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v.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Cf4 35"54 Civ7t. 71t"Wl
CIVIL ACTION - LAW
Larry G. Adams t/d/b/a
Larry G. Adams Rotary Well
Drilling, plaintiff
Ben starner, Defendant
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the followihg 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
tiling 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 plaintitf. 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, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)240-6200
Larry G. Adame t/d/b/a
Larry G. Adame Rotary Well
Drilling, Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
Ben starner, Defendant
COMPLAINT
1. Plaintiff is Larry G. Adams, t/d/b/a Larry G. Adame
Rotary Well Drilling, of 105 country Road, Carlisle, PA 17013.
2. Defendant, Ben starner, resides at 374 Georgetown Road,
Gardners, PA 17324.
3. Defendant orally contracted with the plaintiff on June
15, 1992 to conduct well drilling on defendant's property.
4. Plaintiff completed the drilling and submitted a bill to
defendant on July 15, 1992 for $7,057.47.
$4076.85, leaving $2980.62 unpaid.
5. Defendant contracted again with plaintiff on August 12,
Defendant paid only
1992 to service the well.
6. Plaintiff completed the work and submitted a bill to
defendant on september 12, 1992 for $674.00. Defendant did not pay
any amount on this bill.
7. Plaintiff sent Defendant two more notices regarding the
amount owed. The first was on December 5, 1992, stating defendant
owed $3654.62. The second and final notice sent by certified mail
on June 16, 1993, stated defendant owed $3654.62.
8. Defendant has not attempted to pay any of this $3654.62
amount.
9. plaintiff is asking for the amount owed, $3654.62, plus
intere.t from August, 1993. The total being $4369.53.
WHEREFORE, plaintiff prays this Honorable Court grant the
following relief: $4369.53, being the amount owed to plaintiff
plus interest from August of 1993 to present.
Respectfully Submitted,
re
Duncan & otto, P.C.
1 Irvine Row
carlisle, PA 17013
(717)249-7780
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