HomeMy WebLinkAbout02-2995USF RED STAR 1NC. (US)
Plaintiff
MICROENTERPRISES, 1NC.
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
: CIVIL DIVISION - LAW
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 1N 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 NO/-'HAVE
A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE S~ FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
USF RED STAR 1NC. (US)
Plaintiff
MICROENTERPRISES, INC.
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. Oa. --
: CIVIL DIVISION - LAW
The Plaintiff, USF RED STAR INC. (US), by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of
Assumpsit against the Defendant to recover the sum of SIX THOUSAND, TWO HUNDRED THIRTY-NINE DOLLARS AND
SEVENTY-FOUR CENTS ($6,239.74), along with interest thereon fi.om October 26, 2001, upon a cause of action of which the following
is a statement:
1. The Plaintiff, USF RED STAR INC. (US), is a corporation organized and existing under the laws of the State of
Delaware, having its principal office and place of business at 1151 South 2P~ Street, Harrisburg, Dauphin County, Pennsylvania 17111.
2. The Defendant, MICROENTERPRISES, INC., is a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, having its principal office and place of business at 1004 Rana Village Avenue, Camp Hill, Cumberland
County, Pennsylvania 17011.
3. On the dates, in the amotmts, and for the prices set forth in a true and correct copy of the Plaintiffs Statement of Account
hereto attached, marked as Exhibit "A" and made a part hereof, Plaintiff provided transportation services of the kind and description 'set
forth on said Exhibit to the total amount of Six Thousand, Two Hundred Thirty-Nine Dollars and Seventy-Four Cents ($6,239.74).
4. The prices charged for said services provided were just and reasonable, were the legal and market prices therefor and
were the prices which the Defendant promised and agreed to pay Plaintiff therefor.
5. The balance due and owing by Defendant to Plaintiff is the sum of Six Thousand, Two Hundred Thirty-Nine Dollars and
Seventy-four Cents ($6,239.74), as appears by the Statement of Account hereto attached, made a part hereof and marked as Exhibit "A".
F:\US ER~BONNIEJO\COMP\WORK~28310.WPD:20 Jun02
6. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant
has refused and neglected and still refuses and neglects to pay said amount of any part thereof.
WHEREFORE, Plaintiff brings this suit to recover fi.om Defendant the sum of SIX THOUSAND, TWO HUNDRED THIRTY-
NINE DOLLARS AND SEVENTY-FOUR CENTS ($6,239.74), together with interest thereon from October 26, 2001.
Respectfully submitted,
Robert D. Kodak
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-715i
Attorney ID No. 18041
Attorney for Plaintiff
F:\USER\BONNIEJO\COMP\WORK\28310.WPD:20Jun02
I, ROBERT D. KODAK, state that I am not a party to the action but that, at the request of the Plaintiff, USF RED STAR 1NC.
(US), and based upon knowledge, information, records and documents supplied to me by the Plaintiff, the averments set forth in Plaintiffs
Complaint are true. A Verification executed by the Plaintiff can be supplied at time of trial or upon request.
I tmderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification
to authorities.
Dated:
Robert D. Kodak
F:\USER\BONNIEJO\COMP\WORK\28310.WPD:2OJun02
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-02995 p
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
USF RED STAR INC (US)
VS
MICROENTERPRISES INC
CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
MICROENTERPRISES INCthe
DEFENDANT , at 1355:00 HOURS, on the 25th day of June
at 1004 RANA VILLAGE AVENUE
, 2002
CAMP HILL, PA 17011
TODD SHEDLOSKY, PRES
by handing to
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 9.66
Affidavit .00
Surcharge 10.00
.00
37.66
Sworn and Subscribed to before
me this ~ day of
~, ~ ~L6~ 2_~ A D
/P~otho~otary - ~- ~
So Answers:
R. Thomas Kline
06/26/2002
KNUPp KODAK IMBLUM
USF RED STAR, INC.
Plaintiff
In the Court of COMMON PLEAS of
CUMBERLAND County, Pennsylvania
NO. 02-2995
MICROENTERPRISES, INC.
Defendant(s)
CIVIL DIVISION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned Judgment as Settled and Discontinued With
Prejudice.
TO CUMBERLAND County
Prothonotary
Dated: April 22, 2003
Robert D. Kodak Attorney for Plaintiff
Attorney I.D. No. 18041