HomeMy WebLinkAbout96-02405
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tion date. It is denied that work commenced at the request of
Defendant.
7. Denied. It is denied tha t the labor was performed and
that the materials were furnished with the knowledge and consent
and at the request of the owner of the property.
6. Admitted.
9. Admitted in part and denied in part. It is admitted
that Plaintiff furnished all materials required to be furnished
to repair the roof. It is denied that the materials were fur-
nished in performance of an oral contract or that they were
furnished under any contract between the parties.
10, Denied. It is denied that all of the labor required to
be performed under the alleged contract has been performed in a
workmanlike manner and that all materials thereby required to be
furnished have been furnished.
11. After reasonable investigation, Defendant is without
knowledge or information sufficient to form a belief as to the
averment that a detailed statement of the kind and character of
the labor and materials furnished is included in Exhibit "B" of
Plaintiff's Complaint.
1 2. Admi tted .
13. After reasonable investigation, Defendant is without
knowledge or information sufficient to form a belief as to the
averment that the first item of work and material furnished was
on or about January 30, 1996 or that the last item of work and
f
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E, S, C., Inc,
Plaintiff
vs,
Calabrese & Sons, Inc.
Defendant
In the Court of Common Ple81
Cumberland County, Pennsylvania
Civil Action-law
Complaint
1. Plaintiff, E, S, C" Inc. Is e P6nnsylvanla Corporation with Its principal place
of business located at 12 Hamilton Road, Boiling Springs, Cumberland County,
Pennsylvania.
2, The Defendant and owner of the property which Is the subject of this action
Is Calabrese & Sons, Inc., a Pennsylvania Corporation with Its principal place of
business located et 406 Brandy Lane, Mechanlcsburg, Cumberland County,
Pennsylvania.
3, On or about January 29, 1996 Plaintiff Inspected the roof of the subject
premises. The Inspection ravealed approximately twenty (20) leaks.
4, On or about January 3D, 1996, Plaintiff supplied Defendant with a written
estimate to repair the roof of the subject premises. A copy of the estimate Is attached
hereto and marked Exhibit "A",
5. Plaintiff and Defendant never entered Into a written contract to perform the
work. Defendant orally directed Plaintiff to do the work in accordance with the written
estimate referred to in Paragraph 4 herein.
6. Plaintiff commenced work on or about January 31, 1996 at the request of
Defendant. The date on which Plaintiff completed the work for which this action Is
flIed was February 22, 1996.
7. The labor was performed and the materials were furnished with the
knowledge and consent, and at the request of the owner of the hereinafter described
property.
8. The Interest of the owner In the said real property, so far as Is known to the
Plaintiff, Is fee simple.
9. In performance of said oral contract, Plaintiff furnished all materials required
to be furnished by it under its agreement, 10 repair Defendant's roof,
10. All of the labor required to be performed by Plaintiff under the contract has
been performed in a workmanlike manner and all materials thereby required to be
furnished by claimant have been furnished.
E. S. C., Inc.
Contractor
VB.
OalabreBe & Sonll, Inc.
Owner
In the Court of Common Pleas
Cumberland County, Pennsylvania
Civil Action-law ~)t - d'l/t'l;) j6t i../.J.
Mechanics Wen Claim
,
,.i
1. Claimant, E. 5, C" Inc. Is a Pennsylvania Corporation with Its prlnclpar:plac;:~
of business located at 12 Hamilton Road, Boiling Springs, Cumberland County, .
Pennsylvania.
2. The owner of the property subject to the lien is Calabrese & Sons, Inc" a
Pennsylvania Corporation with Its prlnclpal place of business located at 406 Brandy
Lane, Mechanicsburg, Cumberland County, Pennsylvania,
3. The date on which claimant completed the work for which this claim Is made
was February 22, 1996,
4, Claimant flies this claim under an oral contract and written estimate given to
owner's representative, Mike Calabrese on or about January 31, 1996,
5. The labor was performed and the materials were furnished with the
knowledge and consent, and at the request of the owner of the hereinafter described
property.
6. The Interest of the owner In the said real property, so far as Is known to the
claimant, Is fee simple.
7. In performance of said contract, claimant furnished all materials required to
be furnished by it under Its agreement, to repair owner's roof.
8, All of the labor required to be performed by claimant under the contract has
been performed and all materials thereby required to be furnished by claimant have
been furnished.
9, A detailed statement of the kind and character of the labor and materials
furnished Is attached hereto, incorporated by reference and marked Exhibit "A",
10. The amount claimed to be due is $19,897.00,
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