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HomeMy WebLinkAbout94-00235 c c H -8 . - - o -:r. '" 7' ~ '- ~ UI . , ~ y NOTICE OF APPEAL COMMONWIALTH O' P1NNSYLVANIA COUll O' COMMON PLlAS County of Cumberland JUDICIAL DISTRICT fROM DtSTRICT JUSTtCE JUDGMENT 9tll COMMON PLEAS No. ;l 3 5 ~ I '1'1 Lf NOTICE OF APPEAL No~ce i. given that the appellant has filed in the above CaUlt of Common Plea. an appeal from the judgment rendered by lhe Di.trict Ju.tice on the dale and in the case mentioned beIa.< ...... ....., .... . 09-3-04 District Justice I. Holiday Inn-Harrisburg West ....<lANI v 312 E. Meadow It N Mechanicsbur jf\trll"J PA 17055 Candiello Susan Ka Inn-Harrisbur West . y N ~ J. Puleo, Attorney for Appellant If appel/ant was CLAIMANT (see Pa. R.C.P.J.P. No. 1001 (6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. luOl CV 19. 0000433-93 lT 19 Thi. black will be signed ONLY when this natation i. required under Po. R.cP JP. No. 10088. Thi. Notice 01 Appeal. when received by lhe Di.trict Ju.tice. will operate a. a SUPERSEDEAS 10 the judgment lor pa....sian in this ca.e. Richard &gnat"'" 01 ProthonO/aly ex Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section 01 form to be used ONLY when appellant was DEFENDANT (see Pa. HC.P.J.P. No. IF NOT USED. detach from copy 0/ notice 0/ appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upan Candiello, /00 II 7) In action be/ore District Justice. Susan Kay . appellee(.). to lile a complaint in this appeal ..... 01 """"100(5' .;?3 S &"'.;..( / 11'+ ) within twenty (20) day. after 7~Of judgment of non proL Sog1aturo 01 _.." ex /Us attorney ex agent Richard J. Puleo Attorney for Appellant Attorney I.D. #33951 ( 1) You are natifoedthilt a rule i. hereby entered upan you to lile a complaint in this appeal within twenty (20) day. alter the date of ""vice of this rule upon yoU Ii). personal .ervice or by cer~1ied or regi.tered mail (Cammon Plea. No. RULE: To (I7NDIE.i...Lo ,St/sfW XflL.appellee(.). . Namo 01"""""'51 (2)11 you do not lile a complaint within this time. a JUDGMENT OF NON PROS Will 8E ENTERED AGAINST YOU. (3) The dale 01 service of this rule if .ervice was by mail i. the date 01 mailing. Date:~. :11 . 19!1.1. Jh...: L... a . ~ ~ . J!jAi::' o ~0I~~ NJPC312-84 COURT FILE TO BE FILED WITH PROTHONOTARY .1) 8 ~ --{. . ~ G ..,.. >-,. ;;: c:n - ,~ l- ..,. a ..J ~-, :~.:I ~t U.I'.1: N ~l',)o...; N .~ ~~, ~~ ~.~ cO '0 ") ;,r. j- .- - ;'.;' ~ c--.1 ... ..- ;0 "" " , -. -' -, I. .." 0 ~ ~ C tr- J ~ ,. .. ~ .:;, c.. 0- n T . ,- r! ..." -0 r.l III < ':l I' j ,j J .. 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I i . i; i ./i I";; I i . ;; I II I II " , I I ~-- '5:5ign.ture (Addre....1 II 8. Sign. re ~ I I . .. PS Form l. ,. t. o U.8.Q.P.O.: tOll2407-630 DOMESTIC RETURN RECEIPT ".. Susan Kay Candiello. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW V Paul Lee, G,F.Management, Defendants NO',<35'CIVIL ['tQf 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 pe~sonally 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 judgement may by 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE, PA 17013 (717) - 240-6200 . NOTICE TO PLEAD TO: Jl,uQ ~o . ~. ~ <l'\~~~/'M.R.-vJ-- YOU ARE HEREEt NOT!"'!E~ TO FILE ENCLOSED ~ ~~ WITHIN TWENTY (20) DA.S FROM ERVICE ENTERED AGAINST YOU, A WRITTEN RESPONSE TO THE HEREOF OR A JUDGEMENT MAY BE ~~~ ~(~~ ~ 4. The evening of August 7, 1993, Plaintiff and a experienced a poorly prepared almost inedible dinner "Terrace", the formal restaurant at the Holiday Inn West. friend at the Susan Kay Candiello, Plaintiff IN THE COURT OF COHMON PLEA~ OF CUMBERLAND COUNTY, CO}lliONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW V Paul Lee, G.F, Management, Defendants NO. J,35' CIVIL l'i'i~ COMPLAINT l. at 312 17055. Plaintiff is Susan Kay Candiello, an individual residing East Meadow Drive, Mechanicsburg, Cumberland County, PA 2. Defendantz are; Paul Lee, General Manager of Holiday Inn West, a restaurant and hotel business, owned and operated by GF Management, Holiday Inn West is located at 5401 Carlisle Pike, Mechanicsburg, Curr~erland County, PA 17055. OF Management is a corporation, with it's corporate headquarters at 900 Packer Avenue, philadelphia, PA 19148. 3. Plaintiff does state zhe has had for the greater part of her life an interest and demonstrated a talent for creative cooking. She has entered and won several cooking contests, she has in a voluntary nature provided numerous groups with food items. She has a local group of individuals, who are familiar with and enjoy her culinary skillz. Many of these individuals demonztrated an interest in coming to Defendant's restaurant, when and if it were to be featuring Plaintiff's food. 5. On August 9, 1993, Plaintiff did share her complaints, insights, and some ideas with Defendant on the telephone. 6. On August 10, and 11, 1993, Plaintiff did share some samples of her foods with Defendant at the Holiday Inn West. 7. In several telephone calls Defendant did convey to Plaintiff, Defendant liked her food zamples, and was interested in discussing her ideas with her. O. ~n Aug~~t 14, 1993, at Defendant's request Plaintiff did come to the Holiday Inn W~st for a meeting with Defendant. 9. The following occurred at the meeting: ideas and from. A) Defendant stated he believed Plaintiff recipes which Defendant's restaurant could had some benefit B) Plaintiff told Defendant she had no experience in this field whatsoever. Plaintiff clearly stated she was interested in the extra in~ome, and an outlet for her creative abilities and ideas. Plaintiff stated she was not interested in a full time position, the part-time options suggested by Defendant were agreeable to Plaintiff. C) Defendant Plaintiff: identified the ways he could use a) "Creative Food into Defendant's kitchen, working ~ow to prepare them. Consultant" - bringing recipes with Defendant's staff to learn b) "Test Kitchen" - to supplement kitchen with the creative time, for developing new time which Defendant did not have, due to the demands food service. Defendant's food ideas, of everyday c) "New Food and Ideas"- would introduce Plaintiff's new food ideas buffets at Defendant's evening programs. Defendant stated he via the free food d) "Successful New Food and Ideas" - successful food items from the buffets would be featured on the restaurant menus, apart from the normal fare, identified on the menu as Plaintiff's, D) Defendant stated he was not certain how reimbursement would occur, he suggested two possible methods. First, a standard consultant fee, which would be $20.00 to $30.00 per hour. The other option would be a royalty arrangement where payment would be for amounts of Plaintiff's food sold. E) Defendant stated Plaintiff should obtain a contract to protect herself and to identify how the working arrangement could be set up. Defendant stated his establishment would want exclusive use of Plaintiff's ideas and recipes, Jefendant stated nothing further could be done until these items were specifically stated and agreed to in a contract. 10. Within th~e~ (3) weeks and presented Defendant with a "A"). Plaintiff met with her attorney proposed contract. (See Exhibit 11. Within two (~) weeks Plainti~f and Defendant met in Defendant's office, Defendant stated the contract was fine. There were a few minor details he would need to clarify with Plaintiff. Defendant stated he could not attend to this matter now, he needed this time to supervise the renovations being completed at Defendant's establishment. Defendant gave Plaintiff a copy of the proposed new menu. Defendant stated there was nothing on it that made his "socks go up and down!" He stated to Plaintiff "She should see what she could do with it". Defendant further stated he was looking for items specifically incorporating a nautical theme, to correlate with the renovations. 1~. The following week Flaintif~ stopped at Defendant's establishment, Defendant told her she would need to talk with his Chef to be certain there would be no problems or difficulties in a working relationship with the Chef. Plaintiff telephoned and then met briefly with the Chef. The Chef said things were hectic with the renovations, stated they were hiring some new staff, and would be soon be having meetings to look at the new menu. Plaintiff requested she be advised of any meetings looking at menu ideas, the Chef agreed. The Chef introduced Plaintiff to a food supplier, in the Chef's office, suggesting Plaintiff would be working with the restaurant in a consultant capacity. No problems or difficulties were identified during this meeting with the Chef. 13. Plaintiff during this time did spend many hours in her kitchen; researching cookbooks and recipes, and preparing various food items, which she felt could possibly be utilized by Defendant. At a minimum, ten (10) hours of work were invested by Plaintiff in preforming those activities needed to obtain ideas and recipes to offer Defendant. 14. The following week the Defendant telephoned the Plaintiff making the following statements: A) The Defendant admitted he was food at his establishment. He stated that he staff was ready for the level at which functioning. Defendant stated "My staff has before they can walk or run". not happy with the did not believe his Plaintiff would be to learn to crawl, B) The Defendant stated he believed in several of Plaintiff's food products, and felt Plaintiff should, too. Defendant offered to give rlaintiff names of several vendors whom he felt might be interested in Plaintiff's food products. C) Plaintiff stated although she had invested a lot of time and effort into this project, the only cash which had been expended was the cost to obtain the contract from the attorney. Defendant stated he had absolutely no intention of paying any monies for the ~~ntract, which had cost $675.00. (See Exhibit "Bn) . 15. Plaintiff has ~ad~ ~everal attempts amicably, even offering to split th~ cost of Defendant. Plaintiff has tried to communicate the establishment which Defendant operates. however, no respon~e was ever given. to zettle this the contract with with the owner of O.F. Management, 16. Defendant in response to Plaintiff's attempts to reach an amicable settlement did send an embarrassing letter (See exhibit "C") to "Bar Associations" illuding to Plaintiff's "intimidation techniques", inappropriate use of legal education, and "highly objectionable methods of doing business". WHEREFORE Plaihtiff find the following legal ~acts: does request this honorable court to entities applicable to the above stated COUNT ! Plaintiff does contend Plaintiff and Defendant. to Defendant's restaurant. that a contract was made between use Plaintiff, and her food ideas at Plaintiff does contend that an offer was made by Defendant. Defendant did hold himself out as being able to initiate and conclude a contract of employment with Plaintiff. Defendant did communicate with specificity the terms under which the contract would operate. Defendant did state that to finalise this agreement, a "formal" contract would be required. Thus suggesting an "informal" agreement had been reached. Plaintiff does contend that Defendant accepted the offer. Defendant did verbally state the contract was acceptable, with a few minor items to later be discussed. However, due to the time element in coping with the renovations at his establishment, Defendant could not finalize it, at that time. Defendant did continue to act in a manner which demonstrated knowledge and intent in preforming actions which would give Plaintiff reason to infer that a contract had been formed between Plaintiff and Defendant. Defendant did continue to act in a manner suggesting to Plaintiff that her food ideas would be utilised at Defendant's restaurant. Plaintiff did rely upon ~efendants statements and actions to her detriment. Plaintiff did incur e~penses, and utilise her time ~nd effort i~ perfor~i~g those tasks ~~ich would enable Plaintiff to preform her role as a "Creative Food Consultant" for the Defendant, c~urfT :! Plaintiff does ask, in the alternative, if this court does not find a formal contract was formed between rlaintiff and Defendant, that the court find that a Quasi contract did er.ist between Plaintiff and Defendant. Defendant did through his actions and words, imply to Plaintiff that an agreement to utilize her food ideas at Defendant's restaurant did exist. Defendant did act, and communicate with Plaintiff in a manner suggesting her services would be utilized at Defendant's establishment. Plaintiff did incur expenses, and utilize her time and effort in preforming those tasks which would enable Plaintiff to preform her role as a "Creative Food Consultant" for the Defendant. Plaintiff did rely on the actions and verbal statements of Defendant to her detriment. Plaintiff does not request a just and equitable resolution to her reliance. COUNT III Plaintiff does state she spent many hours reading cooking materials, receipt books. She did make numerous food items, testing them out in various formats, and with differing ingredients, attempting to achieve the quality and type of food product which would be appropriate in the Defendant's restaurant and with the Defendant's nautical theme. Plaintiff does state the minimum amount of time zhe er.pended in these activities was ten (10) hours. Applying the rate of $30.00 per hour consultant fee, as quoted by Defendant, the fee for services to which Plaintiff would be entitled to is $300.00. WHEREFORE, Plaintiff demands judgement against the sum of $675.00 contract cost, $44.50 District and $300.00 Consultant services fee. Defendant for Court costs, Respectfully Submitted, B Susan Kay Caru iello, Esquire Attorney I.D.No. 64998 312 Eazt Meadow Drive Mechanicsburg, PA 17055 (717) C'1.5916 EXHIBIT "A" C'~?AFT INDEPENDENT CONSULTING ~ LICENSING AGREEMENT THIS AGREEMENT is entered into this day of , 1993, by and between: WONDERFUL WANDA'S, a with offices located at hereinafter the "corporation" and SUSAN K. CANDIELLO, an adult individual residing at 312 East Meadow street, Mechanicsburg, Pennsylvania, 17055, hereinafter "Candiello". The corporation was established to provide restaurant and beverage services as well as other sundry entertainments to the establishment known as "Wonderful Wanda's" located at , hereinafter the , "premises". The corporation has retained the services of Candiello as an independent consultant to act in the capacity of creative consultant for food, beverage and marketing for the Premises. In consideration of the mutual promises contained in this document the parties, intending to be legally bound, agree as follows: 1. Nature of Consultant position. Candiello agrees to act as creative consultant for food, beverage and marketing for the Premises. In that capacity, Candiello agrees to provide the corp~ration with recipes as well as other food preparation and 1 I I I I I I. 11 ! presentation techniques. In addition, candiello shall develop certain marketing techniques to promote the sale of food and beverages at the Premises. In carrying out her duties pursuant to this Agreement, Candiello shall work a maximum of hours per month over the term of this Agreement. Candiello is an independent contractor and not an employee of the Corporation and shall determine her own method of operation in accomplishing her duties pursuant to this Agreement. 2. Comcensation. corporation will compensate candiello for the marketing techniques she develops to promote the sale of food and beverages at the Premises by providing a flat monthly fee of $ per month throughout the initial term of this Agreement. In addition to the flat monthly fee, Corporation will compensate Candiello by paying her a license fee pursuant to the terms hereinafter outlined in Paragraph 4 of this Agreement. 3. Trade Secrets. Candiello has expended time and effort experimenting upon different methods ~o develop her recipes which she has from time to time secretly originated, made and perfected for her own exclusive use. The recipes and food presentation techniques developed by Candiello (collectively the "Candiello Recipes") are trade secrets and proprietary in nature and they have not been disclosed to anyone who is not obligated to retain them in confidence. The Corporation in connection with this Agree~ent will have access to the Candiello Recipes that 2 constitute confidential trade secret proprietary information vital to Candiello and her business. Pursuant to the terms of this Agreement, the corporation will hold this proprietary information as a licensee and, shall not disclose or make available to anyone for use outside of the corporation at any time either during the term of this Agreement or subsequent thereto any such proprietary information. The corporation shall keep all information received under this Agreement secret and confidential and shall not disclose the information in any manner except to such employees as are required to use such information. The Corporation shall insure that its employees maintain the secrecy of the information received under this Agreement. The corporation shall be liable for any claims, demands, losses, injury or damages caused to or suffered in any manner whatsoever by Candiello resulting from the disclosure of the information received under this Agreement by any of its employees, officers, agents or representatives. Said information may never be disclosed by the corporation without Candiello's prior written consent. 4. License. Candiello hereby grants to the corporation a sole and exclusive license to prepare and sell the Candiello Recipes created exclusively owned, and controlled by Candiello. The license granted hereby shall apply only to the Premises. The corP9ration agrees to pay Candiello for each contract year of the 3 term of this Agreement the fee set opposite the bracket representing the corporation's monthly gross receipts from the sale of Candiello Recipes for the previous month. As used herein "gross receipts from Candiello Recipe sales" means the aggregate of all gross amounts paid by the patrons of the Premises for the sale of Candiello Recipes. The parties hereby agree that the license fee for the first contract year hereof shall be pursuant to the schedule of license fees hereinafter set forth in this paragraph. Schedule 2f License ~ Gross receipts from sale of Candiello Recipes for previous calendar month: Bracket Range Fee 1. Up to $ $ 2. $ 3. $ ( etc. ) The corporation agrees to pay Candiello at the time of execution of this Agreement the sum of $ on account of the first monthly fee and the balance thereof, if any, not later than thirty (30) days after the commencement of the sale of Candiello Recipes at the Premises. 4 (A) The corporation hereby agrees to prepare and maintain during the term of this Agreement a record of the number of and gross receipts received for all Candiello Recipes sold on the Premises each month. The Corporation agrees to furnish Candiello with a copy of such information with its monthly report. (B) On or before the fifth day of each month during the term of this Agreement the Corporation shall furnish to Candiello a report certified by an officer of the corporation setting forth the bracket which corresponds to its actual gross receipts from sales of Candiello Recipes for the previous month as well as payment of the corresponding license fee pursuant to the terms of this Agreement. In the event that the corporation fails to furnish a report as required herein, the Corporation agrees that the fee for that month shall be the maximum fee provided for in this agreement. (C) Candiello, or her agent or representative, shall have the right at any time during customary business hours to examine the books and records of account of the Corporation to such extent as may be necessary to verify the report of the corporation concerning fees due hereunder. Candiello shall 5 consider all data and information coming to her attention as a result of such examinations as completely and entirely confidential. (0) Upon any breach or default of any term or condition herein contained, Candiello may, at her sole option and in addition to any and all other remedies which she may have at law or in equity, cancel this license immediately. No waiver by Candiello for performance of this license by the Corporation in any one or more instances shall be deemed a waiver of the right to require full and complete performance of this license thereafter or of the right to cancel this license in accordance with the terms of this paragraph. 5. Breach gf Conditions. The Corporation hereby acknowledges that the services to be rendered by Candiello are of a special, unique and extraordinary character. The corporation agrees that if it violates any provision of this Agreement with respect to confidentiality, Candiello would sustain irreparable harm and therefore in addition to other remedies which Candiello may have under this Agreement, candiello shall be entitled to apply to any court of competent jurisdiction for equitable relief including specific performance and injunctions restraining the Corporation for committing or continuing any such violation of this Agreement. 6 ,---.....-.~ 6. continuinq Enforcement ~ Validitv. The covenants in paragraphs 3, 4, and 5 hereof shall survive the termination of this Agreement and shall remain in full force and effect. If for any reason any provision of this Agreement shall be determined to be invalid or unenforceable, the validity and effect of the other provisions shall not be affected. 7. Term. Candiello has agreed to undertake the duties described herein for a period of one year and to allow for a licensing of the Candiello Recipes for that same period. The term shall commence on 1993 and will continue in effect until 1994. Unless otherwise terminated in accordance herewith, this Agreement may be renewed for an additional term of one year and thereafter on a year to year basis. Either party may terminate this Agreement at any time by providing the other party with thirty (30) days written notice that the Agreement has been terminated. Candiello may immediately without notice terminate this Agreement at any time if the Corporation violates any term or condition of this Agreement. 8. Assiqnment. This Agreement shall inure to the benefit and be binding upon the corporation, its successor and assigns. This Agreement shall not be assignable by Candiello and the obligations of Candiello may not be delegated. 7 9. Entire Aqreement. This Agreement represents the entire understanding of the parties. There are no other outstanding agreements, provisions or schedules on the subject matters. This Agreement may not be amended except in writing signed by both parties. 10. ADDlicable ~ The parties agree that this Agreement shall be construed and enforced pursuant to the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOP, the parties hereto have set their hands and seals as of the date and year first above written. WONDERFUL WANDA'S ATTEST: secretary BY: President WITNESS SUSAN K. CANDIELLO 8 EXHIBIT "B" ANDES, VAUGHN & DANGS 525 North Twelfth Street Lemoyne, PA 17043 Statement as of 8/27/93 Our Case' 2046 Description : Contract 8usan Candiello .......aa...................................................................... Fees 8/16/93 JBD Telephone discussion with client re: agreement 8/20/93 JBD Research on agreement with Wonderful Wanda's 8/23/93 JBD Draft of agreement 8/25/93 JBD Review and revision of agreement 8126/93 JBD Conference with client; revision of consulting and licensing agmt. 8/27/93 JBD Review of revised draft ---------- Total Fees $675.00 .............=.............=................................................... Totals Prior Balance Less payments received Current Fees Current Costs $0.00 0.00 675.00 0.00 Amount Due $675.00 IIIUI.....aa Page 1 of 1 EXHIBIT "e" '... ""~ ~Y\.V\: HOME OF WANDA'S RESTAURANT October 27. 1993 Ms. Susan Kay Candiello 312 East Meadow Drive Mechanicsburg, PA 17055 Dear Ms. Candiello, I am sorry to hear that you are aSking me to pay you for services you did not perform. Let's take another look at the truth. IH~ ~lTCH: You made a pitch to me regarding your culinary skills, sent me food and samples to taste, and I found it Interesting, So I made an appointment to see you. THE $ALE~ You told me how great you're much you would benefit Wanda's. I told interested to know more, so I asked you thoughts in writing. ~Q fOR IH~ LHR9AI; Instead of getting an outline of what you plan on performing services, you brought me a contract to hold me legally bound, still not telling me what service you plan to perform. BEJECTIQ.~;. Once you found out that I didn't appreciate your methods of doing business, by aSking me to pay you for services that you have yet performed, you use your legal background to intimidate me. going to be, you I was to put your how Ms. Candiel10, you are the legal expert. Is it fair and legal for you to use your legal background to try to intimidate me, to force me to pay for services not performed? I receive vendor's nroposals for jobs most every day of the week. When I turn down their service proposal, I don't get stuck with a legal document bill. Where did you get off by saying we have a legal oral binding agreement to perform services? I belleve what constitutes an agreement is an offer and an acceptance, Yes, you have made and offer, but did I make an acceptance? DId we address any of the terms of agrHement; Who, When, Where, How, Money for services? HOLIDAY INN" -HARRISBURG WEST 5401 Calli' I. p,ku. MuchanlClbufg. fA 17055.717/697.0321 0WNd & ea-.ed ~ OF ~ UndeI L..... . " ,- -\\~9 HOME OF WANDA'S RESTAURANT I think it is selective hearing on your part. I was trying to be a gracious host; but frankly, I find your methods of doing business highly objectionable. I trust you will reconsider your action on this matter and accept rejection gracefully. cc: Bar Associations HOUDAY INN".HARRISBURQ WEST 5401 Carlisle PUn.. M9chlnlcsburG. PA 17055.717/097.0321 Owned & Cl-..... br or ~ UftdeIlDMe ",.--.-.:......... ",,*J.< . Susan Kay Candiello, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW v Paul Lf:!e, G,F.Management, Defendants NO.J.3S"CIVIL Iqqy. VERIFICA7ION I~JSlh\ ~~ C~(MQJ do on this day of J-~b. I () Ji', , , 1994, verify upon personal knowledge, info"~ation, and belief that the statements contained in this document are true and correct. <---Q,,,,,~ ry ( -.-l.~ Susa ay Candiello ::s::: ood: ..... 'J ., a; >;)- "'-- ~ 1:: ..' .. ~ c:> ." .... ..... '"' SUSAN KAY CANDIELLO VS. HOLIDAY INN - HARRISBURG WEST . CIVIL ACTION 235 1994 . :" I'.;.; :-:N . f" .. -. compaet. ill"" 1 and/ot 2 for McItkNW lIMe... ....cc...".... ""'" 3. IIld 4.. b. . :' 1'.- Print your name and addtt" on the NY"'" of tN,. form 10 thlt WI can mum thII cerci to you. ':', '. Anach thII form to the front of the mlUpltca, or on lhe INc:k If .pace . dol, not PMnlt. l '. .... WrfI, "Return RICeIpt ""Itld" on the ma8pIece below the Ittidt number .-1:i . ThlRtturnRIC.lptwlN'howtowhomtht.nJcJ.W"~ndthedlt. & d....'..,. I 3. Artlcl. Add....ed 10: t,U~N0 \::'.h'/ (:N-)bl tUJ) i 31 d-. 'S.. \'I1~~tJO \)~ D y,- . ffll:c.l:l KI~ tC.Sbi)P.J: h, \loS I 1110 willi to ,"col\/l tho following ..rvfcl. (for on Illlrl fel: . 1. 0 Add........ Add.... 2. 0 R"It/Cled D.Uv.ry Con.ult oltma.ter for f... 41. \~Ol\ ~m 'e \.t- 0 lD I 4b. S.rvlc. Typ. o R.gl.ter.d i;l C.nlfled o EJcp.... M.II 7. 0.1. of O.Uv.ry ~~ 6. Slgn.lu.. lAdd.... .) . -- 8. Add........ Add, .nd f.. I. p.ldl . ::,[": Slgn.tu.. lAg.ntl .'ps Form , O.c.mlle, 1991 "u.ao.P.o.:,_-307.530 DOMESTIC RETURN RECEIPT ~ ' - ... E DER: ; ,.~:. Complet, h."" 1 and/or 2 for .ddldoNl .,me... ,"I". Complet, It,,,,, 3. .nd 4, . b. :':I..';~~ c::r: ;:'lddr... on the FeW," of thl. form 10 thl' w. can ',' ':. AnKh tNi form to the front o' the mallplKI, Or on thl blck If .peCI . . dot. not permft. : I .. WrhI"A.turnAecelP1 Rtqutlt.cf' on the mlil,.ca below the .rtJcl. nwnber '. 1:1 . ThI Return Receipt wla .how to whom the.rddI WII d.Uvered and the d,l. & d.livorld. I 3. Artlcl. Add.....d 10: ~\SW_\C\. --'Ug/ct Hl\tVOf:~I~l(' i GLtl\)\~ ~. \-:i\\:.~~:\L~ Olnlur.o 500 J.. UN l::Hc. STtH. I j(J C.rtlll.d 0 coo ~K\-\ht0l(9)W(. I fJ 1\ \.,OS5 0 exp.... M.II 0 R.lurn R.f.lpl fo, 7. 0.1. 01 ~Uv.ry .. 8. Addrllsse's Address ( .nd f.. I. p.ld) I .110 wl.h to ..c.lv. Ih. following services (for an extra feel: 1. 0 Add........ Add,... 6. Slgn.lu,. lAdd'....., i I J j' !I .. J! l nly If '.qu..ted ... l I 8. Sign. .!I PS Form DOMESTIC RETURN RECEIPT tt U.8.o.P.O.: 1",-301-530 . f J J 1 ~ .. fEll 10 S 43 AH 'Sq Cu" :..,'. .. ' !III "(\'1 ,,' r,~;Ay - -',lid I' 'Ut. ry 't;'i"r.',\il.\ CJ , -' - (215) 468-6270 Fax RICHARD J. PULEO JIttorncy JIt Lalli 900 Packer A venue Philadelphia. Penns)'II'anla 19148 (215) 468.7240 February 4, 1994 Prothonotary Cumberland County Courthouse S. Hanover Street Carlisle, PA 17013 SENT VIA CERTIFIED MAIL AND REGULAR MAIL RE: NOTICE OF APPEAL - PROOF OF SERVICE COMMON PLEAS NO. 235 CIVIL 1994 Dear Sir/Madam: Enclosed please find for filing the original return receipts signed by the Honorable District Justice and Susan Kay Candiello (Appellee) in the above referenced civil action. Kindly file these cards in this mailer and return a time-stamped copy of the same to me in the return self-addressed stamped envelope. Should you have any questions, please feel free to contact me. Sincerely, ~)~ pjchnrd J. Puleo RP/0207 Enclosures: As Stated SUSAN KAY CANDIELLO, ESQ. 312 East Meadow Drive Mechanicsburg, PA 17055 (717) 691-5916 ATIORNEY FOR PLAINTIFP ATIORNEY 10 #64998 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA Susan Kay Candiello, Plaintiff NO. 235 CIVIL 1994 v. Paul Lee GF Management Defendants PRAECIPE TO SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the above-captioned mailer Sellled, Discontinued and Ended upon payment of your costs onlv. " -- Susan Kay C die 10, esquire Allomey for PJain iff, Pro Se -..