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Home My WebLink About02-4364 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Joseph A. Cocciardi and Associates, Inc., Plaintiff Richard J. Lynch, trading as R. J. Lynch Painting Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.~ - ~/.~/ CIVIL TERM : CIVIL ACTION - LAW NOTICE TO: Richard J. Lynch, trading as R.J. Lynch Painting 354 Limeprot Pike Coopersburg, PA 18036 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Date: zoo -Z SAIDIS~,/~ OWER AND LINDSAY Supreme Ct. I.D. # 21458 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff Joseph A. Cocciardi : and Associates, Inc., : Plaintiff : Richard j. Lynch, : trading as R. J. Lynch : Painting, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. oa- 2Ly c vim TERM CIVIL ACTION - LAW SA/DIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA AND NOW comes the Plaintiff, through its attorney, Shuff, Saidis Flower and Lindsay, Plaintiff is Joseph A. Pennsylvania corporation, business at 4 Kacey Court, County, Pennsylvania 17055. Defendant is Richard j. Lynch, Painting Co., 6354 Limeprot County, Pennsylvania 18036. At the request of the Defendant, and avers as follows: Cocciardi and Associates, Inc., with its principal place of Mechanicsburg, Cumberland trading as R. J. Lynch Pike, Coopersburg, Lehigh Plaintiff has provided professional services to the Defendant for which a balance exists in the amount of seven thousand eight hundred ninety-seven dollars and twenty-five cents ($7,897.25). Pursuant to the terms of their agreement, Defendant agreed to pay interest at one and one-half (1.5%) percent per month after thirty (30) days from billing date. Despite repeated demands, Defendant has not paid the outstanding bill. WHEREFORE, Plaintiff demands a judgment against the Defendant in the sum of seven thousand eight hundred ninety- seven dollars and twenty-five cents ($7,897.25), together witf interest in the amount of two thousand eight hundred forty-two dollars and eight cents ($2,842.08) and costs. Respectfully submitted, DATED: ~ ~0~ ~0~.~ SAIDIS, SHUFF, FLOWER & LINDSAY Esq. Supreme Court Id # 21458 26 West High Street Carlisle, PA 17013 717-243-6222 Counsel for Plaintiff SAIDIS ~HUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA V~ERIFICATION I verify that the statements made in the foregoing instrumen are true and Correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relat to unsworn falsification to authorities. os~ President SAIDIS ;HUFF, FLOWER & LINDSAY 26 w. High Street Carlisle, PA SHERIFF'S RETURN CASE NO: 2002-04364 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COCCIARDI JOSEPH A AND ASSOCIA VS LYNCH RICHARD J T/A RJ LYNCH P - OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT to wit: LYNCH RICHARD J T/A RJ LYNCH PAINTING but was unable to locate Him in his bailiwick. deputized the sheriff of LEHIGH County, serve the within COMPLAINT & NOTICE , Sheriff or Deputy Sheriff who being says, that he made a diligent search and He therefore Pennsylvania, to On October 4th , 2002 , this office was in receipt of the attached return from LEHIGH Sheriff's Costs: Docketing Out of County Surcharge Dep Lehigh Co 18.00 9.00 10.00 32.00 .00 69.00 10/04/2002 R~, Thomas Kline ~ Sheriff of Cumberland County SAIDIS SHUFF FLOWER LINDSAY Sworn and subscribed to before me this ~ day of ~&~ PAID In The Court of Common Pleas of Cumberland County, Pennsylvania Joseph A. Cocciardi et al VS. Richard J. Lynch t/a R.J. Lynch Painting SERVE: same No. 02 4364 civil Now, September 13, 2002 hereby deputize the Sheriff of Lehigh deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Now~ within Affidavit of Service ,20 ,at o'clock M. served the upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this day of ,20__ Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT