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Home My WebLink About02-0897 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SELIGMAN FRIEDMAN & COMPANY, P.C. Plaintiff, DAUBERTON MANOR, INC. Defendant. No. NOTICE TO DEFEND 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 2 Liberty Avenue Carlisle, PA 17013 /f/ (717) 249-3166/i//, Hat r Pastemack ~' Attorney I.D. No.: 58887 208 West Hamilton Avenue, #310 State College, PA 16801-5218 (814) 231-2374 FAX (814) 235-2356 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SELIGMAN FRIEDMAN & COMPANY, P.C. Plaintiff, Ye DAUBERTON MANOR, INC. Defendant. } } No. } } } } } COMPLAINT COMES NOW the Plaintiff, Seligman Friedman & Company, P.C., by and through its attorney, Harvey Pastemack, Esquire, and complains of the Defendant, as follows: JURISDICTION AND VENUE 1. Plaintiff, Seligman Friedman & Company, P.C., is a corporation organized and existing pursuant to the Business Corporation Law of 1988 of the Commonwealth of Pennsylvania (15 Pa. C.S.A.§1101 et seq). It is a domestic Pennsylvania business corporation having a principal registered address of 1027 Mumma Road, Wormleysburg, Pennsylvania 17043. 2. Defendant, Dauberton Manor, Inc., is a corporation organized and existing pursuant to the Business Corporation Law of 1988 of the Commonwealth of Pennsylvania (15 Pa. C.S.A.§1101 et seq). It is a domestic Pennsylvania business corporation having a principal registered address of215 North 26th Street, Camp Hill, Pennsylvania 17011. 3. Plaintiffprovided accounting services to the Defendant in Cumberland County. 4. Pursuant to Rule 1006 of the Pennsylvania Rules of Civil Procedure, the cause of action and transaction which lead to the cause of action arose in the County of Cumberland and therefore jurisdiction and venue are proper in the Court of Common Pleas of Cumberland County. 1 CAUSE OF ACTION 5. Paragraphs 1 through 4 inclusive are hereby incorporated by reference to the same extent as if fully set out herein. 7. The Plaintiff provided accounting services to the Defendant beginning January 1998, continuing through July 1998. 8. Defendant was periodically invoiced for these services but has refused to pay and continues to refuse to pay said invoices totaling $13,151.02. A copy of the outstanding invoices is attached as Exhibit A. 9. As of the date of this filing, the Defendant has refused and continues to refuse to pay the outstanding invoices. 10. WHEREFORE, it is prayed that This Honorable Court order, adjudge and decree that the Defendant pay said invoice totaling $13,151.02. WHERFORE, the Plaintiff in the above action demands judgment against the Defendant, Dauberton Manor, Inc., for past due invoices for services rendered, attorney fees, costs of suit and such other and further relief as This Honorable Court may award in justice and equity. Dated: ~Harv~ Past'emack, Esquire PA Bar ID# 5887 208 West Hamilton Avenue, #310 State College, Pennsylvania 16801-5218 (814) 231-2374 FAX (814) 235-2356 539800 October 25, 2001 Dauberton Manor c/o Mr. George Adams 215 N. 26th Street Camp Hill, PA 17011 STATEMENT OF ACCOUNT AS OF 10/25/2001 PREVIOUS <---ITEMS SINCE 09/28/2001 .... > CURRENT BALANCE INVOICES CREDITS FIN CHG BALANCE 13,151.02 0.00 0.00 0.00 13,151.02 DATE FILE AMOUNT CREDITS BALANCE 01/31/98 700.00 420.50 279.50 01/31/98 250.00 0.00 250.00 01/31/98 600.00 0.00 600.00 01/31/98 268.77 0.00 268.77 01/31/98 550.00 0.00 550.00 01/31/98 '' 37.5.00 0.00 375.00 03/26/98 .2,400.00 0.00 2,400.00 06/10/98 4,600.00 0.00 4,600.00 07/14/98 1,400.00 0.00 1,400.00 Accumulated finance charges 2,427.75 TOTAL DUE $13,151.02 ..................... INVOICE AGING IN MONTHS .................... CURRENT 1 MONTH 2 MONTHS 3 MONTHS 4+ MONTHS 0.00 0.00 0.00 0.00 10,723.27 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SELIGMAN FRIEDMAN & COMPANY, P.C. Plaintiff, VJ DAUBERTON MANOR, INC. Defendant. No. VERIFICATION OF COMPLAINT I verify that the statements made in the foregoing Complaint are tree and correct to the best of my knowledge, information and belief. I understand that false statements are subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-00897 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SELIGMAN FRIEDMAN & COMPANY VS DAUBERTON MANOR INC 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, DEFENDANT DAUBERTON MANOR INC but was unable to locate Them in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , NOT FOUND , as to , DAUBERTON MANOR INC OFFICE HAS NOT BEEN AT HERE FOR 10 YEARS. NOT AT 1013 MUMMA RD WORMLEYSBURG EITHER. Sheriff,s Costs: Docketing 18.00 Service 21.39 Not Found 5.00 Surcharge 10.00 .00 54.39 ~. Thomas Kline~ Sheriff of Cumberland County SELIGMAN FRIEDMAN & CO 03/08/2002 Sworn and subscribed to before me this /~ ~ day of ~ ~2~ A.D. Pr~tMonotary ~