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HomeMy WebLinkAbout02-2886INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 02-2886 NOTICE OF DEFAULT JUDGMENT TO: Intertel, Inc. Attn: Kevin DeRossett 12430 Tesson Ferry Road PMB 359 St. Louis, MO 63128 You are hereby notified that on July ,~ , 2002, judgment by default was entered against you in the sum of $9,770.34, plus costs and interest, in the above-captioned case. Prothon;if~-yt ~ O/ 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 I hereby certify that the following is the last known address of the Defendants: Intertel, Inc. Attn: Kevin DeRossett 12430 Tesson Ferry Road PMB 359 St. ~A~f Louis, MO 63128 TU'O S O. n2LmUS, ESQUm Attorney for Plaintiff A Defendido/a Por este medio sea avisado queen el dia __ de ,2000, un fallo por admision rue registrado contra usted por la cantidad de $9,770.34 del caso antes escrito. Fecha: Protonotario LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA A LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-316~ Tho~s O.'Williams Abogado del Demandante INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 02-2886 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, Investigative Consultant Services, Inc., and against the Defendant, Intertel, Inc., in the amount of $9,770.34 plus costs and interest, for failure to plead to Plaintiff's Complaint. The undersigned hereby certifies that a 10-Day Notice of Plaintiff's intent to file the instant praecipe for default judgment for failure to respond to Plaintiff's Complaint was mailed to Defendants. A true and correct copy of the aforementioned Important Notice is attached hereto as Exhibit A. Date: July 23, 2002 Respectfully submitted, REAGER & ADLER, P.C. Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Attorneys for Plaintiff Exhibit A INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO: 02-2886 CERTIFICATE OF SERVICE I, Thomas O. Williams, verify that on July 9, 2002, I caused the Notice which ~atta~ed hereto as Exhibit A to be placed in the United States mail, first class, postage prepaid and addressed to Defendant at Intertel, Inc., 12430 Tesson Ferry Road, PMB 359, St. Louis, MO 63128. A copy of the certificate of mailing is attached hereto as Exhibit B. Date: July [~, 2002 Respectfully submitted, R.EAGER & ADI,~R, P.C. Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 02-2886 IMPORTANT NOTICE TO: Intertel, Inc. Arm: Kevin DeRossett 12430 Tesson Ferry Road PMB 359 St. Louis, MO 63128 DATE OF NOTICE: July 9, 2002 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COLrRT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. LrNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,. A JUDGIVIENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OK TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Respectfully submitted, Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff EXHIBIT "A"  Affix ere ......... E --POSTII~ASTER . ........ J~et Reoel~d From: , ~a~er f 2331 M~ket s~eet ~ ~ Fo~ 3817; ~jl~n~/ end EXHIBIT "B" INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 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 fall 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 INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff 1NTERTEL, INC., De~ndant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 0o- ,2. 7g , COMPLAINT 1. The Plaintiff is Investigative Consultant Services, Inc. (hereinafter "ICS") a corporation incorporated and doing business under the laws of the Commonwealth of Pennsylvania, with its principal place of business located at 4004 East Trindle Road, Camp Hill, Cumberland County, Pennsylvania 17011-4242. 2. The Defendant is Intertel, Inc. (hereinafter "Intertel") a corporation believed and therefore averred to be incorporated and doing business under the laws of the State of Missouri, with its principal place of business located at 12430 Tesson Ferry Road, St. Louis, Missouri 63128. 3. ICS is engaged the business of investigative and surveillance services. COUNT I: BREACH OF CONTRACT 4. At various times from April 2001 through July 2001, Intertel requested ICS to perform investigative and surveillance services on its behalf. 5. ICS performed the requested services for Intertel, which services are more fully described in the invoices of ICS attached hereto and incorporated herein by reference as Exhibit A. 6. A, were the rates and expenses which Intertel agreed to pay to ICS. The charges indicated on the invoices of ICS, which are attached hereto as Exhibit 7. Despite demand for payment by ICS, Intertel has failed and refused to make payment on the invoices of ICS. 8. Intertel accepted the services of ICS. 9. Intertel's failure and refusal to pay ICS's invoices constitute a breach of contract. 10. Intertel acknowledged its indebtedness to ICS for the services performed by ICS in an e-mail message dated October 19, 2001 from Intertel's president, Kevin DeRossett. A true and correct copy of the aforesaid e-mail is attached hereto as Exhibit B. 11. Intertel is promissorally estopped from denying its liability to pay for the services rendered by ICS. 12. All conditions precedent for the bringing of this action have occurred and/or have been performed. The principal balance remaining due ICS for the services rendered Intertel is 13. $9,770.34. 14. 15. contract. 16. Despite demand, Intertel has failed and refused to pay ICS for the services rendered by ICS and there remains a principal balance due of $9,770.34. Intertel's failure and refusal to pay for ICS's services constitutes a breach of As a result of Intertel's breach of contract, ICS has suffered damages in the principal amount of $9,770.34. WHEREFORE, Plaintiff Investigative Consultant Services, Inc. respectfully requests this Honorable Court to enter judgment in its favor and against Defendant Intertel, Inc. in the amount of $9,770.34 plus costs and interest. COUNT II: ACCOUNTS STATED 17. Plalmiff incorporates herein by reference the averments of paragraph 1 through 16 above as if set forth fully herein. 18. ICS performed the investigative/surveillance services for Intertel upon the open account of Imertel for which ICS sent its invoices which invoices are attached hereto as Exhibit A. Intertel has not objected to any of the invoices submitted by ICS and in fact has acknowledged and promised to pay same. 19. ICS's invoices and Intertel's acknowledgment of the charges therein constitute an account stated. 20. Intertel has failed and refused to pay the amount set forth in the aforementioned invoices attached hereto as Exhibit A. WHEREFORE, Plaintiff Investigative Consultant Services, Inc. respectfully requests this Honorable Court to enter judgment in its favor and against Defendant Intertel, Inc. in the amount of $9,770.34 plus costs and interest. COUNT III: UNJUST ENRICHMENT 21. Plaintiff incorporates herein by reference the avermems of paragraph 1 through 20 above as if set forth fully herein. 22. Intertel has accepted the services of ICS and has received the benefit thereof. The fair market value of said services is $9,770.34. 23. It is believed and therefore averred that Intertel passed the charges set forth in ICS's invoices on to Sedgwick CMS and that Intertel has received payment from Sedgwick CMS for those charges but has failed to make payment to ICS. 24. Intertel has refused and continues to refuse to pay the $9,770.34 to ICS. 25. It would be unjust to permit Defendant Intertel to retain the benefit of the services rendered by ICS as reflected in the invoices attached hereto as Exhibit A without paying for SaBle. WHEREFORE, Plaintiff Investigative Consultants Services, Inc. respectfully requests this Honorable Court to enter judgment in its favor and against Defendant Intertel, Inc. in the amount of $9,770.34 plus costs and interest. Date: Respectfully submitted, REAGER & ADLER, P.C. Thomt{s O. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-464 Telephone: (717) 763 - 1383 Attorneys for Plaintiff 4 Exhibit A Investigative Consultant Services, Inc. EMPLOYER I.D. = 23-2078]77 July 31, 2001 Ms. Brenda L. Donat Director of Vendor Relations Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63 I28 Re: Joan Singh, Claimant Client Claim Number: 9968100208-0001-01 ICS File Number: PH-00-1110-RW2 TIME iNVESTED 07/25/01 Surveillance/Investigation-One Day~ $500.00 ....................... S 500;00 EXPENSES ~CURRED 07/25/01 95 Total Miles @ $0.50 Per Mile .............. NC Tolls-$1.20 ....................................... NC Two Videotapes ~ $10.00 Each (Sedgwick and Intertel) ................ NC PAST DUE TOTAL $ 500.00 -- INVOICE PAYABLE UPON RECEIPT- Please remit to: ICS · 4004 E TrindleRd. ° Camp Hill, PA 17011 Investigative Consultant Services,Inc. EMPLOYER I.~1~.. ~,6]~ff$ tJignat Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, MO 63128 July 23, 2001 Re: Jotm Busbey, Subject Client File Number: A068102590-0001-01 ICS File Number: HB-01-535RWI TIME INWESTED 07/13/01 07/14/0I Surveillance/Investigation · . Surveillance/Investigation 16.0 Total Hours ~ $49.00 Per Hour ........................... $ 784.00 EXPENSES INCURRED 07/I3,'0I 07/I4/0I I01 Miles I23 Miles 224 Total Miles ~ $0.50 Per Mile ................ $112.00 Videotape ........................................ N/C I Copy of videotape provided to attorney ...... 25.00 $137.00 TOTAL $ 921.00 PAST DUE -- INVOICE PAYABLE UPON RECEIPT-- Please remit to: ICS · 4004 E. Trindle Rd. ° Camp Hill, PA 17011 Investigative ConSultant Services,Inc. EMPLOYER 1.1~;. :~.2e0rl7dSalE ~onat I~teEel, Inc. 12430 Tesson Fen'7 Road PMB 359 St. Louis, Missouri (53128 July 11, 2001 Re: Debra Rarig, Subject Client File Number: A181005493-0001-01 ICS File Number: HB-01-569 TIME INVESTED 06/28/01 Surveillance/Investigation Report Preparation and Administrative Time 9.0 Total Hours ~ $49.00 Per Hour .................................. $ 441.00 EXPENSES INCURRED 06/28/01 179 Miles ~ $0.50 Per Mile ................ $89.50 TOTAL $ 89.50 $ 530.50 PAST DUE -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4004E. TrindleRd. ° CampHill, PA 17011 Investigative ConsUltant Services, Inc. E~PLOYER L~,~S~' ~:~..~,(~)j,~ ~nat Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, MO 63128 July 5, 2001 Re: John Busbey, Subject Client File Number: A068102590-0001-01 ICS File Number: HB-01-535 TIME INVESTED 06/07/01 06/23/01 Surveillance/Investigation Surveillance/Investigation 18.5 Total Hours ~ $49.00 Per Hour .................................. EXPENSES INCURRED 06/07/01 06/23/01 108 Miles 105 Miles 213 Total Miles ~ $0.50 Per Mile ................ $106.50 4 Motor Vehicle Checks ~ $ I 0.00 Per Check ......... N/C 1 Videotape ........................................ N/C 906.50 PAST DUE TOTAL $ 106.50 " 0 $ I01.~.0 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: IC$ · 4004 E. Trindle Rd. · Camp Hill, PA 17011 Investigative Consultant Services, Inc. EMPLOYER I.D. ~ 23-2078177 June26,2001 Ms. Brenda L. Donat Director of Vendor Relations Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63128 Re: Joan Singh, Subject Client File Number: 9968100208-0001-01 ICS File Number: PH-00-1110RWI TIME IN%qE STED 05/17/01 05/21/01 05/22/0I 05/31/01 06/05/01 Surveillance/Investigation-4.5 Hours Survefllance,rlnvest]=at~on-.~ Hours ... Surv'eilIance/Investigation-2.5 Hours Surveillance/Investigation- 1.5 Hours Surveillance/Investigation -5 Hours (No charge for second investigator) 2 Days Fiat Rate @S500.00 Per Day ..................................... $ 1000.00 EXPENSES [NCLrRRED 05/17/01 05/21/01 05/22/01 05/31/01 06/05/01 84 Miles 84 Miles 89 Miles 90 Miles . · 95 Miles 442 Total Miles ~ $0.50 Per lVlile ..................... N/C 1 PA Motor Vehicle Check ......................... $10.00 PAST DUE TOTAL Jo O0 $ 1010.00 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4004 E. Trindle Rd. · Camp Hill, PA 17011 Inw tigative Consultant Services, Inc. EMPLOYER I,D. x 23.2078 ]'17 3une 12, 2001 Ms. Brenda L. Dong Director of Vendor R~lations /~tertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63128 Re: Cindy Chrke, Subject Claim Number: 9833102702 ICS File Number: WB-99-974.H 05/21/01 Hear/rig-Two Investigators 10.5 Hours ~ $49.00 Per Ho~r ..........................................$ 514,50 EXP_ENSES INCURR Fn 05~1/01 386 To~Miles~$O.50P~Mile ........... $193.00 ,PAST DUE TOTAL 193.00 $ 707.50 q II"tVOICE PAYABLE UPON RECEIPT Please remit to: ICS · 4004E, THndleRd. ,, Camp HJll. PA 170ll Investigative Consultant Services,Inc. EMPLOYER I.D. ~ 23-2078]77 June 11,2001 Ms. Brenda L. Donat Director of Vendor Relations Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63125 Re: Michael Duda, Subject Claim Number: 80013879331 ICS File Number: WB-89-909.A TIME 1NVESTED 06/01/01 Pie 'Idng Up Carncorder And Accessories-0.5 Hour/1 Hour Travel 1.5 Total Hours ~ $49.00 Per Hour .................................... $ 73.50 EXPENSES I'NCURRED 06/01/01 54 Total Miles ~ $0.50 Per Mile .... $ 27.00 PAST DUE TOTAL 27.00 $100.50 -- INVOICE PAYABLE UPON RECEIPT Please remit to: ICS · 4004 E. Trlndl~ Rd. · Camo Hill. PA 1701 Investigative Consultant Services, Inc. Et4PLOYER I.D. ~ 23-2078i77 June 11,2001 Ms. Brenda L. Donat Director of Vendor Relations Intend, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63128 Re: Lorane Gonzalez, Subject Claim Number: A068102320-0001-01 ICS File Number: WB-01-481 TIME IN'VESTED 05/31/01 06/01/01 SurveiI ance/Investigation-5.5 Hours ~ $49.00 Per Hour ............ $ 269.50 Surveillance/Investigation-One Day ~ $500.00 ........................ 500.00 EXPENSES INCURRED 05/31/01 26 Total Miles ~ $0.50 Per Mile ............. $13.00 One PA Motor Vehicle Check ................. $10.00 Two Videotapes ~ $10.00 Each (Sedgwick And Intertel) .............. NC 23.00 PAST DUE $ 792.50 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4OO41= Trlnrtl~,l~4. · CamDHilI. PA 17,qll Investigative Consultant Services,Inc. EMPLOYER i.D. = 23-207817? June 5, 2001 Ms. Brenda Donat Director of Vendor Relations Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63128 Re: Robert Bea~', Subject Client Claim Number: 80001608332 ICS File Number: PG-01-457 TIME IN'VESTED 05/21/01 Live and Well Investigation in Person-0.5 Hour/5 Travel Hours 5.5 Total Hours ~ $49.00 Per Hour .................................... $ 269.50 EXPENSES INCURRED 05/21/01 254 Total Miles @ $0.50 Per Mile .............. $127.00 .127.00 TOTAL $ 396.50 PAST DUE -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4004 E. Trindle Rd. · Camp Hill, PA 17011 InveStigatwe Consultant Services, Inc. EMPLOYER I.D. ~ 23-2078177 June 5,2001 Ms. Brenda Donat Director of Vendor Relations Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Ivfissourl 63128 Re: Eric Burton, Subject Claim Number: A181001347-0001-0i ICS File Number: PH-01-340RW1 TIME INVESTED 05/04/01 05/29/01 05/31/0I Su~'eillance/Investigation Surveillance/Investigation Sur~'eillance/Investigation Two Days ~ $500.00 Per Day ............................................ $1000.00 1 Total Hour ~ $49.00 Per Hour ........................................ 49.00 EXPENSES INrCURRED 05/04/01 05/29/01 05/31/01 130 Miles 126 Miles 60 Miles 316 Total Miles @ $0.50 Per Mile ........... NC Tolls $2.50 ....................................... NC One PA Motor Vehicle Check ................ '.$. 10.00 Two Videotapes ~ $10.00 Each (Sedgwick And Intertel) .............. NC I0.00 PAST DUE TOTAL $1059.00 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4004 E. Trindle Rd. · Camp Hill, PA 17011 Investigative ConSultant Services,Inc. EMPLOYER I.D. * 23-2078177 May 30, 2001 Ms. Brenda Donat/Ms. Robin McCoy Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63128 Re: Brenda Troutman, Claimant Claim Number: A068102465-0001-01 ICS File Number: HB-01-453 TIME INVESTED 05/17/01 05/I 9/01 Surveillance/Investigation Surveillance/Investigation Two Days ~ $500.00 Per Day ............................................ $1,000.00 EXPENSES IN'CUP/LED 05/17/01 05/19/01 265 Miles 252 Miles 517 Total Miles @ $0.50 Per Mile ........... NC One PA Motor Vehicle Check ................. $. 10.00 10.00 TOTAL PAST DUE $1,010.00 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4004F. Trinrlb~l~rt · CnmnHilLPA 17011 Investigative Consultant Services, Inc. EMPLOYER I.D. = 23-2078]77 May 11, 2001 Ms. Brenda Donat Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63128 Re: Val Jean Beltz, Subject Client File Number: Y01-0586/92000632 ICS File Number: HB-99-1468 TIMT INVESTED 04/19/01 04/20/01 04/24/01 Motor Vehicle Search/File Review Telephone Searches Activi¢' Cb. eck Report Preparation and Administrative Time 3.0 Total Hours ~ $49.00 Per Hour ....................................... $ I47.00 EXPENSES INCURRED 04/I 9/0 I 04/20/01 04/24/01 00 Miles 00 Miles 90 Miles 90 Total Miles ~ $.47 Per Mile .......... $ 42.30 3 Motor Vehicle Checks ~ $10.00 Per Check ...... 30.00 Record Checks ........................ 10.00 ' PAST DUE TOTAL $ 82.30_ $ 229.30 INVOICE PAYABLE UPON RECEIPT -- Please remit to: · ~lOnAC "r~.~lor~A · C'~rnr~HilLPA 17011 Investigative Consultant Services, Inc. EMPLOYER I.D. = 2,3-2078177 April 24, 2001 Ms. Brenda Donat Intertel, Inc. 12430 Tesson Ferry' Road PMB 359 St. Louis, MO 63128 RE: CINDY CLARKE ICS FILE NO.: ~VB-99-974 YOUR FILE NO.: 9833102702 TIME INVESTED 04/05/01 04/06/01 04/10/01 Surveillance/Investigation Surveillance/Investigation Surveillance/Investigation Report Preparation and Administrative Time 12.5 Total Hours ~ $49.00 Per Hour ...................................... $ 612.50 EXPENSES~'CURRED 04/05/01 04/06/01 04/I0/01 78 Miles 78 Miles 78 Miles 234 Total Miles ~ $.47 Per Mile .......... $109.98 PAST DUE TOTAL 109.98.' ...' 722.48 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4004 15. Trindle Rd. · Camp Hill. PA 1701 Investigative Consultant Services,Inc. EMPLOYER I.D. = 23-2078177 April 23, 2001 Ms. Brenda Donat Inter'tel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, MO 63128 RE: MICHAEL DUDA ICS FILE NO.: WB-98-909 YOUR FILE NO.: 80013879331 TIME IN'VESTED 04/05/01 04/10/01 04/11/01 Surveillance/Investigation Surveillance/Investigation Surveillance/Investigation Report Preparation and Administrative Time 11.0 TotaI Hours ~ $49.00 Per Hour ...................................... ,~9.00 EXPENSES INCURRED 04/05/01 04/10/0 i 04/11/01 56 Miles 56 Miles 56 Miles 168 Total Miles ~ $.47 Per Mile .......... $ 78.96 PAST DUE TOTAL 78.96_''. 617.96 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: IC.q · 40041:: Tdnrll~!~d · Camv Hill, PA 17011 Investigative Consultant Services, Inc. EMPLOYER I.D. ~ 23-2078]77 April 23, 2001 Ms. Brenda Donat Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, Missouri 63128 Re: Anthony Matuszky, Subject Client Claim Number: 86001177332 · Client Case Number: Y01-1470 ICS File Number: PG-01-346 TIME INVESTED 04/11/01 Live and Well Investigation 2.5 Total Hours ~ $49.00 Per Hour .................................... $122.50 EXPENSES INCURRED 04/I 1/01 80 Total Miles ~ $0.47 Per Mile .............. $ 37.60 PAST DUE TOT=' 37.6Q $160.10 -- INVOICE PAYABLE UPON RECEIPT -- Please remit to: ICS · 4004 E. Trindle Rd. ' Camp Hill, PA 17011 Exhibit B AOL.COM [,AOL Mail , . , . Page 1 of 2 Subj: Vendor Payments Date: Fri, 19 Oct 2001 4:58:46 PM Eastern Daylight Time From: "intertel" <intertel@intertelgo.com> ~o: <ispycarl@aol.com> Dearlnvee~gative Consul~ntSe~ices: INTERTEL wants to keep you informed of the status of our acco'ant with you to pay for services 2efformed by you. We had, and still have, every intention of satisfying our indebtedness.. -towever, recently we were abruptly informed that our SIU contract with Sedgwick was being unilaterally canceled by them. Therefore, the substantial busine,~s that we had expected from them is no longer forthcoming at this time. As a result, we must reduce ou,' overhead by reluctantly cutting our staff and moving to less expensive premises, while we are continuing to operate in an effort to restore lost business. In addition, Sedgwick has refused, without cause, to pay us a substantial amount of money owed to us, most of which was earmarked for payment on our obligations. We are attempting to secure replacement funds as quickly as we can, and you can be assured that we will satisfy our obligation to you as soon as possible. We are exploring with our attorneys all available remedies to put us back in full operation of our business, so that we can continue to work with you and others for our mu[uat profit, with restoration of the good relations that we have enjoyed in the pasL We certainly appreciate all of your past considerations and welcome your cooperation while we are getting this matter straightened out. We shall keep you informed of oul progress. Very truly yours, KEVIN DeROSSETT President, INTERTEL .................... Headers ..................... Return-Path: <intertel@intertelgo.com> Received: from rly-za03.rax.aol.com (rly-za03.mail.aol.com [172.31.36.99]) by air-za02.mail.aol.com (v81.9) with ESMTP id MAILtNZA22-1019165846; Fri, 19 Oct 200! 16:58:~6 -0400 Received: from intertelgo.com (intertelgo.com [199.217.152.90]) by rly-za03.mx.aol.com (v80.21) with ESMT]? id MAILRELAYINZA37-1019165818; Fri, i9 Oct 2001 16:58:18 -0400 Received: from Jan ([192.168.1.34]) by intertelgo.com with SMTP (IPAD 2.52) id 3887500; Fri, 19 Oct 2001 15:16:57 -0600 Hessage-ID: <00b101c158flSaeacb00052201aSc0@ITC> F Include odginaltext in Reply, Reply Reply All Forward Address Book VERIFICATION I, Carl Schleicher, President of Investigative Consultant Services, Inc., 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. Section 4904, relating to unsworn falsification to authorities. CERTIFICATE OF SERVICE I, Thomas O. Williams, counsel for Investigative Consultant Services, Inc., hereby certify that on this date, I have caused to be sent by first class certified mail, return receipt requested, a tree and correct copy of PlaintiWs Complaint to: Kevin DeRossett Intertel, Inc. 12430 Tesson Ferry Road St. Louis, MO 63128 Date: INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO: 02-2886 '. : .AFFIDAVIT OF SERVICE BY MAIL COMMONWEALTH OF pENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) Thomas O. Williams, Esquire, being duly sworn, upon oath, deposes and says as follows: 1. I am the attorney for Plaintiff in the above-entitled case. On June 14, 2002, I caused to be transmitted, by a form of mail requiring a signed receipt, a copy of the complaint filed in this action to the following: Kevin DeRossett, Intertel, Inc. A copy of my transmittal letter is attached hereto as Exhibit "A". 2. I further depose and say th,at, I thereafter received fro,m,,the Postmaster of Camp Hill, a return receipt bearing the notation Date of delivery: 6-18-02. A copy of the official return receipt is attached hereto as Exhibit "B". (~A$$ANDRA T. ROSENBAUM, Noisy Pul~oI REA~,~. (~amp HIll Bom. Cum~fl~d ~n~ / My C~mi~i~ Ex,ms D~m~r 4. ~ ~ ~ ~h6~as O. Willies, Esquire Attorney I.D. No. 67987 2331 M~ket Street Crop Hill, PA 17011-464 Telephone: (717) 763-1383 Sworn to and subscribed before me this 26th day of June, 2002. Notary Public THEODORE A. ADLER + DAVID W. REAGER CHARLES E. ZALESKI LINUS E. FENICLE DEBRA DENISON CANTOR REAGER & ADLER, PC ATTORNEYS AND COUNSELORS AT LAW 2331 MARKET STREET CAMP HILL, PENNSYLVANIA 17011-4642 717-763-1383 TELEFAX 717-730-7366 WEBSITE: ReagerAdlerPC.com Writer's E.Mait Address; tomwitl~epix.net June 14, 2002 Via Certified Mail/Return Receipt Requested THOMAS O. WILLIAMS SUSAN H. CONFAIR JOANNE HARRISON CLOUGH CHRISTINE SCHWAMBERGER DOUGLAS P, LEHMAN + Certified Civil Trial Speciatist Kevin DeRossett Intertel, Inc. 12430 Tesson Ferry Road PMB 359 St. Louis, MO 63128 Re: Investigative Consultant Seryices, Inc. v. Intertel, Inc. Docket No: (~ ~,,--"T ~(,-~ Our File No.: 00-871.004 Dear Mr. DeRossett: Enclosed for service upon you is a Complaint in the above captioned matter. If you have any questions, please do not hesitate to contact me. Thank you. TOW/cmr cc: Carl Schleicher Investigative Consultant Services, Inc. EXHIBIT "A" HILL, PA 17011 7111 1746 2100 0003 0051. By: (P/ease Print 3A 7111 1746 2100 0003 0051 1; Article Addrlssld To: D. Addressee's AddrM~ (~Dmm~MMm~UMd~YM~M KEVIN DEROSSETT INTERTEL, INC. 12430 TESSON FERRY ROAD PMB 359 S~T~.,-~UIS MO 63128 EXI-IIBIT "B" INVESTIGATWE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 02-2886 : CERTIFICATE OF SERVICE I, Thomas O. Williams, verify that on July 9, 2002, I caused the Notice which is attached hereto as Exhibit A to be placed in the United States mail, first class, postage prepaid and addressed to Defendant at Intertel, Inc., 12430 Tesson Ferry Road, PMB 359, St. Louis, MO 63128. A copy of the certificate of mailing is attached hereto as Exhibit B. Date: July/~, 2002 Respectfully submitted, REAGER & ADI_~R, P.C. Thomas O. Williams, Esquirex' Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff INVESTIGATIVE CONSULTANT SERVICES, INC., Plaintiff INTERTEL, INC., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO: 02-2886 IMPORTANT NOTICE TO: Intertel, Inc. Attn: Kevin DeRossett 12430 Tesson Ferry Road PMB 359 St. Louis, MO 63128 DATE OF NOTICE: July 9, 2002 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 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 NOTICE TO A LAWYER AT ONCE. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Respectfully submitted, REA~~. C. Thomas O.'~illiam~ Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff EXHIBIT "A" EXHIBIT "B"