HomeMy WebLinkAbout94-02618
GEORGE F, DOUGLAS, JR.
Am, 1.0. #06270
DOUGLAS, DOUGLAS & DOUGLAS
27 WEST HIGH STREET
P,O. BOX 261
CARUSLE,PA.17013
717-243-1790
A'ITORNEY FOR PLAINTIFF
DO-MA CORP" trading as
THE EMBERS INN AND
CONVENTION CENTER
V,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
CIVIL ACTION - LAW
NO, q ~ - J Ie (8 C i oj, I Tu IY'
CATHY JOHNSON
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 L-7&-~rt
Attorney for Plaintiff
. .
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, Cathy Johnson, is an individual residing at 7 Otto
Avenue, Carlisle, Cumberland County, Pennsylvania,
3, Shortly before October 10, 1992, the defendant contracted with the
plaintiff for the Holsinger fUns wedding reception, which was held at the
Embers place of business on October 10, 1992,
4, While the defendant has made payments toward the cost of this
wedding reception, there is still an outstanding balance of $1,264,23.
5, The plaintiff has made repeated requests of the defendant for
payment of the balance due, but has of this date it has not been paid.
WHEREFORE, the plaintiff claims of the defendant the sum of $1,264,23,
an amount requiring compulsory referral to arbitration under the local rules of
Court.
DOUGLAS, DOUGLAS & DOUGLAS
By ,~F~#
Attorney for Iaintiff
, .
COMMONWEALTH OF PENNSYLVANIA )
ss.
COUNTY OF CUMBERLAND
)
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 and subscribed to before me
this I"> '/-A day of May, 1994.
()/l/YJd: YJ1, X~u,..
Notary I .
NOTARiAl SEAL
JANET M. LAY NOTARY PUBtlC
CARLISLE BORO, CUMBERLAND COllIIlT
MY COMMISSION EXPIRES JUNE 26 1995
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YOU I,JI( HUI In R[ QUlltCO to rlU A
Will'''' H -('5'0..5(, ,0 ,t4, (NCLOSl[J
lIlrllHIN 'WIN" !JOt OAT' nlo-, ,nYlcr
III.lor Olt " JUDf,Il4rNJ Ill", If
fNffr.lO AGAINS' YOU.
DOUGLAS, DOUGLAS & DOUGLAS
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Wt DO HUrftt CUtlfY 'MAr IHI
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0' THt OIlIGIHAl Filla IN JHI~
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By _____
...'TORln",s ...r LAW
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CARll~U:. PE"ltj~VLVMflA
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SHERI FF' S llE'J'URN
CCMMONWEI\L'I1J OF PENNSYLVANIA,
COUNTY OF CLMBERLAND
Do-Ma Corp" t/a The Embers Inn and
Convention Center
VS
Cathy Johnson
Timothv Reitz
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In the Court of Common Pleas of '
Cumberland County, Pennsylvania
No. 94-2618 Civil Term.
Complaint in Civil Action Law and
Notice
. XltDtxX6dX~ Deputy Sheriff of
Cunberland County, Pennsylvania, who being duly swom according to law, says,
Compla'nt 'n C'v'l Action Law and Notice
that he served the within ~ ~ ~ ~
upon
Cathy Johnson
.M. lilSlIlc / EDST, on the
4th
A
7 Otto J\"~nI1~. (".qrl isle
Pennsylvania, by handing to
, the defendant, at
7.24
'o'clock
day of
June
. 19--.ilc4t
,
. Cumberland County.
Cathy Johnson
a true and attested copy of the
Complaint and Notice
and at the same tUne directing
her
the "Notice to Plead" endorsed thereon,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
14.00
2.80
2.00
18.80 Pd. by Atty.
6-6-94
Sworn and subscribed to before me
this /J t!- day of : l.-. _
19-.!L A.D.
C ~., (J, /:.t~.iJ,_ ,,,-~
"t " Prothonotary , , / .
attention to the contents thereof and
So answe~~/ ~
:r~n ....J~ 1.--rr' ~
R. Thomas Kline, Sheriff
by
rJ:A~7 :/ zey
Deputy ,Sheriff
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