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Home My WebLink About95-01864 ~ , ( .... ~ . ., g ~.. -:r: ~ ~ j f I ::r ! ~ ()o - I l.()1 0- . . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. HARTMAN AND ASSOCIATES, INC, Plaintiff KIM-BOB, INC, Defendant CIVIL ACTION - LAW COMPLAINT AND NON, comes Hartman and Associates, Inc" by and through its attorneys Saidis, Guido, Shuff & Mas land, and respectfully avers the following: I, plaintiff, Hartman and Associates, Inc., is an engineering firm and corporation, organized and existing under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 2101 Orchard Road, Camp Hill, Cumberland county, Pennsylvania. 2. Defendant, Kim-Bob, Inc., is a corporation with an address of 1501 South 19th Street, Harrisburg, pennsylvania 17104. 3. On or about January II, 1969, Plaintiff entered into an agreement with Defendant whereby plaintiff agreed to provide engineering services to Defendant and Defendant agreed to pay plaintiff its customary and usual fees for the services performed and all costs incurred on its behalf in connection with services rendered, 4, Invoices were mailed to Defendant setting forth the services which had been rendered by Plaintiff on Defendant's behalf, the amount being charged for the services, and any outstanding balance due on prior invoices. 5. Since November 7, 1969, plaintiff has sent numerOUB 3 " invoices to Defendant in the amount of One Thousand Five Hundred Forty-Seven and 00/1 00 Dollars ($1,547.00). A true and correct copy of the invoices sent to Defendant is attached to and incorporated into this complaint as Exhibit "A". 6. Although Plaintiff has demanded payment of the balance due of One Thousand Five Hundred Forty-Seven and 00/100 Dollars ($1,547,00), Defendant has failed to pay all or any part of the balance due Plaintiff, 7, Plaintiff performed its obligations under the agreement between it and Defendant by providing valuable engineering services to Defendant and incurring costs on its behalf, the fair and reasonable value remaining unpaid of which is One Thousand Five Hundred Forty-Seven and 00/100 Dollars ($1,547,00). 8. Plaintiff has performed its services for Defendant fully and satisfactorily, and conformed to, and complied with, all of the terms and conditions required of it under the oral agreement between it and Defendant. 9, Despite Defendant's obligation to pay Plaintiff for the services performed and costs incurred on its behalf, and despite Plaintiff's demands on Defendant for such payment, Defendant has wrongfully failed and refussd to pay to Plaintiff the sums due it. WHEREFORE, Plaintiff, Hartman and Associates, Inc" demand judgment against Defendant in the amount of Ons Thousand Five 4 , ( ^ :.;1< rlil: 1, ,. I' . ~ I -'1 .j 1'11~lt1fltl\\'F fit 'J Hili ' tn,' I! f'II111lTY ''', f 111'IIiI'l:I <\II! IL^Ji'UIMI /, ^':",'", ii-i i "I \,", Iq!!' flU [i It;, h.. l t: ' , rp '_!; I" 1, ~ ~ll . 11!:l_ 1! " " '. ' i', ~ ; ',""" . '/':"/1. I l' ) w. :;.1 y:, I ti It riO' r" "j ~, r" , , , '. l" . ~ ' ! , 1<' I ., 11' I ~ l~' J .j 1 Cl'l , , I ; J , " I, , oj "L ill,j : " " ; I" " I . Ii 1 n I ',' f'l-q r ", " 11;J!l1l:d ,j," (,'ri'1:iltl, '-'lit \idi_~ IIn.lb ~,. t. d~"rdll I."I,d t LI' h. 'I 11 t II ~ ; I r v,,~ t tit.' ... 1 . t i ; Ii LlEl ,n;j:: \/1' : 1" -d.> t.he .-ltt.)l':tll'd l..!tlln Il"'l' ',,' ~" ~':;hf-:,r 1 f.t . ;-; (" i"' I.: [If)cl~l-Jt ) nq flu t 11 f I' 11/[1! ::::Ul",_"!ldll!" Pt.lII'1I r II ,-, qlIlT', I ~ 1 . _ " ,,, ~:: '. r.,!\I;l,1il:J , "tIl'IAJIl1' ; l' f til. ;,i 1 H,IIII!rll Ii, ...' <''' "1\ , r" (, r'-' i. .- '... "~'I ,,' r,,\:, ~ - .1. f"'",~ r 1 rll 'T II 'I' ,\ r 1 1 ~ i l: t\' I',' I', -,' SWIll " '~Hl,l uf',';'! , I'" ,j . " ! ! t h 1 ;.~ J'f ..... lid)' lit '7 ,t! \ " 'iI' A r '"I, , ,-l'l'-'-'C )JLq,(:,v ""-.05' 1 t"", I I f \,1 \ 1....1.:\-:. . \Ill t :,'. \oJ i." 1 fl i!.' t, t I '--'1 \:' 11,' r ,~. "1,1\ __y 1 ":jrl! ii, "'lll'_ .,'. I '.rlfl,,-:.,.l"'jln );1, "':' 1 pt ,)1 ",," !' ! --- ' r " ! i.,. '-1];"1 ft '1:1 The Court or C.:mmo;l pIe . .. I' "I r \...:.Jr. ~:.:;: ~:t'l="c:l \".:.:t.::--;.I"~I, Psnr:sy l'l:::i:i:: Hartman and ^ssociates. Inc. 'IS. Kim-Bob Inc. :-Ie. 95-1864 Civ,!l Tenll ---. :?_- ~ew, ^pril 19, 1995 :9_ !, S:~~..z:'? O? C:'~GZ?.!..A..'ID COt..~':'?, ?~ co h==--by cL::ue:: th.: Sb.:i.:i 0; Dauphin C"u.::.ry :.;) ~",:==-.u.: ':.:.is '.Y:::, ::is d..~u::.:ct1 . , . :~ -.,.... 1t :.::: :-:qu= :.::d :-=.=,k ~t :.:: ?!1b=:. .-,;-1 ~ r;.%:.--.<< ~~ 5l1e.."1:l at C:==er'~d C~u:tT, ?:I. Affidavit or Sem~ ~(lW. ~9 -. o'.:!cc ~L 1=-.~ =: ';"it!:in '.1pon It by ::u:d!:1J :0 ~ C':P!' Ct ::e ~ri~-.,I " llld _'!lI~. !=wn :0 . ~ .:::u:::::s :::,:::-:L So 3::.SW=. SI='..:i' 01 CaWUl". ?~ =::~_6yoi 19_ COSTS SL1......1CZ ~C!I.Z...GE .\.::IDA.vTI s 5wcr: :me! r.lbc:-Jx:l be:'c:n: __"-'__0 s f_ '"-a '. v. III THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. HARTMAN AND ASSOCIATES, INC, Plaintiff KIM-BOB, INC. Defendant CIVIL ACTION - LAW COMPLAINT AND NOH, comes Hartman and Associates, Inc., by and through its attorneys Saidis, Guido, Shuff & Mas land, and respectfully avers the following: 1, Plaintiff, Hartman and Associates, Inc., is an engineering firm and corporation, organized and existing under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 2101 Orchard Road, Camp Hill, Cumberland county, Pennsylvania. 2. Defendant, Kim-Bob, Inc., is a corporation with an address of 1501 South 19th Street, Harrisburg, Pennsylvania 17104. 3. On or about January 11, 1989, plaintiff entered into an agreement with Defendant whereby Plaintiff agreed to provide engineering services to Defendant and Defendant agreed to pay Plaintiff its customary and usual fees for the services performed and all costs incurred on its behalf in connection with services rendered, 4, Invoices were mailed to Defendant setting forth the services which had been rendered by Plaintiff on Defendant's behalf, the amount being charged for the services, and any outstanding balance due on prior invoices, 5. Since November 7, 1989, Plaintiff has sent numerous 3 invoices to Defendant in the amount of One Thousand Five Hundred Forty-Seven and 00/1 00 Dollars ($1,547.00). A true and correct copy of the invoices sent to Defendant is attached to and incorporated into this complaint as Exhibit "A". 6, Although Plaintiff has demanded payment of the balance due of One Thousand Five Hundred Forty-Seven and 00/100 Dollars ($1,547.00), Defendant has failed to pay all or any part of the balance due Plaintiff. 7, Plaintiff performed its obligations under the agreement between it and Defendant by providing valuable engineering servicea to Defendant and incurring costs on its behalf, the fair and reasonable value remaining unpaid of which is One Thousand Five Hundred Forty-Seven and 00/100 Dollars ($1,547,00). 8. Plaintiff has performed its services for Defendant fully and satisfactorily, and conformed to, and complied with, all of the terms and conditions required of it under the oral agreement between it and Defendant. 9, Despite Defendant's obligation to pay Plaintiff for the services performed and costs incurred on its behalf, and despite Plaintiff's demands on Defendant for such payment, Defendant has wrongfully failed and refused to pay to Plaintiff the sums due it. WHEREFORE, Plaintiff, Hartman and Associates, Inc., demand judgment against Defendant in the amount of One Thousand Five 4 HART~lAN AND ASSOCIATES, INC, IN THE COURT Of COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 95-1864 CIVIL TERM KIM-BOB, INC. Defendant CIVIL ACTION - LAW IMPORTANT NOTICE TO: Kiln-Bob, Inc. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDG~lENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 '1'0 fIND OUT WHERE YOU CAN GET LEGAL HELP. CUlnberland County Court Adlninistrator South Hanover Street Carlisle, PA 17013 (717) 240-6200 SAlOIS, GUIDO, SHUFF , MASLAND Dated: June 13, 1995 BYd---~' Tim thy M. Anstine, Esquire Supreme Court ID #44879 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attorney for Plaintiff, Hartman and Associates, Inc. ,~ / I I .' 1\1) L 'Ii, ),. ' ~ ~ ~ p: ~ ." *- ~ c:-, , U1 9-.J ~ f ..c -- ~ .) " ~ -- ,"'. :" ~ . . -1-- -':\ ' , ~ $ . - N }- <'. ~ ~ f~