HomeMy WebLinkAbout01-1155ALL AMERICAN PLAZAS, INC.,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v. :NO. 01- t/3'5" -~/¢¢~
GUARANTEED OVERNIGHT
DELIVERY,
Defendant
:CIVIL TERM
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 claimed in the Complaint of 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
ALL AMERICAN PLAZAS, INC.,
Plaintiff
GUARANTEED OVERNIGHT
DELIVERY,
De~ndant
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 01-
:CIVIL TERM
COMPLAINT
1. Plaintiff, All American Plazas, Inc., is a Pennsylvania business corporation
with a registered address of P.O. Box 657, 1181 Harrisburg Pike, Carlisle, Cumberland
County, Pennsylvania, 17013.
2. Defendant, Guaranteed Overnight Delivery, has a registered address of
Ft. of Pennsylvania Avenue, South Kearney, New Jersey 07032.
3. At all times relevant hereto, Plaintiff, All American Plazas, Inc., was in the
business of providing diesel fuel and truck repairs to the Defendant and other similar
situated business.
4. In April 1994 the Defendant did apply for credit with the Plaintiff requesting
the ability to buy fuel and services on credit and agreed to pay for the same upon
receipt of invoices; Plaintiff granted Defendant's credit application.
5. On or about September 2000 and continuing through October 2000, the
Defendant did purchase fuel and services from the Plaintiff, in the amount of $8,039.03.
6. Despite repeated demand, the above sum has remained unpaid as of the
date of this Complaint.
7. In addition to the principal amount of $8.039.03, the Defendant has agreed
to terms which include a service charge of 1 ¼ percent per month for the average daily
past due balance.
8. The Defendant also agreed to pay all costs, expenses, including attorney
fees and court costs that may be encountered by the Plaintiff.
9. A copy of the current invoice, which remains unpaid, is attached hereto
and marked Exhibit A.
WHEREFORE, for all the above reasons, the Plaintiff respectfully requests
judgment in its favor in the amount of $8,039.03 plus interest, costs of suit, attorney fees
and expenses.
Date
Respectfully Submitted
TURO LAW OFFICES
Ron Turo, Esquire
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
VERIFICATION
I, Ron Turo, Esquire, attorney for the Plaintiff herein, have sufficient knowledge of
the facts contained in this Complaint and verify that the statements made in the
foregoing Complaint are true and correct to the best of my knowledge, based upon
information received from the Plaintiff. I understand that false statements herein made
are subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to
authorities. A verification executed by the Plaintiff will be filed of record as soon as it
becomes available.
Date Ron Turo, Esquire
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Complaint upon
Guaranteed Overnight Delivery, by depositing same in the United States Mail, first
class, postage pre-paid on the --~ "-~ day of ZL--~~-/-~ , 2001, from Carlisle,
Pennsylvania, addressed as follows:
Guaranteed Overnight Delivery
FT. of Pennsylvania Avenue
South Kearney, NJ 07032
TURO LAW OFFICES
Ron Turo. Esquire
28 South Pitt Street
Carlisle, PA ~7013
(717) 24§-§658
Attorney for Plaintiff