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GOLD_, ~1IIAIf .. ..IPIIIIIl, P.C.
Karan 8. rauchtanbergar - Attcrnay I.D. 158995
320 Harkat 8traat
8trawbarry Squara
P.O. Box 1268
Harri.burg, PA 17108-1268
1717) 234-4161
Attornay for Plaintiff.
PENNSYLVANIA NATIONAL MUTUAL
CASUALTY INSURANCE COMPANY,
subrogee of KEITH AND KATHY
CALTA
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 9 (, -- /7ff/
eLI-I-~ c. 0u/w'--
.
GETTYS BUILDERS, INC. and
LENKER PLUMBING CONTRACTORS,
Defendants
.
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.
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTIeB
YOU KAVB BBRB SUBD 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/Answer, New Matter and Counterclaim 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.
COURT ADMINISTRATOR
Cumberland county Courthouse
1 Courthouse square, 4th Fl.
Carlisle, PA 17013-3387
(717) 240-6200
GOUIUJlG, KM:IIIIUI , ..I'IIAIf, ..C.
Kar.n S. r.ucht.nb.rg.r - Attorn.y 1.0.
320 Hark.t str..t
Itraw~rry squar.
P.O. BOIr 1268
Harri.burg, PA 17108-1268
(717J 234-4161
Attorn.y for Plaintiff.
158995
PENNSYLVANIA NATIONAL MUTUAL
CASUALTY INSURANCE COMPANY,
subrogee of KEITH AND KATHY
CALTA
plaintiffs
IN THE COURT OF COHMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
{) /"v'le't;dul'"
No. 7(,. ,
GETTYS BUILDERS, INC. and
LENKER PLUMBING CONTRACTORS,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
COMPLAINT
AND NOW, come plaintiffS, Keith and Kathy calta, by and
through their attorneys, GOldberg, Katzman' Shipman, P.C., to file
this complaint and, in support thereof, state as follows:
1. Plaintiffs, Keith and Kathy Calta, are adult individuals
residinCJ at 8 Stradford Lane, Mechanicsburg, Cumberland County,
pennsylvania 17055.
2.
Defendant, Gettys Builders, Inc.
("Gettys"),
is
incorporated and existing under the laws of the Commonwealth of
Pennsylvania with a place of business at 1901 state street, Camp
Hill, cumberland County, Pennsylvania 17011.
3. Defendant, Lenker PlumbinCJ Contractors ("Lenker"), is an
entity which regularly conducts business in the Commonwealth of
Pennsylvania with a place of business at RD11, Box 5024, station
Road, Grantville, Dauphin county, Pennsylvania 17028,
4. On December 18, 1992, Plaintiffs entered into a contract
with Gettys for the construction of a residence at Lot #116,
Peninsula Subdivision,
now known as
8
stradford Lane,
Mechanicsburg, Pennsylvania (the "contract"). (see Exhibit A
attached hereto)
5. Pursuant to the Contract and/or blueprints and
specifications, Gettys agreed to install a jacuzzi whirlpool bath
into the aforesaid residence.
6. Gettys subcontracted with Lenker to perform various
plumbing duties including installation of the jacuzzi whirlpool
bath, pursuant to specifications and installation instructions.
(See Exhibit B attached hereto)
7. Plaintiffs moved into their home at 8 Stradford Lane,
Mechanicsburg, Pennsylvania in August 1993.
8. On september 20, 1993, Kathy Calta used the jacuzzi
whirlpool bath for the first time and the jacuzzi whirlpool bath
leaked water causing extensive damage to the residence and personal
property therein.
COUNT I
KEITH AND KATHY CALTA V. GETTYS BUILDERS. INC.
Breach ot contract
9. The averments of paragraph 1 through 8 are incorporated
herein by reference as if set forth in full.
10. Pursuant to the contract, Gettys agreed that it would not
employ any person not reasonably skilled in the work assigned to
him or her and that all labor performed would be of good workman-
like quality. (see paragraph 6 (c) of Exhibit A attached hereto)
11. Gettys breached the Contract by employing Lenker which
was not reasonably skilled in installing the jacuzzi whirlpool bath
and whose labor was not performed in a good workmanlike manner.
12. Gettys' breach of the Contract resulted in leaking of the
jacuzzi whirlpool bath which caused extensive damages to
Plaintiffs' home and personal property therein.
13. After the extensive damages occurred to Plaintiffs' home,
Gettys had the jacuzzi whirlpool bath repaired and also repaired
the family room ceiling which was damaged by the water leakage.
14. Gettys refused to pay for damages to the alarm system and
damage to personal property within the home.
WHEREFORE, Plaintiffs, Keith and Kathy ca1ta, demand judgment
in their favor against Gettys Builders, Inc. in the amount of
$5470, together with interest and costs of suit.
COUNT II
KEITH AND KATHY CALTA V. GETTYS BUILDERS. INC.
Breach ot Warranty
15. The averments of paragraph 1 through 14 are incorporated
herein by reference as if set forth in full.
16. Pursuant to the contract, Gettys expressly warranted that
all labor performed would be of good workmanlike quality. (See
paragraph 6(e) of Exhibit A attached heroto)
17. Gettys breached this express warranty whon Lenker failed
to perform in a workmanlike manner when it failed to properly
instal the jacuzzi whirlpool bath and failed to follow the
installation instructions of the manufacturer.
18. Gettys' breach of its express warranty that labor would
be of good workmanlike quality caused extensive damages to
Plaintiffs' home and personal property therein.
19. Gettys has refused to pay for damages to the alarm system
and damage to personal property within the home.
WHEREFORE, Plaintiffs, Keith and Kathy Ca1ta, demand judgment
in their favor against Gettys Builders, Inc. in the amount of
$5470, together with interest and costs of suit.
COUNT III
KEITH AND KATHY CALTA V. LENKER PLUMBING CONTRACTORS
Breaoh ot Warranty
20. The averments of paragraph 1 through 8 are incorporated
herein by reference as if set forth in full.
21. Lenker contracted with Gettys to perform plumbing work at
Plaintiffs' home, including installation of a jacuzzi whirlpool
bath.
22. Lenker installed the jacuzzi whirlpool bath in the
Plaintiffs' home and impliedly warranted that the work was
performed in a good workmanlike manner.
23. Lenker breached the implied warranty that its work would
be performed in a good workmanlike manner when it failed to
properly install the jacuzzi whirlpool bath and failed to follow
.
the installation instructions of the manufacturer.
24. The installation instructions from the manufacturer of
the jacuzzi whirlpool bath provided that "prior to final
installation, the bath must be filled with water and operated to
check for leaks that may have resulted from shipping damage or
handling." (See page 2 of Exhibit B attached hereto)
25. Lenker failed to perform its work in a good workmanlike
manner when it failed to fill the jacuzzi whirlpool bath with water
and operate it to check for leaks prior to final installation.
26. Lenker's breach of the implied warranty that work was
performed in a workmanlike manner caused extensive damages to
Plaintiffs' home and personal property therein.
27. Lenker has refused to pay Plaintiffs for damages to the
alarm system and personal property within the home.
WHEREFORE, Plaintiffs, Keith and Kathy calta, demand judgment
in their favor and against Lenker Plumbing Contractors in the
amount of $5470, together with interest and costs of suit.
Respectfully submitted,
GOLDBERG, KATZMAN & SHIPMAN, P.C.
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Karen S. Feuc ten
ID#: 58995
320 Market street
P.O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161
Attorney for Plaintiffs
Esq.
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exhibit A
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GettyS Bd 'No.rB InC.
"us """""""" "'_ "_"'" ..... to" --' 8" '" .,
..".""' "" _' bY ,ad bo""oo
, of _ 3 25 Lame POR ~ l.lIne
ca.' "ill." 17' II h"""'" ,,,,,",,,, 0< .,.",01 "."or',
"" """'" ..,lL"" "".. , _",VO." """,,m'ion. ,.""" on 0""" " 3913
Marlult street, C<<l1;IlIill, PI' 17011 (COntrllCtor").
~. tho' tbo portito ...",to. in __"100 of tbo ",,,,,,
__ "" _to ""tolnOl "",in, "" - '" BE """,",,' ""'"
llEREB'l. agree as fou.owsl
1. _,lon. ".. eon"ooter "...u ....' "" l>>lld ' .... - ,tbo
,___, o. thO _, of "" .,..,." ,,""... 0' """,,,,,, .. ~.
Lot M116 peninsula subdivision · (the "premiSes").
,. prlca, ".. ""'" ...... to pay to tbo eon_to< fo< tho parl-
of tho _ -'" to' forth. tho "" of. TWO "..d"d Th'''' sov"_
TOOU..od .... nu"",d "F .,oo,'QC' dou.<a ,'eon-' """".,
3. ~sit. \leC8ipt of 'Een Thousand Dollars -
{S" oM" _' """" ,," '" bo ........ ....... tho """' - ooa' of
consa:uction. is \iB]:eDY acla'lOWledged.
,. ,ion' toO,""" In _" ".. """''''' "...u bo ....... in
___ "'''' "'" lino1 _""""",,,into. ,,.,If""'''''''' """ ,_.
__ _ . eon""",,,' !no"""""" '" '.,..,." "" ",,", oaleO'loO ,...,.
_0 "...u bo dul, """,... "" ""'" "" - port 01 tho -,....
eon-"" "",u. ...... all tho ""or_ "" ..- ,u. tho """ ..
__ to """'at' "'" """,in, In ___ .,to "'" ..._.ont. .-'
for "", "" ",tor'" to bo padO"'" "" -""" bY ... .,..,." " -"""
heJ:ein.
~u~
5. ,.,.;,,'Ut"'''''' "...,..,."...... "tbo"'" "" ....in,'
eon"""" -", .."in all ."'''''''' -'to 0< ,,-""""" ""' all
_",pal"",,", "" ~to 0' u,,,,,,,, ...... "" bo _uool fo' tho
__'100 '" _ of "'" ......"" "". to tbo' .... au_,,, "'"
eon'm''''' '" """to """,," _ on MY ....,100''''''' fo< - -'to "
,u'O",..,,,,... ".. """" ,...., ,,,,",!dO ,ad paY fo< .",,,,,,, voto<. -'
and ...""" fvo' 0' ,,,,,,, '" bo ..ad "",in, ... ""'" of "",_'100.
~ See First Addendum dated December _, 1992 ("Addendum").
.. .." ,E .0' "..'E"""" "~a """" ",..,.." ,"" ""., ...', "
",,' .,..'E"""" " "",.. ,E "'U,,. .... "d,' ., b,ll' .. .... ",.
may approve flna1 specifications. n
.u Sue Exhlb1t /I.-I and A-2. fl
......... c.:.,'l' t\t.ldundum.
Keith , KathY ca1ta
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6. Material.s/Work.. Unless otherwise specified:
/I) Contractor shllll provide and pay for /Ill materials and labor
necessary for the execution /lnd canpletion of improvenents.
b) All materials shall be new /lnd of good quality.
c) Contractor shllll not employ on the pran1ses /100 penoon not
rellSon/lble skilled in the ~rk assigned to him/her. All labor perfoxmed shall
be of good ~rkman1ike qwUity. Materials used shllll be of the gr/lde
specified, and where the grade is not specified, materials nust be of qulllity
. c:unparable to other specified gr/ldes of material.
d) Contractor shall furnish all materials /100 perfOIlll all work as
provided for in the drawings and specifications referenced above. Contractor
shllll, at his own expense, stake out the foundation on Owner's lotI obtein
OI.ner's /lpprovel of house placement and elevation, which /lpprovel shall not be
unrel!llonebly withheld I excavete and erect a foundlltionl beckflll to ths
foundation with materials excavated upon the PrEmises, where possible I end,
above-referenced drawings and specifications.
..
W11.1I~' a ~r'== ~S~ll~: ~:"'H1..d ~1 P::;~h:,1l :r:~i~~t~
0ent!ee~0l!' atId. QlIIl8l'. Illldliliall.y ."tiIlS the Ilata". of the eMflge--U1
S8fl8Uu"UeR ARlI the ~":lit~aJ. c:elll: tMreQf er ~:I.t 1:" De aJ.J.ll\_ apiNt
tile t;ent..._Jt ~.l.e8 gf I:r.:lllIt.rol::t:l.cm. C8l1tr<gr :t8118t>... tIw Rgnt tg wfulIe
-to-~ c;hangllll lAU.c;:h Naw.t-.i.n a lIubetantiaJ. alt_.tiOR of the plans-end
epc.ci!!eatiens. ~1! af ehange swan 'In, bi WD t~R lIigniRg of Raid
. -ehaAge eJ:dc.
B. Stipulation Against Liens. Before final payment, Contrector Bhall
furnish to Owner proper lien waivers fran Contractor, subcontractors and
materilll people who fumished labor or materials on the PrEmises. Prior to
c:cnmencement of construction, Contractor shall execute and deliver to Owner a
proper Stipulatioo and Waiver of Mechenics t Liens, which StipUlation end
Waiver may be filed by OWner in the epproprillte Prothonotary's Office.
9. Improvenents. Contractor hereby certifies that canpleted improvements
will confoiTiito plans and specificetions.
10. Work 13y_ Owner. In the event Owner desires, or may be required to
provide, lebor and materials not included in this Agreenent, OWner shell not
do 50 without the prior written approvel of the Contrector, and shall do so
only in such a manner as to not delay the materilll progress of the
Caltractor's \>\:In. C>.mer further agrees to not interfere with the materiel
pr-~...=s of the work. Should the Owner interfere with the construction or
fall to make scheduled payments when requested, contrector may consider such
f/lllure a breach of this A~..e.:;nent, and thllt breach will excuse Contractor
fran further perfoIlTlallce, and Contractor shllll receive all S\.I11S due hereunder,
including profits lost as a result thereof.
· (hereinafter the "Work"). This Agreement together with all Exhibits
attached hereto describes the Work.
.. Sss Addendum.
... See Addendum.
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, .1 ,11. Insurance/Risk Of ums. The Owner shall:
a) !>.Iring the proqreos of the work, maintain insurance on the
Building against loss or d.YMgu by fire. The (Xllicies shall cover all IoOrk
incorporated in the Building and shall be made payable to the parties hereto,
as their interests may appear. Owner does hereby agree to be responsible for
any theft, malicious mischief, and vandlllisn upon the Building and Premises
during the course of said construction.
b) IndB11l1ify and hold hannless Contractor fran and against any and
all c!"ims, demands, losses, and costs (inCluding reasooable attorney's fees)
arising out of the negligent acts or anissions of Owner, their agents,
,employees, and invites, and resulting in loss or damage to the Premises, or
for injury to, or death of, any person while in, u(Xln, or about the Premises.
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12. Work Carpleted/Cleanup. Nark to be perf01llled under this ^!I4e.:ment
shall cannence on or before .2anYI3[~ 15, 1993 T ~l-- and shall be
COTllleted on or before Julv 151 1993Cche "CiRirllcC Jkohtractor agrees to
carplete ~vsnents as pranptJ.Y as possible. Upon carpletion of work and
before acceptance and final payment, Contractor shall clean and remJVe frail
Runtljng, alley, street, and adjacent prl:)perty, all surplus and c1isc4Xtled
materials, rubbish, and temporary structures. COntractor sMll leave site in
a AM; an4 pAlleRs.le COndition.
"'''''''''' "broom clean"
13. EXcused Delays. The Contractor shall not be liable for any delay in
the prosecution or call1letion of the 1<<lrk caused by, but not limited to, the
act, neglect, or default of the Ownerl or as a result of changes or
alterations in the plans and specifications made by the OWnen or by d<<nage by
fire, earthquake, or other casualty for which the COntractor is not
responsible/ or by strike, walkouts, or any other acts of errployees or
BUpplien of labor or materials over which the Ccntrllctor has no coob:cl or
for which the Contrllctor is not responsible. In any such event, the tUne
herein fixed for the CCJ1llletion of the work shall be extended for a period
equivalent to the tJme lost by reason of any of the causes aforesaid,
pro\'ided, however, that nonperformance of the Agree"lElnt by the Contractor is
excused when such nonperformance is caused by an order of any court or other
pJbllc authority or by any govemnental control, regulations, restrictions, or
allocations of labor, supplies, and materials instituted by any state,
nunicipal, or govemnental agency for any reason wMtsoever. In the event
that the Contractor is excused, the OWners shall be Obligated to pay
Contrllctor for the reasonable value of work canpleted.
14. Warranty/Procedure.
a) Contractor warrants that, for a period of one (1) year fran the
date of the carplet.l.on, Contractor will remedy, replace, or repair defective
work or materials. The liability of the Contractor under this warranty shell
be limited to the replacerrent or correction of said defective materials or
workmanship, and no other claims and demands, wMtsoever, shall be made upon
or required to be allowed by the Contractor. EXcepted and excluded fran the
aforesaid warranty shall be chips, breaks, scratches, or mars in any materials
used in the Building that are not itemized in writing to Contractor prior to
l=OSSessioor "rellR pipeR' bri~k c-J.i.&<:""']QI".t1<)~: .....'oQl1.vlo ~Irv\ "'ukU4lllD8M;
~'a.rplI!!II gr gtl1ar 4aUciencillB E"llsw1tiRg fr(Jll-f.a .t:f1
~llCUng-~~~eE"etB, bRek,--er weedt-llhr-inl<<lg&-and-othel:'-
'" See Addendum.
.. TilE CONTRACT TIME BEING OF TilE ESSENCE OF TIIIS AGREEMENT.
... See Addendum.
.... See Addendum.
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88ttlaJniRt px;gbl~, i.Ad vari.tklRlil in tt.aJ.Red . iSSEi. aldeR as eabi.n~t3, doot:1,
or trim. tJo wa.rrMty sMll applr to dJlnagls S3US8d lJr U9J1ti:ter 9snditisAG,
FUlt9Ralile ".MteJ: ..plS". lw t8ttlemant. ,ita gSRditiGAQ. tesU!ee. er ethCt!'
HtSsste. It is hereby agreed and understood that this warranty applies only
to such items furnished under this A\j."",.ent. ~ OIliER WA/lRANl'IES, tIniER
EXPRESS OR IMPLIED. SIW.L APPLY ro nlIS AGRmlENI'. niE WARRANI'IES CCM'AINED
HEREIN ARE PERSCW.L ro 'IllE a-tNER AND ARE mr TRANS~LE OR ASSIGNABLE AND
'IllE a-tNER OOES. HEREBY, EXPRESSLY WAIVE ANY ornER WARRANTY.
b) In the event there are any defects in worlananship or materials
within the aforesaid one (1) year period. Owner shall pranptly give Contractor
. written notice of seme, and Contractor shall be afforded the opportunity to
remedy, replace, or repair the said defective work. Owner's failure to give
Contractor written notice as aforesaid, and CMner's failure to afforcl
Contractor the opportunity to replace, repair, or remedy the l14id defective
work or material, shall constitute a waiver by Owner of any claim by Owner for
said defective material or worlananship.
15, Occupancy, It is further agreecl that Owner shall not occupy, or
cause to be occupied, the Building IlIXl Premises which are subject to this
~=rent until final payment of all suns due under this ~.""".ent, inclu1ing
any extra charges, shall have been lMde: Occupancy by Owner in violation of
this provis:l.a1 shall be deened llCCeptance by Owner of COntractor's work IlIXl
shall bar withholding of funds for defects or denial of such acceptance by
Owner except as to punch list items previously noted and aa to escrows created
pursuant to Paragraph 12 hereinabove set forth.
16. Unusual Conditions. In the event that the CCrltractor encountere any
unusual cr,lllditions during the course of const%Uct1al. such as solid or machine
II:lCk, quicksand, sink holes, water. or springs, IIIld the unusual condition
requires and work which, in the reasOll/lble ~inion of the Contractor, is
ccnsidered to be unusUlll, such as, but not limited to, the removal of rock by
blasting or drilling or their special excavation or the installation of
special footings, subbase. foundation walls, or drain tiles, the Contractor
shall be cClTill!nsated additionally by Owner for such work and materials
provided at Contractor's usual rates ai1d charges.
17. Unused Materials. It is understood and agreecl that the Owner ahall
not be entitled to any material which has not been incorporated into the
c:alstruction, except where Owner has specifically paid for such materisl under
the special provisions of the Agreement relating to payment specifically of
costs of materials.
lB. Binding Effect. This AgteEll1l!nt shall be binding upon the parties
hererto and their respective heirs, executors, ministrators, successors, and
Il5signs .
19. Agreement Not Assignable, This Agteernent shall not be assigned by
Owner .
20. Notices. Any notice required hereunder shall he either hand
delivered or sent by United States mail. postage prepaid. to the parties at
the address set forth in ,the prearri:lle on the first: l':''lb of this Agreanent, and
shall be deened to have been given upon actual rltceipl "I; such notice.
· but not including amounts in agreed upon escrows, !ur punch list items.
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REFERENCE
84"
FRONT VIEW
REFERENCE
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SIDE VIEW
(R.H. SHOWN; ALSO AVAILABLE IN LH, AND NON.JEll
SPECIFICATIONS
YOOE1.
Tara
ra~rHQ
511b1Jlq, h,
(249 k!)llqm,)
TOIaIWl:
11261bl,
(512 kg,)
DlYENSIONS
60" 1'524 mm~L
60' 1524 mm W.
20' 508mm) ,
YOTOR/PUYP
314 H,P, (0,6 kw)
115VAC
~50RPW10AMP
60Hz,
Slnglo Phaso
'Mnirnun roc:ommondod walOf' hoalor IllO,
The Tars'" Whlrtpool Bath Is a 50" x 50" deep-
soaking two'porson whlrtpool balh combinIng elegance
whh economy. Designed for space-saving comarlnstal-
latlon, the Tara's ample room for two bathers creates an
appearance 01 luxury while halplng to ensure a most
comlortable bathing expertence, yet the Tars Is priced
lor our Builder Group.
For even more comtort and opUmal whl' II>oot perfor.
mance, the Tara features four strategically located
Jacuzzl~ WhIrlpool Bath Powerpronl whlrtpool Jet8,
which are dlreC1lonally adjustable, The whlrtpool sys.
tern, which Is powered by a 3/4 h,p. motor/pump, may be
tumed on and 011 from Inside Ihe balh by means of a
spoclal Maglo Touch'" swhch conveniently located on
the bath rtm. Two knobs allow Ihe bather to regulate the
Silent Air InduC1lon system, To ensure a whlrtpool per.
formance, Jacuzzi Whlrtpool Bath has mounted the
molor whh vlbrallon dampers,
Made 01 lustrous acryllc/FRP, the Tara can be
Inslalled In a raIsed plalform or recessed In the floor.
The sell-contalned whlrtpool bath comes equipped
whh molor and pump aS8embly,Includlng all necessary
plumbing and ,"lings whhln Ihe bath's pertmeter. Just
provide hot and cold water supply aCCOrding to local
codes and make drain and electrical connections.
The Tars Is available In a selection 01 Builder Group
colors. (See Jacuzzi Whlrtpool Bath color guide,) The
color-matched leis and suC1lon cover are faC10ry In.
stalled on the bath.
Optional Features
Trim KII Drain/OVerflow
11le Flange Kit Lamp Package
11mor Water/Rainbow Fill SpoW
FaucalKIl
Architectural Specifications
(Short Form)
Whirlpool Bath shall be the Taranl WhIrlpool Bath
as manulaC1ured by Jacuzzi Whirlpool Balh In colors
and sizes shown In drawings and schedules,
Do not use abrasive cleaner..
Do nol use 011 base bath additives.
gm~~~r8E ~t1ffR. WIll:Jrma
85U,S, Gal. 60 U,8, Gal. 233lbl.
(322 klall) (225 kill...) ('06 kg,)
~~m~
,'5V
'5AMP
60Hz
IlequInJI Dodicalod
Sopara'o Cln:ult
p
UlolnlloJlatlon Inlltuctlonl pro>idod with prodllCl
Product IpeclllColUonl "" lubJecl to dllnll4l without nolloo,
InstaUation Instru~LionS
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Imp.:lrtanl:' Read complole Ins1rucUons boloro boglnnlng Ins1allatlon.
Each whirlpool bath Is shipped completely equipped wllh motor/pUmp assembly. plumbing and IltIlngsl100essary
lor whirlpool operallon and arrives ready for Installation. An opllonal dralnloverllow kit Is available lor Installation on
the bath,
Remove Ihe bath lrom the carton. Do nol des1roy Iho shipping carton unlll o<<or satlafactory Inspoc\lon of
tho product. Do not 11<< the bolh by lhe plumbing at any tlmoj handlo from the sholl only.
Immedlatoly upon receipt, Inspect the shell belore In81alllng, Should Inspection reveal any damage or delect In
Iha finish, do notlns1olltho bBlh. Damaga or defect to Ihe finish claimed alter the bath Is Installed Is excluded lrom
the warranty. Jacuzzi Whirlpool Bath's responslblllly for shipping damage ceases upon dellveryotlhe product In good
order to Ihe carrier. ReIer any claims for damage to Ihe carrier, For dell nil Ions of warranty coverage and IImllatlons
raferto the published warranty Inlormatlon packed wllh the product, All bath unlls are factory tested for proper operation
and watertight connections prtor to shipping, However, prior to IInal Installallon, Ihe bath must be filled with water and
operated to check for leaks that may have rasulted from shipping damage or handling. Jacuzzi Whirlpool Bath Is nol
responsible for any defect that could have been discovered, repalrod, or avoided by lollowlng this Inspection and
lestlng procedure. Install the optional trim parts when all Installation has been completed,
Roughing-In Reference (Product Dimensions Shown)
Framing and Support
The optional dralnloverllow 01 the bath extends
below tho bollom 01 the bath, Note that this requires a
cutout on Ihe floor,
The base allached to the bottom olthe bath must be
supported along Its enllre bottom surlace. For proper
drainage and support of the bath, we recommond that a
bed 01 mortar or plaster be applied underneath the base
at the time of final selling In an amount sufflelent only to
Ievellho bath and not to raise II. Levalthe bath along the
top edge 01 tho rlm when the selling bed Is applied. Allow
p1aBler to 68t completely before applying welghllnslde
or on lop 01 tho bath, The above procedure Is essenllal
to ensuro proper support and drainage 01 the bath,
The rlmoflhe bath Is not designed to support weight,
II finish material Is 10 overlap or contact the bath. the
added weight must be lully sell-supporting,
The floor 81ructure beneath the Tara must be able to
support a total weight of approx, 11261bs, (bath, water,
and bathor) or 51 Ibs, per square foot.
~
Service Access
For partlaUy or fully sunken In81a1latlons. allow for
acce68 to service connections, It Is the In81aller's rospon.
slblllly to provide sufllelent service access, The recom-
mended minimum dimensions allowable lor service to tho
bath ero shown In the .Servlce Acce68.lIIu81ratlon shown
on tha lollowlng page,
An optional skirt Ills along the front and front two sides
of the bath for above-lloor In81allatlons and serves as an
acce68, should servlelng become noce68ary.
Provide clearance at each end of the bath and at tho
floor for remoyal of Ihe skirt IIl1nlshlng materials are
applied eround tho lront sides of the bath. The skirt Is
designed to accommodale the added height 01 the tie,
linoleum. and other floor coverings up 10 112. above lhe
sub-floor and will be flush wllh the floor when Installed,
Allow 0 space of at lea81 8. away from the bath for skirt
removal,
rVPICAL iNSTALLATIONS
(
I . I'
,.X4-
(NOT FOR SUPPORT)
FLUSH TO WALL
(
TU OR 'HtSJtHl
N"fERlAL WATtnPnDOf'
~ElmoclC
WOOTAn
'.X".
(NOT FOR SUPPORT)
SEMI-SUNKEN
OPTIONAL TILE FLANGE KIT
Service Access (continued)
For more detailed Instructions on skll1lnstsllatlon,
lollow directions provided wnh the optional skirt assem-
bly.
When the bath Is not skirted wnh the optional skirt,
provide adequate ventilation (mln, 30 sq,ln. opening) lor
cooling of the motor and sulllcent air supply lor lets,
Electrical Connections
A separate 115 V AC 15 amp clrcun, which roost be
protected by a Ground Faun Clrcun Interrupter (GFCI),
Is required, Because Jacuzzi Whirlpool Bath has de.
signed and Installed a aale, convenient Maglo TouchGll
whirlpool oIVolI swnch on the balh nsan, no remote
swnch or timer Is necessary. For 3/4 HP motors with
swnch and 3,prong cord, Install a 115 VAC, 15 amp
duplex outlet to the stuclwall undemealh the bathtub at
least 4' above Ihe sub-floor.
DANGER: RISK OF ELECTRIC SHOCK. COnnect
only 10 a circuit protected by a Ground Fault Circuit
Interrupler.
CAUTION: Operating the motor/pump without sulll.
clent water In the bath can cauaa leaking and perma-
nent damage to the pump. Belora power Is applied
to the Inslllllatlon, make sura the switch Is In Ihe OFF
poaltlon to avoid pump damage. If Installallon 01 an
optlonalllmsr Is desired, rslsrlo wlrlng Instructions
provided with the timer.
Opllonalllmerls lor 115 VAC only.
Drain Information
A dralIVoverllow assembly. purchased separately
lrom the bath, must be Installed on the bath, waler
tested. and connected to Ihe san nary system 01 tho
house. Alteropenlng Ihecarton.lnspecllordamage and
verify that the kn Is of (ho proper finish, If a Jacuzzi
Whlr1lool Bath dralrvoverllow Is being Installed, note
that lhe waste plug, strainer, overllow cover and cover
SCfOWS are packaged In a soparate package wnhln Ihe
kn to protOellhe trim IInlsh,
11\IJW.w.
SERVICE ACCESS
3PRONO
PLUG
OUPlEX
RECEPT.
SUB-FlOOR
Follow tho Install3110n Instructions provided wllh tho
dralnlovorllow kn.
NOTE: Waterllghtlnstallallonollhedraln Is tho Installor's
rosponslblllty, Any occuronce 01 drain leakage Is ex-
cluded Irom tho Jacuzzi Whirlpool Bath warranty covor-
age 01 this product. (Soo 'Drain Installallon Instructions'
provided wllh drain,)
Rill
, ,
(
,
Plumbing
. ,Pump" jels, and suction 1I1llngs tor the whirlpool
syslem are lactory plumbed In PVC schedule 40 piping,
All Jacuzzi Whirlpool Balh producls are laclory
tested for proper operation and walor tlghl connections
prior to shipping, II leaks are detected, notify your
Jacuzzi Whirlpool Balh Dealer: do nollnstalllhe balh,
Clean-up After Installation
In order to avoid dulling and scratching Ihe surface
01 the balh, mver use abrasive cleaners, A mild liquid
delergent and warm water will clean soiled surfaces,
Remove spilled plaster wllh a wood or plastic edge,
Metal tools will scralch the surface. Spols lell by plaster
or groul can be removed IIl1ghlly rubbed wllh delergenl
on a damp cloth or sponge,
(
Palnl, tar, or olher dilllcull slains can bo romoved
wllh paint thinner, turpentine, or Isopropyl alcohol (rub.
bing alcohol),
Minor scralchos which do not penotrate tho color
lInlsh can be removed by lightly sanding with 600.grft
weVdry sandpapor. You can rostore Ihe glossy lInlsh to
the acrylic surface of the bath wllh a special compound,
Megular's #1 0 Mirror Glaze, II that Is nol available, use
automotive rubbing compound followed by an applica-
tion of automotive pasle wax.
Major scratches and gouges which ponotrelo the
acrylic surface will require rellnlshlng, Ask your Jacuzzi
Whirlpool Bath dealer for speclallnslructlons.
Operation Summary
(For complatalnltrucUona,..a "OparlUng InllrucUonl, ")
Belore using the whirlpool bath, remove all con,
structlon residue and foreign materials,
Close the drain and fill the bath wllh enough water
to submerge the jels until water Is at least 2" above the
jets (see waler line Indicated on this page), Do not
operate Ihe whIrlpool system 01 any lime If the leIS
are not completely Immersed In water.
Your bath Is equipped with the Magic Touch.whlrl.
pool on/off sWllch, Activate the whirlpool system by
pushing down on the Magic Touch switch bullon, To
turn 011 the whirlpool system, push down on the bullon
again; To change the direction of the walerflow, swivel
the Jel nozzle to the desired angle,
Two knobs located on the bath serve as controls for
the air Induction system, The Inlenslty of the hydromas.
sage whirlpool action Is determined by Ihe amount of air
Inducted Into the water. As the amount 01 air Is In,
creased, Ihe amounl of whirlpool action will Increase,
For maximum air Induction, rolate the conlrol knobs lully
counter-clockwlse to the largest circles, For fewer air
FILL TO AT LEAST
2" ABOVE J~;~
q'.."..',-~.
I:..
, ;"
bubbles, decrease the amount of air Induction by rolat-
Ing the control knobs clockwise, When the knobs are
lurned to the smallest circles, only water Is being clrcu-
laled.
PRODUCT SPECIFICATIONS ARE SUBJECTTO CHANGE WITHOUT NOTICE,
USE INSTALLATION INSTRUCTIONS SUPPLIED WITH PRODUCT.
Jacuzzi IVhirlpoolllath has obtalnod opplicablo codo (Itandardl)liltingl gonorally a.allablo on a nalional basll'or produclI 01 thll Iypo, It II
1110 rOlponlibihly 01 tho inltallar/ownar 10 dotormlno Ipocilic Iacalcodo complion", prlor to Inltallation 01 tho product. Jocuzzl Whirlpool Bath
mnkos no reprosontation or warranty rogarding, and will not bo rosponsibkJ for any coda complianco.
JACUZZI WHIRLPOOL BATH
Jecuzzl Whirlpool Beth National Headquarters
P,O, Drawer J, Walnul Creek, CA 94596 (510) 930.7070
Customer Service: Call (SOO) 2S0.4002
JacuzzI Whirlpool Both RegIonal Olllces
Great Lakes Region: 2500 Wesl Higgins Rd" Sulle 1000, Hollman Eslales,lL 60195 (700) B02'0700
Central Region: 17950 Presion Rd"Sulle 700, Dallas, TX 75252 (214) 93t,7474
Soulheast Region: 2500 POlk Cenlral Olvd" Sulle 06, Decalur, GA 30035 (404) 901,0222
Northeast Region: lli1l0 Roule 23, Sulle 150, Wayne, NJ 07470 (201) 696.7704
:co:,',"" 'gi- JaclIlZI Whirlpoolllalh 0470000 C 2/93 @ Prlntod on ,oeycled papor.
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PENNSYLVANIA NATIONAL MUTUAL: IN THE COURT OF COMMON PLEAS
CASUALTY INSURANCE COMPANY. : CUMBERLAND COUNTY. PfNNSYLVANIA
subrogee of KEITH and KATHY CAL T A.
Plaintiffs : CIVIL ACTION . LAW
v, : NO, 96.1799 CIVIL TERM
GETTYS BUILDERS. INC. and
LENKER PLUMBING CONTRACTORS.
Derendants : JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
PLEASE enler my appearance on bchalr or the Dercndant, Lcnkcr Plumbing Contraclors. with
rcgard to the above.caplioncd lawsuit.
Respeclfully sub mill cd,
"
AlIomcys ror Dcrcndant. Lcnkcr Plumbing Contractors
Dalcd: May 9, 1996
71371
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PENNSYLVANIA NATIONAL MUTUAL
INSURANCE COMPANY, subrogee uf
KEITH AND KA HlY CAL TA,
Plaintills
· INTI IE COUIlT OF COMMON PLEAS
· ClJMBEllLAND COlJNTY,l'ENNSYLVANIA
.
.
v.
· CIVIl. ACTION .I.AW
· Nu.: %.171)1) Civil Term
.
.
GETTYS BUILDERS, INC. nnd
LENKER PLUMBING CONTllACTOIlS,
Defendants
· JlJll \' TllIAI. DEMANDED
ANSWEI{ WIT" Nt:W I\INrn:l{ OF Ut:n:NIMNT.
LENKER PLlIMIIING CONTRACTOItS TO I'LAINTWIIS' COMPI.AINT
AND NOW, comes Ihe ()efcndnnl, Lenker Plumhlng Cunlrnclnrs, by and Ihrough its
allomeys, Caldwell & Kearns, und tlIes Ihe Ihlluwinll Answer wilh New Maller to Plaintiffs'
Complaint and slates in support thereuflls Ihlluws.
1,4,5,6.
Admilled bllsed upon Inlhrmllllunllnd heileI'.
2.
Denied. It is helieved Ihllt (iellys Builders hilS II clII'rentllddress of Black Latch Lane,
Camp Hill, Cumberland County, I'ennsylvunill, 171111.
3, 6. Admitled.
8. Denied 115 stilted. It is IIdmillcd hllsed un inlhrmllliunund belief Ihut the jacuzzi
whirlpool bUlh leaked us ulleged. The renllllnlng ullegutluns in '18 arc denied in accordance with
Pa.Il.C.I'. 102lJ(e).
21. Denied as stated. Lenker contracted with Gellys to perform certain plumbing work
at the home, including the installation of the subject jacuzzi whirlpool tub.
22. The averments of ~22 are legal conclusions to which no response is necessary as
provided for under the Rules of Civil Procedure and are deemed to be denied.
23, 25, 26. The averments of ~23, ~25 and ~26 are legal conclusions to which no response is
necessary as provided for under the Rules of Civil Procedure and are deemed to be denied. By way
of further answer, any factual averments are denied in accordance with Pa.R.C.P. I029(e).
24. Denied as stated. A copy of the manufacturer installation instructions allached to the
Complaint speaks for itself and no response is required to the allegations contained in ~24.
27. Admilled.
WHEREFORE, Defendant, Lenker Plumbing Contractors, demands that the Complaint be
dismissed and judgment entered in its favor and against all parties without cost to it but together with
such costs, expenses and allomey's fees as authorized by law and which the Court deems necessary,
just and appropriate under the circumstances.
NEW MAlTER
28. On the date the tub was installed, there was no water or electric service available at
the residence to test the tub, by operating it.
29. It is Defendant's normal practice 10 tesl whirlpool tubs aileI' the installation and at
such time that water and electric service are available to the residence so that the tub can be operated.
3
WHEREFORE, Defendant, Lenker Plumbing Contractors, demands that the Complaint be
dismissed and judgment entered in its favor and against all parties without cost to it but together with
such costs, expenses and allomey's fees as authorized by law IInd which the Court deems necessary,
just and appropriate under the circllmstances.
By:
~~y submitted,
\CfLD,W ~JZu.L L/~ K III ~
\j ')' /
l. ,-
tCbOrah /J/; G vlIciDi, squire)
ttorney I.D. 61900
----
~J)rth Front Street
Harrisburg, PA 17110
(717) 232-7661
Allorney for Defendant
Lenker Plumbing Contractors
Dated:~
75113
4
-_.--,,"- ...~.-. -~,._.,-..... .......-
VERIFICATION
I verify that the averments made in the foregoing document are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to
unsworn falsification to authorities.
Dated: eb-lq(f
, ,
744534
CERTIFICATE OF SERVICE
I hereby certify lhall am this day serving a copy of the foregoing document upon the persons
in the manner indicated below, which service satislies the requirements of the Pennsylvania Rules of
Civil Procedure, by depositing a copy of same in the United States Mail, Harrisburg, Pennsylvania,
with lirst-class postage, prepaid, as follows:
Karen S. Feuchtenberger, Esquire
Goldberg, Katzman & Shipman, P.C.
320 Market Street
P.O. Box 1268
Harrisburg, P A 17108-1268
(Allorneys for Plaintiffs)
Gellys Builders, Inc.
Black Latch Lane
Camp 1-liII, PA 17011
By:
(eALDWELL & KEARNS
\ ) .--,\? )
\ {~\ - .
.\ _1.-/ ,
~nebor ah /J/; aVREjnl: -squire }
Attorney J.D. /167900 /
631 North Front Street -~
Harrisburg, I' A 17110
(717) 232-7661
Allorney for Defendant
Lenker Plumbing Contractors
~~~~d: 'S 17-\ q(,
OOLDBIIRO, 1tA'r11llUf , IBIPIIIUf, P.c.
Karen S. reuchtenberQer - Attorney
320 Market Street
Strawberry Square
P.O. Box 1268
Harri.burQ, PA 17108-1268
[717] 234-4161
Attorney for Plaintiff.
1.0. 158995
PENNSYLVANIA NATIONAL MUTUAL
CASUALTY INSURANCE COMPANY,
subrogee of KEITH AND KATHY
CALTA
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
.
.
No. 96-1799
.
.
GETTYS BUILDERS, INC. and
LENKER PLUMBING CONTRACTORS,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PLAINTIPFS' REPLY TO NEW MATTER OP DEPENDANT.
LENKER PLUMBING CONTRACTORS
AND NOW, come the Plaintiffs, Pennsylvania National Mutual
Insurance company, subrogee of Keith and Kathy Cal ta, by their
attorney, Goldberg, Katzman & Shipman, P.C. and respectfully
represent as follows:
28. Plaintiff is without knowledge or information sufficient
to form a belief as to the truth of the averments of paragraph 28
and, therefore, said averments are denied and strict proof thereof
is demanded at trial.
29. Plaintiff is without knowledge or information sufficient
to form a belief as to the truth of the averments of paragraph 29
and, therefore, said averments are denied and strict proof thereof
is demanded at trial.
...
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GOLDBERG, KATZMAN' SHIPMAN, P.C.
Karen S. Feuchtenberger - Attorney 1.0.
320 Market street
Strawberry Square
P.O. Box 1268
Harrisburg, PA 17108-1268
[7171 234-4161
Attorney for Pleintiffs
H58995
PENNSYLVANIA NATIONAL MUTUAL
CASUALTY INSURANCE COMPANY,
subrogee of KEITH AND KATHY
CALTA
plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 96-1799
GETTYS BUILDERS, INC. and
LENKER PLUMBING CONTRACTORS,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned matter as settled and
discontinued as to Defendant, Lenker plumbing Contractors only.
Respectfully submitted,
GOLDBERG, KATZMAN & SHIPMAN, P.C.
By:~-s9
Karen S. Feuchtenberger, Esq.
ID#: 58995
320 Market Street
P.O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161
Attorney for Plaintiffs
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