HomeMy WebLinkAbout11-7704r#
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MONARCH PRODNIQIMT ( I APB JOB SHE COURT OF COMMON PLEAS OF
COMPANY, INC., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff Cl1MBERLAHO GGd? +'?IL ACTION - LAW
PENNSYLVAK"I"
V.
: NO.11- 1 ? oq
CIVIL TERM
RICHARD P. HART, JR., and
NANCIE J. HART,
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 the pleadings and
Notice are served, 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 pleadings or for any other claim of 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
Wayne . Shade, Esquire
Supreme Court No. 15712
53 West Pomfret Street
WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
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MONARCH PRODUCTS
COMPANY, INC.,
Plaintiff
V.
RICHARD P. HART, JR., and
NANCIE J. HART,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 11-
CIVIL TERM
COMPLAINT
1.
Plaintiff MONARCH PRODUCTS COMPANY, INC., is a corporation organized
and existing under the laws of the Commonwealth of Pennsylvania, with offices at 385
Sipe Road, York Haven, York County, Pennsylvania 17370.
2.
Defendants RICHARD P. HART, JR. and NANCIE J. HART are adult individuals
who reside at 5154 Kylock Road, Mechanicsburg, Cumberland County, Pennsylvania
17055.
3.
On or about June 7, 2011, Defendants ordered from Plaintiff storm water catch
basins and manholes for installation in connection with Defendants' development of Lot
No. 5 in the development known as Village at Fair Oaks, Lower Allen Township,
Cumberland County, Pennsylvania.
WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
4.
Defendants are the owners of said Lot No. 5 which is more particularly bounded
and described in Cumberland County Plan Book 93, Page 84.
5.
Plaintiff issued the invoice for said materials on June 7, 2011, in the total amount
of $5,189.29, upon terms net fifteen days.
6.
All materials for which Plaintiff submitted the invoice to Defendant as averred
herein were satisfactory in all respects and were accepted by Defendants and installed
without complaint.
7.
In spite of repeated demands therefor, Defendants have fully failed and refused to
make any payments on account of the materials.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$5,189.29 plus costs and interest at the legal rate from June 22, 2011.
WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
e Z/6?1 ? / '-7 4' ?
Wayne F.'Shade, Esquire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
I, JOHN F. WAGMAN, President of Plaintiff MONARCH PRODUCTS
COMPANY, INC., make this verification on behalf of Plaintiff, being authorized to do
of minformation
dgehich I
so. The statements made in the foregoing Complaint are based
have given to my counsel and they are true and correct to the best my
information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities.
Date: October (o , 2011 MONARCH PRODUCTS COMPANY, INC.
By: Q,4, 1=
John . Wagman, resident
WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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OCT 21 Al
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Monarch Products Company, Inc.
vs.
Richard P. Hart (et al.)
Case Number
2011-7704
SHERIFF'S RETURN OF SERVICE
10/13/2011 06:45 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
October 13, 2011 at 1845 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Richard P. Hart, by making known unto himself personally, at 5154 Kylock
Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to him personally the said true and correct copy of the same.
1`11A,-r
MICHELLE GUTSHALL, DEPUTY
10/13/2011 06:45 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
October 13, 2011 at 1845 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Nancie J. Hart, by making known unto Richard Hart, Husband of
Defendant at 5154 Kylock Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents
and at the same time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $54.44
October 18, 2011
MICHELLE UTSHALL, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
;ei GOunrySuite Sheriff. Telaosoft. inc.
David D. Oueff
Prothonotary
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_ County,Tennsylvania
ORDER OF TERMINATION OF COURT CASES
Sononage, '-o` —~x -
Solicitor
CIVIL TERM
AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE — THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
8YTHE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square 0 Suite100 CarCisfe, PA 0 Phone 71724O -619J• 717240-6573