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Home My WebLink About05-5614John DeLoxenzq Esgidxe ID. #72190 GOLDBERG, KATZMAN, P.C. 320 ~fazket Steeet, PO Bos 1268 Ha~usburg, P_1 17108-1268 (]_/ 234-4161 ~l ttomeps foe Plaintiff R.H. BLACK, INC. t/d/b/a CUSTOM P_1TI0 ROOMS of cF;NTRAL PA, Plaintiff v. JAMES PERAGINF,, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLV/~A-N~I-A^ NO. DS' - 51-1~f ~tviL [~rrl CIVIL ACTION -EQUITY 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 are served, by entering a written appearance personally or by attorney and filing in writing with the Courtyour 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 nonce for any money claimed in the Complaint ox for any other claim or relief requested by the Plaintiff You map lose money or propert~~ or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA~'i'YER 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 WHF,RE YOU CAN GF.T LEGAI, HELP. Lawyer Referzal Service Cumberland County Bar Associarion 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 John DeLoeenzo, Lsquim LD. #?2190 GOLDBERG, KATZMAN, P. C. 320 D4axkec Street, PO Box 1268 Harrisburg, Pd 17108-1268 (717) 234-4161 ~trorneys fox Plauitiff K.H. BLACK, INC. t/d/b/a CUSTOM PATIO ROOMS OF CEN"TRAL PA, Plaintiff v. JAMES PERAGINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. CIVIL ACTION -EQUITY NOTICIA Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted riene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea adisado que si usted no se defiende, la sin previo aviso o notification y por cualquier quja o puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DE 1VLANDA A UN ABOGADO IMMEDIATAMENTE. SI NO "I'TF,NF: ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR Tr~i, SF,RVICIO, VAYA EN PEKSONA O LLAME POR TELEFONO A LA OFICINA CUYy DIRF,CCION SE ENCUEIvTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland Counn~ Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 john lleLoi~enzq Esquire ID. #?2]90 GOLDBERG, KATZMAN, P.C. 320 b-faiker Srreer, PU I3ox 1208 Haxusbuxg, PA 17105-1268 (717) 234-4161 .~ttoxneys fox PLainriff R.H. BLACK, INC. t/d/b/a : IN THE COURT OF COMMON PLEAS CUSTOM PATIO ROOMS :CUMBERLAND CO., PENNSYLVANIA OF CFN'I'IZAL PA, Plaintiff : NO. DS - $'~[c~ e[c.,~~ ~1L~-,mil v. :CIVIL ACTION -EQUITY J~~IES PER:IGINF,, Defendant COMPLAINT Plaintiff R.H. Black, Inc. t/d/b/a Custom Patio Rooms of Central PA ("Custom Patio"), by and through its attorneys, Goldberg Katzman, P.C., allege the following in support of this Complaint: 1. Plainriff is a Pennsylvania coipoxation with a principal place of business at 4609 Gettysburg Road, Mechanicsburg, PA 17055. 2. Custom Patio is in the business of selling and installing patio rooms throughout Pennsylvania and Maryland. 3. Defendant, James Peragine ("Pexagine") is an adult individual with an address of 1330 Concord Road, Mechanicsburg, PA 17050. 4. Peragine became employed by Custom Patio on June 5, 2001 pursuant to the terms of an Employment Agreement (the "Employment Agreement" or "Agreement") which is attached hereto as Exhibit A. 5. The Employment Agreement was ancillary to Peragine's employment and supported by adequate consideration, in that it was executed at the start of Peragine's employment. 6. On or about August 17, 2004, the parties entered into an agreement ("Purchase Agreement" attached hereto as Exhibit B) by which Gxstom Patio purchased a Dell Inspiron 1150 Lap Top computer ("the Computer") for Peragine. Z 1'he Purchase Agreement required Peragine to return the computer to Custom Patio or purchase the computer from Custom Patio upon termination of his employment. 8. Pergagine resigned from his position at Custom Patio on or about July, 15, ?005. 9. Pexagine failed to return the computer after the termination of his employment. 10. On February 9, 2005, Pexagine signed a Promissory Note ("Note' attached hereto as Exhibit C. 11. T'he Note required Pcxagine to pay Custom Patio a sum of $5,500.00. 12. The Note provided that if Peragine left Custom Patio's employ, the remaining balance would be subtracted from any commissions owed to Peragine. 13. The Note also required Peragine to pay the loan off within 30 days after he left Custom Patio's employ if his commissions did not satisfy the remaining balance. 14. The commissions owed to Peragine did not satisfy the remaining balance of the Note. 15. Peralrine failed to pay the remaining balance on the Note within 30 days of the termination of his employment. 16. Peragine was given a cellular telephone ("cellular phone"), Nextel model I730, to be used fox employment purposes. 17. Peragine failed to return the cellular phone to Custom Patio after he resigned. COUNTI BREACH OF CONTRACT 18. The averments contained in paragraphs 1 through 17 are incorporated herein as if set forth in full. 19. "The promises contained in the Note are legally enforceable and create a contract between Custom Patio and the Defendant. 20. Defendant has not paid the remaining balance on the Note. 21. Defendant's failure to pay the remaining balance constitutes a breach of contract. WHEREFORE, Plaintiff Custom Patio respectfully requests that judgment be entered in its favor and against the Defendant plus interest and costs of suit, including reasonable attorneys fees, as well as whatever other remedy this Court deems proper. COUNT II BREACH OF CONTRACT 22. The averments contained in paragraphs 1 through 21 are incorporated herein as if set forth in full. 23. The promises contained in the Purchase Agreement are legally enforceable and create a contract between Custom Patio and the Defendant. 24. Under the terms of the Purchase Agreement, the termination of Defendant's employment with Custom Patio gave the Defendant the option of either returning the computer or purchasing the computer from Custom Patio. 25. Defendant's failure to return the computer or purchase the computer from Custom Patio constitutes a breach of contract. WHEREFORE, Plaintiff Custom Patio respectfully requests that judgment be entered in its favor and against the Defendant plus interest and costs of suit, including reasonable attorneys fees, as well as whatever other remedy this Court deems proper. COUNT III CONVERSION 26. The averments contained in paragraphs 1 through 25 axe incorporated herein as if set forth in full. 27. Pursuant to the Purchase agreement, Defendantwas obligated to return the computer or purchase it from Custom Patio. 28. Defendant was required to return the cellular phone when his employment ended. 29. Defendant has neither returned the computer nor purchased it from Custom Patio, nor has he returned the cellular phone. 30. The Defendant has no legal right to possess the computer or the cellular phone. 31. Defendant's failure to return the computer or purchase it from Custom Patio and his failure to return the cellular phone constitutes an unlawful conversion of the Computer and the phone. WHF,KEI'ORF., Plaintiff Custom Patio respectfully requests that judgment be entered in its favor and against the Defendant plus interest and costs of suit, including reasonable attorneys fees, as well as whatever other remedy this Court deems proper. GOLDI3~ KAT"L~M.~N, P.C. BY ~ohn DeLorenzo, Esq. Attornev LD. # % 2190 320 Market Street, P.O. fox 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys fox Plaintiff Date: Am~z c;~a ~; ~z~ne i ~EC~ ~ b~~ ~ ~,~~,, EMPLOYMENT AGREEMENT THIS AGREEMENT is made and entered into as of the 5th day of June, 200[(the "Effective Date") by and between CUSTOM PATIO ROOMS OF CENTRAL PA., a Pennsylvania corporation, with its principal offices at 4609 Gettysburg Rd. Mechanicsburg, Pennsylvania 17055 ("Employer"), and James Peragine individual residing at 16 E Gate Drive Camphill, Pa 17025. ("Employee") WITNESSETH: WHEREAS, Employer desires to employ Employee and Employee desues to be employed by Employer as an Office Manager for Employer's customized patio enclosure systems, subject to the general supervision ofEmployer; and WHEREAS, in connection with his or her employment hereunder, Employee will acquire extensive confidential information pertaining to the business and operations of Employer, and will be given an opportunity to participate in the relationships between the Employer and its customers, which relationships constitute a valuable asset of the Employer's business. NOW, THEREFORE, in consideration of the mutual covenants contained herein, and intending to be legally bound, Employer and Employee agree as follows: 1. At-Will Em~loyment. Employer hereby employs Employee as a Sales Rep and Employee hereby accepts such employment and agrees to perform Employee's duties and responsibilities hereunder in accordance with the terms and conditions hereinafter set forth. Employee acknowledges that he or she is an at-will employee and as such Employee may terminate his or her employment with Employer at any time and/or Employer may terminate Employee's employment at any time with or without cause. 2. Duties. Employee shall perform all duties and accept all responsibilities asassigned by Employer from time to time, which duties may be changed at any time at Employer's sole discretion. Employee shall devote his entire time and use his best efforts to the performance of his or her duties hereunder, it being understood and agreed between the parties that Employee's employment is full-time employment. 3. Compensation and Benefits. In consideration of the services to be rendered by Employee and for so long as Employee is employed hereunder, Employer shall pay to Employee salary of $500 per week with Employer's usual payroll procedures. 4. Term of Employment. The term of employment shall commence as of the Effective Date and shall continue indefinitely, except as otherwise provided by this Agreement. 84898,10469.0 Copyright 1999,Custom Patio Rooms, Hic. 5. Termination of Empoovment. A. Death. Employee's employment and this Agreement shall terminate immediately upon Employee's death during the term of this Agreement, in which case Employee's estate shall be paid an amount equal to any earned but unpaid wages. B. Termination for any other Reason. Employer or Employee may terminate the employment relationship created hereunder for any reasoq with or without cause, by giving written notice to the other party (the "Temvnation Notice") at the address set forth herein. 6. Restrictive Covenants. During the term of this Agcement and without regazd to its termination for any reason which does not constitute a breach of this Agreement by Employer, and for an additional period of one (2) year thereafter (the 'Noncompete Period"), Employee shall not: A. Agreement Not To Compete. Directly or indirectly own, manage, operate, finance join, control, or participate in the ownership, management, operation, financing, or control of, or be connected as an officer, director, employee, partner, principal, agent, representative, consultant or otherwise with, or use or pemut Employee's name to be used in connection with any business or endeavor similar to, or competitive with, or in conflict with that conducted by the Employer at the time of the Employee's terrination. B. Non-Solicitation. Duectly or indirectly solicit, divert, or take away, or attempt to divert or take away any of Employer's customers, or seek to stop any customer from doing business with Employer or assisting any other person; employee, corporation, partnership or entity from doing so. This restriction shall apply to all customers with which Employer did business at any time during the term of Employee's employment. C. Non-Hiring. Duectly or indirectly solicit any employee of the Employer to terminate his or her employment or association with the Employer and become employed by Employee or any other person or entity in substantially the same or similar business as that engaged in by the Employer. D. Non-Disclosure. (i) Directly or indirectly use, divulge, or disclose any confidential information or trade secrets of the Employer or divulge the source of its suppliers or its customers to any person, firm, corporation, association, or other entity for any reason for any purpose whatsoever; (ii) Upon termination of Employee's employment pursuant to this Agreement, the Employee shall return to the Employer all price lists, customer lists, customer files, card files, writings, or other confidential information or trade secrets or parts thereof and all documents, things, and copies thereof produced by the Employer; it being expressly understood and agreed by the parties hereto that the same and all copies thereof are and shall forever remain the sole and exclusive property of the Employer. (iii) Employee shall at all times take all precautions necessary to protect from loss or disclosure by him or any and all documents or other information containing, referring to, or relating to such confidential information and trade secrets. (iv) For purpose of this Agreement "Confidential Information" means any information relating in any way to the business of the Employer disclosed to or known to the Employee as a consequence of, result of, or through the Employee's employment by the Employer which consists of technical and non-technical information about the Employer's products, processes, programs, concepts, forms, business methods, data, any and all financing and accounting data, marketing, customers, customer lists, and services and information corresponding thereto acquired by the Employee during the term of the Employee's employment. Confidential Information shall not include any of such items which are published or aze otherwise part of the public domain, or freely available from trade sources or otherwise. E. Advice of Counsel. The Employee acknowledges and agrees, after opportunity to seek advice of counsel, that the duration, scope, territory and business limitations of the foregoing provisions aze reasonable, necessary and fully enforceable. Employee represents to the Employer that, notwithstanding the provisions of this Section 6, by virtue of her education, training a.rd experience, she will be able to obtain suitable employment in another business, for purposes of earning a livelihood, without in any manner violating the restrictive provisions of this Section 6. 7. Unique Nature of Agreement. The Employee acknowledges and agrees that the Employer's rights under this Agreement aze specialized and unique in character and that any violation of the terms made in Section 6 of the Agreement would case substantial and irreparable injury to the Employer. Notwithstanding any election by the Employer to claim damages from the Employee as a result of the Employee individually, or doing a business as a partnership, corporation, or in any other forrr>, the Employer may jointly and severally enjoin the Employee from arty breach or threatened breach thereof in addition to, but not in the limitation o>y any of the rights or remedies to which the Employer is or maybe entitled to at law or in equity or under this Agreement or any agreement related thereto. The Employee hereby agrees that in the event he violates the provisions of this Section, the non-compete period shall be extended by that number of days which equal the aggregate days during which any such violation occurred. 8. Prior Employment. Employee warrants and represents to the Employer that Employee's performance of the terms of this Agreement and the performance of Employee's duties hereunder do not and will not breach any agreement between Employee and any prior employer or other person or entity for whom Employee performed services. Employee further represents and warrants that Employee has not brought and will not bring to the Employer or use in the performance of Employee's duties any materials, documents, technical data, marketing data or other information of a prior employer or other person or entity for whom Employee performed services, unless Employee has lawfully obtained pemtission to do same under an assignment, license or other valid written agreement. 9. Severability. The covenants, provisions and sections of this Agreement aze severable, and in the event that any portion of this Agreement is held to be unlawful or unenforceable, the same will not affect any other portion of this Agreement, and the remaining terms and conditions or portions thereof will remaur in full force and effect. This Agreement will be construed in such case as if such unlawful or unenforceable portion had never been contained in this Ageement, in order to effectuate the intentions of the Employer and Employee in executing this Ageement. 10. Reformation. In furtherance and not in limitation of the foregoing, should any duration or geographical restriction on business activities covered under this Agreement or any other provision of this Agreement be found by any court of competent jurisdiction to be less than fiully enforceable due to its breadth or restrictiveness or otherwise, Employee and the Employer intend that such court will enforce this Agreement to the full extent the court may find permissible by construing such provisions to cover only that duration, extern or activity which may be enforceable. The Employer and Employee acknowledge the uncertainty of the law in this respect and intend that this Agreement will be given the construction that renders its provisions valid and enforceable to the maximum extent permitted by law. 11. Miscellaneous. A. No Waiver. The failure of either the Employer or Employee to object to any conduct or violation of any of the covenants made by the other under this Agreement will not be deemed a waiver of any rights or remedies. No waiver of any right or remedy arising under this Agreement will be valid unless set forth in an appropriate writing signed by both the Employer and Employee. B. Assignment and Survival This Agreement is binding upon the Employer and Employee and their respective hens, personal representatives, successors and assigns. The obligations of Sections 5 and 6 of this Agreement will survive the termination of this Agreement. The services to be rendered by Employee to Employer under this Agreement are personal in nature, and therefore, Employee may not assign or delegate Employee's duties or obligations under this Agreement without the prior written consent of the Employes. Employer may assign its rights under this Agreement by providing written notice of such assignment to Employee. C. Governing Law. Tlvs Agreement will be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania. Employee acknowledges the jurisdiction of the State and Federal Courts located in Pittsburgh, Pennsylvania. D. No Oral Modifications. No alterations, amendments, changes or additions to this Agreement will be binding upon either the Employer or Employee unless reduced to writing and signed by both the Employer and Employ. E. Notices. All notices under this Ageement shall be sent and deemed duly given when posted in the United States first-class mail, postage prepaid to the addresses supplied in writing for such purposed by the Employee and the Employer. These addresses may be changed from time to time by written notice to the appropriate party. F. Headin¢s. The section headings of this Agreement aze for convenience of reference only and shall not affect the construction or interpretation of any of the provisions hereof. G. Entire Agreement. This Agreement constitutes the entire understanding between the Employer and Employee and supersedes all prior oral or written communications, proposals, representations, warranties, covenants, understandings or agreements between the Employer and Employee relating to the subject matter of this Agreement. IN WITNESS WHEREOF, the undersigned have hereunto set their hands and seals the day and year first above written. ATTEST: CUSTOM PATIO ROOMS OF CENTRAL PA. A Pennsylvania Corporation By: Robert H Black, President WITNESS: EMPLOYEE: isa Cbenelle, Office Manager ~~~~ ~ / ~} ~i~ ~~ ~3 AGREEMENT __ r By and between Custom Patio Rooms of (~ -xf..i ~ %~LLC hereby referred to as i --~ Purchaser ands' i`/ s ~ ` ~ ~-~ , an employee of Custom Patio Rooms ~~~~ LLC Hereby referred to as recipient. °~` i 'J That Purchaser purchased (1) Dell Model Inspiron 1150 Lap Top Computer and case, Serial Numbef~~/~%'%,~ ~~i~~/ ~ ~ !~' > for the purpose of enhancing the job i performance of the recipient. That Purchaser purchased the afore mentioned equipment for $1080.00 and the recipient agrees to pay to Purchaser one-half of the purchase price ($540.00). The recipient agrees to have Purchaser deduct from his payroll check, the amount of $45.00 monthly basis for a period of 1 year. The recipient agrees to be personally and solely responsible for the afore mentioned equipment should the equipment become lost, damaged or stolen under any circumstance. The following warranty applies to the equipment Next Business Day Parts and Labor On-Site Response- Initial Year Next Business Day Parts and Labor On-Site Response- 1 YR Extended Complete Care Accidental Daman Service, Inspiron, 2 Years (Service Tag Number, ~~ y ,Express Service Code Recipient agrees to take full advantage of this warranty should any damage be done to the equipment. The recipient agrees to surrender the afore mentioned equipment in the working condition of which it was received upon the termination of his employment with Purchaser. At the time of his termination of employment ,recipient has the option to purchase the afore mentioned equipment for one-half of the remaining balance due from Purchaser or End- of-Lease Buyout (whichever applies at that time), in addition to any monies owed on the initial agreement of one-half of the purchase cost to Purchaser. i.e.- If agreement is less than one year old =the unpaid balance up to $540.00. If agreement is more than one yeaz old - $1.00 buyout. If the recipient does not opt to purchase the equipment, he agrees to return the equipment to Purchaser immediately upon termination of employment, at which time a refund of any monies paid to purchaser minus a usage allowance of $25.00 per month will be reimbursed to the recipient. Should the recipient opt to purchase the equipment, he agrees to return the equipment to CPR Communications LLC immediately upon termination whereby the "Custom Patio Rooms" presentation will be permanently removed from the afore mentioned equipment prior to releasing the recipient from any financial obligation for the equipment. By my signature, I agree to,the above terms and conditions set forth in this agreement: < _ - -7 j ~ '' - .:.yc. Custom Patio oms of 1x,,1j~Za^- /~Ft~C ° (Employee Name) (Puchaser) ~ ~; (Recrprent ) ~l~~~L~y Date ~~/~~<-~ Date i , J ~ ~-__-,_ _ _____ /~ Attest ~/ v -•_~ . Witness , v r¢c+aw y b ~`~~" ~~~ '~- ~~ ~- - ~ ~ ~ I ~ ~ - . -~. ' ~ t~ , _' 'r:'. `- SHERIFF'S RETURN - REGULAR CASE NO: 2005-05614 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND R H BLACK INC TDBA CUSTOM PATI VS PERAGINE JAMES RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly swo-rn according to law, says, the within COMPLAINT - PERAGINE JAMES DEFENDANT the at 1111:00 HOURS, on the 7th day of November 2005 at 1330 CONCORD ROAD MECHANICSBURG, PA 17055 by handing to JAMES PERAGINE a true and attested copy of COMPLAINT - EQUITY together with and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 10.56 Postage .37 Surcharge 10.00 .00 38.93 Sworn and Subscribed to before me this ~~~ day of A.D. Pro n tary~ was served upon So Answers: ~~ ~ R. Thomas 11J09/2005 GOLDBERG KATZMAN By. C_~~.vC!!~~__% Deputy Sh riff w R.H.BLACK, Ina t/d/b/a CUSTOM PATIO ROOMS OF CENTRAL PA, No. OS-5614 Plaintiff v, James Peragine, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA CIVIL, ACTION- EQUITY Defendant 1. Agreed 2. Agreed 3. Agreed ANSWER TO COMPLAINT 4. Agreed, though I respectfully ask the court to recognize that Plaintiff's Exhibit A, the Employment Agreement, has been left unsigned by Robert H. Black, President of Custom Patio Rooms and that the document is also unwitnessed. 5. Agreed. 6. Agreed. 7. Agreed. 8. Agreed 9. Agreed 10. Agreed 11. Agreed 1- 12. Agreed 13. Agreed 14. Agreed. 15. Agreed. 16. Denied. Salesmen at Custom Patios were charged for their cell phones on the first paycheck after receiving it. At Exhibit A, I've included my sales statement for this time period, with the charge of $ 116.58 for the cell phone circled. 17. Agreed. THE BALANCE OF COMPLAINT, TO INCLUDE BOTH BREACH OF CONTRACTS, AND CONVERSION: Denied. Defendant maintains that: a) As per Denial at 16., above, Defendant purchased the cell phone from Custom Patios on June 30, 2001. b) Plaintiff's Exhibit B clearly states that salesmen agree to pay $ 540. for the Dell notebook computer, to be deducted in 12 monthly payments of $ 45, each. In fact, as outlined in Defendant's Exhibit B, 11 such payments have been made (each circled). As per the contract, one final payment of $ 45. is due. Further, on 3uly 2I, 2005, Defendant contacted Detective Justin Spaulding after Custom Patio contacted Defendant and threatened legal action. Defendant's intention was to clarify the situation and offer to make that payment, which Detective Spaulding subsequently did do. Exhibit C is the Complaint Report filed by Detective Spaulding relative to this incident; if it please the court, the narrative of the report can be acquired. c) Defendant has paid, through paycheck deduction, a total of $ 2100. towards the Promissory Note. Additionally, Defendant maintains that, due to negligence and substandard business practices, Plaintiff created a hostile working environment that constitutes its own Breach of Contract. Defendant was compelled to leave Custom Patios' employ and seek other employment. As Plaintiff had induced the Defendant to relocate to perform duties that subsequently became untenable, Defendant maintains that he should not be held liable for the $ 1050. of the Promissory Note that comprised the security deposit on the apartment Defendant rented pursuant to his relocation. -2 - N ~, s. ~~. i~ -., Im ~ o o O y 3 N N N 'q O < Z m ro ~ ~~ ~ ~O ~ ~ ~ ~ ~ r ~ m ~q ~ m ~ ~ `~~' m m Z y a m z ~ rn N O y 0 r ~~~ ~~.~a m ~O r ny im ~ ~° ~' D to C 3 n D 3c o~ z c vo ~ ~z ~~ a ~ o '~ ~~ 0 z p ~ ca m~ ~~ D C O C "~ y0 3q n, r y ..~. 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Method Received Dalertlme Receivetl Cleared 0 Phone 7/21/2005 12:55 PM Day of rde Week Haw Hanmetl Thursday Pfione Complaint Nawre. Peragrine called ref past employer wanting a Lap Top computer back that was on a purchase agreement Complaint Location Sveer Numbev Street Block: Prediremion Sveel Name: Street Type. Posrdlreclion 4609 Gettysburg RD -Road PD. BOx Cross-Pretlvecuon Sleet Name. 9reer Type: Highway Name. Highway Number'. Hlghwdy MlleposL. Rural RpWe' County'. Junstliction Number. Cumberland Location Township Magisletlal Dimricl-. Clry Political Subdrvismn. Lower Allen Township 09-1-01 Camp Hill Smte: Zone Number Zlp, Area. Ghd: Residence Type' llnlt Type'. PA 1 17011 1203 Unit Number (IOr,apQ'. LatiWde. Longiwtle: Locallon Type: Country'. United States of America (USA) Locarlon Oescriptlop: Complaint Information Salmarion First Name Mlddle Name Last Name $dRl% James Peragrine pare or Bmb Race Sex White Male Address 1330 Concorde Rd Apartment City. Stare' Zip Code Mechanicsburg PA 17055 Phone Number 1 Area COOe Number Exl PM1ane Type 717 9999999 Home Phone Number2 Area COd¢ Numbef Ext PM1bne Type 717 Np1ily Complainant Call Taker lD Dispatcher lD cNET Cbmplainr k'. 1818 1818 45610 User Defined Field 1 User Defined Field 2 Complainant User Defined Fleld 3 User OeFlned Fleltl 9 Complainant Associate Information Page 1 Area Code Number Exl Pnone Type - 1717 975-9291 Work l Pnone NumOerT Area Code Number Ext Pbone Type 717 User Defined Feld 1 U6ee Definetl Field 2 Business User Defined Fleld3 Usei Definetl Flalp 4 Salutation Fuss Nam¢ MiOdl¢ Name Lasl Name SuPox Pamela Black Dade pi Blnn Face Sex Female Atltlress 4609 Gettysburg Rd Apenmenl clry Slela Lp coos Mechanicsburg PA 17055 Pnune Number ~ Area Code NumDe~ Exl Pnone Type 717 975-9291 Work Phone NumberT Atea COOe Number Exl PDOne Type 717 User Defined Fieltl 1 User DefineO Field 2 Owner User Defnetl Fie10 3 User Definetl Field 4 Justin - 1818 -Lower Allen Twp Reporting Officer 11818 Dispatcnetl Emwte 7/21/2005 12:00 PM Arrives Clearetl 7112/2005 12:00 PM 7/21/2005 12:11 PM User DeYrnetl Fi¢Id1 Use~Dafnab Fieid2 9 User Defined Feld 3 User DeflneO FSeld 4 Attachments Page 2 L.-~Chr ~r~f,`. ~z ` ~, ~; ~~ R.H. BLACK, INC. t/d/b/a CUSTOM PATIO ROOMS OF CENTRAL, PA, Plaintiff V. JAMES PERAGINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. OS-5614 Civil Term CIVIL ACTION -EQUITY PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: ~? ~' - c7 C __• ~, -;, ~~ -;~{. E~-! .. --~ -i -~ ~ Please withdraw the appearance of John DeLorenzo, Esq., as counsel for Custom Patio Rooms of Central PA. GOLDBERG KATZMAN, P.C. By: DATE: May 23, 2007 143227.1 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 "'~ .-- ~ ~ -n -` _~ _ --~ ~: , ~_. ~~ - .~ -,-r F_; ~ ~. ,_ .: ~a e-..t.,, .. 4 ~.... ~:C R.H. BLACK, INC. t/d!b/a CUSTOM PATIO ROOMS OF CENTRAL, PA, Plaintiff v. JAMES PERAGINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. OS-5614 Civil Term CIVIL ACTION -EQUITY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Michael F. Socha, Esq., as counsel for Custom Patio Rooms of Central PA. By: GOLDBERG KATZMAN, P.C. ~r~~O Michael F. Socha, Esquire Attorney ID #200988 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 DATE: May 23, 2007 ;~.,, n ~, ,. ~~ ~ ~ i ---~ '` '~_ , ,- --- _ ~ ~," ~ j ; _ -G