HomeMy WebLinkAbout05-3849
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
The RecovAR Group LLC,
Plaintiff,
v.
G]obal Logistic, Inc. d/b/a Global Logistics
d/b/a GLI
Defendant.
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No. 05 -3f49 C;L>LllSe-~
Type ofP]eading: Complaint in Civil
Action
Filed on Behalf of Plaintiff:
The RecovAR Group, LLC
Counsel of Record for this Party:
Linda A. Mich]er, Esquire
Pa. I. D. No. 535]8
7228 Baptist Road, #175
Bethel Park, PA ]5102
(4]2) 854-4315
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 is
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 judgment maybe
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.
YOV SHOVLD TAKE THIS PAPER TO YOVR LAWYER AT ONCE. IF
YOV DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OVT WHERE YOV
CAN GET LEGAL HELP.
CVMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENVE
CARLISLE, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
The RecovAR Group LLC,
No. 0 S" - 3P'I9
CI~Lt ~~
Plaintiff,
)
)
)
)
)
)
)
)
)
)
)
)
v.
Global Logistics, Inc. d/b/a Global Logistics
d/b/a GLI
Defendant.
COMPLAINT IN CIVIL ACTION
1. Plaintiff is The RecovAR Group, LLC, as assignee of United Parcel Service
("UPS"), having an address of] 182] ParkIawn Drive, Rockville, MlIl)'land.
2. Defendant, Global Logistics, Inc. d/b/a G]obal Logistics, d/b/a GLI is a Pennsylvania
corporation, whose Registered AgentlPresident, Thomas Hocker, is an adult individual, having a
last known address at 5267 Simpson Ferry Road, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
3. At the special instance and request of Defendant and in a continuing course of
business from March 27, 2004 through September 1],2004, UPS sold and delivered to Defendant
certain shipping services, in the total aggregate amount of$9,137.20, as is more specifically
shown by UPS' Statement of Account, true and correct copies of which is attached hereto marked
Exhibit "A".
4. Defendant received and accepted the aforementioned services.
5. The prices charged were the customlll)' and usual prices, and Defendant agreed to
pay.
6. A true and correct copy of the Assignment of Accounts Receivable from UPS to
Plaintiff is attached hereto marked Exhibit "B" and made a part hereof.
8. Plaintiff avers that the balance due by Defendant amounts to $9,137.20, as evidenced
by UPS' Statement of Account (Exhibit "A").
9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed
and refused to pay the aforesaid remaining balance, or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant, Registered
AgentlPresident, Thomas Hocker, in the amount of $9,137.20, together with appropriate interest,
late fees, and costs, including but not necessarily limited to costs of collection and attorney fees.
Date~, 2005
.
~k~
Lina3 A. Mich]er, Esquire
Attorney for Plaintiff, The Recov AR Group, LLC
Pa. ill # 53518
7228 Baptist Road, #175
Bethe]Park,PA 15102
(4]2) 854-4315
SCHEDULE
TO
Assignment of Account(s) Receivable
Debtor Original Balance Payments Credited Account Receivable
Purchased (Debt)
. .
Global LOgIStiCS. Inc. d/b/a Global
Logistics d/b/a GLI
$9.137.20
$9.137.20
Schedule to Assignment of UPS Acct
\ l t X hi bi -f f\ V1
1011
.
United Parcel Service
General Information (G)
Account: EW9593
Name: Global Logistics, Inc.
D/B/A Global Logistics d/b/a GU
5267 Simpson Ferry Road
Mechanicsburg, PA 17055
Phone: (717) 697-5007
Balance: $9.137.20
W/E Date Trans Adj
Invoice No. Type Type Amount
0000EW9593134 3127/04 A 1 $1,184.70
0000EW9593144 4/3104 A 1 $2,245.49
OOOOEW9593154 4/10/04 A 1 $475.01
0000EW9593164 4/17/04 A 1 $879.01
00OOEW9593174 4/24/04 A 1 $1.607.59
. 0000EW9593184 5/1/04 A 1 $1.599.96
0000EW9593194 5/8/04 A 1 $478.47
0000EW9593204 5/15/04 A 1 $287.02
0000EW9593214 5/22/04 A 1 $199.89
OOOOEW9593224 5/29/04 A 1 $105.49
OOOOEW9593234 6/5/04 A 1 $38.52
0000EW9593244 6/12/04 A. 1 $14.35
0000EW9593254 6/19/04 A 1 $9.99
0000EW9593264 6/26/04 A 1 $5.27
0000EW9593374 9/11/04 A 1 $6.44
Total $9,137.20
ASSIGNMENT OF ACCOUNT (8) RECEIVABLE
Effective Pate: November 18, 2004
This Assignment of Account(s) Receivable is made by and between The RetovAR
Group, LLC ("RecovAR") and United Parcel Service, Inc. ("UPS") effective On the date
fll'st written above.
WHEREAS, Each ofthe debtors identified ("Debtor") on the Schedule to Assignment of
Account(s) Receivable (the "Schedule") attached hereto is currently indebted to UPS for
the amount(s) indicated fot each on the Schedule together with allowable interest,
attorney's fees and costs, where applicable, for services rendered and/or goods pr\)vided
by UPS to Debtor (the ''Debt'');
WHE.REAS, The Debt is not subject to offset, counterclaims or just grounds of defense;
WHEREAS, UPS 1Nishes to sell and RecovAR wishes to purchase the Debt; and,
NOW THEREFORE, For good and valuable consideration, the receipt and sufficiency of
which are hereby acknowledged, UPS does hereby irrevocably assign, set over and
transfer to Recov AR all rights, title and interest to the Debt. .
FOR:
THE REeOV AR GROUP, LLC
B~~~
Pamela Bart]ett
Chief Operating Officer
The Recov AR Group, LLC
11821 ParklawnDrive, Suite 310
Rockville, MD 20852
CE, INC
By:
Paul Gallais or Bill Stuh1tragt\1"
Corporate Credit
United Parcel Service, Inc.
55 Glenlake Parkway, NE
Atlanta, GA.30328
\ \ (.0n-\ P'i-t fbVl
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DlV]SION
The RecovAR Group LLC, ) No.
)
Plaintiff, )
)
v. )
)
Global Logistics, Inc. d/b/a Global Logistics )
d/b/a! GLI )
)
)
)
Defendant. )
VERIFICATION
The Undersigned verifies that the facts set forth in this complaint are true and
correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C. S. S 4904, relating to
unsworn falsification to authorities.
I am duly authorized to make this verification on behalf of The Recov AR Group,
LLC because of my position as CleD /~tt4~~BEJ2_.
Date: [~ I C;, 2005
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
The RecovAR Group LLC,
Plaintiff,
v.
Global Logistic, Inc. d/b/a G]obal Logistics
d/b/a GLI
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
No. 2005-03849 Civil Term
Type of Pleading: Praecipe to
Discontinue Action Without
Prejudice
Filed on Behalf ofP]aintiff:
The Recov AR Group, LLC
Counsel of Record for this Party:
Linda A. Michler, Esquire
Pa. I. D. No. 535]8
7228 Baptist Road, #175
Bethel Park, PA 15102
(412) 854-4315
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
The RecovAR Group LLC, )
)
Plaintiff, )
)
v. )
)
Global Logistics, Inc. d/b/a Globa] Logistics )
d/b/a GLI )
)
)
)
Defendant. )
No. 2005-03849 Civil Term
PRAECIPE TO DISCONTINUE ACTION WTlliOUT PREJUDICE
TO THE PROTHONOTARY:
Kind]y discontinue this action without prejudice on the records of this Court.
Date: August 16, 2005
~4~~
Linda A. Michler, Esquire
Attorney for Plaintiff, The Recov AR Group, LLC
Pa. ill # 535]8
7228 Baptist Road, # 175
Bethel Park, PA 15102
(412) 854-4315
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SHERIFF'S RETURN - NOT FOUND
.
CASE NO: 2005-03849 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
RECOVAR GROUP LLC THE
VS
GLOBAL LOGISTIC INC DBA GLOBAL
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
GLOBAL LOGISTICS INC D/B/A
GLOBAL LOGISTICS D/B/A GLI
but was
unable to locate Them in his bailiwick. He therefore returns the
NOTICE
COMPLAINT
, NOT FOUND , as to
the within named DEFENDANT
, GLOBAL LOGISTICS INC D/B/A
GLOBAL LOGISTICS D/B/A GLI
5267 SIMPSON FERRY ROAD
MECHANICSBURG, PA 17055
GLOBAL LOGISTICS IS NO LONGER OPERATING OUT OF ADDRESS PROVIDED,
CURRENT BUSINESS OWNER ROBERT GOUDY STATES HE IS NOT ASSOC. W/GLOBAL
Sheriff's Costs:
Docketing
Service
NOT FOUND RETURN
Surcharge
18.00
8.00
5.00
10.00
.00
41.00
So answe:!:'3--'--?" - _...._~
-~~~~
Sheriff of Cumberland County
LINDA MICHLER
08/04/2005
Sworn and subscribed to before me
this
9
day of
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&1,1 ~ : -1Y\... J}." ~AO-
thonotary
-0/5'.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
The RecovAR Group LLC,
Plaintiff,
v.
Global Logistic, Inc. d/b/a Global Logistics
d/b/a GLI
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
No. 0 ~ - 3f'-1'1
C;u~l';~
Type of Pleading: Complaint in Civil
Action
Filed on Behalf of Plaintiff:
The RecovAR Group, LLC
Counsel of Record for this Party:
Linda A. Michler, Esquire
Pa. I. D. No. 53518
7228 Baptist Road, #] 75
Bethel Park, PA 15102
(412) 854-43]5
Tl1lJE COpy FROM rUECDRD
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honotary
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 is
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 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.
YOV SHOULD TAKE THIS PAPER TO YOVR LAWYER AT ONCE. IF
YOV DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OVT WHERE YOV
CAN GET LEGAL HELP.
CVMBERLAND COVNTY BAR ASSOCIATION
2 LIBERTY A VENVE
CARLISLE, P A 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIV]L DIVISION
The RecovAR Group LLC,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
No.
. Plaintiff,
v.
Global Logistics, Inc. d/b/a Global Logistics
d/b/a GLI
COMPLAINT IN CIVIL ACTION
]. Plaintiff is The RecovAR Group, LLC, as assignee of United Parcel Service
("UPS"), having an address of] 182] Parklawn Drive, Rockville, Maryland.
2. Defendant, Global Logistics, Inc. d/b/a Globa] Logistics, d/b/a GLI is a Pennsylvania
corporation, whose Registered AgentlPresident, Thomas Hocker, is an adult individual, having a
last known address at 5267 Simpson Ferry Road, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
3. At the special instance and request of Defendant and in a continuing course of
business from March 27, 2004 through September 11, 2004, UPS sold and delivered to Defendant
certain shipping services, in the total aggregate amount of$9,137.20, as is more specifically
shown by UPS' Statement of Account, true and correct copies of which is attached hereto marked
Exhibit "A".
4. Defendant received and accepted the aforementioned services.
5. The prices charged were the customary and usual prices, and Defendant agreed to
pay.
6. A true and correct copy of the Assignment of Accounts Receivable from UPS to
Plaintiff is attached hereto marked Exhibit "B" and made a part hereof.
8. Plaintiff avers that the balance due by Defendant amounts to $9,137.20, as evidenced
by UPS' Statement of Account (Exhibit "A").
9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed
and refused to pay the aforesaid remaining balance, or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant, Registered
Agent/President, Thomas Hocker, in the amount of $9,137.20, together with appropriate interest,
late fees, and costs, including but not necessarily limited to costs of collection and attorney fees.
Date~, 2005
-
~""~~
Attorney for Plaintiff, The RecovAR Group, LLC
Pa. ID # 53518
7228 Baptist Road, # 175
Bethel Park, P A 15102
(412) 854-4315
Debtor
SCHEDULE
TO
Assignment of Account(s) Receivable
Original Balance
Payments Credited
Global Logistics. Inc. d/b/a Global
Logistics d/b/a GLI
Schedule to Assignment of UPS Acet
$9,137.20
\ l t X ne bi -f F\ III
Account Receivable
Purchased (Debt)
$9,137.20
1011
..
United Parcel Service
General Information (G)
Account: EW9593
Name: Global Logistics. Inc.
D/B/A Global Logistics d/b/a GLI
5267 Simpson Ferry Road
Mechanicsburg, PA 17055
Phone: (717) 697-5007
Balance: $9,137.20
W/E Date Trans Adj
Invoice No. Type Type Amount
0000EW9593134 3/27/04 A 1 $1.184.70
0000EW9593144 4/3/04 A 1 $2,245.49
0000EWg593154 4/10/04 A 1 $475.01
0000EW9593164 4/17/04 A 1 $879.01
0000EW9593174 4/24/04 A 1 $1,607.59
. 0000EW9593184 5/1/04 A 1 $1,599.96
0000EW9593194 5/8/04 A 1 $478.47
0000EW9593204 5/15/04 A 1 $287.02
0000EW9593214 5/22/04 A 1 $199.89
0000EW9593224 5/29/04 A 1 $105.49
0000EW9593234 6/5/04 A 1 $38.52
0000EW9593244 6/12/04 A. 1 $14.35
0000EW9593254 6/19/04 A 1 $9.99
0000EW9593264 6/26/04 A 1 $5.27
0000EW9593374 9/11/04 A 1 $6.44
Total $9,137.20
ASSIGNMENT OF ACCOUNT (S) RECEIVABLE
Effective Date: November 18, 2004
This Assignment of Account(s) Receivable is made by and between The Re<:ovAR
Group, LLC eRecovAR") and United Parcel Service, Inc. ("UPS") effective on the date
frrst written above.
WHEREAS, Each ofthe debtors identified ("Debtor") on the Schedule to Assignment of
Account(s) Receivable (the "Schedule") attached hereto is currently indebted to UPS fOJ;
the amount(s) indicated for each on the Schedule together with allowable interest,
attorney's fees and costs, where applicable, for services rendeJ;ed and/or goods prl)vided
by UJ>S to Debtor (the "Debn;
WHE.REAS, The Debt is not subject to offset, counterc1aims or just grounds of defense;
WHEREAS, UPS wishes to sell and Recov AR wishes to purchase the Debt; and,
NOW THEREFORE, For good and valuable consideration, the receipt and sufficiency of
which are hereby acknowledged, UPS does hereby irrevocably assign, set over and
transfer to RecovAR all rights, title and interest to the Debt. .
FOR:
THE RECOV AR GROUP, LLC
B~~'--
Pamela Bartlett
Chief Operating Officer
The Recov AR Group, LLC
11821 ParklawnDrive, Suite 310
Rockville, MD ;:<0852
. By: o~
Paul Gallois or Bill Stuhltrag(\l'
Corporate Credit
United Parcel Service, mc,
55 Glenlake Parkway, NE
Atlanta, GA30328
\' ~)(\1-\ P'I -t 16'"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVIS]ON
The RecovAR Group LLC, ) No.
)
Plaintiff, )
)
~ )
)
Global Logistics, Inc. d/b/a Global Logistics )
d/b/a! GLI )
)
)
)
Defendant. )
VERIFICATION
The Undersigned verifies that the facts set forth in this complaint are true and
correct to the best of my knowledge, information, and belief. 1 understand that false
statements herein are made subject to the penalties of 18 Pa. C. S. 9 4904, relating to
unsworn falsification to authorities.
I am duly authorized to make this verification on behalf of The RecovAR Group,
LLC because of my position as CleO l~tt4ldw.EWlBEJL.
Date; ~ \ 0,2005
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