZ 4 5 ..LU? z??'YL ,.fix < Q Q't < sn ,t ?<z<k- ,-- c =.c s Hui 2F. o: ll 3 ti log -5 a H 4z? 3"- _ _ ?G'?ggR E 3'ff b i t v ' M x cc vi w" -M jr 4 2 6 ? ? - ? ? ? oa ? c y ? a?? ? ?,,;. ,? c ? C -? 'rte E •C ? = ?` x g 12 g's t yam,..- ? ? HIM 1 Pi- AW t ? ?' 't2.? tK r ? i Z.c ec $ > oD.?-? 5... - y _ .71 4 40 W tin K, N _ _ v _ s x mitt wi no = A ? ". _ SOUR FILE NO. 00-75617-0 Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.639o Fx:717.240.6397 Plaintiff/s: YELLOW BOOK SALES & DISTRIBUTION COMPANY, INC. Defendant/s: Serve Upon: Court Number: Expiration Date: Type of Action: CIVIL ACTION COMPLAINT FLOYD ALLAMON, individually; and FLOYD ALLAMON t/a F & R Property Maintenance and/or d/b/a F&R Property Maintenance FLOYD ALLAMON Address for Service: 329 BAHAMA CIRCLE, LEIBY'S PARKWAY CARLISLE. State PA 17015 Alternate Address for for Service: ?- State AR Type of Service: r' Adult in Charge rX' Personal Deputize (- Certified Mail Posting **Copy of Court Order Required with Posting** Special Service Instructions: *If service is to be made by deputized service to another county please specify which county* Filing Attorney: Name: ALISON B. WEINROTH-SHAW, ESQUIRE Address: MATTLEMAN, WEINROTH & MILLER, P.C. / SUITE 2226, LAND TITLE BUILDING BROAD & CHESTNUT STREETS, PHILADE6 State PA 0 19110 Phone Number: +1 (215) 923-2225 OUR FILE NO. 75617-01 Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.639o Fx:717.240.6397 Plaintiff/s: Court Number: YELLOW BOOK SALES & DISTRIBUTION Expiration Date: COMPANY, INC. Type of Action: CIVIL ACTION COMPLAINT Defendant/s: FLOYD ALLAMON t/a F & R Property Maintenance and/or d/b/a F&R Property Maintenance and FLOYD ALLAMON, individually Serve Upon: FLOYD ALLAMON t/a F & R Property Maintenance and/or d/b/a F&R Property Maintenance Address for Service: 329 BAHAMA CIRCLE, LEIBY'S PARKWAY CARLISLE State PA 17015 Alternate Address for for Service: ?- State JAType of Service: FX' Adult in Charge FX" Personal F- Deputize F-' Certified Mail F- Posting **Copy of Court Order Required with Posting** Special Service Instructions: *If service is to be made by deputized service to another county please specify which county* Filing Attorney: Name: ALISON B. WEINROTH-SHAW, ESQUIRE ....._._......... __....___._....., Address: MATTLEMAN, WE1IN1ROTH & MILLER, P.C. /S .. UIT I E 2226, LAND TITLE BUILDING 11 11 BROAD & CHESTNUT STREETS, PHILADE6' State PA 19110 Phone Number: +1 (215) 923-2225 14YATTLEMAN, WEINROTH & MILLER, P.C. By: Alison B. Weinroth-Shaw, Esquire Land Title Building, Suite 2226 .r TH" n 'ARY Broad & Chestnut Streets Philadelphia, PA 19110 2010 APR 29 An 29 (215) 923-2225 Our File No.: 00-75617-0 r YELLOW BOOK SALES & DISTRIBUTION COURT OF COMMON PLEAS COMPANY, INC. ; CUMBERLAND COUNTY Plaintiff(s), Case Number: /D vs. FLOYD ALLAMON, individually; and FLOYD ALLAMON t/a F & R Property Maintenance and/or d/b/a F & R Property Maintenance Defendant(s). ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as counsel for the Plaintiff, YELLOW BOOK SALES & DISTRIBUTION COMPANY, INC.. MATTLEMAN, WEINROTH & MILLER, P.C. Date: March 29. 2010 By: Aliso B. Weinroth-Shaw, Esquire Attorney for Plaintiff .., MATTLEMAN, WEINROTH 8~ MILLER, P.C. BY: Alison B. Weinroth-Shaw, Esquire Attorney I.D. No.: 84407 Suite 2226, Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 (215) 923-2225 Attorneys for Plaintiff Our File Number: 00-75617-0 2~IQ ,~1.1~ -7 PSI ~~ ~~ f•'C,i~i4~~J~1 r`l.t~rl~l°,,t~, YELLOW BOOK SALES 8~ DISTRIBUTION COMPANY, INC. 2201 Rennasaince Boulevard King Of Prussia, PA 19406 No. Plaintiff, vs. FLOYD ALLAMON 329 Bahama Circle Leiby's Parkway Carlisle, Pennsylvania 17015 COURT OF COMMON PLEAS Cumberland County 10-2879 Civil Term FLOYD ALLAMON t/a F 8~ R Property Maintenance and/or d/b/a F 8~ R Property Maintenance 329 Bahama Circle Leiby's Parkway Carlisle, Pennsylvania 17015 Defendant(s). STIPULATION FOR JUDGMENT AND PAYMENTS WHEREAS, Plaintiff, YELLOW BOOK SALES & DISTRIBUTION COMPANY, INC., instituted the present action against the Defendant(s), FLOYD ALLAMON and FLOYD ALLAMON t/a F 8~ R Property Maintenance and/or d/b/a F 8~ R Property Maintenance, for payment of monies due and owing under the terms of an agreement. WHEREAS, the parties have agreed to amicably settle the matter. NOW, THEREFORE, intending to be legally bound, the parties hereby stipulate as follows: The Defendant(s), FLOYD ALLAMON and FLOYD ALLAMON t/a F ~ R Property Maintenance and/or d/b/a F ~ R Property Maintenance, agree(s) that the Clerk of _ _ _ _ 7 Court or Prothonotary is directed to enter Judgment against them in the sum of c!~ sa~~,v $10,464.84 plus additional interest of $1,108.73 plus court costs of $141.84 for a total ~-a3y.~~ ~,`,1 ` tt of $11,715.41. "" This is an attempt to collect a debt and any information obtained will be used for that purpose.'* 2. Payment of the aforementioned sum shall be as follows: a. Beginning 5/24/10, Defendant(s),FLOYD ALLAMON and FLOYD ALLAMON tla F ~ R Property Maintenance and/or d/b/a F 8~ R Property Maintenance, shall pay the sum of $500.00 per month to the Plaintiffs counsel and shall continue to make payments on the 24th of each month thereafter until the entire judgment has been paid in full. All monthly payments shall be due and owing on or before the 24th of each month. b. The parties also acknowledge that no payments have been received by the plaintiffs counsel prior to the execution of this agreement. c. All payments shall be made payable to the Plaintiff, YELLOW BOOK SALES 8~ DISTRIBUTION COMPANY, INC., and forwarded to Plaintiffs attorney at: MATTLEMAN, WEINROTH & MILLER, P.C. 401 Route 70 East, Suite 100 Cherry Hill, New Jersey 08034 Attention: Alison B. Weinroth-Shaw d. If any one (1) payment is more than five (5) days late, Defendants shall be in default under the terms of this Agreement. In such case, Plaintiff shall move EX PARTE for Post Judgment remedies for the balance remaining, plus all costs, attorney's fees and accrued Post Judgment interest, having given credit for any payments made. e. The acceptance by Plaintiff of any late payment(s) tendered by the Defendants, FLOYD ALLAMON and FLOYD ALLAMON t/a F 8~ R Property Maintenance and/or d/b/a F ~ R Property Maintenance shall not act as a waiver of Plaintiffs right as set forth hereunder. ** This is an attempt to collect a debt and any information obtained will be used for that purpose.** 3. The Agreement set forth herein is the entire Agreement by and between the parties. Any modification of said Agreement must be made in writing and must be filed with the Honorable Court. FLOYD ALLAMON, Defendant Dated: S~3S jb MATTLEMAN, WEINROTH & MILLER, P.C. Alison . Weinroth-Shaw, Esquire Attorney for Plaintiff ~~L~-- FLO D ALLAMON t/a F ~ R Property Maintenance and/or d/b/a F~ R Property Maintenance, signed by Defendant Dated: S~1S~ l o * This is an attempt to collect a debt and any information obtained will be used for that purpose.** Request for Military Status Page 1 of 2 Department of Defense Manpower Data Center Jun-03-2010 12:01:58 Military Status Report Pursuant to the Service Members Civil Relief Act Last FirstlMiddle Begin Date Active Duty Active Duty End Service Name Status Date Agency ALLAMON FLOYD Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). ~~. ~,-~ Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink mil/faq/pis/PC09SLDR html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service https://www.dmdc.osd.mil/appj/scra/popreport.do 6/3/2010 Request for Military Status SCRA points-of-contact. Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:2KAEVAFN8D https://www.dmdc.osd.mil/appj/scra/popreport.do 6/3/2010