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Home My WebLink About12-4773PENNSYLVANIA CIVIL ACTION - LAW RITE AID CORPORATION, Plaintiff V. 3 Ci i No. Ia9A RONALD BROCK, Defendant NOTICE TO DEFEND C) rn Nr w 1 ?o -0 C- ) -n ?o °s y2 ? a -c -4 YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST T CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITH TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERINC WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WI' THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YC YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT Y( AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FORTH NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM 1 RELIEF REQUESTED BY THE PLAINTIFFS. YOU MAY LOSE MONEY OR PROPERTY 1 OTHER RIGHTS IMPORTANT TO YOU. A R R YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO N T HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFI E CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROM E YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES J'O ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. I LIV a?B (rya IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RITE AID CORPORATION, Plaintiff V. RONALD BROCK, Defendant No. 120791.901 COMPLAINT Plaintiff, RITE AID CORPORATION, by and through its counsel, Demetrios Tsarouhis, files this Complaint and avers as follows: 1. Plaintiff, RITE AID CORPORATION, ("Plaintiff') is a Pennsylvania corporation having its principal and registered office address at 30 Hunter Lane , Camp Hill PA 17011. 2. Defendant, RONALD BROCK, is an adult individual resident of GA maintains an address at 1440 OCEAN BLVD APT 102, SAINT SIMONS GA 31522-3838. 3. On or about 9/28/2006, Plaintiff and Defendant executed an Offer Letter w Defendant agreed to remain employed as a pharmacist for two (2) years in consideration for payment of a signing bonus. Attached hereto and marked as Exhibit "A" is a true and copy of the Offer Letter entered into between both parties. 4. As part of the employment compensation, Plaintiff agreed to pay to De $5000.00 as a signing bonus. 2 5. The signing bonus was subject to certain conditions in order to fully vest. 6. In order for the bonus amount to fully vest, Defendant had to meet certain terms and conditions as set forth in the employment agreement. 7. Defendant was required to remain employed with the Plaintiff for two (2) from the date of employment. 8. The Defendant never met the certain terms and conditions as set forth in the Letter. 9. Subject to the terms of a Promissory Note executed by the parties, D agreed to repay any signing bonus amounts received 10. As such, the signing bonus paid by Plaintiff to Defendant was wrongfully and the Defendant must pay the same back to Plaintiff. COUNTI BREACH OF CONTRACT 11. Plaintiff incorporates the allegations of every paragraph enumerated above Complaint as if said paragraphs were fully set forth here at length. 12. On or about 9/28/2006, Plaintiff entered into a contract with Defendant. 13. Subsequently Defendant breached the contract by failing to meet the terms and conditions as set forth in the contract. 14. The signing bonus paid under the contract was not earned by the Defendant Defendant failed to remain employed by Plaintiff for the full term of service set forth in the Letter. As such, the Defendant must now return said signing bonus to the Plaintiff. 15. The Promissory Note allows for reasonable attorneys fees to be collected in event of default. In the instant matter, reasonable attorneys' fees equals $500.00. d is 3 WHEREFORE, Plaintiff, RITE AID CORPORATION, respectfully requests that judgment be entered against Defendant RONALD BROCK as follows: a) Judgment in the amount of $5000.00; b) Interest at the per diem rate of $0.82 from the date of filing Complaint until the date of Judgment; C) Court Costs; and d) All other amounts which this Court deems just and proper. COUNT II Alternative to Count I - Unjust Enrichment 12. Plaintiff incorporates the allegations of every paragraph enumerated above Complaint as if said paragraphs were .fully set forth here at length. 13. At Defendant's request, Plaintiff conferred a benefit upon Defendant by givi signing bonus to the Defendant. 14. Defendant received and accepted the benefit of the signing bonus provided Plaintiff. 15. At all times material hereto, Defendant was aware that Plaintiff was extending aforesaid signing bonus to Defendant. 16. At all times material hereto, Defendant, with the aforesaid knowledge, Plaintiff to provide said signing bonus and to incur damages. 17. At all times material hereto, Defendant was unjustly enriched by retaining I benefit of receiving said bonus without paying Plaintiff the unpaid balance. 18. Allowing Defendant to retain the benefit of the signing bonus would be unjust. ?a by 4 19. By reason of the aforesaid unjust enrichment of Defendant at Plaintiffs expen?e, a contract exists between Plaintiff and Defendant and Defendant is obligated to pay Plaintiff! the quantum meruit value of the bonus amount described in the exhibit attached hereto in the am?unt of $0.00. WHEREFORE, Plaintiff, RITE AID CORPORATION, respectfully requests that judgment be entered against Defendant as follows: a) Judgment in the amount of $5000.00; b) Interest at the per diem rate of $ 0.82 from the date of filing Complaint until the date of Judgment; C) Court Costs; and d) All other amounts which this Court deems just and proper. Respectfully Submitted, KEIFER & TSAROUHIS, LLP 6??4j Z??- DEMETRIOS H. TSAROUHIS I.D. #88513 Attorney for Plaintiff 21 S. 9` Street-Suite 200 Allentown, PA 18102 610-439-1500 Date: July 20, 2012 5 August 7, 2006 Ron Brock 1970 New High Shoals Rd. Watkinsville Ga 30677 Brock6000tabellsouth.net ?=D. V-M tx5`L2. Dear Ron: We are pleased to confirm our offer to you for the position of [Full Time Registered Floating Pharmacist) in the (Shippy) District. I wiah to extend my personal welcome to you as a member of the Brooks Eckerd Pharmacy tram in (East Atlanta District). Your date of hire is anticipated to be (September 2006). The details of this offer are described below- • SalAry: You will receive an hourly rate of $49.00. Your next scheduled monetary review will be August 20+)7 • Sign On Boons: Upon Completing this employment offer, we will issue you a $(10.000.00) sign on bonus for a (2 year) commitment. Please note that the Sign On Bonus will be paid to you in 2 installments (less applicable taxes) as described below- PMyment 3oheduta ?- 0 First installment Amount: _500000 Date paid to you: Oct W06 v ` Second Installment Amount: SQN QQ Date paid to you: Oct 2007 of Third Installment Amount: Dace paid to you. All instalment payments are contingent upon maintaining a satisfactory performance rating. • Vacation: Beginning (September 2005), you will be eligible for 4 weeks of vacation, which will be prorated for the balance of this calendar year. Tbowm er, you will be eligible for 4 weeks of vacation. Please note that if you leave the company before completing 12 months of continuous service, regardless of the mason, any unused vacation provided under this special vacation eligibility will be forfeited, and. you will only receive payment for hours earned under our normal vacation schedule. For additional information regarding our company's cc Exhibit " standard vacation schedules and additional benefits available to you, please see "Benefits at a Glance" which has been enclosed with this letter. COBRA Relsabwwmomtt You are also eligible for 90 days of COBRA reimbursement, which is considered taxable income. You must furnish me with a copy of your COBRA invoice as well ss a copy of your canceled cheek(s) as proof of payment in order to receive any reimbursements. The amount of each reimbursement will be the difference between your contribution to your former employee's insurance program and the COBRA amount that you pay to continue coverage. In accepting this offer, you acknowledge that Brooks Eckerd Pharmacy is an "at--will" employer and that this letter does not represent and should not be considered an employment contract. In order to accept the terms of this offer, pleam sign and date the enclosed copies of this letter in the.spatce-provided and return the origuaal to my attention at (3469 Lawrenceville Hwy Suite 100 Tucker Ga. 30084 before yotr Ifine Date and retain a copy for your files. The terms offered In this agreement shall be cowidered null and void if not aced by August 15, 2006. (no more than 30 days from the date of the letter). (Ron), if you have any questions please give me a call at (444-290-9759). Sincerely, (Cal Isaacs) Regimal Recruiter A2knowlamud and Agreemtent I agree to reimburse Brooks Eckerd Pharmacy for the M amount paid to me as a Sign On Bonus should any of the following situations occur. (a) I terminate my employment with the Brooks &Aerd Pharmacy within 24 months of the Agreement Date, or (b) Brooks Pharmacy terminates my employment for any reason within 24 months of the Agreement men or (c) I am no longer employed in a full time capacity as a Registered Pharmacist within 24 months of the Agreement Dec. I agree in the event it becomes necessary to collect the Sign On Bonus as noted above in (a), (b), or (c) that Brooks Ecketd Phamacy may deduct this money from my tact pay check (s), and the balance, if any, will be paid by .rue within thirty days from my date of termination or change in status. I accept Brooks Eckerd Pharmacy's offer of the position of (Registered Pharmacist) in accordance with the terns of this letter. I Sigeatore Date P..4 ?.- VERIFICATION I, Demetrios H. Tsarouhis, attorney for Plaintiff, verify that the statements contained in the aforementioned Complaint are true and correct based on my communications with my client. I make this verification because my client is unavailable to sign this document at this time. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ec. 4904 relating to unworn falsification to authorities. Date: July 20, 2012 Demetrios H. Tsarouhis, Esquire 6 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION -LAW RITE AID CORPORATION, Plaintiff V. No. 12-4773 =' MM C- RONALD BROCK =M , Defendant, rv � 120791.001 .3 C:� Z:-- PRAECIPE TO REINSTATE ° Y ch TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly reinstate the above captioned Complaint. DEMETRIOS H. TSAROUHIS Attorney for Plaintiffs Attorne ID # 88513 21 S. 9 Street Allentown, PA 18102 DATE: June 13, 2013 I do hereby certify that the within is a true and correct copy of the original filed in this action. Demetrios H Tsarouhis t � a� Q or)C1 oL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F FICr- Sheriff OTHOtA - E PR Of THE IO Jody S Smith Chief Deputy 7013 JUL Richard W Stewart Solicitor OFFICE OF THE SHERIFF CUI SERLANVN AUNTY PENNS YL 'A Rite Aid Corporation Case Number VS. 2012-4773 Ronald Brock SHERIFF'S RETURN OF SERVICE 06/24/2013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states that he served the within Complaint&Notice upon the within named defendant, Ronald Brock, in the following manner: On June 24,2013 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint&Notice to the defendant's last known address of 1440 Ocean Blvd., Unit 102, Sain Simons Island, GA 31522. The certified mail return receipt card was received by the Cumberland County Sheriffs Office signed by S. Brock on July 1,2013. 06/25/2013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states that he served the within Complaint&Notice upon the within named defendant, Ronald Brock, in the following manner: On June 25, 2013 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint&Notice to the defendant's last known address of 1970 New High Shoals Road,Watkinsville, GA 30677. The certified mail return receipt card was returned by The USPS marked"Return to Sender, Unclaimed, Unable to Forward". SHERIFF COST: $56.62 SO ANSWERS, July 16,2013 RbNW R ANDERSON, SHERIFF SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY ■ Complete items 1,2,and 3.Also complete A. Sal ature item 4 if Restricted Delivery Is desired. ❑Agpmt ■ Print your name and address on the reverse CKddressee so that we can return the card to you. B.WReve, by(,Printed,Name) C. D a of Delivery ■ Attach this card to the back of the mailpiece, or on the front If space permits. Lal D. Is defiviry address different fro rA item 1? 13 fes 1. Article Addressed to: If YES,enter delivery address below: ❑No Ronald Brock 1440 Ocean Blvd. q7 73 Unit 102 3. Service Type Saint Simons Island,GA 31522 ❑Certified Mail ❑Express Mail ❑Registered ❑Reftim Receipt for Merchandise ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7007 0710 0003 2210 3450 (rransfer from service labeg Ps Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheri t i ,��.� I -: ff 99 �� ff �r 1 T 0 , Jody S Smith Chief Deputy I `�' JUL I AEI Richard W Stewart S = .. ¢Fl.MBERLAW CO Solicitor I PENNSYLVANIA Rite Aid Corporation Case Number vs. 2012-4773 Ronald Brock SHERIFF'S RETURN OF SERVICE 06/24/2013 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within Complaint& Notice upon the within named defendant, Ronald Brock, in the following manner: On June 24, 2013 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint&Notice to the defendant's last known address of 1440 Ocean Blvd., Unit 102, Sain Simons Island, GA 31522. The certified mail return receipt card was received by the Cumberland County Sheriffs Office signed by S. Brock on July 1, 2013. 06/25/2013 Ronny R Anderson, Sheriff,who being duly sworn according to law, states that he served the within Complaint& Notice upon the within named defendant, Ronald Brock, in the following manner: On June 25, 2013 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint& Notice to the defendant's last known address of 1970 New High Shoals Road, Watkinsville, GA 30677. The certified mail return receipt card was returned by The USPS marked"Return to Sender, Unclaimed, Unable to Forward". SHERIFF COST: $56.62 SO ANSWERS, 4—�� - July 16, 2013 RONW R ANDERSON, SHERIFF SENDER and 3.Also complete 7B. RW,,re • Complete Items 1,2, ❑ item 4 If Restricted Delivery.is desired. • Print your name and address on the reverse t dresses so that we can return the card to you. d by( n ted N ) C. D of Delivery • Attach this card to the back of the mailpiece, or on the front If space permits. D. Is dav&y address different ftmA Item 1? ❑f8s 1. Article Addressed to: If YES,enter delivery address below: ❑No Ronald Brock q77,3 1440 Ocean Blvd. (��0� - Unit 102 3. service Tips Saint Simons Island, GA 31522 ❑Certilm Mail ❑Evress mail ❑Registered ❑Return Receipt for Merchandise ❑Insured Mail ❑C.O.D. 4. Rest icted Delivery?Pit Fee) ❑Yes 2. ArlicleNumber ij 7007 2710 0203 2212 3450 omsfer from servlce M* PS Forfii 3811 Febrfuarl 20104` D f#aarrn Receipt 102595-M 4&1540 tsao -- _ U.S.POSTAGE>>PITNEY aOwEs �.�.��.. ZIP 17013 $ 006-310 02 1YY COUNTY OF CUMBERL 0001368848 JUN 25 2093 Office of The Shea 7007 103 Q003 2210 ��q� 1 Courthouse Square, Rm. 303 y Carlisle, Pennsylvania 17013 Ronald Brock `�- 1970 New Hi h Shoals Road � Watkinsvill 1 7f)1 -A zMA1ciI , I I i SECTION SENDER: COMPLETE THIS SECTION COMPLETE THIS ON DELIVERY ■ Complete Items 1,2,and 3.Also complete nature I item 4 If Restricted Delivery Is desired. X ❑Agent i ■ Print your name and address on the reverse ❑Addressee so that we can retum the card to you. eceived by(Printed Name) C.Date of Delivery I ■ Attach this card to the back of the mailpiece, or on the front If space permits. D. Is delivery address dHferentlrom item 11 13 Yes 1. Article Addressed to: ' r If YES,enter delivery address below: ❑No I Ronald Brock 1970 New High Shoals Road 3. Service Watkinsville GA 30677 certified Mall �pre nall I `' i v ❑Registered ❑Return Receipt for Merchandise O ❑Insured Mail ❑C.O.D. 4. Restrkted Delivery?(Extra Fee) ❑Yes i 12. Article Number 7407 0710 0003 2210 3443 I i jj[# (( j Ilij� [ff l! i P$Form ebruary 2bOd Domestic Return Receipt 10¢ 02 M t5ao i. Cvpb g�Yn C1 COURT OF COMMON PLEAS OFACOUNTY, PENNSYLVANIA CIVIL ACTION-LAW RITE AID CORPORATIONa . Plaintiff r-- V. No. 12-4773 RONALD BROCK :Z CD r Defendants 01 . 120791.001 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY OF SAID COURT: Enter Judgment in favor of Plaintiff and against: RONALD BROCK for want of Answering the Complaint and Entry of a Defense. Assess damages as follows: Debt $5,000.00 TOTAL $5,000.00 ® I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain for the complaint. ® Pursuant to Pa.R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ® Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intent to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of notice is attached. DATE: ` �" TSAROUHIS Attorney for Plaintiffs 21 S. 9 Street Allentown, PA 18102 610-439-1500 Attorney ID 88513 1 2013, JUDGMENT IS EN RE - S AB E. NOW, D >. Prothonotary 400 By: � 1 � *-1li.5p� Ck:% )uia V-4 ag44►, N10'�i(e 1ACLV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION—LAW RITE AID CORPORATION, Plaintiff V. : NO. 12-4773 RONALD BROCK, Defendant 120791.001 To: RONALD BROCK 1440 OCEAN BLVD APT 102 SAINT SIMONS GA 31522-3838 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, 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 ELIG103LE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 34 S. Bedford Street Carlisle,Pennsylvania- telephone number 717-249-3166 Respectfully Submitted, DEMETRIOS H. TSAROUHIS Attorney for Plaintiff Attorney ID#88513 21 S. 90'Street Allentown, PA 18102 Tel: (610)439-1500 Date: July 22, 2013 IN THE COURT OF COMMON PLEAS OF ACOUNTY, PENNSYLVANIA CIVIL ACTION-LAW RITE.AID CORPORATION Plaintiff V. : No. 12-4773 RONALD BROCK Defendant 120791001 NOTICE OF FILING JUDGMENT To: RONALD BROCK 1440 OCEAN BLVD APT 102 SAINT SIMONS GA 31522-3838 Pursuant to Pennsylvania Rule of Civil Procedure 236,you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. + Money Judgment. If you have any questions concerning this notice, please call Attorney Demetrios H. Tsarouhis at this telephone number: 610-628-2440, or, you may contact Attorney Demetrios H. Tsarouhis, Esq. via written correspondence at 21 S. Stn Street, Allentown, PA 18102. DAT : ,Prothonotary IN THE COURT OF COMMON PLEAS OFACOUNTY, PENNSYLVANIA CIVIL ACTION-LAW RITE AID CORPORATION Plaintiff V. No. 12-4773 RONALD BROCK Defendants 120791.001 CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: The address of the plaintiff,judgment creditor, is 30 Hunter Lane, Camp Hill PA 17011, and the last known address of the defendant(s),judgment debtor(s) is as follows: RONALD BROCK 1440 OCEAN BLVD APT 102 SAINT SIMONS GA 31522-3838 DATE. DETRl. TSAROUHIS Attorney for Plaintiffs 21 S. 9 Street Allentown, PA 18102 610-439-1500 Attorney ID 88513 IN THE COURT OF COMMON PLEAS OF A COUNTY, PENNSYLVANIA CIVIL ACTION-LAW RITE AID CORPORATION Plaintiff V. No. 12-4773 RONALD BROCK Defendants 120791.001 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF LEHIGH 1, Demetrios H. Tsarouhis, being duly swom according to law, deposes and says that he is the attorney of plaintiffs, that he is authorized to make this affidavit on behalf of plaintiffs; that the above-named defendant RONALD BROCK reside(s) at 1440 OCEAN BLVD APT 102, SAINT SIMONS GA 31522-3838 ; and that the defendants are not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Service Members Civil Relief Act and the amendments thereto. Demetrios H. Tsarouhis, Attorney for Plaintiff Swom and subscribed Before me this70*,day of 20130 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Donald Saunders Litman,Notary Public Towarnencin Up.,Montgomery CGWy My commission Expires September 11,2016