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Home My WebLink About01-5926NORTH MIDDLETON TOWNSHIP, Plaintiff vs. GEMINI SOLUTIONS, LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. OI-sq civIL 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 enter- ing 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. Lawyer Referral Service Cumberland County Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorney for Plaintiff, North Middleton Township NORTH MIDDLETON TOWNSHIP, Plaintiff VS. GEMINI SOLUTIONS, LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW North Middleton Township, Plaintiff, by and through attor- ney, James D. Bogar, Esquire, respectfully represents as follows: 1. Plaintiff herein is North Middleton Township, a Pennsylvania Second Class Township, having its principal office and a mailing address of 2051 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant herein is Gemini Solutions, LLC, a foreign limited liability company, authorized to do business in the Commonwealth of Pennsylvania, having its principal office 845 Fourth Avenue, Suite 212, Coraopolis, Allegheny County, Pennsyl- vania 15108 and a mailing address of 434 Beaver Street, Sewickley, Allegheny County, Pennsylvania 15143. 3. In accordance with a Proposal made by Defendant, said Proposal being dated December 7, 2000 and accepted by Township on December 11, 2000, all of which occurred in Cumberland County, Pennsylvania, Defendant agreed to install at the offices of North Middleton Township, as above-referred to, its "Municipal Office 2000" software program, along with supporting products and, further along with training, maintenance, updates, installation, delivery and set-up. A true and correct copy of the Proposal is attached hereto, marked Exhibit "A" and incorporated herein. 4. Defendant, despite repeated attempts, has not been successful in fully implementing the Municipal Office 2000 software program, along with supporting products, training, maintenance, updates, installation, delivery and set-up, all as warranted and represented by Defendant. 5. Plaintiff, pursuant to the Proposal, paid the amount of $9,500.00 to Defendant. 6. Defendant was obligated to fulfill its obligations with respect to having successfully implemented the installation and functioning of the Municipal Office 2000 software program and related items, all on or before April 1, 2001. 7. Defendant not was successful in implementing the installation and functioning of the Municipal Office 2000 soft- ware program and related items, by April 1, 2001, as warranted, represented and promised. 8. Despite Plaintiff,s repeated demands, Defendant has failed and refused to refund, in full, the amount of $9,500.00 to Plaintiff. COUNT NO. 1 - BREACH OF CONTRACT 9. The averments of Paragraphs I through and including 8 hereinabove are incorporated herein by reference thereto. 10. Defendant did not fulfill its obligations under the Proposal dated December 7, 2000 in that it failed to install its 2 Municipal Office 2000 software program, along with supporting products and, further along with training, maintenance, updates, installation, delivery and set-up, said installation to be completed and the programs to be up and running on before April 1, 2001. 11. To date, the Defendant, despite repeated requests and demands by Plaintiff, has not refunded the amount of $9,500.00. WHEREFORE, Plaintiff demands judgment against Defendant, Gemini Solutions, LLC, in the amount of $9,500.00, plus interest at the lawful rate from April 1, 2001, together with the costs of this action, attorneys' fees and any and all other relief deemed just and appropriate. COUNT NO. 2 - OUANTUM MERIT/IMPLIED CONTRACT 12. The averments of Paragraphs 1 through and including 11 hereinabove are incorporated hereby by reference thereto. 13. Despite repeated requests made by Plaintiff, Defendant has not fulfilled its obligations under the Proposal dated December 7, 2000 and, further, has not made a full and complete refund to Plaintiff in the amount of $9,500.00. 14. By reason of Defendant's inability to satisfactorily install the software program such that it would be up and running on or before April 1, 2001, Defendant impliedly promised to return, in full, the amount of $9,500.00 as paid by Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant, Gemini Solutions, LLC, in the amount of $9,500.00, plus interest at the lawful rate from April 1, 2001, together with the costs of this action, attorneys' fees and any and all other relief deemed just and appropriate. COUNT NO. 3 - UNJUST ENRICHMENT 15. The averments of Paragraphs 1 through and including 14 hereinabove are incorporated herein by reference thereto. 16. Defendant obtained from Plaintiff the amount of $9,500.00 as set forth herein. 17. Defendant did not provide the software programs, nor perform the services set forth and promised in its Proposal of December 7, 2000, all on or before April 1, did not, despite repeated requests, return, of $9,500.00 to Plaintiff. 2001, and, further, in full, the amount 18. As a direct and proximate result of Defendant's refusal to perform its obligations and, further, to refund the amount of $9,500.00 paid to it by Plaintiff, Defendant has been unjustly enriched in the amount of $9,500.00. WHEREFORE, Plaintiff demands judgment against Defendant, Gemini Solutions, LLC, in the amount of $9,500.00, plus interest at the lawful rate from April 1, 2001, together with the costs of this action, attorneys' fees and any and all other relief deemed just and appropriate. Attorney for-~laintiff, North Middleton Township Dmemb~r ?, 2000 DeetBob: '-~'"' .,',,,,,-,,,=~t~om~l~l~to~town~M. Unlike W'md - ~-- .----r- nmows enwronment , Our pfogrmn~ were deigned ~d writte~ for · _n~_ 2000. ~S ~ ~,, ,~ ~ m oM ~m~ ~o~t' ............................ ~_~?~.~~ ......................................................................... 1. *'Financial Office 2000". This system will be $5,000 EXHIBIT "Aw · 2. Tekcommnuic. tfions. Soflware. I~ Anywhere provide~ a tdecomm~nicofio~ link bY wbkh ~ system can b~ accessed and tim runo~ for update ~ ~'°1~ ~ cle~a~ to '---'~ the ~ff~m m perform thor du~ie~ from a remora sir~ if ~2e nell a~sc.~ $ 1S0 Training- Two (2) days oft~-;~ for ctum~ e~yee~ in fl~c use of co~?,~'~_ ba~d on & nm~ally conve~ent mhedul~ mm~g pboae suppoW Additlon~l trehi~ cea be provided, ifnece~-y. $~25 e~ hour, in. ding ~revel time. e~ ~be ~ost of 4. ~5.M~te.n~uc~ ~nd Upda~. of the Gea~i $olu6on~ solacere es Io~ es it b in TOTAL SYSTEM ]PRIC~ -~le~o~~~.P~ ~ ~ on your s~stcm prior ~o the ~he s~em price reflec~ 2000 priciog which will' be effective through 2001 with ..c~t Oem~i Solution~ c~n be~in ivstall~ within ~-- ,~- ~ ~'~ ~ Y~ ~'~- Pa~ ~ f~ b~ ~e COD covered, attached a copy of our 2001 agreement m g~ve you an idea of what h 'No~h kfiddleton Tow~gp Gemini Solutions is proud to offer your unmicipa~y the fme~t tools ~h~ modem tedmolo~y ,,~t-~ av'~lable. Ple~.se call R'you have m~y questiom or need ~ay clariF~a~om o~ t~ ~ We look fnrwsrd tn .h~in8 ~rom you. Sincerely, I verify that the statements made in this Complaint are true and correct. I understand that unsworn statements herein are made subject to the penalties of 18. Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: October 12, 2001 NORTH MIDDLETON TOWNSHIP Deb6rah A. Stef~'ee Township Manager NORTH MIDDLETON TOWNSHIP, Plaintiff vs. GEMINI SOLUTIONS, LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW G civil 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 enter- ing 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. Lawyer Referral Service Cumberland County Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 James D. B6g~,~Esquire Pa. I.D. No. ~k~75 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorney for Plaintiff, North Middleton Township ]'RUE COPY FROM RECX)RD in Testlm~y wl~mOl, I h~l un~ !1I ~J ~ Thls_.,.~::~ day ~~ · ~ ..... ~ ~~ ' u NORTH MIDDLETON TOWNSHIP, Plaintiff vs. GEMINI SOLUTIONS, LLC, Defendant IN THE COURT OF COMMON P?.R~S OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL COMPLAINT North Middleton Township, Plaintiff, by and through attor- ney, James D. Bogar, Esquire, respectfully represents as follows: 1. Plaintiff herein is North Middleton Township, a Pennsylvania Second Class Township, having its principal office and a mailing address of 2051 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant herein is Gemini Solutions, LLC, a foreign limited liability company, authorized to do business in the Commonwealth of Pennsylvania, having its principal office 845 Fourth Avenue, Suite 212, Coraopolis, Allegheny County, Pennsyl- vania 15108 and a mailing address of 434 Beaver Street, Sewickley, Allegheny County, Pennsylvania 15143. 3. In accordance with a Proposal made by Defendant, said Proposal being dated December 7, 2000 and accepted by Township on December 11, 2000, all of which occurred in Cumberland County, Pennsylvania, Defendant agreed to install at the offices of North Middleton Township, as above-referred to, its "Municipal Office 2000" software program, along with supporting products and, further along with training, maintenance, updates, installation, delivery and set-up. A true and correct copy of the Proposal is attached hereto, marked Exhibit "A" and incorporated herein. 4. Defendant, despite repeated attempts, has not been successful in fully implementing the Municipal Office 2000 software program, along with supporting products, training, maintenance, updates, installation, delivery and set-up, all as warranted and represented by Defendant. 5. Plaintiff, pursuant to the Proposal, paid the amount of $9,500.00 to Defendant. 6. Defendant was obligated to fulfill its obligations with respect to having successfully implemented the installation and functioning of the Municipal Office 2000 software program and related items, all on or before April 1, 2001. 7. Defendant not was successful in implementing the installation and functioning of the Municipal Office 2000 soft- ware program and related items, by April 1, 2001, as warranted, represented and promised. 8. Despite Plaintiff's repeated demands, Defendant has failed and refused to refund, in full, the amount of $9,500.00 to Plaintiff. COUNT NO. i - BREACH OF CONTRACT 9. The averments of Paragraphs 1 through and including 8 hereinabove are incorporated herein by reference thereto. 10. Defendant did not fulfill its obligations under the Proposal dated December 7, 2000 in that it failed to install its 2 Municipal Office 2000 software program, along with supporting products and, further along with training, maintenance, updates, installation, delivery and set-up, said installation to be completed and the programs to be up and running on before April 1, 2001. 11. To date, the Defendant, despite repeated requests and demands by Plaintiff, has not refunded the amount of $9,500.00. WHEREFORE, Plaintiff demands judgment against Defendant, Gemini Solutions, LLC, in the amount of $9,500.00, plus interest at the lawful rate from April 1, 2001, together with the costs of this action, attorneys' fees and any and all other relief deemed just and appropriate. COUNT NO. 2 - OUANTUM MERIT/IMPLIED CONTRACT 12. The averments of Paragraphs 1 through and including 11 hereinabove are incorporated hereby by reference thereto. 13. Despite repeated requests made by Plaintiff, Defendant has not fulfilled its obligations under the Proposal dated December 7, 2000 and, further, has not made a full and complete refund to Plaintiff in the amount of $9,500.00. 14. By reason of Defendant's inability to satisfactorily install the software program such that it would be up and running on or before April 1, 2001, Defendant impliedly promised to return, in full, the amount of $9,500.00 as paid by Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant, Gemini Solutions, LLC, in the amount of $9,500.00, plus interest at the lawful rate from April 1, 2001, together with the costs of this action, attorneys' fees and any and all other relief deemed just and appropriate. COUNT NO. 3 - UNJUST ENRICHMENT 15. The averments of Paragraphs i through and including 14 hereinabove are incorporated herein by reference thereto. 16. Defendant obtained from Plaintiff the amount of $9,500.00 as set forth herein. 17. Defendant did not provide the software programs, nor perform the services set forth and promised in its Proposal of December 7, 2000, all on or before April 1, 2001, and, further, did not, despite repeated requests, return, in full, the amount of $9,500.00 to Plaintiff. 18. As a direct and proximate result of Defendant's refusal to perform its obligations and, further, to refund the amount of $9,500.00 paid to it by Plaintiff, Defendant has been unjustly enriched in the amount of $9,500.00. WHEREFORE, Plaintiff demands judgment against Defendant, Gemini Solutions, LLC, in the amount of $9,500.00, plus interest at the lawful rate from April 1, 2001, together with the costs of this action, attorneys' fees and any and all other relief deemed just and appropriate. Date: October 12, 2001 Ja~nes D~ B~r, E.s.q~.ire Attorney f~JPlalntlff, North Middleton Township DearBob: 2000 - B~ Pri~ To~ lrmm~isl ~ ~OO0 lMce $5,000 EXHIBIT Not, th Middletoa Township Page 2 2. Yele~ommun~on~Software. PC Anywhe~c providu a tdecoamurdcetio~ link bY wb~ your sYStem can b~ accessed ~td mn remote fur ulxi~ ~u~f 4. Main .t.e~mn~ and Updates. of the Gemini $olution~ software ~ Ion8 a.t it is in TOTAL SYST~[ ~RICE tn..qallat~m ofti~ ~ software.. ,,- ~,~- ~7~tem prior zo me can .t~?n mstal~n w~dn thirty (30~ da. of ..... · . ~ ~ ~ya xcctnp[O~. ngnea Pfo~ml fi'om your mun~pality. Pa.vment m'm ~or th balance tre COD North Middleton T°wnggp ~ Solutions is proud to offer your nmnkipalit~ g~e finest tools that modern tecimology ,,~'es available. PleISe call ii'you have any questions or need any clari~csti,~ns o~ ~ prolxts~. We look ixward to h~a~m~ t, om you. ' Via Fax and US Mail with euclosures VERiFiCaTiON I verify that the statements made in this Complaint are true and correct. I understand that unsworn statements herein are made subject to the penalties of 18. Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: October 12, 2001 NORTH MIDDLETON TOWNSHIP D~te~fe~~z Township Manager SHERIFF'S RETURN - C~SE NO: 2001-05926 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH MIDDLETON TOWNSHIP VS GEMINI SOLUTIONS LLC OUT OF COUNTY R. Thomas Kline duly sworn according to law, says, that he made a diligent and inquiry for the within named DEFENDANT to wit: GEMINI SOLUTIONS LLC , Sheriff or Deputy Sheriff who being search and but was unable to locate Them in his bailiwick. deputized the sheriff of ALLEGHENY County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On November 13th , 2001 , this office was in receipt of the attached return from ALLEGHENY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Allegheny Co 32.00 Notary 3.00 72.00 11/13/2001 J~kMES BOGAR R. tThomas Klih'~e- Sheriff of Cumberland County Sworn and subscribed to before me this 2~-- day of ~2~,~/ A.D. 7 ; P~hthono~ar~ / ' Iff The Court of Common Plea, s of CumberlanOA.Coun~v~cl~nnsylvania North Middleton Township · rv ~ j . ~i ~lutions ~ ~ow, ~tober is, 2001 , I, SHE~FF OF C~BE~ CO~TY, PA, do hereby deputize the Sheriff of Allegheny County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA within Affidavit of Service ,20¢,...~/ , at ~]~t'~-~)'clock __ served the upon at by handing to a copy of the original and made known to Sworn and subscribed before me this d_ay of ,20 --~..0V 0 42001 '' My~Comm!~ - ' NOTARIAL SEAL - Sheila R. O'Brien, Notary Public C~y of Pittsburgh, County of Allegheny s~si..,.o,~n E~!re.~s~,,~une 19, 2004~J So answers, Sheriff of COSTS s~,RwcE 53,,U3 MILEAGE AFFIDAVIT the contents thereof. JERRYE,~NLON ,~Lq~~RTMENT NORTH MIDDLETON TOWNSHIP, Plaintiff vs. GEMINI SOLUTIONS, LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAi~D COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-5926 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT TO: Curt Long, Prothonotary Cumberland County Please reinstate the Complaint filed in the above-captioned matter. Date: December 21, 2001 ~Z~ ~'~F~' ire 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorney for Plaintiff, North Middleton Township SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-05926 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORTH MIDDLETON TOWNSHIP VS GEMINI SOLUTIONS LLC Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT GEMINI SOLUTIONS LLC but was unable to locate Them in his bailiwick. deputized the sheriff of ALLEGHENY County, serve the within COMPLAINT & NOTICE , Sheriff or Deputy Sheriff who being says, that he made a diligent search and , to wit: He therefore Pennsylvania, to On January 25th , 2002 , this office was in receipt of the attached return from ALLEGHENY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Allegheny Co 31.50 Notary 3.00 71.50 01/25/2002 JAMES BOGAR So answers R. l~homas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 30 ~ day of~ /- ! ~oD~ A.D. ~ / Prothonot~r~ ' In The' CouYt of Common P4eas of Cumberland County, nia North Middleton Township VS. Gemini Solutions, LLC SERVe: Gemini /Solutions, LLC hereby deputize the Sheriff of 01 5926 civil , I, SHERIFF OF CUMBERLAND COUNTY, PA, do Alle~eny County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Now, within upon at by handing to Affidavit of Service l- ':/- 02. ,20 07-r. at It, S o'clock ~ M. served the H0 _Service mao~ a and made ka~own to copy of the original the contents thereof. So answer, COSTS' S~RWC~ MILEAGE AFFIDAVIT Sheriffof ~ ' County, PA NORTH MIDDLETON TOWNSHIP, Plaintiff vs. GEMINI SOLUTIONS, LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-5926 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT TO: Curt Long, Prothonotary Cumberland County Please reinstate the Complaint filed in the above-captioned matter. Date: March 1, 2002 J~e~%. ~g~r, Esquire Pa. I.D..~_19475 1 West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorney for Plaintiff, North Middleton Township NORTH MIDDLETON TOWNSHIP, Plaintiff vs. GEMINI SOLUTIONS, LLC, Defendant TO: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-5926 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Curtis R. Long, Prothonotary Cumberland County Kindly enter Judgment in favor of North Middleton Township, Plaintiff, and against Gemini Solutions, LLC, Defendant, for want of an Answer and assess to North Middleton Township, Plaintiff, damages as follows: Amount claimed in Plaintiff's Complaint $ 9,500.00 Interest (6% per year): From 4/1/01 to 4/19/02 $ 599.67 TOTAL $10,099.67 It is certified that a written Notice of Intention to file this Praecipe was mailed (delivered) to Gemini Solutions, LLC, Defendant, against whom this Judgment is to be entered, after the default occurred and at least ten (10) days prior to the date of filing of this Prae- cipe. The Notice of Intention to file the within Praecipe, along with the Certificate of Service, is attached hereto and incorporated herein. Date: April 19, 2002 B JA~ES ~. B~G~R, ESQUIRE Pa. I.D. NoX~J19475 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorney for Plaintiff North Middleton Township Judgment is hereby entered and damages are assessed as/gbove. Cu~r~is R. Long ~ Prothonotary NORTH MIDDLETON TOWNSHIP, Plaintiff vs. GEMINI SOLUTIONS, LLC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-5926 CIVIL TERM TO: Gemini Solutions, LLC 605 Beaver Street Sewickley, Pennsylvania 15143 DATE OF NOTICE: April 4, 2002 IMPORTANT NOTICE 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: Lawyer Referral Service Cumberland County Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 Pa. I.D. Nd~ 1%475 One West Ma~'r~treet Shiremanstown, PA 17011 (717) 737-8761 Attorney for Plaintiff North Middleton Township CERTIFICATE OF SERVICE I, James D. Bogar, Esquire, hereby certify that I am this day serving the foregoing Notice as required by Pa. R.CoP. 237.1 upon the following named individuals this day by depositing same in the United States Mail, Certified Mail, Return Receipt Requested, at Shiremanstown, Pennsylvania, addressed as follows: Gemini Solutions, LLC 605 Beaver Street Sewickley, Pennsylvania 15143 Date: April 4, 2002 ~-J~e~ D. B6~ Esquire