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HomeMy WebLinkAbout01-4579Weis Markets, Inc. fOca- l 000 South Second Street Sunbury, Pennsylvania 17801-0471 VS Eichelberger Construction, Inc. 124 West Church Street Dillsburg, PA 17019 In the Court of Common Pleas of Cumberland County Pennsylvania No: q5 74' /e STIPULATION AGAINST LIENS Whereas Weis Markets, Inc., a Pennsylvania Corporation, having a place of business in the City of Sunbury, Northumberland County, Pennsylvania, is about to execute contemporaneously herewith with Eichelberger Construction, Inc., 124 West Church Street, Dillsburg. PA 17019 for General Construction, Electrical, HVAC, Plumbing and Sprinkler work in accordance with plans and specifications (and any other work as may be required by this contractor) upon a lot of land located at 1195 Lowther Road, Camp Hill, PA 17011. Now July 18, 2001 at the time of and immediately before the execution of the principal contract and before any authority has been given by the said Weis Markets, Inc., to the said Eichelberger Construction, Inc. to commence work on the said building or purchase materials for the same, in consideration of the making of the said contract with Weis Markets, Inc., and the further consideration of $1.00 to him in hand paid by Weis Markets, Inc., it is agreed that no mechanics or other liens shall be filed against the building by the Contractor or any subcontractor, nor by any of the material purchased for the erection of said building, or against any structure whatever covered by said contract, the right to file such liens being expressly waived. WITNESS my hand and seal the day and year aforesaid. ATTEST: ATTEST: DATED: 7/24/01 W 01HB-00132 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 . Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne),s for Defendants ANGOLA Do. Nm~ ZIMMer, VS. DONfil.n E. DONOVAN AND JUOY K. DONOVAN, IN THE COURT OF COMMON ]~LEAS{ CUMBERLAND COUNTY, PENNSYLVANIA No. 2001-4744 CML ACTION- LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANTS, DONALD E. DONOVAN AND JUDY K. DONOVAN~ TO PLAINTIFF'S COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4.- 17. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §1029(e). WHEREFORE, the Defendants respectfully pray this Honorable Court to dismiss laintiff s Complaint, and to enter judgment against the Plaintiff and in favor of the Defendants. 18. Paragraphs 1 through 17 are incorporated herein by reference, and made a part hereof as if set forth in full. 19. Plaintiff's claims are ban~d in whole or in pa~ by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylwni~ Motor Vehicle Financial Responsibility Law. WHERENORE, the Defendants mspe~ully pray this Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiff and in favor of the Defendants. Date: November 13. 2001 R~spectfully submitted, LAW F ! C SABA By: it: ~ l~na~d R. Doter, Bs fire Attorney for Defendants Identh~cafion No. 3~125 01HB-00132 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite ~03 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants ANG~.~ DIANNE Z~, VS. DON~Ln E. DONOVAN AND JUDy K. DONOVAN, Dr, rr-~rOANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4744 CIVIL ACTION- LAW JURY TRIAL DEMANDED VERIFICATION We, Donald E. Donovan and Judy K. Donovan, verify that the statements made in the foregoing Answer with N©w patter of D~fendantn Donald E. Donovan and Judy Donovan. to Plgintlt~f's Com_olaint, 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, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolutiun at trial, by the Court, or by continuing investigation and preparation for trial. We understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and we leave the determination of these matters to my attorneys on their advice. We understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unswom falsificati0~s to authorities. Donald E. Donovan Dated: 01HB-00132 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants VS. DONAI.r~ E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS I~ T~ CouRt OF COMMON PLE~s CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4744 CML ACTION- LAW JuRY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendants, Donald E. Donovan and Judy K. Donovan, to Plaintiff's Comolalnt to be served by regular first class mail upon: Date: November 13 2001 Marcus A. Mci(might, III Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Donald R. Doter, Esquire Attorney for Defendants