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HomeMy WebLinkAbout10-6636MICHAEL L. BANGS, ESQUIRE I.D. #41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF HMPT BROS., INC. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT W. BAKER, JR., d/b/a ROBERT BAKER JR. CONSTRUCTION, ROBERT W. BAKER, JR. and JEANETTE BAKER, his wife Defendants NO. 2010 - ?oI?31o (2io perm CIVIL ACTION - LAW 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP . C) MW Cumberland County Bar Association M ? c, - --n r- 32 South Bedford Street s --rj? Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166° -? U $9a. W PA A-rr-y c-0 q47g P-* aq98'w MICHAEL L. BANGS, ESQUIRE I.D. #41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF HEMPT BROS., INC. vs. Plaintiff ROBERT W. BAKER, JR., d/b/a ROBERT BAKER JR. CONSTRUCTION, ROBERT W. BAKER, JR. and JEANETTE BAKER, his wife Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010 CIVIL ACTION - LAW COMPLAINT AND NOW comes the Plaintiff, Hempt Bros., Inc., by and through its counsel, Michael L. Bangs, Esquire, and files this Complaint based upon the following: 1. Plaintiff, Hempt Bros., Inc., is a Pennsylvania corporation with its principal place of business at 205 Creek Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant Robert W. Baker, Jr., is an adult individual who trades or does business under Robert Baker Jr. Construction and who resides at 551 Le Sentier Lane, Harrisburg, Dauphin County, Pennsylvania, 17112. 3. Defendant Jeanette Baker is an adult individual who resides at 551 Le Sentier Lane, Harrisburg, Dauphin County, Pennsylvania, 17112. 4. Plaintiff is in the business of, among other things, supplying certain building materials including crushed stone, sand, gravel, concrete and asphalt. 5. Defendant Robert W. Baker, Jr. opened up a credit account under the name of Robert Baker Jr. Construction whereby Defendant Robert W. Baker, Jr. agreed to pay the prices for the materials delivered to Defendant Robert Baker Jr. Construction under the terms and conditions of the credit account. 6. Defendant Robert W. Baker, Jr. and his wife, Defendant Jeanette Baker, signed a certain personal guarantee so as to induce Plaintiff to provide materials under the credit account. Said personal guarantee is attached hereto and marked as Exhibit A. 7. The personal guarantee provides, among other things, for the payment of all costs including, but not limited to, reasonable attorney's fees for the enforcement of the terms and conditions of the personal guarantee. 8. Plaintiff has engaged the law firm of Michael L. Bangs, Esquire, at the rate of $200.00 per hour to enforce the terms of the agreement between the parties and for the enforcement of the personal guarantee. 9. Defendant Robert W. Baker, Jr. and Defendant Jeanette Baker, pursuant to the guarantee, also agreed to pay the sum of one (I%) percent interest per month for any outstanding invoices due over thirty (30) days. COUNTI HEMPT BROS., INC., vs. ROBERT W. BAKER, Jr., d/b/a ROBERT BAKER JR. CONSTRUCTION BREACH OF CONTRACT 10. The averments of Paragraphs 1 through 9 are incorporated herein by reference as if more fully set forth herein. 11. Plaintiff, at the insistence and request of the agents, servants, or employees of Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction, acting within the scope of their employment, sold and delivered to Defendant Robert W. Baker doing business as Robert Baker Jr. Construction certain goods and materials at the times and in the amounts and 2 for the prices set forth in Plaintiffs Statement of Account which is attached hereto and marked as Exhibit B. 12. Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction accepted and received all materials ordered from Plaintiff and referenced on Exhibit B. 13. Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr., Construction has failed or refused to pay Plaintiff for the materials received by him and identified by the invoices which are reflected on Exhibit B. 14. Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction has breached the agreement with Plaintiff by his failure to pay for the materials received pursuant to the terms and conditions of the credit account. 15. Plaintiff has been damaged in the amount of $27,472.79 as a result of Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction's failure to pay for all outstanding invoices in accordance with the agreement between Plaintiff and Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr., Construction. 16. Plaintiff is also entitled to receive interest at the rate of one (1 %) percent per month for all invoices due over thirty (30) days as a result of Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction's failure to pay for the materials received in accordance with the credit account established by Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction in the amount of $27,472.79, plus interest at the rate of one (I%) percent per month for all outstanding invoices due over thirty (30) days, to be calculated until the time of judgment in this case. This amount requires mandatory arbitration. COUNT II HEMPT BROS., INC., vs. ROBERT BAKER, JR., d/b/a ROBERT BAKER JR. CONSTRUCTION UNJUST ENRICHMENT 17. The averments of Paragraphs 1 through 16 are incorporated herein by reference as if more fully set forth herein. 18. The prices charged for said goods and materials are just and reasonable and are the prices which the agents, servants, and employees of Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction, acting within the scope of their employment, orally promised to pay Plaintiff for those goods and materials. 19. Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction has failed or refused to pay for the goods and materials received by it despite repeated demands by Plaintiff. 20. Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction, has been unjustly enriched at Plaintiff's expense by its failure to pay for the goods and materials it received in the amount of $27,472.79, plus interest at the rate of one (1 %) percent per month for all invoices due over thirty (30) days, as a result of its acceptance of the goods and materials delivered by Plaintiff and used by Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction. WHEREFORE, Plaintiff demands judgment against Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction, in the amount of $27,472.79, together with interest at the rate of one (I%) percent per month for all invoices due over thirty (30) days, to be calculated until the time of judgment in this case. This amount requires mandatory arbitration. 4 COUNT III HEMPT BROS., INC., vs. ROBERT W. BAKER, JR. and JEANETTE BAKER ACTION ON PERSONAL GUARANTEE 21. The averments of Paragraphs 1 through 20 are incorporated herein by reference as if more fully set forth herein. 22. Defendants Robert W. Baker, Jr. and Jeanette Baker, pursuant to Exhibit A, personally guaranteed the amounts due and owing to Plaintiff, on a joint and several basis, for the materials received by Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction. 23. Plaintiff is owed the amount of $27,472.79 as a result of the failure of Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction to pay all outstanding invoices in accordance with the terms of the credit account agreement between Plaintiff and Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction, and as such, the guarantors, Defendants Robert W. Baker, Jr. and Jeanette Baker, are personally liable, joint and severally liable, for said payment to Plaintiff. 24. Plaintiff is also entitled to receive interest at the rate of one (1%) percent per month for all invoices due over thirty (30) days as a result of the failure to pay for the outstanding invoices and pursuant to the terms of the guarantee. 25. Defendants Robert W. Baker, Jr. and Jeanette Baker are also responsible for all costs and expenses, including, but not limited to, reasonable attorney°s fees and costs which are incurred by Plaintiff in the enforcement of the personal guarantee and in the enforcement of the terms and conditions of the credit account between Plaintiff and Defendant Robert W. Baker, Jr., doing business as Robert Baker Jr. Construction. 5 WHEREFORE, Plaintiff demands judgment against Defendants Robert W. Baker, Jr. and Jeanette Baker, joint and severally, in the amount of $27,472.79, plus interest at the rate of one (1%) percent per month for all invoices due over thirty (30) days, to be calculated until the time of judgment in this case, plus reasonable attorney's fees and costs of suit. This amount requires mandatory arbitration. Respectfully submitted, MICHAEL L. BANGS Attorney for Plaintiff 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 6 VERIFICATION MAX J. HEMPT, being duly sworn according to law, deposes and says that he is the President of HEMPT BROS., INC., a Pennsylvania corporation, the Plaintiff herein, and that as such President, he is authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief, and further understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. HEMPT BROS., INC. BY: MAX J. HEMPT, President 7 EXHIBIT A EXHIBIT B N N tto fn CO N N CA ?NN (A (OA N j U1 N fA N i (A t`??b fn 7 ? ` ppS? co ?S co Qj 14 ? ? W 0 pop pp?op a Cn U I ? O O fD 41 A '< < << < < < < m m m m m m zz zZ Z Z Z Z Z? Rio ? i? F a 3t3 63 m £d f a 3£ m ? m i3 m S 0 0 0 0 0 0 0 0 0 l ?. v i v i c n CD ?° W IL m ?i w m w I R N m m N Q?L R cn m V) i 0 a ai ?n a V) m m N N N R A ?-R ? S :2 8 8 Q1 8 00 m m 00 m m 0 o?i 0 o?i 0 w 0 w 0 m w o 7m7 Imo w w X 7 mp w M w w M w -:0 o A z z < < Z < Z < Z < Z Z < C Z C Z < Z < ZZ C ZZ C Z < Z < cp tt ?P O o pp 0/ p O o? (O p , 1 N N? N I? pp 0077 01 ??pp N t0 S S O w ? p? O OOff N N N N N N N N N N N N N N ??pp ??pp N N N N N D 'T' ( ? m M MmrnA MM ;a r i . M z x'00 to ED m 070000 co m m I 0 00000 00000 0 70A 000 l < u mmm ?z? 4 m mmlTim ;a 4 M m m m m m r?rir?'rrmmm ;a; w m m m m mmmmm 0;U? m m m m mmmm C C D ? - mmm -i i -i -I mmmmm m -i -1 -I -i -i -I - -? ?A -? -I m CO ) 888 z z z C3 n 00 80000 z z z z z 0 0 z 00088 000 88000 000 0 0 008 00 < -mi-cn i?misn tn z Z z z zl cnv??ntn?n Z z z z z tnmrnmw z m z z z m?nm m ? O C C O ? ? fQ? ? 0 0 0 .?. i 0 0 i 4 0 ? 0 0 0 _ i x -' ? 0 0 -? 0 O i 0 0 0 O 0 O 0 O 0 0 O 0 O 0 O 0 N r W 0 0 0 W 0 0 ?QT 0 F3 o O I 1 \ nn \ + ?p -a N t N J g ? i 2 J 2 j 2 i 2 N - m 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 4 0 0 0 0 i 0 0 - 0 . J 0 0 J 0 0 i 0 6 0 0 7 1 N W N A rn to N W -+ Uv i OD A tD N W ON -` G N : V ? P p p? i? W N i V m A W 01 V N 0 S -- W S O -V ??,,11 _A T W y _ f V w p Q> Ot Vj T Ch w A W W V W W v i N .6 N 0 V cp0 O I i T I ? p? [7? ?f t(?j N ? ?Np 1V CA) t0 pi OOf N tAp .4 C OVf D W 0) , W p N m W ? O i C4 ( V i A V . W S 9 A A SHERIFF'S OFFICE OF CUMBERLAND COUNTY' Ronny R Anderson Sheriff t?ttr a4 ?tttbbr?? = W Lit Jody S Smith ??? ?4? C + Chief Deputy z Richard W Stewart Solicitor OFFICEOF'-E S"ERIRF -- `_ ' Hempt Bros. Inc. Case N umber vs. 2010-6636 Robert W. Baker, Jr. (et al.) SHERIFF'S RETURN OF SERVICE 10120/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Robert W. Baker Jr., but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 10/20/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Robert W. Baker Jr. d/b/a Robert Bakerjr. Construction, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 10/20/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Jeanette Baker, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 10/2712010 10:34 AM - Dauphin County Return: And now October 27, 2010 at 1034 hours 1, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeanette Baker by making known unto herself personally, at 551 Lesentier Lane, Harrisburg, PA 17112 its contents and at the same time handinc to her personally the said true and correct copy of the same. 10/27/2010 10:34 AM - Dauphin County Return: And now October 27, 2010 at 1034 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert W. Baker Jr. by making known unto Jeanette Baker, Wife of defendant at 551 Lesentier Lane, Harrisburg, PA 17112 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/27/2010 10:34 AM - Dauphin County Return: And now October 27, 2010 at 1034 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Robert W. Baker Jr. d/b/a Robert Baker Jr. Construction by making known unto Jeanette Baker, Wife of defendant at 551 Lesentier Lane, Harrisburg, PA 17112 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $69.00 November 09, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF !c Count}Suite Shenft. Teieosott inc. (911iz.e of #tEe c***xiff William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin HEMPT BROS INC. JEANETTE BAKER Sheriff s Return No. 2010-T-3275 OTHER COUNTY NO. 20106636 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy VS And now: OCTOBER 27, 2010 at 10:34:00 AM served the within NOTICE & COMPLAINT upon ROBERT W BAKER, JR by personally handing to JEANETTE BAKER 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 551 LESENTIER LANE HARRISBURG PA 17112 SPOUSE Sworn and subscribed to before me this 28TH day of October, 2010 *'?*z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Answers, Sheriff of D?abhini C By Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $87.75 10/22/2010 #fir eoaf Ott: csl?eri ? ff William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin HEMPT BROS INC. JEANETTE BAKER Sheriff s Return No. 2010-T-3275 OTHER COUNTY NO. 20106636 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy VS And now: OCTOBER 27, 2010 at 10:34:00 AM served the within NOTICE & COMPLAINT upon ROBERT W BAKER, JR by personally handing to JEANETTE BAKER I true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 551 LESENTIER LANE HARRISBURG PA 17112 SPOUSE Sworn and subscribed to before me this 28TH day of October, 2010 *")P*Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17 2014 So Answers, ? k? e';? Sheriff of D By Deputy Sheriff Deputy: W CONWAY Sheriff s Costs: $87.75 10/22/2010 'r 10 ? (qtlitt Of thjV'*4vSrr'rf William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin HEMPT BROS INC. JEANETTE BAKER Sheriff s Return No. 2010-T-3275 OTHER COUNTY NO. 20106636 ? 1?7 lAnd now: OCTOBER 27, 2010 at 10:34:00 AM served the within NOTICE & COMPLAINT upon So Answers, JEANETTE BAKER by personally handing to JEANETTE BAKER 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 551 LESENTIER LANE HARRISBURG PA 17112 Sworn and subscribed to before me this 28TH day of October, 2010 0??*z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17 2014 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy VS Deputy: W CONWAY Sheriffs Costs: $87.75 10/22/2010 MICHAEL L. BANGS, ESQUIRE I.D. NO. 41263 429 SOUTH 18" STREET CAMP HILL, PA 17011 ATTORNEY FOR PLAINTIFF Q HEMPT BROS., INC. Plaintiff VS. ROBERT W. BAKER, JR., d/b/a ROBERT BAKER, JR. CONSTRUCTION, ROBERT W. BAKER, JR., and JEANETTE BAKER, his wife Defendants IN THE COURT OF COM PIMAS5..n OF CUMBERLAND CO - 3 rnc. PENNSYLVANIA E C 4 N0.2010-6636 CIVIL CQ - a ?- nn v c ? =Z5 CIVIL ACTION - LAW 5? TO: ROBERT W. BAKER,•JR., d/b/a ROBERT BAKER JR. CONSTRUCTION DATE OF NOTICE: November 23, 2010 IMPORTANT NOTICE Required by Rule 237.1(a)(2) 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR'TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 A , flA ju if. 0, EL L. BANGS Attorney for Plaintiff MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF I.D. NO. 41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 HEMPT BROS., INC. ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) NO. 2010-6636 CIVIL ROBERT W. BAKER, JR., d/b/a ) ROBERT BAKER, JR. CONSTRUCTION,) CIVIL ACTION - LAW ROBERT W. BAKER, JR., and ) JEANETTE BAKER, his wife ) ( o Defendants MCD zern - TO: ROBERT W. BAKER, JR. ? © ?n ?© -4C; DATE OF NOTICE: November 23, 2010 ? Z e ' IMPORTANT NOTICE ._ Required by Rule 237.1(a)(2) A cf 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 TAKL THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAY140T AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO F;:ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 I ka a ?. X? .4 - 4LM L. BANGS Attorney for Plaintiff MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF I.D. NO. 41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 HEMPT BROS., INC. ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) NO. 2010-6636 CIVIL ROBERT W. BAKER, JR., d/b/a ) ROBERT BAKER, JR. CONSTRUCTION,) CIVIL ACTION - LAW ROBERT W. BAKER, JR., and ) C-) C) JEANETTE BAKER, his wife ) Defendants o rn- TO: JEANETTE BAKER C"' © Ern =° DATE OF NOTICE: Novemb--r 23, 2010 :°=3 a off? IMPORTANT NOTICE ` Required by Rule 237.1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILS 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING-OFFICE TOFIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 It L_ LIAO CHAEL L. BANG :, . Attorney for Plaintiff MICHAEL L. BANGS, ESQUIRE I.D. No. 41263 429 Sou h 18'h Street Camp Hill, PA 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF BROS., INC. Plaintiff S. ROBE W. BAKER, JR., d/b/a ROBE BAKER JR. CONSTRUCTION, ROBE W. BAKER, JR., and JEANE TE BAKER, his wife, Defendants TO PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-6636 CIVIL CIVIL ACTION - LAW PRAECIPE N) .C >c , .. mark the above matter settled and discontinued. submitted, i MICHAEL L. BANGS Attorney for Plaintiff 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 Date: April 20, 2011