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Home My WebLink About87-0014IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JURY TRIAL DEMANDED P.G.A. GOLF, Plaintiff V. MIKE WENRICH t/a PERSONAL TOUCH PRODUCTS, Defendant COMPLAINT LA~ OFFICES OF GRAF, KNUPP 0 ANDREWS, p. C. CAMERON MANSION 40? NORTH FRONT STREET P, O, BOX 11848 HARRISBURG, PA 17108 - 1848 J~, l; Ill z: illM '1)? CL COMP#1:'12919 NOTICE:12/04/86 P.G.A. GOLF, Plaintiff V. MIKE WENRICH t/a PERSONAL TOUCH PRODUCTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ;~ ~c~, 198~ CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 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 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 OR CANNOT AFFORD ONE~ GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE THIRD FLOOR CARLISLE, PENNSYLVANIA 17013 (717) 249-1133 CL COM~1:12919 COMP:12/04/86 P.G.A. GOLF, Plaintiff V. MIKE WENRICH t/a PERSONAL TOUCH PRODUCTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, ~?.~NSYLVANIA.. NO. l~ ~ , 193~6 CIVIL DIVISION - LAW JURY TRIAL DEMANDED COMPLAINT The Plaintiff, by its attorney, Graf, Knupp & Andrews, P.C., brings this action of Assumpsit against the Defendant to recover the sum of Eleven Thousand, Four Hundred Sixteen Dollars and Sixty-Nine Cents ($11,416.69), together with interest thereon from November 4, 1985 upon a cause of action of which the following is a statement: 1. The Plaintiff, P.G.A. GOLF, is a corporation organized and existing under the laws of the State of Illinois, having its principal office and place of business at Post Office Box #8547, Chicago, Illinois 60680. 2. The Defendant, MIKE WENRICH, is trading and doing business as PERSONAL TOUCH PRODUCTS and has an office and place of business at 41 Gettysburg Pike, Mechanicsburg, PA 17055. 3. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiff's books of original -1- CL COM#1:12919 COMP:12/04/86 entry hereto attached, made a part hereof and marked Exhibit "A", Plaintiff, at the special instance and oral request of the Defendant, sold and delivered goods, wares and merchandise of the kind and description set forth on said Exhibits to the total amount of Eighteen Thousand, Four Hundred Sixteen Dollars and Sixty-Nine Cents ($18,416.69). 4. The prices charged for said goods, wares and merchandise were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay Plaintiff therefor. 5. The Defendant paid to Plaintiff on account of the aforementioned charges, certain sums of money in the total amount of Seven Thousand ($7,000.00) Dollars. 6. The balance due and owing by Defendant to Plaintiff is the sum of Eleven Thousand, Four Hundred Sixteen Dollars and Sixty-Nine Cents ($11,416.69), as appears by the Statement of Account hereto attached, made a part hereof and marked Exhibit "A". 7. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused -2- CL COM~1:12919 COMP:12/04/86 and neglected and still refuses and neglects to pay said amount or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of Eleven Thousand, Four Hundred Sixteen Dollars and Sixty- Nine Cents ($11,416.69), together with interest thereon from November 4, 1985. Attorney for Plaintiff -3- STATEMENT TOMMY ARMOUR GOLF 2-12- 85 82434 8350 NORTH LEHIGH AVENUE MORTON GROVE, ILLINOIS 60053 Mike Wenrich ~' ~/V PHONE (312) 966-6300 Carlisle CC 1242 Harrisburg Pike Carlisle, PA 17013 ACCOUNT NUMBER TOLL FREE NUMBER ' 800-742-4653 WITHIN ILLINOIS 800-742-4244 TO BETTER SERVE YOU, PLEASE NOTE ANY ADDRESS CHANGES OR COMMENTS ON REVERSE SIDE! 235259.00 23525900 23525900 23525900 23525900 23525900 23525900 23525900 23526400 23526400 23526400 ~36 36 )737 75 4/24/86 7/10/82 3,375,72 4/30/82 7/10/86 168.00 5,000.00 5,000.00 5,000.00 359.03 May 24 500.00 June 4 400.00 July 22 400.00 Aug 24 500.00 Sep 23 300.00 Oct 25 916.69 Dec 12 127.03 Jan 29 40.97 May 24 3,583.31 Dec 12 00.00 00.00 1,416.69 5,000.00 5,000.00 FUTURE DUE I CURRENT DUE 1-30 DAYS 31-60 DAYS TOTAL BALANCE I $ ,416.69 PLEASE REMIT TO: IF YOU PAY TOTAL ACCOUNT BALANCE BY TOMMY ARMOUR GOLF P.O. BOX 8547 YOU MAY DEDUCT CASH DISCOUNT OF $ CHICAGO, IL 60680 CODES: CM -- CREDIT MEMO SC -- SERVICE CHARGE PP -- PARTIAL PYMT. IN -- INVOICE AD -- ADJUSTMENT UP -- UNAPPLIED PAYMENT DM -- DEBIT MEMO TOMMY ARMOUR GOLF PLEASE DETACH AND RETURN THIS STUB WITH YOUR REMITTANCE. IF LESS THAN THE FULL AMOUNT OF THIS STATEMENT IS PAID, PLEASE CHECK INVOICES PAID. 12-12-85 ACCOUNTNO. 82434 NAME Mike Wenrich 23525900 23526400 0736 D737 0775 00.00 CL COMP#1:12919 AFFI:12/04/86 STATE OF ILLINOIS COUNTY OF COOK SS: : Personally appeared before me, a Notary Public in and for said State and County, V.R. DEMM~E who being duly sworn according to law, deposes and says that he is the Credit Manager of P.G.A. GOLF, Plaintiff in the foregoing Complaint, and that the facts set forth in said Complaint so far as they are within his personal knowledge are true and correct, and as to facts based upon the information of others, he believes them to be true and correct. Sworn to and subscribed before me this 16 day of December , 1986. Notary Public MY(sEAL)commission expires: '/~.~?z~ ~i / /~ V. R. Demme Credit Manager PGA Golf PERSONAL TOUCH PK~ODUCTS 925 KRANZEL DRIVE CAMP HILL, PA 1701 SF~RY~?' S ~:~ETURN COMMON'w-EJ_LTH OF PENNSYLVANIA COUNTY OF C~ERf_A~ND P.G.A. Golf In the Court of Common Pleas of Cumberland County, Pennsylvania No. 14 Civil 1987 Civil Action Law Complaint VS Mike Wenrich t/a Personal Touch Products Harry King Y~~xor Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according co law, says, Civil Action Law Complaint zhac he served Che wichin Products Mike Wenrich t/a Personal Touch 1:00 upon ,che defendanc, ac o'clock ~. EST /Xg~ on the 12th day of 923 Kranzel Drive, Mechanicsburg Jan11~rv , 19 87 , aC , Cumberland Councy, (screec number) Pennsylvania. by handing Co (cicy. or cown) Mike Wenrich a cz'ac and accesced copy of :he and ac che same cime direecing Civil Action Law Complaint his actencion ~o che concencs thereof and che ~loc'_ce ~o Plead" endorsed :hereon. She.~iff's Coscs: Dockecing Service Affidavit Surcharge 14.00 6.15 2.00 $ 22.15 pd. by Sworr~ and subscribed before me chis ./~ day of ~, ' Prothonotary atty 1-13-87 by P.G.A. GOLF Plaintiff --V-- MIKE WENRICH t/a PERSONAL TOUCH PRODUCTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 14 Civil , 1987 IN ASSUMPSIT JURY TRIAL DEMANDED TO: PROTHONOTARY, COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Enter judgment in favor of Plaintiff and against the Defendant above named for failure to file within the required time an Answer to the Complaint in the above captioned case, and assess the Plaintiff's damages as follows: Amount claimed in Plaintiff's Complaint ~1,416.69 Interest from November 4, 1985 $ 856.75 Total $12,273.44 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A and B attached. DATED: ~Attorney for P~-aintiff Robert D. Kodak Judgment entered and damages assessed as above. P, OBEP, T E~TN'C K~IPP (1932-1976) CHRISTIAN V. GRAF ROBEKT L. KNUPP FREDERICK W. ANDREW5 ROBEP, T D. KODAK DAVID H. P, ADCLIFF WILLIAM J. FULTON KEV1N P,. DERR Mr. Mike Wenrich PERSONAL TOUCH PRODUCTS 41 Gettysburg Pike Mechanicsburg, PA 17055 LAW OFFICES OF GRAF, KNUPP ~ ANDREWS, P. C. C-~uM E R. ON MANSION 407 NORTH FRONT STR. EET P. O. BOX 118.48 IdAR.P, ISBUR. G, PA 17108 - 18,:1.8 February 3, 1987 OF COUNSEL JOHN E. FULLER.TON 717/238- 7151 717/236- 9318 WEST HANOVER TOWNSHIP OFFICE 4814 JONESTOWN KO,M) HAKRISBUKC, PA 17109 717/657- 2858 Re: P.G.A. Golf Vs: Mike Wenrtch t/a Personal Touch Products Our File #12919 No: 14 Civil 1986 Dear Sir: In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a notice of a praecipe for entrance of default judgment. According to the records as they are found in the Prothonotary's Office of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed notice which indicates that if you do not take action as set forth in this notice, we, at the expiration of time indicated therein, will request the Prothonotary's Office of Cumberland County to enter judgment against you in the amount as set forth in said Complaint. Very truly yours, GRAF, KNUPP & ANDREWS, P.C. RDK/bas Enclosure Robert D. Kodak CC: F.C.C. Financial Credit Corporation 7001 West North Avenue Oak Park, IL 60302 EXHIBIT "A" P.G.A. GOLF, Plaintiff vs. MIKE WENRICH t/a PERSONAL TOUCH PRODUCTS, De fe nd a n t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 14 CIVIL 1986 CIVIL ACTION - LAW IMPORTANT NOTICE TO: Mike Wenrich (Defendant) DATE OF NOTICE: February 3; 1987 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ~ LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR - THIRD FLOOR CUMBERLAND COUNTY COURTHOUSE HANOVER AND HIGH STREETS CARLISLE, PENNSYLVANIA 17013 (717) 249-1133 NOTICIA IMPORTANTE A: Mike Wenrich (Demandado) FECHA DE NOTICIA: February 3, 1987 USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO EN TOMAR MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIa, ES POSIBLE QUE UN FALLO SERIA REGISTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIA PERDER SU EXHIBIT "B" DCBA-200-Rule 4.7-4/3/81-M PROPIEDAD O OTROS DERECHOS IHPOPTANTES. USTED DEBE LLEVAR ESTA NOTICIA A SU ABOG~DO EN SEGUIDA. SI USTED NO TIENE ABOGADO O NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA O LLAMF A LA OFICINA E$CRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE OBTENER LA AYUDA LEGAL. COUI~T ADMINISTRATOR - THIRD FLOOR CUMBERLAND COUNTY COURTHOUSE HANOVER AND HIGH STREETS CARLISLE~ PENNSYLVANIA 17013 (717) 249-1133