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HomeMy WebLinkAbout97-05917 1 ., " ~ I ~ j ~ ~ ..t " .\ ~ ~ ~ v '", ~ '.. ..... .... .-; ~ H \!) .::3 " n / ~ ~ ~i / / IN THE COURT OF COMMON PLEAS OF CUMIJERLAND COUNTY, PENNSVI, VANIA CIVIL IJIVISION - LA W UGI UTILITIES. INC. P.O. Bo)( 25148 Lehigh Valley. PA 18002-5148 vs. File No.: f);/- 11/7 (II (if C KINSLEY CONSTRUCTION RD8 York. PA 17402 Civil Action: PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in civil action in the above case, ~ Writ of Summons shall be issued and forwardcd to Sheriff. ROEGER. WALKER. CASSEL & HOLKO 609 Hamilton Mall Allcntown. PA 18101 (6101433-5850 Namc/ Addressrrelcphone Number of Attorney Datc: October 22. 1997 Suprcme Courll.D. Number: 37386 ...*. SUMMONS IN CIVIL ACTION TO: Kinsl~y Construction YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAI~T1FF HAS COMMENCED AN ACTION AGAINST YOU. Date: /0- J- 4 - 17 ~U1lG-L C J! L~ J I by . i i i ! ! I I I 1 .r ,\.I ~ ..... \ - $, ~") ~ ~ ~ - I :::; \f:l '" ."">l \S'o ~ l" Cl ........~" ,~ '\l 3\ d,.......~ '- "1, t._. Jj~ ~ iN ,. !, . SHERIFF'S RETURN - OUT OF COUNTY CASE NOr 1997-05917 P CO""ONWEALTH OF PENNSYLVANIA: COUNTY OF CU"BERLAND UGI UTILITIES INC VS. KINSLEY CONSTRUCTION R. Thomas Kline . 5h.ri~~, who being duly sworn sccording to law, says, that he made a diligent ..arch and inquiry ~or the within named de~endant, to wit: KINSLEY CONSTRUCTION but was unable to locate Them in his bailiwick. He there~ore deputized the sheri~~ o~ YORK COUNTY County, Pennsylvania. to serve the within WRIT OF SU""ON5 On November 24th. 1997 the attached return ~rom . this COUNTY of~ice was in receipt o~ County, Pennsylvania. YORK Sheri~~'s Costsr Docketing Out o~ County SurcharHe YORK CO NTY So answers: 18.00 9.00 2.00 21. 86 - --- >. / - ---.-;..".. .:.... ,.- ....-!'..,~ R. Thomas ~line, Sher1%% e~0.B6 ROEGER WALKER CASSEL HaLKO 11/24/1997 Sworn and subscribed to before me "- this .L'I - day o~ ,'wI>< M (.~~ 19 q., A. D. ..~ ~l I. n. 11.\,1 1',',. Ul,JLJ' M pr'5'thono~ary . . '-UIIIUC'1 &,,&IIU ,-lJUII".', IlG) t.:J:i1ities, Inc. \'~ Kinsley Construction llio, 97-5917 Civil Term 19_ I'ow, Oc t. YOrK 27, 1~~., SHERIFF or Cl'MBERLA:'iD COl~TY, fA do bmb~' d.purlzelbe Sbtrlffor Coual)'lo U.CUle this \Vrlt,lhls deputalloa b.la~ made at tb. request aDd risk orlb. Plaintiff. ~ ..., ... ....., ....'" '"1:,1; rr~ r"T) ~'. 0:' 1"1-11 <::> ." .,., r~<<~~ "".' f'l .&: W - . ~ - SberlfforCumberlaad CouDry. Pa. -oc >c. lj) rn -r. ;:;;s:. ~ Affidavit of Senoice l'ow,.Jjovembel' 6, lqq7 wltbin Summons In Civil Act.ion 19 .ar 12: 45 o.clock P . ~l. sened tbe upon l(inQ1py f"'nnQtr'lIrtinrl ar bybandla~to Tina O'8l'ien, Office ManageI' who accepted artemd cOP~'Ofl~~~r~~rJ;~Ct10n Summons in Civil Action he I' Ihe coo rents tbereof. fol' Kinsley a true aad and mad. kao",n to So :1n5WerS, ~ Al(~~ - Sherlffof YOl'k Coun~, Po, Jack Klingaman, Deputy Sheriff COSTS ~\\l)rn ;and 5ub~crih~d before mothb 21st dJ~ofNovember 9 97 SERVICE MILEAGE AfFlOnn s 18.00 1.86 2.00 NO'.lilt rlpill MHh~.l ,j (; 1',,' ,rv rlllJlir. Vi" ~. C'" ,-. , Uy Cl~tn'ld -. . ':"1: 'I 1'1<'1 s 21.86 Paid IN THE COURT OF COMl\-iON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION . LAW UGI UTILITIES. INC., ) Plaintiff ) ) VS. ) ) KINSLEY CONSTRUCTION, ) Defendant ) NO. 97-5917 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 PERSON ALL Y 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. COURT ADMINISTRATOR 4TH FL CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA \7013 (717) 240-6200 Dated: ~.I 7 .1 y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION. LAW UOI UTILlTIES.INC., Plaintiff No. 97-5917 vs. KINSLEY CONSTRUCTION, Defendant COMPLAINT AND NOW comes the Plaintiff, UOI Utilities, Inc. by and through its counsel, Roeger. Walker. Cassel & Holko, and avers as follows in support of its Complaint against the Defendant in this matter: I. The Plaintiff. UOI Utilities. Inc.. is a Pennsylvania Corporation having its registered offices at Green Hills Corporate Ccnter. Ste. 400. 100 Kachel Boulevard. Reading. Berks County. Pennsylvania. 2, The Defendant, Kinsley Construction. is believed to be either a Pennsylvania Corporation, a Sole Proprietorship, or a Pennsylvania Partnership with a business address of RD#8. York. York County. Pennsylvania 17402. 3. It is believed and therefore averred that the Defendant is in the exca vatinglconstructionlcontracting business. 4. At all times relevant to the within cause of action, the Defendant acted by and through its owners, agents, servants and employees, who were acting within the scope of their employment with the Defendant. S. AI all limes releYillll herehl, Phlinllff was Ihe lIwner lIr c'ertilln Mil' pipelines situated undcr the strcel surface on Winding lIill RlI,1l1 and RlIule I' in tipper Allen TlIwnship, Cuml1erland County, Pennsylvania. 6. On or uhout Noyelllhcr 21, 1l)I)S, ulIIl for MIme lime prillr theretll, l>Cfcllllunt individuully und Ihrough ils owners. ugents und emplllyees. phmnelltll cnguge in construction and/or excuvution at the uforesuid locutilln. 7. At ulltimcs relevunlto the within cause lIf uction, l>Cfendunt fuiledlU comply with its duties a.s set forth in 73 P.S. ~ 17fl, el seq. 8. At all times relcvant to the within cuuse of uclilln, PluintllT cllll1plied with its duties as set forth in 73 P.S. A 17fl, cl sell., and properly Illurkedlhe loculion lIf its fucilities utthe uforesuid locution. 9. Defendunt, hy and through it, lIwners, ugenls, servllnls und employees, conducted excuvation und/or conslruction allhe ufllrclllcntillnedlllculilln ulIIl dUlllugcdthe ufllresuid ga.s pipeline owned hy the Plaintiff. l'uusing it gu, Icuk. 10. Defendant specificully ignorcd Ihe c1eurly murkedlocution of the Pluintifrs fucililies ut Winding Hill Roud und RI. IS,lIpper Allel1 TlIwn,hip, ('ullll1erlund County,Pennsylvania. I \. Defendunt. Ihrough ils owners, ugenls, ,ervunls ulIIl employecs, was negligent in the following aspecls: a. in failing to prlllectPlail1lill's gi... Iinc,; h. in failing to nOlify Plainlill' when DcfcOllunt uncovered Ihe said gas pipeline, and at such time re1luesling ussislance wilh Ihe sume; c. in failing to exercise due care and take all reasonable steps necessary to avoid injury to or interference with Plaintiffs lines while Defendant was working in and around said lines; d. in failing to perform hand-dug test holes to ascertain the precise position of Plaintiffs lines; e. in failing to plan the excavation and or construction to avoid damage to, or minimize interference with Plaintiffs lines; f. in failing to coordinate Defendant's excavation with Plaintiff; g. in failing to consult with Plaintiff; h. in failing to take all reasonable steps necessary to protect Plaintiffs lines once they were exposed; i. in disregarding the Plaintiffs markings showing location of gas lines; j. in damaging said gas pipelines which were in fact actively carrying gas, thereby creating a gas leak and the potential for a catastrophic event; and k. in failing to otherwise use due care under the circumstances as set forth above. 12. By reason of the negligence of the Defendant, Plaintiff incurred the cost to bring emergency personnel to the scene to repair the damage to its lines, as is more specifically set forth in Exhibit "A", attached hereto. at the cost of $10,503.95. 13. Pla:ntiff mailed an invoice to the Defendant on May 15. 1996, a copy of which is attached hereto and marked Exhibit "B", requesting reimbursement for the cost of the damage done. 14. Defendant has failcd 10 rcilllhm'sc "Iuinllff fur Ihe dlllllllgc 10 its lincs. dcspite written requests given to Defendantlln numcrous lli.'ClISinns, liS evidcnccd by Ihc Icttcrs attached hereto and marked Exhibit "C", WHEREFORE. Plaintiff dcmllnds judgment ill its fllvnr IInd against Defendant. Kinsley Construction, in tbe amnuntllf $IO,~()].I)~, with illlerestlhcreoll from November 21. 1995 to the present plus dclay damagcs IIIl1I cmls nf suil. ROEOER, WALKER. CASSEL & HOLKO ~ VERIFICATION I, Jeffrey T. WOodWlICd, Division Claims Administrator, UGI Utilities, Inc" herein states' that the facts set forth in the foregoing complaint are true and correct to the best of my knowledge. information and belief, and that this statement is made subject to the penalties of 18 Pa. C.S.A. ~ 4904, relating to unsworn falsificatic,n to authorities. I~~Y odward Claims Administrator i1ities, Inc. Dated: '1-/7' fer 15 Ut-l. Billing Work Sheet ( IJ '-1 ~()vf.:J"/ )!1.Damages Co Our Facillllll o Services Perlormed 'or Olhers Inv, No. "'111 f" J. 1/11 r. Oamage No. 1 9 j -0 lO 1 " COSI 01 repairs 10 'ur Fac i 11 t h s Oall Prepared 'acililles aC 4/02/96 Address Wind ina Hill Rd, & Rt. 15 UDoer Allen Twn. Oameged byyou on 11/21/95 Bill 10: Name Addrell Kinc;1ey r.nn~trll~r:ian Rn R Prepared By: N ~o:; ~:: UGI Labor Employ.. Name Charles Busler Gary Glessner Alvin S ra ue Rand Robertson Employ.. Classification Tech Svc Tech III Mech III Mech II Mech II Tech Welder Mech II Ollie Williams Robert Richmond Brendan Re olds Jerome Pettis Contractor Costs 1. Sub-Total UGI Labor 2. Taxes & Insurance % of UGI Labor Only ~ ~/4t ii9. !f, Equlpmenl Group 110 Passenger Cars Group 141 Ughl Trucu 15000-9000 lb., Groll WlI Group 143 Heavy TruekslOver 9000 lb.. GrOll WlI I Houri I I , Rile Per Hour XXXlOOOOOOOOl Group 320 Compressors, Mounled Uncluding Vehicie) Group 330 Comprllsors, Portlble Group 360 Trenching Machines Group 370 Agroholl and Backholl Group 360 Welding Machines Uncluding VehICles) I . . I EXHIBIT flAil S.. QUI., Sid. U~ UGI UIlIIIlIS. lnc G.uOI.....Slon 2121 C,lV llnl Road POll Ollico 80. 251'8 l.n,i" ValllY. PA 1800lo51ol1l 16101868,0951 rlllpllono IIU"flll. lilt May IS, 1996 Kinsley Construction RD 8 York. PA 17402 Gentlemen: Please find enclosed two copies of our Invoice No. 6-2-0239 which represents UGI's cost of repairs to our gas main facilities at Winding Hill Road & Rt. 15, Upper Allen Twp. damaged by you on November 21, 1995. We will appreciate your immediate attention regarding payment for these damages. Sincerely, Jeff Woodward Division Claims Administrator JW:kg Enclosures 1 EXHIBIT , I ('GlI U.t-# ( U~: U:...:I!S In: :O~J..J:i': 3~t.u~.tC: -:s:)",:,.a3JI:Z571 '"'U:~; :I:" 19~:,.Z577 II 111" II J. ,AI: ':': .::1:~j Tele:.":""; I Kinsley Construction -, DATE April 25, 1996 RD 8 OUR INV. NO, 6-2-0239 York, PA 17402 OUR O.c. NO. 2-95:0101 L ..J YOUR JOB NO. fiRMS: CoUH To insure proper credit to your aC::Junt,:: use return canary copy at invoice with your reminane.. Cost of repairs to our facilities at Winding Hill Road and Rt. 15 Upper Allen Township damaged by you on November 21, 1995. Labor Labor Overhead Material Other Charges Overhead Contractor's Cost S 2.199.30 439.86 836,25 82.00 570.33 637621 Total Amount Due S10,503.95 " (' LAW OFI'!CES OF ROEGER, WALKER, CASSEL & HOLKO WILLIAM C ROEGER, 1R. JAMES C WALKF.R PAUUNI! M. CASSEL /05EPII A HOlkO JOHN E. KAUNKOS KEVIN ,. KELUHER THE SOVEREIGN BUILDINO 009 HAMILTON MALL ALLENTOWN, PENNSYLVANIA 18101 210 WEST WALNtlT STREET PO aax :ZS9 PERKASIE, PA 1'944.()259 1:115) ZS7.]666 FAX 12151..53.0892 (6101.33~llIlO FAX 16101776,878. ((( "'~~ February 4, 1997 Kinsley Construction R.O. #8 York, PA 17402 RE: UOI Uti/mes, Inc. v. Kins/ey Construction LocaJion oJ'Damage: Winding Hill Road & RI. 15, Upper A//en Township Date of Damage: November 21, 1995 Amount of Damage: $10,503.95 Dear Sir/Madam: Please be advised that I represent UOl Utilities, Inc., who has requested that I pursue an action against you for the damages caused by you on November 21. 1995 at Winding Hill Road & Rt. 15. Upper Allen Township. If you have not already done so, please turn this matter over to your liability carrier and ask that representation from that company to contact me immediately. If you do not have liability insurance, please have one of your representatives contact me so that we can discuss this matter in order to avoid the cost of litigation. If I do not hear from you or your liability carrier within a reasonable period of time, I will file a complaint. Very truly yours, Joseph A. Holko JAH:baf cc: Mr. Jeffrey T. Woodward 5 EXHIBIT A f II C-\' UGI UtlhUts. Inc G.SOIYlSlon 2121 Clry Lme Raid Post Otlle. 80.1; 25148 ltnogll VJllty, PA 1800/\148 16101866,09\1 Ttl.pIlont Uf-I /I(/lIrlll. "" October 7, 1996 Kinsley Construction RD 18 York, PA 17402 Gentlemen: Enclosed is a copy of Invoice 16-2-0239 which was sent to you on May 15, 1996 regarding damages to UGI gas service facilities at Winding Hill Road & Rt. 15, Upper Allen Twp. damaged by you on November 21, 1995. We have not had any response to date from either your firm, or your insurance carrier, regarding payment for these damages. We will appreciate hearing from you regarding this claim so that we may proceed accordingly. Sincerely, Jeff Woodward Division Claims Administrator JW:kg Enclosure . .... . , cause of action complied with the provisions of 73 P.S, 5176, et seq., as set forth in New Matter, infra. 8. Denied. To the contrary, Plaintiff failed to comply with the provisions of 73 P.S. 5176, et seq. in that its facilities were not marked and, in addition, were improperly located, as set forth in New Matter, infra, 9. Admitted in part I denied in part, It is admitted that Defendant, by and through its owners, agents, servants, and employees, conducted excavation and/or construction at the aforementioned location. It is specifically denied that any act or failure to act on its part caused any damage to Plaintiff's gas pipeline or was the cause of any leak of Plaintiff's gas pipeline. To the contrary, Defendant at all times acted in accordance with the provisions of 73 P.S. 5176, et seq. 10. Denied. To the contrary, Plaintiff's facilities were not marked. 11. Denied. It is specifically denied that Defendant, or its owners, agents, servants or employees, were negligent in any respect, and to the contrary it is averred that it at all times acted properly and in a reasonable manner, in accordance with all provisions of 73 P.S. 5176, et seq. a-j. The averments of subparagraphs a through j are denied generally pursuant to Pa.R.C.P. 1029(e). k. Denied. The averments of subparagraph k are prohibited by case law. 2 12. Denied, It is specif ically denied that Defendant was negligent in any respect, and to the contrary it is averred that it at all times acted reasonably, properly, and in accordance with the provisions of 73 P. S. U 76, et seq. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining averments of paragraph 12, and proof thereof is demanded. 13. Admitted. 14. Admitt-ad. WHEREFORE, Defendant demands judgment in its favor and against Plaintiff, UGI Utilities, Inc. NEW MATTER 15. On February 16, 1995, Defendant obtained a serial number from the Pennsylvania One Call System in accordance with 73 P.S. ~180, with regard to the construction project at Winding Hill Road and Route 15 in Upper Allen Township. 16. Plaintiff's facilities were not marked at the site of Winding Hill Road and Route 15. 17. Plaintiff's facilities were improperly located at said site in that the lines were within the right-of-way line of the Pennsylvania Department of. Transportation. lB. Plaintiff, through its agents, servants, and/or employees represented to Defendant that its facilities were laid at least seven feet deep and that the line was clear. 19. Plaintiff's damages may have been caused in whole or in part by the negligence of third persons not presently involved in 3 this action in that the Pennsylvania Department of Transportation did not notify Defendant of a restriction or conflict for the Winding Hill Road/Route lS intersection site. 20. Construction of the new ramp at the Road/Route lS intersection necessitated the Plaintiff's facilities. 21, The costs Plaintiff seeks to recover from Defendant resulted from the required relocation of Plaintiff's facilities. 22. Defendant at all times complied with the provisions of 73 P.S. ~176, et seq. 23. Defendant at all times complied with the provisions of 73 P.S. USO. 24. If it should be found that there was any negligence on the part of Defendant, which negligence is expressly denied, any such negligence was not a proximate cause of any damages to Plaintiff. 2S. Plaintiff's damages were caused in whole or in part by an act of God or by other forces beyond the control of Defendant. 26. If Plaintiff suffered the damages alleged in the Complaint, those damages were caused in whole or in part by the negligence of Plaintiff, and recovery in this action is barred or diminished in accordance with the Pennsylvania Comparative Negligence Act. Winding relocation Hill of 4 WHEREFORE, Defendant demands judgment in its favor and against Plaintiff, UOI Utilities, Inc. T & COHEN, LLC By: nnic uire Supreme Court No. 74453 100 East Market Street P. O. Box 15012 York, PA 17405-7012 (717)B46-B8BB 5 '. APIHO-96 THU 12: 32 P,02 .......ftt!..i.ftCIW %, Xaitb ROle, ~oj.Qt Manage~ of Xinll.y conltruction, Ino., ~ei~i authori.ed to do 10. h.~.Qy v.~i!y that the faot. ..t (o~th in tho fO;AlJoinlJ AD.wer and Now Matter are true and correct to the I:l..t of my knowledge, info=ation and belief. I undultand that fal.. Btatement. harein a~e made ~j.ct to the penalti.. of 18 Pa.e.e.A. 14904 relating to Wi.worn talaif1C1ation to authodt1... tlatec1: ~.a~/9J" . ~~~ RO'. CERTIFICATE OF SERVICE AND NOW, this jr~day of April, 199B, I, Paul W. Minnich, Esquire, hereby certify that I have served a true and correct copy of the within Answer and New Matter by depositing the same in the United States mail, postage prepaid, at York, Pennsylvania, addressed as follows: Joseph A. Holko, Esquire Roeger, Walker, Cassel & Holko 609 Hamilton Mall Allentown, PA 1B101 By: au . Mi , Supreme Court No. 74453 100 East Market Street P. O. Box 15012 York, PA 17405-7012 (717)B46-BBBB 642B4.1 . >- 0_ ;- 0; (0". I - , I~'; ; lJJ' 1 ( ,.. , i.i~ ~ ., ., '" .f ;~.-! S\ ... I] f;;t '. . r;!t , 'id .... il !u. t.:: .... - . II. r.~ 'j 0 0' U FT & COHEN, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UGI UTILITIES, INC., Plaintiff No. 97-5917 vs. KINSLEY CONSTRUCTION, Defendant civil Action - Law PRAECIPE Kindly enter the appearance of Paul W. ~Iinnlch, J::squire, of the law offices of Barley, Snyder, Senft & Cohen, LLC on behalf of Defendant, Kinsley Construction in the above-captioned matter. By: au W. Minnic , Esquire Supreme Court No. 74453 100 East Market Street P. O. Box 15012 York, PA 17405-7012 (717) B46-88BB . ~ AND ~IFICATE OF SERVICE NOW, this ~ day of April, 199B, I, Paul W. Minnich, hereby certify that I have served the within Praecipe by Esquire, depositing the same in the United States mail, postage prepaid, at York, Pennsylvania, addressed as follows: Joseph A, Holko, Esquire Roeger, Walker, Cassel & Holko 609 Hamilton Mall Allentown, PA 1B101 T & COHEN, l.LC -.->"~-....-~-- By: ire Supreme Court No. 74453 100 East Market Street P. o. Box 15012 York, PA 17405-7012 (717)846-88BB 64210.1 ... ~ .:\' ;- - l:";; 'r, (~ ~ ~,~ ~.~~ uJ:-' (.).': ..- \:t' ~t:, ,>.- .j:":! co . -. ~: t l' .)~.:; i.'.-. '" , ~ ','\Irw 0;1' ~, ,,- i".:}o- ;u: :;.~ '0 CO ? " <1" U '- ,. IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION. LAW UGI UTILITIES, INC. ) ) ) ) ) ) ) NO. 97-5917 Plaintiff vs. KINSLEY CONSTRUCTION Defendant PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR TERMINATION TO THE PROTHONOTARY/CLERK OF SAID COURT: You are hereby authorized. empowered, and directed to enter. as indicated, the following on the records thereof: The within suit is Settled. Discontinued and Ended, with costs paid. -1L The within suit is Settled. Discontinued and Ended, IDth Prejudice. and costs paid as to the plaintiffs claim. The within suit is Settled, Discontinued and Ended. without Prejudice, and costs paid, ...** Satisfaction of the Award in the within suit is acknowledged. Satisfaction of Judgment, with interest and costs, in the within matter is acknowledged, *.. \fl * Date: Other 7- j. 9f. COST PAYMENT VERIFICATION I understand that the above action cannot be filed and docketed until all costs have been paid, including Sheriffs costs; and hereby verify that all costs have been paid, I undcrstand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Secti relating to unsworn falsificati to authorities. . >. cr, r:: (,. c: ". . .'- "ih ,?: ')a~ ". . ....--. ~,{ I ... I'; :_. ll..j -- '!9j' ,.... (") -::j (J)C ..~ 0'\ ""Ct) [...J' - N ',; : .111. e-.-. i~'u: _I ;'11(0 -1..'1. ::;, ~~u. ,.. .. tJ. CO ::> 0 '" <.)