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HomeMy WebLinkAbout14-7370 Supreme Court of-Tennsylvania Court'of.Common'.Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: y m County N_ J�U The infbI-InCt6077 collected on th s fOrn] is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required b.v law or rules of cou.u-t. Commencement of Action: S Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking ) r� C Lead Plaintiff's Name: Lead Defendant's Name:lN. 4V 7 ok F-6t o G YJ (i Tp 194 _ob►nsoYav� �n��`T ] n1� rl I Are money damages requested? Yes El NO Dollar Amount Requested: wi hin arbitration limits (check one) ❑outside arbitration limits O N Is this a Class Action Sant? ❑Yes ,KNo Is this an MDJAppeal? ❑ Yes ❑ No A Name of Plaintiff/Appellant's Attorney: Check here ifvou have no attorney (are a Self-Represented [Pro Sel Litia-ant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S ❑ Product Liability(does not include ]pass tort) El Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination C ❑ Other: ❑ Employment Dispute:Other ❑ Zoning Board T+ ❑ Other: I ❑ Other: O MASS TORT ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort-DES ❑ Toxic Tort-Implant 1 ❑ Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Other: 1:1 Ejectment ❑ Common Law/Statutory Arbitration ! B ❑ Eminent Domain/Condemnation ❑Declaratory Judgment i ❑ Ground Rent ❑ Mandamus E ❑ Landlord/Tenant Dispute ❑Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITYg g Quo Warranto ❑ Mort a e Foreclosure: Commercial ❑ Dental ❑ Partition ❑Replevin ❑ Legal ❑ Quiet Title Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA r D �o����tnSo� R;,nr� }�Yl i �e �obI h5n Plaintiff H-1 c(vt VS ' T- r� r DCIV�d FO f'p a,n 7est�n UjosL fe Zn c :n i, rl�) CD Defendant c=_ 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 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 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 REDUECED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 1-800-990-9108 717-249-3166 't4.\ 3 I�s.'ls ,SIT cash Page (1)of(11) Court of Common Pleas Cumberland County Division Carlisle, Pennsylvania Case: Date:December 24,2014 Jody Robinson and Mike Robinson P. O. Box 374 New Kingstown,PA 17072 Plaintiffs Versus Northeast Testing Upstate, Inc and David Foro aka Dave Foro and Ed Foley :2--in 21 Everett Road Ext , a psi` Albany, NY 12205 and other addresses being - -- 5722 Arenas Timbers Drive Humble TX 77346 600 Kenrick Drive Suite B 1 Houston TX 77060 YRC Terminal 100 Roadway Drive Carlisle PA 17013 Defendants Complaint Comes now Jody Robinson and Mike Robinson who files this complaint in good faith and further states that it is meritorious and worthy of Judicial consideration. We are ignorant of law and legal procedures. However, in High School studies of the United States of America Constitution,we remember that justice is not solely techniques and procedures but is,justice and fair play. We ask that this honorable court to overlook procedures and form as we are Lay persons and lack of funds to obtain a licensed legal representative. That we have been going through financial difficulties due to being owed and promised monies for payment of drug and alcohol testing services performed and rendered at YRC Inc Terminal 100 Roadway Drive Carlisle PA 17015 to employees of YRC Inc via a 1099 contract with Northeast Testing Upstate Inc. That David aka Dave Foro and Ed Foley malicious and intentional acts caused us emotionally and financial torment and distress. Our lack of monies and lack of knowledge in the legal proceedings and of the correct form of presenting our case should by no means diminish the facts of this case. We ask the honorable court to consider the larger issue in this matter. Statement of Facts That the persons of ownership, authority and representative of Northeast Testing Upstate are David aka Dave Foro and Ed Foley. That writecorrespondence including signing of checks drawn on Northeast Testing Upstate bank account are David aka Dave Foro and Ed Foley, That post accident, follow up and probable cause testing was initiated by YRC Inc that random testing requests were initiated by Escreen of Overland Park then notifying YRC of Overland Park then notifying YRC divisions were employees were based to have the testing done at YRC Carlisle division then notifying either or both Northeast Testing Upstate of Albany NY and notifying Jody Robinson and Mike Robinson plaintiffs who then preformed the testing at YRC 100 Roadway Drive Carlisle PA. The testing for which monies are due took place at YRC 100 Roadway Drive Carlisle PA. This relationship between all parties had been in place prior to the unpaid months as evidenced with email in which back pay was to be given to both plaintiffs when Ed Foley defendant was meet with personnel at YRC 100 Roadway Drive Carlisle PA in September 2013. At that time Ed Foley did not bring any check nor any form of payment for the months owed prior to August 2013 but did state to Jody Robinson that it would be in the mail. That Page I..2)of(11) includes exhibits payment did arrive for the months prior to August 2013 via mail USPS postmarked November 2,2013. but no payment for the months of August 2013 , September 2013, October 2013,November 2013, December 2013, January 2014 and February 2014. An empty envelop postmarked January 22, 2014 was received from defendants and notice of it being empty was corresponded in writing to both David Foro and Ed Foley. This was a habitual practice of plaintiffs preforming services and defendants slowly with numerous excuses not paying within the times they stated pay would be forthcoming. Payment for services was promised to Jody Robinson and Mike Robinson by both Dave Foro and Ed Foley of Northeast Testing Upstate on numerous occasions both by telephone and email and USPS mail. They stated that the checks were in the mail, that they must not have put the correct address on them it even though Jody Robinson and Mike Robinson sent Ed Foley self addressed stamped envelops which they had successfully used prior to the months now in default of payment. (see Exhibit) For the months of this complaint both Dave Foro and Ed Foley stated that YRC Inc had not paid Escreen, that Escreen was sorting out the paperwork and that was the hold up. Dave Foro did mail 2 checks on March 10'2014 one being for$945.00 and the other for$900.00 with a note"Hi Jody, Here e 2 checks,please wait until the 160'. For one then the 231d.For the other Dave" We complied only w have both checks returned for not sufficient funds and thus suffered monetary penalties owed our b nk in which the checks were deposited(see Exhibit). We have attached for the courts review. PI * iffs requested by letters of demand both USPS mailed and by fax payment in full on numerous dates with all being ignored to be paid for the months owed. (see Exhibits) Argument The d fendants actions against us were at the height of impropriety and by knowingly not having funds for th 2 checks to clear this was an illegal act. The d fendants intentionally stalled payments for services preformed. The fendants never made good on the 2 checks returned for insufficient funds. The d fendants exposed us to financial distress by not paying for.services rendered. The fendants habitually do not pay contractors on time. The defendants habitually do not pay contractors. The defendants do not respond to write correspondence. The defendants actions are intentional,willful,malicious and knowing. Conclusion It is a vident that the Defendants Northeast Testing Upstate Inc, David aka Dave Foro acted outside the law. DefendantsNortheast Testing Upstate Inc,David alta Dave Foro and Ed Foley actions served their self interest by having plaintiffs preform work for which they have been paid directly and indirectly by YRC Inc and Escreen Inc. That their actions were intentional,willful,malicious and knowing to conth tue their contract with YRC Inc and Escreen at the plaintiffs expense. We know that all defendants still do business with one another and monies are being paid. We know that we have not been aid and are owed monies for alcohol and drug testing of which specific examples of specimen colle tion numbers are attached. (see Exhibit) We ask the court to please consider how this affected our fiances to be negated for 10 or more months the time and expenses that were and still are involved due to the defendants actions and lack of action. We ask for the amount of $20,000.00 which includes payments owed for the months of August 2013 , September 2013, October 2013,November 2013, December 2013,January 2014 and February 2014, twice the face value of the bad checks which is allowable by the state,notification and mailing fees, court/legal fees,and compensatory damages so defendants will be deterred from doing this to others who they owe for their provided services. Jod obinson Mike Robinson *011500120* 03/31/2014 000008902330079NORTHEAST TESTING UPSTATE INC, im3 1061 rZI This Is a LEGAL COPY of your C3 N"LEARENAS Tt618EASORNE ' TX ru check.You can use it the same Q" way you would use the original m S- check. Na kER ^�m ccU ru FZ �..,:__. . .. _.... 036076150033114164 +Oa �01 1 u DOLIAAS 8 �. 011500120 0 0 WOODFOREST• `p 0 [� NH im, ; ;... r-q : FOR Au c....,C rErT C3 11100106111" +:3 E4g4 2853+: 08 E E034 E07a• 11500 LOG Lila 41: 3149728531: 8 L t i034 LO711' 16'000009450011' x 1<•0•e xUllbuuLcu* 106 °`� •.r; 03/31/2014 �. NORTHEAST TESTING UPSTATE INC. OOQ008902330078 W22ARENA811IMEAS4RWE µ ,p This 16'8 LEGAL COPY of your O ru NV MLEITX"3" till check.You can use it the same "11.% �A�Q Nis DATE way you would use the original m 0 O ff `v check. N mfn C3m ER —� N �O S --- — OOLLAA8 a 036076150033114164 ti o �y00DFOREST 011SOQ120 a�NATIONAL 1. C3o u Lnc " . a FOR 0 arc 0 W , .. �OOE0621� t:3E4972853+: u'8�EE034b07>`' 11500 3.06 2n' 4>f: 3 149 ? 211 .9 3i: 8 L L L0 34 LO W" .,'000OQg000 0", To: D#Wdil love Foro prmldent/owner of Northest Tatiag,Uptats,lnc. (roan:Jod Robinson and Mko/1lfichael Robinson Rates A pit 69 2014 Rei Money Owed Yep have_ orad eur corr@-spwde--no aed lottor of d@-maad and bavo not.pald,a for work pohmod at YRC and paid though Eserm to your cempaayslnce`August of 2013. You eoBt _t:ea 109 14 1A a 1 3 Pt loft Mid 001-9 two cb 'whkh you dam 147-14 one hr$943 and the other hr$900,knowing,ahoy woulel.uot be good as your letter also inside that envelop stated aM Jody are 2 checks,plam wait uadl the 160.For one thea the 2P.For the other.Rave" Uwe do not receive all our money owed In the bra of cub-able money orders as outlined below and mein it Within 19 of this mailing beteg received at your office,we will then go to the Humble Police In Humble TX (they have j3risdiction for your address of 9722 man Timms Drive�i kip 77346)whom we havve already spel en with and file a crhainal complaint for writing 2 bad cheek and not paying us what Is owed. �® further Into d to file cirri taimplalaft as Well for this Walter. Tkie Rumble TX palfce dote we spoke with. are in#eyes#e I in thi matter. 1''lea;e b€aware ha#i yc :s a�Oren as our sftL-ydU nes#a*0-wwt th face value of the checks but it penalty of twice their-written,ainouiit. Addl fonally,for titre Wkg&6 a crim- faai MGM: on could servo JOB tle_u. We est our mon . if iandoy � wo do not got Aour money emrod In the forte®fcash�ble money orders as . . o It within is days of this mailing being received at-your Am— wt%will then go to the Rumble Poli The total Includes the penalty for wrift the bad chemo which was iiupas�by our bnk and amount WIN led by thea:etas. , MOME JODY ROBINSON® �ROBIN3tN OWED Atm 2013 $540 $313 ° 403 M5 October 20.13 Nbor 20 3 40S :. 100. -�a 430 :225: December 2013 JsnUM 2014 r . `630 - : < . 270 - yekuffly 201 7.20 .313 Dad Chock k061' 2 times bee value 1$90 Bad Check 41062 2 times bee value.1800 Bank fee for iot sufficient toads 100 We bole tbrw1rd toa tes- mer tied@n and receiving$31"(Fethousand one hundred and uinety4ve dollars)payment for the months Jody worl€eel, $18330(One Thousand five hundrtd and thirty dol. Ian)payment for the months Me wonted,$945(Nine Hundred and Forty--five dofars)and$�(Nine Hun- dred dollm")IPor M- for WrM--Ag bad ch ;$160(one Ru—ndred sonars)for bay fees a¢gocia+ed with writ ing bad reeks for a fowl of"1 70(Six Thousand Sia Huudd,,ed and Seventy dollars Pl®neo forward promptly wither in the @nolo@od envelop addr@enod to both Judy Robinson and Mike Rvbineon P.O. Rex 374, New Kinvetewnt PA 17092 ur in do otivolnp of your ohoiva. xno10®od pro sou® sotcor of d@mand To: David/Dave Foro presidentlowner of Northeast Testing Upstate Inc. From:Jody Robinson and Mike/Michael Robinson Date:August 6,2014 Re: Money Owed You have ignored our correspondence and letter of demand and have not paid us for work performed at YRC and paid through Escreen to your company since August of 2013. You sent us postmarked March 10, 14 in a USPS priority mail envelop two checks which you dated 1-17-14 one for$945 and the other for$900,knowing,they would not be good as your letter also inside that envelop stated "Hi Jody Here are 2 checks,please wait until the 16*.For one then the 23rd.For the other. Dave" If we do not receive all our money owed in the form of cash-able money orders as outlined below and receive it within 15 days of this mailing being received at your office,we will then go to the Colonie Police in Colonic NY (they have jurisdiction for your address of 21 Everett Rd.Eat.Albany NY 12205)whom we have already spoken with and file a criminal complaint for writing 2 bad checks and not paying us what is owed. We further intend to file civil complaints as well for this matter. The Colonie NY police detectives we spoke with are inter- ested in this matter and think you are running a scam. Please be aware that in your state as well as our state you not only owe the face value of the checks but a penalty of twice their written amount. Additionally,for this being considered a criminal offense you could serve jail time. We just want our money. Uwe do not get all our money owed in the form of cash-able money orders as itemized below and receive it within 15 days of this mailing being received at your office,we will then go to the Colonie Police. The total includes the penalty for writing the bad checks which was imposed by our bank and amount imposed by the state. MONTH JODY ROBINSON OWED M[KE ROBINSON OWED August 2013 $540 $315 September 2013 405 225 October 2013 405 180 November 2013 450 225 December 2013 45 0 January 2014 630 270 February 2014 720 315 Bad Check#1061 2 times face value 1890 Bad Check#1062 2 times face value 1800 Bank fee for not sufficient fonds 100 We look forward to avoiding taking further legal action and receiving$3195(Three thousand one hundred and ninety-five dollars)payment for the months Jody worked, $1530(One Thousand five hundred and thirty dol- lars)payment for the months Mike worked,$945(Nine Hundred and Forty-five dollars)and$900(Nine Hun- dred dollars)for penalty for writing bad checks,$100(one Hundred dollars)for bank fees associated with writ- ing riting bad checks for a total of$6670(Sia Thousand Sia Hundred and Seventy dollars). Please forward promptly either in the enclosed envelop addressed to both Jody Robinson and Mike Robinson P.O. Box 374, New Kingstown, PA 17072 or in an envelop of your choice. Enclosed previous letter of demand Letter of Demand This is a letter of demand for both individuals Ed Foley and Dave/David Foro and their company Northeast Testing Upstate Inc. of 21 Everett Road Ext, Albany,NY 12205 with checks having.the address as 5722 Arenas Timbers Drive, Humble, TX 77346. It is now Ap it of 2014 and pay is still due from you and your company for: MONTH JODY ROBINSON OWED MIK$315BINSON OWED August 2013 $540 September 20. 45 03 405 225 October 2013 405 180 November 201 450 225 � , December 201 630 270 January 2014 315 February 2011 720 This is pay iEor both and individually for Jody Robinson and Mike Robinson. Self addressed stamped envelops have been provided and not all provided have been used to mail the pay to eLther or both Jody Robinson and/or Mike Robinson. are due To further the insult of having preformed satisfactory work to owihlch these monies for Jody Mr. Dave/Da d Foro sent an envelop postmarked March 10, _ for The copiesRobinson butnothing for Mike Robinson son followedithecinstructionsareerequestingwhichrthattoneecheck insufficien funds even after Jody be presented for cashing on the lothweachuoflt hcchecks havingmanJanuaryt2014tdateothe l asthedate without indication of the month wi they were written. We suggest you send the amount due for Jody Robinson of $3295 (Three thousand two hundred and Robin- ninety-five dollars) which includes $100 fdor i'tY�dollars ) todsatisd the fyoall ll pastunt duefdue immedi- son of $153 (One Thousand five hundredtrust in ately. Due to your checks being returnedfor insuf icie t shiers and checkewillkbefaccepted this matter a United States postal Money Order asnd court costs will occur' If it is no received by May 15, 2014 additional legal We anticipate your compliance and understand how in the service business your reputation is paramount tD retaining and increasing your busness.essed to both Jody Robinson and Mike Robin- Please forward promptly in the enclosed envelopaddr son P.O.Box 374, New Kingstown, PA 17072. 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Sent: Thu 8/22/13 8:10 AM To: i iaspghan@hotmail.com Hi Jody, It looks like we will receive full payment through July from Escreen and will be able to pay you and Mike in full by September 7th, $2655.00 in total I will bring checks with me, YRC would like to meet with you and I and MLke on the 30th in the morning, probably before 12 noon. Will that work or the both of you? ast Testing Upstate . verett Rd. Extension Jhany,NY 12205A ` . � 1 �o �- rn be � 93A1AR1TY MAIL ILLY U.S.PAID GUILDERLRND.NY 120$q UNItiDsrdtFS MAR 1 o.'1 q rosrns sr�evres AMOUNT xao aTp ro aALIQ 1006 $560 1p Duo Jo 3 w£Z D uD17072 00076989-17 3 •tn9 i a It�un�rsm a�aid`s�oa>:�o Z aru axaH `Spof IH 6Y5 m AP - 1-01 UMITEDSTATES ;veA /0 POSTAL SERVICE* ,�Ap'�teA h9 9ok USPS TRACKING # tusps.comok 'S 0 . •• ��.�.' L�v�',lJ �uJL�aU r.J i�J��i�L�i:1E�iv�.J 1 �ti 4' ''ff'r +l�ti' ►r j`NedJ•li,v� 1 9114 9011 5981 8550 7484 39 )NAL RESTAICTIONS APPLY: - ms ere required.Consult the I Mail Manual(IMM)at pe uspsuom \ it/Associate for detalls. �-D n.ro LOP Recycle This packaging is tho propo*of tho U.3.Postal �'•nr�dy+afii Jain xu.,��/J7riy, dodosflnatiQnt / 1 i ) Sorvlco00and isprovidadsololyfor usnln t.lmdinq Priority Ma/160 uhipnmrity, ` War'11 rgrly tin it vlotallon of Irrrf"17,11 iuw. Tfrl.•. 1 +�j !ru An�JIn+J P.n�rr fur r�+,+dr+ 111141 �lll {`` i ' f5 ,.►rd'.,.�vl .. how.'Irl.'. X111il,11ir,w,ovril WILLIAM C. COX UNDERSHERIFF ALBANY COUNTY SHERIFF'S OFFICE County Court House Albany, New York 12207 (518) 487.6400 MICHAEL S. MONTELEONE CHIEF DEPUTY CRAIG D. APPLE, SR. SHERIFF CUMBERLAND COUNTY COURT OF COMMON PLEA STATE OF PENNSYLVANIA JODY ROBINSON AND MIKE ROBINSON vs. NORTHEAST TESTING UPSTATE INC PAUL M. COURCELLE CHIEF DEPUTY KERRY B. THOMPSON CHIEF DEPUTY CERTIFICATE OF SERVICE CORPORATE SERVICE Index Number - 14-7370 Sheriff File Number - 14007525 I certify that I am an Albany County Deputy Sheriff and that I am not a party to the above -entitled action. !further certify that I made service of the within described papers upon NORTHEAST TESTING UPSTATE INC, the defendant in the following manner. Papers Served: NOTICE TO DEFEND; COMPLAINTS; STATEMENT OF FACTS Address Where Service was Made: 21 EVERETT RD EXT ALBANY, NY 12205 Date and Time Of Service CORPORATION 12/31/2014 at 10:35 AM By delivering to and leaving with ED FOLEYAND, the OWNER for the NORTHEAST TESTING UPSTATE INC. personally a true coov thereof. STATUTORY FEE At the time of service, a statutory fee of n/a was also left with the person mentioned and described herein. DESCRIPTION The person served was approximately: Skin Color. White, Hair Color: Bik/Gry, Gender: Male, Height: 5' 10", Weight: 175, Age: 54. Dated: Monday, January 05, 2015 TIMOTHY COX DEPUTY SHERIFF