HomeMy WebLinkAbout02-0078CC,.u _~_ ~I~fEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. ~c~
NOTICE OF APPEAL
Notice is givefl that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice o~ the
date and in the case mentioned below.
LINDGREN CHRYSLER f/k/a
ADO~SS Of A~U~NT
09--3--04
Reading PA 19607
1600 Lancaster Avenue
..... · ,~,-r,~,~ ~h~v~ler-PlvmouLn~ Inc.
, /hi I c~F~fey Auto ~pply, Inc.
CV~ 0000~6-01
.... / ~~' ~ ~~~r~ '- No.
U lY / ~L--' ---
Thk ~ck will ~ ~ ONLY ~n ~is ~ is mqulred u~ P~ R.C~J~. ~ If a~ll~t ~ CLAIMANT (s~ ~. R.C.P.J.P.
1~8E 1001 (6) in ~ti~ ~f~ District J~tice, he MUST
~is ~e o~ A~eaJ, w~ ~ ~ t~ District Justice, will
~PERSEDEAS ~ t~ j~ ~ ~s~ in ~is cas~ FILE A COMPLAINT within twenty (20) da~ after
filing h~ NOTICE of APPEAL.
S~atu~ of ~t~o~y ~
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotmry
Enter rule upon C..~'~'~ AUTO SUPPLYI INC. , appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleos Ncx ~' 7~' ~/~ ) within twenty (20' dc~s afler.~ict°f r~/~-~_ ~ °f 'udg--' °f n°fl Pr°S'
- /~ ggna~e of appe~a~ or h~s a~omey or a~,
CArFRE¥ ~UTO SUPPT.¥, TN¢. , =ppellee{s).
RULEr To
~ of apse;eels)
(J) Yoo =re ~oti~d t'n=t = rule ~s hereby entered upon you to file = co~i~t in th~s op~e~l wi~in twe~'y (201 doys c6ter ~e date of
~ervice of this role upon you by personal service o~ by cer~fied or registered moil.
(2) If you do not fib ~ complaint within this time, ~ .IU~ENT O~ NON PROS WILL 6E ENTERED AGAINST YOU.
(3) The d~e of service of this ru~e if ~ervice w~s by moil is the d=te of meilln~
DGte: ~/
COURT FILE TO BE FILED WITH PROTHONOTARY
AOPC 312-90
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTER ,filing the notice of appeal, Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF_
AFFIDAVIT: I hereby swear or affirm that t served
[] a copy of the Notice of Appeal, Common Pleas No. _, upon the~District Justice designated therein on
(date of service) , [] by personal service [] by (certified) (registered) mail, sender's
receipt attached hereto, and upon the appellee, (name)
, on
,19... [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto.
[] and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s} to whom
the Rule was addressed on _, 19_ , [] by personal service [] by (certified) (registered)
mail, sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF , 19
Sifnature of officlai before who~r~ affidavit was rr~eda
Signature of affiant
My commission expires on
· COMMONWEALTH OF PENNSYLVANIA
;OUNTY OF: COMB~
M,,. Dist. No.: 09 - 3 ' 04
DJ Name: Hon.
THOMAS A. PLACEY
A~ess: 104 S. SPOHTING HILL P.D.
MECHANICSBURG, PA
Telepho.e: (717) 761- 8230 17050
LINDGREN CHRYSLEK' PLYMOUTH, INC-
1600 LANCASTER AVE.
p~.ADT_/~G, PA 19607
NOTICE OF jUDGMENT/TRANSCRIPT
CIVIL CASE
pLAINTiFF: NAME and ADDRESS --~
~CAFFREY AUTO SUPPLY, INC.
110 S. SpoHTING HILL RD.
MECHANICSBU~G, PA 17050
L. VS.
DEFENDANT: NAME a~d ADDRESS
~LIRDG~ CIIKYSLEK' pLYMOOTH, INC. -]
1600 LANCASTER AVE.
READING, PA 19607
IDocket No.:
Date Filed:
THIs IS TO NOTIFY YOU THAT:
Judgment:
~ Judgment was entered for: (Name)
~ jUdgment was entered against: (Name)
in the amount of $ _ ~ .- q ~; ~ ' '/'7 on: (Date of Judgment) ~ 1 ~/1 '~/nl
~ Defendants are ioint[y and severally liable. (Date & Time) _
- ~-Amount of Judgment ~ 2 898.7~
[ ~ Damages will be assessed on: judgment Costs $_ 67.0~
....... Interest on Judgment $ .0
L
~ This case dismissed without prejudice. A~orney Fees [' 2 9 65.7~
To~l
~ Amount of Judgment Subject to Post Judgment Credits
A~achmenFAct 5 of 1996 $_ Post Judgment Costs
~ Levy is stayed for_ . days or
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS A~ER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PRO~ONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
~ceedings containing the judgment.
My commission expires first Monday of Janu~W, 200~
AOPC 315-99
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DA YS AFTER filing the notice of appeal, Check applicable boxes
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF-.--~u~ ; ss
AFFIDAVIT: I hereby swear or affirm that I served
~-~ a copy of the Notice of Appeal ~ Pleas No. 02-78 upon theiDistrict Justice des gnated therein on
(date of service) .~~.~,~_~J~Q~. , [_-_,' by personal service ~J by (certified) (registered) mail, sender's
receipt attached hereto, and upon trl~ appellee, (name) .Caffrey Auto Supply, TZLC · , on
__,.T~%[tuar.~__~ , ~) 02 ._ ~ by personal service [] by (certified) (registered) mail, sender's receipt attached hereto.
[] and further that I Served the Rule to File a Complgint accompany ng the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed oil January ~,~ , ~0J:).2~ ~ by personal service~] by (certified) (registered)
mail, sender's receipt attached hereto, ~ ~
SWORN__c_I^FF . ED} .¢
Signature of affiant
CAFFREY AUTO SUPPLY, INC.,
Plaintiff
L1NDGREN CHRYSLER-PLYMOUTH,
INC.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-78
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 claim or relief requested by the Plaintiff. You may lose money or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
4TH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
TELEPHONE: (717) 240-6200
CAFFREY AUTO SUPPLY, 1NC.,
Plaintiff
LINDGREN CHRYSLER-PLYMOUTH,
INC.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-78
CIVIL ACTION - LAW
COMPLAINT
AND NOW, comes the Plaintiff, Caffrey Auto Supply, Inc., by and through its
attorneys, Butler Law Firm, and files this Complaint against Defendant, Lindgren Chrysler-
Plymouth, Inc., and in support thereof avers the following:
1. The Plaintiff, Caffrey Auto Supply, Inc., is a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania with its principal place of business located
at 110 South Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant, Lindgren Chrysler-Plymouth, Inc., is a corporation organized
and existing under the laws of the Commonwealth of Pennsylvania with its principal place of
business located at 1600 Lancaster Avenue, Reading, Pennsylvania 19607.
3. On or about June 10, 1996, Plaintiff and Defendant entered into an agreement
whereby Defendant accepted various equipment and materials from Plaintiff. A true and correct
copy of said consignment agreement is attached hereto and made a part hereof as Exhibit "A".
4. The parties agreement was such that as long as Defendant continued to order
replacement supplies from Plaintiff, Defendant would be charged only for said supplies and not
for the original equipment and materials supplied to Defendant. Further, when and if Defendant
stopped ordering additional supplies, Defendant would then be charged for all set-up supplies
and equipment.
5. Defendant continued to order and pay for replacement supplies from Plaintiff
until on or about March 5, 2001, after which time Plaintiff billed Defendant for all set-up
supplies and equipment. A true and correct copy of invoice #43747 dated March 12, 2001, is
attached hereto and made a part hereof as Exhibit "B".
6. The total amount due and owing pursuant to invoice #43747 is $2,623.32.
7. Defendant is also indebted to Plaintiff for finance charges in the amount of 1.5%
per month on all overdue invoices. The amount due for finance charges from April 12, 2001,
through January 12, 2002 is $354.15.
8. The prices Plaintiff charged Defendant for all of the aforementioned equipment
and supplies were just and reasonable and were the legal and market prices therefor.
9. The total balance due and owing by Defendant to Plaintiff for the
aforementioned equipment and materials plus the finance charges thereon is $2,977.47.
10. Plaintiffhas frequently demanded payment from Defendant of said amount due
and owing but Defendant has refused and neglected to pay said amount or any part thereof.
WHEREFORE, Plaintiff demands judgment against Defendant in the sum of
$2,977.47 plus interest and costs and all such other relief as this Honorable Court deems
appropriate.
Respectfully submitted,
BUTLER LAW FIRM
By:
Ronald D. Butler, Esquire
I.D. #09826
Jana Butler Toole, Esquire
I.D. #8O574
500 North Third Street
P.O. Box 1004
Harrisburg, PA 17108
(717) 236-1485
110 S. Sporting Hill Road
PO Box 169
Mechanicsburg, PA 17055-0169
717-761-6800
FAX 717-761-7320
I ACKNOWLEDGE THAT THE FOLLOWING EQUIPMENT IS ON LOAN FROM CAFFREY
AUTO SUPPLY, INC. THE DEALER WILL BE RESPONSIBLE FOR MAINTENANCE
OF SAME.
EQUIPMENT
GRIME BLASTER GUN
WET & DRY VACUUM CLEANER
METERING DEVICE
INDUSTRIAL STORAGE CABINET
VARIABLE SPEED BUFFER-SER#53512
CHAPIN TANK
TOWEL DISPENSER
METAL DRUM PUMP
SIGNATURE
SIGNER HAND PRINT NAME HERE
COMPANY
DATE
SERIAL #
TIC86HDG
VAC87071
CASMD2
PXXX1W944
BLD6138
CHP1370
MID203001B
BRO1800
LINDGREN CHRYSLER-PLYMOUTH
MAZDA
1600 LANCASTER AVENUE
READING, PA 19607
EXHIBIT "A"
110 S. Sp~rting Hill Road
PO Box 169
Mechanicsburg, PA 17055-0169
717-761-6800
FAX 717-761-7320
CONSIGNMENT SYSTEM
CAS55GBP02
1CAS55GBP1
1 CAS55GMCll
1 CAS5GBP7
12 SHOPll2
12 SHOTU10
6 CAS1602
2 CAS1GAPD
1CAS1GNS47
1CAS1GUW200
1CAS1GVLC
1CAS1GBP9
1CAS1GBP25
12 SHOP108
4 CASQCP
4 CASQDS
4 CASQDS2
3 CAS8CEPP
1ABS149
1 AND275
2 ANDAP1
1 PRWA
1 CST304705
1 RHOSL00
7 TOLBA
7 TOL32
1 TOLl23
3 TOLWD12
1FLT72
1FLT103
1FLT105
1 FLTll2
2 BRO219
SOLV ALL
SPRAY 1
M.C. CAR WASH
WHITE WALL CLEANER
VELOUR CLEANER
TU-10 DRESSING
BLACK SPRAY PAINT
BLUE SHINE A/P DRESSING
NYLON SPOTTER
UNIVERSAL WHEEL CLEANER
VINYL LEATHER CONDITIONER
TAR CLEANER
ODOR OUT
CLEAR VIEW GLASS CLEANER
COMPOUND
DIAMOND SHINE
DIAMOND SHIELD
CLEAR COAT PADS
ABSORBER
WASH MITT
POLISH APPLICATOR
PRO WIPES
RAZOR BLADES
STEEL WOOL
TRIGGERS
BOTTLES
3/4" FAUCET
WAX DISPENSER
WHITE WALL BRUSH
DETAIL BRUSH
PARTS BRUSH
UPHOLSTERY BRUSH
ACID BRUSH
I ACKNOWLEDGE THAT THE ABOVE MATERIALS ARE ON CONSIGNMENT FROM
CAFFREY AUTO SUPPLY, INC. THIS INVENTORY WILL BE~MAINTAINED.
SIGNATURE ~~ .
SIGNER HAND PRINT NAME HERE .'~/h4~%' ~.. ,')41L~.~f~
COMPANY LINDGREN CHRYSLER-PLYMOUTH
ADDRESS 1600 LANCASTER AVENUE
DATE
READING, PA 19607
110 S. SPORTING HILL ROAD · PO BOX 169 , MECHANICSBURG. PA 17055-0i69
71 ?-761-6800
BILE TO: 62060
LINDGREN CHRYSLER/PLYMOUTH
1600 LANCASTER AVENUE
SHiP TQ:,
6~060
SAME ***
READING PA 19607 CHECK NO:
2 ~ 0 AND AP1 -OLISH APPLIOATOR 1.41 '~ ......... '
SERVICE CHARGE WILL BE ASSESSED ON ALL PAST DUE BA~NCES. . , ..... ., ' . ,, .at. :
IERCHANDISE R~URNS WITHOUT AUTHORI~TION. NO RETURNS ON SPECIAL ORDERS, ,
ITEMS HAVE BEEN CHECKED AND RECEIVED AS BILLED UNLESS OTHERWISE NOTED. ' , *,i" *, 'f;, '*':i;'~; ~;.~ ~ .....
SIGN AND RETURN (OR SIGNATURE COPY) , -- ".'!:
' EXNIBIT."B"
110 S. SPORING HILL ROAO · PO BOX 186 o MECHANICSBURG. PA 17055-0169
717-761-6S00
BILL TO:
62060
LINDGREN CHRYSLER/PLYMOUTH
1600 LANCASTER AVENUE
READING
F'A 19607
ShIP TO:
6~060
SAME ***
CHECK
3/07/01 DETRIL. 3/1;:'/01 NET ..~0 DRY. · ,
'.~'- · ;1 :~, ~ ~
4 4 0 CAS QCP lAS COMPOUND/BT 17,~5 1~;'95
4 4 0 CAS QDS;~ DIAMOND SHIELD/QT 17. ~5 1~'. 9~
.: d.z.;L..t -:':~-~;~; ~BP; ~:A~~~~ ~
1 1 '0 FLT ~05 ~ ~ BRUSH 8,6~
' ' , -1: ~;';~: :':'~' :; ~ ~c ~ ~ I
1 1 0 F.LT 72 BRASS W/W BRUSH ~,58
1 1 0 PRW A ' "PRO--WIPES" 85.15- 64.00
~ 1 0 JXX WC8 CAS WALL CHART 13.00
:% S~RVI~ CHARGE WILL BE ASSESSED ON ALL PAST DU~ BA~NCE~. '
,~ERCHANOSERETURNSWITHOUTAUTHOR~TiON. NORETURNSONSPECIALORDERS' ; :: := ...;=. ~ ~
~,,y ,~b,l~ ~n,,.,,~:,on with me .m ~ thru merabank--. . CDNT [ NLIED NEXT
VE ITEMS HAVE BEEN CHECKED AND RECEIVED AS BILLED UNLESS OTHERWISE NOTED f~, ~
'O, BY (FULL NAME) X ?':' ~"~ ~ ~;~'~'~:~4~
SIGN AND RETURN.(OR SIGNATURE COPY) .... _.~_~.---,..-~--,:.~: ,: .: : :. '.
110 S, SPORTING H~LL ROAO, PO BOX 169, MECHANICSBURG, PA 17055-O169
717-761-6BO0
BILLTO: 62060 SHIPTO:
I_INDGREN CHRYSLER/PLYMOUTH
1600 LANCASTER AVENUE
62060
SAME ***
READING PA 19607
"~:,~ :~1'~ ~1;~
12 12 0 SHO P311 . VELOUR CLEANER. 5. a0
1 ' 1 0 TIC 86HDG GRIMEBLASTER 7981~ 66.95 ~1,.95 ': .?:4'I'i~95'.- ~'~;'~
7 '7 0 TOL 32' 32 OZ CAS BOTTLE 1.33
~i ~'~ ~~ ' ' """
,' :..2~.:~ ~.'.;~ ~,~
E ITEMS HAVE BEEN CHECKED AND RECEIVED AS ~l//~n UNLESS OTHERWISE NOTED, ~
) BY (FULL NAME) X ... : ,
SIGN
AND
RETURN
,~OPY) .... ,:: :,
VERIFICATION
I, KENNETH F. CAFFREY, JR., President of the Plaintiff herein, hereby certify
that the facts set forth in the foregoing Complaint are true and correct according to the best of my
knowledge, information and belief.
I understand that any false statements herein are made subject to penalties of
18 Pa. C.S. §4904 relating to unswom falsification to authorities.
CAFFREY AUTO SUPPLY, 1NC.,
Plaintiff
LINDGREN CHRYSLER-PLYMOUTH,
INC.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-78
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Jana Butler Toole, Esquire, hereby certify that on the ~,~ day of January, 2002,
I served a tree and correct copy of the foregoing Complaint by depositing same in the United
States Mail, postage prepaid in Harrisburg, Pennsylvania, addressed as follows:
Frederick G. McGavin, Esquire
Binder, McGavin & Myers
527 Elm Street
P.O. Box 399
Reading, PA 19603
Attomtty for Plaintiff
I.D. #80574
500 North Third Street
P.O. Box 1004
Harrisburg, PA 17108
(717) 236-1485
CAFFREY AUTO SUPPLY, INC.
Plaintiff
VS.
LINDGREN CHRYSLER-PLYMOUTH,
INC.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-78
CIVIL ACTION - LAW
ANSWER OF LINDGREN CHRYSLER TO COMPLAINT
1. Denied. Defendant is without knowledge of the averments set forth and if
material demands proof thereof at time of trial.
2. Admitted except that the correct name is Lindgren Chrysler.
3. Admitted in part and denied in part. Defendant admits that it entered into two
documents of consignment but denies that said consignments constitute agreements for the
reason that the consignments are devoid of provisions to constitute a contract.
4. Denied. Defendant denies the contents of Paragraph 4 of Plaintiffs Complaint
for the reason that said averments are not a part of the consignment. It is further denied that
any oral agreements were entered into as herein averred.
5. Defendant admits that it stopped ordering supplies in or about March 5, 2001 and
that invoice # 43747 was received but denies that it owes any part or all of said amount. By
way of further answer Defendant incorporates its answer contained in Paragraph 3 and 4 as
though fully set forth herein.
amount.
7.
8.
Denied. Defendant denies that it owes the sum of $2,632.32 or any other
Denied. Defendant denies that it owes the sum of $354.14 or any other amount.
Denied. Defendant has no knowledge of whether prices of Plaintiff were just and
reasonable and denies that they were legal and market prices. If material, Defendant
demands proof thereof at time of trial. Defendant further avers that prices of other suppliers for
supplies of similar or identical quality are lower than those of Plaintiff.
9. Denied. Defendant denies that it owes the sum of $2,977.47 or any other
amount to Plaintiff.
10. Admitted in part and denied in part. Defendant admits that demands have been
made but denies that any part or all of said amount is due and owing by Defendant. On the
contrary Defendant avers that none of said amount or any other amount is due and owing to
Plaintiff.
WHEREFORE, Defendant demands that the claim of Plaintiff be dismissed.
By
Respectfully submitted,
Frederick ~.'McGavin, Esquire
Attorney ID. 091130
Binder, McGavin & Myers
Attorneys for Defendant
527 Elm Street
P. O. Box 399
Reading, PA 19603
(610) 376-9742
-2-
I, GREGORY L. MILLER, Vice President of Lindgmn Chrysler, Defendant herein,
hereby verify that the facts set for[h in the foregoing Answer to Complaint are true and correct
to the best of my knowledge, information and belief. I understand that false statements by me
are subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to
authorities.
Dated: 2/15/02
CAFFREY AUTO SUPPLY, INC.
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-78
LINDGREN CHRYSLER-PLYMOUTH,: CIVIL ACTION - LAW
INC., :
Defendant :
CERTIFICATE OF SERVICE
I, FREDERICK G. McGAVIN, ESQUIRE, hereby certify that I have on the date
set forth below, served a true and correct copy of the foregoing ANSWER TO COMPLAINT
upon the Plaintiff, Caffrey Auto Supply, Inc., by mailing the same to its attorney, by first-class
mail, postage prepaid.
Attorney for Caffrey Auto Supply, Inc.
Ronald D. Butler, Esquire
Jana Butler Toole, Esquire
500 North Third Street
P. O. Box 1004
Harrisburg, Pa 17108
Dated: 2/15/02
FREDERICK"G~ McGAVIN, ESQUIRE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. "/ ~'-"LOOZ._. Civil. 19
Prothonotary
19
~'~ Attomewfor P-..laintiff
I~'-o~ '[~ ~-~"-
I:;ENh'SYLV/~NIA
NO.
Filed
VS.
PRAECIPE
19
, Atty.
CAFFREY AUTO SUPPLY, INC.,
Plaintiff
LINDGREN CHRYSLER-PLYMOUTH,
INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 78-2002
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned action satisfied, settled and discontinued with
prejudice.
Dated:
Ronald D Butler, Esquire
I.D.#09826
500 No~h Third Street, 12th Floor
P.O. Box 1004
Handsburg, PA 17108-1004
(717) 236.-1485
CAFFREY AUTO SUPPLY, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. : NO. 02-78 CIVIL 19
LINDGREN CHRYSLER - PLYMOUTH, INC. , ; Defendant :
RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Ro]:~rt B. Lieberman, E$c~ire , counsel for the plaintifl~l~tl~ in ~e above ~tion (or actions),
resp~lly ~p~s~ ~t:
1. ~e ~ve~fion~ ~tion ~ is ~) at isle.
2. ~e cl&m of ~e pl~ntiff in ~e ~tion is $ 2,997.47
~e co.tedium of ~e defend~t in the ~fion is N/A
The following attorneys are interested in the case(s) as counsel or are othenvise disqualified to sit as arbitrators:
Frederick G. McGavin~ EsqUirer 527 Elm St.r PO Box 399r R~dinq, PA 19603r (6~0) 376-2866
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be
submitted.
~Y subnai~2~_t~
~Rg.bert B. ~Lieberman, Esquire
ORDER OF COURT aE~orney ~or Plaintiff
foregoing petitionj ~ff~TT,~,~ X -~..z_~ (~~ Esq., ff'~L~ ~
aE~tiq.;nT)t pra~ye~ f.C~oi~/,2J.t/;,u~ /~,~,...Esq., are appointed arbitrators in the above captioned action (or'ff
By the ~
qATH
~e, =he undersigned ar~i==a=or~, hav~n~ been dui7 appoin=ed ~d ~o~
(or ~f~ed), ~a :he fo~ award:
separa=al7 stack. ) ' '
Da:e of Awar~: I