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BRENNEMAN
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MIDDLESEX TOWNSHIP MUNICIPAL
AUTHORITY,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.2001- .s'91.'i (l,'o;(T€.A...hL
Plaintiff
v.
CARLISLE MOTEL AND
CAMPGROUND, INC.,
Defendant
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 twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with a 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 LA WYER 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, Pennsylvania 17013
(717) 249-3166
SNELBAKER, BRENNEMAN & SPARE, P. C.
By:
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Solicitor for Plaintiff
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MIDDLESEX TOWNSHIP MUNICIPAL
AUTHORITY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.2001- ~1./1 C"iLT~
Plaintiff
v.
CARLISLE MOTEL AND
CAMPGROUND, INC.,
Defendant
CIVIL ACTION - LAW
COMPLAINT
Middlesex Township Municipal Authority, by its Solicitor, Snelbaker, Brenneman &
Spare, P. C., files this Complaint against Defendant Carlisle Motel and Campground, Inc. as
follows:
BACKGROUND
I. Plaintiff Middlesex Township Municipal Authority (the "Authority") is a duly
authorized and existing municipal authority under the laws of the Commonwealth of
Pennsylvania with a principal office and place of business located at 350 N. Middlesex Road,
Carlisle, Middlesex Township, Cumberland County, Pennsylvania.
2. Defendant Carlisle Motel and Campground, Inc. is a Pennsylvania business
corporation with a principal office and place of business located at 1075 Harrisburg Pike,
Carlisle, Cumberland County, Pennsylvania.
3. Defendant is the owner of a parcel of real estate located at 1075 Harrisburg Pike,
Carlisle, in the Township of Middlesex, also identified as tax parcel No. 21-19-1637-011
(hereinafter the "premises").
4. Plaintiff provides municipal water and sewer service in and to various locations
throughout Middlesex Township.
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5. Defendant is provided at its premises, for its and/or the occupants of Defendant's
premises use and benefit, municipal water and sewer service by the Authority.
COUNT I
6. The averments of Paragraphs I through 5, inclusive, of this Complaint are
incorporated by reference herein in their entirety.
7. At all times relevant hereto, specifically from January 2001 through August 2001,
Plaintiff provided Defendant with water and sewer services at Defendant's premises.
8. The water and sewer services provided to Defendant by Plaintiff as described above
were provided in accordance with the terms, conditions and requirements of applicable rules,
rates and regulations as established by the Authority.
9. Defendant has consistently failed and refused to pay Plaintiff in full for charges
assessed Defendant for water and sewer services provided Defendant at Defendant's premises for
the period of January 2001 through August 2001 despite repeated requests to do so.
10. Defendant has failed and refused to pay the total amount of$19,542.57 due and
owing Plaintifffor water and sewer services provided the premises from January 2001 through
August 200 I, which sum includes applicable late charges or penalties assessed in accordance
with rules, rates and regulations of the Authority.
I I. The amounts billed by Plaintiff to Defendant for water and sewer services provided
Defendant's premises were never objected to by Defendant as being inaccurate.
12. The amounts billed by Plaintiff to Defendant for water and sewer services provided
Defendant's premises were fair, reasonable and never objected to by Defendant.
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13. The amounts due and owing Plaintiff by Defendant as set forth in Paragraph 10,
above, were billed to Defendant on a monthly basis, which bills contained a statement of current
monthly charges due together with an indication of any previous balance due on Defendant's
account for water and sewer services provided together with applicable penalties. A true and
correct copy of Defendant's account statement with amounts claimed to be due as set forth in this
Complaint, is attached hereto and incorporated by reference herein as "Exhibit A".
14. Defendant's failure timely to pay for water and sewer services provided Defendant's
premises is a material breach of Defendant's express and/or implied obligation to pay for same in
accordance with Plaintiffs applicable rates, rules and regulations.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$19,524.57 together with interest and costs of this suit.
COUNT II
(In the alternative to Count I)
15. The averments of Paragraphs I through 14, inclusive, of this Complaint are
incorporated by reference herein in their entirety.
16. The water and sewer services provided by Plaintiff to Defendant at Defendant's
premises were not provided by Plaintiff to Defendant as a gratuity.
I 7. The charges for the water and sewer services as more fully set forth in Court I of this
Complaint were fair, reasonable, customary and never objected to by Defendant.
18. Defendant wrongfully secured benefits from the use of the water and sewer services
provided Defendant's premises that would be unconscionable for Defendant to retain.
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19. Defendant has been unjustly enriched at the expense of Plaintiff in the amount of
$19,524.57.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$19,524.57 together with interest and costs of this action.
SNELBAKER, BRENNEMAN & SPARE, P. C.
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Date: Oe~6t.t 15, 20{)/
BY:
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, P A 17055
(717) 697-8528
Solicitor for Plaintiff
Middlesex Township Municipal Authority
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VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4909 relating to unsworn falsification to authorities. I verify that I am authorized to execute this
Verification on behalf of the Plaintiff in my capacity as Operations Manager.
Rory orrison, Oper ions Manager
Middlesex Townshi Municipal Authority
Date: /O-/5"-tJ/
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I D9/D7!DleL 2,477.16 1,223.83 3,700.99 19,154.47 BILLING 2001/AUGUST I
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~.o8/d2/01py -15,431.59 -6,189.27 -21,620.86 11,708.39
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~'01jOS101BL 1,418.76 708.63 2,127.39 18,528.98 ,BILLING 2000/DEC. ;ff
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-05969 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MIDDLESEX TOWNSHIP MUNICIPAL
VS
CARLISLE MOTEL AND CAMPGROUND
SHANNON SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CARLISLE MOTEL AND CAMPGROUND INC
the
DEFENDANT
, at 1519:00 HOURS, on the 17th day of October ,2001
at 1075 HARRISBURG PIKE
CARLISLE, PA 17013
by handing to
RAY CASHILL, OWNER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18,00
3,25
,00
10,00
,00
31.25
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R. Thomas Kline
10/18/2001
BRENNEMAN &
Sworn and Subscribed to before
By:
SPARE
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me this 3/.....-
day of
C)~ .2C>o \ A,D.
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P othonotary .
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MIDDLESEX TOWNSHIP
MUNICIPAL AUTHORITY,
Plaintiff
vs.
CARLISLE MOTEL AND
CAMPGROUND, INC.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
01-5969 CIVIL
IN RE: MOTION TO COMPEL
AND NOW, this
Jlih
ORDER
day of April, 2002, a rule is issued on the defendant to
show cause why the relief requested in the within motion ought not to be granted. This rule
returnable twenty (20) days after service.
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BY THE COURT,
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PENNSYLVANIA
LAW OFFICES
SNELBAKER,
BRENNEMAN
& SPARE
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MIDDLESEX TOWNSHIP MUNICIPAL
AUTHORITY,
Plaintiff
v.
CARLISLE MOTEL AND
CAMPGROUND, INC.,
Defendant
AND NOW, this
day of
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-5969 CIVIL TERM
CIVIL ACTION - LAW
ORDER
, 2002, upon consideration of
the Motion To Compel of Middlesex Township Municipal Authority, it is hereby ORDERED
that Defendant shall file an answer to Plaintiffs Interrogatory directed to Defendant within
twenty (20) days of the date of this Order.
BY THE COURT:
J.
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02 JiPfi I i Al'll0: 02
CUMBl::RLfh:[) COUNTY
PENNSYLVANIA
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MIDDLESEX TOWNSHIP MUNICIPAL
AUTHORITY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
: NO. 2001-5969 CIVIL TERM
CARLISLE MOTEL AND
CAMPGROUND, INC.,
Defendant
CIVIL ACTION - LAW
PLAINTIFF'S MOTION TO COMPEL
ANSWER TO INTERROGATORY
Plaintiff Middlesex Township Municipal Authority, by its Solicitors, Snelbaker,
Brenneman & Spare, P. C., files this Motion To Compel and in support thereof states the
following:
I. On February 21, 2002 Plaintiff served upon Defendant an Interrogatory. A true and
correct copy of the aforementioned Interrogatory is attached hereto and incorporated by
reference herein as "Exhibit A".
2. Contrary to the Notice contained with the Interrogatory, Defendant failed to file any
response to the Interrogatory within thirty (30) days of February 21, 2002.
3. On March 26, 2002 counsel for Plaintiff sent to the Defendant a letter reminding them
of their obligation to serve an answer to the Interrogatory. A true and correct copy of the letter
dated March 26, 2002 is attached hereto and incorporated by reference herein as "Exhibit B".
4. Defendant has failed and refused to provide an answer to the Interrogatory in spite of
the initial notice provided to it and the subsequent letter made reference to in Paragraph 3, above.
WHEREFORE, Plaintiff requests this Court to issue an Order directing that Defendant
provide a full and complete answer to the Interrogatory served within twenty (20) days ofthe
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date of the Court's Order.
SNELBAKER, BRENNEMAN & SPARE, P. C.
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By:
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PAl 7055
(7 I 7) 697-8528
Solicitors for Plaintiff
Middlesex Township Municipal Authority
Date: April 3, 2002
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I MIDDLESEX TOWNSHIP MUNICIPAL
, AUTHORITY,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v,
: NO. 2001-5969 CIVIL TERM
CARLISLE MOTEL AND
CAMPGROUND, INC.,
Defendant
CIVIL ACTION - LAW
TO: Carlisle Motel and Campground, Inc., Defendant
,: PLEASE TAKE NOTICE that you are hereby requested pursuant to Pennsylvania Rules
iii
I
of Civil Procedure 4001, et seq., to serve upon the undersigned within thirty (30) days after
service of this Notice, answers in writing and under oath to the following Interrogatory.
SNELBAKER, BRENNEMAN & SPARE, P. C.
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Date: February 21, 2002
By:
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PAl 7055
(717) 697-8528
Solicitor for Plaintiff
Middlesex Township Municipal Authority
EXHIBIT A
LAW OFFICES
SNe:LBAKER.
BRENNEMAN
& SPARE
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DEFINITIONS AND INSTRUCTIONS
When you are asked to "name" a person or individual, you are to state the first name, last
name and any known middle initial for such person or individual.
When you are asked to give the address of any person or individual, state the lot number,
if applicable, together with street as well as the entire mailing address.
INTERROGATORY
1. State the name and address of each and every person who is a tenant at the property of
Carlisle Motel and Campground, Inc. located at 1075 Harrisburg Pike, Carlisle, whether or not
the tenant resides there,
ANSWER:
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SNEL8AKER.
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CERTIFICATE OF SERVICE
I, KEITH 0, BRENNEMAN, ESQUIRE, hereby certify that I have on the below date,
caused a true and correct copy ofthe foregoing Interrogatory to be served upon the person and in
the manner indicated below:
FIRST CLASS MAIL POSTAGE PREPAID, ADDRESSED AS FOLLOWS:
Carlisle Motel and Campground, Inc.
I075 Harrisburg Pike
Carlisle, PA 17013
I~
Keith O. Brenneman, Esquire
SNELBAKER, BRENNEMAN & SPARE, P. C.
44 W. Main Street
P.0,Box318
Mechanicsburg, PAl 7055
(717) 697-8528
Solicitors for Plaintiff
Date: February 21, 2002
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SNELBAKER, BRENNEMAN 8 SPARE
^ PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
44 WEST MAIN STREET
MECHANICSBURG, PENNSYLVANIA 17055
RICHARD C. SNELBAKER
KEITH O. BRENNEMAN
PHIUP H. SPARE
717-697-8528
P. O. BOX 318
FACSIMILE (717) 697-7681
March 26, 2002
Mr. and Mrs. Raymond Cashill
Carlisle Motel & Campground, Inc.
I 075 Harrisburg Pike
Carlisle, PAl 70 13
Re: Middlesex Township Municipal Authority v. Carlisle Motel & Campground, Inc.
No. 2001-5969, Cumberland County
Dear Mr. and Mrs. Cashill:
On February 21, 2002 I sent to Carlisle Motel & Campground, Inc. an Interrogatory to be
answered, It has been more than thirty days since the service of the Interrogatory upon you.
If I do not receive in writing from you an answer to the Interrogatory which sets forth the
name and address of each of your tenants, I will proceed with obtaining an Order from the Court
compelling you to provide that information.
Please be guided accordingly.
Yours truly,
Keith O. Brenneman
KOB/sz
CC: Rory Morrison, Operations Manager
EXHIBIT B
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CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date,
caused a true and correct copy of the foregoing Motion to be served upon the person and in the
manner indicated below:
FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS:
Date: 1/(l1U1 ~I 2OOJ-
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Carlisle Motel and Campground, Inc.
1075 Harrisburg Pike
Carlisle, PAl 7013
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Keith O. Brenneman, Esquire
SNELBAKER, BRENNEMAN & SPARE, P. C.
44 W. Main Street
P. O. Box 318
Mechanicsburg, PAl 7055
(717) 697.8528
Solicitors for Plaintiff
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MIDDLESEX TOWNSHIP
MUNICIPAL AUTHORITY,
Plaintiff
v.
CARLISLE MOTEL AND
CAMPGROUND, INC.,
Defendant
TO THE PROTHONOTARY:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 2001 -5969 CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE
Please mark the above-captioned action satisfied, discontinued and ended upon your
docket and indices.
Date: September 6, 2002
SNELBAKER, BRENNEMAN & SPARE, p, C.
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BY:
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PAl 7055
(717) 697-8528
Solicitors for Plaintiff
Middlesex Township Municipal Authority
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CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date,
caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the
manner indicated below:
FIRST CLASS MAIL POSTAGE PREPAID. ADDRESSED AS FOLLOWS:
Carlisle Motel and Campground, Inc.
1075 Harrisburg Pike
Carlisle, PA 17013
~
Keith 0, Brenneman, Esquire
SNELBAKER, BRENNEMAN & SPARE, p, C.
44 W. Main Street
p, 0, Box 318
Mechanicsburg, P A 17055
(7 I 7) 697-8528
Attorneys for Middlesex Township Municipal Authority
Date: q (f ( f/2..
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