HomeMy WebLinkAbout02-4675THE TOWNSHIP OF EAST PENNSBORO
MARY ARNOLD
Registered Owner
IN THE
mtr!
OF CUMBERLAND COUNTY, PENNA.
No..0.,,~..:...q.~..7. ,~...~Q.. TERM ...........
EPT LIEN DOCKET
THE TOWNSHIP OF EAST PENNSBORO hereby files its claim against ................................
MARY ARNOLD registered owners, and all that certain lot or piece
of ground situate in East Pennsboro Township, Cumberland County, Pennsylvania, on the
MAGARO ROAD
............................................................................... side of .................................................................................
o~ 40Magarx~ Rd, Enola, PA 17025 and having thereon
and being known and numbered .............................................................................
erected a dwel]ing house ................................................................ for:
1. Sewer rental for the period of 1-1-2000 to 9-30-2002
both dates being inclusive, for a total amount of $ ........ .1.2.0.,2..:.9...3. .........................
2. Sewer tap-on fee and sewer installation charges as follows:
The said sewer installation was completed on the ................................ day of
...................................................... and duly assessed and taxed and charged as
per bill and statement as follows:
The said services were provided, or the installation made, by the Township of East Pennsboro
and tax levied therefor in strict accordance with Ordinances Nos. 54-58 and 55-58, as amended,
which Ordinances were duly ordained by the said Township on December 3. 1958.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ROBERT L. GILL
.............................................................................. being duly sworn according to law, deposes and
says that he is ................... ~..A..G..E..R. ................................................ of the Township of East Penneboro,
and that the facts set forth in the foregoing claim are tru~ and correct to the best of his know-
ledge, information and belief. [~L~/f~gi]~]l~..]~'
ROBERT L. GILL
Sworn and subscribed to before me this
4th day of SEPTEMBER 2002
...................... i ............. S AL I
HELEN M. GRIFRTH, Nota~] PuNIc
E~d Pe,r, slx~o Twp. Cung:~'land Co.
SGS CONSTRUCTION, INC.,
.Plaintiff
V.
KUX GRAPHIC SYSTEMS
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 02-4765
:
REPLY TO NEW MATTER AND
ANSWER TO COUNTERCLAIM
AND NOW comes the Plaintiff, SGS Construction, Inc., which, by and through
its attorneys, Thomas A. Beckley, Esquire, Thomas S. Beckley, Esquire, and Beckley &
Madden, of Counsel, files this Reply to New Matter and Answer to Counterclaim.
I. REPLY TO NEW MATTER
20. Plaintiff hereby incorporates paragraphs 1 tl~rough 19 of its Complaint as
though set forth here at length.
21. The allegations contained in paragraph 21 of Defendant's New Matter
constitute a conclusion of law to which no response is necessary.
22. The allegations contained in paragraph 22 of Defendant's New Matter
constitute a conclusion of law to which no response is necessary.
WHEREFORE, Plaintiff, SGS Construction, Inc., respectfully requests the Court
to enter judgment in its favor and against the Defendant, Kux Graphic Systems, in the
principal amount of $12,790.00, plus interest, costs, penalties and attorneys' fees as
allowed by law.
H. ANSWER TO COUNTERCLAIM
23. Plaintiff hereby incorporates paragraphs 1 tln:ough 19 of its Complaint and
paragraphs 20 through 22 of its Reply to New Matter as though set forth here at length.
24. Denied as stated. It is denied that Plaintiff failed to complete its work in a
good and workmanlike manner. To the contrary, Plaintiff ,completed its work as required
by the parties' contract. It is further denied that Plaintiff failed to complete its work in a
timely fashion. To the extent there were delays on the Project, those delays were caused
by Defendant's failure to deliver the proper materials to the Project in a timely manner.
25. After reasonable investigation, Plaintiff is without knowledge or information
sufficient to form a belief as to the averments contained in paragraph 25 of Defendant's
Counterclaim. By way of further answer, Defendant has failed to list with any degree of
specificity its alleged loss of business and profits.
WHEREFORE, Plaintiff, SGS Construction, Inc., respectfully requests the Court
to dismiss Defendant's Counterclaim, and enter judgment in its favor and against the
Defendant, Kux Graphic Systems, in the principal amount of $12,790.00, plus interest,
costs, penalties and attorneys' fees as allowed by law.
DATED: December 5, 2002
Of Counsel
BECKLEY & MADDEN
212 North Third Street
Post Office Box 11998
Harrisburg, Pennsylvania 17108-1998
(717) 233-7691
Respectfully submitted
Thomas A. Beckley, E~qmre
~omas S. Beckley, Esquire
A~omeys for Pla~tiff
SGS Cons~ction, hc.
I, Gary Kirklin, hereby verify that I am an adult individual; that I am authorized to
make this statement on behalf of SGS Construction, Inc.; that I have read the foregoing
document; and that the facts set forth in the foregoing docttment are tree to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. § 4904 relating: to unswom falsification to
authorities.
SGS Construction, Inc.
CERTIFICATE OF SERVICE
I, Thomas S. Beckley, Esquire, hereby certify that on this day a tree and correct
copy of the foregoing document was served upon the persons and in the manner indicated
below:
SERVICE BY FIRST CLASS MAll,
Charles Rector, Esquire
Law Offices of Charles Rector, Esquire, PC
1104 Femwood Avenue, Suite 203
Camp Hill, Pennsylvania 17011
DATED: December 5, 2002
Thomas S. Beckley