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Home My WebLink About11-8516FILED-OFFICE Christopher E. Rice, Esquire Cf THE F1C1T0 TAY I.D. Number 90916 1 P ?. MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER 150 MARTSON LAW OFFICES CUMBERLAND COUNTY Ten East High Street p NtjsYLV; NIA Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING IN THE COURT OF COMMON PLEAS OF SERVICES, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 2011 - ROBIN LEE, 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 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 Plaintiffs. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 PA ??7? FAFiLESUients\12156 Madden Engineering\12156.19\12156.19.com/mah Christopher E. Rice, Esquire I.D. Number 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs MADDEN ENGINEERING IN THE COURT OF COMMON PLEAS OF SERVICES, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 2011 - ROBIN LEE, Defendant COMPLAINT AND NOW, comes the Plaintiff, Madden Engineering Services, Inc., by and through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers as follows: 1. Plaintiff, Madden Engineering Services, Inc., is a Pennsylvania corporation with a registered address at 24 North 4`h Street, Newport, Perry County, Pennsylvania 17074. 2. Defendant, Robin Lee, is an adult individual with a last known address of 5747 Old Clifton Road, Clifton, Virginia 20124. 3. Plaintiff is in the business of providing services, mainly engineering, to certain businesses and individuals. 4. Plaintiff has provided services to Defendant for a total value of $7,594.00. True and correct copies of Plaintiff's invoices are attached hereto as Exhibit "A." 5. Defendant has failed to pay for such services and, therefore, is liable to Plaintiff for the amounts owed plus interest, costs and attorney fees. 6. Despite repeated demands, no payments have been made by the Defendant for amounts due nor has Defendant disputed this debt. COUNT I - BREACH OF CONTRACT 7. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 6 as if fully set forth. 8. Defendant has breached an expressed or implied agreement, directly or through agents, to pay for the goods and services provided to Defendant from Plaintiff and/or Plaintiff's agents. WHEREFORE, Plaintiff demands judgment against Defendant in the total amount of $7,594.00, plus interest at the rate of 18% per annum as set forth in the invoices, attorney's fees and costs. COUNT II - QUANTUM MERUIT 9. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 8 as if fully set forth. 10. Defendant is liable to the Plaintiff and/or has been unjustly enriched in the amount of $7,594.00. WHEREFORE, Plaintiff demands judgment against Defendants in the total amount of $7,594.00, plus interest at 18% per annum as set forth in the invoices, attorney's fees and costs. MARTSON LAW OFFICES By:_ (?,V -x <5 4-,-- Christopher E. Rice, Esquire ID Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: 1131wl Attorneys for Plaintiff EXHIBIT "A" Madden Engineering Services, Inc. 24 North Fourth Street Newport, PA 17074 To: Robin Lee 5747 Old Clifton Road Clifton, VA 20124 Statement Date 5/26/2011 Amount Due Amount Enc. $7,594.00 Date Transaction Amount Balance 04122/2010 INV #10.69. Due 05/07/2010.Orig. Amount $542.50. 542.50 542.50 06/15/2010 INV #10.107, Due 06/30/2010.Orig. Amount $3,324.00. 3,324.00 3,866.50 05/26/2011 INV #11.098. Due 06/10/2011.Orig. Amount $3,727.50. 3,727.50 7,594.00 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS Amount Due DUE DUE DUE PAST DUE 3,727.50 0.00 0.00 0.00 3,866.50 $7,594.00 Madden Engineering Services, Inc. 24 North Fourth Street Newport, PA 17074 Bill To Robin Lee 5747 Old Clifton Road Clifton, VA 20124 Invoice Date Invoice # 4/22/2010 10.69 Terms Due Date Project Net 15 5/7/2010 Stoey Property Description Amount Professional Services: 2/13/2010 through 4/17/2010 Concept Plan 542.50 Existing Features Meeting with Surveyor re: Survey, Easements & Turnpike S WM Narrative and Act 14 Notices Madden Engineering Services, Inc.'s invoices are due within 15 days of the date of the invoice. If payment is not received by the due date, one past due notice will be sent on the sixteenth (I 6th) day, Thereafter, one final notice will be sent informing you that we are stopping all work on this project until payment is received in full. If payment is not received within thirty (30) days of the date of this statement, interest at 18% per annum will be added to any unpaid balance, along with the costs of suit and attorney's fees should the same be incurred as a result of any action by us to collect any balance past due. Total $542.50 Madden Engineering Services, Inc. 24 North Fourth Street Newport, PA 17074 Bill To Robin L= 5747 Old Clifton Road Clifton, VA 20124 Invoice Date Invoice # 6/15/2010 10.107 Terms Due Date Project Net 15 6/30/2010 Stoey Property I Description I Amount Professional Services: 4/18/2010 through 6111/2010 Revised Concept Plan 2,990.00 Planning Module Preparation Site Visits Subdivision Plan Preparation Application Preparation Plots, Delivery, Submission Preparation Reimbursement Requested for Fees Paid to: 295.00 Lurgan Township $80.00 (Vince Elbel site visit) Lurgan Township $105.00 Franklin County $110,00 Printing Reimbursement: 26 sheets (24 x 36) @ $1.50/sheet 39.00 Madden Engineering Services, Inc.'s invoices are due within 15 days of the date of the invoice. If payment is not received by the due date, one past due notice will be sent on the sixteenth (16th) day. Thereafter, one final notice will be sent informing you that we are stopping all work on this project until payment is received in full. If payment is not received within thirty (30) days of the date of this statement, interest at 18% per annum will be added to any unpaid balance, along with the costs of suit and attorney's fees should the same be incurred as a result of any action by us to collect any balance past due. Total $3,324.00 Madden Engineering Services, Inc. 24 North Fourth Street Newport, PA 17074 Bill To Robin Lee 5747 Old Clifton Road Clifton, VA 20124 Description Professional Services: 6112/2010 through 5/20/2011 Attend Lurgan 'T'ownship Meetings PNDI Updates, Planning Module Work Plan Revisions per Township Engineer Invoice Date Invoice # 5126/2011 11.098 Terms Due Date Net 15 6/10/2011 Madden Engineering Services, Inc.'s Invoices are due within 15 days of the date of the invoice. If payment is not received by the due date, one past due notice will be sent on the sixteenth (16th) day. 't'hereafter, one final notice will be sent informing you that we are stopping all work on this project until payment is received in full. If payment is not received within thirty (30) days of the date of this statement, interest at 18% per annum will be added to any unpaid balance, along with the costs of suit and attorney's fees should the same be incurred as a result of any action by us to collect any balance past due. Project Stoey Property Amount 3,727.50 Total $3,727.50 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, l may be subject to criminal penalties. W. John Madden, President Madden Engineering Services, Inc. Omlr Prothonotary ~�'the ��~~^()fn � Office -/ _ - '-�-/ ��/��/�D�t� _ County, ---'/''_.- /1~ ORDER OF TERMINATION OF COURT CASES 7CirkS.- -''o`--Q Solicitor CIVIL TERM AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO POCEED AND RECEIVING NO RESPNSE-THEABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH P4R.[.P.23O2. BY THE COURT, DAVID D. BUELL PROTHONOTARY