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Home My WebLink About02-1180IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BALL, MURREN & CONNELL, a partnership NO.0j %? *" 2002 Civil Term 2303 Market Street Camp Hill, PA 17011 Civil Action-Law Plaintiff V. MOSAICA EDUCATION, INC. 61 Broadway, Room 2924 New York, NY 10006-2810 c/o CT Corporation System 1635 Market Street Philadelphia, PA 19103 Defendant PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary: Kindly issue a Writ of Summons in the above-Kpned action. l Richard E. Connell, Esq. Attorney I.D. #21542 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 Date: March 8, 2002 Attorney for Plaintiff WRIT OF SUMMONS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO: Mosaica Education, Inc. do CT Corporation System 1635 Market Street Philadelphia, PA 19103 Defendant You are hereby notified that BALL, MURREN & CONNELL, Plaintiff, has commenced an action against you. e%jm March 0' 2002 ?i CJJ m r • ,o ? CU -pG p rn? BALL, MURREN & CONNELL, : IN THE COURT OF a partnership, :COMMON PLEAS 2303 Market Street : CUMBERLAND COUNTY, PA Camp Hill, PA 17011 Plaintiff NO. 02-1180 2002 Civil Term V. MOSAICA EDUCATION, INC., CIVIL ACTION -LAW Defendant 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BALL, MURREN & CONNELL, a partnership, 2303 Market Street Camp Hill, PA 17011 Plaintiff : IN THE COURT OF :COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 02-1180 2002 Civil Term V. MOSAICA EDUCATION, INC., : CIVIL ACTION -LAW Defendant NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros decrechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADOO SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BALL, MURREN & CONNELL, a partnership, 2303 Market Street Camp Hill, PA 17011 Plaintiff V. : IN THE COURT OF :COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 2001 MOSAICA EDUCATION, INC., : Civil Term Defendant : CIVIL ACTION -LAW COMPLAINT 1. Plaintiff, Ball, Murren & Connell, is a law firm and partnership, organized and existing under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 2303 Market Street, Camp Hill, Pennsylvania. 2. Defendant, Mosaica Education, Inc., is a Delaware corporation with registered office in Pennsylvania at CT Corporation System, 1635 Market Street, Philadelphia, PA 19103. 3. Plaintiff entered into an agreement with defendant whereby plaintiff agreed to provide legal services to defendant and defendant agreed to pay plaintiff its customary and usual fees for the services performed and all costs incurred on defendnat's behalf in connection with services rendered. 4. During the course of its legal representation of defendant, plaintiff maintained books of account on the services that it rendered and the costs that it incurred on defendant's behalf, which accounts are an accurate and running account of all debits and credits for the provision of such services and incurring of such costs. 5. Regular invoices were mailed to defendant setting forth the services which had been rendered by plaintiff on defendant's behalf during the previous months, the reasonable value being charged for the services, and any outstanding balance due on services rendered prior to that time. 6. During the course of plaintiff's representation of defendant, plaintiff has from time to time received payments on the outstanding balances of defendant's accounts. 7. On or about March 18, 2002, plaintiff rendered the most recent of numerous written accounts to defendant in the amount of $55,176.50. A true and correct copy of the most recent accounts sent to defendant is attached to and incorporated into this complaint as Exhibit "A". 8. Although plaintiff has demanded payment of the balance due of $55,176.50, defendant has wrongfully failed and refused to pay all or any part of the balance due plaintiff. 9. Plaintiff performed its obligations under the agreement between it and defendant by providing legal services to defendant and incurring costs on its behalf, the fair and reasonable value remaining unpaid balance of which is $55,176.50. 10. Plaintiff has performed its services for defendant fully and conformed to, and complied with, all of the terms and conditions required of it under the oral agreement between it and defendant. 11. Despite defendant's obligation to pay plaintiff for the services performed and costs incurred on its behalf, and despite plaintiff's demands on defendant for such payment, defendant has wrongfully failed and refused to pay to plaintiff the sums due it. 12. Defendant has had an opportunity to scrutinize the accounts. 13. Defendant has agreed to or acquiesced in the correctness of the accounts and in its obligation to pay plaintiff the invoiced amounts for services rendered on its behalf. 14. Defendant has never questioned or objected either specifically or generally to the numerous accounts rendered. WHEREFORE, plaintiff, Ball, Murren & Connell, demands judgment against defendant in the amount of $55,176.50 together with costs, interest, and any other relief this court deems appropriate. Richard E. Connell Date: // A aU66 I.D. # 21542 (Attorney for Plaintiff) Ball, Murren & Connell 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 VERIFICATION I, RICHARD E. CONNELL, ESQ., verify that the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. m RICHARD E. CONNEL Date: At, '4 cv, ae6 '2- CERTIFICATE OF SERVICE I, Richard E. Connell, Esq., hereby certify that I placed a true and correct copy the foregoing Complaint in the U.S. Mail, first-class, postage prepaid, this 44 day of March, 2002. Hilary Lehv, Esq. General Counsel Mosaica Education, Inc. 61 Broadway, Suite 2924 New York, NY 10006-2810 Mosaica Education, Inc. c/o CT Corporation System 1635 Market Street Philadelphia, PA 19103 Richard E. Connell, Esq. I.D. # 21542 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 _? ?, - ' ?;? `<,; , ?.. :.? a?? BALL, MURREN & CONNELL, a partnership, : IN THE COURT OF :COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff V. NO. 02-1180 Civil Term 2002 MOSAICA EDUCATION, INC., Defendant : CIVIL ACTION -LAW TO: Mosaica Education, Inc. 61 Broadway, Suite 2924 New York, NY 10006-2810 and Hillary Lehv, Esq. 61 Broadway, Suire 2924 New York, NY 10006-2810 Date: May /"/ , 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 RIGIfTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, Pte-} (717) 0-6200 Richard E. Connell, Esq. I.D. # 21542 BALL, MURREN & CONNELL 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Richard E. Connell, Esq., hereby certify that I placed a true and correct copy of the foregoing documents in the U.S. Mail, first-class, postage prepaid to the following: Mosaica Education, Inc. 61 Broadway, Suite 2924 New York, NY 10006-2810 and Hillary Lehv, Esq. 61 Broadway, Suite 2924 New York, NY 10006-2810 DATE: )02 Richard E. Connell, Esq. C N Z - - r-, Cl) r; - 4 -, F-4 _ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BALL, MURREN & CONNELL, a partnership Plaintiff : No. 02-1180 CIVIL TERM 2002 V. MOSAICA EDUCATION, INC. CIVIL ACTION-LAW Defendant PRAECIPE TO SETTLE, DISCONTINUE & END WITH PREJUDICE TO THE PROTHONOTARY: Kindly mark the above-captioned matter as "Settled, Discontinued and Ended with prejudice." Richard E. Connell, Esquire # 21542 Counsel for Plaintiff Ball, Murren & Connell 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 Date: c r o a ? v C7 ?'` KAREN S. GEHRING and LARRY E. GEHRING, wife and husband, Plaintiffs V. PAUL E. HIGHLANDS, Defendant ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1180 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw NEALON GOVER & PERRY'S appearance on behalf of the Defendant, Paul E. Highlands, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: 4 - - Matthew R. Gover, Esquire Attorney I.D. No. 47593 For: Nealon Gover & Perry 2411 North Front St. ?S ?07 Harrisburg, PA 17110 Date: (717) 232-9900 011 CERTIFICATE OF SERVICE AND NOW, this U*l' day of October, 2007, 1 hereby certify that I have served the foregoing Withdrawal of Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Karl J. Januzzi, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Micha uson, Esquire r? c s=: - 1