01312011 DISTRICT COURT OF MARYLAND DIST: 06 CIVIL SYSTEM JUDGMENT UPDATE 06 01 CASE NUMBER VER: 9191 2000 CASE ACTIVITY DATE: 07052001 STATUS: A 04242000 CLAIM TYPE: CONT FILING DATE: 04072000 9M7 TRIAL DATE: DISP: JUDG COMP FILN DATE: 04072000 COMP ACTIV DATE: 07052001 COMP STATUS: JUDG 03132001 COMPLAINT NUMBER: 001 COMPLAINT TYPE: REGL LEVIN, ROBERT PC VS. CINEMA GRILL SYSTEMS INC. JUDGMENT TYPE: AFDV DATE: 03122001 06 01 JUDGE ID: 9M7 AMOUNT: 6,847.50 INTEREST: 0.00 COST: 33.00 OTHER: 0.00 ATTORNEY FEE: 0.00 POST INTEREST LEGAL RATE: CONTRACTUAL RATE: JOINTLY AND SEVERALLY: IN FAVOR OF DEF: DISMISSED WITH PREJUDICE: POSS OF PROP VALUED AT: 0.00 AWARDED TO: DAMAGES: 0.00 0.00 VALUE OF PROPERTY AND DAMAGES OF: 0.00 AWARDED TO: AMOUNT: 0.00 BAD FAITH INSURANCE CLAIM IND: RECORDED LIEN DATE: RENEWED LIEN DATE: SEND NO NOTICES: JUDGMENT RENEWED DATE: SATISFACTION DATE: END OF DATA 01 PAGE: 001 _fuk 9/97) MOKEGGMERY C, T3 $10,000 'if W, vY,. lik 33; In an action-ofljconiract [Mort lfifeplevm _*mf :El Uetiriu?iei 5: ,mifzraiiv :xii my n? gfi?issxsaqags; ern; iffy 33 _'xgr} 'emi Q5 anno ni Irasgngiivfgf _.lf . gp _5fr?m?z?xiz? Sei? \f'?5iiSE 1 1 'ms nf; :fi ani? mga; fi* 'in ami nyaii .1 JL. ;31;;l?1 mr gif; 1' 9 emi; uw; _0;aws_i Qmrug 20550 1 -'zu Ferry lnna? 7 if -Probe?s sm; 9* ?gawi ..kiwi gg nf 14100 I 5? I A IQ 5312, $53 I ?'?1i5 :itil :xoiM;zZfr%;qZEURxou ATTORNEYS ww mfxri Fiirfifii fi* $0 .r1uuD 5" 4 QL an 03 wimm 2, A an mm? zy?b (Oli .EYAQ Of .I .men "mmf 'i3 .S 05; 'jiwgzifmm 1 vii fv QE .2 EURRrl\i5f??i??3 v?isg ski mm ww? . waz; fr Ji AiRoedi JG (Q _and Qu rt c0StS_ fl" 1 4 .aw 1" 'wie Other . 'fr?ih f' mm including the amciunt ff "ig fa; Properly, aulhenticatechcopy of upomwhich AEI vouch -f -1 emi- I QWWQI1 repglf bllhorz-esinmate' f. Qwnelru, 4 _fm 1.1mm Ib Tn ip, arms Eh' <6 wnef a ne en mf 7 mamgsq (mi (Sl are madwn set forI|1~|n the 'Complaints ,aids nif- nm mm 'in nm #uh ,v/ci W5 i>l0r?r?5iw Hd <11 imiupax 'Um 'io sd! nw _vzuml hluurka io, 1 _th esg noir :sen/ice;: as_ defined >>the. nor hasbeen . if lJU~f mio? :uit I: ziumlfilfi OT ao (msn nu mil f_ zzimdo U5 nigh li amd Date Slnnalum nr Aram fl S) DISTRICT COURT OF MARYLAND FOR MONTGOMERY COUNTY Robeit Levin, P.C. 1901 Research Boulevard Suite 400 Rockville, Maryland 20850 Plaintiff, v. . Cinema Grill Systems, Inc. 1690 South Johnson Ferry Road Civil Action No. Atlanta, GA 3003 19 Defendant VERIFIED COMPLAINT Comes now Plaintiff by and through its counsel, Robert N. Levin, and sues Cinema Grill Systems, Inc. and for causes of action respectfully shows the Court as follows: 1. Plaintiff is a corporation engaged in the practice of law in the State of Maryland and elsewhere. 2. Defendant is a corporation engaged in the business of selling Hanchises. 3 . Defendant retained Plaintiff to represent it in regard to a lawsuit that had been filed against it in the United States District Court for the District of Maryland. Plaintiff was successful in having the suit dismissed. 4. Plaintiff provided the said services to Plaintiff at Plaintiff's request pursuant to an agreement that required Defendant to pay for the services on an open accotmt. 5. Despite the agreement between them and despite demand, Defendant, without just cause or lawful excuse, has failed and refused to make payments due from it to Plaintiff. As ofthe time ofthe filing of this action, the total amount owed on this account was $6,847.50 (Six Thousand Eight Forty Seven Dollars and Fifty Cents). 6. Based upon the foregoing, there is now due and owing from Defendant to Plaintiff a sum of not less than $6,847.50 (Six Thousand Eight Hundred Forty Seven Dollars and Fi&y Centsj. COUNT 1 (Breach of Contract) 7. Plaintiff restates and incorporates by reference all ofthe foregoing, as though it were fully set forth herein. 7 8. Defendant breached his contract with Plaintiff by failing to pay for the services rendered by Plaintiff, by failing to reimburse its out-of-pocket expenses. 9. Said breaches of contract foreseeably have caused Plaintiff pecuniary injury in the amount of $6,847.50 (Six Thousand Eight Forty Seven Dollars and Fifty Cents) plus costs of this action. WHEREFORE, the premises considered, Plaintiff prays judgment as follows: A. Compensatory Damages $6,847.50 (Six Thousand Eight Hundred Forty Seven Dollars and Filty Cents). B. Interest. C. Costs of this suit. D. Such other and ftuther relief as to the Court seems just. COUNT 2 (Quantum Meruit) 10. Plaintiff restates and incorporates by reference all ofthe foregoing, as though it were tially set forth herein. 2 f- A, V) 1 1. In order to induce Plaintiff to perform the subject services for Defendant, Defendant represented to Plaintiff that Plaintiff would be paid as aforesaid. 12. In reliance on Defendant's representations, Plaintiff performed valuable services as aforesaid and Defendant accepted and benefitted from said services to the detriment ofthe Plaintiff The fair and reasonable value of the benefits thus conferred on Defendant but not yet paid for by Defendant is $6,847.5 0 (Six Thousand Eight Hundred Forty Seven Dollars and Fifty Cents). WHEREFORE, the premises considered, Plaintiff prays judgment as follows: A. Compensatory Damages $6,847.50 (Six Thousand Eight Hundred Forty Seven Dollars and Cents). B. Interest. C. Costs of this suit. D. Such other and further relief as to the Court seems just. Respectfully submitted, Ro ert N. Levin Robert N. Levin, P.C. 1901 Research Boulevard Suite 400 Rockville, MD 20850 (301) 517-8727 VERIFICATION Upon being sworn, Robert Levin, stated as follows: At all times relevant hereto I was President ofthe Plaintiff firm and Ihave been authorized by it to make this Verification on its behalf I am an adult and I am otherwise competent to testify as to the following. I have read the foregoing Complaint and the factual allegations contained therein are true. Ihave personal knowledge ofthe 3 5' facts alleged in the Complaint. Defendant is indebted to Plaintiff in the amount of $6,847.50 exclusive of interest and costs, and that sum is now due and payable and Defendant is not entitled to any setofl; recoupment or other defense thereto. The fees charged Defendant were fair and reasonable and were consistent with the nature of the tasks performed for Defendant. Robert N. Levin Sworn and subscribed before me a Notary Public thisf day of April, 2000. Notary Public #535 *Maggy Mm uma 4 f. Civil Clerk's Office Law Offices Of ROBERT N. LEVIN, RC. 1901 RESEARCH BOULEVARD SUITE 400 ROCKVILLE, MARYLAND 20850-3164 TELEPHONE (301)517-8727 TELECOPIER (301) 762-4056 E-Mail nlevin@er0ls.c0m April 4, 2000 District Court for Montgomery County 27 Courthouse Square Rockville, Maryland 20850 Re: Robert N. Levin, P.C. v. Cinema Grill Systems, Inc. Dear Madam Clerk: Please find enclosed a Verified Complaint and a check in the amount of $28 00 for the filing fee and certifiedmail fee. Thank you. RNL:alc "Enclosures LSP 1 113 c' Very truly yours obert N. Levin ?cT 0? thy 5 DISTRICT COURT OF MARYLAND for Mont timer Coun '31 iy Located at Z7 Courthouse Square, Rockville, Maryland 20850 Wrur or SUMMONS 'Inv Date Filed Apr 7 2000 Defendant . CINEMA GRILL SYSTEMS INC. Issue Dm Apr 237 2000 Serv" Cum Case Number 06010009191z000 Address 1690 soUrH JOHNSON Com WMNO 001 ATLANTA, GA 00000 Trial Date Aug 9, 2000 Trial Time 08:00 am Trial Room 101 You are summoned to appear for trial at the date, time and location shown above. If you intend to be present at the trial, you must file the attached Notice of Intention to Defend Within sixty days of receiving this complaint, Failure to fle the Notice of Intention to Defend may result in a judgment by default or the granting ofthe relief sought. MUST BE SERVED BY May 24, 2000 Jeffery Ward, Administrative Clerk DJ CUTHERE CUTHERE NOTICE OF INTENTION TO DEFEND Case Number :060l0009l9l2000 Complaint No. 001 TrialDate :Aug 9, 2000 NOTICE: If you contest the claim or any part thereoi you must complete and te ar off this Notice of Intention to Defend and tile this notice no later than 60 days alter you receive this Summons and be present in court on the trial date. If you do not appear judgment by default or the relief sought may be granted. A corporation may enter an appearance only by an attorney except that an ofthe corporation may appear on its behalfif the action is based on a claim that does not exceed $2,500. Any reasonable accommodation for persons with disabilities should be requested by contacting the court prior to trial. SEE ATTACHED NOTICE FOR IMPORTANT INFORMATION I intend to be present at the trial of this claim and demand proof ofthe Plairititfs claim. Explanation of defense Date Signature Work Phone Home Phone Case (M DISTRICT COURT OF MARYLAND for Montgomery County Located at 27 Courthouse Square, Rockville, Maryland 20850 VVRIT OF SUIVIMONS 0 em; Defendant CINEMA GRILL SYSTEMS INC. 2123330 serve On CINEMA GRILL SYSTEMS INC. Case N?mber Address 1690 soUrH JOHNSON C0mphimND 001 ATLANTA GA 00000 Trial Date Aug 9 2000 Trial Time 08:00 bm Trial Room 101 You are summoned to appear for trial at the date, time and location shown above. If you intend to be present at the trial, you must iile the attached Notice oflntention to Defend Within sixty days this complaint. Failure to tile the Notice oflntention to Defend may result in a judgment by default or the granting ofthe relief sought. MUST BE SERVED BY May 24, 2000 Jeffery Ward, Administrative Clerk/ DJ CUTIIERE HERE NOTICE OF INTENTION TO DEFEND Case Number 060100091912000 Complaint No. 001 Trial Date :Aug 9, 2000 NOTICE: If you contest the claim or any part thereoi you must complete and tear off this Notice of Intention to Defend and file this notice no later than 60 days alter you receive this Summons and be present in court on the trial date. If you do not appear judgment by dehult or the relief sought may be granted. A corporation may enter an appearance only by an attorney except that an ofthe corporation may appear on its behalfif the action is based on a claim that does not exceed $2,5 00. Any reasonable accommodation for persons with dis abilities should be requested by contacting the court prior to trial. SEE ATTACHED NOTICE FOR IMPORTANT INFORMATION I intend to be present at the trial of this claim and demand proof of the Plaintiifs claim. Explanation of defense e>?T 0? fl fl DISTRICT COURT OF MARYLAND for Montgomery County 2 Located at 27 Courthouse Square, Rockville, Maryland 20850 WRIT or SUMMONS 'nv I Date Filed Apl'7 2000 lsisiizddiit I OINEIVIA Date Ap' 200? Case Number 2 0601000919l2000 Address 1690 SOUTH JOHNSON FERRY RD. Complaint N0 001 ATLANTA GA 00000 I Tr1alDate Aug 9 2000 Trial Time 08:00 ,am Trial Room 101 You are summoned to appear for trial at the date, time and location shown above. If you intend to be present at the trial, you must tile the attached Notice of lntention to Defend Within sixty days of receiving this complaint. Failure to Hle the Notice oflntention to Defend may result in a judgment by default or the granting ofthe relief sought. MUST BE SERVED 24, 2000 Jeffery Ward, Administrative Clerk/ DJ CUTHERE UTHERE NOTICE OF INTENTION TO DEF END Case Number 060-l 00091912000 Complaint No. 001 Trial Date Aug 9, 2000 NOTICE: If you contest the claim or any part thereof; you must complete and tear off this Notice of Intention to Defend and tile this notice no later than 60 days after you receive this Summons and be present in court on the trial date. If you do not appear judgment by or the relief sought may be granted. A corporation may enter an appearance only by an attorney except that an oillcer ofthe corporation may appear on its behalfif the action is based on a claim that does not exceed $2,5 00. Any re as onable accommodation for persons with dis abilities should be re que sted by contacting the cotut prior to trial. SEE ATTACHED NOTICE FOR IMPORTANT INFORMATION I intend to be present at the trial of this claim and demand proof ofthe Plaintiffs claim. Explanation of defense N, rn mo 22 Qs. *5 :/155 0:5 502-'" oO>? 5 OQH (U 0 O0 $11 "uw SQ>or sl; ron DETENTION |s AWARDED T0 'rue June: ID: CW DATE: 04/07/2000 INITIAL AFFIDAVIT CASE FILING . REGULAR CLAIM UNCLAIMED MAIL ON DEFENDANT 06/13/2000 NOTICE OF ourcone up ORIGINAL SENT TO THE 10/18/2000 SUMMONS RENEWAL REQUESTED BY ATTORNEY FOR PLAINTIFF 10/30/2000 NOTICE OF SUMMONS RENEWAL SENT TD THE FLAINTIFF 10/30/2000 NOTICE OF MERIT TRIAL SENT TO ALL PARTIES 11/20/2000 SUMMONS RENEWAL, SERVED ON DEFENDANT