HomeMy WebLinkAbout04-6270ROMA FOOD ENTERPRISES, INC.
Plaintiff
V.
CARLO PALUMBO, Individually and Trading As,
PALUMBO'S PIZZA
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. O L4 - 4ioM nn l :1 U 'L L'--NFJ?
CIVIL DIVISION - LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 an 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, 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
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
ROMA FOOD ENTERPRISES, INC.
Plaintiff
V.
CARLO PALUMBO, Individually and Trading As,
PALUMBO' S PIZZA
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. OY - &,a 7D 01 at
CIVIL DIVISION -LAW
COMPLAINT
The Plaintiff, ROMA FOOD ENTERPRISES, INC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings
this action of Assumpsit against the Defendants to recover the sum of FIVE THOUSAND, NINE HUNDRED TWENTY
DOLLARS AND NINETY-TWO CENTS ($5,920.92), along with interest thereon from November 1, 2004 at the rate of 1.5%
per month, upon a cause of action of which the following is a statement:
The Plaintiff, ROMA FOOD ENTERPRISES, INC., is a corporation organized and existing under the laws
of the State of New Jersey, having its principal office and place of business at 45 Stanford Road, Piscataway, New Jersey
08854
2. The Defendant, CARLO PALUMBO, is an adult individual trading and doing business as PALUMBO'S
PIZZA with an address and place of business at 4729 Old Gettysburg Road, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
3. Plaintiff, at the special instance and oral request of the Defendant, sold and delivered goods, wares and
merchandise to the Defendant as shown on Plaintiff's Statement attached hereto, marked Exhibit "A" and made a part hereof
in the total amount of Four Thousand, Five Hundred Nineteen Dollars and Seventy-Nine Cents ($4,519.79).
4. The prices charged for said goods, wares and merchandise were just and reasonable, were the legal and market
prices therefor and were the prices which the Defendant orally promised and agreed to pay to Plaintiff.
F:\USMSTAMCCP COMPLAINTS\WORK\31033PALUMBO.wpd:06Dec04
Due to Defendant's default in payment of said amount due and owing as aforesaid, interest has been added
to said account in the total amount of Two Hundred Seventy-One Dollars and Nineteen Cents ($271.19).
6. Due to the default of Defendant, and pursuant to the terms and conditions of the Credit Application and
Personal Guaranty executed by Defendant hereto attached, marked Exhibit "B" and made a part hereof, attorney's fees in the
total amount of One Thousand, One Hundred Twenty-Nine Dollars and Ninety-Five Cents ($1,129.95) have been added to
said account.
Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but
Defendant refused and neglected and still refuses and neglects to pay said amount of any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FIVE THOUSAND, NINE HUNDRED
TWENTY DOLLARS AND NINETY-TWO CENTS ($5,920.92), along with interest thereon from November 1, 2004 at the
rate of 1.5% per month.
Respectfully submitted,
KNUPP, KODA BLUM, P.C.
Robert D. Kodak
407 North Front Street
Post Office Box # 11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney ID No. 18041
Attorney for Plaintiff
FAUSEWSTACY\CCP COMPLAINTS\WORK\31033PALUMBO.wpd:06Dec04
.,ROMA F D ENTERR S, INC.
45 STANFORD ROAD,, PISCATAWAY, NJ, 088 4
908-463-ROMA • 1-800-526-ROMA • FAX: 908-356-4852 • TLX: 844296
CREDIT APPLICATION
DATE:
LEGAL NAME: (as used on contractual obligations)
TRADE NAME:
DELIVERY ADDRESS- Li 7
CITY: 1kr Y ae, i re COUNTY STA4: ZIP: 0
BILLING ADDRESS: J
TYPE OF ORGANIZATION: CORPORATE PART RSHIP PROPRIETO S IP
OWNER(s) or PRINCIPAL(s) OF BUSINESS:a PHONE:+ .3 c'? «`??t`? ?
HOME ADDRESS: 4( 22i U c,ar it w ?C C% HOW LONG IN BUSINESS t10
NAME & ADDRESS OF LANDLORD: ?a rtit k5 4 0OJt-,
ESTIMATED AMOUNT OF CREDIT TO BE NEEDED FROM ROMA FOOD FOR A NORMAL WEEKLY PURCHASE:
SOCIAL SECURITY NUMBER: DATE OF BIRTH FEDERAL ID #:
o? - 4 - ?G Q Li - STATE ID #:
SALES TAX ID #:
IF CORPORATION, LIST NAME HOME ADDRESS & HOME PHONE NUMBER OF SHAREHOLDERS
NAME: PHONE #:
ADDRESS:
NAME: PHONE #:
ADDRESS:
REFERENCES:
NAME:
ADDRESS:
NAME:
ADDRESS:
NAME, ADDRESS AND PHONE NUMBER OF YOUR PRINCIPAL SUPPLIERS:
NAME: 'eC" J O PHONE #:
ADDRESS: CITY & STATE:
NAME: PHONE #:
ADDRESS: CITY & STATE:
NAME OF BANK(s) ,
NAME:"
!,l
ADDRESS:' l <. r,?i `(t ': y t + r4 f r
ACCOUNT NUMBER: INDIVIDUAL TO CONTACT:
FINANCIAL STATEMENT ATTACHED: YES ? NO
TERMS AGREEMENT '
The undersigned ("Purchaser") agrees that all purchases made by Purchaser from Roma Food Ent., Inc. or any of its subsidiaries and
affiliated entities ("Seller") are subject to the following terms and conditions.
1. All amounts due for goods and services purchased from Seller are payable at the Seller's distribution facility from which the goods
and services are delivered. Purchaser acknowledges that such amounts are not payable in installments, but are payable in full as
stated herein.
2. All amounts due Seller are payable in accordance with the payment terms granted by Seller's credit department from which the
goods and services are delivered. If any amount due Seller is not paid in accordance with such payment terms, a delinquency
charge of either one and one-half percent (1 112%) per month or the maximum lawful rate permitted to be charged under the
applicable state's law shall be added to the sum due. All payments shall be applied first to court costs (if any), next to expenses
incurred in collecting any amount due, next to accrued interest, and last to principal,
3. Purchaser shall pay Seller a service charge in an amount equal to the greater of $10.00 or 5% of the check balance for all checks
returned by Purchaser's bank, provided, however, that such service charge shall not be due and payable in the event such payment
would result in the violation of the usury laws of the applicable jurisdiction.
4. In the event the account is turned over to an attorney or other agency for collection, or suit is brought on same, or the same is
collected through any judicial proceeding whatsoever, purchaser shall pay all reasonable attorneys' fees and court costs incurred
by Seller.
5. Purchaser shall notify Seller by certified mail of any change of ownership of Purchaser. Purchaser warrants to Seller that all
financial information furnished for the purpose of obtaining credit is true, correct and complete in all material respects, and
Purchaser authorizes Seller to investigate all references furnished pertaining to the credit and financial responsibility of Purchaser.
"PURCHASER"
j ?-
c t t3? v rti?t?
Date (Type or Print Name of Purchaser)
C. 4\
By: X' -cam -?c'_?
a
Sales Representative of Seller Printed Name:
Title:
I INDIVIDUAL PERSONAL GUARANTY
0 , for and in consideration of your extending credit at my
request to (the "Company"), personally guarantee
prompt payment of any obligation of the Company to Roma Food Ent. Inc. and each of its subsidiaries and affiliated entities ("Seller"),
whether now existing or hereinafter incurred, and I further agree to bind myself to pay on demand any sum which is due by the
Company to Seller whenever the Company fails to pay same. It is understood that this guaranty shall be an absolute, continuing, and
irrevocable guaranty for such indebtedness of the Company, and therefore, the undersigned jointly and severally take a full obligation
and responsibility to honor and guarantee, also, all of the conditions described in the above "Terms Agreement."
I expressly waive presentment, demand, protest, notice of protest, dishonor, diligence, notice of default or nonpayment, notice of
acceptance of this guaranty, notice of the extending of any guarantied indebtedness already or hereafter contracted for by the
Company, notice of any modification or renewal of any credit agreement evidencing the indebtedness hereby guarantied, notice of any
renewal or indebtedness hereby guarantied and to all renewals or extensions of such indebtedness. I further waive any right to
require Seller to proceed against, or make any effort at collection of the guarantied indebtedness from, the Company or any other
party liable for such indebtedness.
If the guarantied indebtedness is not paid by me when due, and this guaranty is placed in the hands of an attorney for collection, or
suit is brought hereon, or it is enforced through any judicial proceeding whatsoever, I shall pay all reasonable attorneys' fees and
court costs incurred by Seller.
In the event more than one party executes this Guaranty as a guarantor, then each guarantor agrees to b9Q'PAI and severally
liable for the guarantied indebtedness, and, in all instances herein, the singular shall be construed to ACtGd6 the plura .
Guarartor\
Address: [ fo t ??!??.. U #' o --vi -e
'/7 1-7 1 I
Witn4ssed and Attested by:
P . 1 v
Date:
X
Guarantor
Date:' Address:
Date:
12/09/2004 11:06 000000
DEC 06 '04 03:58PM KNIIPP & KODAK PC
VERIFICATION
PAGE 02
P.5
rL c,e ? L- A N Z c, A ? ," k" zed A ?
Nmcl
of ROMA FOOD ENTERPRISES, INC., verify that the statements made in the aforegoing document are true and
correct. I understand that false statements herein arc made subject to the penalties of 18 Pa. C. S. §4904, relating
to =sworn falsification to authorities.
ROMA FOOD ENTERPRISES, INC.
it
By:
Title. A c C n -
Dated: 1?. I %q
31033
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ROMA FOOD ENTERPRISES, INC.
Plaintiff
V.
CARLO PALUMBO, Individually and
Trading As, PALUMBO'S PIZZA
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-06270
CIVIL DIVISION - LAW
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint filed to the above term and number and forward same to the
Sheriff for service upon Defendants at 10 DAPP LANE, MECHANICSBURG, PENNSYLVANIA
17055.
TO CUMBERLAND County
Prothonotary
Robert D. Kodak Attorney for Plaintiff
Attorney I.D. No. 18041
Dated: Februarv 14, 2005
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2004-06270 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROMA FOOD ENTERPRISES INC
VS
PALUMBO CARLO ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
PALUMBO CARLO but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT , PALUMBO CARLO
4729 OLD GETTYSBURG PIKE
NOT FOUND , as to
MECHANICSBURG, PA 17050
PALUMBO'S PIZZA IS NO LONGER IN BUSINESS.
NO FORWARDING ON FILE AT POST OFFICE.
Sheriff's Costs: So answers__,
Docketing 18.00f ,
Service 10.36
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
43.36 KNUPP KODAK IMBLUM
12/30/2004
Sworn and subscribed to before me
this j0 `- day o 11-i?
A. D.
ProVhdnotary
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2004-06270 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROMA FOOD ENTERPRISES INC
VS
PALUMBO CARLO ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
PALUMBO CARLO T/A PALUMBO'S PIZZA
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
NOT FOUND , as to
the within named DEFENDANT , PALUMBO CARLO T/A PALUMBO'S
PIZZA
4729 OLD GETTYSBURG PIKE
MECHANICSBURG, PA 17050
PALUMBO'S PIZZA IS OUT OF BUSINESS. DINER AT GIVEN ADDRESS.
NO FORWARDING ADDRESS ON FILE AT POST OFFICE.
Sheriff's Costs:
Docketing 6.00
Service .00
Not Found 5.00
Surcharge 10.00
.00
21.00
So answera.:-_ .
f R. Thomas Kline
Sheriff of Cumberland County
KNUPP KODAK IMBLUM
12/30/2004
Sworn and subscribed to before me
this day of?u
.2612',?' A. D.
Pr t onotary
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06270 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ROMA FOOD ENTERPRISES INC
VS
PALUMBO CARLO ET AL
RONALD HOOVER Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according
says, the within COMPLAINT & NOTICE was served upon
to lava,
PALUMBO CARLO _ th
DEFENDANT at 1048:00 HOURS, on the 3rd day of March 2005
at 10 DAPP LANE
MECHANICSBURG, PA 17055 by handing to
ROSA PALUMBO, WIFE
a true and attested copy of COMPLAINT & NOTICE together w th
and at the same time directing Her attention to the contents the leof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 5.18
Affidavit .00
Surcharge 10.00 R. Thomas Kline
33.18 03/04/2005
KNUPP KODAK IMBLUM
Sworn and Subscribed to before By:
me this 7 C?/ day of 7l'ldr
Y lJ?c? A. D.
Prothonota,Ey ^J
Deputy Sheriff
1
SHERIFF'S RETURN - REGULAR
'(!ASE NO: 2004-06270 P
COMMONWEALTH OF PENNSYLVANIA: -
+
COUNTY OF CUMBERLAND _
ROMA FOOD ENTERPRISES INC
VS
PALUMBO CARLO ET AL
RONALD HOOVER Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according o law,
says, the within COMPLAINT & NOTICE was served upon
PALUMBO CARLO T/A PALUMBO'S PIZZA th
DEFENDANT at 1048:00 HOURS, on the 3rd day of March 2005
at 10 DAPP LANE --
MECHANICSBURG, PA 17055 by handing to --?
ROSA PALUMBO, WIFE OF CARLO _
a true and attested copy of COMPLAINT & NOTICE together w' th
and at the same time directing Her attention to the contents the eof.
Sheriff's Costs: So Answers:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
16.00 03/04/2005
BLUM
KNUPP KODAK IM `
Sworn and Subscribed to before By:
MB
me this _Qz_ day of%,,r k h Deputy Sheriff
V..
A.D.
Pr thonotar
ROMA FOOD ENTERPRISES, INC. : IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2004-06270 CIVIL TERM
CARLO PALUMBO, Individually and :
Trading As PALUMBO'S PIZZA : CIVIL ACTION - LAW
Defendants
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT JUDGMENT
Enter judgment in favor of Plaintiff and against Defendant(s) CARLO PALUMBO,
Individually and Trading As PALUMBO'S PIZZA, named for failure to file within the
required time an Answer to the Complaint in the above-captioned case and assess the
Plaintiffs damages as follows:
Amount claimed in Plaintiff's Complaint less payments $920.92
Interest at the rate of 1.5% per month from November 1, 2004 $593.83
Total = $1,514.75
I hereby certify that a written Important Notice of the intent to file this Praecipe was
mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after
the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe
and a copy of the notice is attached.
KODAK & C.
By
Robert D. Kodak, Attorney for Plaintiff
DATED: &I-A4102 Judgment entered and damages assessed as above.
?71, A.
Pro onota
LAW OFFICES OF
KODAK & IMBLUM, P.C.
Robert D. Kodak CAMERON MANSION
Gary J. Imblum 407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
W&Iaw®verizonnet
May 5, 2008
CARLO PALUMBO
10 DAPP LANE
MECHANICSBURG PA 17055
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k
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C
c
s
717.238.7158
RE: Roma Food Enterprises, Inc.
VS: Carlo Palumbo, i/ a/ t/ a Palumbo" s Pizza
No. 2004-06270 Civil Term, Court of Common Pleas
Cumberland County, Commonwealth of Pennsylvania
Our File No. 31033
Dear Mr. Palumbo:
In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are
enclosing herewith a Notice of a Praecipe for Entry of Default Judgment According to
the records as they are found in the Office of the Prothonotary of Cumberland County,
you have not filed responsive pleadings to the Complaint filed against you to the above
term and number, nor has any attorney entered an appearance on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that
if you do not take action as set forth in this Notice, we, at the expiration of time
indicated therein, will request the Office of the Prothonotary of Cumberland County to
enter Judgment against you in the amount as set forth in said Complaint.
Very truly yours,
KODAK & IMBLUM, P.C.
Robert D. Kodak
THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE
RDK/kqb
enclosure
cc: REGAL COLLECTIONS
POST OFFICE BOX 1038
FAIR LAWN NJ 07410-8038
#A484%/PA17470
ROMA FOOD ENTERPRISES, INC.
Plaintiff
v.
FILE
: IN THE COURT OF COMMON P Y
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2004-06270 CIVIL TERM
CARLO PALUMBO, Individually and Trading :
As PALUMBO'S PIZZA : CIVIL ACTION - LAW
Defendants
IMPORTANT NOTICE
TO: CARLO PALUMBO T/A PALUMBO'S PIZZA , Defendant(s)
DATE OF NOTICE: MAY 5, 2008
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 (10) 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
LAW OFFICES OF
KODAK & 1MBLUM, P.C.
Robert D. Kodak CAMERON MANSION
Gary J. Imblum 407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
kkLIaw@verizon.net
May 5, 2008
CARLO PALUMBO
T/A PALUMBO S PIZZA
10 DAPP LANE
MECHANICSBURG PA 17055
Telephone
5958
F I L E 04?1
RE: Roma Food Enterprises, Inc.
VS: Carlo Palumbo, i/a/t/a Palumbo's Pizza
No. 2004-06270 Civil Term, Court of Common Pleas
Cumberland County, Commonwealth of Pennsylvania
Our File No. 31033
Greetings:
In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are
enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to
the records as they are found in the Office of the Prothonotary of Cumberland County,
you have not filed responsive pleadings to the Complaint filed against you to the above
term and number, nor has any attorney entered an appearance on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that
if you do not take action as set forth in this Notice, we, at the expiration of time
indicated therein, will request the Office of the Prothonotary of Cumberland County to
enter Judgment against you in the amount as set forth in said Complaint.
Very truly yours,
KODAK & IMBLUM, P.C.
Robert D. Kodak
RDK/kqb
enclosure
cc: REGAL COLLECTIONS
POST OFFICE BOX 1038
FAIR LAWN NJ 07410-8038
#A484%/PA17470
ROMA FOOD ENTERPRISES, INC.
Plaintiff
v.
FILE COPY
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2004-06270 CIVIL TERM
CARLO PALUMBO, Individually and Trading :
As PALUMBO'S PIZZA : CIVIL ACTION --LAW
Defendants
IMPORTANT NOTICE
TO: CARLO PALUMBO. Defendant(s)
DATE OF NOTICE: MAY 5, 2008
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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YU 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
401.
-
a4 .
- n
,? r.
p
ROMA FOOD ENTERPRISES, INC.
Plaintiff
V.
CARLO PALUMBO, Individually and
Trading As PALUMBO`S PIZZA
Defendants
TO: CARLO PALUMBO , Defendant(s)
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-06270 CIVIL TERM
CIVIL ACTION - LAW
You are hereby notified that on ? une a , 20pj the following
(Judgment) has been entered against you in the above-captioned case.
MgMent enhmed in the amount of $1,514.75.
DATE:
P ono
I hereby certify that the name and address of the proper person(s) to receive this
notice is:
CARLO PALUMBO
10 DAPP LANE
MECHANICSBURG PA 17055
ROMA FOOD ENTERPRISES, INC.
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-06270 CIVIL TERM
CARLO PALUMBO, Individually and :
Trading As PALUMBO'S PIZZA : CIVIL ACTION - LAW
Defendants
TO: ?ARLQ PALUMB4A PALUMBQ'S PIZZA, Defendant(s)
You are hereby notified that on ?,)ne A4 , 200L the following
(Judgment) has been entered against you in the above-captioned case.
j ant entered in the am t of $1MC75.
DATE:
?144" -
Pr onota
I hereby certify that the name and address of the proper person(s) to receive this
notice is:
CARLO PALUMBO
T/A PALUMBO S PIZZA
10 DAPP LANE
MECHANICSBURG PA 17055
ROMA FOOD ENTERPRISES, INC.
Plaintiff
v
CARLO PALUMBO individually and
trading as PALUMBO'S PIZZA
Defendant(s)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004-06270
CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned Case as being satisfied in full.
TO: Cumberland County
Prothonotary
Date: July 8, 2008 'rr
Robert D. Kodak, Esquire Attorney for Plaintiff
I.D. No. 18041
F
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