HomeMy WebLinkAbout98-03292
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HARTMAN & ASSOCIATES, INC'I
Pial ntiff
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NQIlCE
vs,
CHARLES McCOWN AND PATRICIA
McCOWN, his wife,
Defendants
TO DEFENDANT NAMED HEREIN:
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO, 9(>-.]~9~ Cui C-~.~
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
(717) 249.3166
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HARTMAN & ASSOCIATES, INC"
Plaintiff
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 9f'- ,~;)?~ C'(/II~~1l.fr\
CHARLES McCOWN AND PATRICIA
McCOWN, his wife,
Defendants
COMPLAlNI
AND NOW comes the above. named Plaintiff, by its attorney, Samuel L. Andes, and
makes the following Complaint in this matter:
1. The Plaintiff is Hartman & Associates, Inc. a Pennsylvania Business Corporation
which maintains its principal offices at 2101 Orchard Road in Camp Hill, Cumberland
County, Pennsylvania.
2. The Defendants are Charles McCown, also known as Chuck McCown and Patricia
McCown, his wife, adult individuals who reside at 3 Graystone MannoI' Drive in Camp Hill,
Cumberland County, Pennsylvania.
3. The Plaintiff is, and has been at all time relevant to this action, engaged in the
business of professional civil engineering, surveying, and related engineering and land.
development work.
4, The Defendants own property in Hampden Township, Cumberland County,
Pennsylvania, which they have subdivided and developed.
5. Pursuant to an oral agreement between the Plaintiff and the Defendants, the
Plaintiff provided certain engineering, survey, and related work and services to the
Defendants, to assist Defendants in the sub.division and development of their property.
Pursuant to the oral agreement between the parties, the Defendants agreed to pay
Plaintiff's fair and customary charges for the work and the Plaintiff agreed to perform the
work In exchange for those payments.
6. Plaintiff has well and truly performed its obligations under the oral agreement
with Defendants and performed its work in a good and workmanlike fashion.
7. Although Defendants have paid Plaintiff part of the sums due for the work done
by Plaintiff, Defendants have failed or refused to pay a remaining balance of $2,347.50 for I
work done by Plaintiff, as that work is described in the statement which is attilched hereto I
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and marked as Exhibit A. I
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8. The prices charged by Plaintiff for its work are fair, are Plaintiff's customary I
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charges for such work, are in accordance with the customary charges for such work in the i
Central Pennsylvania area, and are the prices which the Defendants agreed to pay for such ,I
work.
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9. Despite repeated requests and demands by Plaintiff, Defendants have failed to
make payment of the sum due Plaintiff since 7 July 1997.
WHEREFORE, Plaintiff demands judgment against the Defendants in the amount of
$2,347.50, plus interest after 7 July 1997, plus costs of suit.
~QJ2-~
Samuel l.. Andes
Attorney for Plaintiff
Supreme Court 10 # 17225
525 N. 12th Street
Lemoyne, PA 17043
(717) 761.5361