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Home My WebLink About99-01316 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA D. THEODORE OPPERMAN. DMD and SUSANNA OPPERMAN. Plaintiffs. c.A. No. 99-1316 v. WILLIAM ADAMS and SUSAN ADAMS. Defendants. PETITION FOR WITHDRAWAL OF APPEARANCE or CONTINUANCE 1. Petitioner is Mary Ann P. Bazzano, counsel of record for Defendants William Adams and Susan Adams. 2. Defendant William Adams is currently a resident of a Correctional Facility in the state of Florida. 3. There has been no activity with this matter for three years as referenced in the docket. 4. Since his incarceration, Defendant Susan Adams has filed for divorce against her co-defendant William Adams. Petitioner represents Defendant Susan Adams in that divorce action. 5. Defendant Susan Adams has retained a counsel to represent her in this action, specifically Mark Bailey, Esquire. An entry of appearance by Mr. Bailey and withdrawal of appearance pleading by Mary Ann P. Bazzano will be filed of record. 6. Petitioner has had no contact with Defendant William Adams about this matter for several years and has no authority to further advocate on his behalf. WHEREFORE, Petitioner requests this court to grant her Withdrawal of COG III :Os ~ ~g, II: "!;i III ..~ ~ "i III ...."" Z ~~ < ~ m ~i ~ I '"~ III ~~!gf u .!l > II < ~ ~ ~~ ~ I 0 .... >- 0 U "!.... i Sl::f~ ....N <l ....... U "iN Q ~~ 0 ......,: > ........ ........ II ~~ == U < 4. On Junc 7. IlJlJlJ. f)c!cndunts. Ihcn rcprcscntcd by Mury Annc lluzzllno. Esquirc.joinlly tilcd un Answcr 10 I'luintifls' ('ompluint (ullachcd liS Exhibil "Il"). 5. Said Answcr admits IlmtPlaintins and Defendant. William Adllms. cntered into an oml contract to pcrform ecrtain construction work: however. said Answcr specifically dcnics Ihal Dclcndanl. Susan Adams, cntered into the samc contract with PlaintilTs. 6. The only conncction thut Dcfcndant. Susan Adams. has with the lawsuit is thc fact that she was once marricd to Defcndant. William Adams. 7. Defcndants wcre subscquently divorced after Pluintiffs filed their Complaint. 8. Plaintiffs listcd the above case lor Trial by Praecipe dated October 23, 2003. over four (4) years after the Complaint was filed. 9. Plaintiffs have requested and completed no discovery with regard to the Complaint. 10. Plaintiffs have failed to support Ihe allegation that Defendant. Susan Adams. was a party to the aforementioned "oral contract" in any way. 11. There exists no genuine issue of any material lacts with regard to Count I of Plaintiffs' Complaint. WHEREFORE. Defendant. Susan Adams. respectfully requests that the Court enter Summary Judgment in her favor and against Plaintiffs on Count I of the Complaint. II. MOTION FOlt SlJMMAltV ./lII>GMENl' TO COUNT II OF I'LAINTIFFS' . COMI'LAINT HV I)EFF.N1>ANT. SUSAN AI)AMS 12, Prcvious parugruphs arc incorporlltcd in thcir cnlircly hcrcin. 13. ('ountll of Plaintills' Complaint stutcs a cluimlilr Unlilir Trude Practices in Consumcr Protcetion Law. 14. Pluintills uilcgc thutthc "conducl ofthc Dcfcndants was fraudulcnt and in bud faith in ordcr to dcccive Ihc Pluintil1s." 15. Plaintiff.~ havc rcqucslcd and complctcd no discovcry with rcgard to the Complaint. 16. PlaintilTs havc failcd to support the above allegalions in any way. 17. Plaintiffs have tililed to support Susan Adams' connection with the alleged contract and/or fraud in any way. 18. There cxists no genuine issue of any material fact with regard to the Unfair Trade Practices claim contained in Count II of Plaintiffs' Complaint. WHEREFORE. Defendant. Susan Adams. respectfully requests that the Court enter Summary Judgment in her favor and against Plaintiffs on Count II of the Complaint. Respectfully submitted. ROMINGER & BA VLEV Date: t Z--2.-0 ~ ~ Mark F. Bayley. Esquire 155 S. Hanover Street Carlisle. P A 170 J 3 (7 J 7) 24 J -6070 Supreme Court I.D, # 87663 Attorney for Defendant ; , D. Thcodorc Opperman. DMD lInd Susanna Oppcrman. PllIintilTs : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA t v. : CIVil. DIVISION Williams Adams and Susan Adams. Dcfcndants : CA NO. 99.1316 VERIFICATION MARK F. BA YLEY. ESQUIRE. statcs that hc is thc lIttorncy for Dcfendant. Susan Adams. in this action; that hc makcs this aftidavitas attorncy bccausc hc has suflicicnt knowlcdgc or information and bclicf: bascd upon his invcstigation of thc mattcrs avcrrcd or dcnicd in thc foregoing document; and that this statcmcnt is madc subjcctto thc pcnalties of 18 Pa.C.S. ~4904. relating to unsworn falsification to authorities. Datc: 12-Z-0:5 ~ Mark F. Baylcy. Esquirc Attorncy for Defendant interior painting and built-in cabinctry. TI1C contract pricc for thc aforesaid work WllS thc total sum of Twelve Thou.o.and and .00/100 ($i2,000.00) dollars. Thc work was to be concludcd on or bcforc August 28, 1998. 5. The Plaintiffs paid thc Dcfcndants thc sum of One Thousand Five Hundrcd and.OO/IOO ($1,500.00) dollars prior to commencement of work. Thcrcaficr. the Plaintiffs paid periodically additional sums of money totaling Ten Thousand Nine Hundred and .0011 00 ($10,900.00) dollars. 6. The Defendanls never completcd the work as refcrenccd in paragraph four (4) by August 28, 1998. 7. The Plaintiffs made rcpeatcd requests upon the Defendants to complcte the work and they failed to do so. 8. As a rcsult of the Dcfendants' failure to complete the work, the Plaintiffs were requircd to pay additional sums of money to complete thc aforesaid projcct referenced in paragraph four (4). 9. In addition to the monies total Twelve Thousand Four Hundred and .00/100 ($12,400.00) dollars that the Plaintiffs paid to the Defcndants, the Plaintiffs were required to pay a sum in excess ofTwelve Thousand and .001100 ($12,000.00) dollars to complete the work not completed by the Defendants and to completc defective and improper work that the Defendants performed. 10. The Defendants also failed to properly perform the work in a good and workman- like manner in addition to its failure to completc thc project. Plaintiffs in this lransaclion. As a re;;ull ofthc actions being in violation of73 P.S. ~201-1 et seq., the Plaintiffs arc cntilk-d to trcblc damagcs. 17. Furthcr, as a rcsull of thc conduct ofthc Dcfcndants, thc Plaintiffs arc also entitled 10 rcimbursement of nil attorncy fccs cxpcndcd. WHEREFORE, Plaintiffs dcmand judgmcnt against the Dcfcndants for treble damages in thc amount in cxcess ofThirty-scvcn Thousand Two Hundred and .00/100 ($37,200.00) dollars plus costs, intcrcst and altorncy fees. Respectfully submilted, THE MOLNAR LAW OFFICES /...---.." . ",- , John Molnar, /;:squire . Wind Gap PrOfessional Center "669.t~ullivaP Trail WindCiap,'PA 18091 (610) 863-3200 Attorney I.D. No. 21425 0_. _ ~ , I I I I I f I I I' I ,. j.. .. l f I. f I COnSlnlClion work allhc PlainliJls' rcsidcJllial dwelling aI 21112 Merion Road. Camp 11iI1. Cumberland (:oullly. I'cnnsylvania II is spccifically dcnicd that on or nhoul May 15, 19911. thc Plailllifis and Dcfcndant. Susan Adams. enlcred into an oral conlrnct to perlorm certain constnlction work at the Plaintills' residcnlial dwclling at 2812 Merion Road. Camp Hill. Cumberland County, Pennsylvania. It is spccifically denied that the aforesaid conslnlction work was to include the conversion of a side porch into an enclosed family room with siding. new roof, windows. exterior doors and intcrior work including molding. interior trim, drywall, interior painting and built in cabinetry. It is admilled the contract price for the aforesaid work was the total sum of $12.000. It is denied Ihe work was 10 be concluded on or before August 28. 1998. 5. Admilled. 6. Admilled. 7. Denied. It is specifically denied the Plaintiffs made repeated requests upon the Defendants to conclude the work and they f.1iled to do so. 8. Defendants do not have suflicient intormation to either admit or deny this allegation and. thercf(lre, strict pro0fis demanded at trial. 9. Defendants are without suflicient information to either admit or deny this allegation and, therefore. strict proof is demanded at trial. 10. Denied. It is specitically denied the Defendants failed to properly perform the work in a good and workmanlike manner in addition to its failure to complete the project. II. This is a conclusion of law to which no response is required. ~ .... M r- .. ~~ 10 . ) ~. ") ( "',~ :c G':(--' "" ):;:j 9 t- ...~ '", N '~U) (J .;. I z ''':'!:." f';.?' c.: diD ..i:,." - l.. ::.1 a.. (": C:' ". .~ ") ::> r..:> U " D. Theodore Opperman, DMD and Susanna Opperman, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL DIVISION Q 0 0 r.. w " ;;~ ."" .... rB'''' ill '::'!l '" ,") z-" , - I ,.fP ~:;-. w ,.J -- .~ :'::l,,:J ~[': .", " :;:(, ::>: :-\,Ji 'q >'.' 'i! :.,n .~ C. -. :.~ ~ 5; :,1 '" -< Williams Adams and Susan Adams, Defendants CA NO. 99-1316 MOTION FOR CONTINUANCE AND NOW, comes Defendant, Susan Adams, by and throu9h her attorney, Mark F. Bayley, Esquire, and in support of this Motion avers as follows: 1. Plaintiffs filed a Complaint with regard to the above mailer on or around May 17, 1999. 2. Plaintiffs listed the above case for non-jury Trial by Praecipe dated October 23, 2003, over four (4) years after the Complaint was filed and after completing and requesting no discovery. 3. The Honorable Edgar B. Bayley scheduled a Trial to take place on December 8, 2003, 4. Co-Defendants were initially both represented by Mary Ann Bazzano, Esquire. 5. Co-Defendants have been divorced since the Plaintiffs' Complaint was filed and their interests are now divergent. 6. On December 2, 2003, the undersigned allorney entered his appearance on behalf of Susan Adams. >- - ?: s~ (";. z ,- ;3~ UJ~:'J - - ..)~ (..'~ ,': .... LL.... . < '.J-~ '1- c'. (,.}C) N '-~in C.)~.. I ')2 t" J ,}idi l.r\:.~ u w.l t.!.lQ,. ~~. t::l ::.;; 'L. C'? :::> 9 0 (,.) COG ~ i~8 III :Os "!~ II: ;~ III 3: "! ....00 III i~ z ~ ~ ~~ ~ 01: I "'f 08!:! 0>;:: III .!! ~! ~I'f u - > Q 01: ~ ~j~~i I 0 >- "!.., U ~N ...- C NN U ". ~ ~~ ~... 0 ....;:! > ~~ == Q 01: interior painting and built-in cabinetry. The contract price for the aforesaid work was the total sum of Twelve Thousand and .00/100 ($12,000.00) dollars. The work was to be concluded on or before August 28, 1998. 5. The Plaintiffs paid the Defendants the sum of One Thousand Five Hundred and.OO/IOO ($1,500.00) dollars prior to commencement of work. Thereafter, the Plaintiffs paid periodically additional sums of money totaling Ten Thousand Nine Hundred and .00/1 00 ($J 0,900.00) dollars. 6. The Defendants never completed the work as referenced in paragraph four (4) by August 28, 1998. 7. The Plaintiffs made repeated requests upon the Defendants to complete the work and they failed to do so. 8. As a result of the Defendants' failure to complete the work, the Plaintiffs were required to pay additional sums of money to complete the aforesaid project referenced in paragraph four (4). 9. In addition to the monies total Twelve Thousand Four Hundred and .00/100 ($12,400.00) dollars that the Plaintiffs paid to the Defendants, the Plaintiffs were required to pay a sum in excess of Twelve Thousand and .00/100 ($12,000.00) dollars to complete the work not completed by the Defendants and to complete defective and improper work that the Defendants performed. 10. The Defendants also failed to properly perform the work in a good and workman- like manner in addition to its failure to complete the project. VERIFICATION I, John Molnar, Esquire, being duly sworn according to law and state that 1 am attorney for D. Theodore Oppcrman, DMD and Susanna Opperman, husband and wife. and that 1 make this verification on thcir behalf and that the said D. Theodore Opperman, DMD and Susanna Opperman, husband and wife are unavailable and unable to make this verification on their behalf and that the facts set forth in the Complaint are true and correct to the best of counsel's knowledge. information and belief. This verification is made pursuant to Pa. R.C. P. 1024 and is based on interviews, conferences, reports, records and other investigatory material in this file. Date: May 14. 1999 ,/ John MOin~-, squire Attomey for . Theodore Opperman, DMD Susanna pperman, husband and wife f1:IWPDA T AILlTIGA TII0PPERMANlADAMSICOMPLAIN,DOC ~ ?:; ... ~) :l :.:.: ~ 0 ., V ~ ... _ r.' . ~ u '" :: ~ ~ .:..0(.... C/l o ... " Q: ~ S:S '8 ~ ~ ~ "" ~ ~ .~ '. ~ ~~ III ;::: 0 ~ ~ ~ ~ . ~~<~~ ~ ~ It. e:l;;' (f. ~ ;:J M .... ~ ~~ . ~ m gJ m Cl::: ~ ." ~ i'. C/l"" 3 ~ 0 rr. ;J ~ i~ ~Ul"" c .' Q: ill IJJ Co ~~ . "Sill a. I'. :.. fool " Ula.", rn 1ll"S 8 ...l ;J,. Co a.0;i :> <lJ ~ 0 Q ~ ~~ a. . UJ"" o ~ P: ~ \j 08 ol~ ~~ ~ c ~ ~ gJ Po ~ ~ ~ ~ ~~ 8!!l - it: ... ~ - ... " @Ul 1-< " " >-< .. p '" '" ~~ . ~ Q .~ ,~ I ,-: (-.... -- '., -\1 ;-\0 . ~- ': -) r'J l/) ',.} q 0- 0 0-- , '.....d () ., '.... 1\ :1j , (-_I t-) '.~ '-' -;;: j ~ rJl 5 ... Ol ~ ~ 0 'g ~ tJ Ol ..... ~ ... 10 ~ I !:: 0 cd:l -< ~ c c o ~ Wi ~ Z 10 > Z ~ -< ~E rn Hi\! ~ S ~ ~ :l'D ~~ Ul... ~~ .., ...:l ~ (') ~ Ul '0... . C I ot~ ~~~g~ rn 100\ O:H 8'''' :> 0\ f2~ <lJ @ ~ 0 ~ Ul jl, ~t.. Co ~z ...l ,.. >< rn ~~~~~ ~~ fjO ffi H ti 'M !;J ~ ~ ~ "" o. "" . 'M ... 1-< ... ~ Cl 3: ~ '. Defendant, Susan Adams, enter~-d into the sonIC contruct with Plaintiffs. Defendants' Answer also denied 011 "fraud" and "bad faith" alleged in Count II under the Unfair Trade Practices and Consumer Protection Law as to both Defendants. The only conncction Defendant, Susan Adams, has with the lawsuit is the fact that she was once married to Defendant, William Adams. Defendants were subsequently divorced after Plaintiffs filed their Complaint. Plaintiffs listed the above case for Trial by a Praecipe dated October 23, 2003, over four (4) years after the Complaint was filed. The Honorable Edgar B. Bayley scheduled a Trial to take place on December 8, 2003. The case was subsequently transferred to the Honorable Kevin A. Hess due to the undersigned counsel's involvement and his relationship with Judge Bayley. Trial was continued until March 22, 2004. Plaintiffs requested and completed no discovery in connection with the Complaint. II. DISCUSSION: Under the Pennsylvania Rules of Civil Procedure, with respect to summary judgment, it is provided as follows: [A]ny party may move for summary judgment in whole or in part as a malleroflaw 1) whenever there is no genuine issue 0 f any material fact as to a necessary element of the cause of action or defense which could be established by additional discovery or cxpert report, or 2) if, after the completion of discovcry relevant to lhc motion, including the production of expert reports, an advcrse party who will bear the burden of proof at trial has failed to produce evidence of facts esscntialto the cause of action or defense which in a jury trial would require the issues to be submitted to ajury. Pa. R.C.P. 1035.2. Plaintiffs bear the burden of proof at trial of facts essential to their cause of action. An essential element Plaintiffs must prove with regard to Count I is that Defendant Susan Adams was party to the alleged "oral contract". Plaintiffs completed no discovery with regard to the aforementioned Complaint. It can be presumed that the record is closed due to the fact that Plaintiffs listed the case for trial. There is no support in the record that Susan Adams was a party to the alleged "oral contract" in any way. Therefore, the issue should not go to ajury. An essential element Plaintiffs must prove with regard to Count II is that Defendant Susan Adams was connected with the alleged "fraud" or "bad faith". There is no support in the record that Susan Adams was involved with either of these items, Therefore, the issue cannot be put to a jury. III. CONCLUSION An individual is not obligated by a contract in which he or she is not a party. Without facts in the record to connect Susan Adams with the alleged "oral contract", Summary Judgmcnt must be gruntcd to SUSlIll Adums with rcgurd to Count 1 oflhe Complaint. Likewise, Pluintiffs offer no support that Susan Adams was cOMected with the "fraud" or "bad faith" alleged in Count II. Summary Judgment is appropriate for this count as well. Respectfully Submitted, ROMINGER, BAYLEY & WHARE l-t, t-Q\l Date Mark F. Bayley, E' ulfe 155 S. Hanover Street Curlisle, PA 17013 (717) 241-6070 Supreme Court 1.0. # 87663 Attorney for Defendant D. Theodore Opperman, DMD and Susanna Opperman, Plointiffs : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA v. : CIVIL DIVISION Williams Adams and Susan Adams, Defendants : CA NO. 99-1316 CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant, Susan Adams, do hereby certify that I this day served a copy ofthe Motion for Continuance upon John Molnar, Esquire and Mary Anne Bazzano, Esquire, by Fax and First Class Mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: John Molnar, Esquire The Molnar Law Offices Wind Gap Professional Center 6697 Sullivan Trail Wind Gap, PA 18091 FAX #(610) 863-3232 Mary Anne Bazzano, Esquire 502 West Cypress Street P. O. Box 942 Kennett Square, P A 19348 FAX #(302) 652-5379 Dated: I -. OZ. g-' "J,' (j t" I , . t}\M Mark F, Bayley, Esquire Allomey for Defendant, Susan Adams interior painting and built-in cabinetry Thc contract price for the aforesaid work was the total sum of Twelve Thousand and .00/100 ($12,000.00) dollars. Thc work was to be concluded on or before August 28, 1998. 5. Thc Plaintiffs paid thc Defendants the sum of One Thousand Five Hundred lIJ1d.OO/IOO ($1,500.00) dollars prior to commcncemcnt of work. Thereafter, the Plaintiffs paid periodically additional sums of money totaling Ten Thousand Nine Hundred and .00/100 ($10,900.00) dollars. 6. The Defendants never completed the work as referenced in paragraph four (4) by August 28, 1998. 7. The PlaintitTs made repeated requests upon the Defendants to complete the work and they failed to do so. 8. As a result of the Defendants' failure to complete the work, the Plaintiffs were required to pay additional sums of money to complete the aforesaid project referenced in paragraph four (4). 9. In addition to the monies total Twelve Thousand Four Hundred and .001100 ($12,400.00) dollars that the Plaintiffs paid to the Defendants, the Plaintiffs were required to pay a sum in excess of Twelve Thousand and .00/100 ($12,000.00) dollars to completc the work not completed by the Defendants and to complete defcctive and improper work that the Defendants performed. 10. The Defendants also failed to properly perform the work in a good and workman- like manner in addition to its failure to complete the project. II. As a result of Defendants fililure to complete and thc dcfective and impropcr workmanship, the Plaintiffs have beell damaged in the sum in cxcess of Twelve Thousand and .00/100 ($12,000.00) dollars. WHEREFORE, Plaintiffs rcqucstjudgment :Igainst the Defendants in the amount in excess of Twclve Thousand and .00/100 ($12,000.00) dollars plus costs and interest. COUNT TWO - PRIV ATE ACTION UNDER THE UNFAIR TRADE PRACTICES AND CONSUMER PROTECTION LAW 73 P.S.S201-1 et seq. 12. Paragraphs one (1) through elevcn (1 I) are hercby incorporated by reference as fully as though set forth hcrein and at length. 13. The Defendants did violate the laws of the Commonwealth of Pennsylvania including but not limited to the Unfair Trade Practices and Consumer Protection Law (73 P.S. 9201-1 et seq.) More specifically, the Defendants received monies from the Plaintiffs to ' construct the residential addition as set forth in paragraph four (4) and used those monies for their own purposes and did not complete the project as required. 14. The conduct of the Defendants was fraudulent and in bad faith in order to deceive the Plaintiffs by paying to the Defendants under the assumption that the work would be completed. 15, Said conduct of the Defendants was an unfair method of competition or an unfair or deceptive act or practices as defined under 73 P.S. 9201-2. Said acts under 73 P.S. 9 201-2 culminated in the Defendants engaging in a fraudulent conduct which creates the likelihood of confusion or of misunderstanding. 16, The fraud perpetrated on Plaintiffs by the Defendants was willful and wanton and was perpetrated with malice, vindictiveness and wholly wanton disregard of the rights of the construction work at the Plainlill's' residential dwclling at2812 Mcrion Road, Camp Hill, Cumberland County, Pennsylvania. It is spccifically denied that on or about May 15, 1998. the Plaintiffs and Defendant, Susan Adams, entered into an oral contract to perform ccrtain constnlction work at the Plaintifis' residential dwelling at 2812 Merion Road, Camp Hill, Cumberland County, Pennsylvania. It is specifically denied that the aforesaid construction work was to include the conversion of a side porch into an enclosed f.lmily room with siding, new roof, windows, exterior doors and interior work including molding, interior trim, drywall, interior painting and built in cabinetry. It is admitted the contract price for the aforesaid work was the total sum of$12,OOO, It is denied the work was to be concluded on or before August 28, 1998. 5. Admitted, 6, Admitted, 7. Denied. It is specifically denied the Plaintil1S made repeated requests upon the Defendants to conclude the work and they failed to do so. 8, Defendants do not have sufficient information to either admit or deny this allegation and, t!)ercFore, strict pJ'l)(1fis,demande,d at trial. 9. Defendants are without suffici'ent information to either admit or deny this allegation and, therefore, strict proof is demanded at trial. 10. Denied, It is specilically denied the Defendants failed to properly perform the work in a good and workmanlike manner in addition to its failure to complete the project. II. This is a conclusion of law to which no rcsponsc is required, iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYL V ANlA D. THEODORE OPPERMAN. DMD and SUSANNA OPPERMAN, Plaintiffs, C.A. No. 99-13 16 v. WlLLIM1 ADAMS and SUSAN ADAMS, Defendants. CERTIFICATE OF SERVICE I, Mary Ann P. Bazzano. hereby certify a true and correct copy of Defendants' Answer to Plaintiffs' Complaint was served via regular United States Mail to the individual below on the date indicated: John Molnar, Esquire The Molnar Law Offices Wind Gap Professional Center 6697 Sullivan Trail WindGap,PA 18091 COOCH AND TAYLOR DATE: &/j/17 BY: (, MARY (P. BAZZ 502 West Cypress Street P.O. Box 909 Kennett Square, P A 19348 (610) 444-3700 Attl)rneys for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA D. THEODORE OPPERMAN, DMD and SUSANNA OPPERMAN, PlaintilTs, C,A. No, 99-1316 v. WILLIAM ADAMS and SUSAN ADAMS, Defendams. CERTlFICATE OF SE!tVICE I, Mary Ann p, Bazzano, hereby certify a true and correct copy of Defendants' Answer to PlaintilTs' Complaint was served via regular United States Mail to the individual below on the date indicated: John Molnar, Esquire The Molnar Law Offices Wind Gap Professional Center 6697 Sullivan Trail Wind Gap, PA 18091 COOCH AND T AYLOR DATE: &/J/97 BY: (, MARY AN, P. BAlZ 502 West Cypress Street P.O. Box 909 Kennell Square, PA 19348 (610) 444-3700 Attorneys for Defendants construction work at thc Plaintill's' residelllial dwelling at 2812 Merion Road, Camp Hill, Cumberland County, "cnnsylvania It is specifically denied that on or about May 15, 1998, the Plaintill's and Defendant. Susan Adams. entercd into an oral contract to perf olin ccrtain construction work at the ('laintil1's' residential dwelling at 2812 Merion Road, Camp Hill. Cumberland County, Pennsylvania, It is specifically denied that the aforesaid construction work was to include the conversion of a side porch into an enclosed f.1mily room with siding, new roof, windows. exterior doors and interior work including molding, interior trim. drywall. interior painting and built in cabinetry, It is admitted the contract price for the aforesaid work was the total sum of $12.000, It is denied the work was to be concluded on or belore August 28. 1998, 5. Admitted. 6. Admitted. 7. Denied, It is specifically denied the Plaintill:S made repeated requests upon the Defendants to conclude the work and they f.1iled to do so, 8, Defendants do not have sullicient information to either admit Dr deny this allegation and. therd1Jre. strict pro('lf is demanded at trial. 9. Defendants are without sullicient information to either admit or deny this allegation and, therefore, strict proof is demanded at trial. 10. Denied. It is specitically denied the Defendants failed to properly perform the work in a good and workmanlike manner in addition to its lililure to complete the project. 11. This is a conclusion of law to which no response is required. 1;; U') ~ C is c.:: :-;~ IJ If:? '5:.) fr :<; 0;;: '(, ['.r <.1_ (:1?i SiC .. ~)- I, .- ~~U) 8f; I L "...- :J':Z --il' -- 'UiiJ li:. ' =5 Jol.: nlu.. --, "> ~ C'\ ::; 0'\ U . - -I '-e." --r- .;--'-'.- r~l ~ . ---~- -~ -' - ., :t; Q: - ',' Cl ~ ... S~ " 0 "S Ul v ... ., ~~ ~ .... ~ ..l'" '" Ul ~ ~ . ~ ~ to; ~I ... '"'1 ..l ... -< ... 0 "- ~ " ~ a.~ .t~ ~ ~ ~ :: ~ ;< Ul S ~ ~ ~ i~ ::>00 Po ~ Ul'" a. ~ ~ :'. ;,. IUl"" 't:l i6 .0: ..l Po '... . ~ ' rJi Ula..., . i6"S '" ~ "" ~ :~ Poo;i rn f2 ,.; " e ..l ~. a. . :> <lJ .... ... ..... ol~ Ul"" ~ o rJi ;; .J ~~ OJ ~ fY ~ ::' gJ c.. a. , E: r- rJi ... ~ >-< - :J ,.. ",. ~~ 8!!l ~ 0 Co 0 Cl ... .;l 0 ~ @UJ ~ - :3 Q: ;:) ~ ".~ P >-< Po :.l ~ ~ ~~ "" ~ "" .... ... . >-< .... ... ... Cl :;: 1-< ~ " .. . OCT 2 4 2003 \.. II; " PRAECIPE fOR LiStiNG CASE FOR TRIAL (It.tst be typ.written lIIld sutrn1tted in duplicate) 'to TIl!: PIOI1a01'ARY or ClHIERLAN> coom'Y ( Plelll!le list the fallowing case. (Chec:k one) tor JURY trilll at the next term of civil court:. for trie1 without a :lw:y. x ----------------------------------------- CAPTION OF CASE (entire eaptial /lUSt be stated in full) (check one) I" (X) Civil Action - Law Appeal fran Arbitr"Uon D. Thecdore OA>eIman. !:MD and Susanna OppeIlllan (other) (Pl"intiff) vs. Willian Mans and Susan J\dans The trial list will be cilled on !II'ld Trials comrence on (Defendant) Pretrials will be held on (Briefs are due 5 days before pretrials.) (The party listing this ClISe for trial shall provide forthwith " cOf1Y of the praecipe to all counsel. pursU!lJlt to local Rule 214.1.) vs. No. Civil 99-1316 19 Indicate tM attomey who will try case for the party who files this pzaecipe: John Molnar , Esquire Indicate trial counsel for other parties if known: Mary Ann P. Bazzano, Esquire This case is ready for trial. , Esquire Date: October 23. 2003 1:-U .111 JWlMtM Of ....."VANIA f C_ pu'iO.'-- /' I"'" V . rtOM NOKIAI ..tlllet DISTRICT JUSTICE JUDGMENT COMMON 'UAS.... . t '; - I ~ I b C \ '.' ',: 'r t:! r Ii' NOTICE OF APPEAL Notice .. oi- Ihat .... --'>0' he" ldod on ,ho oboYo C_, of Coovnon PIoo. on oppooI front 'ho j~ rondered by tho Di.'rict Juat~. on tho ... and In tIw COM _.""...l below HA./lW CJ ~-_.--==- .._, ~'_.-_._,~-~._----~- _'I MollO Cdf:OIlU.'Ml"Or D, ll) j I , I. ii" 1 I ,t J ! I '"" J t- r I'; ,t 1\ " '... , IlIUaI or ~ OJY. A ,a;: . J.,:; I t.,/ "I{" H ::'./ C. ;~ J\\ e HI LI_ 1)/.) ~ ~(.urorl""rIIl Jjf"L:> (~J -miJd'll___Ll. ~ .L'{lp, Kr:" -'?~',':' rd\)rhl", tl~' / ,"'", "~J~)' CV 19 II ;', x- , .rt;~" ( 'rl C (I LHU.., I (.~ Cf L. :t- LT 19 i t n. bIot~ w' be algnod ONly"",," ,hi. nololion i. required under Po. R.cP JP, No. 1001l "* No'ko of AjIpO<lI. wl_ _oi..d by ,ho Oi.'r~' Ju.Iic.. will operot. o. 0 5Ul'U51Ol!A5 10 ~. judgment lor po....1ion in ,hi. co... u COOl 110 I &groturo 01 Pro,honoIaty Of Deputy II appellant was CLAIMANT (see Pa. R.C.P.J,P' No. tOO/ (6) in action belore District Jus/ICe, he MUST FILE A COMPLAINT within twenty (20) days alter Iiling his NOTICE 01 APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE IfhIa ItJCIIon oIlonn /0 bo usocJ ONLY when appel/anI was DEFENDANT (see Pa. R,C.P.J,P. No. 1001(7) in action before District Jus/ico, IF NOT USED. doIJtch 110m c",y 01 nolice 01 appeal to be served upon appellee), 'IAICIPI, To Prolllonolory Ii " Enter rule upon i iv..~ () ,-be c..' :\~j> t ;11/4/..) , Name oI8(:peJloe(s} 'l"-l~.l!, it, r:i \!;1 T~rm " II j..-')I\ I ) . oppell..(.). 10 file 0 complaint in this appeal (Commr.on PIoo. No. RULE. To , llt'.r\c.... c!.bpf'rl1\rl1j .appellee(.), Nwne oIlJtJJ6/loe(sJ/ J ) within twenty (20) day. oller service of rule or .uffer .j,fry of judgm.nt of non pIO<. (" r. ,,. J '--6.1J..'C.~u--C Dcl.~.n(~./( r,<ll' / 5qlat1le at appeMont 01 fJ:s' attorneY Of 8g9tJI . (11 You ore noHfied ,hot 0 rule i, he<eby entered upon yoo to file 0 complaint in this appeal within twenty (20) day. alter the dote of "' ..vlc. of this rule upcn you by personal service or by certified or registered maiL .\,.... c, (21 K you do not file 0 complaint within this time. 0 JUDGMENT OF NON PROS WILL BE ENTERED AGAINST'.~OU." '. :'1" (31 Tho dote of servlc. of 'hi. rule if .ervic. was by moil i. the dote of moiling. Dote: Mnt Cfl t1, (j'l .19_, ; i"~ J f I ". '. ra/' 1/". II /"gl," '; i SigJstlie 01 Prothot'Iotwy 01.' ,')' " ",- " NlPC J IJ-"" COURT FILE C__WIALTH Of ,.NNIY'''AH.... COUll Of C__ "'A. NOTICE OF A"EAL lUDIC"" OI"IICI fIOM DISTRICT JUSTICE JUDGMENT C_mA.", 99-1316 Civil Ttlrm NOTICE OF APPEAL Notic. i. vi- that tho --""", has filod in 'ho "'-0 C""', ., C_ PIto. on oppoaI from tho judgmon' ,ondorod by tho Oi",icl .M'ic. on tho deN one! in tho CQIO ".,Ii..oed bee- SUSA.., A-UA \'V\ So gn S-r ''''"' "'" : GO .....ro. .J 5A .... -COMMONWEALTH OF PENNSYLVANIA COUNTY OF' COMBBRLAND OJ_ .... ROBOT V. MANLOVE -... 1901 STATB STRBBT CAMP HILL, PA ...""'" 1717) 761- 0583 17011-0000 NOTICE OF JUDGMENTfTRANSCRIPT CIVIL CASE PLAINTIFF: NAME.""ADDRESS !OPPBRHAN, DMD, D. THBODORB, BT AL.' 2812 MBRION RD CAMP HILL, PA 17011 L ~ VS. DEFENDANT: NAME &ndADOAESS 'ADAMS, WILLIAM, BT AL. 221 N 24TH ST CAMP HILL, PA 17011 L , ..... Doll No 09'1-02 SUSAN ADAMS 221 N 24TH ST CAMp HILL, PA 17011 Docket No.: CV- 0000466 -98 Dale Filed: 11/16/98 ~ 1& THIS IS TO NOTIFY YOU THAT: Judgment: POR PI.A TN'I'TPP [!J Judgment was entered for: (Name) m'PRRMUJ mm n [!J Judgment was entered against: (Name) IInIlMR, WTT.T.TIIM INfllnnnR'R. 'R'I' in the amount of $ 7, li1 A iiI; on: (Date of Judgment) (Date & Time) ?/04/QQ . o Defendants are jointly and severally liable. o Damages will be assessed on: Amount of Judgment $ 7.500.00 Judgment Costs $ 118.65 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 7.618.65 Post Judgment Credits $ Post Judgment Costs $ o This case dismissed without prejudice. O Amount of Judgment Subject to AttachmenVAct5 of 1996 $ o Levy is stayed for _ days or 0 generally stayed, ------------ ------------ o Objection to levy has been filed and hearing will be held: Certified Judgment Total $ 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 T PROTHONOT AR CLE K OF THE~OU~ of: COMMON PLEAS, CIVIL DIVISION. YOU MUST INCI,A:JDE A OPY OF THIS TI , F!! DGM NT ANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. /. ?: --- ,,', '/ ~Date -- , District Justice e re~{ the proceedings containing the judgment. 'j/ Date , District Justice / ( My commission expires tirst Monday of January, AOPC 315,96 2000 SEAL I >- - c ~ c.-; ., I":~ .'- 1.!Jr~ ::).... 0-,' C>~: ~ G:\.' .~ ' ).r, '.l~ _!. .", "- ~.~ C' :::, ;!.J(:' .. . :- :.>' C:l ',") . u.'j.. I J;': 2: , 0-: , . ..~- IlJ ., ."';. ::!.... I ~ I "" :.-) (~) Cr\ '-.) -. .... 'J 'a ,~< ......:,. ..". ~". ',.. .': I I . . .cOMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NoWl! IfId ADDRESS 'OPPBRMAN, DMD, D. THBODORB, BT AL.' 2812 MBRION RD CAMP HILL, PA 17011 L ~ VS. DEFENDANT: NAME al\dADORESS 'ADAMS, WILLIAM, BT AL. 221 N 24TH ST CAMP HILL, PA 17011 L ....; c.,tNo' 09-1-02 DJHatne: Hon. ROBERT V. MANLOVE -OIl 1901 STATB STREBT CAMP HILL, PA T......n" 1717) 761- 0583 17011- 0000 , SOSAN ADAMS 221 N 24TH ST CAMP HILL, PA 17011 ~ 1& Dock'3tNo.: CV-0000466-98 Date Filed: 11/16/98 THIS IS TO NOTIFY YOU THAT: Judgment: POR PT.ATNTTPP ~ Judgment was entered for: (Name) npPRRMlI~. nun n ~ Judgment was entered against: (Name) lInAMA, AITAAN 'l'RRnnnRll 1l'11 in the amount of $ (Date of Judgment) (Date & Time) 7 /;1 A h~ on: 2/n4/qq , o Defendants are jointiy and severally liable. o Damages will be assessed on: Amount of Judgment $ 7.500.00 Judgment Costs $ 118.65 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 7.618.65 Post Judgment Credits $ Post Judgment Costs $ o This case dismissed wilhout prejudice. O Amount of Judgment Subject to AtlachmenVAct 5 of 1996 $ o Levy is stayed for _ days or 0 generally stayed. ------------ ------------ o Objection to levy has been filed and hearing will be held: Certifilld Judgment Total $ ID~' Time: r~ OF APPEAL WITH THE PROTHONOTA MU~COPY OFTHIS 'h Date I ce ify t t this is a true an ~ ~ Date My commission expires first Monday of January, Aope 315,96 SEAL 2000 ,'\ ... .- r; h.:; ~ c.": i~ ~.~ U.1Q ..- i I.~ ?".: u v j.c, :c '.1_ .1 .a: :--J C)t..-; '..: g' a:. ;- " , :!:~ l.ul~ I :~~ ctl~-, C.:: ;( l'I'_.:..J :i... .....i. L':"'!~~ ,-' ~ I.L. en ::J 0 CT' 0 '~, -. "''' . ~ NOV 2 42003 h IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA 0, THEODORE OPPERMAN. OMD and SUSANNA OPPERMAN, Plaintiffs, C.A. No. 99.1316 v. WILLIAM ADAMS and SUSAN ADAMS, Defendants. AND NOW. this RULE ,"- day of 7>"" ~ tu- . 2003, upon consideration of the attached Petition to Withdraw Entry of Appearance. a Rule is hereby entered on William Adams and Susan Adams, to show cause, if any there may be. why the prayer of the attached Petition should not be granted. This Rule is Returnable on: ZoO ~S' ~t<-- S-<,v,...... . Court Notice is hereby given to William Adams and Susan Adams that the well pled facts of the Petition shall be admitted unless an answer specifically denying the same is filed by the close of court on the return date hereof, BY THE COURT: 744 Appearance from representation of Defendant William Adams in tho above referenced malter, or in the alternative, requests a continuance of this matter until such time as the Respondent is released from his incarceration. AND ~o~~r; lA/( C00 MAR AN P. BAZZANO, 10 61019 1687.B West Doe Run Road P.O. BOK 942 Unionville, PA 19375 610-347-6700 Attorney for Defendants William Adams & Susan Adams BY: I //IJ/ ()"!; Date: IN THE COURT OF COMMON ('LEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA D. THEODORE OPPERMAN, DMD and SUSANNA OPPERMAN. Plaintiffs. c.A. No <)C}-1316 v. WILLIAM ADAMS and SUSAN ADAMS, Defendants. CERTIFICATE OF SERVICE I, Mary Ann P. Bazzano, hereby certify a true and correct copy of a Petitioner's Petition To Withdraw was mailed via regular United States Mail on the date indicated below to the following individual: D. Theodore Opperman, DMD and Susanna Opperman c/o John Molnar, Esquire Wind Gap Professional Center 669i Sullivan Trail Wind Gap, PA 18091 COOCH AND TAYLOR BY: Date: I //'j(O~ MARY ANN . BAZZANO, 10 1687B W. Doe Run Road P.O. Box 942 Unionville, PA 19375 610-347-6700 Attorneys for Defendants f;; <- I ,- C'. f::: ~;~. r::: l;J ; , (.' i ) ~l : , .:.. ' , I,J 1 ;i.~ L:: '=l " ;:2 ('" d '- -' ~. 1'-:..1 L.. . ~, ..i.. , :-:; '-'- ,.) U ..:.::.:.' () COG III :Os ~ ~t II: "!~ W ~.. 3: ;1!ij III ....00 Z ~" < ~8 ~ ~ ~~ ~ I ..~ w 08 e !g~ u .!! :; Q ~ ~ g~l < I 0 .... >- 0 U "!.., i s;~ ~ C ~N ...~ U NN 0 r-:~ Q ~~ > ~.., Q ........ < ~~ =: n 0 Q, c.: w ;;: 0 .... -UI"P r<1 :T: ~1'l C!hj:: ='> \"I~r <IL..J..,' I -(''In'\ zC" .;So ~.,~; w (~)6 f:.":' -U ~1l <- ?ie, =.: :,,=~ &-.() r.a ~~ ;J"C ~ ;:> ~ N THE MOLNAR LAW OFFICES' WIND GAP PROFESSIONAL CENTER ROl!TES 33 '" 512 6697 SULI.IV AN TRAJI. WIND GAP, PENNSVLVA.'llA 18091 (J~ 1''':'-~J4IoJ./ Jobn Molaar AlIorn.y II La.. 610,163-3100 610-746-9000 FI..lmU. 610.863-3131 FACSIMILE TRANSMITTAL TO: Mark F. Bayley, Esquire FROM: JohnMoln:lf,Esquiro FIlL\! : Rominger'" Bayley DATE: February 4, 2004 RE: D, Thtodore Opperman, DMD and Susanna Opperman v,', Willium Adams und Susan Adams No, 99-1316 FACSIMILE NUMBER: 717.241.6878 NO. OF PAGES: 1 Denr Mark: I bave been trying to reach you by telephone to advise you thaI I will not be opposing the Motion for SUIIII1W}' Judgment that you have filed. .___.?~ ely yours, I '-....... JMItrk If you do notreedv. all of the pages .bov.. pltaSe call Tasha at (610) 863-3200. This message is intended only for the use of the individual or entity to which it is address, and may contain information that is privil.ged, eonfid.ntial and exempt from disclosur. under applicable law. If the reader of this messAge is not intended recipient, or the employee or agent responsible for deliveriDg the message to the intended rec:ipicat, you arc hereby notified that any dissemination, distribution or copying of this communicatioD is strictly prohibi1ed. It you have received this communication in error, plcase notify us immediately by telephonc, and rcturn the original message tn UiIi. Thank you. ~XJ+I e fi "A" -- ..,.- . '>. 0'\ E 1:::: - -0,: ,., ..:r 7\.._ Hie'': <)~~) -~ I -! It_,- w: \,', ~.' g~ : .-'::-:i \D .. , l'" IJ..'~_ - '-' ff!IIJ "'" , i!: ~ , :';~'.~ -~ ',> U. c~., :":j 0 <-~ 0 '" III coB II: :08 ~ it 11/ "!~ 3: ~.!! III ;!ill z ....00 < ~~ ~ ~8 I = m~ ~ III "'f u 08 ~ o~i :: .!! Q ~ ~ ~~i < I 0 >- .... ~ j ~~I u ~.., C ~N U ...~ 0 "iN > ......" o ~~ Q ~.., < ........ ~~ == n r- .;;:: iFit "" 1'5 "'"' ..,., r" C7> , 0'> -0 ::.: ...- o -., 5!~ m~ .."hi 7J~ b :;1;;ij' ()' ..... ) t)i:" .;;1 :0 -< (:~,. Gi..-~' "'" it;! ~ '" " ., D. Theodore Opperman, DMD and Susanna Opperman, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL DIVISION c::> t..> r'" ,'1 n I c..> ." :1' r.a o r-> ~ ;,- ""0':-:' n-Hl' ~.~' ~.(. UJ.,:.. ~..~. ~t~'. Z,", /~c' >L:<: ~ Williams Adams and Susan Adams, Defendants CA NO. 99-1316 MOTION FOR CONTINUANCE AND NOW, comes Defendant, Susan Adams, by and through her attorney, Mark F. Bayley. Esquire, and in support of this Motion avers as follows: 1, Plaintiffs filed a Complaint with regard to the above matter on or around May 17, 1999. 2. Plaintiffs listed the above case for non-jury Trial by Praecipe dated October 23, 2003, over four (4) years after the Complaint was filed and after completing and requesting no discovery. 3. The Honorable Edgar B, Bayley scheduled a Trial to take place on December 8, 2003. 4. Co-Defendants were initially both represented by Mary Ann Bazzano, Esquire. 5. Co-Defendants have been divorced since the Plaintiffs' Complaint was filed and their interests are now divergent. 6, On December 2, 2003, the undersigned attorney entered his appearance on behalf of Susan Adams. o .11 ,,-J ..." ,''''t-' .In ," ,;)(1, ')-,~~" " .<.~ ,.) .-, ~ I D. Theodore Opperman, DMD and Susanna Opperman, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL DIVISION Williams Adams and Susan Adams, Defendants : CA NO. 99-1316 CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant, Susan Adams, do hereby certify that I this day served a copy of the Motion for Continuance upon John Molnar, Esquire and Mary Anne Bazzano, Esquire, by First Class Mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: John Molnar, Esquire, The Molnar Law Offices Wind Gap Professional Center 6697 Sullivan Trail Wind Gap, PA 18091 Mary Anne Bazzano, Esquire 502 West Cypress Street p, 0, Box 942 Kennett Square, PA 19348 " Dated: l. 2. t;\, Mark F. Bayley, Esquire Attorney for Defendant -1/ ,~.'I ~) ro' l.~ ..\ D. THEODORE OPPERMAN, DMD AND SUSAN OPPERMAN, PLAINTIFFS V. WILLIAM ADAMS AND SUSAN ADAMS, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA AND NOW, this : 99-1316 CIVIL TERM ORDER OF COURT ~ day of December, 2003, IT IS ORDERED: (1) The trial before this judge scheduled for December 8, 2003, IS CANCELLED. (2) The case is transferred to the Honorable Kevin A. Hess. (3) The trial will be conducted before Judge Hess in Courtroom Number 4, Cumberland County Courthouse, Carlisle, Pennsylvania at 9:30 a.m., Monday, March 22, 2004. (4) Judge Hess, who entered a Rule to show cause why Mary Ann P. Bazzano should not be allowed to withdraw as counsel for William Adams will enter an order when appropriate on that issue.1 Edgar B, Bayley, J. ...... ~ ~,~ \~t;j I Mark F, Bayley, Esquire, has already entered an appearance for Susan Adams which resolves the issue of her representation. " l 1:._ :; ,"':J lIJ ~~2 .- u__ '.1'( ()(~ 6,: l.LllJ. :-c1"1 .. l!..~.: -oj U. .:'" ., i.) u C",.. c.., . ..-. ..- .. .,...~.,. "',""'~~" .-..".,.,..:.....t""'>)<.~~ ~1?e/'&~4P LAw OFFICES ADVOCACY - ADVICE - ANSWERS 155 SOUTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 .. .. .~- 't~~ .-...~ -- ...- .t~-.dIotor__ " ...... - P"I P '07 J. ,'. J. ." 1lt- DQ,,:57':: .. ,.} {... .:; {, ._I,~h';. f ;,''1' ::.,...;, .~, 1.._ I i 0 i ~ . 1 !', John Molnar, Esquire, The Molnar law Offices Wind Gap Professional Center 6697 Sullivan Trail Wind Gap, PA 18091 .." "' ,'c,, .l~:' . '.' ,.- .... " I. I 1 . , I \ >4 'I' ,\': "! ,I. ~~ ; -'......,'......'.-:'".~''"'"......~......'" ""'.-.'.' "';~H'i"':"'""~"""f.~'~.r .....,.?-~~i(..." ~t&~1P LAw OFFICES ADVOCACY - ADVICE - ANSWERS 155 SOUTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 ",... .. ,".'~'r~..=~- --=- .. ~~.--- -" -- l)n~"":Ii f' "" r (I -7 ,. u (, . -' ~ ~" :.I v: z. U .. ~"> .J . . " " 1 :0.:....',;" ! ':<",1", . '.;~I :.,. 1"'; U 1 :5 Mark F. Bayley, Esquire Rominger & Bayley 155 S. Hanover Sl. Carlisle, PA 17013 ..." ;("";~"~;';,'~\>~'~_'~;,:;,~:,-:,<,:':;~;'~.::;':-;~J.j,:L'<.,.. '..... "".' ...."''I'.,~,'..'' ' '. D. TIIEODOHE OPPEHMAN, DMD and SUSANNA OPPEHMAN, Plaintiffs v WILLIAM ADAMS olnd SUSAN ADAMS, Defendants I tJ TilE (:OIJHT OF COMMON PLEMj or CU11BEHLAND COUNTY, PENNSYLVANIA CIVIL N:TION - LA~I 110. ~ '! -1 J 1 OJ C 1 V 1 I. TERM IN HE: NON-JURY TRIAL ORDt:R or COURT AND NOW, this 22nd day of March, 2004, after a non-jury trial, we find in favor of the plaintiffs, D. Theodore Opperman, DMD, and Susanna Opperman, <.ll1d against the defendant, William Adams, in the amount of $35,850.00. By the Court, Jdhn Molnar, Esquire vFor the Plaintiffs ~ry Ann 1', Bazzano, Esquire 1687-B West Doe Run Road P.O. Box 942 Unionville, PA 19357 For the Defendant ~lliam Adams-11250067 FCI Miami P.O. Box 779800 Miami, Florida 33177 :bg '":fr',/!;4 . /7 03-23-0 I , .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA D. THEODORE OPPERMAN. DMD and SUSANNA OPPERMAN. P/aillliOs. CA No. 99-1316 v. WILLIAM ADAMS and SUSAN ADAMS. Defendants. ORDER AND NOW, this J1ib.. day of l!Jo...rf' h ;).00 Y ,~. upon consideration of the Petition to Withdraw to which no response or objection has been filed, it is hereby ORDERED AND DECREED that Mary Ann Plankinton Bazzano, Esquire is granted leave to withdraw as counsel for William Adams in the above captioned matter. IS/~flRh:J yj~. 'w J, ., >- IX) ~ u: .:r ..: ,- .. ... il - :.;>-::.:; x: (.J ~~ 0- '_I~ (:~~j '" ~q! N .J....::. 0::: J-~ o:~ -< :',jiJ.J x: lOa.. .... u.. -"" => CO 0 CO (.) '" ,