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Home My WebLink About01-03704 . ~.".---, '. ;-',0.-;-' ;~ ,- d.--c < .'~-- -'--'0-:,,,,,---:&:.\1..': ~'~;\", IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GEORGE M, HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs v. GLENN A. LAYSON, SR. And LAYSON'S HOME IMPROVEMENTS, INC. Defendants No. 01-3704 - Civil NOTICE TO PLEAD TO: George M. Hoffman and Claire M. Hoffman, Plaintiffs You are hereby notified to plead to the enclosed New Matter and Counterclaim within twenty (20) days from service hereof or a default judgment may be entered against you. Law Offices ofVanOrmer & Associates B . RlC . GR ATTORNEYFO EFENDANTS 344 South Market Street Elizabethtown, P A 17022 (717) 367-6831 - - ~. ,.,'-; - i .-1,_ ,.' ~-.:-;.:;~ .'~' -~,- '1,ll--' l;lfhlc-;'. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GEORGE M, HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs v. GLENN A. LAYSON, SR. And LAYSON'S HOME IMPROVEMENTS, INC. Defendants No. 01-3704 - Civil DEFENDANTS' ANSWER. NEW MATTER AND COUNTERCLAIM 1. Admitted. 2. Admitted in part and denied in part. It is admitted that Glenn A. Layson, Sr. is an adult individual. It is admitted that Layson's Home Improvement, Inc., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its offices and principal place of business at 440 Sheep Bridge Road, York Haven, York County, Pennsylvania 17370. It is specifically denied that Glenn A. Layson, Sr. is trading as Layson's Home Improvement, Inc. By way of explanation, Glenn A. Layson, Sr. is President and a shareholder of Layson's Home Improvement, Inc., however, the entity known as Layson's Home Improvement, Inc. is a duly recognized corporation. 3. Plaintiff is without sufficient knowledge, information or belief to form an opinion as to the truth of the matter asserted and strict proof thereof is demanded at the trial of this matter. 4. Admitted in part and denied in part. It is admitted that Plaintiffs entered into a contract with Layson's Home Improvements, Inc., on or about November 19, 2000. The Defendants aver that the contract speaks for itself, however, it is specifically denied that Glenn A. Layson, Sr., _- I - ~ , I 'i ,'~ ~ ."'h~_;: individually, entered into any contract with the Plaintiffs. Furthermore, it is specifically denied that Layson's Home Improvement, Inc. agreed pursuant to the contract to "reconstruct and remodel" the master bathroom. By way of explanation, the contract indicates that Layson's Home Improvement, Inc. will "Gut entire upstairs master bathroom, Reinsulate ceiling." Layson's Home Improvement, Inc. specific,uly avers that reconstruction of the master bathroom would not include tearing down and rebuilding exterior walls which was not included in the price of the contract. As Layson's Home Improvement, Inc., never removed the exterior walls, the frame which was originally out of plumb, remained in said condition. Defendant acknowledges that the original cost quoted pursuant to the contract was $10,850.00, "plus" costs for fixtures for plumbing, electric, tile, rock board, cabinets and countertops which were to be paid for by the Plaintiffs pursuant to paragraphs 11 and 12 of the contract dated October 2, 2000.. 5. No response is required, as the change order/modification ofthe contract speaks for itself. 6. Admitted. 7. Admitted. 8. Denied as a conclusion of law to which no response is required. To the extent a responsive pleading is required, Defendant, Glenn A. Layson, Sr., specifically avers that he never performed work pursuant to the contract nor was he required to do so in his individual capacity. Layson Home Improvements, Inc. specifically denies that the work was performed negligently and believes and therefore avers that all work was performed in a proper and workmanlike manner, and in response thereto, avers the following: ~ , " , --I. ,l-_ "" -"-"..... , d A. The floor was not level at the commencement of the work by Layson's Home Improvement, Inc., and the contract did not include leveling the floor. In the event Layson's Home Improvement, Inc. leveled the floor, a step up would have been required from the bedroom to the master bathroom thereby creating a hazard. Plaintiffs were advised that the floor would be the same as before and agreed to accept this condition without modification. B. During the time Layson's Home Improvement, Inc, , worked on Plaintiffs' residence, a portion of the scabbed board used by Layson's Home Improvement, Inc., broke lose, however, the board was repaired. At the time Layson's Home Improvement, Inc. completed the work at Plaintiffs' residence, there were no cracks, and any cracks which have occurred since that time, would be beyond the knowledge, information and belief of the Defendant. Furthermore, Defendant believes and therefore avers that any such cracks would not be caused by work they performed, but rather as a result of the prior floods which have hit the Plaintiffs' residence on more than one occasion, C. At the outset of the work by Layson's Home Improvement, Inc., and as stated previously, plumbing the walls was not part of the contract. In order to make the walls plumb, Layson's Home Improvement, Inc. would have been required to remove the exterior walls, including, but .not limited to, the bathroom, main bath, hall, and master bedroom walls. D, and E. In order to properly seal the tile grouting, Layson's Home Improvement, Inc., through its employees, applied excess sealer to the grout which later would have been removed with a special solvent. Prior to employees applying the solvent to remove the excess grouting, Claire M. Hoffman scrubbed offthe excess sealer, thereby causing damage to the '.,-- '-,-, -;" '" -L ;,-",;C;f,,' ~z grout and tile. Ms. Hoffman refused to inform Mr. Layson of the type of cleaner she used, and therefore, Layson was unable to determine whether the solvent would be effective to resolve the problem. In addition to Ms. Hoffman causing damage to the grout and tile, she prevented Layson's Home Improvement., Inc., from solving the problem with the solvent as stated. Defendants are without sufficient knowledge, information or belief to form an opinion as to whether the damage is permanent as Layson's Home Improvement, Inc., was never provided the opportunity to apply the solvent that removes the excess sealer from the tile. F. It is acknowledged that the shower floor and seat slope, however, Layson's Home Improvement, Inc., had agreed to repair the slope prior to completing the job. Plaintiffs prevented Layson's Home Improvement, Inc., from accessing the property to complete the job. H. Plaintiffs ordered and purchased the shower stall, therefore, any problems with installation would be due directly to the Plaintiffs improperly measuring for and ordering the shower stall. Defendant believes and therefore avers that a shower frame can be made for the shower, however, believes the Plaintiffs failed to obtain the proper frame to complete the job in a proper manner. 1. Plaintiffs had agreed to complete the painting of the entire job pursuant to the change order dated January 29, 2001, and signed February 7, 2001. Defendants believe and therefore aver that the door frame and trim would be the responsibility of the painters/owners. 9. Admitted. 10. Admitted in part and denied in part. It is admitted that the Plaintiffs' credit card was debited $2,664.00 by ProSource, however, it is specifically denied that this was done at the 'l. , r-- :";_:';"- ,~ -_,:,~fp" _",__:__ -~-"~"'- request of either Defendant. Mr. Layson had placed two (2) job orders through ProSource and ProSource erroneously charged the second job order to the Plaintiffs' credit card. As soon as the error was discovered, Defendants believe and therefore aver that the proper credit was applied to Plaintiffs' credit card. Defendants specifically deny that the materials in question were in any way damaged beyond repair by any acts or omission of the Defendants. II. Defendants acknowledge that $106.85 was charged to Plaintiffs' account for tools, however, Mrs. Hoffinan specifically agreed that she would pay for these additional items. 12. Denied. Layson's Home Improvement, Inc., through its agents/employees, attempted to contact the Plaintiffs on a number of occasions to discuss any perceived problems, however, the Plaintiffs failed to respond to their agents/employees. 13. Denied as a conclusion of law to which no responsive pleading is required, and strict proofthereof is demanded at the trial of this matter. WHEREFORE, Defendants respectfully request that Glenn A. Layson, Sr., be dismissed from this lawsuit as an improper party, and request that judgment be entered in favor of Layson's Home Improvement, Inc., and against Plaintiffs. NEW MATTER 14, Paragraph Nos. 1 through 13 are incorporated herein as though fully set forth. 15. Defendant, Glenn A. Layson, Sr., did not enter into a contract with the Plaintiffs and has no individual liability to them. "- ,- ~~'" ~-'" '",'--" . ,,-,-'-';,L -"Ji._' 16. Layson's Home Improvement, Inc., completed all work in a proper and workmanlike manner. 17. Any damage to Plaintiffs' property was directly due to their own negligence or other circumstances beyond Defendant's control. 18. The Plaintiffs prevented the Defendant, Layson's Home Improvement, Inc., from completing the final phases of the contract. COUNTERCLAIM 19. Paragraph Nos. 1 through 18 are incorporated herein a though fully set forth. 20. On April 6, 2001, Layson's Home Improvement, Inc., prepared a proposal for additional work to be performed at the Plaintiffs' residence. 21. The proposal was accepted by Claire M. Hoffman on April 11 , 200 I. A true and correct copy of said contract is attached hereto, incorporated herein by reference, and marked Exhibit "A", Layson's Home Improvement, Inc., performed the services set forth in the contract in a proper and workmanlike manner. 22. Plaintiffs have refused to remit payment for the work completed, despite having received reimbursement from Layson's Home Improvement, Inc.'s insurance company. 23. Layson's Home Improvement, Inc., also completed a substantial portion of the cOntracts dated October 2, 2000 and January 29, 2001, and Plaintiffs have prevented Layson's Home Improvement, Inc., its agents and representatives from completing the work. Layson's Home --,." "I"" .:' ;,-,~'" ',. "'- ~~k,''- Improvement, Inc., believes $1,318.75, remains due pursuant to the two (2) original contracts, plus $2,010.00, provided by the third (3rd) contract entered into by the parties. 24. The contracts entered by the parties also assess attorney fees, interest and costs against the Mr, and Mrs. Hoffman in an amount to be proven at the trial of this matter. WHEREFORE, Defendant, Layson's Home Improvement, Inc., respectfully requests This Honorable Court enter judgment against George M. and Claire M. Hoffman in an amount not in excess of $25,000.00, plus interest, attorney fees and costs of this suit; an amount within the jurisdiction of arbitration under the local rules of court. RlC 1. GR MEN, JR. Attorney for Defe dants 344 S. Market Street Elizabethtown, P A 17022 LD.#48990 (717) 367-6831 ".......-"'~-~ _J __ " -"----"""'Il:I-'!h' VERIFICJl.TTQN I, GLENN A. LAYSON, SR., President of LA YSON'S HOME IMPROVEMENT, , ii INC., verify that the statements made in the foregoing Apswer. New Matter and Counterclaim, are :; true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification j:o authorities, Dated: D121 / (j / / ~c~/ O!l.ENN A LAYSON, SR. . President of Ll!,Yson's Home Improvement, Inc. ""~ c. \ : _ _ )., ,')'; ")" ... ~......,' . ., ~ - '. ii<;-' - ~. '~-"""'[" . . Layson's Home Improvement Inc. ~ 440 Sheep :Bridge Road York Haven, PA 17370 Telephone (717) 93U340 Fax (717) 932-0885 Proposal submitted to: Proposal for Contract Wod::Loca:tion: Cootract Infurmatioo: George or Clare HotTman 820 COl\odguinet Dr Camp aiD, P A 17011 Phone (717) 737-4779 Work Other Township: Attention 'v.J._ (1l.';I'f> "n 2- - 7f$9 Proposal number 1058 Date: 04/0612001 Architect Start Date ********************************************************************************************************************, We hereby propose to furnish all material and perfOITl'\ all the labor necessary furtbe installations of the fullowing items listed: I. Remove the rest of the damaged drywall from kitchen ceiling. $150.00 2. Remove wet insulation in ceiling. S100.00 3, Install new 1/2 drywall. 16' X 16' area. Labor and material $430.00 4, Install 3 coats of paint. Labor and material $180.00 5. Install new oak crown around edge of room 68 LF. $450.00 6. Dumping fees $100.00 7. Labor for tear down and removal of ceiling day of back up of pipe. 6 Hours 2 men At 40.00 an hour ~ $480.00 8, Clean up and tarp replacement. $120.00 The total cost of the job will be $2,010.00 With payments to be made as follows: Material Down: $1,005.00 Upon completion of the job an amount of $1,005.00 is due. All material is guaranteed to be specified and the above described work to beperfonned in accordanoewith the drawings andforspecificarionssubmitted for said work and will be done in aworlananlike m~. Payment shall be due upon agreement above. If ovmer should filii to make inunediate payment on asreement. an mten:sl mte of eighteen (18%) pm:mt per annmn will be chmged on any unpaid balance accruing from the date of substantial completion of ~ mentioned job. Also the conlnlclor is entitled to court oosts. including alIomey fees. and damages as permitted by law, for any breach thereafter by the ownerfcustomer. Any 8Iterations 01 deviations from the above specifications and drawing; ordesc:riptions ofwmk\Wich cimse5 extra cost to be incurml shaI1 be added to the alxwe price of1hejoh. Further, any such aItendions ortbiations shaI1 be in writings;gned by thecustomerorhi<;/heragent and dated. This or any agn:ement madc between thepartiesshannotbeconsiden:d~ bytbe~intheeventofstn'"kes,accidenlsorotherdelaysbeyond controloftbe contractor. Owner/aJstomer is to carry fire. tornado and other necessary insurance upon above work. The contractor\M.Dcarry PublicLiabJlity Insuram:e. Workmen's compensation shall be borne by sub- conlnlclolS. This Proposal forcontract may be withdmwn by us ifnot accepted within (3) days of signed date of contractor. Upon signing this contract Layson's Home Improvements is allowed to have a sign posted in 1heyard up to 30 days aftereompIetion ofthejoh. Respectfully Submitted: Glenn A. Lavson. Sr. 0410612001 ********************************************************************************.******************************** Signature ACCEPTANCE OF PROPOSAL to begin work as specified Payment shall be made as outlined above. Date '# J; / The above proposal fur work. material, and prices is understood and Signature: Date Page 1 of! ~ ~ , ',,'," ,-C', .-1 -"-. , '''''~-'"''''''~'' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GEORGE M. HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs v. GLENN A. LAYSON, SR. And LAYSON'S HOME IMPROVEMENTS, INC. Defendants No. 01-3704 - Civil CERTIFICATE OF SERVICE ..;<.. AND NOW, this ,:1C day of ~ ,2001, I Dawn M. Bawell, Paralegal, of the Law Offices of VanOrmer & Associates, Attorneys for Defendants, hereby certify that I this day served the within Answer, New Matter and Counterclaim, upon the persons indicated below, by depositing a true and correct copy of the same in the United States Mail, postage prepaid, at Elizabethtown, Pennsylvania, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: William A. Addams, Esquire Attorney for Plaintiffs 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013 LAW OFFICES OF. V ANORMER & ASSOCS. BY: #~ if i30//~ ;i('- <~i:-'<'t&ir~.r'jl_~~~~...~~~f>'~:E[,:-l ,~~.,.'-*C>Cl'lli'",,~;~~,~fmjfi""!llJ9-'''''~''''''''''''if!!>~~ir'~-- I --, 1"_~I!tIf=:" _J!',~~~". -'.7",'" _~y~_"",,,_ "' "'-'"~ ~,_,o~~ _~'."~~~', ". _.' ,,'. _",,, ,M"'_e"_~ _ _~ _ ,,_~<^,,"~~,_ ,~ { "",.'" ~ . ,- ,~~"" ^- ~ - -., ~~ -- ..> c\ ~; ,~~'"' '-":;.1 I I Ii 1..11 I I' II I I ) ,--'- " , I I t ~,": -< "-~ ~. -" ~-- ---,'--'h- - . ""'- "., ';;'- .'+ -~ -'," >~:__r:-- _>:';: "'" ,-.~ ."'Ai , ~~- - - "iflirl1",,-i- GEORGE M. HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. OI-J707' CNIL TERM v. GLENN A. LAYSON, SR. and LAYSON'S HOME IMPROVEMENT, INC: 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 Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 - <' ~ - . -- - - ,- ",-' . " ;', ,;: - -~,-~,:-,'.L~';.;;;' ,'- -: ~, "'~,d GEORGE M. HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO.01-370If, CMLTERM v. GLENN A. LAYSON, SR. and LAYSON'S HOME IMPROVEMENT, INC: Defendant COMPLAINT AND NOW, come the Plaintiffs, George M. Hoffman and Claire M. Hoffman, by their attorney, William A. Addams ofthe Law Office of Michael J. Hanft, and file the following Complaint: I. The Plaintiffs are George M. Hoffman and Claire M. Hoffman, adult individuals residing at 820 Conodoguinet Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendants are Glenn A. Layson, Sr., an adult individual tla Layson's Home Improvement, Inc., a corporation organized and existing under the laws ofthe Commonwealth of Pennsylvania, with its offices and principal place of business at 440 Sheep Bridge Road, York Haven, York County, P A 17370. 3. The Plaintiffs are the owner ofthe real estate and dwelling house in which they reside. 4. On November 19, 2000 Plaintiffs entered into a contract with the Defendants, a copy of which is attached as Exhibit "A", whereby the Defendants would reconstruct and remodel the master bathroom at a cost of $1 0,850 plus fixtures for plumbing, electric, tile, rock board, cabinets and counter tops. 5. On February 7, 2001 Plaintiffs accepted a change order dated January 29, 2001, a copy of which is attached as Exhibit "B", adding $1,725 to the job. -",,". " ., ,-,' '. c'" -., . ~'-,,:..;,,;', j-" ,.- , ,,' '''''1>;g~; 6. The Defendants began the work on or about January 15, 2001. 7. The Defendants contracted to perform the job in a workmanlike manner. 8. The Defendants negligently performed the work and failed to perform in a workmanlike manner in that: A. The floor was not level. B. The floor was not properly supported and has given way resulting in numerous cracks. C. The walls were not plumb. D. The grout for the tile was applied in a sloppy manner. E. The tile was permanently damaged in not being cleaned after the sealer was applied. F. The shower floor slopes to a comer and does not completely drain resulting in a pool of water. G. The seat in the shower slopes to the comer and does not completely drain. H. The shower base is not level so the shower surround cannot be installed properly. 1. The door frame and trim was left in a rough and unfinished condition. 9. As the work progressed, the Plaintiffs paid the Defendants $11 ,256.25. 10. The Defendants charged $2,664 at ProSource to Plaintiffs' credit card account for materials, some of which were not for the Plaintiffs' job, and most of which have been damaged beyond repair. The Plaintiffs were able to obtain a credit of $709.67 resulting in a loss of $1,954.33. '-'~ ~, ., C' " ~' - -, " - ',<- i' '''",-;C- ,-~o>, -"j-' ~L",",~ 11. In addition, the Defendants charged $106.85 to the Plaintiffs' account for tools. 12. The Defendants have been offered the opportunity, but have failed, to correct the deficiencies in the work. 13. The Plaintiffs will be required to pay at least $8,513 to repair the deficiencies and complete the work. WHEREFORE, the Plaintiffs demand judgment against the Defendants for an amount not in excess of $25,000 plus interest and costs of suit, an amount within the jurisdiction of arbitration under the local rules of court. LAW OFFICE OF MICHAEL J. HANFT By: ~ Attorney J.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorneys for Plaintiff , '-,.xf..". .1..::'<',- ':"_,':.,,,:- _____'',_'_'_'_ - ~t' VERIFICATION George M. Hoffman and Claire M. Hoffman hereby verify that the facts set forth in the foregoing Complaint are true and correct to the best of their knowledge, information and belief, and understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsifications /1 "'"'-' , r;Lw~ DATE: c:-t/e>f/C! . ~:;~~':'-[ri~:JrJd1ili';;>~ ~ "-"ci,'-' '"';,' ~" ,~ ,"~"'- -~~ '--' '- -" '-','-:_' '~"'-"'I\;;>u''''''''';;'.P.i'.~!l:lt'ilII.'Il..t " ~ ",' .-~ , "'. ~.~ , "'"'''-~ ,~- "',- _ ,{.'. ",,:-;>;, ,;"- - ('.) f(r Il "- 9J "- /$v \) ~. -. ~ ,,- - 10 r , ,- ",~.- .-~', ~ "'Q "!q. ~'1<5 ~8~ \ , ~~ J '-"0""" )~,..tia:-'~4- -",,,,,-c" . ~ . 0 0 0 C -;"j ;0- '- -0 L~~ ('- g f1lf'\1 Z:_tl - i- ~ -;yr-- ~~~: en , - ..:~I~~ k:C ~r) -_:.. ,-~ ~ ~~~~ 2;:0 .- ~:;:;C) ~ PC Z W ;Sc, ~ 'l" ~ 11; H ,., ._, " -j", "I , " c: , """>-':".";' ... , ""- GEORGE M. HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3704 CIVIL TERM v. GLENN A. LAYSON, SR. and LAYSON'S HOME IMPROVEMENT, INC: Defendant PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: William A. Addams, ofthe Law Office of Michael J. Hanft, counsel for the Plaintiffs in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the plaintiff in the action is not greater than $10,574.18. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: N/ A WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted ~/ '$~'~ Date: 9--("3 -or ORDER OF COURT AND NOW, ~/J".I- If ,2001, in consideration of the foregoing petition, jJ ~.d-/;6 ~ or Esq., ' sq., and j/ ~ 11vA;~.I/ b /-.......Esq. are appoint arbitrators in the above-capti ned action as prayed for. By the Court, P.J. 1;.'1 ;"-/:",t))-{)<TiCf (}-: ,. 'F:::,.\iUTAqy (' j '[I" I ' d 11,J!, :.;. Pri w: 15 CUi\1BERlANu COUNTY PENNSYLVANIA --I. t.C... ~ ~ S '--- ~ ~ 0.;, E; '5 N- >- 1'"- r<) a: ..::t ~ ~ :'t: ,.. (Y) '- '-" N ::::>$ UJQ \'Y) In fE~' 82: <s ::c '- :'C 0- C)~ " ~ ~ -.... 0:.--_ "7)..:: :q: f '-__ (':) ":~"(I) ~ or' :::)2: ;j LU('_ O::z ~ ~h',: S? l.UlU l/) _\'- ~ (00.. "- I-" c:t "> lL ::s 0 <::> (.) , .~ L"_ , ""~,- ' ,-y",,,,,,",-, - -', -,--"~,-,,)},,-, - '" --''''';-'1:- " ~;,- ~ :" --" ... ,".':>:",-:--;" -,\ ,_,e,"'_~_~_ <:~-:,::;':'':,'-:;-z-:,:,:~-,-, -',- 4_","_ , ~n ~ -- i,)J,_;~, ,,- ~i::;f'!:,~.\:!:':;-t;'''''--'-';\~,:,,7'E'::'!-i;:-;'F'-'-~';'_'__: ., ~., ._""'~~--~"--"" -;-.r'- . ~, .,.~:~~- - '.'", """,,-.L"-'--,-lb!.,,,~iW--, ., SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-03704 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOFFMAN GEORGE M ET AL VS LAYSON GLENN A SR ET AL 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: LAYSON GLENN A SR but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On July 2nd , 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge 18.00 9.00 10.00 .00 .00 37.00 07/02/2001 ADDAMS & RUNDLE S;?r~ R. Thomas Kline" Sheriff of Cumberland County Sworn and subscribed to before me this .... /1 <.--- day of 9,0.1 A.D. :)<-iJ! 0'f' - 0 l'1t ,op", *1) . prothonotar -- , ~t- , ~ " ~ ~",.i~~V- 1 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-03704 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOFFMAN GEORGE M ET AL VS LAYSON GLENN A SR ET AL 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: LAYSON'S HOME IMPROVEMENT INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, pennsylvania, to On July 2nd , 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 07/02/2001 ADDAMS & RUNDLE SO~~ R. homas Kline Sheriff of Cumberland County Sworn and subscribed to before me , /"6" ~ d f II. thlS '7 ay o. /'#r ~1 A.D. 97. 'p'r~h~ci~y~ COUNTY OF YORK 2 of 2 OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST" YORK, PA 17401 ,.". .... " ~....._."."."."""" """."..".". " INSTRUC" TIO" NS SHERIFF SERVICE . "". "". "" "." """. " """"" """.""" "".""".""" " " """" PROCESS RECEIPT. d AFFIDAVIT OF RETURN " """ "PLEASETYPEOlllLY UNES1 TO 12 ,an """ DO NOTDETACH ANY COPIES. .-."".-...". ...."....... ."..".".. """".....""""""""--.--.. ..... 1. ~NTIFF/SI '" I 0l" ;2. COURT NUMBER Q1__=-_~!04 c.:!-v~ ....\..?__e6v::~.~.~,.L.C;11d__.ckixr, rJ. J;bj;'\-In CU1 4 TYPE OF WRn OR COMPLAINT 3 DEFENOAblflSi (: 1e.\'lrlJl...1,'vsen ')f', ,:.tncl 1 "''JcOOh$ LL,~-.r.mM.m.mt..iit ev,j C-Ol'l"I",'Y1t SE'FlVE { 5 N,(ME OF INDIV~DUAL, COMPANY ORPORA~tc_ iOSERiJk:: 6ROESCR1PTr6N OF PRoPERi'i-io.BEI~AnAcHED. OR SOLO .-- ........ __ 1. ct Ii $~l:l..s__.llim.f..__.Lu ,1 l::o.?'e m e '1t~T.n,,,,-,-. _ "_. _.____ ___. ~ Ij ADDR~S tSl"AEE; r OH AFD WITH BOX NlJMOER, API NO, l..JII Y. BORO. TWP:, STATE AND ZIP CODE _!,T. Lflf{) ,)h"e~....Ll,,~t:- ~I;"J_~ ~ t:f...k C'"unt~ ffJ_..1737t_ Z.:.tND_I.2~!'?..~~,?E: 0 PE~(jOO~._---9.!..!?!!.~_.'_._._..!~~J:lARGE "' oepu ~ MAIL _......!=l .. elA.55 MAil _ a pOS!.~E-."_.-E-'?.~ER NOW . uun~"".lH, ~."." Xfij(___..__I, SHERIFF OF 'l'eftK COUN~~;j~eputize t e J'eriff ot ___."."."."."." ~ork. " COUNTY to execute!Jlllf'W~ ak r t rn t cording to law. This deputation being made at the request and risk ot the plaintiff. .. .".".".~"."."."."."."::.''"~ ' . ~ __"'....... _ ..~. __'_ .__--1!J:!.f..B.J.E.f...JJ.L... _ .,.....~.t..Q~I-Y___..,.... 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cu:nber land fh It: 93B. t,340 OUT()FCOUNTY CUMBERLAND ADVANCED FEE rAID BY ATTY. ..---...-'. ...-....... NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN. Any deputy sheriff levying upon or attaching any property under within writ may leave sama without a watchman. in custody of whomever is found in possession, after notifying person at levy or attachment, without liability on the part 01 such deputy or the shenff to any plamtiff herein lor any 10::;5, destruction, or removal of any property before sheriff's sale thereof. ~~. tYP" E" NAME" AN'[j AD~RESS'O' ATTORNEY/OA"IGINATOR-and S" IGNATUR" "E"""" ,........ ~"~"""" ..~'(i/./ /~/ 110' TELEPHONE NUMBER" ""FDA~E":"'FiL~ LJiJk,w,1l:,)iJq"",S.. )"/ !)rook,J..d H~i:: C~di5J! (~l21li~V~L1L7.;jJfl-S3'131~ /15 /0/ 12., SEND NOTICE OF $ERVI~ COPY TO NAME AND ADOi?e:SS BELOW! (This area must b completed if notice is to be mailed). Ji2;J I ,'a ~ Il ~~tlf3~~o~~~~lligi otiH~~H~afJtl~~-d6~6~ WRlf~l:=~~~~~j~OL.'N~H:~I FF 13:=~i~=s=,i~;~~;~1 R. AHRENS SIGNAfiiRE.OFAiiTHORiZEDCLERK-.~"-'--:..I'~~~'9:~"ed 15. ~:i~~~~i:'~n:.~~~ 16-, HOW SERVED: PERSONAL ( 'I RE'SIDENC~. ._"~~:!.~~ ( rOE ( ) SHERIFF'S OFF { ,\ OTHER ( ) SEE REMARKS _~X:.O I he.~~.~i' cert~!y"..~~.? return a NOT FOU~_~l?eGaUSE! I an:'..~.nab~~.!-~!_~~te the individual, coml?~.,:,!Y,_~p'.'?:~ation, e!c,__,!arned above, fSe(~ remarks below.! ___ 1ft NA~~~L~~F I~_IDUAL:RVEO ~jS;~o;RE~ Hl.:,e IF SN~~HOW~;;V;;lationshtP to Defendant) 19. ~~/;er7~e 20. Time of servi~_I~ i ~~~mMPT~:;~lW~' DaierimelMi,e. In': DTI:~.:I'nt]~~iL'.1MiIe.rn'.t::::r"me Mile. Int. Date IT'meIMi'~r~:u r 22. REMARKS: ~3 Advance Cost. L:S.lVlce~~ts 25 NIF 2b M,'.ag. 27 po'tage. 28 's:;~r~'a' \29 Pound 30:.Nota'Y Fee 31 surch.'!!e] ~2 Tolal Costs 33 Gos' Due or Relund :" FOre,g~.Counw ::L:V=.~~.S'.T:.selV'ce Gosts 37 NOla~.C:J.'~ MlleagefPostagelN F. 39" rota'~~srs 40 Cnsl [)"e '" Refond SO ANSWER, 44. Signature of ,... ~~.......... 45 Sf '"",bgrltt,.",,"." k ~~0'<'=,;'rj. J.-. gnaureo or ./,!,Ck:::.....""."""f ~..'<-~ County Sheriff L"'-' - lJ,:: ,.",,--~' ,;' ., ""' FOR WILLIAt~ M. HOSE I,~,"""""",' 1;:"">';'z<,.~'Ul<..----- Proll:19n9fary~l:A~p 4e::-STgnalUre-of Foreign l>' "-'-""""--- :'? .... M,,'CQQMM SJON EXPIRES 7 ~..G~..'. (';~_l,lfl'!y.Sherifl ...__~ .._,.. __.""'_ 50, [ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RetURN SIGNATURE f51~"Date Recelyed OF AUTHOf!}ZED ISSUING AVTHORI1Y AND Tn:~..... ~__.... ..-1-..._... 1. WHITE ~ Issuing Authority 2. PINK. Attomey ~t CANARY. Sheriff's Office 4. BLUE. Sheriff's Office 41, AFFIRMED 43, 6-27-01 49.bate '.1"",,: "cCliJN'ryUf''iORK .. ~... . """" """."". nUTUF,,;j)[lNn :':'>'~Vt'taE~t~~~.~ :{-" """""~_;rrEMP~sl;~~}~;: '~,~~7. ~~~. 2i!. FlEMAIlK$; :' .:..:.l.:W:~ C~;S\DU~.~:B~~:lrr-\d .....j .:_.' ",';;',,"". . ,,~-'" ',~\' . .,..... .-'.>>:'.'. ...........,....... ..,','.,..........'.........::,.:-:.::, """.""""............f~~:,~a"' B.t.i",ct COUNTY OF YORK 1 of 2 OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET SC, YORK. PA 17401 ----"-"-"--"G"""" """"" " ",--'-"-"- ~" SHERIFF SERVICE " """" """ >, INSTRllc:TIONS PROCESS RECEIP,[ a d AFFIDAVIT OF RETURN" """ PLEA" S"""" """S"."".""""T".""Y "" PE".O"."" ""N".""""."LY"""" LINE,S 1TO"" 12 , n "" ""DO NOT DETACH ANY COPIES. 1.PJ::A1NTjFF/St .'---""'--'.'--"--'-'-'- '--'---'---'.' ....-.-- 2.COURTNUMBER oj .::." 3704 clv ...G!'l'I'"~ ~~!) aJ C'\O\\rl::<.J~.Ii..~lT!dl1 _..____ 4 TYPE OF WRIf OR COMPLAIN I ---.- -- 3 Q~'FEN T/$/ .. _ fl .. "'''I Llm __.8_~ts.~;/{<~Lf!.n~hJ';'?-9h~s-__:1~i'M!3..c1l1. _~k" __~';(Jt') L 'or~J___ S.ERVE { G~L~.;\"N._;:VI0{tl_;7~;:~O~:.~.:_~_'. TC~:S::~:~: OE.SCR~:::~~_::O.PE::.T._:::"_~E lEO, ArTACHED, OR SOLD. 6- ADDRESS (STREE OR AFD"WffH 80 UMBER, APT NO., CITY, BORD, 1WP., ~TATE AND ZlP CODE __J::~.~_____.fL1jf)" ('>-tll,.~-_C~i AI j,1V' k JJ~-~~.1..~ ~ K elL h +-" P f) } 7..1:1 ().._ k~:CATES~~'18 ~-P~~~tL - PERSON ~ A~'-'~-TsH~~~~'~~PA-""s;,~;:b S ::tutlze ~:O:;::~iffO~C>'!'~-~ .-"-"-----"------"-"-"" "-"-____"_ "..-"_, , .. 99 Y P __.... _ York __ ___ COUNTY to exec~ make return according to law. This deputation being made at the request and risk of the plaintiff. _.~_._.~~~_._ __. _, "._ e", SPECIAL lNSTRUCTIONS OR OTHER INFORMA"nON THAT WILL"ASSIST IN EXPEDITING SERVICE; -.----- . efI~-'-- ..-...-.--.....,.--" ADVANCED FEE PAID BY ATTY. OUT OF COUNTY CUMBERLAND NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S, WAIVER OF WATCHMAN - Any deputy e,tleriff levying upon (lr attaching any property under within writ may leave same without -a watchman, in custody at whomever is tound in possession, after notifying person of levy or attachment, withoulliablllty on the part of $(lch deputy or the ..hentt IO--'OIl)y plaintiff herein for any loss, destruction, or removal of any property betere sheritf's sale thereof. 9:'~fvPE NAME AND A."DORESS of ArTORNEYIORiiiiNAT"OR an;i"siG~ATURE "~" ._."."...._.... _.-~--'---_...[.-10. TELE".PHONE NUM"" BE""...R 11. DA:rE FILED "" , ,C4dl~e.JI'~. '." ~ " -JH! [.,X \I\'6iI',,_li,ll-_J)_,:l"'~ i 7 r)r.U):./<.'o,,_Jli~J I7D i-r , /.. _ , 7/1 \,2_'11-5"3 23_t;~tJL 12. SEND NOTICE OF SERVI COPY TO NAME AND ADDR!;SS BELOW: his area must be, completed if notice Is to be mailedj. I I'll' li\ vl II. ) C1'~ \..' i Vl ,- 'L_ "~ co" I J n...i ,,-- "" ., CUMBERLAND CO. i"~L I ~l" If,~~ BE~O~r;~~~D;~g;Vt~~ ~~~~;~f-6~f~:DOUdf"WRh-"e..d~~;THit~i~RJ FF ~_._. '-.--'.- _..._--_.,....._-,._---,._.--_........_...,...._--._~....."----_._--~_.".(....--:---~_.,,_.-.__.._-~- 13. I acknowledge rec;eTPt of the writ SIGNATURE OF AUTHORIZED CLERK 14. Date Received l1fi, LxplrattOniH"eanng Date .._'::~~~.Ia'n:..a" '~_:':'o~R..:-_AH~ENS "._____________ 6-19-QL..___1-15-0.1 16.HOWSERVEO: PERSONAL~ RESI?EN~:_~~.~....._ P(~~...... SHERIFF'S OFF ( 1 OTHER ( ) SEE REMARKS 17, U 1 hereby cerltfy and return a NOT FOUND because I am unable to locate the individual, company, corporalton, etc, named above iSee remarks below,) .~i'NAMEt)yrrLE O/OriIO L ~~RVED I liST AD~~ESS HEREiFN~_~~HOWN ABOVE iRela_li:n'hIPtoO.f.ndant)!~L.%,;'-'ce ~]t;~~Se'C~~~ 21.A~ ITlm"e1Mi Int. DateTTlmeIMn~Sllnt. Date TimelMileSI Int. oatelnmel'Miles, Int. Date I Time It MileS! Int. Date Tlme,Miles Int. __ "" - 33'>' ~ B5 ..J 1301 1 1_ _~.__ I_'-----L i I 22.AEMARKS: ". I > \1 ",", to-"Zl-O ) 41 ,AFFIRM 5urcliarge!32.1o"ta, CQ~to~~~~ 38.35 ~61.65 37 NoW" C.~ 1:3" Mileagen>"<lagp~NF__ 39~:::::'~'S -l~:~;;e';iRe~;'nd- SO ANSWER. ::~:~~~~,~ YQik-~~~"" ~k';-",,--A<G""b;~< -~~~:::c;>__ County Sheriff ' {..x......:.:--.-.--'ff ,; _ -<' ,.,r., ; / FOR \HLLIAM M. HOSE ~'o"" /,,}' t.<."'...".yli2/c_- 6-27-01 ... P~~;O)MY~ U .' '4li:sTiiiiatureQ('H5reign J 49"Oate-'.'-- ~y COM ION EXPIRES: . '!Y' - ~ - ..~....._ CoJ!!)jy. Sheriff \:".-" (. ~o. ~~~~~~;1~3~~T~~~I!.X:~~~ri~~:~ S~~NATUR~.._~... . -J !).~' Date Recelve~.....__....... 1. WHITE . t.~ing Authority 2. PINK. Attornev 3. CANARY. Sheriff's Office 4. slUE. SheriWs Office O;:;;~f "'~lf, 'H^"f!;f\. "'-Y 42,day of n, loj2 .. . ~ .. COUNTY OF '(ORK OFFICE OF THE'SHERIFF , ,~. SERVICE CALL J717) 771-9601 . ,~ . r i f ! . ! 28 EAST MARKET ST" YORK, PA 17401 ",^""Clc~_~-"""''',~-, INSTRUCTIONS PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY COPIES. c:!.v ?-fi. SHERIFF SERVICE ;']>ROCESS RECEIPT, and AFFIDAVIT OF RETURN .L. / - """'''''.<J.">'-'-.~'"'''I- o llf\ aJ C:\G\\fe. t"l, fJ-ol;'trrlal] ;;'i-. C' ,I 1111 I CCM )41'(1 f G' IJ , ~ ADVANCED FEE PAID BY ATTY. OUT OF COUNTY CUMBERLAND .-,,~- :. .~---- NOTE ONLY ApPUCABLE ON WRIT OF EXeCUTION: 'N.B. WAivER OF WATcffMArif=-Any -depufy sli'erlfnevYifi~rtl-p'itrioi' aftaClllng any' prop:erty lmd"e;rwitflirl writ may leave - same witho1Jfi:! y..'atchman,_ in custody of whomever Is found In possession, after notifying-person of levy or attachment, without JiabTIfly on fhe part of such deputy or the sheriff 10 any plaintiff herein for any loss, 'destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NMtE AND ADDRESS of ATTORNI;V/ORIGINATOFLandSI(:rfllAtuRE 10. TELEPHONE r>JUMBER 't1. DATE FILED \\i'am~1J, IlJJat;, "V'HK/J.IoOcl kC~~I~~'et1fl/" 7/1-,,2'17-53'73 IC l'i/O/ < 12. SEND NOTICE OF-sERVrCE_COPYTO NAME ANb ADD- ESS BELOw: (Tfl 5 are must be completed if notice IS to be mailed).' II II I~ f.Yl ))"'}3' CUMBERLAND CO. wi ,'a,: tf, . rr U SHERIFF ..:,. RITE BELOW THIS LINE 13. 1 acknowl~dge receipt of the writ or comP1~nl as indicated aboj"e. 14. Date Received 15. Expiration/Hearing Date , 6-19-01 'SEE REMARKS "' '''' ;'V "'" VZ1--6 ) J!< )l-ti.c9 -;D . _~ :!-:.:;:::,r."~~~..,.::,\...\ "t:~. 41. AFFIRMED and sulSscril:ied to beforEfme this ~: .<:t'U'!'!iE'^' " ," ----.-;>,- ".4.J ..'\Ii ' . .;,.. ... , 44. Signature of . o riff"" 45. Signature of York County Sheriff 'OR WrLUA:Il M. ,,'-- ":'"SCl ANSWER. / ,!/::;;D--- ;r . , 'j- '-, .!F~Y~(k7._ ::~I/' .'1- '-. - -rr" 47.Daij{ I:' c- 48. Date' I HOSF: 6-27-01 49. Date 46. Signature 0 ForeIgn Coun Sheri~ IGNATURE . ~~ .,.,,' ---. Sd)ate f1eceiveCl l,. ~~sheriffos 15ffice ., --,~ - ~ ,""'!-. --""'~ "_k ""-~ .~ :--..~""~...-,,-:,.,, - ,., ~., '~,~ ,"e, ",,~, ~"",'~o' ."',,_, '-, ..'''c',:, _+__'0. .~,," ~;-.;:;;.-~ "' GEORGE M. HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV AN1A : NO. 01-3704 CIVIL TERM v. GLENN A. LAYSON, SR. and LAYSON'S HOME IMPROVEMENT, INC: Defendant REPLY AND NOW, come the Plaintiffs, George M. and Claire M. Hoffman, by their attorney, William A. Addams of the Law Office of Michael J. Hanft, and make the following reply to the Defendants' answer with new matter and counterclaim: 1-13. No answer is required. NEW MATTER 14. No answer is required. 15. The conclusion oflaw is denied. 16. The conclusion oflaw is denied and the allegations of the complaint are incorporated herein by reference. 17. The answer to Paragraph 16 is incorporated herein by reference. 18. Denied. The Defendant was either unwilling or unable to complete the work. WHEREFORE, the Plaintiffs request the new matter be dismissed. COUNTERCLAIM 19. No answer is required. 20. Denied as stated. The proposal was prepared so that the Defendants could recover for the repairs from their own insurance company as a result of their faulty workmanship. 21. The answer to Paragraph 20 is incorporated herein by reference. "' '".,., """"'-' ;'r~-"'~~ 22. Denied as stated. The insurance check was payable jointly to the Plaintiffs and the Defendant. The Defendants have failed to return to complete the work and pick up the check. 23. Denied. The allegations of the complaint and Paragraphs 20-22 are incorporated herein by reference. 24. The conclusion oflaw is denied. WHEREFORE, the Plaintiffs request the counterclaim be dismissed. LAW OFFICE OF MICHAEL J. HANFT By: ~~ William. dams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorneys for Plaintiff , . .,,-, _,-r "' -",~--'" , " , h,-<<; " ~. ,', n " "0- .. ,el '. . ' . . VERIFICATION George M. Hoffman and Claire M. Hoffman hereby verify that the facts set forth in the foregoing Reply are true and correct to the best of their knowledge, information and belief, and understand thaC false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsifications DATE: 74/&/ r\t~~i''''~:d"= """'-J!-;~--'- '-j;j~~~"llt:jj~~~~_Iio!.,ai{'-'-'- ~'~~'i~-""""-~ IlL.~ __~, "~". -^~ "., n ..;;,~ .........-.~ -: ' ," '! (") 0 0 C -11 s: "'" ~':Fl~~ ::9.0:' c:: fl'lfTl G') Z::I) I ~"I-n Zx:;.- :~6 (/),,:<: CO ~.d,:". ~c; ""'U " )-..... ,-.. :x z:> ::Ii z" --;>-C) -..0 :::> o.<Tl J;-'c ".., ~ '" )> ()"I ~ ." ,. '""'-- , .~'~j- .. ~~ , ~.,.. "^ lli"-"'-'~>l!"""i0 G--eOr'J<- C\Nr,,- /IA. \-..\" ~'i--",^o... '" \-\-0 ~~"",-.....", , VV\ . ) ) ) ) ) LtJ-i <'o,^, 3 r. ) )lo~ .;. _" lJIOllf_.t; ) ( ::+"'"C . In The Court of Common Pleas of ./ Cumberland County, ?ennsylvania (;-1,," Y\ '\ A . L"'-760,^ t.:; ~o. ,0/-370'1 ~ W>. i T zI'VV'... OATH We do solemnly swear (or affirm) the Constitution of the United States wealth and that we will discharge the that we and the dutie will support, obey and deiend Constitution oi this Common- four ifice with fidelity. ~ We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ()'^ a.s<Al^~r r\~^"\-; ~~; c.1~VV'\ WR.. ~\",J \'\ ~\lor D~ f\",",'A~' ~~3' c;_ J ) ~'L \-~",-~",vJ: L.a...., ~b" t.:; flolM~ .L"",prov{ W'k.:r I.A", , "- ~ $.} I I) I O-w-..our-l o~ 7\ 10&, ~s ~ c>" {)~~~","d.,^-^\~' c..o",..:]tl'c!o..t'v-, v' h~J I^ k"",,.r- o\;. \..""7"""1'-" (-fo"",.. r.~{'r.II{II'NI--::r; 't:.,^-c, Cu".<! tL~tN"'sf f(",,~"c.f:s ,^ \'Nl ",,,,^~,,.4' ~co$'.3, 7s-. N"t ....,,u....r-J ~ 1<. ~ t'l""'...t"..f:-~5 u . 0/1 -h$', '" S 3:.7" \___'~ b-~u~ -' . Arbitrator, dissents. (Insert name ~f applicable. ) Dace of Hearing: ~eu..",^,\".QS 3> ? oc) '; , Date of Award: NOTICE OF ENrRY AWARD Now, the.?/2..C-~ay of ~,.,..J,~ 1;>iI~/, at/O};aJ.., E-.~1., the above c~d was encered upon "tRe docket aad notice" thereof given by mail .to the parties or their attorneys. .. ~ ... ." ..~ ~:,::~:(- Arbitrators' compensation to be paid upon appeal: $ ;Ro ,DO !t~ki :<~~~'.di.i;jb~I;.~.i"h,~:iw"''''Y~'il'"o\!a~~_''*,''''~'h,-g;(,8:'.'-:_i,:j;-i_.L'i,_"j'_""_1f~m~,;'.!;h.ww.<i~mk " . , ;j!If,!~EiliUii'~ "--.~~~tilt~~~"Mlilii:''''-'.'~~~--~~_~-lf ;j'J../lVJ ~jd. <.11"'-5 ~D' ( .[) ~ ~~ II'.. ~(;o.-vJ" .~ G,....^""J : '31'2..1 - F ~ c (LJ " 7/755<- W\,-t. V'^ t. ((A :::T'o 7 ) I20b ):-~y - h'~ J0.Uf 4 -r 4 bJ-Lk."L,0 S~e-J.:.s ~l Jx.,t- .;,;;u.:"'iu - S;",d.,... 9.Jr,~'" J..,...k;.y Gr'l '16 C. /) . Copy rn~L~l --10 ~ w./U~~ It ,( (.).If R. ~~ t!,-~ ~" /.;& bC,. 0' 9-, ,'" ~~-''"'''",,-,~-,., ~,~,-~,--~----~-~"'-"'-",' ,,, .,. ,-, - ,~ ' ,~ ".. ~-< - . , 1\::) 'K. , C'.:I () _ '-\", !C1 ,,0. ,", - "\ :-::~ "-;"\ " ~ ':-,' ;-=, ()\...J - ::D C0 ,.c-'l o ~ ""- -rJtT tIi:fr, Z""" ~~. '2: c) bel >c: ~ -'0 -""',. -"... . '."- ~'-',,~ -> -;:::':-::.!T1 !:-? ::::> 0"" '~:J ~~ ~ ~ ~"~ ,~ "i ... , - GEORGE M. HOFFMAN and CLAIRE M. HOFFMAN, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3704 CIVIL TERM v. GLENN A. LAYSON, SR. and LAYSON'S HOME IMPROVEMENT, INC: Defendant PRAECIPE Sir: Please mark this action settled and discontinued. HANFT & KNIGHT, P.C.. By: ~? ~ /~ William . Addams Attorney J.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013 (717) 249-5373 Attorneys for Plaintiff To: Curtis R. Long, Prothonotary Date: March _' 2002 '~ ;, --, ~ " ~'J:; s ;J~:d:t:~ZJ C'1i<.,'i."':<~"<6M:'" ""'~~t~~~lJ'_' '!7 '~'~"!io'~~~""~W~",jj~~C"'-'';''~'-;''''!J..,,,", - ~";iI __~ '0 - ~ ~" o 1'-'> ~ <"~"" ;..0 o c: ~? -om f1-\I!' :z: ~," zc;,. ~~ :z~ t;:C.. J:'" --~ :z:L .' _~C) ~~~ :2 !!t<d,~"''',"~" ,. _~" "^ ." \ cO r-) ,- -'(1 -~ ~... ~' - -'--~, ;:;.::; :\T-\ . -'( >-::. ,'-\ -,:j~:f. ,,--.-n ':t}f, .-~ ~ -'. 6 .' "'" rv .,,-, _'1'