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HomeMy WebLinkAbout01-04603SOFA SELECTIONS Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY v. RICHARD SiLVERMAN Defendant No. 2001-4603 Civil Term ANSWER AND NEW MATTER OF DEFENDANT RICHARD SII,VERMAN Defendant Richazd Silverman ("Silverman") hereby responds to the Complaint of Plaintiff and in support thereof avers as follows: 1. Admitted upon information and belief. 2. Admitted. a. Denied. To the contrary, Silverman is not employed by Hughes Furniture Inc. b. Admitted. c. Denied in part and admitted in part. It is specifically denied that Silverman determines pricing of the products. It is admitted that Silverman conveys pricing information to retail furniture dealers. d. Denied. To the contrary, the manufacturer determines and is responsible for performance of all sales agreements. By way of further answer, the sales agreements are documents in writing which speak for themselves and Silverman denies any chazacterization to the contrary. e. Denied. By way of further answer, Silverman denies that he approves or has the ability to commit the manufacturer to approve repairs or compensate retail dealers for warranty work that is performed by the retail dealers. £ Denied as stated. By way of further answer, sales were accepted upon receipt and acceptance of the sales agreement by the manufacturer. 3. The allegations contained in Paragraph 3 of Plaintiff's Complaint constitute conclusions of law to which no response is required and they are, therefore, deemed denied. 4. Silverman is without knowledge or information. sufficient to form a belief as to the truth of the allegations contained in Paragraph 4 of Plaintiff's Complaint and they are, therefore, deemed denied. a. Denied. To the contrary, Silverman did not purposely avoid taking calls and returning them. b. Denied. It is specifically denied Silverman refused to order the part or that he was invited to go to the customer's home. By way of further answer, Plaintiff's allegations as to what constitutes "industry practice" are denied, and strict proof thereof at trial is demanded. c. Denied as stated. By way of further answer, December 21, 2000 was the first date that Silverman was apprised of the need for a repair part by Plaintiff. d. Denied. By way of further answer, Silverman states that any problems associated with the repairs were not his responsibility, nor did any action or inaction taken by him cause them. Further answering, Silverman is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 4d. of Plaintiff s Complaint and they are, therefore, deemed denied. -2- e. Denied. Silverman is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 4e. and they are, therefore, deemed denied. By way of further answer, to the extent any warranty existed as alleged by Plaintiff, the manufacturer, not Silverman, owed such warranty. f. Denied. By way of further answer, it is specifically denied that Silverman is required to honor the warranty. To the contrary, Silverman is not personally required to honor the warranty. 5. Admitted in part and denied in part. It is admitted only that Silverman advised Plaintiff that Plaintiff was over the credit limit and that a purchase order was submitted to Silverman. . a. Admitted in part and denied in part. It is admitted that Plaintiff submitted check # 1749 in the amount of $2,706.16 dated March 12, 2001 to Hughes Furniture. Silverman is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of pazagraph Sa., and they aze, therefore, deemed denied. b. Silverman is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph Sb., and they aze, therefore, deemed denied. c. Silverman is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph Sc., and they are, therefore, deemed denied. d. Silverman is without knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph Sd., and they are, therefore, deemed -3- denied. By way of further answer, the allegations contained in paragraph Sd. constitute conclusions of law to which no response is required. 6. WHEREFORE, Defendant Richazd Silverman respectfully requests that this Court grant judgment in his favor and against Plaintiff Sofa Selections and Order such other and further relief as this Court deems just and appropriate. NEW MATTER The relief requested in Plaintiff's Complaint is barred by the doctrines of accord and satisfaction, estoppel, payment, release and/or waiver. 2. Plaintiff s Complaint fails to state a claim upon which relief can be granted. 3. Plaintiff's business relationship with Silverman was terminated by Plaintiff on Mazch 9, 2001 at the time that Plaintiff invoked hostile, inappropriate, offensive and discriminatory verbal attacks upon Silverman. 4. Silverman was not a party to any sales agreements between Plaintiff and the manufacturer, and is therefore not responsible to Plaintiff for any damages allegedly sustained by Plaintiff. 5. Silverman is under no obligation to compensate Plaintiff for any repairs allegedly required to be performed by Plaintiff. Any agreement to compensate any retail dealer for repair work is strictly within the control of the manufacturer. -4- WHEREFORE, Defendant Richazd Silverman respectfully requests that this Court grant judgment in its favor and against Plaintiff, and awazd costs to Defendant and order such other and further relief as this Court deems just and appropriate. azd Silverman Silverman Associates, Inc. 3 Fox Pond Spring House, PA 19477 (215) 643-1188 -5- CERTIFICATE OF SERVICE I, Richard Silverman hereby certify that on August 21, 2001, I caused a true and correct copy of Answer and New Matter of Defendant to be served upon the Plaintiff as listed below via First Class U.S. Mail postage prepaid: Donald L. Spitler SOFA SELECTIONS 4920 Carlisle Pike Mechanicsburg, PA 17050 ' and Silverman -6- ~~ ~i'' ° i' ,.,j ~~.' _ :.~ s.'. -`' { COMMONWEALTH OF PENNS~'LVANIA N®TICE OF APPEAL • ~ ~ ~ COURT OF COMMON PLEAS FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT Ir COMMON PLEAS No U' ~.., ~1f~~ ~1 Utl.~~+~ W NOTICE OF APPEAL Notce is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below ~~' e LzscF ~ NR zc.~ ~ p oso DUE OF IUDGMEM N THE OF f ) ((MhntlaN) OAIM Na SIGNATURE d APPEItAM R MS ATTOR R NT LT 19 This block will be signed ONLY when this notation is required under Pa. R.C.PJ.P. Na 1008FL This Notice of Appeal, when received by the District Justice, will operate as a $UPERSEDEAS to the judgment for possession in This case Signature of Prothonotary or Deputy If appellant was CLAIMANT (see Pa. R.C.P.J.P. No. 1001(6) in action before Disvict Justice, he MUST FILE A COMPLAINT within twenty (20) days after Kling his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to 6e used ONLY when appellant was DEFENDANT (see Pa. R.C.P.JP. No. 1001(7) in action before Disvict Justice. IF NOT USED, detach from copy of no[ICe of appeal to be served upon appellee). PRAECIPE: To Prothonotary Eller rule upon (Common Pleas No appellee(s), to file a complainT in this appeal within twenty (20) days after service of rule or suffer entry of judgment of ran pros Sigrratwe o/ aopepant a his attorney a agent RULE: To , appellee(s). Name o/ eppelipe(S) (1) You are notified shot a rule is hereby entered upon you ro file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail (2) If you do rat file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of This rule if service was by mad is the date of mailing. Dote: , 19_. Slgrlaeue or Protharrdary ar Deputy Aoxa,z-ea COURT FILE TO BE FILED WITH PROTHONOTARY Name o/ appeeee(s) P~~~F ~F ~EPVI~~ ~P td~TICE ~F J~IIPPEAL dlN~ RUSE T~3 FiL~ GCDfiAP`ABI~T (This proof of serviae MUST ®E FttEl? WlTH1N TErLr ,10) DAYS AFTER frting the notice of appeal. Checle applloaGts troxes) GOFN6AfltdWEAl.7W OF PEP8Pd3Y6.YANIA ~CDUtdTY 9P ; xs AFFB~A~IT: i hereby swear or affirm #hat I served O a copy of The Notice of Rppeal, Common Pleas No.. .~ ,upon the District Justice designated therein on (date of service) _ , ra by personal servloa ^ by (Gartffied} (registered} mail, Sander S receipi attached hereto, and upon the appellee, {Hamel ~____________ __..____.__._, qn t9 C7 by personal service ^ by icerti#iedj (registered} maN, sender's receipt attached here#o. ^ and furtherihat4servedthaRuletoFiieaComplaintaccompanyingtheatagvePJoticeofAppealupontheappe€Ies(s}to whom the Rule was addressed qn _~ , 19____.~ ~ [ay persona! serviae ~ by (certified} {registered} mail, sender's receipt a##ached hereto. SWORN {AFFIRMECt} ANC 5U6SCRI0E0 BEFORE ME THtS L?AY C3F 79______ Signature of atfiant S+gnainre of ot£toiat before wham effldevri was mreda T)itB pf Ofticiat My commission ©xpires on ~ '~ C3 ' ~ ]9 _~ ~ r- V -~ t `e'i's KK ~ i ~ l_ Yi r ~~ . /r ~^' ti~ I~t"i } r ~ 1~ ~y}NS4t*nrsJY ~~3~,~"ck1'n E"). q- . 1~N~F?~$e COMMONWEALTH OF PENNSYLVANIA ~'r';"ni InITV nF CDMBERLAND Mag. Dist. No.: 09-3-04 DJ Name: Hon. THOMAS A. PLACEY Atltl,esa' 104 S. SPORTING HILL RD. MECHANICSBURG, PA Telephone: (717) 761-8230 17050 SOFA SELSCTIONS 4920 CARLISLE PIKE MSCHANIC5BIIRG, PA 17055 THIS IS TO NOTIFY YOU THAT: Judgment: Judgment was entered for: NOTICE OF/~JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME antl ADDRESS rSOFA SELECTIONS ~ 4920 CARLISLE PIKE MECHANICSBIIRG, PA 17055 L -~ VS. DEFENDANT. NAME and AODRESs rSILVERMAN, RICH ~ 3 FOX POND SPRING HOIISE, PA 19477 L J DocketNo.: CV-0000198-01 Date Filed: 4/09/01 i r_ l~n, ~ ''i . ~~ (Name) SIi.VRRMANr RT(`H Judgment was entered against: (Name) SOFA SEi.RCTIONS in the amount of $ _ 00 on Defendants are jointly and severally liable. Damages will be assessed on: This case dismissed without prejudice. Amount of Judgment Subject to AttachmenUAct 5 of 1996 $ Levy is stayed for days or ~ generally stayed. Objection to levy has been filed and hearing will be held: Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOyilrE OF JUDGAgEjJT NS RIPT FORM WITH YOUR NOTICE OF APPEAL. _ 1'~~1__ Date ,District Justice I certif~ ~hat~th~ is a true ar~d~creeFeepy-ofth~ f the~ceedings containing the judgment. Date h` ,District Justice My commission expires first Monday of January, 2004 SEAL -AOFC375-99 -. -- - - - (Date of Judgment) 7/~q/Oi , (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs $ ~ Certified Judgment Total COMMONWEALTN OF PENNSYLVANIA 1dGTICE CfF ~LPPEAhL~ `t COURT OF COMMON PLEAS FROM iuolclAL DrsrRlcr DISTRICT JUSTICE JUDGMENT COMMON PLEAS Na ~,,l,) •.~ .t ~~,~~ ~+~ 4~ f ~3f ~«-~1 NOTKE OF APPEAL Notice is given that the cppelhnt has fik:d in the. above Court of Common Pk:as dri appeal from .The judgment rendered by the District. Justice on the daM and in the case mentioned below ADDRE53 a APPELLAM CRY STATE ZP CODE '`~~~ ~RRL.,LS~r~ NsKE MEGNAU~LGs~iGY,~+~- Ay /'7C7S"O ~GF(9 SFL.EC7IC9,tpS cv 19 t~boU /gS-d d , ~~.,,,,,~, ,,~ .,.c,~ LT 19 ~ This block will be sgned ONLY when this'notafion is require under. Pa. R.CPJJ'. Nw If appellant was CLAIMANT (see-Pa. R.C.P.J.P. NO. 1008& This Notice of Appeal, when received by the Dishid Justice, will "bperote as a 1001(6) in action beioie District Justice, he MUST SUPERSEDERS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Signature of Prothonoary or Deputy PRAECIPE T:O ENTER RULE TO FILE COMRLAINT AND RUl.ETO FILE' (This section pI tam to tie used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J:P. ,No. 1001(7) in action before, District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). ''~, PRAECIPE: To Prothonotary Enter ruk: upon (Common Pleas Na RULE: To Name of appellpe(s) ,,.. . ,',;~ ~ . ,_ ~ .. appelkie(s) to file a'.comp'I~nt ir~'this appeal Name of apps/!ee(s) ~ . )within twenty (20) days after service of rule a suffer entry of judgment of non pros Signatu2 0/ appellant a his attorney or agent appellee(s). (1) You are nofified that a rule is hereby entered upon you fo file a complaint in this appeal within twenty (20) days after the date of service of this ruk: upon you by personal service a by certified or registered mail. (2) ff you do rat file d complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The daM of service of this rule if service was by mail is the date of mailing. Date: , 19_. _ Signature of Roflw~y or U9rlutF N7PC 312-aq ~GURT -FILE t,~>~~~ ~~.x~~,~~rx a._~ r ~_-- -.~-- --~,~ ,.,,..---- P~{~~F ~~ SEFBVI~E t3F FIl3TICE AF AiPPEAI. APIL? Fi9Ji~E 'f~ FIL.E ~5311~P~.AIN~' (This proof at servioa tvfUST 6F FfG.ED WITHIN TE'N (?0) D,§YS AFTE13 1?ling the notioe of appeal, Cheok ap.ptleabis boxes) CCS~1i4-~N'IYEALT't•! OF ~~NNSVLVogMO couN~Y ofi G %Z !M1'E ~ ~aQ is ig ~ ; x~ A~FI~A~~I': i hereby swear or affirm that I served ~, a copy of the Notic of Appeal, Comman Pleas Na. ~c'L~L~ ~~ ,upon the 6lstrict Justice designated therein an (date of service) ~ '~ ~." ~~ A ~1 by personal saruice ~ b (certified} {registered} mail, sender's receipt ttachad hereto ean3dyupon the appellee, {name] l~,.y C ~~ S~ ~ y~~z~._A ~ ._ _®_ , an " ly ~9" j ]_3 by persona! service~.by {cerfifiedi (registered} mail, sender's receipt atiachPd hereta. D arrdfurtherthatEservedtheRUtetoFileaGomtsiaintaccompanyingtheabcvaNnticaafFlppealupontheappeiiea{sytawham iha Rule was addressed on _____, ~t9_..._._, ^ lay aarsonai service (~ by {certified) {registered} mail, sender'; receipt a#tachad herato- 3WQRN (AF iFtiFt,MEC3} AND't185G 18ED BEFORE ME (l /y j ,_ ~_.y,LJ - _ _ ., / Signature of'~tilfiant litYe of oflit r My rommissioir ~.xpsre: on ~a '//v//qq/~~~r~~^J// \\1~.r V ~ ~ "+ ~~ y ', ~ ,~~ ~ ' ~y ; , r 4 ^r 4 ~ v ~ ~~~~~ . ~L !. ~_ r -n t" x ~~ O - ^_' r~r, "~ ~~ N G3 -- ,1~4~E+"~r,~r~a;3'3[u.. --..I~IRp3ta~l~rl~~, M~.tsi~er.,.a .-, ,, _, ....... .... ...- ~,, ,.;.. ,,i-: ~- 0 .~ a t.r1 G7 O O O [~ .~ A i Return Receipt Fee ~ (Entlorsement Requiretl) O q n p ui etl) t Re (Endorseme l7 Total Postage & Fees ~ A Sent T ~~ _ - .; or P o pt. N A Sireet ~~ ~~ f ~ ~~. -. D L1P Ciry fat rv f'~ Ld ~; /1 m r o- ui O rl Reurn (Endorsement Requred) Restdcted Delivery Fee (Endorsement Required) Total Postage & Fees Q 43.94 '. O O j O f r` I Postage $ _ .. Certifietl Fee 42.1:' ~'Q ~~1~ ost rk \ Receipt Fee 5 ~ v dare i (~ 41 7- '~O N SOFA SELECTIONS 4920 CARLISE PIKE MECHANICSBURG PA 17050 PLAINTIFF RICH SILVERMAN 3 FOX POND SPRING HOUSE, PA 19477 DEFENDANT :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, :PENNSYLVANIA :N0.2001-4603 CIVIL TERM :CIVIL ACTION--LAW 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 (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 judgement 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 TARE 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 WSERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717 249-3166 SOFA SELECTIONS 4920 CARLISE PIKE MECHANICSBURG PA 17050 PLAINTIFF RICH SILVERMAN 3 FOX POND SPRING HOUSE, PA 19477 DEFENDANT :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, :PENNSYLVANIA :N0.2001-4603 CIVIL TERM :CIVIL ACTION--LAW COMPLAINT AND NOW COMES the Plaintiff, Sofa Selections who avers the following in support of the Complaint. 1. The plaintiff, is a retail furniture store, engaged in the selling of retail furniture at 4920 Carlisle Pike, Hampden Center, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant, Rich Silverman, is an adult individual who resides at 3 Fox Pond Spring House, PA 19477. a. Defendant is employed as a Sales Agent for Hughes Furniture Inc. b. As Sales Agent he has discretion over who carries the Hughes product. c. As Sales Agent he determines and conveys pricing to individual dealers. d. As Sales Agent~he bound the manufacture in the performance of sales agreements which he accepted. e. As Sales Agent he would approve repairs and commit the factory to compensate dealers for warranty work performed in the field by retailers. f. All prior sales were accepted upon faxing to Hughes Furniture Industries Agent Rich Silverman. 3. The Defendant acting as Agent, by his previous actions, gave the apparent authority of having full authority over all aspects in his territory. 4. On September 13, 2000 a sofa was delivered to customer Lestyan. (EXHIBIT A) The sofa had a defect in the fabric, and the customer wanted it replaced. a. I attempted to contact Rich Silverman, he was purposely avoiding taking calls and returning them. b. Rich Silverman refused to order the part after the sofa was in the customers home, I invited him to go look at it, It is industry practice that they are certainly responsible for shipping defective fabric. c. Eventually I was informed by Rich Silvernman that if I faxed him an order for the part, maybe something could be done. (EXHIBIT B) This nonsense began on 12/21/00. d. The parts were not forthcoming, and problems developed. In total there in need of repair. (EXHIBITS C,D,E) required eighteen hours of labor at $450.00. Sofa Selections has never these repairs. additional were four pieces The pieces a cost of been paid for e. In addition to the actual loss, we ask that the court set aside a reserve of a minimum of $500.00. This reserve is required as the product carries a 10 year frame warranty, 5 years springs, 2 years on cushions and 1 year on fabric. f. The reserve is required as Rich Silverman has shown that he will not honor the warranty as stated. 5. On march 12 2001 Sofa Selections submitted our purchase order Hughes6 to Rich Silverman. We were advised that we were over our credit limit. (EXHIBIT F) a. We submitted our check # 1749 in the amount of $2,706.16 dated March 12, 2001 to Hughes Furniture in anticipation of our order being filled. (EXHIBIT G) . b. We were never appraised that our order would not be filled if the check was sent. T only leaned about it several weeks later when I called the factory. c. We were advised by the factory that the order had not been submitted by Rich Silverman. We were also advised that he has complete discretion over the territory regarding sales, distribution, pricing, repairs and he would have to submit paperwork for reimbursement of repairs. We were also advised to look to him for any compensation. d. Sofa Selections has been harmed to the amount of $761.00 due to the discriminatory behavior of Rich Silverman. This amount has been arrived at by taking the selling price of the goods to customers Morris, Peiffer, and Farey, and then subtracting the cost as indicated on the purchase order. 6. WHEREFORE, Plaintiff respectfully requests that judgement be entered in favor of Plaintiff in the amount of $1,711.00. This is comprised of $450.00 for repairs already completed, future reserve of $500.00 and lost revenues of $761.00. Dated: ~~~ Respectfully submitted, ~ C J DONALD L. SPITL OWNEE~ SOFA SELECTIONS 4920 Carlisle Pike Mechanicsburg, PA 17050 (717) 763-8912 -~, .-~ 1113LI~'1:lIY SOFA SELECTIONS HAMPDEN CENTRE ~ ~ ~ ~' 4920 CARLISLE PIKE MECHANICSBURG,PA 17055 ~~~ 717 763-8912 717 763-9341 FAX DELIVERY Il2- NAME: G~LL/a LE,3"TY19~ 1I y STREET : I l t,i (,u v~(JC'd ~ G 7 CITY: m,~~~ ZIP:I,.7O~ PHONES: W H Gql~ Sq~3 SPECIAL INSTRIICTIONS: QG cxs,U S~' fJ~i2`S' ~~ ~~ ~~IVERY ITEMS OFA L S CHAIR TABLES OTHER x~-- - - THE ABOVE I S WERE RECEIVED IN GOOD CO-7N~D/I'TION. 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