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Home My WebLink About01-2374IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, LABOR READY, INC. Plaintiff vs. CIVIL DIVISION COMPI~%INT PENNSYLVANIA TIM WILB~/R individually and as a partner trading and doing business as TIM WILBUR MECHANIC Defendant(s) FILED ON BEHALF OF Plaintiff(s) COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KR~WEC, ESQUIRE PA I.D. ~38527 JON A. MCKEC~INIE, ESQUIRE PA I.D. $36268 Bernstein Law Firm, P.C. Firm ~718 1133 Penn Avenue Pittsburgh, PA 15222 412-456-8100 DIRECT DIAL: (412) 456-8114 BE~NSTEIN FILE NO. 00029885 98850402 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION READY, INC. Plaintiff Civil Action TIM WILBUR individually and as a partner trading and doing business as TIM WILBUR MECHANIC Defendant NOTICE AND COMPLAINT NOTICE TO DEFEND 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 upon you, 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. CUMBERLAIgD COUNTY BAR ASSOCIATION Two Liberty Avenue Carlisle, Pennsylvania 17013 {717) 249-3166 (1-800) 990-9108 98850402 CU~BZRLAND 1. Plaintiff is a corporation having offices in Pittsburgh, PA. 2. Defendant is an individual engaged in business at 507 North York Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. As TIM WILBUR MECHANIC is an unregistered fictitious name, Plaintiff brings this action pursuant to PA.R.C.P. 2128(d). 4. At the special instance and request of Defendant, Plaintiff provided to Defendant certain temporary persounell services. 5. Defendant received and accepted the aforementioned services. 6. The prices charged by Plaintiff were the fair, reasonable, and market prices that prevailed at the time of the transaction. 7. The prices charged by Plaintiff were the prices that Defendant agreed to pay. 8. Plaintiff avers that the balance due amounts to $l,476.73, as is more specifically shown by Plaintiff's payment history, a true and correct copy of which is attached hereto, marked Exhibit "1", and made a part hereof. 98850402 9, Plaintiff claims legal interest as damages on the liquidated debt from August 18, 2000. 10. Plaintiff avers that interest amounts to $86.66 to April 18, 2001. 11. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to pay the aforesaid balance, interest, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment against Defendant in the amonnt of $2,563.39, with continuing interest thereon at the rate of 1/2% per month and costs. BEP/~STEIN BERNSTEIN KRAWEC & WYMAP~D, P.C. 1133 Penn Avenue Pittsburgh, PA 15222 BERNSTEIN FILE NO. 00029885 (412} 456-8100 98850402 Customer Collections Web User: FAYE PRIMEAU Page 1 of TiM WILBUR MECHANIC 3901-1742 Credit Limit: ~_~ 000.0_0__j Balance; 1~2 475.73 Invoices; I * Double click on your selection or click the Payment H_istory b_utton below 1Invoice # Date i Amount Total Paid I UnPaid 'ADI~ I Job Location - 4981742 ~ 8/11100 ~$1,420.10 $0.00 151,420.10 0 IPLUMBERS HELPER Payment History: VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities, that he/she is an Attorney Agent of Labor Ready Inc. , Plaintiff herein, that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing complaint are true and correct to the best of his/her knowledge, information and belief. (SIGN IN BLUE IATK) )c: SHERIFF'S RETURN - CASE NO: 2001-02374 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LABOR READY INC VS WILBUR TIM ET AL REGULAR RICHARD SMITH , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE WILBUR TIM DEFENDANT at 0014:08 HOURS, on at 507 NORTH YORK STREET MECH/~NICSBURG, PA 17055 TIM WILBUR a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the the 30th day of April , 2001 by handing to & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.06 Affidavit .00 Surcharge 10.00 .00 36.06 Sworn and Subscribed to before me this ,_~.~ day of So Answers: R. Thomas Kline o5/ol/2OOl BERNSTEIN, By: fepu/cy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2001-02374 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LABOR READY INC VS WILBUR TIM ET AL RICHARD SMITH Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE WILBUR TIM MECHANIC DEFENDANT , at 0014:08 HOURS, at 507 NORTH YORK STREET MECHANICSBURG, PA 17055 TIM WILBUR Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 30th day of April by handing to the , 2001 true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 3~-~ ._ day of · --~/ A.D. So Answers R. Thomas Kline 05/01/2001 BERNSTEIN, By: P~AWEC /Deputy Sheriff ~lay 29, 2001 Page 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LABOR READY Plaintiff(s) No. 01-2374 CIVIL VS. TIM WILBUR individually and as a partner trading and doing business as TIM WILBUR MECHANIC Defendant(s) PRAECIPE TO SETTLE, DISCONTINUE, AND END FILED ON BEHALF OF Plaintiff(s) COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA I.D. #38527 JON A. MCKECHNIE, ESQUIRE PA I.D. #36268 Bemstein Law Firm, P.C. Firm #718 1133 Penn Avenue Pittsburgh, PA 15222 412-456-8100 DIRECT DIAL: (412) 456-8114 BERNSTEIN FILE NO. 00029885 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LABOR READY Plaintiff VS. TIM WILBUR individually and as a partner trading and doing business as TIM WILBUR MECHANIC Defendant PRAECIPE TO SE'YI~LE, DISCONTINUE AND END Settle, discontinue and end the above-captioned matter upon the records of the Court and mark the costs paid. BERNSTEIN LAW FIRM, P.C. Alt6meys for Pl~miff / ~ 1133 Pe~ Avenue Pi~sb~gh, PA 15222 (412) 456-8100 BE~STE~ FILE NO: 00029885 Sworn to and su~s$~bed before n~.e this [ ~'& , 2001 0tary Public Civil Action No. 01-2374 CIVIL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: