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ERIC and PATRICIA L. SCHEIBELER, husband Plaintiffs, vs. AMWAY CORPORATION, a foreign corporation; QUIXTAR CORPORATION, a foreign corporation; JA-RI CORPORATION, a foreign corporation; RICHARD and HELEN DEVOS, husband and wife; JAY and "JANE DOE" VANANDEL, husband and wife; AMWAY DISTRIBUTOR'S ASSOCIATION, a foreign association; FRED and LINDA HARTEIS, husband and wife; HARTIES ENTERPRISES, INC., a Pennsylvania Corporation; LOUIS and JEAN MAZZANTEE, husband and wife; LEE and LINDA FESSLER, husband and wife; TO:
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IN THE COURT OF C0MMON PLEAS OF LYCOMIING COUNTY, PA CIVIL ACTION - LAW NO. 00-01715 JURY TRIAL DEMANDED |
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N O T I C E 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. You may lose money or property or other rights important to you. YOU SHOULD CONTACT YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD AN ATTORNEY, GO TO OR TELEPHONE ONE OF THE OFFICES LISTED BELOW: |
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| PROTHONOTARY LYCOMING COUNTY COURTHOUSE 48 WEST THIRD STREET WILLIAMSPORT, PA 17701 TELEPHONE NO. (570) 327-2251 |
SUSQUEHANNA LEGAL SERVICES 329 MARKET STREET WILLIAMSPORT, PA 17701 TELEPHONE NO. (570) 323-8741 |
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AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Lycoming County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Court Administrator's Office, Lycoming County Courthouse, 48 West Third Street, Williamsport, Pennsylvania; telephone no. (570) 327-2330. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. GORDON, THOMAS, HONEYWELL, MALANCA, By: James B. Meade,WSBA No. 22852 CAMPANA, CAMPANA & LOVECCHIO, LLP. By: Marc F. Lovecchio, Esquire |
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| ERIC and PATRICIA SCHEIBELER, husband and wife, Plaintiffs,
AMWAY CORPORATION, a foreign corporation; QUIXTAR CORPORATION, a foreign corporation; JA-RI CORPORATION, a foreign corporation; RICHARD and HELEN DEVOS, husband and wife; JAY and "JANE DOE" VANANDEL, husband and wife; AMWAY DISTRIBUTOR'S ASSOCIATION, a foreign association; FRED and LINDA HARTEIS, husband and wife; HARTIES ENTERPRISES, INC., a Pennsylvania Corporation; LOUIS and JEAN MAZZANTE, husband and wife; LEE and LINDA FESSLER, husband and wife; Defendants. |
COURT OF COMMON PLEAS LYCOMING COUNTY
CIVIL ACTION - LAW NO. 0 0 -0 1715 JURY TRIAL DEMANDED |
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COMPLAINT
COME NOW the plaintiffs, above-named and state claims based upon information and belief as follows:
PARTIES
1. Plaintiffs Eric and Patricia Scheibeler are husband and wife, residing in Williamsport, Pennsylvania.
2. Defendant Amway Corporations is a closely held (by Defendants Ja-Ri Corporation, the DeVos and VanAndel families) foreign corporation, doing business and fraud in Lycoming County, Pennsylvania. Defendant Quixtar Corporation, is a closely held foreign corporation (by Defendants Ja-Ri Corporation, the DeVos and VanAndel families), designed by the principles in Amway to continue Amway's and the other defendants fraud over the internet.
3. Defendant Ja-Ri Corporation is a foreign corporation, wholly owned by Defendants DeVos and VanAndel, doing business and fraud in Lycoming County, Pennsylvania. All acts hereinafter alleged to have been performed by Ja-Ri, Inc. were done individually and on behalf of the corporation, the marital communities of the DeVos', the VanAndel's,, and as agents and representatives of Amway and the other named defendants.
4. Richard and Helen DeVos are husband and wife, residing in Grand Rapids, Michigan and doing business and fraud in Lycoming County, Pennsylvania. All acts hereinafter alleged to have been performed by Richard and Helen DeVos were done individually and on behalf of their marital community and as agents and representatives of Amway and the other named defendants.
5. Jay and "Jane Doe" VanAndel are husband and wife, residing in Grand Rapids, Michigan and doing business and fraud in Lycoming County, Pennsylvania. All acts hereinafter alleged to have been performed by Jay and "Jane Doe" VanAndell were done individually and on behalf of their marital community and as agents and representatives of Amway and the other named defendants.
6. Amway Distributor's Association ("ADA"), now known as Independent Business Owner's Association ("IBOA"), a foreign association, is a mandatory association to which the plaintiffs and other Amway distributors are required to belong. All acts hereinafter alleged to have been performed by the ADA were done on behalf of Amway, and the other named defendants, for the purpose of perpetrating a fraud upon the plaintiffs and the Pennsylvania consuming public.
7. Fred and Linda Harteis are husband and wife, residing in Harrisburg, Pennsylvania, and doing business and fraud in Lycoming County, Pennsylvania. All acts hereinafter alleged to have been performed by Fred and Linda Harteis were done individually and on behalf of their marital community and as agents and representatives of Amway and the other named defendants.
8. Harteis Enterprises, Inc., is a Pennsylvania corporation, wholly owned by Defendants Fred and Linda Harteis, doing business and fraud in Lycoming County, Pennsylvania. All acts hereinafter alleged to have been performed by Harteis Enterprises, Inc, were done individually and on behalf of the Harteis' and as agents and representatives of Amway and the other named defendants.
9. Louis and Jean Mazzante are husband and wife, residing in Easton, Pennsylvania, and doing business and fraud in Lycoming County, Pennsylvania. All acts hereinafter alleged to have been performed by Louis and Jean Mazzante were done individually and on behalf of their marital community and as agents and representatives of Amway and the other named defendants.
10. Lee and Linda Fessler are husband and wife, residing in Williamsport, Pennsylvania, and doing business and fraud in Lycoming County, Pennsylvania. All acts hereinafter alleged to have been performed by Lee and Linda Fessler were done individually and on behalf of their marital community and as agents and representatives of Amway and the other named defendants.
11. Plaintiffs are informed and believe and therefore allege that at all times herein mentioned, each of the defendants was acting as the agent, employee and joint venturer of each and all of the remaining defendants in order to perpetrate a fraud upon the plaintiffs and the Pennsylvania consuming public. At all times material hereto the defendants and each of them had the authority to act and were acting within the course and scope of said agency, employment and joint venture relationships during their dealings with plaintiffs and the acts hereinafter alleged.
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