The URL can be used to link to this page

Home My WebLink About05-4788 MID - ATLANTIC STATES TITLE, INC.: COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. ()~ -41 pI C(..J~L ~VV} v. INTEGRATED REAL ESTATE PROCESSING, CIVIL ACTION - LAW ARBITRATION CASE Defendant NOTICE 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 have been served. To defend against aforementioned claims, a written appearance stating your defenses and objections must be entered and filed in writing by you, the Defendant, or by an attorney. You are warned that if you fail to take action against these claims, the court may proceed without you and a judgment for any money claimed in the complaint or for another claim required by the Plaintiff may be entered against you by the Court without further notice. You may lose money, 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 (717) 249 - 3166 (800) 990 - 9108 ,If- Ie ~ Brian K. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Atty Id. No. 59262 MID - ATLANTIC STATES TITLE, INC., : COURT OF COMMON PLEAS CUMEBERLAND COUNTY, PA Plaintiff v. NO. ()~ - l-{'1J>p evil ~~ INTEGRATED REAL ESTATE PROCESSING, CIVIL ACTION - LAW Defendant ARBITRATION CASE COMPLAINT 1. The Plaintiff Mid - Atlantic States Title, Inc. is a business with an address of 2132 Market Street, Camp Hill, PA 17011. 2. The Defendant Integrated Real Estate Processing is a business with an address of 290 Billmar Drive, Pittsburgh, PA 15205. 3. From October 6, 2003 until March 3, 2004, the Plaintiff performed services for the Defendant. These services were title searches on properties in the Commonwealth of Pennsylvania and recording documents. See attached as Exhibit "Au, the invoice for the services. 4. The total amount due the Plaintiff is $4,679.00. COUNT I BREACH OF CONTRACT 5. The Plaintiff incorporates by reference hereto paragraphs 1 through 4 as if more fully set forth herein. 6. The Plaintiff and the Defendant had a contract in which the Plaintiff would provide the Defendant with the title searches and recordings and the Defendant would pay for said services. 7. The Defendant has not paid the outstanding balance despite repeated requests for payment. 8. The Defendant by not paying has breached its' contract with the Plaintiff. WHEREFORE, the Plaintiff demands judgment in its favor and against the Defendant in the amount of $4,679.00 plus interest, court costs and attorney fees. The amount in controversy is less than $35,000 and requires compulsory arbitration. COUNT II UNJUST ENRICHMENT 9. The Plaintiff incorporates by reference hereto paragraph 1 through 8 as if more fully set forth herein. 10. The Plaintiff alleges and therefore avers that the services performed conferred a benefit on the Defendant by the Plaintiff. 11. The Plaintiff alleges and therefore avers that the Defendant appreciated the services. 12. The Defendant was unjustly enriched by receiving the services without paying for them. 13. The Plaintiff alleges and therefore avers that it would be unconscionable for the Defendant to retain the services without paying for them. WHEREFORE, the Plaintiff demands judgment in its favor and against the Defendant in the amount of $4,679.00 plus interest, court costs and attorney fees. The amount in controversy is less than $35,000 and requires compulsory arbitration. Date: if] /0 r -~~:::.-:==.-=-- Brian K. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Attyld. No. 59262 MID ATLANTIC STATES TITLE INC PO BOX 368 CAMP HILL, P A 17001 Statement DATE 9/2/2005 TO: INTEGRATED RE PROCESSING (I.R.E.P.) 290 BILLMAR DRIVE PITTSBURGH PA 15205 AMOUNT DUE AMOUNT ENC. $4,679.00 DATE TRANSACTION AMOUNT BALANCE 01/01/03 Balance forward 0.0 10/06/03 INV #9083 / 3,634.00 3,634.0 10/07/03 PMT - PAYMENT ON ACCOUNT -405.00 3,229.0 10/17/03 PMT - PAYMENT ON ACCOUNT -2,265.00 964.0 10/23/03 PMT - PAYMENT ON ACCOUNT -610.50 353.5 11/03/03 PMT -353.50 0.0 11/03/03 INV #9098 / 5,237.00 5,237.0 11/04/03 PMT - PAYMENT ON ACCOUNT -1,863.00 3,374.0 12/01/03 PMT #253028 - PAYMENT ON ACCOUNT -75.00 3,299.0 12/01/03 PMT #253633 - PAYMENT ON ACCOUNT -2,060.00 1,239.0 12/01/03 PMT #0137067 - PAYMENT ON ACCOUNT -50.00 1,189.0 12/01/03 PMT #7147 - PAYMENT ON ACCOUNT -25.00 1,164.0 12/01/03 PMT #257305 - PAYMENT ON ACCOUNT -405.00 759.0 12/05/03 INV #9110 / 5,921.50 6,680.5 12/07/03 PMT #257866 - PAYMENT ON ACCOUNT -1,995.00 4,685.: 12/19/03 PMT - PAYMENT ON ACCOUNT -60.00 4,625.: 12/19/03 PMT #261727 - PAYMENT ON ACCOUNT -60.00 4,565.~ 12/19/03 PMT #262279 - PAYMENT ON ACCOUNT -2,255.50 2,310,( 01/02/04 INV #9122 / 4,854.00 7,164,( 01/05/04 PMT #266230 - PAYMENT ON ACCOUNT -1,591.00 5,573.( 01/05/04 PMT 11266561 - PAYMENT ON ACCOUNT -99.00 5,474.( 01121/04 PMT 11270703 - PAYMENT ON ACCOUNT -1,676.00 3,798.( 01121/04 PMT # 141225 - PAYMENT ON ACCOUNT -500.00 3,298.( 01/21/04 PMT #270171 - PAYMENT ON ACCOUNT -35.00 3,263.( 01/21/04 PMT #8095 -;~A YMENT ON ACCOUNT -35.00 3,228.( 02/12/04 INV #9143 2,157.00 5,385,( 02/20/04 PMT #27789 - PAYMENT ON ACCOUNT -600.00 4,785.1 02/20/04 PMT #8588 - PAYMENT ON ACCOUNT -10.00 4,775.1 02/20/04 PMT #275847 - PAYMENT ON ACCOUNT -10.00 4,765.l 02/20/04 PMT # 144462/ YMENT ON ACCOUNT -25.00 4,740.1 03/03/04 INV #9152 709.00 5,449.1 03/04/04 PMT #8908 - PAYMENT ON ACCOUNT -25.00 5,424.1 03/04/04 PMT #283660 - PAYMENT ON ACCOUNT -300.00 5,124.1 03/04/04 PMT # 145631 - PAYMENT ON ACCOUNT -100.00 5,024.1 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 0.00 0.00 0.00 0.00 4,679.00 $4,679.00 Page 1 MID ATLANTIC STATES TITLE INC PO BOX 368 CAMP HILL, P A 17001 TO: INTEGRATED RE PROCESSING (I.R.E.P.) 290 BllLMAR DRIVE PITTSBURGH PA 15205 Statement DATE 9/2/2005 AMOUNT DUE AMOUNT ENC. $4,679.00 DATE TRANSACTION AMOUNT BALANCE 03/19/04 PMT - PAYMENT ON ACCOUNT -90.00 4,934.0 03/19/04 PMT - PAYMENT ON ACCOUNT -85.00 4,849.0 04/06104 PMT -PAYMENT ON ACCOUNT -20.00 4,829.0 05/03/04 PMT - PAYMENT ON ACCOUNT -35.00 4,794.0 05/03/04 PMT - PAYMENT ON ACCOUT -50.00 4,744.0 06/10/04 PMT - PAYMENT ON ACCOUNT -35.00 4,709.0 06/10/04 PMT - PAYMENT ON ACCOUNT -10.00 4,699.0 06/18/04 PMT - PAYMENT ON ACCOUNT -20.00 4,679.0 CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS AMOUNT DUE DUE DUE DUE PAST DUE 0.00 0.00 0.00 0.00 4,679.00 $4,679.00 Page 2 . . Date: o d\ ~ It ~(-J,::> f-- ( ~,-o S VERIFICATION "AJO ~l - ~ ~ ~ -...... ~ -.) '6s. o 0{ D ~ ~ ~ (-) __. , -II r .~ :- ~~p ~, ,;~ - C'.., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MID-ATLANTIC STATES TITLE INC., CIVIL DIVISION Plaintiff, Case No. 05-4788 CIVIL TERM vs. PRAECIPE FOR APPEARANCE INTEGRATED REAL ESTATE PROCESSING, Defendant. Filed on Behalf of Defendant Integrated Real Estate Processing Counsel of Record for this Party: Thomas K. Lammert, Jr., Esquire Pa.I.D.#53496 General Counsel Integrated Real Estate Processing 290 Bilmar Drive Pittsburgh, PA 15205 (412) 808-1710 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA MID-ATLANTIC STATES TITLE INC., Plaintiff, vs. Case No. 05-4788 CIVIL TERM INTEGRATED REAL ESTATE PROCESSING, Defendant PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Please enter my appearance for defendant Integrated Real Estate Processing in the above case. Respectfully submitted, /7di Thomas K. Lammert, Esquire 1.0. # 53496 General Counsel Integrated Real Estate Processing 290 Bilmar Drive Pittsburgh, PA 15205 (412) 808-1710 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Praecipe for Appearance has been served by U.S. Mail, this 4th day of October 2005 as follows: Brian K. Zellner Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, PA 17011 Jl- //r~ 2------- Thomas K. Lammert, Jr., Esquire 3 n ,......,) C:~7:I C) '<..> ':,,'1 -" n =-;:3 C) ""T) C.) '_J :.ml ('_..j '"-' =:.;..: MID - ATLANTIC STATES TITLE INC., COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 05 - 4788 CIVIL TERM v. INTEGRATED RELA ESTATE PROCESSING, Defendant CIVIL ACTION - LAW ARBITRATION CASE ACCEPTANCE OF SERVICE I accept service of the Complaint on behalf of the Defendant Integrated Real . t. p. Estate Proessing and certify that I am authorized to do so. - -1 Date: Oc/z,0 ) Zc..,o';--- ) ~/C_--Z- ~ o \ ...,[.) ~ "" ~~:l C'::'-} C,.., f:":_~ ~ o -" :2-,. rn..: !"'r', , , ,"-, ':--.' .,:}:L: <f;~ ~~ -...;: -0 ~.",~ (;~) (.,) -' MID - ATLANTIC STATES TITLE, INC., : COURT OF COMMON PLEAS CUMEBERLAND COUNTY, PA Plaintiff NO. 05 - 4788 CIVIL TERM v. INTEGRATED REAL ESTATE PROCESSING, CIVIL ACTION - LAW Defendant ARBITRATION CASE PRAECIPE TO SETTLE. END AND DISCONTINUE To the Prothonotary: Please mark the above - captioned matter settled, ended and discontinued with prejudice. Date: lo}JI/OS- (( Ie _IY-- ~~. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Atty ld. No. 59262 g 5_ -o,"j) t::f:,T; ;f;'i( (1'1):, =<;., r:::t.. ~':::~, :Pc:. 7": ::;: ....' = "'" cJ' - ~ I - ~ .-\ ~::!J -otr. -DY (2:9 -:c..,\) C)(J 4ff'\ :~~ ~ '-< ..." -;J: 1'3 ., s::- t.!!