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SOWERS, GARNER, SAYLOR
ARCHITECTS ENGINEERS, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 06- 2'1("(,,
CiUlt't~
HALLMARK SENIOR COMMUNITIES,
L.L.C. ,
Defendant
NOTICE
YOU HAVE BEEN SUED 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 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
249-3166/800-990-9108
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SOWERS, GARNER, SAYLOR
ARCHITECTS ENGINEERS, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 0-0- j</~t.- ~T..e--
HALLMARK SENIOR COMMUNITIES,
L.L.C. ,
Defendant
COMPLAINT
COUNT I
BREACH OF CONTRACT
1. Plaintiff is Sowers, Garner, Saylor Architects
Engineers, Inc., (hereinafter "SGS") a Pennsylvania Corporation
with its principal place of business at One Tyler Court,
Carlisle, Pennsylvania 17013.
2. The Defendant is Hallmark Senior Communities, L.L.C.
(hereinafter "Hallmark"), a Delaware Limited Liability Company
with its registered place of business in Pennsylvania at 4043
Irene Street, West Mifflin, PA 15122.
3. SGS is engaged in the principal business of providing
architectural and engineering services,
4. Hallmark is the owner of Heritage Manor, a skilled
nursing facility for the aged located at 3122 Lebanon Church
Road, West Mifflin, Pennsylvania 15122.
5. Hallmark is the owner of Locust Grove, a skilled
nursing facility for the aged located at 4043 Irene Street, West
Mifflin, Pennsylvania 15122.
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6. Hallmark is the owner of Twin Oaks, a skilled nursing
facility for the aged located at 2560 Stroschein Road,
Monroeville, Pennsylvania 15146.
7. Hallmark is the owner of Patrick Place, a skilled
nursing facility for the aged located at 3560 Outlook Drive, West
Mifflin, Pennsylvania 15122.
A. HERITAGE MANOR.
8. In or about June of 1999, Hallmark decided to renovate
its facilities at Heritage Manor and requested a meeting with SGS
to discuss the performance of certain architectural and
engineering services by SGS for the project (hereinafter the
"Heritage Manor proj ect") .
9. Representatives of SGS met with Daniel A. Hirschfeld
and Barbara J. Schneck of Hallmark to discuss the Heritage Manor
Project in early June of 1999.
10. Daniel A. Hirschfeld was the President and CEO of
Hallmark at all times relevant hereto and as such had authority
to contractually bind Hallmark with respect to the requested
services for the Heritage Manor Project.
11. Following SGS' meeting with Mr. Hirschfeld, SGS
proposed to prepare concept floor plans for Heritage Manor's
lower level, first floor and second floor.
12. SGS' proposal for the Heritage Manor Project was
outlined in a correspondence to Mr. Hirschfeld dated June 9,
2000, a copy of which is attached hereto as Exhibit "A" and the
terms of which are incorporated herein by refJrence (the
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"Heritage Manor Proposal"). Pursuant to the Heritage Manor
Proposal, 8G8 was to prepare certain concept floor plans for
Heritage Manor's lower level, first floor and second floor for a
fixed sum of $7,800.00. 8G8' normal hourly rates, as set forth
in the Heritage Manor Proposal, were to apply to any additional
services requested by Hallmark. 8G8 was to invoice Hallmark
monthly for its services.
13. Mr. Hirschfeld subsequently requested that 8G8 perform
the architectural and engineering services outlined in the
Heritage Manor Proposal in accordance with the specific terms
thereof.
14. Mr, Hirschfeld subsequently requested in or about
August of 1999 that 8G8 perform additional services with respect
to the Heritage Manor Project on a time and materials basis.
8uch additional services consisted of the preparation of final
construction documents indicating demolition and proposed new
work. Mr. Hirschfeld's oral request for such additional services
was memorialized in a correspondence from 8G8 dated August 19,
1999, a copy of which is attached hereto as Exhibit "B."
15. Mr. Hirschfeld's requests for architectural and
engineering services created a binding agreement between Hallmark
and SG8 for the Heritage Manor Project - the terms of which were
set forth in the Heritage Manor Proposal of June 9, 1999, as
supplemented by Mr. Hirschfeld's request for additional services
(hereinafter the "Heritage Manor Agreement") .
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16. Hallmark was to provide 8G8 with marked-up drawings of
the existing conditions at Heritage Manor in accordance with the
Heritage Manor Agreement in order to facilitate 8G8' preparation
of concept floor plans, Hallmark in fact provided 8G8 with such
drawings.
17. SGS timely completed the requisite architectural and
engineering services contemplated under the Heritage Manor
Agreement, as well as the additional services as requested by
Hallmark,
18. 8GS timely submitted invoices for architectural and
engineering services performed by it in accordance with the
Heritage Manor Agreement,
19. At the present time, $7,800.00 is in arrears under the
Heritage Manor Agreement with respect to the architectural and
engineering services originally contemplated under the Heritage
Manor Proposal of June 9, 1999.
20. At the present time, $1,152.50 is in arrears with
respect to the additional architectural and engineering services
as requested by Hallmark for the Heritage Manor Project.
21. Hallmark is now refusing to compensate 8G8 for the
architectural and engineering services performed by it under the
Heritage Manor Agreement and as additionally requested by
Hallmark.
22. 8G8 has performed all services required of it under the
terms of the Heritage Manor Agreement.
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23. Hallmark's refusal to compensate 8G8 for the
architectural and engineering services performed by it
constitutes a breach of the Heritage Manor Agreement.
24. The Heritage Manor Agreement called for payment to 8G8
at its offices located at One Tyler Court, Carlisle, Pennsylvania
17013.
25. Hallmark currently owes 8G8 approximately $8,952.50 in
the aggregate, exclusive of interest due thereon, for
architectural and engineering services rendered to Hallmark in
conjunction with the Heritage Manor Project. A copy of 8G8' most
recent invoice evidencing the amount in arrears is attached
hereto as Exhibit "I."
B. LOCU8T GROVE.
26. In or about June of 1999, Hallmark decided to renovate
its facilities at Locust Grove and requested a meeting with SG8
to discuss the performance of architectural and engineering
services by SGS for the project (hereinafter the "Locust Grove
proj ect")
27. Representatives of SG8 met with Daniel A. Hirschfeld
and Barbara J. Schneck of Hallmark to discuss the Locust Grove
Project in June of 1999.
28. Daniel A. Hirschfeld was the President and CEO of
Hallmark at all times relevant hereto. Mr. Hirschfeld had
authority to contractually bind Hallmark with respect to the
requested services for the Locust Grove Project.
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29. Following 8G8' meeting with Mr. Hirschfeld, 8G8
proposed to prepare concept floor plans for Locust Grove's first
floor including alterations to the solarium, lobby, reception
area, and nurse's station.
30. 8GS' proposal for the Locust Grove Project was outlined
in a correspondence to Mr. Hirschfeld dated June 9, 2000, a copy
of which is attached hereto as Exhibit "e" and the terms of which
are incorporated herein by reference (hereinafter the "Locust
Grove Proposal"). Pursuant to the Locust Grove Proposal, SGS was
to prepare certain concept floor plans for a fixed sum of
$5,100.00. 8G8' normal hourly rates, as set forth in the Locust
Grove Proposal, were to apply to any additional services
requested by Hallmark. 8G8 was to invoice Hallmark monthly for
such services.
31. Mr. Hirschfeld subsequently requested that 8G8 perform
the architectural and engineering services outlined in the Locust
Grove Proposal in accordance with the specific terms thereof,
32. Hallmark was to provide SG8 with marked-up drawings of
the existing conditions at Locust Grove in accordance with the
Locust Grove Proposal in order to facilitate SG8' preparation of
concept floor plans.
33, Hallmark in fact provided 8GS with such drawings of the
existing conditions at Locust Grove.
34. Mr. Hirschfeld subsequently requested in or about
August of 1999 that 8G8 perform additional services with respect
to the Locust Grove Project on a time and materials basis. 8uch
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additional services consisted of the preparation of final
construction documents indicating demolition and proposed new
work. Mr. Hirschfeld's oral request for such additional services
was memorialized in a correspondence from 8G8 dated August 19,
1999, a copy of which is attached hereto as Exhibit "D."
35. Mr. Hirschfeld's requests for architectural and
engineering services created a binding agreement between Hallmark
and SG8 - the terms of which were set forth in the Locust Grove
Proposal as supplemented by Mr. Hirschfeld's subsequent request
for additional services (the "Locust Grove Agreement") .
36. 8G8 timely completed the requisite architectural and
engineering services contemplated under the Locust Grove
Agreement.
37. 8G8 timely submitted invoices for architectural and
engineering services performed by it in accordance with the
Locust Grove Agreement and as requested by Hallmark.
38, At the present time, $5,100.00 is in arrears with
respect to the initial architectural and engineering services
contemplated under the Locust Grove Agreement.
39. At the present time, $7,082.00 is in arrears with
respect to the additional architectural and engineering services
requested by Hallmark for the Locust Grove Project.
40. Hallmark is now refusing to compensate 8G8 for the
architectural and engineering services performed by it under the
Locust Grove Agreement and as requested by Hallmark.
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41. SGS has performed all services required of it under the
terms of the Locust Grove Agreement.
42. Hallmark's refusal to compensate SGS for the
architectural and engineering services performed by it
constitutes a breach of the Locust Grove Agreement.
43. The Locust Grove Agreement called for payment to SGS at
its offices located at One Tyler Court, Carlisle, Pennsylvania
17013 .
44. Hallmark currently owes 8G8 approximately $12,182.00 in
the aggregate, exclusive of interest due thereon, for
architectural and engineering services rendered for the Locust
Grove Project. A copy of SGS' most recent invoice evidencing the
amount in arrears is attached hereto as Exhibit "I."
C. TWIN OAKS.
45. In or about June of 1999, Hallmark decided to renovate
its facilities at Twin Oaks and requested a meeting with SGS to
discuss the performance of architectural and engineering services
by SGS for the project (hereinafter the "Twin Oaks Project") .
46. Representatives of SGS met with Daniel A. Hirschfeld
and Barbara J. Schneck of Hallmark to discuss the Twin Oaks
Project in June of 1999.
47. Daniel A. Hirschfeld was the President and CEO of
Hallmark at all times relevant hereto and as such had authority
to contractually bind Hallmark with respect to the requested
services for the Twin Oaks Project.
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48. Following SGS' meeting with Mr. Hirschfeld, SGS
proposed to prepare concept floor plans and color boards for a
"main street theme" at Twin Oaks.
49. SGS' proposal for the Twin Oaks Project was outlined in
a correspondence to Mr. Hirschfeld dated June 9, 2000, a copy of
which is attached hereto as Exhibit "E" and the terms of which
are incorporated herein by reference (the "Twin Oaks Proposal")
Pursuant to the Twin Oaks Proposal, SGS was to prepare certain
concept floor plans for a fixed sum of $4,475.00. SGS' normal
hourly rates, as set forth in the Twin Oaks Proposal, were to
apply to any additional services requested by Hallmark. SGS was
to invoice Hallmark monthly for such services.
50. Mr. Hirschfeld subsequently requested that SGS perform
the architectural and engineering services outlined in the Twin
Oaks Proposal in accordance with the specific terms thereof.
51. Mr. Hirschfeld subsequently requested in or about
September of 1999 that SGS perform additional services with
respect to the Twin Oaks Project on a time and materials basis.
Such additional services consisted of the preparation of final
documents for construction and preparation of Labor & Industry
drawings for approval. Mr. Hirschfeld's oral request for such
additional services was memorialized in a correspondence from SGS
dated September 21, 1999, a copy of which is attached hereto as
Exhibi t "F."
52. Mr. Hirschfeld's requests for architectural and
engineering services created a binding agreement between Hallmark
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and SG8 - the terms of which were set forth in the Twin Oaks
Proposal of June 9, 1999, as supplemented by Mr. Hirschfeld's
request for additional services (the "Twin Oaks Agreement") .
53. 8G8 timely completed the requisite architectural and
engineering services contemplated under the Twin Oaks Agreement,
as well as the additional services requested by Hallmark.
54. 8GS timely submitted invoices for architectural and
engineering services performed by it in accordance with the Twin
Oaks Agreement and as requested by Hallmark.
55, At the present time, $4,475.00 is in arrears with
respect to the initial architectural and engineering services
contemplated under the Twin Oaks Agreement.
56. At the present time, $2,573.75 is in arrears with
respect to the additional architectural and engineering services
requested by Hallmark for the Twin Oaks Project.
57. Hallmark is now refusing to compensate 8G8 for the
architectural and engineering services performed by it under the
Twin Oaks Agreement and as requested by Hallmark.
58. 8G8 has performed all services required of it under the
terms of the Twin Oaks Agreement.
59. Hallmark's refusal to compensate SG8 for the
architectural and engineering services performed by it
constitutes a breach of the Twin Oaks Agreement.
60. The Twin Oaks Agreement called for payment to 8G8 at
its offices located at One Tyler Court, Carlisle, Pennsylvania
17013 .
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61. Hallmark currently owes 8G8 approximately $7,048.75 in
the aggregate, exclusive of interest due thereon, for
architectural and engineering services rendered for the Twin Oaks
Project. A copy of 8G8' most recent invoice evidencing the
amount in arrears is attached hereto as Exhibit "I."
D. PATRICK PLACE.
62. In or about June of 1999, Hallmark decided to renovate
its facilities at Patrick Place and requested a meeting with 8GS
to discuss the performance of architectural and engineering
services by 8G8 for the project (hereinafter the "Patrick Place
proj ect")
63. Representatives of 8G8 met with Daniel A. Hirschfeld
and Barbara J. 8chneck of Hallmark to discuss the Patrick Place
Project in June of 1999.
64. Daniel A. Hirschfeld was the President and CEO of
Hallmark at all times relevant hereto, Mr. Hirschfeld had
authority to contractually bind Hallmark with respect to the
requested services for the Patrick Place Project.
65. Following 8G8' meeting with Mr. Hirschfeld, 8G8
proposed to prepare concept floor plans and color boards for a
"main street theme" at Patrick Place.
66. 8G8' proposal for the Patrick Place Project was
outlined in a correspondence to Mr. Hirschfeld dated June 9,
2000, a copy of which is attached hereto as Exhibit "G" and the
terms of which are incorporated herein by reference (the "Patrick
Place Proposal"). Pursuant to the Patrick Place Proposal, 8G8
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was to prepare certain concept floor plans for a fixed sum of
$4,715.00. 8G8' normal hourly rates, as set forth in the Patrick
Place Proposal, were to apply to any additional services
requested by Hallmark. 8G8 was to invoice Hallmark monthly for
such services.
67. Mr. Hirschfeld subsequently requested that 8G8 perform
the architectural and engineering services outlined in the
Patrick Place Proposal in accordance with the specific terms
thereof.
68. Mr. Hirschfeld subsequently requested in or about
August of 1999 that 8G8 perform additional services with respect
to the Patrick Place Project on a time and materials basis. 8uch
additional services consisted of architectural and engineering
services relating to the modification of the "toilet rooms" at
Patrick Place. Mr. Hirschfeld's request for such additional
services was memorialized in a correspondence from 8G8 dated
August 6, 1999, a copy of which is attached hereto as Exhibit
"H."
69. Mr. Hirschfeld's request for architectural and
engineering services created a binding agreement between Hallmark
and 8G8 - the terms of which were set forth in the Patrick Place
Proposal of June 9, 1999, as supplemented by Mr. Hirschfeld's
request for additional services (the "Patrick Place Agreement")
70. 8G8 timely completed the requisite architectural and
engineering services originally contemplated under the Patrick
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Place Agreement, as well as the additional services requested by
Hallmark.
71. 8G8 timely submitted invoices for architectural and
engineering services performed by it in accordance with the
Patrick Place Agreement and as requested by Hallmark.
72. At the present time, $4,715.00 is in arrears with
respect to the initial architectural and engineering services
contemplated under the Patrick Place Agreement.
73. At the present time, $1,163.25 is in arrears with
respect to the additional architectural and engineering services
requested by Hallmark for the Patrick Place Project.
74. Hallmark is now refusing to compensate 8G8 for the
architectural and engineering services performed by it under the
Patrick Place Agreement and as requested by Hallmark.
75. 8G8 has performed all services required of it under the
terms of the Patrick Place Agreement.
76. Hallmark's refusal to compensate 8G8 for the
architectural and engineering services performed by it
constitutes a breach of the Patrick Place Agreement.
77. The Patrick place Agreement called for payment to SG8
at its offices located at One Tyler Court, Carlisle, Pennsylvania
17013 .
78. Hallmark currently owes 8G8 approximately $5,878.25 in
the aggregate, exclusive of interest due thereon, for
architectural and engineering services rendered for the Patrick
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Place Project. A copy of SGS' most recent invoice evidencing the
amount in arrears in attached hereto as Exhibit "I."
79, Hallmark currently owes SGS approximately $34,061.50
for architectural and engineering services performed for each of
the Heritage Manor Project, the Locust Grove Project, the Twin
Oaks Project and the Patrick Place Project.
WHEREFORE, Sowers, Garner, Saylor Architects Engineers, Inc.
demands judgment in its favor and against Hallmark Senior
Communities, L.L.C. in the amount of $34,061.50, together with
interest, and costs of suit. The amount in controversy exceeds
the jurisdictional amount requiring compulsory arbitration in
accordance with Local Rule 1301-1.
COUNT II
UNJUST ENRICHMENT
80. SGS incorporates herein by reference paragraphs 1
through 79 above as if set forth at length.
81. SGS performed architectural and engineering services
for the exclusive benefit of Hallmark for each of the Heritage
Manor Project, the Locust Grove Project, the Twin Oaks Project
and the Patrick Place Project (collectively the "Projects") at
Hallmark's express request, and in reliance upon Hallmark's
representations that it would pay SGS for such services.
82, SGS has completed all architectural and engineering
services for the Projects as requested by Hallmark.
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83. Hallmark has refused to compensate SGS for the
architectural and engineering services performed by it.
84. SGS anticipates that Hallmark will continue to refuse
payment to SGS.
85. SGS justifiably relied to its detriment on Hallmark's
representations that it would pay SGS for the requested work on
the Projects.
86. SGS has conferred a benefit on Hallmark in the nature
of architectural and engineering services for the Projects.
87. SGS has been damaged as a result of Hallmark's refusal
to pay for the requested work on the Projects, since it has
incurred expenses and performed work that it otherwise would not
have done if it had known that Hallmark had no intention of
paying SGS for the work and expenses.
88. Hallmark has been unjustly enriched in the amount of
approximately $34,061,50, which evidences the fair market value
of the architectural and engineering services performed by SGS
for the Projects. A copy of SGS' most recent invoice evidencing
the amount in arrears is attached hereto as Exhibit "I."
WHEREFORE, Sowers, Garner, Saylor Architects Engineers, Inc.
demands judgment in its favor and against Hallmark Senior
Communities, L.L.C. in the amount of $34,061.50, together with
interest, and costs of suit. The amount in controversy exceeds
the jurisdictional amount requiring compulsory arbitration in
accordance with Local Rule 1301-1.
A171070:
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Date: June 5,2000
A171070:
EE WALLACE & NURI~
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I,D. No. 75896
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff
05/12/2000 08:20
7172490
STEPHEN L BLOOM.
PAGE: 04
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One Tyler Court
C"rl~... PA 17013
717/249-4569
Fox: 717/249-ll2S4
Emoil: ssgs@po.nel
SCHOLL" SCHNEll$. .. CAQ:N.ER ~ SAYLOR
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June 09,1999
Mr. Daniel A. Hirachfeld
President and CEO
Hallmark Senior Communities, Inc.
8422 Bellona Lane, Suite 205
Towson, MD 21204-2057
410-626-1676
RE: Heritage Manor
3122 Lebanon Church Road
West Mifflin, PA 15122
88GS 99055
Dear Mr. Hirschfeld:
SSGS Architectu~J Associates, Inc. is pleased to submit this proposal to provide professional
architectural and engil'1eering services for the renovation project as per your recent request
Our firm brings L1n4;lqualed slrengths and value to your project through:
. Active supervision of all tasks by a prIncipal of the firm,
. Dedication to providing superior client service. .
. . Extensive related experience.
. ADA expert on staff.
. In-house engineering services.
88GS enjoys an outstanding reputation in the industry for the accuracy and completeness of
our documents. We recognize the importance of providing quality drawings and expedient
service to our clients. Be assured, your expectatiorls will be mel.
55GS firmly embraces the philosophy of strict adherence to principles of cost control, quality
assurance and functionality of design, thus assuring the success of your project.
We are excited about having the opportunity to work with you and Hallmark and are eager to
demonstrate our capabilities. We are prepared to accomplish the assigned tasks to your
complete satisfaction.
LEROV R. SCHOLL. JR.. AlA - DENNIS F. SOWERS. AlA - BRUCE E. GARNER - LARRY E. SAYLOR. AlA
4
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05/12/2000 08:20
71 72497C
STEPHEN L BLOOM ~
, PAGE' 05
Mr, Daniel A, Hirschfeld
June 09, 1999
Page 2
SCOPE OF SERVICES
Our. propollS-' Is basad upon our discussion with you and Barbara J. Schneck for renovations
and proviCihg concept drawings on the Lower Llilvel, First Floor and Second Floor, SSGS
Architectural Associates, Inc. proposes to provide the following professional services for the
project:
1. Prepare concept floor plans showing:
a.) Lower Level:
Formal Dining Room
Preparation Kitchen with warming carts
b.) First Floor:
Lobby Area layout
Main Entrance Doors
Existing Dining Area conversion
Activities Room
c,) . Second Floor:
Alzheimer's Area modifications
Nurses Station
Creale Lounge Area
2. Plans will be devaloped with consideration being given to code issues.
3, Hallmark to provide existing conditions marked-up drawings to SSGS for preparation of
consept drawings,
FEES
SSGS Architectural Assooiates, Inc. proposes to provide professional architeotural and
engineering services as required for the project,
Our fee shall be a fixed sum of seven five thousand eight hundred dollars ($7,800.00),
Reimbursable expenses such as reproducil19 drawings, travel and mileage are included in this
fee and will not be additionally bllled.
Upon being awarded a contract to develop construotlon doouments, 88GS will provide a credit
against our fee in an amount equal to the fee paid under this agreement.
5
05/12/2000 08:20
7172497~
Mr. Daniel A Hirschfeld
June 09, 1999
Page 3
.~
STEPHEN L BLOOM 0
, PAGE, 06
)f additional servJces beyond the agreed upon scope are requested, the following hourly rates
apply: i'
Jj
Principal
Project Architect
Project Engineer
T echnlcsl Support
Secretarial Support
$105.00
$80.00
$80,00
$60,00
$30.00
Invoices will be submitted monthly based upon the percentage of the project completed during
the preceding month, Invoices shall be paid within thirty (30) days of date of invoice.
All changes and additional services will be documented, and supplemental invoicing Will be
provided.
The above services to be completed by July 2, 1999 with a review meeting scheduled for July
6,1999 in our office,
Thank you for the opportunity to be of servica,
Sincerely, .' {
~,^l/
Principal
Accepted:
Hallmark Senior Communities, Inc.
Date
6
SCHOILI!.. .. SOWERS'" GARNER. SAYLOR
One Tyler Court
Carlisle. PA 17013
717/249-4569
Fax: 717/249-0284
Emall: ssgs@pa.nel
ARCHITECTURAL ASSOCIATES. INC_
CONTRACT MODIFICATION
Date:
Auaust 19. 1999
Attention:
Mr. Daniel Hershfeld. CEO
Client Name: Hallmark Senior Communities. Inc.
Address:
8422 Bellone Lane. Suite 205, Towson, MD 21204-2057
Heritaae Manor
3122 Lebanon Church Road
West Mifflin~ PA 15122
S8G8 Project#: 99055.001
RE:
Dear Mr. Hershfeld:
Regarding your request for 88G8 Architectural Associates, Inc.to proceed with additional
professional architectural and/or engineering service for the above-referenced project for work
above our arranged agreement fee in the amount of $7,800.00. this letter is to confirm our
agreement to increase our existing fee on a time and material basis using the hourly rates
included in our proposal to you dated June 9, 1999.
The additional architectural and engineering services to be provided consist of final documents
for construction indicating demolition and proposed new work. The scope of work and all terms
and conditions outlined in the original proposal shall remain the same, except as modified
herein. We are proceeding with the work load on your verbal authorization. Please advise me
immediately if you take exception to this understanding.
Authorization
Date
Please sign and return.
cc: Michelle Ewing - 8SG8
LEROY R. SCHOLL JR.. AlA - DENNIS F. SOWERS. AlA - BRUCE E. GARNER - LARRY E. SAYLOR. AlA
..
_A, ,__
'"' ~.:
05/12/2000 08:20
71724~
STEPHEN L BLOOM.
PAGE 07
'",l~-Y'-,' '-"",
One Tyler COUrt
Ca~i'le. f'A 17013
717/249-4569
Fax: 717/249-0284
Ernoll: ssg,@pa.nel
SCHOLL - SOWERS'" -GARNER to SAYLOR
ARCHITECTURAL ASSOCIATES. IINC.
;j
June09.19~9
Mr. Daniel A. Hirschfeld
President and CEO
Hallmark Senior Communities. Inc.
8422 BeUona lane, Suite 205
Towson, MD 21204-2057
410-828-1876
RE: Locust Grove
4043 Irene Street
West Mifflin, PA 15122
85GS 99056
Dear Mr, Hirschfeld:
58G8 Architectural Associates, Inc. is pleased to submit this proposal to provide professional
architectural and engineering services for the renovation project as per your recent request.
Our firm brings unequaled strengths and value to your project 1hrough:
. Active supervision of all tasks by a principal of the firm.
. Dedication to providing superior client service.
. Extensive related experience.
. ADA expert on staff.
. In-house engineering services.
88G8 enjoys an outstanding reputation in the industry for the acouracy and completeness of
our documents. We recognize the importance of providing quality drawings and expedient
service to our clients. Be assured, your expectations will be met.
88GB firmly embraoes the philosophy of strict adherenoe to prinoiples of cost control. quality
assurance and functionality of design, thus assuring the success of your project.
We are excited about having the opportunity to work with you and Hallmark and are eager to
demonstrate our capabilities. We are prepared to accomplish the assigned tasks to your
complete satisfaction.
LEROY R. SCHOLL JR., AlA - DENNIS F. SOWERS. AlA - BRUCE E. GARNER - LARRY E. SAYLOR. AlA
7
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'\il]]
05/12/2000 08:20
71 724977P
STEPHEN L BLOOM .
, PAGE' 08
Mr. Daniel A. Hirsohfeld
June 09,1999
Page 2
SCOPE OF SERVICES
Our propo~1 is based upon our discussion with you and Barbara J. Schneck for renovations
and proviMng concept drawings of various areas. SSGS Architectural Associates, Inc.
proposes to proVide the following profeSSional services fOr the projeot:
1, Prepare concept floor plans showing:
a.) First Floor:
Solarium at front entrance
lobby back wall to corridor to be removed
Relocate reception area
Beautyl Barber - create admissions office
Create office for diatition
BacK stage area - create to private dining room
Enlarge nurse's station
locate office area to Regional office wing
End of hall nurses station ohange into storage! med room
2. Plans will be developed with consideration being given to oode issues.
3. Hallmark to provide existing conditions marked-up drawings to 55GS for preparation of
conoept drawings.
FEES
88GS Arohitectural Associates, Inc. proposes to provide profeSSional architectural and
engineering services as required for the project.
Our fee shall be a fixed sum of five thousand one hundred dollars ($5,100.00). Reimbursable
expenses suoh as reproducing drawings, travel and mileage are Inoluded in this fee and will not
be additionally billed.
Upon being awarded a contract to develop construction documents, 55G5 will provide e credit
against our fee in an amount equal to the tee paid under this agreement.
if additional services beyond the agreed upon scope are requested. the following hourly rates
apply:
8
-.
05/12/2000 08:20
71724977P
Mr. Daniel A. Hirschfeld
June 09, 1999
Page 3
Principal
Project Architect
Project Engineer
Technia\i Support
Secretarial Support
$105.00
$80.00
$80.00
$60.00
$30.00
.i;.
"'
STEPHEN L BLOOM .
, PAGE' 09
Invoices wiD be submitted monthly based upon the percentage of the project completed during
the preceding month. Invoices shall be paid within thirty (3D) days of date of invoice.
All changes and additional services will be documented, and supplemental invoicing will be
provided.
The above services to be completed by July 2, 1999 with a review meeting scheduled for July
6,1999 in our offioe.
Thank you for the opportunity to be of service.
Accepted:
Hallmark Senior Communities. Inoo
Date
9
~. ililllllll,llMllMfl
ARCHITECTURAL ASSOCDATES. INC.
One Tyler Court
Ca~i,le. PA 17013
717/249-4569
Fax: 717/249-0284
Emall: ..g.@pa.net
CONTRACT MODIFICATION
Date: Auaust 19. 1999
Attention:
Mr. Daniel Hershfeld. CEO
Client Name: Hallmark Senior Communities. Inc.
Address:
8422 Bellone lane. Suite 205. Towson. MD 21204-2057
locust Grove
4043 Irene Street
West Mifflin. PA 15122
SSG8 Project#: 99056.<'0 I
RE:
.~
Dear Mr. H~rshfeld:
Regarding your request for SSG8 Architectural Associates, inc. to proceed with additional
professional architectural and/or engineering service for the above-referenced project for work
above our arranged agreement fee in the amount of $5,100.00, this letter is to confirm our
agreement to increase our existing fee on a time and material basis using the hourly rates
included in our proposal to you dated June 9, 1999.
The additionai architectural and engineering services to be provided consist of final documents
for construction indicating demolition and proposed new work. The scope of work and all terms
and conditions outlined in the original proposal shall remain the same, except as modified
herein. We are proceeding with the work load on your verbal authorization. Please advise me
immediately if you take exception to this understanding.
If you have any questions, please call me.
Authorization
Date
Please sign and return.
cc: Michelle Ewing - 88GB
LEROY R. SCHOLL. JR.. AlA - DENNIS F. SOWERS. AlA - BRUCE E. GARNER - LARRY E. SAYLOR. AlA
..;.
~ .
"-G
05/12/2000 08:20
7172490
STEPHEN L BLOOM ~
PAGE 10
One Tyler Court
Carlisle. PA 17013
717/249-4569
Fcx: 717/249.0084
Ernell: ssg,@pc.net
SCHOl.l!.. .. sOV\ol'eRS .. GARNEQ' ~ S.AY!LO~
Alilctll.yeC"U~AL ASSOCRA1'ES. aNe.
'/
~.
June 09,1999
Mr. Daniel A. Hirschfeld
president and CEO
Hallmark Senior Communities, Ino.
8422 Bellona Lane, Suite 205
Towson, MD 21204-2057
410-828-1876
RE: Twin Oaks
2560 Strosoheln Road
Monroeville, PA 15146
88GS 99057
Dear Mr. Hirsohfeld:
88G8 Architectural Associates, Ino. is pleased to submit this proposal to provide professional
architeotural and engineering services for the renovation project as per your recent request.
Our firm brings unequaled strengths and value to your project through:
. Active supervision of all !asks by a principal of the firm.
.,. lDedicatlon to providing superior client service.
. Extensive related experience.
. ADA expert on staff.
. In-house engineerJng servioes.
88G5 enjoys an outstanding reputation In the industry for the aocuracy and completeness of
our documents. We recognize the importance of providing quality drawings and expedient
service to our clients. Be assured, your expectations will be met.
88G8 firmly embraces the philosophy of strict adherenoe to prinoiples of oost control, quality
assurance and functionality of design, thus assuring the success of your project.
We are excited about having the opportunity to work with you and Hallmark and are eager to
demonstrate our capabilities. We are prepared to accomplish the assigned tasks to your
complete setlsfaction.
SCOPE OF SERVICES
Our proposal Is based upon our discussion with you and Barber!! J. Schneck for providing main
street .Iheme torlhe tacJllty. 55GS ArChitectural Associates, Inc. proposes 10 provide the
following professional services for the project:
1. _ Prepare concept floor plan sketches and color boards.
LEROY R. SCHOLL JR.. AlA - OENNIS F, SOWERS. AlA - BRUCE E. GARNER - IARRY E. SAYLOR. AlA
10
.." c,
05/12/2000 08:20
71 72497Q
PAGE 11
0,
.--'
STEPHEN L BLOOM
Mr. Daniel A. Hirschfeld
June 09,1999
Page 2
FEES H
SSGS Architectural Associates, Inc. proposes to provide professional architectural and
engineering services as required for the project.
Our fee shall be a fj)Ced sum of lour thousand four hundn,d seventy five dollars ($4,475.00)
Reimbursable exposes such as reproducing drawings, travel and mileage are included in his
fea and will not be additionally billed.
If additional services beyond the agreed upon soope are requested, the following hourly rates
apply:
Principal
Project Architect
Project E;ngineer
Technical Support
Secretarial Support
$105.00
$80.00
$80.00
$60.00
$30.00
Invoices will be submitted monthly based upon the percentage of the project completed during
the preceding month. Invoices shall be paid within thirty (30) Qaysof date of invoice.
All changes and addillonal services will be documented, and supplemental Invoicing will be
provided.
The above services to be completed by July;2, 1999 with a review meeting scheduled for July
6,1999 In our offioe.
Thank you for the opportunity to be of service.
Accepted:
Hallmark Senior Communities, Inc.
Date
11
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I
,
i
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,
i
,
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05/12/2000 08:20
o
71 72497757
'J
il<
CONTRACT MODIFICATION
Date:
SePlember21.1999
Attention:
Mr. Daniel Hershfeld. CEO
Client Name: Hallmark Senior Communities. Inc.
Address:
STEPHEN L BLOOM
-,
o
8422 Bellone Lane. Suite 20S.Towsol1. MD 21204-2057
Twin Oaks
"1560 Stroschein Road
Monroeville. PA 15146
SSGS Project#: 99057.001
RE:
Dear Mr. Hershfeld:
..~
PAGE 12
Regardin9your request for SSGS Architectural AssOCiates, ine. to proceed with addit10nal
professional architectural and/or engineering service for the above-referenced project for work
above our arranged agreement fee in the amount of $4,475.00, this letter is to confirm our
agreement to increase our existing fee on a time and material basis using the hourly rates
included in our proposal to you dated June 9, 1999.
The additional architectural and engineering services to be provided consist of final documents
for oonslnJction indicating demolition and proposed new work and preparation of Labor a.
Industry drawing for approval. The scope of work and all terms and conditions outlinEld in the
original proposal shall remain the same, except as modified herein. We are proceeding with the
work load on your verbal authorization. Please advise me immediately if you take exception to
this understanding.
If you have any questions, please call me.
Sincerely,
Larry E. Saylor, AlA, IFMA, CDT
Principal
Authorlzalion
Please sign and return.
cc: Michelle Ewing - SSGS
Date
12
85/12/2000 88: 20 . 71724970
STEPHEN'L BLOOM 0
PAGE 13
,
~ ,~
"
g
.'
OnE> TylE>r Court
Ccrll,le. PA 17013
n 71249-4569
Fox: 717/249-D234
Emoll: s;gs@po.nel
SCHOLl!.. .. SOWEJ;!S .. CARNER'" SAVLOa-
j'
I:!
June 09,1999
Mr. Daniel A. Hirschfeld
President and CEO
Hallmark Senior Communities, Inc.
8422 Bellona Lane, Suile 205
Towson, MD 21204-2057
41 0-828-1 876
RE: PatrIok Place
3560 Outlook Drive
West Mifflin, PA 15122
SSG5 99058
Dear Mr. Hirschteld:
SSGS Architectural Associates, Inc. is pleased 10 submit this proposal to provide professional
architectural and engineering services for the renovation project as per, your recent request.
Our firm brings unequaled strengths and value to your project through:
. Active supervision of all tasks by a prinolpal of the firm.
.' Cllidication to providing superior olient service.
. ExtensIve related experienoe.
. ADA expert on staff.
. In-house engineering servioes.
SBGS enjoys an outstanding reputation in the industry for the accuracy and completeness of
our documents. We recognl<:e the importance of providing quality drawings and expedient
service to our clients. Be assured, your expeotations will be met.
SSGS firmly embraces the philosophy of strict adherence to principles of cost control, quality
assurance and functionality of design, thus assuring the success of your projeot.
We are excited about having the opportunity to work with you and Hallmark arid are eager to
demonstrate our capabilities. We are prepared to accomplish the assigned tasks to your
complete satisfaction.
SCOPE OF SERVICES
Our proposal is based upon our disoussion with you and Barbara J. Sohneck for providing main
street theme for the faoility. SSGS Arohitectural Associatel!l. tno. proposes to provide the
following professional servioes for the project;
1. . Prepare concept floor plan sketches and color boards.
J.EROV R. SCHOJ.L JR.. AlA - OENNIS F. SOWERS. I'JA - BRUCE E. GARNER - LARRY E. SAYLOR. AlA
13
.~
, ~
~" '.' ~~ ~~
, ,
05/12/2000 08:20 ' 7172497~
STEPHEN L BLOOM <:)
, PAGE' 14
Mr. Daniel A. Hirschfeld
June 09, 1999
Page 2
FEES
"
tJ
85GS Arohitectural Associates, Inc. proposes to provide professional architectural and
engineering services as required for the project,
Our fee shall be a fixed sum of four thousand seven hundred fifteen dollars ($4,715.00)
Reimbursable exposes such as reprOducing drawings, travel and mileage are included in his
fee and will not be additionally billed.
If additional servlces beyond the agreed upon scope are requested, the following hourly rates
apply:
Principal
Project Arohlteot
P rOjeot Engineer
Technical Support
Secretarial Support
$105.00
$80.00
$80.00
$60,00
$$0.00
i
I
i
I
I
I
I
I
!
i
I
I
I
InVOices Will be submltte.d monthly based upon the percentage of the project completed during
the preoeding month. Invoices shall be paid within thirty (30) days of date of invoice.
. All changes and additional services will be documented, and supplemental Invoicing will be
provided. .
The above servIces to be completed by July 2, 1999 with a review meeting scheduled forJuJy
6,1999 In our offioe.
Thank you for the opportunity to be of service.
Sincerely,
Larry E. Saylor AlA
Principal
Acoepted:
Hallmark Senior Communities, Inc.
Dale
14
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05/12/2000 08:20
.
71 7249770
STEPHEN L BLOOM, 0
PAGE' 15
SCHOLL - SOWERS ~ GAJ;lNl:Jl - SAVLDR
One Tyler Court
CarfJ,le. i>A 17013
7171249-4509
Fax: 7J 7/24<Nl284
Emoil: $SQ$@pcl.nAl
CONTRACT MODII#CATION
Date:
August 6, 1999
Attention:
Mr. John Thacik, Vice President/Operations
RE:
Hallmark Senior Communities, LLC
4 Gomber Drive, McDonllid PA, 1S057
Hallmark Senior. Communities, llC
Patrick Place - Additional Services
Client Name:
Address:
S5GS Project #:
99058.001
Dear
Mr. Thacik:
Regarding your recent request for additional professional architectural and engineering services for the above
referenced project, this is to confirm our agreement to increase our eXisting fee on a time and material basis
based on the hourly rates included in our proposal and as discussed during our phone conversation of August
6, 1999.
The additional architectural and engineering services to be provided consist of structural services required to
remove portiom; existing bearing walls and the architectural services required to modify the existing toilet
rooms. The scope of work and all other terms end conditions outlined In the original proposal remain the seme
except as modified herein. As we Bre proceeding with work based on your verbal authorization, please advise
me immediately if you take exception to this understanding.
If you have any questions. please call me.
zrelY~Q I
L~-;7-
Principal
Date
Authorization
Please sign and return.
cc: M. Ewing/PF
Mark Ritchie
LEROY R. SCHOu.. JR.. AlA - OENNIS F. SOWERS. AlA - SRUCE E. GARNER - LARRY E. SAYLOR. AlA
15
-
,
05/12/2000 08:20
717249'0
Hallmark Senior Communities
8422 Sellono Lane
Suite 205
Towson, MD 21204-2057
May 02, 200IJ
91.120 121 + Total AR
3,000.00 3,000.00
2,651.00 2,551.00
2,149.00 2,149.00
7.eoo.OO 7.800.00
341.25 341.26
776.25 776.26
36.00 35.00
1,162.60 1.162.60
2.000.00 2,000.00
1,764.00 1,754.00
1,:126.00 1,336.00
5.100.00 5,100.00
5,300.00 6,300.00
1,782.00 1,782.00
7,082.00 7.062.00
4,200.00 4,200.00
276.00 276.00
4,475.00 4,476.00
2,573.75 2.573.75
2,573.75 2.573.76
4,700.00 4,700.00
16.00 15.00
4,715.00 4,715.00
688.00 588.00
26.26 26.25
71.00 71.00
500.00 500.00
1,103.25 1,163.26
34,081.50 34,081.50
34,081.50
STEPHEN L BLOOM 0
, Statement of Account
,--"-.,,
'-,
',-, ~
PAGt: 03
Jnvoice #
'J
J;i
Date
990S5 Hallmark.Horitage
6487 0712811998
6638 OS/2611999
6577 09123/1998
O. 30
31.50
61. 90
Sublotal:
99055.001 Hallmark.Heritage
8578 09l:2:ll1999
6628 10122/1999
6SB5 11/19/1999
Sub1DllIl:
9a05S HaJlm.rk'~oeu.t Greve
6488 07/28/1S99
6636 08/2611999
6679 09/:2:lI1999
Subtotal:
9905a.aOl Hallmark.Locuat Grove
6560 0812311998
6629 10/22/1999
Sub1Dlal;
99057 Hallmark-Twin 0.".
6469 07126/1966
6681 09123/1999
Subtotal:
99057.001 Hallmar"- TWin 0.".
6630 10122/1999
Subtotal:
900Se Hailmark-f1atrick Pll1ce
6490 07/26/1 999
6537 OS/2Si1999
SublOlal:
89056.001 Hallmark-Patricl< Tollet Room
6582 09123/1998
6668 10122/1 ege
56M 11/19/1998
6637.001 08128/1999
SublOlal:
BalanCII Du......
Total Amount Now Due
3
.- --f<- ,~, ,~"-' __ _, ,~- -" -
'" - -~-
"n -._,',,- - _';;-::<-i',',-" .'_ C. ,_;" ~
0<;;-..,
VERIFICATION
I, Bruce E. Garner, Principal, verify that the statements
made in the foregoing document are true and correct 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.
S 4904, relating to unsworn falsification to authorities.
~Ga~e~
Dated: May 31 , 2000
A171070:
. ~ . "I
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I
. r. '"~'""^-_'"
,.
SHERIFF'S RETURN - OUT OF COUNTY
. CASE NO: 2000-03466 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SOWERS GARNER SAYLOR ARCHITECT
VS
HALLMARK SENIOR COMMUNITIES
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
HALLMARK SENIOR COMMUNITIES
but was unable to locate Them
in his bailiwick. He therefore
deputized the sheriff of ALLEGHENY
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On July
7th , 2000 , this office was in receipt of the
attached return from ALLEGHENY
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Allegheny Co
Allegheny Notary
18.00
9.00
10.00
31.00
3.00
71.00
07/07/2000
MCNEES, WALLACE
~~
R. Thomas Kline
Sheriff of Cumberland County
& NURICK
Sworn and subscribed to before me
this /9 ~ day oa::)Jl,
aluvv A.D.
~t2 "- ~~
'J1,,~II~.~, A~
Pro tho 0 a y
llr.-. <;,..
r In The Court of Common Pleas of Cumberland County, Pennsylvania
..
Sowers, Garner, Saylor Architects Engineers, Inc.
. VS.
. -Ha~~mark-S-enT=--eO!1lmun 1. t ie s ,- 'L . C~:C .
.~ ;~~~i~S2_-~~~~~~~~0~~3~4~OCiVl(-":
Now, 6/8/00 , 20Ve, I, SHERIFF OF CUJ\1BERLAND COUNTY, PA, do
hereby deputize the Sheriff of Alleghe ny
County to execute this Writ, this
deputation being made at the request and risk of the ?~ ~ t
Sheriff of Cumberland County, P A
-be--~~~
~~.
~]fl!/a-=s /~ '
. ~-----:~~ '..
at~~
by handingt:#~~,
~~~=---'- ~
/'
Affidavit of Service
.~ :;'4,/ -='~~'-=-.. ~""
,,-~;'2U~ ,at.:z, ~'clock P?.<M.'servedthe
'<- ---' ~ -----
._---~
--;- ~_.--
Now,
within
upon
copy of the original
~-
a
--- ----
,"<= ---
and made known to
the contents thereof.
-=--->-
--"_~_i____~-
COSTS
SERVICE 7:>\ ,OD
lVIILEAGE
AFFIDAVIT ..6.c50
NOI.rlal Seal
Sheila R. 0'8,..n, Notary Public
PittSburgh, Allegheny County
My Commission Expires June 19, 2004
Member, PennsytvanlaAssodatlonol NoIaJ1es
$
Swo~ and subscribed beforSUl n ~ 2000
me this _ day of ; 2(j"_
$ ~ ,e[)
""~' ,~~
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~,,~-, ,
SHERIFF'S RETURN - OUT OF COUNTY
(
'"" CASE NO: 2000-03489 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TULLY-HANLE DOROTHY
VS
HANLE MICHAEL B
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
HANLE MICHAEL B
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
serve the within COMPLAINT - DIVORCE/NOTIC
County, Pennsylvania, to
On July
7th , 2000 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Deputize Dauphin
18.00
9.00
10.00
25.50
.00
62.50
07/07/2000
MANCKE, WAGNER,
~
R. Thomas Kli .e
Sheriff of Cumberland County
HERSHEY, TULLY
Sworn and subscribed to before me
this /9!!:' day Of~
.:wvV A.D.
0~ t?o~r~
.~".'"'.
~& '<~
-
@ffitt of t1p~ ~4e~iff
(
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Ralph G. McAllister
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Peunsylvania 17101
ph: (717)255-2660 fax: (717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
HANLE-TULLY DOROTHY
vs
Connty of Dauphin
HANLE MICHAEL B
Sheriff's Return
No. 1411-T - -2000
OTHER COUNTY NO. 00-3489
AND NOW: June 23, 2000
at 9:25PM served the within
COMPLAINT IN DIVORCE
upon
HANLE MICHAEL B
by personally handing
to HIM
1 true attested copy (ies)
of the original
COMPLAINT IN DIVORCE
and making known
to him/her the contents thereof at 1340 N. 6TH STREET
HARRISBURG, PA 17101-0000
C!-.
So Answers,
Jf~
Sworn and subscribed to
before me this.26TH day a JUNE, 2000
f~
Sheriff of
e f
PROTHONOTARY
By
Sheriff's Costs: $25.50 PD 06/22/2000
RCPT NO 138203
ETITS
,'.-~ '""
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In The Court of Common Pleas of Cumberland County, Pennsylvania
~ . Dorothy Tully-Haule
" . VS.
Michael B. Hanle
No. :W-3489 Civil
Now.,
6/19/00
, 20 () (J ~ I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
~~
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
, 20_, at
0' clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made Imown to
the contents thereof.
So answers,
Sheriff of
County, PA
20
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COSTS
SERVICE
lvllLEAGE
AFFIDAVIT
$
Sworn and subscribed before
me this day of
$
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Sowers, Garner, Saylor
Architects Engineers, Inc.,
Plaintiff
In the Court of Common Pleas
Cumberland County,
Pennsylvauia
v.
No. 00 - 3466 Civil
Hallmark Senior Communities, L.L.C.,
Defendaut
Civil Action - Law
WITHDRAW ALJENTRY OF APPEARANCE
To the Prothonotary:
Please withdraw the appearance of Thomas G. Collins, Esquire, on behalf of Plaintiff
~owers, Garner, Saylor Architects Engineers, Inc., formerly with the law firm of McNees,
Wallace & Nurick with a mailing address of 100 Pine Street, P.O. Box 1166, Harrisburg, PA
17108-1166, and enter the appearance of Thomas G. Collins, Esquire, on behalf of Plaintiff
Sowers, Garner, Saylor Architects Engineers, Inc., who is now with the law firm of Buchanan
Ingersoll Professional Corporation, whose address is One South Market Square, 213 Market
Street, 3rd Floor, Harrisburg, P A 17101 in the above-captioned action.
homas G. 0 lins, Esquire
I.D. #75896
One South Market Square
213 Market Street, 3rd Floor
Harrisburg, PA 17101
(717) 237-4800
Date: August 4, 2000
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CERTIFICATE OF SERVICE
I certify that I am today serving the foregoing document upon the person and in the
manner indicated below, which service satisfies the requirements of the Federal Rules of Civil
Procedure.
Date: August 4, 2000
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SOWERS, GARNER, SAYLOR * IN THE COURT OF COMMON PLEAS
ARCHITECTS ENGINEERS, INC.
Plaintiff * OF CUMBERLAND COUNTY,
v. * PENNSYLVANIA
HALLMARK SENIOR COMMUNITIES, * Case No. 00-3466
LLC
Defendant *
* * * * * * * * * * * * * * * * * * * * *
NOTICE OF FILING OF BANKRUPTCY
Hallmark Senior Communities, LLC, defendants, provides
notice of the filing of a petition under Title 11 of the United
States Code on July 21, 2000, in the United States Bankruptcy
Court for the District of Maryland, Northern Division, the
assignment of Case No. 00-59131-SD.to that proceeding, and the
application of the automatic stay of !l 362 of the Bankruptcy
Code to further proceedings in this case.
Gary . Greenblatt
MEHLMAN & GREENBLATT, LLC
1838 Greene Tree Road, Suite 360
Baltimore, Maryland 21208
(410) 486-4790
Attorneys for Hallmark Senior
Communities, LLC
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CERTIFICATION OF MAILING
I HEREBY CERTIFY, that on this ~~t10 day of July, 2000, a
copy of the foregoing Notice of Filing of Bankruptcy was mailed
first class, postage prepaid and sent by Facsimile to:
Thomas G. Collins, Esquire
Buchanan Ingersoll
1 South Market, 3rd Floor
213 Market Street
Harrisburg, PA 17101
(717) 233-0852
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SOWERS, GARNER, SAYLOR
ARCHITECTS ENGINEERS, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 00-3466
HALLMARK SENIOR COMMUNITIES,
L.L.C.,
Defendant
PRAECIPE TO FILE ORDER OF RECORD
To: Prothonotary
Please file of record in the above referenced matter the Order of July 12, 2002 of the
Bankruptcy Court for the District of Maryland dismissing the bankruptcy case ofHallmark
Senior Communities, L.L.c.. A true and correct copy of the Order of July 12, 2002 is attached
hereto as Exhibit "A".
BffiAN INGERSOLL
P OFE IONAL CORPORATION
B : ~~uA) \. ~._~
Thomas G. Collins, Esquire
LD. #75896
One South Market S~uare
213 Market Street, 3 Floor
Harrisburg, P A 171 01
(717)237-4843
DATE: August 13, 2002
.
.
IN THE UNITED 5T A TES BANKRUPTCY COURT
FOR THE DISTRICT OF MARYLAND
lnre
Hallmark Senior Communities, LLC
Debtor
Bankruptcy No.:
00-5-9131-SD
Chapter 11
ORDER. DISMISSING ClIAP,(,liR II CASU
creditors, it is hereby
ORDERED that this case be and it is hereby DISMISSED Creditors are hereby informed
of the termination of the automatic stay of]) USC Section 362(a).
Do< y-1/I,to'7- ",,",;.,.$
UNITED STATES BANKRUPTCY ruDGE
cc0C'n parties in interest
ENTERED
!lU.STmslee
JUL 1 2 200l
CLERl<i8 OFfICe
1I S. IIAN1<RlJPTCY COURT
DISlRtCT OF MARYLAND
BAL TlMOl'lE
054941
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CERTINCATEOFSERVICE
I hereby certify that on this day, I served a copy of the foregoing document by placing a
true and correct copy ofthe same in the United States Mail, First Class, postage pre-paid upon
the following:
Hallmark Senior Communities, L.L.C.
4043 Irene Street
West Mifflin, P A 15122
Kathryn Murdoch, Esquire
Sherrard, German & Kelly, P.C.
210 6th Avenue, 35th Floor
FreeMarkets Center
Pittsburgh, PA 15222
By: ~.S. tu~~
Pamela S. Walker, Esquire
DATE: August 14, 2002
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SOWERS, GARNER, SAYLOR
ARCHITECTS ENGINEERS, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 00-3466
HALLMARK SENIOR COMMUNITIES,
L.L.C.,
Defendant
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
To: Prothonotary
Kindly enter default judgment against Hallmark Senior Communities, L.L.C. and in favor
of Sowers, Garner, Saylor Architects Engineers, Inc.
A copy of the written notice of intention to file this Praecipe for Default Judgment
against Hallmark Senior Communities, L.L.C. is attached hereto as Exhibit "A" and is hereby
certified as being mailed to Defendant Hallmark Senior Communities, L.L.C.
Please assess damages in the amount of $34,061.50, together with interest, and costs of
suit as demanded in the Complaint.
BUCHANAN INGERSOLL
P~SSIONAL CORPORATIO~
B~:~_~~...... ~ ~
Thomas G. Collins, Esquire
LD. #75896
One South Market S~uare
213 Market Street, 3' Floor
Harrisburg, PA 17101
(717)237-4843
DATE: August 13, 2002
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SOWERS, GARNER, SAYLOR
ARCHITECTS ENGINEERS, INC.,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 00-3466
HALLMARK SENIOR COMMUNITIES,
L.L.C.,
Defendant.
IMPORTANT NOTICE
To: Hallmark Senior Conimunities, L.L.c.
4043 Irene Street
West Mifflin, PA 15122
Date: July 29,2002
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
717-249-3166/800-990-9108
BUCHANAN INGERSOLL
P~~NAL CORPORATION
B~:_i~:~~_..~ b l~~~
Thomas G. Collins, Esquire
One South Market Square
213 Market Street - 3 rd Floor
Harrisburg, PA 17101
Attorneys for Plaintiff
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. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mal/piece,
or on the front if space permits.
1. Article Addressed to:
Hallmark Senior Communities,
L.L.C.
4043 Irene Street
West Mifflin, PA 15122
2. Article Number
(Transfer from service label)
PS Fonn 3811. March 2001
V
D. Is delivery address different from item 1?
If YES, enter delivery address below:
o Agent
o Addressee
DYes
o No
3.\. SJ'Vice Type
,)Sl Certified Mail
o Registered
o Insured Mail
4. Restricted Delivery? (Extra Fee)
7001 1940 0001 3207 0630
Domestic Return Receipt
p;.c.
Postage
Certif1ed Fee
Return ReceIpt Fee
(Endorsement RequIred)
Restricted Delivery Fee
(Endorsement Required)
Total Postage & Fees
DYes
102595-01.M-1424
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CERTIFICATE OF SERVICE
I hereby certify that on this day, I served a copy of the foregoing document by placing a
true and correct copy ofthe same in the United States Mail, First Class, postage pre-paid upon
the following:
Hallmark Senior Communities, L.L.C.
4043 Irene Street
West Mifflin, PA 15122
Kathryn Murdoch, Esquire
Sherrard, German & Kelly, P.C.
210 6th Avenue, 35th Floor
FreeMarkets Center
Pittsburgh, PA 15222
BY:P~s;: jA)~
Pamela S. Walker, Esquire
DATE: August 14, 2002
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