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HomeMy WebLinkAbout04-4803COMWANWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Cumberland County JUDICIAL DISTRICT 9th NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS Nm O q _ ggb3 NOTICE OF APPEAL S# a3 2OOy Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below NAME OF APPELLANT MAG. DIST. NO OR NAME OF 0.1 Hoffman Mechanical, Inc. 09-1-01 ADDRESS OF APPELLANT OTY STATE ZIP CODE 3 Keystone Drive Mechanicsburg, PA 17055 DATE OF JUDGMENT IN THE CASE OF (R'aiMiH) (DOWdwt) 8/25/04 The Drexel Group, Inc. vs Hoffman Mechanical, Inc. CLAIM NO SIGNATURE APPEL NT OR HIS ATTORNEY OR AGENT CV AIi 0000196-04 LT 19 This block will be signed ONLY when this notation is required under Pa. R.C P. Na If appe was CLAIMANT (see Pa. R.C.P.J.P. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate cs a 1001(6) in action before District Justice, he MUST SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after Signature of Prothonotary or Deputy filing his NOTICE of APPEAL. 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 Prothonotary Enter rule upon The Drexel Group (717 Market Street, Lemoyne, PA 17044pellee(s), to file a complaint in this appeal 1 Name of appellee(s) (Common Pleas No. D4_ qW3 Glut within twenty (20) days after s vi a of e r suf entry of judgmenrof non pros. a of appellant or his attorney or agent RULE: To The Drexel Group , appellee(s). Name of appellees) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date+?oof service of this rule if service was by mail is the date of mailing. , Date: P`? ?? 17 64-t-r. of Prothonotary or Deputy COURT FILE TO BE FILED WITH PROTHONOTARY AOPC 312-86 =?9r°CPx? ^?M" ?:7F1+>r ,a^R; ,r?sq asf{`5 a'Fa COMMONWEALTH OF PENNSY^ VANI COUNTY AFFIDAVIT-, I he :iav WCOr ? ed 11 k1i c?, r @r?{. .; rya ,addres••, ,::c moil, sende%s receipt 0; .Uci.,d here ..?- SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF Signature of official before whom affidavit was made Title Of onkfew My •ommission oxpires on 19_. Signature of a!t/arrt COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mad. Dist. Ne.: 09-1-01 DJ Name: Hon. CHARLES A. CLEMENT, JR. Addf'as 400 B}cIDGE STREET OLDS TOWNE COMMONS -SUITE 3 NEW CUMBERLAND, PA Telephone: (717) 774-5989 17070 ATTORNEY DEF PRIVATE F. STEPHENSON MATTHES ESQ. 111 N. FRONT ST TICKER ARENSBERG & SWARTZ HARRISBURG, PA 17108-0889 THIS IS TO NOTIFY YOU THAT: Judgment: NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRESS rTHE DREXEL GROUP INC 7 717 MARKET STREET LEMOYNE, PA 17043 L VS. DEFENDANT: NAME and ADDRESS rHOFFMAN MECHANICAL INC 3 KEYSTONE DRIVE MECHANICSBURG, PA 17055 L DocketNo.: CV-0000196-04 Date Filed: 4/28/04 DEFAULT JUD(.MRNT PLTF Judgment was entered for: (Name) mRR nRRXRT. r.RnTIP TNr. ® Judgment was entered against: (Name) ROFFMAN MR('HANTrAT. TNP. in the amount of $ 1,204.1a on: (Date of Judgment) 7 Defendants are jointly and severally liable. Damages will be assessed on: 7 This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ Portion of Judgment for physical damages arising out of residential lease $ (Date & Time) R/25/n4 Amount of Judgment $ 3,119.88 Judgment Costs $ 84.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 3,204.38 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY THE DISTRICT JUSTICE.- . _:,;_): UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTQ9E*9TEQIN 7WE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGM?A7•DEBTOR RAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ^? _ ='• - " at "z AUG 2 5 2004 . C? ry 1 i` Date i District Justice I certify that this is a true and correct copy of the record of the proceedings cenjadniAg1the jGdgment. Date !"Ms'inct Justice My commission expires first Monday of January, 2008 . SEAL J J AOPC 315-03 DATE PRINTED: 8/26/04 8:08:04 AM a PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN FIVE (5) DAYS AFTER tiling the notice of appeal. Check applicable boxes) y, _ COMMONWEALTH OF PENNSYLVANIA COUNTY OF . L) m r-112 1 `/' : In . AFRDAVff: I hereby swear or affirm" that I served Q -upon the District Justice designated therein on a copy of the Notice of Appeal, Common Pleas No. (date of service) 2 , w? by p rsonal serv fe_ ,? by (?Cfied) (registered) mail, sender's e ? / on ,eceippt attached here o, and up n the appellee ,.(nalne) ?p 0WLM {r?23 , * ? by personal service &by (certified) (registered) mail, sender's receipt attached hereto. and further that I served the Rule to File a mploint accompanying the above Notice of Appeal upon the dppellees) to whom the Rule was addressed on S 2 e r 0 by personal serviceA by (certified) (registered) o 0 mail, sender's receipt attached hereto. C SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS 0d D n 4? Wre of oidakt belae whom aiddeWf was made ?s lTtle dam- ? ? __ ?? My commission expires on ?"A,9 ,.lac S . Co Co '?IAIlIL BfAI :: ?; WJIEEIFG? NECIELE CIIYOFNIMRMMJRG Coulw U.S. Postal ServiceTIA un CERTIFIED MAIL- RECEIPT r? (Domestic Mail Only; No insurance coverage Provided) !U r- m ? ru PjFee ra CertifiC3 Postmark C3 Return RecieHere (Endorsement ReO Restricted Delivr? (Endorsement Re1/; ?t/J tL Total Postage $ 3''r 1 NO Sent To I II _._ ............. . _n_.. u ? C5. ___ _ _ ------ 711. i [` Street, AP[. No.; _ or POBe-No. Cj.?'.1r_ yYLmUN-S-cry, sieie; zia+a" /t? 1._?IQ? O r r r 1.. tylAC U.S. Postal Service- CERTIFIED MAIL. RECEIPT (Dome tic Mail Only; No insurance Coverage Provided) r m ru Postage $ -7 ra Certified Fee O Return Reciept Fee (Endomement Required) O Restrictec Delivery Fee rT (Endorsement Required) ru Total Postage & Fees Postmark Here J:A , COMMONWEALTH OF PENNSYLVANIA Cumberland County JUDICIAL DWIHCT 9th NOTICE OF APPEAL FROM DISTRICT "TICE JUDGl111ENT COMMON PLEAS Ne i / t•/ _ y. NOTICE OF APPEAL Pf '013' 9 Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice an the date and in the case mentioned below. 09-1-01 Drive PA Ifappe&rk was vs Hoffman mechanical, Inc. LT 19 __.-W- ...wr, mrs rOmmn-'s requirdd under Pa. 10088; , This Notice A of Appeal, when received by the District Justice, will o SUPERSERSEDERS to the iudcIm&gmM M%NM6 or 17055 (see Pa. R.C:P.J.P. Ab. a 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (fib) days eer filing his NOTICE of APPEAL. rtr his section of form to be used ONLY When appe&W 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 Prothonotary Enter rule upon The Drexel (717 Market Street, Nana of arpapets) (Common Pleas Na OU- 4fW3 e IV., t within twenty (20) days after RULE: To The Drexel Group Nave of appelk, , appellee(s). w his artomey or agent (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon You by personal service or by cerfified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. Date: . a3 , a4 Y Of A'otharatay or Deputy 70 ?rT/ip?ellee(s), to file a complaint in this appeal of r dr suf entry o ju me f non pros. AOPC 312- COURT FILE THE DREXEL GROUP, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW HOFFMAN MECHANICAL, INC., : NO. 04-4803 Defendants AFFIDAVIT OF SERVICE: COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND AND NOW, this ? LO 1H- day of September, 2004, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Dawn T. Heilman, who, being duly sworn according to law, deposes and says that she is the secretary for F. Stephenson Matthes, who is the attorney for Hoffman Mechanical, Inc., defendant herein, and that she mailed a Notice of Appeal from District Justice Judgement, on September 23, 2004 to The Drexel Group. Inc., 717 Market Street, Lemoyne, PA 17043, by Certified Mail No. 7002 2410 0001 2367 2751, return receipt requested, and the same was received on September 24, 2004, and Hon. Charles A. Clement, Jr., 400 Bridge Street, Olde Town Commons, Suite 3, New Cumberland, PA 17070, by Certified Mail No. 7002 2410 0001 2367 2775, return receipt requested, and the same was received on September 24, 2004, as indicated by the Return Receipt Cards, which are attached hereto. t J Dawn T. Heilman SWORN TO AND SUBSCRIBED before me, this day of September, 2004. 'Notary Public 72215.18i- ?ggER'FORW No1aN pU00 COIMN *MWAN Fcomvvo Pb, 2007 es " Cammu? ?;...---- h' C=,J f? ? iLL Q7 ?fYl N :Xy cr, Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER, PICCOLA & ALFORD 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717) 236-9316 - fax btpa@att.net Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. HOFFMAN MECHANICAL, INC., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA' NO. 04-4803 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 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en ]as paginas siguientes, uted tiene viente (20) dias de plazo al partir de la fecha de le demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas os sus objeciones a leas demandas en contra de su persons. Sea avisado que si usted no se defiende, la corte tomara medidas y peude entrar una order contra usted sin pervio aviso o notificacion y por cualquiOr queja or alivio que es pedido en la peticion de demanda. Usted peude perder dinero os sus propiedades o ostros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIE:NTE DE PAGAR RAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONE A LA ICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA VERIGUAR DONDE SE UEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER, PICCOLA & ALFORD 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717) 236-9316 - fax btpa®att.net Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' V. HOFFMAN MECHANICAL, INC., DEFENDANT NO. 04-4803 : CIVIL ACTION - LAW COMPLAINT Plaintiff, The Drexel Group, Inc., by its attorneys, Leonard Tintner, Esquire, and Boswell, Tintner, Piccola & Alford, and presents its complaint against Defendant, Hoffman Mechanical, Inc., as follows: 1. Plaintiff, The Drexel Group, Inc., is a Pennsylvania corporation, with an office located at 717 Market Street, Lemoyne, Cumberland County, Pennsylvania 17043. 2. Defendant, Hoffman Mechanical, Inc., is a Pennsylvania corporation, with its principal place of business located at 3 Keystone Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff is a business that supplies temporary workers to customers who desire same. 4. In February, 2002, Plaintiff and Defendant entered into a contract for the supply of temporary personnel. 5. Temporary workers were supplied by Plaintiff and were employed at Defendant's business from February 2002 through August, 2002. 6. From July 22, 2002 through August 2002, the following temporary workers were employed at Defendant's place of business: Angela Billow, Michelle R. McCullough and Pamela J. Kibler. 7. Defendant was billed on a weekly basis, which invoices prior to July 22, 2002, were paid. 8. The unpaid invoices due to Plaintiff are from work performed July 22, 2002 through August 16, 2002. Copies of the invoices are attached hereto and identified hereto as Exhibit "A." 9. The amount due on the invoices supplied to Defendant totals $2,399.91. 10. According to the terms of the contract, Plaintiff is entitled to collection expenses, including attorneys fees and court costs, which total $804.47. 11. Defendant has not made a payment on the amount due and owing. 12. The current outstanding balance due is $3,204.38. 13. Despite Plaintiff's numerous attempts to collect this amount, Defendant has continuously refused to make payment to Plaintiff for the balance due. WHEREFORE, Plaintiff demands judgment in an amount not in excess of $35,000.00, which amount requires submission of this matter to compulsory arbitration, plus interest and costs of suit. RESPECTFULLY SUBMITTED, Attorney for Plaintiff The Drexel Group, Inc. BOSWEL TINTNER, PICCOLA & ALFORD BY: ? onard Tintner, Esquire DATE: October 13, 2004 The Drexel Group, Inc. 0. Box 6348 _arrisburg, Pa. 17112 (717) 652-3123 Accounts Payable Hoffman Mechanical Inc. INVOICE Invoice Date: 08/02/2002 Invoice #: 02- 1724 Customer #: 561 Cost Center: 3 Keystone Dr P.O. #: Mechanicsburg PA 17050 Contact: Employee Week Ended Hours Rate Extended Billow Angela 7/28/02 REGULAR: 38.75 13.49 522.74 OVERTIME: 0.00 20.24 0.00 DOUBLE: 0.00 26.98 0.00 SALES TAX AMOUNT: 10.44 TOTAL AMOUNT DUE: 533.18 InvoiceTerms: NET 10 DAYS The Drexel Group, Inc. .lul 26 02 01:52p Hoffman Mechanical Inc 717 790 6075 r' ' F, a5 Y AA IP .2 The Drexel Group, Inc. 0. Box 6348 .arrisburg, Pa. 17112 (717) 652-3123 Invoice Date: 08/09/2002 Invoice #: 02-1783 Customer #: 561 INVOICE Accounts Payable Hoffman Mechanical Inc. Cost Center: 3 Keystone Dr P.O. #: Mechanicsburg PA 17050 Contact: Employee Week Ended Hours Rate Extended Billow Angela 8/4/02 REGULAR 40.00 13.49 539.60 OVERTIME: 0.00 20.24 0.00 DOUBLE: 0.00 26.98 0.00 SALES TAX AMOUNT: 10.78 TOTAL AMOUNT DUE: 550.38 Invoice Terms: NET 10 DAYS The Drexel Group, Inc Rub 02 02 03:34p Hoffman Mechanical Inc 717 7S0 6075 CLIENT NAME • ADDRESS CiT1' REPORTTO: TIME DEPT, TA-3 ARRiAWN PRBYT Np/VNn/O®11iwgMC® CALL 1-G0-1S'8-0182 .!/ 10, CROUP. VJC 4815 JONESTOWN RD. #201 HARRISBURG, PA 1710GI (717) 652-3123 FAX (717) 657-3533 COMPANY WEEKENDING N ADDRESS CITY /Fq''p11LOYEE NAWIE HMOLYO O MMAYIL ytr7 1a.1 4• .? ]? \\nl `? CHECK DHECKLY I? ?CUU URITY NUMBER AVAILABLE YES ? 1 7SEC1 1151 y 1 R113 19 WORK! ND , . :EXMPLOY WUUIFg/L/{7o .'.... WHEN ._._ I - QpIpO m ^w ¢NC?6 ¢' BY? IS FORM EMPLOYEE AGREES TO TERMS AND ?mne?e¢ n t TIER mwu is •TIUE ANO ACCURATE. AND DAY I DATE TER HOUR REG HOURS TUES .--%o 5,00 $'`bp r').r .: :.g.... THUR 9-1-02- a', 00 1a;DO ! . FRI -z-o S'-oo ;5;o0 - SAT SUN YE5 ND LMS P•2 I SHOWN ARd CORRECT; WORK WA9 DONE 6ATISFACTORBY: AND THAT OUENT AGREES m THE TERMS AND CONDITIONS ON THE REVERSE SIDE OF THIS FORM. PLEASE DRAW UNE 7HROU3H UNUSED SPACZS ABOVE, OFFICE COPY WitiEil]Db REV. ilCO The Drexel Group, Inc. ^.O. Box 6348 arrisburg, Pa. 17112 (717) 652-3123 Invoice Date: 08/16/2002 Invoice #: 02-1851 INVOICE Customer #: 561 Accounts Payable Hoffman Mechanical Inc. Cost Center: 3 Keystone Dr P.O. #: Mechanicsburg PA 17050 Contact: Employee Week Ended Hours Rate Extended Billow Angela 8/11/02 REGULAR: 40.00 13.49 539.60 OVERTIME: 0.00 20.24 0.00 DOUBLE: 0.00 26.98 0.00 SALES TAX AMOUNT: 10.78 TOTAL AMOUNT DUE: 550.38 Invoice Tema: NET 10 DAYS The Drexel Group, Inc. Rug 09 02 03:53p Hoffman Mechanical Inc 717 790 6075 _ CLIENT NAME ADDRESS CfTY REPORTTO: TIME DEPT. 1 TA-3 APF6RGBN RRNR MANABEMiMT Y@RVICEa CALL 1-0DD4SB•S1F2 4815 R R #201 HARRISBURG, , PA 17109 (717) 652-3123 FAX (717) 657-3533 cm oil i n, •? HMY ? MY ?i .? cnBCn cNBdc YES FOR 41?4 µ WHEN AVAILABLE? EE BY EKECUTING THIS FORM. EMPLLYEE AGREES TO TERMS AND BIDE COMPIES THAT THIS FORM IS TRUE AND ACCURATE AND JFFERED DAY GATE HOURS TO NEAREST OUAATER HOUR ' OURS D.i. HOURS STARTED FINISHED LE54 UAJCH REG H MON } ?x TUES r THUR S-?- C2 FM N-?, s t 0- s? ? S SAT SUN CLIENT: PLEASE RITE TOTAL HOURS IN w. L'. V r Ilft OFFICE COPY P.1 The Drexel Group, Inc. 0. Box 6348 arrisburg, Pa. 17112 (717) 652-3123 Invoice Date: 08/23/2002 Invoice #: 02- 1908 Customer #: 561 INVOICE Accounts Payable Hoffman Mechanical Inc. Cost Center: 3 Keystone Dr P.O. #: Mechanicsburg PA 17050 Contact: Employee Week Ended Hours Rate Extended Billow Angela 8/18/02 REGULAR: 16.00 13.49 215.84 OVERTIME: 0.00 20.24 0.00 DOUBLE: 0100 26.98 0.00 McCullough Michelle R 8/18/02 REGULAR: 13.00 13.49 17537 OVERTIME: 0.00 20.24 0.00 DOUBLE 0.00 26.98 0.00 SALES TAX AMOUNT: 7.81 TOTAL AMOUNT DUE: 399.02 Invoice Tem:s: NET 10 DAYS The Drexel Group, Inc. i ' M M ce) T O i M C4 O co v O nI: [[TT Z <t qq 2 M p¢ J M O N CO m n T II r S C{" u° 2g MOO 0 Z Z OI 17 C'] ? Cp W $ 11 11 I1?4 l r LL = O •? Wy?Fr{ 3¢W Wa ? YYZ7I OD ki ? O I I I I I LL I y y lg The Drexel Group, Inc. ^.O. Box 6348 aarrisburg, P2.17112 (717) 652-3123 Invoice Date: 09/06/2002 Invoice #: 02- 2019 Customer #: 561 INVOICE Accounts Payable Hoffman Mechanical Inc. Cost Center: 3 Keystone Dr P.O. #: Mechanicsburg PA 17050 Contact: Employee Week Ended Hours Rate Extended Kibler Pamela J. 9/1/02 REGULAR 24.00 14.99 359.76 OVER11ME: 0.00 22.49 0.00 DOUBLE: 0.00 29.98 0.00 SALES TAX AMOUNT: 7.19 TOTAL AMOUNT DUE: 366.95 Invoice Tema: NET 10 DAYS The Drexel Group, Inc _ CLIENT NAME AD RESS Cm ' RFPORTTD TIME DEPT j . TA-3,__._mFanoN worlr nvNnanamvr navrie cALl i.gDD.n3smax GROUP. INC 4815 JONESTOWN RD. #201 HARRISBURG, PA 17109 (717) 652-3123 FAX (717) 657-3533 COMPANY NAME WEEK Erqmi?G SUNDAY I I/ 31 cip j CITY O -p a o j HdP NAME Ho m MAIL c„?o o / 5 CIAL SECURITY NUMBER AVACA3LE YES t I li toISIB 5 5 ? ?WyWeFGNATURE WHEN AVAILABLE? X IuroRUNr FDR eNPLOYEe BY EXECUONG THIS FOR.14 MPLOYEE AGREES ro TmMS.aND !. COlIDffIONB ON REVERSE SIDE; Ck'RTIRFS THAT T1US FOW,;1 IS TRUE AND ACCURATE, THAT NO NUURIES WERE 3 AND UFFEREO DAY DATE HOURS TO NEAREST QUARTER HOUR STARTED RNISHED LESS LUNCH REG HOURS aT HOURS MON i TOES WED a ; THU g, ... _ i . I'd SL09 DSL LIL Fm b g 5 1- SAT SUN MRS MIN MRS MIN Cl1ENT PLEASE WRTTETML-HOURS W. WORDS TOTAL'. ?. TO NEAREST QUARTER HOUR ABOVE HOURS P ' APR NT NAME (?I?IIn^ TITLE --_ m i" mme-lomm YE3 ASST ? NO 1 ?POR aGeCUTt'CN OF THIS FORM, CLIENT HE SH E COR CF, WORK WAS DOME SATISFALTORILY AND THAT' A 3?E ON TIIE REVERSE SIDE OFTl38 FTORA. PLEASE DRAW LRIE THgpUOi{ xRmly omm OFFIOECOPY ' oui Ieoiue4OBW ueWJJOH d8}:.10 20 06 9nU THE DREXEL GROUP, INC., : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 04-480:3 HOFFMAN MECHANICAL, INC., DEFENDANT : CIVIL ACTION - LAW VERIFICATION I, Angela Lakavage, Project Manager of The Drexel Group, Inc., Plaintiff, hereby verify that the facts contained in the foregoing Complaint 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.A. §4904 relating to unsworn falsification to authorities. (- L L (it, GELA AKAVA E DATE: )011,3)LY CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct. copy of the foregoing Plaintiff's Complaint by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: F. Stephenson Matthes, Esquire Tucker Arensburg,P.C. 111 N. Front Street Post Office Box 889 Harrisburg, PA 17108 By. / Denise L. Foster, Paralegal Date: October 13, 2004 J - c> Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER, PICCOLA & ALFORD 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax btpa@aft.net Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA V. HOFFMAN MECHANICAL, INC., DEFENDANT : NO. 04-4803 : CIVIL ACTION - LAW CERTIFICATE OF NOTIFICATION I, Leonard Tintner, Esquire, do hereby certify that I served the Defendant, Hoffman Mechanical, Inc., with the Notice of Intent to Take Judgment Non-Pros, sending same by first-class mail, postage prepaid to it, at the following address: CIO F. Stephenson Matthes, Esquire Tucker, Arensburg, P.C. 111 N. Front Street PO Box 889 Harrisburg, PA 17108 A copy of said Notice is attached hereto. BOSWELL, TINTNER, PICCOLA & AL FO By: eonard Tintner., Esquire DATE: November 9, 2004 Leonard Tintner, Esquire Supreme Court I.D. #06559 BOSWELL, TINTNER, PICCOLA & ALFORD 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717) 236-9316 - fax btpa@att.net Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' v. : NO. 04-4803 HOFFMAN MECHANICAL, INC., DEFENDANT : CIVIL ACTION - LAW NOTICE TO: HOFFMAN MECHANICAL, INC., DEFENDANT C/O F. STEPHENSON MATTHES, ESQUIRE DATE: NOVEMBER 9, 2004 YOU ARE IN DEFAULT BECAUSE YOU have failed to file an Answer in this case. Unless you act within ten (10) days from the date of this Notice, a Judgment may be entered against you without a hearing and you may lose your right to sue the Plaintiff and thereby lose property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer, go to or telephone the following 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 l"'? N r A t , ( -r-iT4 f. y f .) 1 C.'T IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA THE DREXEL GROUP, INC., Plaintiff, V. HOFFMAN MECHANICAL, INC., Defendant. No. 04-4803 CIVIL ACTION-LAW ANSWER Plaintiff, Hoffman Mechanical, Inc., by and through its attorneys, F. Stephenson Matthes, Esquire and the law firm of Tucker Arensberg, P.C., files the within Answer to Plaintiffs Complaint and avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. The averments contained in paragraph 4 of Plaintiffs Complaint constitute a conclusion of law to which no response is required. To the extent that a response is required of this answering Defendant to the averments contained in paragraph 4, the same is denied. 5. Admitted in part, denied in part. It is admitted that Plaintiff supplied temporary workers for employment at Defendant's business in 2002, however, it is denied that Plaintiffs workers were employed through August 2002 and strict proof thereof is demanded at trial. 6. Answering Defendant is without sufficient knowledge or information to form a belief as to the truth or veracity of the averments in paragraph 6 of Plaintiffs Complaint. To the extent that an answer is required of this answering Defendant, the same is denied and strict proof thereof is demanded at the time of trial. 7. Admitted. 8. Defendant is without sufficient knowledge or information as to the truth or veracity of the averments contained in paragraph 8 of Plaintiffs Complaint. To the extent that an answer is required of answering Defendant, the same is denied and strict proof thereof is demanded at the time of trial. 9. Defendant is without sufficient knowledge or information as to the truth or veracity of the averments contained in paragraph 9 of Plaintiffs Complaint. To the extent that an answer is required of answering Defendant, the same is denied and strict proof thereof is demanded at the time of trial. 10. Denied. It is denied that any "contract" exists between Plaintiff and Defendant, furthermore, Plaintiff has failed to attach any indicia of or copy of any document which would entitle Plaintiff to any collection expenses, including attorneys' fees and court costs. 11. Denied. It is denied that Defendant has not made payments for amounts properly due and owing and by way of further answer, Defendant disputes any outstanding balance allegedly due to Plaintiff. 12. Defendant is without sufficient knowledge or information as to the truth or veracity of the averments contained in paragraph 12 of Plaintiffs Complaint. To the -2- extent that an answer is required of answering Defendant, the same is denied and strict proof thereof is demanded at the time of trial. By way of further answer, it is denied that Defendant owes Plaintiff the sum of $3,204.38. 13. Denied. It is denied that Defendant has refused to make payment of any amounts properly due and owing to Plaintiff. WHEREFORE, Defendant, Hoffman Mechanical, Inc., respectfully requests this Honorable Court to dismiss Plaintiffs Complaint with prejudice. Respectfully submitted, TU = ARENSBERG, P.C. .? F. Stephenson Matthes PA . . No. 67408 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 Telephone: 717-234-4121 Facsimile: 717-232-6802 Dated: November is , 2004 Attorneys for Hoffman Mechanical, Inc. 73408.1 -3- VERIFICATION AND NOW, comes Emily Hoffman, and verifies that the facts contained in the foregoing Answer are true and correct to the best of her knowledge, information and belief. This Verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities, which provides criminal penalties if a person with intent to mislead makes a written false statement which he does not believe to be true. ZilyHoff n 73408.1 -4- CERTIFICATE OF SERVICE AND NOW, this J!? day of November, 2004, I, Dawn T. Heilman, Secretary to F. Stephenson Matthes, Esquire, for the law firm of Tucker Arensberg, P.C., attorneys for Hoffman Mechanical, Inc., hereby certify that I have this day served the foregoing Answer by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Leonard Tintner, Esquire Boswell, Tintner, Piccola & Alford 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 Dawn T. Heilman -5- T??l t^.) C_ t.? T7 _r' I tlr-. _" ?' ?`? ": i C?' Cf t `. '•. 1.. r 9:. ,?- ,? ? . ? _..? } _ ??? -1 ?; ,i Curtis R. Long Prothonotary (OffICC Of the i3rotbonotarp Cumbertanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 041- YeO,3 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square 0 Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573