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Home My WebLink About06-7253Daniel G. Dougherty, Esquire Attorney I.D. No. 61075 881 Third Street Suite B-3 Whitehall, PA 18052 (610) 264-9840 SATELLITE INDUSTRIES, INC. 2530 Zenium Lane N. Plymouth, MN 55441 Plaintiff vs DONALD L. GROFF and DAVID E. FEAGLE T/A GROFF & SON PORTABLE TOILET SERVICE a/k/a GROFF SEPTIC SERVICE 99 Ickes Lane Newville, PA 17241 Defendant NOTICE ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY, PA COURT OF COMMON PLEAS CIVIL DIVISION No. ~~ --- 7.23 ~ t v ~ ~,.~ 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (800)990-9180 ,~ Daniel G. Dougherty, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW SATELLITE INDUSTRIES, INC. Plaintiff No. ~(~ ., 'r~ e`~ v ~ ~~~~ vs DONALD L. GROFF and DAVID E. FEAGLE T/A GROFF & SON PORTABLE TOILET SERVICE a/k/a GROFF SEPTIC SERVICE CIVIL ACTION Defendant COMPLAINT NOW COMES, the plaintiff , SATELLITE INDUSTRIES, INC., by and through its attorneys, DANIEL G. DOUGHERTY, P.C. and DANIEL G. DOUGHERTY, ESQUIRE and sues the defendant, DONALD L. GROFF and DAVID E. FEAGLE T/A GROFF & SON PORTABLE TOILET SERVICE a/k/a GROFF SEPTIC SERVICE and in support of his Complaint, avers the following: 1. The plaintiff, SATELLITE INDUSTRIES, INC., a corporation authorized to do business in the Commonwealth of Pennsylvania located at 2530 Xenium Lane N., Plymouth, MN 55441. 2. The defendant, DONALD L. GROFF T/A GROFF & SON PORTABLE TOILET SERVICE a/k/a GROFF SEPTIC SERVICE , a corporation with a place of business at 99 Ickes Lane, Newville, Cumberland County, Pa. 17241. 3. The defendant, DAVID E. FEAGLE T/A GROFF & SON PORTABLE TOILET SERVICE a/k/a GROFF SEPTIC SERVICE, a corporation with a place of business at 99 Ickes Lane, Newville, Cumberland County, Pa. 17241. 4. At the defendant's specific request plaintiff sold and delivered to defendant various articles of merchandise as more fully described in the invoice attached hereto, made a part hereof and marked Exhibit "A". Copies of this invoice were delivered to defendant. 5. The merchandise was sold and delivered on the dates for the prices and the quantities set forth in Exhibit "A". 6. The prices charged in Exhibit "A" are correct, just and reasonable, and the usual and market prices for the merchandise sold to defendant, and further are the prices which the defendant agreed to pay. 7. Defendant submitted a partial payment to plaintiff July 7, 2006 in the amount of $596.25. S Defendant remains indebted to plaintiff in the amount of $4,173.75 plus interest from September 6, 2005. ~. Defendant has received all credits to which defendant is entitled. l~ Although plaintiff has often demanded payment of the sum in question, defendant refuses to pay. 1 f. The amount in controversy does not exceed the jurisdictional amount requiring arbitration WHEREFORE, Plaintiff demands judgment against the Defendant for the sum due and owing of $4,173.75 dollars together with interest thereon at the rate of 1.5% per month from September 6, 2005 and court costs. DATE: ~~~~y/0 b DA L G. DOUGHERTY, P.C. Daniel G. Dougherty, Esquire Attorney For Plaintiffs Attorney I.D. No. 61075 881 Third Street, Suite B-3 Whitehall, PA 18052 (610)264-9840 VERIFICATION I, Daniel G. Dougherty, Esquire, attorney for plaintiff, SATELLITE INDUSTRIES, INC. in the within matter, do hereby verify that I am duly authorized to make this verification on its behalf and that the statements contained in the Complaint are true and correct to the best of my knowledge, information and belief. Affiant makes this verification through his personal knowledge, information and belief; and, that any information as to matters not stated upon affiant's personal knowledge is derived through investigation and conversation with said Plaintiff. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. G. Dougherty, P.C. Date: 1~'~l~t (O6 Daniel G. Dougherty, Esquire Attorney I.D. No. 61075 Attorney for Plaintiff S~TEL~ITE 1NDUSTRIES INC 2530 XENIUM LN N PLYMOUTH, MN 55441 UNITED STATES OF AMERICA Phone : 763-553-1900 Fax: 763-553-1905 Federal ID No.: 41-0854413 c.,raT Cusfomer: 117514 Statelite• INVOICE Invoice: Slf-IN001499 .Date: 06-Sep-2005 GROFF li SON PORT TOILET SVC 99 ICKES LN NEWVILLE, PA 17241 UNITED STATES OF AMERICA _ Remit To SATELLITE INDUSTRIES INC NW 7477, PO BOX 1450 MINNEAPOLIS, MN. 55485-7477 UNITED STATES OF AMERICA "This address is for remittance only. Please send alt correspondence to the main address at left " ca;~ r CUStomer: 117514 GROFF 8 SON PORT TOILET SVC 99 ICKES LN NEWVILLE, PA 17241 UNITED STATES OF AMERICA Attention: 717.776-7402 Customer Number: 117514 Payment Terms : NET 30 DAYS Order Number; SII-S0001760 Ship Via: LTL-CHROBINSON Customer PO# : Freight Tem1s : l Freighf Destination Product Quantity Price Each Net Price Extended Description Price 1038A 5 EA 676.00 676.00 3,380.00 TUFWAY- 0007 AQUAlAQUA REG TANK RECYCLED BASE MOUNT PAPER GUARD IN STANDARD LOCATION 1180A 1 EA 1,390.00 1,390.00 1,390.OU LIBERTY- C018 DGRY/DGRY 35 GAL TANK MOUNT PAPER GUARD IN STANDARD LOCATION Area Manager: PAT WEST Tif/e : AM NORTHEAST Totallnvolce Am ount: 4,770.00 USD En1ai1 Address : patty@satelliteco.com / ' Phone : 800-328-2331 Amount: /~ ~ 4,770. I_ 00 Due: 06-Oct-2005 PAYMENTS NOT RECEIVED WITHIN THE PAYMENT TERMS SHOWN ABOVE WILL BE ASSESSED A LATE FEE OF 1.5% PER MONTH ON THE UNPAID USD BALANCE . CLAIMS ON SHORTAGES OR DAMAGED GOODS MUST BE MADE WITHIN 30 DAYS OF RECEIPT OF GOODS Reissuing or invoices resulting from (Wanting, charge in terms or change in bit!-to entity ,viU incur an administrative lee for each invoke reissued Page 1 of 1 u t' ~ n ~' ~ ~ W ~ ~ c ~'? ~_ ~1i~ ~. ~.~ `_-~ ~~ n :, ~, i _~~. ~~ }-=, ::~ C~" SATELLITE INDUSTRIES, INC. VS DONALD L. GROFF and DAVID E. FEAGLE T/A GROFF & SON PORTABLE TOILET SERVICE a/k/a GROFF SEPTIC SERVICE PRAECIPE TO THE PROTHONOTARY: :CUMBERLAND COUNTY, PA :COURT OF COMMON PLEAS :CIVIL DIVISION :No. 06-7253 Kindly mark the above captioned matter settled, discontinued and ended upon payment of your costs only. ~~iz~~~ Resp lly submitted, By DANIEL G. DOUGHERTY, ESQUIRE Attorney for Plaintiff N e~ wn ~ ~ ~ rn , t .~ .r v ~ ~ -=r i . ~' ` ~.../t _ F`.. ~ ...,.a ~ .«w ~„ _' SHERIFF' S RETURN - REGULAR ""'" ,.rr ,.~.. CASE N0: 2006-07253 P ..r.. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SATELLI'T'E INDUSTRIES INC VS GROFF DONALD L ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GROFF DONALD L T/A GROFF & SON_PORT TOILET SERV AKA GROFF SE the DEFENDANT at 1632:00 HOURS, on the 27th day of December 2006 at 99 ICKES LANE NEWVILLE, PA 17241 by handing to DONALD GROFF, CO-OWNER ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.20 Affidavit .00 Surcharge 10.00 .00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 12/28/2006 DANIEL DOUGHERTY By: D puty Sheriff A.D. ::.. ..n.w ..pil. ..i~.r. ...... .r wic ...: r, ~ SHERIFF'S RETURN - REGULAR CASE NO: 2006-07253 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SATELLITE INDUSTRIES INC VS GROFF DONALD L ET AL JASON VIORLA Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FEAGLE DAVID E TjA GROFF & SON PORT TOILET SERV AKA GROFF SE the DEFENDANT at 1632:00 HOURS, on the 27th day of December 2006 at 99 ICKES LANE NEWVILLE, PA 17241 by handing to DONALD GROFF, FATHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 ~f ~ ~i' jD ~ (1,__ 16.0 0 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 12/28/2006 DANIEL DOUGHERTY By: ~ putt' Sheriff A.D. .. ... -.r.i ..il ..4J .+1 _„ ~.i- ,r~ ~;,