HomeMy WebLinkAbout96-03144
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'HARTMAN AND ASSOCIATES, INC.
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTYf PENNSYLVANIA
NO . 1t.-. 11 <f 'I G...J -r:;......"
JOHN BYERLY,
Defendant
CIVIL ACTION - LAW
COMPLAINT
AND IIOW, comes Hartman and Associates, Inc., by and through
its attorneys Saidisf Guido, Shuff & Maslandf !lnd respectfully
avers the following:
1.
Plaintiff f
Hartman and Associates,
Inc. ,
is an
engineering firm and corporation, organized and existing under the
laws of the Commonwealth of Pennsylvania with its principal place
of business located at 2101 Orchard Road, Camp Hill, Cumberland
CountYf Pennsylvania.
2. Defendant, John ByerlYf is an adult individual, residing
at Rose Hill Farm, 542 Lextington Avenue
The Vineyardf
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. On or about May 9, 1994, Plaintiff entered into an
agreement with Defendant whereby Plaintiff agreed to provide
engineering services to Defendant and Defendant agreed to pay
Plaintiff its customary and usual fees for the services performed
and all costs incurred on its behalf in connection with services
rendered for Rose Hill Farm.
4. Monthly invoices were mailed to Defendant setting forth
the services which had been rendered by Plaintiff on Defendant's
behalf, the amount being charged for the services, and any
outstanding balance due on prior invoices.
5. Since May 9, 1994f Plaintiff has sent numerous invoices
3
,
to Defendant in the amount of Forty-Six Thousand Three Hundred
Fifteen and 38/100 Dollars ($46,315.38); a true and correct copy of
an invoice sent to Defendant is attached to and incorporated into
this complaint as Exhibit "A".
6. Despit6 repeated demands by the Plaintiff for payment of
the balance due of Forty-Six Thousand Three Hundred Fifteen and
38/100 Dollars ($46 f 315.38), Defendant has refused to pay and
continues to fail to pay the balance due.
7. Plaintiff has performed its services for Defendant fully
and satisfactorily, and conformed to, and complied with, all of the
terms and conditions required of it under the agreement between it
and Defendant.
8. Despite Defendant's obligation to pay Plaintiff for the
services performed and costs incurred on its behalf, and despite
Plaintiff's demands on Defendant for ouch paymentf Defendant has
wrongfully failed and refused to pay to Plaintiff the sums due it.
WHEREFORE, Plaintifff Hartman and Associates, Inc., demands
judgment against Defendant in the amount of Forty-Six Thousand
Three Hundred Fifteen and 38/100 Dollars ($46,315.38), together
with costs and any other relief this Court deems appropriate.
Respectfully submitted,
SAIDIS, GUIDO, SHUFF & MASLAND
Dated: mao d/, 19')~
By:
Joh J. ily, Esquire
supreme cotirt ID #53147
2109 Market Street
Camp Hill, PA 17011
(717) 761-1881
Attorney for
Associates, Inc.
Hartman
end
4
.
H.rtman , Assooiat.., Inc.
2101 orcbard Road
Camp Hill, iA 17011
(717) 737-3495
FAX. (717) 737-2003
.
ROS!: HILL FARM
MR. JOliN J3YERLY
542 LEXINGTON AVENUE - THE VINEYARD
MECHANICSBURG. PA 17055
0",ted: 11/02/%
BTATEM!NT rOR CLIENTI '73
',.,.,................,..,...",..,......,....."....,.,...,.........................,...............,."..,,,'..
"'uro OUr On. C1iye
Job No. '"voter' ",II~ Old 'roJ.tt Wlmt
Inltlll
Invoice _l.I'1t
PI."..."" OutUOrKl:,
!toc.fvl'd ("tor..t "1.1r'~~
9l490. 9'49072 05109/94 \42 . JOHN IIERLI ' IKlrCH PLAN . 17,902.50 11,642,00 11,561,01 117,021.S'
9l49O, U49074 07l0ll/94 4e2 . JOHN IIERLl . SKlrCH PLAN . 19,477.00 10,00 1909,79 110,'86,7-
93490. U49071 01/00/94 451 . JOHN IIERll . .KlrcH PLAN . 10,5zr.50 10,00 11,010,64 111,538.11
93490, 9:149076 09/07/94 421 . JOHN IIERLI . .KlrcH PLAN . 12,740.00 10.00 1263.04 I3,OOl.o'
9l49O, 9349086 07/15/95 110 . JOHN IIEAlI ' SKlrCH PLAN . 1:"'00.00 10.00 1105.90 SJ,56~.~I';
,..,..,.......,......."...,................",.,.."....,...............................,...",...,....,.".....
SUf<HAAY 10rAlS
144,027,00
11,642,00 13,9JO,3. 146,5!5.,:
..,.."..,.....,..,.,........"....,.....,..,..........................,...,..,........,..,...,......,...,.,'..,..
Th, j~volc.. tflted .bov. .'. past due. PI'I'. ~ht,~ your recorda
end (1 tn .ar'~nt, remit thf. b.lanct. If vour chICk t. in th.
m~fl, pt..5. Icc~t our thank..
Eih,bA 'I. f\\'