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Home My WebLink About01-2796 : IN THE COURT OF COMMON PLEAS ~ AMERICAN pLAZAS, INC., : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- ~ ff ~ CIVIL TERM V. CHARD GREER TRUCKING, iNC., : Defendant 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 sewed, 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 Cariisle, PA 17013 (717) 249-3166 ALL AMERICAN PLAZAS, INC., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 01- ,~ '7 q ~, CIVIL TERM :HARD GREER TRUCKING, INC., Defendant : 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, Richard Greer Trucking, Inc. is presumably a Missouri corporation with a last known address of 8888 B Hall Street, St. Louis, Missouri, 63147. 3. At all times relevant hereto, Plaintiff, All American Plazas, Inc., hereinafter All was in the business of providing diesel fuel and truck repairs to the Defendant and other similarly situated businesses. 4. From 1999 to the present the Defendant, Richard Graer Trucking, Inc., did utilize the services of All American at various locations owned by the Plaintiff for both the purchase of diesel fuel as well as truck repairs. 5. At some point in the year 2000, the Defendant fell seriously behind in it's account with the Plaintiff and the President of the company, Richard Greer, indicated to the Plaintiff that he would make lump sum payments to in order to bring the account current. 6. Based on such assurances the Plaintiff did continue to extend the credit of the Defendant which credit continued through the year 2001. 7. As a result of these assurances the Plaintiff did extend credit to the Defendant of the purchase of diesel f~el and other services in an amount of $76,231.57 with a credit for payments of $255.48 and a net balance due of $75,976.09. 8. Despite repeated demands, the above sum has remained unpaid as of the date of this Complaint. WHEREFORE, for all the above reasons, the Plaintiff, All American Plazas, Inc., request judgment in its favor in the amount of $75,976.09 plus interest and costs of suit. Respectfully Submitted TURO LAW OFFICES Date /-.~on'~'u ro~, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attomey for Plaintiff VERIFICATION I, Ron Turo, Esquire, am the attorney for All American Plazas, Inc. and am familiar with the facts concerning the above Complaint against Defendant, Richard Greer Trucking Company, Inc. and I swear and affirm that the facts set forth in the Complaint are true and correct to the best of my knowledge, information and belief which have been provided to me by my client or gathered by myself during the preparation of this Complaint. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Ture Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 ., 1 ALL AMERICAN PLAZAS, INC., : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . : NO. 01- ~'7 q~ CIVIL TERM V. : RICHARD GREERTRUCKING, INC., : Defendant : AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I sewed a true and correct copy of the Complaint in the above captioned case upon Richard Greer Trucking, Inc., by certified mail, return receipt requested on May 10, 2001 addressed to: Richard Greer Trucking, Inc. 8888 B Hall Street St. Louis, MI 63147 and did thereafter receive same as evidenced by the attached Post Office receipt card dated May 14, 2001. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES o~n~-/Turo, Esquire Date 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Z 452 476 225 US Postal Sewlce Receipt for Certified Mail No Insurance ~ovem_ge p~. ~ ~ ~ for J~nal ~1 ~ ~, 55 ~F~ ~&~ 'TAL~'&F' $ ~.9~ ~Receipt ERIC J. SNYDER : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : WENDY L. SNYDER : 01-1811 CIVIL ACTION LAW DEFENDANT IN CUSTODY AND NOW, Friday, May 18, 2001 , upon consideration of the attached Complaint, it is hereby directcd that parties and their respective counsel appear before Jacqueline M. Verney, P-sq. . the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, June 06, 2001 at 8:30 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a tcmporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the putties to furnish uny and ,,11 existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Is/ .ktcqueline M. Verney. Esq.~Y~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before thc court. You must attend the scheduled conference or bearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATI'ORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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. Pennsylvania 17013 Telephone (717) 249-3166 ALL AMERICAN PLAZAS, INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYVLANIA v. : NO. 01-2796 CIVIL TERM RICHARD GREER TRUCKING, INC. : CIVIL ACTION - LAW Defendants .~_~.--"~ PRAECIPE FOR ENTRY OF JUDGMENT TO: Prothonotary Cumberland County Courthouse Courthouse Square Carlisle, PA Please enter judgment in favor of Plaintiff, All Amedcan Plazas, Inc. and against Defendant, Richard Greer Trucking, Inc. in the amount of $69,976.09. Defendant was sewed with a 10 Day Notice dated and served Mamh 1, 2002, as evidenced by the attached copy of the Notice and Certificate of Service attached hereto and incorporated herein as Exhibit "A'. a. Principal $69,976.09 b. Interest $ 0.00 c. Late charges $ 0.00 d. Attomey's fees $ 0.00 Total ^mount: $69,976.09 Plus additional interest at the legal rate for every day after entry of judgment up to and including the day the judgment debt is fully liquidated. Respectfully Submitted TURO LAW OFFICES (717) 245-9688 Attomey for Plaintiff CERTIFICATE OF SERVICE I hereby certify that I served a true and correct COpy of the Default Not/ce upon Richard Greer c/o Richard Greer Trucking, Inc., by depositing same in the United States Mail, first class, POStage pre-paid on the 1st day of March, 2002, from Carlisle, Pennsylvania, addressed as follows: R/chard Greer Richard Greer Trucking, Inc. 8888 B Hall Street St. Louis, MO 63147' TURO LAW OFFICES Car/isle, PA 17013 (717) 245-9688