HomeMy WebLinkAbout14-6825 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CLEVELAND BROTHERS EQUIPMENT CIVIL DIVISION
CO.,INC., No. ll��� t „ ?A s et-u
Plaintiff,
TYPE OF PLEADING:
VS.
PRAECIPE FOR ENTRY OF
WILSON LAWN &PROPERTY CARE, LLC; JUDGMENT PURSUANT TO
and CHRISTOPHER WILSON a/k/a CHRIS CERTIFICATION OF DOCKET r
WILSON, individually and now or formerly ENTRIES
t/d/b/a WILSON LAWN & PROPERTY CARE,
WILSON CONSTRUCTION ASSOCIATES, .'
LLC, WILSON 1 ARDSCAPE WORKS, and
WILCOMM COMMUNICATIONS,
•a,te c'-)
Defendants. '" p
FILED ON BEHALF OF: - ..
CLEVELAND BROTHERS EQUIPMENT
CO., INC., PLAINTIFF
COUNSEL OF RECORD FOR THIS
PARTY:
Donald L. Phillips, Esquire
PA I.D. 901339
Ann E. L. Shapiro, Esquire
PA I.D. #35166.
DONALD L. PHILLIPS, P.C.
Suite 800, Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 281-1977
Attorneys' Firm I.D. #0327
ot
at
COPY OF DOCKET ENTRIES
COMMONWEALTH OF PENNSYLVANIA)
SS.
ALLEGHENY COUNTY )
Among the Records and Proceedings of the Court of Common Pleas in
and for the County of Allegheny,and Commonwealth of Pennsylvania,the following is a true and correct
copy of the Docket Entries at No. AR-14-001309
DOCKET ENTRY
CLEVELAND BROTHERS EQUIPMENT CO.,INC.
VS
WILSON LAWN&PROPERTY CARE,LLC;AND CHRISTOPHER WILSON a/k/a CHRIS WILSON,individually and now or
formerly t/d/b/a WILSON LAWN&PROPERTY CARE,WILSON CONSTRUCTION ASSOCIATES,LLC,
WILSON HARDSCAPE WORKS AND WILCOMM COMMUNICATIONS.
I,Kate Barkman,Director of the Department of Court Records
of the Court of Common Pleas in and for said County,certify that the foregoing is a full and
correct copy of the Docket Entries wherein Cleveland Brothers Equipment Co.,Inc.
Plaintiff(s)and Wilson Lawn&Property Care,LLC;and Christopher
Wilson a/k/a Chris Wilson, individually and now or formerly t/d/b/a Wilson Construction Associates,LLC,Wilson Hardscape Works and
Wilcomm Communications Defendant(s);as the remains of record
before the said Court,at No, AR-14-001309
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the said Court,the
18th day of NOVEMBER 20 14 \
4
D'REC"!'OR OF TH ' E ARTMEENNT/OF COURT RECORDS.
Certified b
_CLERK
i
No. AR-14-001309 `f
CLEVELAND BROTHERS EQUIPMENT CO., INC.
vs
WILSON LAWN & PROPERTY CARE, LLC; and CHRISTOPHER WILSON a/k/a CHRIS
WILSON, individually and now or formerly t/d/b/a WILSON LAWN & PROPERTY CARE,
WILSON CONSTRUCTION ASSOCIATES, LLC, WILSON HARDSCAPE WORKS, and
WILCOMM COMMUNICATIONS
EXEMPLIFICATION OF RECORD
At No. AR-14-001309
from the Court of Common Pleas, in and for the County of Allegheny, Pennsylvania
; f .
DEBT'-- $33,258.36
INTEREST FROM
-. P__-LLEGHENY COUNTY COSTS $431.00
THIS RECORD $20.00
DONALD L. PHILLIPS, ESQUIRE
ATTORNEY FOR PLAINTIFF
Home
Allegheny County - Department of Court Records
Civil/Family Division Docket Report
AR-14-001309 Cleveland Brothers Equipment vs Wilson Lawn & Prop
Run Date: 11/18/2014
Run Time: 09:30:15 AM
Court Type: Arbitration
Case Type: Contract- Debt Collection Related Cases:
Judge: No Judge Jury Requested: No
Current Status: Bill of Costs Amount In Dispute: $ .00
Parties
- Litigants --
ID11-Name IIFName 19 Type Address Phone Attorney
@ 1462515
Cleveland Brothers ---
Plaintiff 4565 William Penn Highway -- Phillips
Equipment Company Inc. Murrysville PA 15668 ❑ Donald L,
@2048616 Wilson Christopher Defendant 7-C N. 21st Street Camp Hi
ll
A 17011
@2048615 1wilson21s Lawn & Property Care �a Defendant 137-C N. t Street Camp Hill -- __
LL
PA 17011
-- Attorney --
ID LName FName MI Type Address Phone
01339 Phillips Donald Plaintiff's �[Suite 800 Lawyers Building 428 Forbes Avenue 428 Forbes Avenue (412)
Attorney ittsburgh PA 15219 2811977
-- Non Litigants --
ID
11-Name FName MI Type � Address Phone
ARBC Arbitration Center Arbitration Center 414 Grant Street Courtroom 2 7th Floor Pittsburgh PA 15219
Alternative Names
ID Name Alternative Name
@2048616 --][Wilson Christopher lWilson aka Chris
@2048616 Wilson Christopher 1wilson Lawn & Property Care itdba
@2048616 Wilson Christopher Wilson Construction Associates LLC itdba
@2048616 Wilson Christopher IWilson Hardscape Works itdba
@2048616Wilson Christopher Wilcomm Communications itdba
Docket Entries
Filing Docket T e Docket Text
Date yp Filing Party
��� Cleveland Brothers
r
3 r
03/19/2014 Complaint Count #1: $23,506.74. Plus costs/interest/attorney fees. Hearing date 05/23/14. Equipment
Company inc.
Christopher Wilson was served by Served - Adult Agent or person in charge of
Defendants) office or usual place of business Service Upon Christopher
Cleveland Brothers
04/16/2014 Sheriff Return Wilson with Complaint on 3/27/2014. Served Stuart Wilson Operations Equipment
Manager Company Inc.
Wilcomm Communications itdba was served by Served -Adult Agent or person
in charge of Defendant(s) office or usual place of business Service Upon Cleveland Brothers
04/16/2014 Sheriff Return p
Wilcomm Communications with Complaint on 3/27/2014. Served Stuart Wilson Equipment
Operations manager Company Inc.
EHeja
urnment of Dated 05/21/2014. Case continued to 09/22/2014 at 09:00 a.m., Arbitration Wilson Lawn &
05/21/2014 ing Center Property Care LLC
Cleveland Brothers
09/18/2014 Bill of Costs Equipment
Company Inc.
09/18/2014 -------------------------------
=DefaultIn default of an answer in the amount of$33,258.36. Certification of mailing of Cleveland Brothers
10 day notice on 04/21/14 upon Defendants. Notice of judgment sent. Equipment
Company Inc.
Judgment Against
ID Type Name Amount Satisfied Docket Filing Date
@2048616 Defendant Wilson Christopher 33258.36 Default Judgment 09/18/2014
@2048615 Defendant Wilson Lawn & Property Care LLC 33258.361 = Default Judgment 09/18/2014
Judgment For
ID Type Name Amount Docket Filing Date
@ 1462515 Plaintiff Cleveland Brothers Equipment Company Inc. 33258.36 Default Judgment 09/18/2014
Event Schedule _
Event Scheduled Event Date
Arbitration Hearing 9/22/2014
Arbitration Hearing 5/23/2014
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
CLEVELAND BROTHERS EQUIPMENT ARBITRATION DIVISION
CO., INC.,
No. AR 14-001309
Plaintiff,
TYPE OF PLEADING:
vs.
PRAECIPE FOR ENTRY OF
WILSON LAWN &PROPERTY CARE, LLC; DEFAULT JUDGMENT
and CHRISTOPHER WILSON a/k/a CHRIS
WILSON, individually and now or formerly
t/d/b/a WILSON LAWN & PROPERTY CARE,
WILSON CONSTRUCTION ASSOCIATES,
LLC, WILSON 1 ARDSCAPE WORKS, and
WILCOMM COMMUNICATIONS,
Defendants.
f
FILED ON BEHALF OF:
CLEVELAND BROTHERS EQUIPMENT
CO., INC., PLAINTIFF
COUNSEL OF RECORD FOR THIS
PARTY:
Donald L. Phillips, Esquire
PA I.D. #01339
LLI Ann E. L. Shapiro, Esquire
--� ' PA I.D. #35166
LLI
V) DONALD L. PHILLIPS, P.C.
Suite 800, Lawyers Building
428 Forbes Avenue
Pittsburgh, PA
(412)281-1977
Attorneys' Firm I.D. #0327.
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
ARBITRATION DIVISION
CLEVELAND BROTHERS EQUIPMENT )
) No. AR 14-001309
CO.,INC.,
Plaintiff, )
vs. )
WILSON LAWN&PROPERTY CARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
WILSON, individually and now or formerly )
t/d/b/a WILSON LAWN &PROPERTY CARE, )
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON HARDSCAPE WORKS, and )
WILCOMM COMMUNICATIONS, )
Defendants. )
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE DIRECTOR OF COURT RECORDS:
Enter judgment in favor of Plaintiff, Cleveland Brothers Equipment Co., Inc., and against
Defendants, WILSON LAWN & PROPERTY CARE, LLC; and CHRISTOPHER WILSON a/k/a
CHRIS WILSON, individually and now or formerly t/d/b/a Wilson Lawn & Property Care, Wilson
Construction Associates, LLC, Wilson Hardscape Works, and Wilcomm Communications, in default
of an answer, in the amount of$33,258.36, liquidated as follows:
Principal balance claimed in Complaint: $ 23,506.74
Service charges of 1.5%per month
from October 14, 2013 (11 months): 3.878.61
Subtotal: $ 27,385.35
Reasonable attorneys fees calculated at
20%of the Subtotal 5,477.07
Costs of suit(inc.judgment entry) 395.94
TOTAL L33,258.36
DONALD L. PHILLIPS, P.C.
Ann E. L. apiro, soaire
Attorney for Plaintiff
• IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
ARBITRATION DIVISION
CLEVELAND BROTHERS EQUIPMENT )
'No.
) AR 14-001309
CO., INC.,
Plaintiff, )
vs. )
WILSON LAWN & PROPERTY CARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
W,!."'*1Njndiyidually and now or formerly )
t/d/b/a WILSON LAWN & PROPERTY CARE,)
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON HARDSCAPE WORKS, and )
WII..COMM-COMMUNICATIONS, )
Defendants. )
TO: Wilson Lawn & Property Care, LLC
1600 Hummel Avenue
Camp Hill, PA 17011
DATE OF NOTICE: APRIL 21, 2014
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
MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
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:
Lawyers Referral Service
Allegheny County Bar Association
I I" Floor,Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 261-5555
Ann E. L. Shapiro, Esquire
PA. ID # 35166
DONALD L. PHILLIPS, P.C.
Suite 800, Lawyers.Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 281-1977
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
ARBITRATION DIVISION
CLEVELAND BROTHERS EQUIPMENT )
CO., INC., ) No. AR 1.4-001309
Plaintiff, )
vs. )
WILSON LAWN & PROPERTY CARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
WILSON, individually and now or formerly )
t/wb/a WILSON LAWN & PROPERTY CARE, )
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON HARDSCAPE WORKS, and )
WILCOMM COMMUNICATIONS, )
Defendants. )
TO: Christopher Wilson a/k/a Chris Wilson, i/and now or formerly
t/d/b/a Wilson Lawn & Property Care, Wilson Construction Associates, LLC,
Wilson Hardscape Works, and Wilcomm Communications
1600 Hummel Avenue
Camp Hill, PA 17011
DATE OF NOTICE: APRIL 21,2014
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 MAYBE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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:
Lawyers Referral Service
Allegheny County Bar Association
11" Floor, Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 261-5555
Ann E. L. Shapiro, Esquire
PA. ID # 35166
DONALD L. PHILLIPS, P.C.
Suite 800, Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
(412) 281-1977
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
ARBITRATION DIVISION
CLEVELAND BROTHERS EQUIPMENT )
CO., INC., ) No. AR 14-001309
Plaintiff, )
vs. )
WILSON LAWN & PROPERTY CARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
WILSON, individually and now or formerly )
t/d/b/a WILSON LAWN & PROPERTY CARE,)
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON I-IARDSCAPE WORKS, and )
WILCOMM COMMUNICATIONS, )
Defendants. )
VERIFICATION OF NON-MILITARY SERVICE
I, Ann E. L. Shapiro, on advice and belief hereby swear or affirm that the above-named
Defendant is not presently in the active military service of the United States of America and that
Defendant is not a member of the Army of the United States, the United States Navy, the United
States Marine Corps, the United States Air Force, or the United States Coast Guard, and is not an
officer of the Public Health Service detailed by proper authority for duty with any military or
naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 as designated therein as
military service, nor has Defendant, to the best of my knowledge, enlisted in the military service
covered by this Act; that the averments herein set forth, insofar as they are within my knowledge,
are correct and true; and insofar as they are based on information received from others, are
correct and true, and I verily believe.
This Verification is made under the provisions of the Soldiers and Sailors Civil Relief Act of
1940.
This Statement is made subject to
the penalties of 18 Pa. C.S. §4904
relating to unsworn falsification to
authorities.
BY:
Ann E. L. Shapiro, squir
Attorney for Plaintiff
IN T HE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
ARBITRATION DIVISION
CLEVELAND BROTHERS EQUIPMENT )
CO., INC., ) No. AR 14-001309
Plaintiff, )
vs. )
WILSON LAWN& PROPERTY CARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
WILSON, individually and now or formerly )
t/d/b/a WILSON LAWN & PROPERTY CARE)
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON HARDSCAPE WORKS, and )
WILCOMM COMMUNICATIONS, )
Defendants. )
CERTIFICATION OF ADDRESSES
I certify that the address of the Plaintiff-Creditor is as follows:
CLEVELAND BROTHERS EQUIPMENT CO., INC.
c/o DONALD L. PHILLIPS, P.C.
Attorneys for Plaintiff/Creditor
Suite 800, Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
and that the name(s) and address(es) of all Defendants entitled to Notice of entry of default
judgment are as follows:
WILSON LAWN & PROPERTY CARE, LLC
1600 Hummel Avenue
Camp Hill, PA 17011
CHRISTOPHER WILSON a/k/a CHRIS WILSON
i/and now or formerly t/d/b/a Wilson Lawn & Property Care,
Wilson Construction Associates, LLC, Wilson Hardscape
Works, and Wilcomm Communications
1600 Hummel Avenue
Camp Hill, PA 17011
and that on April 21, 2014, written Notices of intention to file the within Praecipe for Default
Judgment in the form required by Pa. R.C.P. 237.1(c) were mailed to the Defendants against
whom the judgment is to be entered, and to their attorney of record, if any, these Notices being
sent after the default occurred and at least ten days prior to date of the filing of this Praecipe for
Default Judgment. Copies of the Notices, as mailed, are being filed along with this Certification
and Praecipe for Default Judgment.
Ann E. L. Shapiro, Esqu'
Attorney for Plaintiff/Creditor
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CLEVELAND BROTHERS EQUIPMENT )
CO., INC., ) No.
Plaintiff, )
vs. )
WILSON LAWN &PROPERTYCARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
WILSON, individually and now or formerly )
t/d/b/a WILSON LAWN& PROPERTY CARE,)
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON HARDSCAPE WORKS, and )
WILCOMM COMMUNICATIONS, )
Defendants. )
VERIFICATION OF NON-MILITARY SERVICE
I, Ann E. L. Shapiro, on advice and belief hereby swear or affirm that the above-named
Defendant is not presently in the active military service of the United States of America and that he
is not a member of the Army of the United States,the United States Navy,the United States Marine
Corps,the United States Air Force, or the United States Coast Guard, and is not an officer of the
Public Health Service detailed by proper authority for duty with any military or naval units covered
by the Soldiers and Sailors Civil Relief Act of 1940 as designated therein as military service,nor has
he, to the best of my knowledge, enlisted in the military service covered by this Act; that the
averments herein set forth,insofar as they are within my knowledge,are correct and true;and insofar
as they are based on information received from others, are correct and true, and I verily believe.
This Verification is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940.
This Statement is made subject to
the penalties of 18 Pa. C.S. §4904
relating to unsworn falsification to
authorities. BY:
Ann E. L. Shapir , sq
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CLEVELAND BROTHERS EQUIPMENT )
CO., INC., ) No.
Plaintiff, )
vs. )
WILSON LAWN &PROPERTY CARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
WILSON, individually and now or formerly )
t/d/b/a WILSON LAWN&PROPERTY CARE,)
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON HARDSCAPE WORKS, and )
WILCOMM COMMUNICATIONS, )
Defendants. )
CERTIFICATION OF ADDRESSES
I certify that the address of the Plaintiff-Creditor is as follows:
CLEVELAND BROTHERS EQUIPMENT CO., INC.
c/o DONALD L. PHILLIPS,_P.C.
Attorneys for Plaintiff/Creditor
Suite 800, Lawyers Building
428 Forbes Avenue
Pittsburgh, PA 15219
and that the name(s) and address(es) of all Defendants entitled to Notice of entry of judgment are
as follows:
WILSON LAWN & PROPERTY CARE, LLC
1600 Hummel Avenue
Camp Hill, PA 17011
CHRISTOPHER WILSON a/k/a CHRIS WILSON
i/and now or formerly t/d/b/a Wilson Lawn &Property Care,
Wilson Construction Associates, LLC, Wilson Hardscape
Works, and Wilcomm Communications
1600 Hummel Avenue
Camp Hill, PA 17011
and that on September 18, 2014, a default judgment was entered against the Defendants, against
whom this judgment is to be entered,in Allegheny County.A copy of the certified docket entries is
being filed along with this Certification and the within Praecipe for Entry of Judgment Pursuant to
Certification of Docket Entries.
Ann E. L. Shapiro, sq r
Attorney for Plaintiff/Creditor
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CLEVELAND BROTHERS EQUIPMENT CIVIL DIVISION
co., INC., las
'
Plaintiff, No.
TYPE OF PLEADING:
vs.
PLAINTIFF'S BILL OF COSTS
WILSON LAWN &PROPERTY CARE, LLC;
and CHRISTOPHER WILSON a/k/a CHRIS s :,
WILSON, individually and now or formerly
t/d/b/a WILSON LAWN &PROPERTY CARE,
WILSON CONSTRUCTION ASSOCIATES,
LLC, WILSON HARDSCAPE WORKS, and
WILCOMM COMMUNICATIONS,
Defendants.
FILED ON BEHALF OF PLAINTIFF:
Cleveland Brothers Equipment Co., Inc.
COUNSEL OF RECORD FOR THIS
PARTY:
Donald L. Phillips, Esquire
Attorneys PA ID #01339
Ann E. L. Shapiro, Esquire
Attorneys PA ID #35166
DONALD L. PHILLIPS, P.C.
Suite 800, Lawyers Building
428 Forbes Avenue .
Pittsburgh, PA 15219
(412) 281-1977
Attorneys' Firm ID #0327
b'
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
ARBITRATION DIVISION
CLEVELAND BROTHERS EQUIPMENT )
) No. AR 14-001309
CO., INC.,
Plaintiff, )
vs. )
WILSON LAWN &PROPERTY CARE, LLC, )
and CHRISTOPHER WILSON a/k/a CHRIS )
WILSON, individually and now or formerly )
t/d/b/a WILSON LAWN &PROPERTY CARE,)
WILSON CONSTRUCTION ASSOCIATES, )
LLC, WILSON HARDSCAPE WORKS, and )
WILCOMM COMMUNICATIONS, )
Defendants. )
PLAINTIFF'S BILL OF COSTS
Notice of entry of judgment required by
Pa. R.C.P. 236 and/or local rule of Court 20.00
TOTAL $20.00
DONALD L. PHILLIPS, P.C.
Ann ZE. L. Shapiro, Esq . e
Attorney for Plaintiff,
Cleveland Brothers Equipment Co., Inc.