Loading...
HomeMy WebLinkAbout96-05573 ~ " . ~ . . ~ I ~ I i I 1 . '" ,~ I t: -) 1 ,~ 1 ~ , I ~ I 't \ \ ).... \ ~ ~ '~ " ) - . ... ~ .... \J ~ ~"" . ~, G': '" c:, \ \' s; G....~ ~~. -.::::::;- ~ p ~ \\--<.. - ,~ ~ ~ l-, "" 'I'- '0--- ~ ---.... "--.. L <,;,-. ;::" j: '" ~ 3' CJ0 ~ BAYARD D, JAMES, TRUSTEE OF THE JAMES FAMILY TRUST IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTlH' CIVIL ACTION NO, 96,5573 v, PATRICKSMITll,lNDIVIDUALLY, THE HOMESTEAD GROUP,INC. RICHARD W. WALKER,INDIVIDUALLY AND JACK GAUGllEN REALTOR. DEFENDANTS JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiffs Bayard D, James, is an adult individual residing at 554 St. Johns Drive, Camp Hill, Pennsylvania, 17011, 2, The Defendant, Patrick Smith, is an individual whose licensed to sell real e&tate and at all times concerning this complaint was licensed with The Homestead Group, Inc" 4075 Market Street, Camp Hill, Pennsylvania, 17011. 3, The Defendant, The Homestead Group, Inc., is a licensed real estate brokerage firm with its principal place of business located at 4075 Market Street, Camp Hill, Pennsylvania, 17011. 4, The Defendant, Richard W, Walker, is an individual whose licensed to sell real estate and at all times concerning this complaint was licensed with Jack Gaughen Realtor, 3800 Market Street, Camp Hill, Pennsylvania, 17011. 5. The Defendant, Jack Gaughen Realtor, is a licensed real estate brokerage firm with its principal place of business located at 3800 Market Street, Camp Hill, Pennsylvania, 1701 I. 6, On or about September 13, 1995, the Plaintiffs entered into an Agreement of Sale to purchase the property at 554 St. Johns Drive, Camp Hill, Pennsylvania, 17011 from Donald and Grace Juul for a purchase price of$135,000,OO, A copy of the Agreement of Sale and Purchase of Real Estate is attached hereto and made a part hereof as "Exhibit A", 7, Under the Agreement of Sale the seller warranted all plumbing, heating, air conditioning, mechanical and electrical systems and equipment and appliances would be in proper working order at time of settlement. 8, The settlement for sale of the property located at 554 St. Johns Drive, Camp Hill, Pennsylvania, 17011 was scheduled for Monday, November 28,1995. WHEREFORE, the Plaintiffs demand damages from the Defendants in an amount in excess of$20,OOO,OO. Respectfully submitted, Date: ~ boh7 / I ~,~ William T. Smith Attorney for Plaintiff 3747 Derry Street Harrisburg, P A 17 111 Supreme Court I.D, 06887 (717) 561-2677 >- 0" c:-; (.; " ;.. LIJ~- 0' e.- " u. ~ , " C>'. \ . C':' l~ I . [i.: ~ ; ~ i.. . lL r- U c.... U '. '. CERTIFICA TE OF SERVICE AND NOW. this 24th day of July, 1997, the undersigned does hereby certify that she did serve a copy of the foregoing appearance upon the other parties of record by causing same to be deposited in the United States Mail, first class postage propaid, at Lemoyne, Pennsylvania, addressed as follows: William T. Smith, Esquire 3747 Derry Street Harrisburg, PA 17111 Patrick Smith The Homestead Group, Inc. 4075 Market Street Camp Hill, PA 17011 The Homestead Group, Inc. 4075 Market Street Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER ,,'- -oh!! U ,1't.2..~'IU r Sharon L. RudV ( fr. -' .. c (.. ;}; ._;'" IlJQ "'..... :) .'f' u/.. " Ii" -- -.' 0 c5~:l ,'- . , c,~.~ ' ~, () ~/ U:.\-). C'" I ..' , , ;.i /: u: , _.1 " J ~) ~ I " , -:J l~ r- :':':J 0 cr U / Johnson, Duffie, Stewart & Weidner By: C. Roy Weidner, Jr, J.D. No. 19530 301 Market Street p, 0, Box 109 Lemoyne, Pennsylvania 17043,0109 (717) 761.4540 BAYARD D, JAMES, TRUSTEE OF THE JAMES FAMILY TRUST, Plaintiff v, PATRICK SMITH, Individually, THE HOMESTEAD GROUP, INC" RICHARD W, WALKER, Individually, and JACK GAUGHEN REALTOR, Defendants Attorneys for Defendants Richard W. Walker, Individually and Jack Gaughen Realtor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 96-5573 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER TO PLAINTIFF'S COMPLAINT AND NOW, this t6f:. day of August, 1997, come Defendants Richard W, Walker and Jack Gaughen Realtor, through their undersigned attorneys, and answer Plaintiff's complaint as follows: 1,3. Admitted. 4. Denied. On the contrary, to the extent that Plaintiff is attempting to identify the individual involved in the transaction on behalf of Jack Gaughen Realtor, it was Richard G, Webb, who was the sales associate affiliated with Jack Gaughen Realtor that entered into the exclusive right to sell agreement for sale of real estate with the owners, 5-8, Admitted. 9, Denied. That Patrick Smith appeared as averred where Plaintiffs were living and enticed and coerced Mr, James into signing a document representing that they had made a final inspection of the property where he had not is denied, in that, after a reasonable investigation, answering Defendants are without knowledge or information sufficient to form a belief as to the truth of said averment, To the extent that Plaintiff avers that Mr, Smith did so at the request of Mr, Walker [sic] knowing that Plaintiff had not made a final inspection and that it would have revealed the repairs needed as averred in paragraph 10, said averment is specifically denied, 10. Denied, After a reasonable investigation, answering Defendants are without knowledge or information sufficient to form a belief as to the truth of said averment, 11, Denied. Any averment of deception and fraud upon the Plaintiffs is specifically denied, At aI/limes, answering Defendants acted reasonably, ethically and professionally under the circumstances, Insofar as the expenditures averred, after a reasonable investigation, answering Defendants are without knowledge or information sufficient to form a belief as to the truth of said averment, 13, Denied, Paragraph 11 hereof is incorporated by reference herein, WHEREFORE, Defendants Richard W, Walker [sic] and Jack Gaughen Realtor demand that Plaintiff's complaint against them be dismissed. JOHNSON, DUFFIE, STEWART & WEIDNER " ct::~ :65680 VERIFICA TION I, Karen R, Stone, Executive Vice President, verify that the statements made in the foregoing document, which are w!thin the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believes them to be true, And further, this verification is signed on the recommendation of my attorneys, who advise me that the statements and language in this document are required legally to raise issues for resolution at trial by the Court. or by continuing investigation and preparation for trial. I understand that some of these statements may prove inappropriate after investigation and trial preparation are complete, and' leave determination of these matters to my attorneys on their advice, Date: i/vc;191 I understand that all statements herein are made subject to the penalties of 18 Pap C,S,A. ~ 4904, relating to unsworn falsification to authorities, 'I /'7' ' "-it I>' /11. . )1.., J y-jl(n(~ ~ Kar,en R, Stone, Executive Vice President CERTIFICA TE OF SERVICE AND NOW, this /~ay of August, 1997, the undersigned does hereby certify that she did serve a copy of the foregoing answer upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania. addressed as follows: William T. Smith, Esquire 3747 Derry Street Harrisburg, PA 17111 Patrick Smith The Homestead Group, Inc, 4075 Market Street Camp Hill, PA 17011 The Homestead Group, Inc, 4075 Market Street Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER BY:~~ ~ ichelle Hagy :-"'4 r" . .. ~.; ('.~' , '. (""~ " ( ~~ I .. ,-. (1";' , L (::1 1 ~_ L_ t c..~ , u..:: " ._, , C' tJ' (5 N .. ~~8~ ffi 1=;;: -J~(f.l,....~ !ii)",I:'::t'" olSai~Q.~ a:ti<~E ~o::!:i:!::. ~~-.. a:<a::!: 5 . I<.\\KILO'AOGGtLO..,Q"'L"'"lfGln OtlI'fllOlO:JJ.'1ddnsWOJ,n"n'T1'f' ,. BAYARD D, JAMES, TRUSTEE OF THE JAMES F AMIL Y TRUST. Plaintiff v, PATRICK SMITH, Individually, THE HOMESTEAD GROUP, INC" RICHARD W. WALKER, Individually, and JACK GAUGHEN REALTOR, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No,: 96,5573 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: PLEASE enter my appearance on behalf of Defendants, Patrick Smith and The Homestead Group, Inc, with regard to the above-captioned matter. Dated: 4,~ t?J!'i5 "1 C:\OFFICElWPWIN\DA VElENTRY A"PJlCiI By: REAG'R~Z Davii, eager, sqUlre--- Attorney I.D, No, 20868 2331 Market Street Camp Hill, PA 170 II Attorney for Defendants Patrick Smith and The Homestead Group, Inc, ~ CERTIFICATE OF SERVIn; AND NOW, this bay of August, 1997, the undersigned does hereby certify that he did serve a copy of the foregoing Answer upon the other partics of record by causing same to be dellosited in the United States Mail, first class postage prcpaid, at Camp Hill, Pennsylvania, addressed as follows: William T, Smith, Esquire 3747 Derry Street Harrisburg. P A 17111 C, Roy Weidner, Jr, JOHNSON, DUFFIE, STEWART & WEIDNER 30 I Market Street P,O, Box 109 Lemoyne, PA 17043,0109 By: C:\OFFICE\WPWIN\D^ VElANSCOMI'I..IIGI 5 aVI ,eager, squire Attorney I.D, No, 20868 2331 Markct Street Camp Hill, PA 17011 Attorney for Defendants Patrick Smith and The Homestead Group, Inc, .1 v, . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA : No,: 96,5573 BAY ARD D, JAMES, TRUSTEE OF THE JAMES FAMILY TRUST, Plaintiff PATRICK SMITH, Individually, THE HOMESTEAD GROUP, INC., RICHARD W, WALKER, Individually, and JACK GAUGHEN REALTOR, Defendants . CIVIL ACTION - LAW . JURY TRIAL DEMANDED DEFENDANTS. PATRICK SMITH find TIlE HOMESTEAD GROUP, INC.'s ANSWER TO PLAINTIFF'S COMPLAINT AND NOW, this ~\tn day of August, 1997, come Defendants Patrick Smith and The Homestead Group, Inc,. through their undersigned attorneys and answer Plaintiff's Complaint as follows: I, Admitted, 2, Admitted, 3, Admitted, 4, Denied, It is believed that Plaintilr intends to identity the individual as Richard G, Webb who is a sales associate affiliated with Jack Gaughen Realtor, 5, Admitted, 6, Admitted, 7, Admitted, 8, Admitted, 9, Admitted in part and denied in part, While it is admitted that Defendant, Patrick Smith, met with Plaintiff on Friday, November 24. 1995, it is specifically denied that the meeting was for the purpose of enticing or coercing Plaintiff into signing any document. In further answer thereto, it is averred that Plaintiff advised Defendant, Patrick Smith, that he had been to the property on many occasions and did not wish to make an additional inspection, 10, Denied, After a reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of said averment. 11. Denied, Defendants specifically deny any deception or fraud on the part of Plaintiff, In further answer thereto, with regard to the listed expenditures, Defendants are without knowledge or information sufficient as to form a belief as to the truth of said averment and proof of same is demanded at trial. ~ ~......;_. . .. ~,...... - 13, Denied, It is specifically denied that Defendants acted in an unethical or unprofessional manner. WHEREFORE, Defendants, Patrick Smith and The Homestead Group, Inc, demand that Plaintiffs Complaint against them be dismissed, By: Dated: A.,"H'" f ./5<17 a VI ,eager, Attorney I.D, No, 2 2331 Market Street Camp Hill, PA 17011 Attorney for Defendants Patrick Smith and The Homestead Group, Inc, C:IOFFICEIWPWINlDA VElANSCOMPLJIGI 2 VERIFICATION I, Michael J, Greene, President of The Homestead Group, Inc" verify that the statements made in the foregoing document, which are within the personal knowledge of the undersigned. are true and correct, and as to the facts based on the informatIOn of others, the undersigned, after diligent inquiry, believes them to be true, And further, this Verification is sij,lned on the recommendation of my attorneys, who advise me that the statements and languaj,le in thiS document are required legally to raise issues for resolution at trial by the Court, or by continuing investigation and preparation for trial, I understand that some of these statements may prove inappropriate after investigation and trial preparation are complete, and I leave determination of these matters to my attorneys on their advice, I understand that all statements herein are made subject to the penalties of 18 Pa, C.S,A. 94904, relating to unsworn falsification to authorities, By: Dated: 8/a/91 , C:\OFFICElWPWlN\D^ VElANSCOMI'LJlOl 3 VERIFICATION I, Patrick Smith, verifv that the statcments made in the foregoing document, which are within Ihe personal knowledge of ihe undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believes them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the statements and language in this document are required legally to raise issues for resolution at trial by the Court, or by continuing investigation and preparation for trial. I understand that some of these statements may prove inappropriate after investigation and trial preparation are complete, and I leave determination of these matters to my attorneys on their advice, I understand that all statements herein are made subject to the ~enalties of 18 Pa, C,S,A. 94904, relating to unsworn falsification to authorities, Dated: A..; :I /[$., ~~ C:IOFFICEIWPWIN\DA VElANSCOMl'l..IlOl 4 , BA YARD D. JAMES, TRUSTEE OF TilE JAMES FAMILY TRUST IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF v, CIVIL ACTION NO, 96-5573 PATRICK SMITH, INDIVIDUALLY, TilE HOMESTEAD GROUP, INC, RICHARD G. WEBB, INDIVIDUALLY AND JACK GAUGHEN REALTOR. DEFENDANTS JURY TRIAL DEMANDED AMENDED COMPLAINT I, The Plaintiffs Bayard D, James, is an adult individual residing at 554 St. Johns Drive, Camp Hill, Pennsylvania, 17011. 2, The Defendant, Patrick Smith, is an individual whose licensed to sell real estate and at all times concerning this complaint was licensed with The Homestead Group, Inc" 4075 Market Street, Camp Hill, Pennsylvania, 17011. 3, The Defendant, The Homestead Group, Inc" is a licensed real estate brokerage firm with its principal place of business located at 4075 Market Street, Camp Hill, Pennsylvania, 1701 I. 4, The Defendant, Richard G, Webb, is an individual whose licensed to sell real estate and at all times concerning this complaint was licensed with Jack Gaughen Realtor, 3800 Market Street, Camp Hill, Pennsylvania, 17011. 5, The Defendant, Jack Gaughen Realtor, is a licensed real estate brokerage firm with its principal place of business located at 3800 Market Street, Camp Hill, Pennsylvania, 1701 I. 6, On or about September 13, 1995, the Plaintiffs entered into an Agreement of Sale to purchase the property at 554 St. Johns Drive, Camp Hill, Pennsylvania, 1701 I from Donald and Grace Juul for a purchase price of$135,000,OO, A copy of the Agreement of Sale and Purchase of Real Estate is attached hereto and made a part hereof as "Exhibit A", 7, Under the Agreement of Sale the seller warranted all plumbing, heating, air conditioning, mechanical and electrical systems and equipment and appliances would be in proper working order at time of settlement. 8, The settlement for sale ofthc property locatcd at 554 St. Johns Drive, Camp Hill, Pennsylvania, 1701 I was scheduled for Monday, Novembcr 28,1995, WHEREFORE, the Plaintiffs demand damages from the Defendants in an amount in excess of $20,000,00, Respectfully submitted, Date: 7 h If 7 / I dJl~0 ~~, William T. Smith Attorney for Plaintiff 3747 Derry Street Harrisburg, PA 171 I I Supreme Court I.D, 06887 (717) 561-2677 AFFIDA VIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for the above County, Bayard D, James, Trustee of the James Family Trust, who deposes and says that the facts set forth in the within AMENDED COMPLAINT are true and correct to the best of his knowledge, information and belief Subscribed and sworn to before me this?'~ day of t2_u',t.t...4 ,:/ , 1997, ./ /;J 7 4.J1. tf 4d. ,- NOTARY PUBLIC~ My commission expires: /.;l -....-."... NQT...R1Al 5E"\ PAULA A. WYO!tA, t~ory p",Oltc HonhburQ. Dauphin County, PA lit( Com.."'. E>qll... Do<- ~. :zooo CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Amended Complaint was served concurrently upon the following person(s) by depositing the same in the United States mail, first class, postage prepaid, in Harrisburg, Pennsylvania, on this date: Patrick Smith C/O The Homestead Group, Inc 4075 Market Street Camp Hill, PA 17011 Richard G, Webb C/O Jack Gaughen Realtor 3800 Market Street Camp Hill, PA 17011 THE HOMESTEAD GROUP, INC 4075 Market Street Camp Hill, PA 1701 I JACK GAUGHEN REALTOR 3800 Market Street Camp Hill, PA 1701 I Date: ?)!fl I '-~ ~9 -e William T, Smith Attorney for Plaintiff LD, #06887 3747 Derry Street Harrisburg, PA 1711 I '.. '" , .. f-: ; c: PI " L.~ 1.1~ , " " c..) , c- , , , i_i . ~ ,j '- , ..c:. " r- :~j G U' ~-) CERTIFICA TE OF SERVICE AND NOW, this 2"" day of September, 1997, the undersigned does hereby certify that she did serve a copy of the foregoing answer upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: William T, Smith, Esquire 3747 Derry Street Harrisburg, PA 17111 David W, Reager, Esquire Reager & Adler, P.C, 2331 Market Street Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER By: ~htuulY; ~ Sharon L. Ruci0 >. l{l [."\" c: ;<: '[~:.-:" ('~ [i: \..:.. L'--' O~~- ........, n .. iTi' I ~t n " ,.... v; lI. e- ,) U cr ,) >. <'J - ~.~ c:.; r+.: I, lU" ("J- .'_r \I~ ,.... ()' f'.- '.}l Ll' L'J' I [, " ( t.. , , (/; " ,- I () (,J' ) N :t. ~ Iii! ~~~~~ 51g!~~~ "'", ~ 5 J ~ wO::E...J~ e"o_:i:r::. ~S!:l~ 5 - , ...."'Klll.HIIIlll.'.nU..JI.r51L. ()lojI'NOJI 03~'W4ntl 'M)1l11,JI'" , BAYARD D, JAMES, TRUSTEE OF THE JAMES F AMIL Y TRUST, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No,: 96-5573 : CIVIL ACTION, LAW : JURY TRIAL DEMANDED v, PATRICK SMITH, Individually, THE HOMESTEAD GROUP, INC" RICHARD W, WALKER, Individually, and JACK GAUGHEN REALTOR, Defendants DEFENDANTS, PATRICK SMITH and THE HOMESTEAD GROUP. INC.'s ANSWER TO PLAINTIFF'S AMF:NOEO COMPLAINT AND NOW, this ~lday of September, 1997, come Defendants Patrick Smith and The Homestead Group, Inc" through their undersigned attorneys and answer Plaintiff's Complaint as follows: I. Admitted," 2, Admitted, 3, Admitted, 4, Admitted, 5, Admitted, 6, Admitted, 7, Admitted, 8, Admitted, 9, Admitted in part and denied in part, While it is admitted that Defendant, Patrick Smith, met with Plaintiff on Friday, November 24, 1995, it is specifically denied that the meeting was for the purpose of enticing or coercing Plaintiff into signing any document, In further answer thereto, it is averred that Plaintiff advised Defendant, Patrick Smith, that he had been to the property on many occasions and did not wish to make an additional inspection, 10, Denied, After a reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of said averment, 11. Denied, Defendants specifically deny any deception or fraud on the part of Plaintiff, In further answer thereto, with regard to the listed expenditures, Defendants are without knowledge or information sufficient as to form a belief as to the truth of said averment and proof of same is demanded at trial. 13, Denied, It IS specifically denied that Defendants acted In an unethical or , VERIFICATION I, Patrick Smith, verify that the statements made in the foregoing document, which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believes them to be true, And further, this Verification is signed on the recommendation of my attorneys, who advise me that the statements and language in this document are required legally to raise issues for resolution at trial by the Court, or by continuing investigation and preparation for trial. I understand that some of tnese statements may prova inappropriate after investigation and trial preparation are complete, and I leave determination of these matters to my attorneys on their advice, I understand that all statements herein are made subject to the penalties of J 8 Pa, C,S,A. ~4904, relating to unsworn falsification to authorities, Dated: 9/8197 I . , C:IOFFICE\WPWINIHGI\SMITHANS.AMD 4 CERTIFICATE OF SERVICE AND NOW, this ft~ay of September, 1997, the undersigned does hereby certifY that hc did serve a copy of the orcgoing Answer upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Camp Hill, Pennsylvania, addresscd as follows: William T, Smith, Esquire 3747 Derry Street Harrisburg, P A 17111 C, Roy Weidner, Jr, JOHNSON, DUFFIE, STEWART & WEIDNER 30 I Market Street P,O, Box 109 Lemoyne, PA 17043.0109 By: REAGER & ADLER, P,~, , /) ~O (~~~ aVI ,Reager, squire Attorney I.D, No, 20868 2331 Market Street Camp Hill, PA 17011 Attorney for Defendants Patrick Smith and The Homestead Group, Inc, . C:IOFFICElWPWIN\HCIISMITHANS,AMD 5 . ' Johnson, Duffie, Stewart & Weidner By: C, Roy Weidner, Jr, 1.0, No, 19530 30 J Market Street p, 0, Box 109 Lemoyne, Pennsylvania 17043.0109 (7 17) 761-4540 Attorneys for Richard W, Walker, Individually and Jack Gaughen Realtor BAYARD D, JAMES, TRUSTEE OF THE JAMES FAMILY TRUST, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 96.5573 Plaintiff v, CiVIL ACTION. LAW PATRICK SMITH, Individually, THE HOMESTEAD GROUP, INC" RICHARD W, WALKER, Individually, and JACK GAUGHEN REALTOR, JURY TRIAL DEMANDED Defendants PRAECIPE TO SETTLE, SA TISFY AND DISCONTINUE AND NOW, this /111: day of September, 1998, please mark the above captioned action settled, satisfied and discontinued, including all counterclaims, crossclaims and joinders of additional parties, LAW OFFICE OF WILL~TH Q BY:~ _ William T, Smith Attorney for Piaintiff ART & WEIDNER By: :114445 C, Roy eidner, Jr, Attorney , , Walker and Jack Gaughen Realtor .. SON, DUFFIE, STEWART & WEIDNER CERTIFICA TE OF SERVICE AND NOW, this Q~~ay of September, 1998, the undersigned does hereby certify that she did this date serve a copy of ths foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: William T, Smith, Esquire 3747 Derry Street Harrisburg, PA 17111 David W, Reager, Esquire Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011.4642 By >- m ~ ~ U'; ~'- >- cr. --",( n U.l-,-,: , C) ". ~ '," ..--C, :-::-:J C.~ " " ('.,5~: ~ C)~- '.:> .,:! 1-1..:'- c-..' ~~; C" :'":j ,,, .' V, u. CO ::> 0 (T, U ,.