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HomeMy WebLinkAbout10-6325SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFFICE OF THE ?ERiFF Vif,,tr)YAc + 2010 l3~7 }i? e ?' ... cUI' BE.R'L . C3 Ct t; ' ` `t` rs? ,?l sl?,c91!? Jody S Smith Chief Deputy Richard W Stewart Solicitor Presstek/ Abdick vs. Cumberland Printing Co. Case Number 2010-6325 SHERIFF'S RETURN OF SERVICE 10/07/2010 03:35 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on October 7, 2010 at 1535 hours, he served a true copy of the within Complaint and No' e, upon the within named defendant, to wit: Cumberland Printing Co., by making known unto Wayde S gler, Press Operator for Cumberland Printing Co. at 4 W. Allen Street, Mechanicsb , Cumbe d County, Pennsylvania 17055 its contents and at the same time handing to him feally p{?jetaid true and correct copy of the same. r ' ,DEPUTY SHERIFF COST: $37.00 October 08, 2010 SO ANSWERS, 1?z xoo??'2' RON R ANDERSON, SHERIFF (c) CouniySuite Sheriff. TTe.eosoft Inc ~i~~~-~~~f~l~ Craig A. Diehl, Esquire ~ ~° , „ , ^ ~ I.D. No. 52801 ita ~ ~ i'-. t, r~ - ~ ~!~ .~~ ~ LAW OFFICES OF CRAIG A. DIEHL 3464 Trindle Road °y ~ ~ ~' ~ k ~ _ r; ~'< ~ ~` (~~! U i j ~' C jS!'^a ern z Camp Hill, PA 17011 ~_P.,~`~ (~.~,~,ES{~ Attorney for Defendant, Minent, LTD PRESSTEK, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-6325 -Civil Term MINENT LTD a/k/a MINNICH LTD t/a CUMBERLAND PRINTING COMPANY, Defendant CIVIL ACTION -LAW ANSWER TO COMPLAINT AND NOW COMES Defendants, Minent, Ltd. and Cumberland Printing Company, by and through their counsel, Law Offices of Craig A. Diehl, answering the Complaint as follows: 1. Denied. The averment contains the name ABDick Presstek which is different from the Plaintiff named in the caption, Presstek, Inc. 2. Denied. The Defendants are Minent, Ltd. and Cumberland Printing Company. 3. Admitted. 4. Denied. Defendants received a bad roll of plate material (Mega Pro) and is being billed erroneously for said product. Defendants are also disputing the service agreement charges. The printing press was never repaired properly and Plaintiff or its predecessor never issued certain credits it had promised to Defendants. Additionally, Defendants were to receive credits from ABDick for a bad press, press #9995 A. 5. Denied. Certain credits were to be provided to Defendants which did not occur. Defendants are also being billed for a faulty roll of Mega Pro. 6. Denied. Defendants orally discussed the noted deficiencies with representatives of ABDick. 7. Admitted. 8. Denied. Defendants are unaware of any contract or terms entitling Plaintiff to pre judgment interest at 6% per annum. WHEREFORE, Defendants respectfully request this Honorable court to determine the accurate amount owed by Defendants to Plaintiff. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date: By: ~ Craig A. iehl, Esquire Attorney I.D. No. 52801 3464 Trindle Road Camp Hill, PA 17011 Tel: (717) 763-7613 Fax: (717) 763-8293 Attorney for Defendants VERIFICATION I, Scott Minnich, President of Minent, Ltd. t/a Cumberland Printing Company, Plaintiff above-named, being duly sworn according to law, deposes that the facts set forth in the foregoing Answer to Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: ~~ 02 7 d2 ~/ a ~~~ Scott Minnich, President Minent, Ltd. t/a Cumberland Printing Company CERTIFICATE OF SERVICE AND NOW, the ~ 7~ day of October, 2010, the undersigned hereby certifies that a true and correct copy of the foregoing Answer to Complaint was served upon the opposing party by way of United States first class mail, postage prepaid, addressed as follows: Derek C. Blasker, Esquire Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Debra A. Fike, Legal Secretary v mQ tAF' i a ft ?Ii ! APR 25 PM 2* ri"UMBERLAND COUNT"PENNSYLVANIA Burton eil & Associates, P.C. By: De ek C. Blasker, Esquire ID. NO. 202150 1060 A drew Drive, Suite 170 West C ester, PA 19380 610-69 -2120 Attorne for Plaintiff PRES t/a ,EK/ABDICK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-6325 CIVIL TERM T LTD akd MINNICH LTD BERLAND PRINTING CO Defendant : CIVIL ACTION - LAW Praecipe to Discontinue To the I discontinue the above-captioned action withkt? prejudice. BurtoM8ft Associates, P.C. By: lasker, Esquire T Plaintiff The law of Burton Neil & Associates is a debt collector. 125083