HomeMy WebLinkAbout01-4592-- ~6 28 South Pitt Street
. - ~'~;~Carlisle PA 17013
i717) 245-968e
ALL AMERICAN PLAZAS, INC.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
THOMPSON TRANSPORTATION, INC.,:
Defendants : CIVIL TERM
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 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 of 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 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
ALL AMERICAN PLAZAS, INC.,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
THOMPSON TRANSPORTATION, INC.:
Defendant :CIVIL TERM
COMPLAINT
1. Plaintiff, All American Plazas, Inc. is a Pennsylvania Business Corporation with a
registered address of P.O. Box 657, 1181 Harrisburg Pike, Carlisle, Cumberland
County, Pennsylvania, 17013.
2. Defendant, Thompson Transportation, Inc. is presumably a Virginia Corporation
with a last known address of 15402 Nelson Hill Road, Milford, Virginia, 22565, and a
mailing address of P.O. Box 496, Thornburg, Virginia 22565.
3. At all times relevant hereto Plaintiff, All American Plazas, Inc. (hereinafter All
American) was in the business of providing diesel fuel to the Defendant and other
similarly situated businesses.
4. From July 2000 to the present the Defendant, Thompson Transportation, Inc. did
utilize the services of All Amedcan at various locations owned by the Plaintiff for the
purchase of diesel fuel.
5. On July 12, 2001 the Defendant made payment to All American in the amount of
Thirty Thousand Five Hundred Thirty-One and 19/100 ($30,531.19) Dollars after which
it purchased large quantities of diesel fuel and quickly closed its doors and terminated
operations.
6. At the time Defendant terminated business, it owed Plaintiff Seventy Thousand
Six Hundred Twenty-Five and 15/100 ($70,625.15) Dollars for diesel fuel purchases
made on credit.
7. Despite repeated demands the above sum has remained unpaid as of the date of
this Complaint.
Wherefore, for all the above reasons, the Plaintiff, All American Plazas, Inc.
requests judgment in its favor in the amount of Seventy Thousand Six Hundred
Twenty-Five and 15/100 ($70,625.15) Dollars plus interest and costs of suit.
Respectfully Submitted
TURO LAW OFFICES
~,.x.~,~ ~T
Date
Jai~l!s M. Robinson, Esquire
28 South Pitt S~reet
Carlisle, PA 17013
(717) 245-9688
Attomey for All American Plazas, Inc.
VERIFICATION
I, James M. Robinson, Esquire, am the attorney for the All American Plazas, Inc.
am familiar with the facts concerning the above complaint against Defendant
Thompson Transportation, Inc. and I do swear and affirm that the facts set forth in the
complaint are true and correct to the best of my knowledge, information and belief which
have been provided to me by my client or gathered by myself during the preparation of
this complaint. I understand that false statements herein made are subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities.
Date