HomeMy WebLinkAbout06-0436TEX VISIONS, LLC,
Plaintiff,
V.
RAINMEN USA, INC., t/d/b/a
AAA UMBRELLA COMPANY
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: Ob - 4l31a
CIVIL ACTION - LAW
NOTICE TO DEFEND
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 OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING AN ATTONEY.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFOMRATTON ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY COURTHOUSE
e FLOOR
CARLISLE, PA. 17013
#717-240-6200
TEX VISIONS, LLC,
Plaintiff,
V.
RAINMEN USA, INC., t/d/b/a
AAA UMBRELLA COMPANY
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 0 L - !Y36
CIVIL ACTION - LAW
COMPLAINT
AND NOW, this day of2006, comes the Plaintiff,
Tex Visions, LLC, by and through its undersigned attorneys, McShane & Hitchings,
LLC, and Joseph L. Hitchings, Esquire and avers in support of its Complaint against
Defendant, Rainmen USA, Inc., t/d/b/a AAA Umbrella Company, as follows:
1. Plaintiff, Tex Visions, LLC, is a limited liability company organized and
existing under the Laws of the Commonwealth of Pennsylvania with a principal place of
business located at 453 Lincoln Street, Carlisle, Cumberland County, Pennsylvania
17013.
2. Defendant, Rainmen USA, Inc., t/b/d/a AAA Umbrella Company, is believed
to be a New York corporation, which is doing business and engaging in commerce within
the Commonwealth of Pennsylvania with a principal address of 210 Route 4 East, Suite
302, Paramus, New Jersey, 07652.
3. Plaintiff is in the business of producing and selling custom printed textile
products.
4. Defendant does business under the fictitious name of AAA Umbrella
Company, using the same address as Raimmen USA, Inc.
5. On March 4, 2005, Rainmen USA, Inc. through its President, Jeff Nanus,
completed a Credit Application, which was approved and accepted by the Plaintiff. A
true and correct copy of the Credit Application is attached hereto, and incorporated here
and by reference and marked as Exhibit "A".
6. On that same date, March 4, 2005, Jeff Nanus, President of Rainmen USA,
Inc., also executed a Terms of Supply and Payment document detailing the terms,
conditions, and obligations for orders made through the Plaintiff. A true and correct copy
of the Terms of Supply and Payment is attached hereto, and incorporated here and by
reference and marked as Exhibit "B"
6. Pursuant to the terms and conditions of the Credit Application attached hereto
as Exhibit A, Defendant has agreed that venue for any action based on or arising out of
the Agreement will lie in a Court of competent jurisdiction in Carlisle, Pennsylvania.
COUNTI
HENNESSY TABLECLOTHS AND RUNNERS
7. The averments of paragraphs 1 through 6 hereof are incorporated by reference
as if the same were more fully set forth at length herein.
8. On or about January 14, 2005, Defendant placed a Purchase Order with the
Plaintiff for eight hundred and thirty (830) table runners, size 12" x 72", and eight
hundred and thirty (830) table cloths, size 60" x 84" bearing the logo "Hennessy".
A true and correct copy of the Purchase Order is attached hereto, and incorporated
here and by referenced and marked as Exhibit "C".
9. The Purchase Order attached hereto as Exhibit C makes it clear that the
method of decoration is embroidery, screen printing.
10. Defendants provided to Plaintiff the logos, which they were to use on the
table runners and tablecloths, however, the logo for the table runners was too small to
screen print and the Plaintiff declined to print the same.
11. Upon being informed that the logo was too small to screen print, the
Defendant insisted that the Plaintiff attempt to screen print anyway and Plaintiff asked its
Production Department to find a print solution.
12. Plaintiff's Production Department used an adhesive in order to screen print the
table runners, and the fabric, and the colors of the table runners were the same according
to eye inspection and according to the Plaintiff's color matching equipment. All banners
likewise passed Plaintiff's quality control.
13. Plaintiff ran several different combinations of the fabric and colors to satisfy
the Defendant. Throughout this period, the Defendant was in contact with Martin
Krause, who was acting on behalf of the Defendant via phone calls and email, and the
Defendant was advised that the problem with the printing would not exist if the table
runners were done in digital print.
14. Plaintiff fulfilled and delivered the order for the table runners and tablecloths
on March 16, 2005, and the same were accepted by the Defendant at its place of business
in Paramus, New Jersey.
15. Seeing that they had erred in ordering the tablecloth with the logo, the
Defendant attempted to cover itself by forwarding a revised Purchase Order sent by email
on March 17, 2005, removing the reference to a logo on the tablecloth. A true and
correct copy of the Purchase Order sent March 17, 2005, is attached hereto, and
incorporated here and by reference and marked as Exhibit "D"
16. Despite receipt and retention of the tablecloths and table runners, Defendant
has refused to pay the balance owing on the production of those items and there is
currently due and owing the total sum of fifteen thousand, seven hundred and one dollars
and fifty cents ($15,701.50).
17. The table runners and tablecloths delivered to the Defendant were free from
defects in both materials and workmanship, and passed both the Plaintiff's high quality
control standards as well as the quality control standards of the textile screen printing
industry.
18. Pursuant to the terns and conditions of the Credit Application, the Defendant
is liable for a service charge in the amount of twelve percent (12%) per month on the
outstanding balance together with all reasonable attorneys' fees, court costs and fees.
WHEREFORE, Plaintiff, Tex Visions, LLC, respectfully demands judgment
against the Defendant, Rainmen USA, Inc., t/d/b/a AAA Umbrella Company, in an
amount in excess of twenty five thousand dollars ($25,000.00).
COUNT II
ETOILE BANNER
19. Paragraphs 1 through 18 hereof are incorporated by referenced as if the same
were more fully set forth at length herein.
20. On or about January 5, 2005, Defendant faxed a Purchase Order to the
Defendant for one hundred and eighty (1$0) triple-point, high resolution screen printed
"Etoile Banners". A true and correct copy of the Purchase Orders are attached hereto,
and incorporated here and by reference and marked as Exhibit "E",
21. Upon receipt of the Purchase Order, Defendant began production of the
ordered banners.
22. On March 17, 2005, after the dispute arose concerning the Hennessy table
runners and cloths, Defendant attempted to change its prior Purchase Order by emailing a
new Purchase Order changing the order to digital print.
23. As was explained to the Defendant regarding the Hennessy orders, digital
printing is more expensive than screen-printing and cannot be offered at the same rate set
forth on a screen-printing Purchase Order.
24. Based on Defendant's original Purchase Order, Plaintiff produced two (2) pre-
production orders of the Etoile Banners.
24. When Plaintiff would not agree to change the Purchase Order for digital
printing at the screen printing cost, Defendant attempted to cancel its order.
25. Plaintiff has invoiced the Defendant in the amount of one thousand, two
hundred and thirty dollars ($1,230.00) constituting the pre-production samples run on the
Etoile Banners and the Defendant has failed and refused to pay all or any part of the
outstanding invoice. A true and correct copy of the invoice is attached hereto, and
incorporated here and by reference and marked as Exhibit "E"
26. Pursuant to the terms and conditions of the Credit Application, the Defendant
is liable for a service charge in the amount of twelve percent (12%) per month on the
outstanding balance together with all reasonable attorneys' fees, court costs and fees
WHEREFORE, Plaintiff, Tex Visions, LLC, respectfully demands judgment
against the Defendant, Rainmen USA, Inc., t/d!b/a AAA Umbrella Company, in an
amount less than twenty five thousand dollars ($25,000.00).
Respectfully submitted,
McShane & Hitchings, LLC
Joseph L. Hit6hings, E
Supreme Court I. D. No
f
4811 Jonestown Road
Suite 125
Harrisburg, PA 17109
717-657-3900
Attorneys for Plaintiff
VERIFICATION
1, Marcel Ruhland, President of Tex Visions, LLC, verify that the statements
made in this Complaint are true and correct to the best of my knowledge information and
belief. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. § 4904 relating to unswom falsification to authorities.
Date
,G
Marcel Ru land, President
Tex Visions, LLC
EXHIBIT ??E???
COPY
v sons .,
Credit Application:
Business Name tCa2 h rrt.e,? JS A T t c,
31,f jo.r
Street Address -1-10 1F. K ufe I (R.n jo2.)
P.O. BoxAf applicable)
City t OL'Y V_s
County State A) -Zip 07 AR
Phone (>O/ ) i? 6 c193 t? eM Fax --10/ )??G ma5</
Business Type (check applicable):
Sole Proprietor- Partnership
In Business since:
Principal Owners or Stockholders:
15' Principal ?1?E A)" uS
Corporation ?
Social Security N
Address 0-t0 E. 1
City, State, Zip ara H vs f>7GSY
Phone( ?01 ) --" 00 3J' ext ?0K
Title yes: d?1
2nd Principal
Social Security
Address
City, State, Zip
Phone ( _) - eM
Title
3'd Principal
Social Security
Address
City, State, Zip
Phone O eM
Title
Have you had any Bankruptcies?
Have you had any judgments, liens or pending suits against you or your company? _ D
Monthly Credit required? -2 000-
We will furnish financial statements on a yearly basis: ?o __ yes (attach copy)
Tex Visions LLC
453 Lincoln Street
Carlisle, PA 17013
(717) 249-3273 ph
(717) 249-4209 fax
Bank References:
Bank Name /17
Account No. 8
Street 1'10o r
City, State, Zip _
Person at bank to
Phone (S7-
Date Account -6-0-(
Bank Name
Account No.
Street
City, State, Zip
Persc: at bank to contact
Phone () - ext_
Date Account Opened
Fax O _ .
Current Trade Suppliers Where You Have an Open Account:
Company: 0 f/o lwe'a j 42- Titc
2
City, State, Zip: ors n A/A / k 'FS
Phone a ext Fax
Date Account Opened 7 y rs
Company:,/h.^ ? o .a-„c c-
City, state, Z-yD: r'vlct-? 51-e_ eJt_7e4777---
Phone _
('l1u ) 2'S1 -410in,, ext Fax( %
Date Account Opened 4N C5
Company: VorwaR.o ORFi`ec VttZ441Q' GEC
City, State, zip: IJ J yo-r;< N!? 102 6- /17/
Phone smo ext ? 'Fax ( / )x8 .._- *Coe _
Date Account Opened +l v rs
Credit Terms:
The Customer requests that Tex Visions LLC, including any assumed name or fictitious name or
trade name under which it trades or does business, hereinafter known as TV, sell goods on
account in consideration of which the Customer and TV agree as follows:
The Customer agrees to pay for all goods purchased 30 days after product completion. The
Customer agrees to pay a service charge on the outstanding balance for which payment has not
been received according to the terms stated. The service charge shall be 12% per month of the
Customer's outstanding balance and such service charges shall become part of the Customer's
outstanding balance.
In the event TV, must take legal action to collect this account, the Customer agrees to pay all
reasonable attorney's fees, including those incurred in any bankruptcy or appellate proceeding,
court costs, sheriff's fees, bond costs and lien costs incurred by TV.
If the Customer is not a corporation, the principal owners will remain personally liable for any
indebtedness incurred on the aforesaid account even if they later incorporate, unless the
customer serves a written notice of said incorporation by certified mail, return receipt requested,
upon TV at the above-indicated address. Personal liability shall continue for the account balance
incurred before said notice is received.
The Customer warrants that it will use all goods purchased under this account for business
purposes and that the Customer is not a consumer as defined by any applicable federal or state
usuryiaw.
This Credit Application cannot be amended or revised except in a written document executed by
the parties.
Venue for any action based on or arising out of this Agreement will lie in a court of competent
jurisdiction in Carlisle, PA.
I have read and fully understand the terms of payment outlined above.
I also read and fully understood the separate Tex Visions Terms and Conditions document. I am
duly authorized by the company to sign this document on its behalf.
Company Name "h wt e-" (Js/} ?KC
i
Signature _ Date _ 3 D
Print Name !v A?, S
Title Poe .5;7'
Signature
Print Name
Title
Date
rev. 01
EXHIBIT "B"
copy
Tex Visions LLC
453 Lincoln Street Carlisle, PA 17013, USA ???????
Tel. (717)249-3273 Fax: (717)249-4209 "
www.texvisiaiis.com trade@texviVuhs.com CAN- -
Terms of Supply and Payment
1. Making of Contract
Seteiy our terms set forth below shall apply. No contradictory rulings or rulings differing from our terms will be recognized- Inasmuch as rulings in these terms are subject to the reser-
vation of there being a different contractual agreement, this applies to individual agreements only and not to general terms of business which the other contractual partner may moor
porate into the contract. The sales consultants and robot staff of Tex VISIONS ILLS thereinafter called TV) are only authorized to accept declarations of intent and to broker contracts
They hold no power of representation enabling them to make and amend contracts, unless they have power of representation with a scope prescribed by law. The principles of appar-
ent authority or authority by estoppel are not prejudiced hereby. An order is only deemed to have been placed and have legal effect if acknowledged in writing by TV management.
Verbal agreements made between customers and TV employees are only effective when acknowledged in writing by TV management.
2. Prices
All prices quoted are without commitment. The prices are quoted net (not including any TA%). The quoted prices are subject to supply of all necessary customer designs which must
nave been graphically processed in compliance with the PC instructions supplied by TV. Charges apply at the then current hourly rate for any requested amendments or necessary
graphical processing. Items can date be collected from the works subject to cash payment. It, between submission of the tender and execution of the order, there is a rise in prices
Caused by increases in material or wage costs, TV has the right to amend prices. This shall apply during the rust 4 months after the making of the contract but only if the customer is
not a parent person. It price rises represent an increase by more than 5% of the total original price, the customer has the tight to rescind the contract within 14 days of receipt of the
rise
3. Customer's obligations to co-operate, Copyright, Trademarks
If contractual supply periods have been agreed, the customer must ensure that TV receives in due time the designs and computer files required for processing ue the artler. In respect
of printed data, the customer is liable for there being no infringement of copyrights, trademark rights and other property rights or third parties or companies. The drawings, drafts, pro
visional templates, films, computer files or other design material prepared by TV for the processing of the order shall remain the property of TV and may only be amended or passed
on to third parties in agreement with TV. Material relating to the order will be kept for 2 years in the form of films and/or drawings- Subsequent follow-up orders will be subject to
payment of a share in the costs of reactivating these designs. Charges will be. made at the then current hourly rates,
4. Fabrication in line with customer designs, excess or short supply, deviations is size
If items are to be produced using customer designs, TV will reproduce such designs as precisely as possible. IV reserves the right to make minor devoldens in color and representa-
tion which may resort door technical limitations of textile printing and from differing colors on different types of background materials. Such deviations do not constitute grounds for
complaint. This also applies to printing samples in comparison with series production. The customer agrees to accept any custonary excess or short supply by up to 100/. in respect
of items made to order. The customers account will be adjusted accordingly at the point of shipping. If an exact quantity is remained, there will be a price premium applied to the
order. All digitally printed orders will receive exact quantities. Deviations in width and length by +/- 7% are unavoidable as a result of technical production procedures and thus do
not constitute grounds for complaint. Exact measurements available on request.
5. Shipment/Supply
The supply periods quoted and prescribed are non-binding, unless TV has given an express guarantee that the supply period will be observed. The quoted supply date usually refers to
the date se shipment ex works. If the supply date is exceeded, the customer must first set an extension period of 14 days for completion or subsequent performance of the contract
and cannot rescind the contract and/or require damages instead of performance until this extension period has expired. The scope of such damages is defined under Section 10. The
goods are shipped at the expense and risk of the customer. Transportation and packaging casts will be paid by the customer. TV shall not be liable if there are delays in production or
supply or if such production or supply becomes impossible for reasons for which TV is not responsible. Such reasons can, in particular, be amendments or failure to supply necessary
material or drawings or delayed supply of the same. TV has the right to make partial deliveries and to bill them.
6. Supply of flagpoles and large pictures
When supplying flagpoles, TV accepts no liability for the necessary technical requirements being met or for statics, fastening or base. It is the responsibility of the customer td erect
flagpoles, to complete the assxiafed study of technical prerequisites and to arrange for the same. Large fabric pictures are subject to varying weather influences, especially when
positioned outside, the size of the advertising surface, and selection of basic material. Fabrication and erection technology have a decisive influence on proper and safe use of the
product. Consultation of a project manager with knowledge of local conditions is always recommended. TV's product warranty is limited to resistance to testing, light fastness and
washability under laboratory conditions. For products with a surface area of less than 25 m, the customer should request TV's production and erection recommendations before plac-
ing an order. For advertising surfaces with a basic area of more than 25 m , the customer most always arrange for planning work to be done before placing an artler. TV will not
accept any liability which is due to the customufs failure to consider specific application conditions and/or improper erection/uee-
7. Warranty
Notices of complaints will only be accepted if submitted to TV in writing within 8 days of receipt of the goods. If the customer is not a private person, this exclusion period only
applies to obvious faults. No warranty will apply if the customer fails to observe the supplied instructions for care and erection or if said customer has processed the goods or taken
them into operation. Usual wear and tear resulting from use does not constitute a reason for complaint, it complaint notices are justified, TV has the right either to remedy the defect
or to supply a non-defective replacement within 14 days of receipt of the returned goods. In soon a case, TV will pay the necessary shipment costs. If subsequent performance proves
unsuccessful, TV can do no more than reduce the purchase price or rescind the contract. The limitation period for the customer's warranty right is 112 of a year from receipt of goods.
This limitation reduction only applies if the customer is an non private person. This liability reduction for the limitation period does not apply in cases in which TV is liable due to
intent or in cases in which a defect has been maliciously concealed or in which a warranty has been given for product qualities.
8. Reservation of ownership
The goods supplied remain the property of TV until all outstanding claims and subsidiary claims have been paid in full. The customer is permitted to resell the conditional goods in
the course of due business only, inasmuch as said customers financial position does not deteriorate. The customer hereby assigns to TV the claim, including all subsidiary rights,
resulting from resale of the conditional goods. TV accepts this assignment. If assertion of this claim becomes necessary, the customer must provide TV with all necessary information
and permit verification of such information.
q. Liahire,
Damage claims resulting from breaches of obligations are restricted to compensation for foreseeable lasses and to the amount of the purchase price payable- This doe-, not apply to
intent and gross negligence on the part of TV, its legal representatives and agents dr in the event of injury to life, body and health- Tex Visions cannot be held resposible for damages
caused by improper handling, installation, extremes in weather condition, vandalism or accidents
10. Data recording
The customer agrees on the recording and processing of his personal data in a database. All data provided by the customer is subject to the obligation of secrecy and is not accessible
to third parties without a written document of authorization by the customer, exempt from a legal or official aide,
11. Place of junsdichod. place of fulfilment, applicable law -
If the customer is a merchant, Carlisle is deemed agreed as the common place of performance and place of junsmiftim far all reeproWl performance resulting from the contactual
relationship. In addition, the contract is governed solely by the law of the U lied State' sit America.
Name. _jGFC /J" 1/S Titre: de-d
Company- ? Ayyz ?1 JSf) 3,1 C Sfgnatur? lrv-- C.®PnP?o'iC")y &.-T p
once.
EXHIBIT "C"
r?
aaa
SATCHELS
rove xvx, rso.2. n.veas
zm e
I
vo,o . ..... 1W mss: rou :m-226 xxvavm
Ph 7172493273 Fx 7172494209 Vend# Req ship PO# Joh#
V
E
N
110604
02/10/05 50720 50720
D Tex Visions LLC.
R 453 Lincoln St
Carlisle PA 17013 H AAA U mbrella
t
P
T
O
Via Delivery Truck FOB FACTORY
Cust pa # Ord date Terms Salesperson
5441 01/07/05 Net 30 2P 4 Eileen Koslow
Ordered Shipped Item # Description Per Unit cost
630 RUNNER-HEN TABLERUNNER 12 X 72 EA 18.420
LOGO: HENNESSY
830 CLOTH-HENN TABLECLOTH 60- X 84 EA 5.560
LOGO: HENNESSY
Color and imprinting instructions Instructions to factory
LOGO: HENNESSY OVERSEAS ORDER Shi via
Delivery Truck
SIZE: BEST METHOD OF DECORATION: EMBROIDERY: SCREEN-
FOR THE TABLE RUNNER, 12 X 72,
FOR IMPRINT PMS# 180 RED
AND PANTONE BLACK 4C.
FOR THE TABLE CLOTH, 60 X 84, IMPRINT PANTONE BLACK 4C.
PRE-PRO: YES - ASAP
Frog #
OSBAGS
Instructions to factory
IIIIII I IW I? I? II? I? IIII
50720
Terms and conditions NEW PHONE 201-22"035 EW FAX 01.22"041 S, NJ 07852
PURCHASE ORDER
EXHIBIT "D"
?1
aaa
SATCHELS
zro n.m.a...n.ne xoz, vn.,.: v
vaxs
-22646
vm.m..,+u mesx r,,:xwamaoa+
V Ph 7172493273 Fx 7172494209 Vend# Req ship PO# Job#
E
D Tex Visions LLC. 110604 02/10/05 50720 50720
R 453 Lincoln St
Carlisle PA 17013
H AAA IImb=ells
P
T
O
Via Delivery Truck FOB FACTORY
Gust po # Ord date Terms Salesperson
5441 01/07/05 Net 30 2P 4 Eileen Koslow
Ordered Shipped Item # Description Per Unit cost
830 RUNNER-HEN TABLERUNNER 12 X 72 EA 5.560
LOGO: HENNESSY
830 CLOTH-HENN TABLECLOTH 60 X 84 EA 18.420
LOGO: NONE
Color and Imprinting instructions Instructions to factory
LOGO: HENNESSY OVERSEAS ORDER
SIZE: BEST METHOD OF DECORATION: SCREEN: Ship via Delivery Truck
FOR THE TABLE RUNNER, 12 X 72, IMPRINT RED AND BROWN AS
TEX VISIONS SAMPLE SUBMITTED AND APPROVED PREVIOUSLY
TABLE CLOTH, 60 X 84, COLOR TO MATCH BROWN OF TABLE
RUNNER
T
Instructions to factory 1
Prog # OSBAGS
C)
4j
? Q.yy?(.'?t' y.} dr?5+?.??
/
Sp
III?I
?
?III???I
II
3?17??s 1
II
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50720
rerms and conditions NEW ADD
NEW PHO
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EXHIBIT "E"
?Hr: b5-zbl?b(WtD) 11:21 RAINMEN USA (?AX)2?1 22F+9041 P. 00,/001
a1 S (r O
SATCHELS
hnnu., NJ 4}flee rue. ROy33e-0ON
Ph 7172493273 Fx 7172494209 Vend# Req ship PO # Job#
V
E 110604 02/11/05 50516 50516
o Tex Viai.one LLC.
R 453 LineOla 3t
Carlisle PA 17013 H To
I FOLLOW
P
T
O
Via UPS GrOUndTrak FOB FACTORY
Cost po # Ord date Tanns Salesperson
5432 12/17/04 Nat 30 2P 4 Eileen Koslow
Ordered Shipped Item # Description Par Unit cost
180 BANNER ETOILE BANNER EA 11.900
COLOR: TA UPE PMS# 8005
Color and Imprinting instructions instructions to factory
SAGO: ETOILE Ship via
UPS GrotladTtak
SIZE: BEST
Ile?= COLOR(S): 4 COLOR PROCESS
PANEL(S) PRINTED: ON THE BANNER
PRE-PRO: YES - ASAP
TRIPLE POINT HIGH RESOLUTION PRINTING
Prog # OSSAGS
Instructions to factory
PACKED: 5
CARTON DULR1(ING9/SHIP TO (TO FOLLOW)
IIII?I?II?I?II?>???
50516
Teens and conditions NNEW ADDRESS 210 ROUTE 4 F_ SM EW PHONE 2e1.71&aa3 NEW FAX 20142" d1U5, N! a7H52
PURCHASE ORDER
EXHIBIT "F"
Tex Visions
k "r
ons
453 Lincoln Street
Carlisle, PA 17013
USA
Bill To
AAA Umbrella Company
Jeffrey Nanus
210 Route 4 Eas14302
Paramus, NJ 07652
USA
Invoice
Date Invoice #
4!5(2005 85
Ship To
AAA Umbrella Company
Jeffrey Nanus
210 Route 4 East d 302
Paramus, NJ. 07652
USA
Soloc # P.O. No. Terms Due Date Rep Ship Via
54 50516 Due on receipt 4!512005 Team3 UPS
Item Description Qty Rate Amount
Indoor Banners... PROJECT: Etoile ***PRE-PRODUCTION SAMPLES*** 2 600.00 1,200.00
ES]. DEL. DATE: ASAP
SIZE: 15"x28" (width x height)
MATERIAL: Dckoflag H
PRINT: 4 color process Screen Print, 50-70% throughprint
FINISH: cut 4 sides plus special cut
ACCESSORIES: Dowel and polyester cord
LAYOUT: according to confirmed proof provided by Tex Visions, color design in
accordance with your artwork, digitally printed, design reads correctly on the front and
moderate on the back side
COLORS:PMS 8005 Since you did not provide a proof (sample, printed proof) we
will adjust the colors according to your graphic. Color deviations as reason for
complaint wilt not be accepted.
Subtotal
Our Perms of Supply and Payment apply and are available online at www.texvisionscom or Sales Tax (0.0%)
upon request
Total
Payments/Credits
Balance Due
Phone # Fax # E-mail Web Site
(717) 249-3273 (717) 249-4209 tradela,texvisionsxom www.texvisions.com
Page 1
Tex Visions
453 Lincoln Street
'1/I5?t1t15 .M Carlisle, PA 17013
,q%jwww.,?, USA
Bill To
AAA Umbrella Company
Jeffrey Nanus
210 Route 4 East#302
Paramus. NJ 07652
USA
Invoice
Date Invoice #
4/5/2005 85
Ship To
AAA Umbrella Company
.Jeffrey Nanus
210 Route 4 East # 302
Paramus, NJ. 07652
USA
SO/OC # P.O. No. Terms Due Date Rep Ship Via
54 50516 Due on receipt 41512005 ream3 Lips
Item Description Qty Rate Amount
*** PRE-PRODUCTION SAMPLES***
-- ---------------------------------------------
Shipping/Handl... Charges for Shipping and Handling TBD 1 30.00 30.00
Subtotal
Our Terms of Supply and Payment apply and are available online at www.texvisions.com or
upon request. Sales Tax (O,Q%)
Total
PaymentslCredits
Balance Due
Phone # Fax # E-mail Web Site
(717) 249-3273 (717) 249-4209 trade?,texvisions.com wcvw.texvisions.com
$1,230.00
$0.00
$1.230.00
$0.00
$1,230.00
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TEX VISIONS, LLC,
Plaintiff,
V.
RAINMEN USA, INC.,t/d/b/a
AAA UMBRELLA COMPANY
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.: 06-436
CIVIL ACTION -LAW
TO: CUMBERLAND COUNTY PROTHONOTARY
PRAECIPE FOR REINSTATING COMPLAINT
Kindly reinstate the Complaint in the above-matter and return the same to the undersigned.
Respectfully submitted,
Dated: April S , 2007
To:
MCSHANE & HITCHINGS LLC
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Attorney ID No.: 65551
4807 Jonestown Road, Suite 148
Harrisburg, PA 17109
Telephone: (717) 657-3900
Attorney for Plaintiff
Office of the Prothonotary
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Curtis R. Long
Prothonotary
Office of the Vrotbonotarp
Cumberlaub (fountp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
-loin - j3 p CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573