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Home My WebLink About94-02145 ~ ~ ~' \f) cj l- I d -, {j ~ J ~ Q ~ ~ 1 ~ J ~ . !.-! ~ ,. '" "J'" \\ ~ if:: 11'1 "., N ~>- .., '- ..,['1':';.' CJ_. ~~ ..... '- ..,. !--. ~(":~( ~\;~ :.i'..~ "'.... '''I .) .,. '" - ..... - ~J ~ O!. [ 1- ~ '-'"') ." Q; "- ~ .. ;".r 'diJ . ;.. .~ .J '.' t: .. ., ~ -. lOU ARt Hr.,", .fQU'ltlD fa till.. W.UIIH IU~"O...'" .J Uff 1"(lO,\ln """IU"I '''I Nil" 1101 t\,.." ,lit"... !o111tVler 1I11l( Of llA ... JUOlo'4I", MAY III I "Ill hn AG.......'" ,au DOUGLAS DCUGl.AS (. DOUGLAC; "'JrZ ,'; '.1 ~',"" ".... ,., ... ~ '." . ' Wl 00 H'.'U-t:tR'lf: filAr 'H' WITHIN IS A 'Nut. lNocalUU C f CO.., 0' 1'H[ OItIGIHAl t1llD IN Htl~ Al;T1CN. '" .lto."" '... ~ I ' . ~ I j I .. ~ , '..\', n. AITOFUj(, ""1 , ) - ... .. GEORGE F, DOUGLAS,IR. ATTY, I,D. #06270 DOUGLAS, DOUGLAS & DOUGLAS 27 WEST HIGH STREET P.O, BOX 261 CARUSLE,PA.17013 717-243-1790 DO-MA CORP" trading as THE EMBERS INN AND CONVENTION CENTER V. SEW-ART INTERNATIONAL: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 71'J/~~ ~ ,-~ NO. GVH., 1!}94 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 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. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, Pa. 17013 717-240-6200 DOUGLAS, DOUGLAS & DOUGLAS By /~ ~~d Attorney for Plaintiff I ~ , ... - ..; COMPLAINT 1. The plaintiff, Do-Ma Corp., t/a The Embers Inn and Convention Center, is a Pennsylvania corporation, having a place of business at 1700 Harrisburg Pike, Middlesex Township, Cumberland County, Pennsylvania. 2. The defendant, Sew-Art International, is a corporation, having a place of business at 145 South Main Street, Box 550, Bountiful, Utah 84010. 3. On July 31 to August 3, 1990, the defendant rented 12 motel rooms from the plaintiff, and had a meeting room for July 31 through August 3, 1990, with as many as 95 meals being served twice a day, 4, The defendant has paid on the outstanding balance of this account, which was once as much as $29,580,13, but is now down to a $3,580.13 balance. Despite promises on the part of the defendant, this $3,580.13 balance has not been paid. WHEREFORE, plaintiff claims of the defendant the sum of $3,580.13, an amount requiring compulsory referral to arbitration under the local rules of Court. DOUGLAS, DOUGLAS & DOUGLAS By ~~Q Attorney for Plaintiff ' ... . ) ~ .. COMMONWEALTH OF PENNSYLVANIA ) 55. COUNTY OF CUMBERLAND ) AFFIDAVIT Mark A. Hayward, being duly sworn according to law, deposes and says that he is the President of Do-Ma Corp., and that the averments of the within complaint are true and correct, to the best of signer's knowledge, information, and belief, Sworn to and subscribed before me this ~~4 day of April, 1994. C?ma Yh. JfCUt' Notary NotARIAL SEAl JANET M. LAY NOTARY PUBtlC CARLISLE BORO" CUMBERLANO COUNTY MY COMMISSION EXPIRES JUNE 26. t995 , I DOUGLAS, DOUGLAS & DOUGLAS :17 W. HIGII ST. POB :161 CARLISLE PA 17013 TELEPHONE 717.:143.1790 WILLIAM P. DOUGLAS, ESQ. Supn:ma Coun 1.0.' 37926 It GEOROE P. DOUGLAS, ill, ESQ. Suprema Coun 1.0.' 61886 DO-MA CORP., trading as THE EMBERS INN AND CONVENTION CENTER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERlAND COUNTY PENNSYLVANIA 1994 - 2145 CIVIL TERM \S SEW-ART INTERNATIONAL, CIVIL ACTION LAW DEFENDANT To: Lawrence E, Welker, Prothonotary ~~ECIPE Please enter a judgment in the amount of $2,000.00, in favor of the plaintiff and against the defendant. Attached are a copy of the Notice of the intention to enter the default judgment and an affidavit of mailing this Notice more than ten days before this praecipe is filed. DOUGLAS. DOUGLAS & DOUGLAS Date: September 11, 1995 , GEORGE F, DOUGLAS, III ATTY, I,D, # 61886 DOUGLAS, DOUGLAS & DOUGLAS 27 WEST HIGH STREET P,O. BOX 261 CARLISLE, PA. 17013 717-243-1790 DO-MA CORP., trading as THE EMBERS INN AND CONVENTION CENTER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. CIVIL ACTION - LAW SEW-ART INTERNATIONAL: NO. 1994-2145 CIVIL TERM TO: Charles Merrill Sew-Art International 145 South Main Street Box 550 Bountiful, Utah 84010 Date of Notice: August 25, 1995 IMPORTANT NOTICE 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE 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 HELP, COURT ADMINISTRATOR FORTH FLOOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6200 r r-" (/ f)_ ..- JU~)... ,~~~,'~{J~.-l"" George . Douglas, III,' squire r,~"'.~--_h'''' ,,"...;0..""'" . DO-MA CORP., trading as THE EMBERS INN AND CONVENTION CENTER V. SEW-ART INTERNATIONAL: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO, 1994-2145 CML TERM AFFIDAVIT OF MAILING I, George F, Douglas, ill, being duly sworn according to law, depose and say that on August 25, 1995, a notice of default was sent by regular mail to the defendant, Charles Merrill of Sew-Art International, setting forth that on or after ten days a judgment would be entered against them, (U ...._1 Sworn to and subscribed before me this 11th day of September, 1995. y /)(01- Yn. .:Yfo' J-.. Notary V ' NOTAR1AL SEAL JANET M. LAY NOTARY PIIIt.IC eARlISlE BORO., CUMBERlAND COUIIY MY COMMISSION EXPIRES JUNE 1999 "ii":~~1'I1:?21011 OblHfllfl.i, ~l" liJJj 'rllll;;r[ ao~o-' CIll'iBEI!l"fIlO COOlQA lliilU "'- m ilOI_lIJ. WlIll" IlCIYKM 2m \ ., \1' .,;. .... '" i ~ ~ ~ ~ - "," ""I~ :r.: ~.~;.:_,t~': I:l' c.... 1 OZ:"-'~T.' "" .... ,:'0<'" : .... ;~ ~~, ~~2 ~ -:r . .::: " .t ..11:: ',-.04 . .1' ..~ ~ ..... 4.;, .... <.-;... .,., ~ \..~Jit ~