HomeMy WebLinkAbout05-5797IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MAGGIE ADAMS LTD CIVIL ACTION - LAW
Plaintiff
NO. CU S - 5747 L
v.
JOHN R. HALL, individually and
Trading as,
ELECTRONIC CONCIERGE,
OF PENNSYLVANIA,
Defendants
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
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 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 INFORMATION ABOUT 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 REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MAGGIE ADAMS LTD.
Plaintiff : CIVIL ACTION - LAW
V. :NO. OS - 5797
JOHN R. HALL, individually and ,
trading as,
ELECTRONIC CONCIERGE
OF PENNSYLVANIA,
Defendants
COMPLAINT
AND NOW, comes Plaintiff, by and through its Attorney, the Law Offices of
Eric J. Wiener, and hereby states as follows:
1) The Defendant, John R. Hall, individually and trading as Electronic
Concierge of Pennsylvania, is an adult individual, resides at 4131
Nantucket Drive, Mechanicsburg, Cumberland County, PA 17050.
2) Maggie Adams, Ltd. is a Pennsylvania Corporation maintaining an
office and place of business located at 3605 Gettysburg Road,
Camp Hill, Cumberland County, PA 17011.
3) On or about May 1, 2005, Maggie Adams Ltd., entered into a
Display Agreement with John R. Hall, whereby he was to place
advertisements at the Radisson Crowne Plaza Hollywood Suites for
the sum of $850.00.
1
4) On or about July 1, 2005, Changes Salon and Day Spa entered into
a similar agreement and also paid $850 to John R. Hall, with the
agreement that in addition to the advertising, Mr. Hall would set up
an appointment with the Sales and Banquet Manager at Radisson
Hotels for Valerie Lauren to make a presentation.
5) Changes Salon and Day Spa has assigned all interest in the
Agreement of aforesaid to Maggie Adams Ltd. and/or LouAnn
Wiener.
6) After the total sum of $1,700.00 was paid to John R. Hall, it was
learned that not only is there no such entity formed in or filed in the
State of Pennsylvania known as Electronic Concierge of
Pennsylvania and that Defendant John R. Hall fraudulently
obtained the sum of $1,700.00 without having made any
arrangements nor had any discussions with the Radisson Crowne
Plaza, all of which has been confirmed by the Plaintiff herein.
WHEREFORE, Plaintiff demands Judgment in the amount of $1,700.00
for breach of contract and fraudulent conversion of the sum of $1,700.00.
Dated:
?f y 0?
Respec bmitted,
ERIC J. WIE VER, ESQUIRE
Pa. Supreme Court ID # 18046
LAW OFFICES OF ERIC J. WIENER
2407 Park Drive
Harrisburg, Pennsylvania 17110
(717) 657-7701
2
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
MAGGIE ADAMS LTD.
Plaintiff : CIVIL ACTION - LAW
vi. : NO.
JOHN R. HALL, individually and
trading as,
ELECTRONIC CONCIERGE
OF PENNSYLVANIA
Defendants
COMPLAINT
VERIFICATION
Subject to the penalties in 18 Pa. C.S. §4904, 1 hereby verify that the
averments of fact in this Complaint are true and correct to the best of my
knowledge, information and belief.
Dated:
'LouAnn Wiener
MAGGIE ADAMS LTD.
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CASE NO: 2005-05797 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ADAMS MAGGIE LTD
VS
HALL JOHN R
SGT JODY SMITH
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
HALL JOHN R
was served upon
the
DEFENDANT , at 1024:00 HOURS, on the 16th day of November , 2005
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013 by handing to
JOHN R HALL
a true and attested copy of COMPLAINT & NOTICE _ together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service .00
Postage .37
Surcharge 10.00
.00
28.37
Sworn and Subscribed to before
me this " day of
?hlru.c.? „1 "j A. D.
Prot of y
So Answers:
?.-^.?•.,,s.:=,:??...s..te ..-/'. '.:air'-F.
R. Thomas Kline
11/16/2005
ERIC WIENER
By: f
joC LA( d mzt-
Deputy Sheriff
CASE NO: 2005-05797 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ADAMS MAGGIE LTD
VS
JOHN R ET AL
SGT JODY SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
HALL JOHN R T/A ELECTRONIC CONCIERGE OF PENNSYLVANIA the
DEFENDANT
at 1024:00 HOURS, on the 16th day of November , 2005
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
SLE, PA 17013 by handing to
JOHN R HALL, OWNER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this ? 2 ?til day of
1DO A.DDO A.D.
Pro oPro o ay
So Answers:
16
R. Thomas Kline
11/16/2005
ERIC WIENER
By:
Dep tyf She f
Curtis R. Long
Prothonotary
office of the Protbonotarp
11 Renee K. Simpson
Cumberlanb Countp
Deputy Prothonotary
John E. Slike
Solicitor
09- .5!791 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREMICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
rind rn„rthnnce Rminre • Carlisle. Pennsvivania 17013 • (717) 240-6195 • Fax (717) 240-6573