HomeMy WebLinkAbout99-02741
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outstanding discovery. This date, the Court has denied
plaintiff's request for protective order on discovery, thus
enabling defendant's discovery to proceed. Currently there
is a defense set of interrogatories given to plaintiff, and
unanswered to this point. Plaintiff's counsel suggests
that he can answer these interrogatories and deliver the
requested documents, asked for, within seven days of
today's date. In any event, defense counsel will have 45
days to complete discovery after delivery of the documents
requested.
In view of the uncompleted discovery
situation, the case is stricken from the trial list and
either counsel is free to relist the case for the May term
of court.
By the Court,
C. Lee Anderson, Esquire
For the Plaintiff
Steven N. Goudsouzian, Esquire
For the Defendant
Prothonotary
Court Administrator
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Steven N. Goudsouzian, Esquire
1.0.# 74831
70 East Broad Street
P.O. Box 1426
Bethlehem, PA 18016-1426
(610) 882,1180
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HINTON & ASSOCIATES, INC.,
Plaintiff
No: 99-2741
v,
NOR-CAR FEDERAL CREDIT UNION,
Defendant
. ()~JLQIL<:O_UJIT
AND NOW, this 'f-JL_ day Of.il.lc:__. 2000, Plaintiffs Motion for
Protective Order is hereby DENIED and DISMISSED.
BY THE COURT:
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4. Admitted.
5. Denied as stated. Exhibit "An is a document which speaks for itself. To
the extent the averments in this paragraph are inconsistent with same, thcy are
spccifically denied.
6. Denied as stated. Exhibit "An is a document which speaks for itself. To
the extent the avemlents in this paragraph are inconsistent with same, they are
specifically denied.
7. Denied as stated. Exhibit "An is a document which speaks for itself. To
the extent the avenncnts in this paragraph are inconsistent with same, they are
specifically denied.
8. Denied. It is specifically denied that no discovci)' requests were
forthcoming. By way of further answer, counsel for Defendant has forwarded to
counsel for Plaintiffs:
a. A requcst for Production of Documents;
b. Interrogatories;
c. Notice of Deposition.
9. Admitted in part, denied in part. It is admilted Ihal Plainliffs altomcy has
2
listed this matter for trial. It is further admitted that counsel for Defendant indicated
to counsel for Plaintiff that he wished to engage in discovery. Furthennore, counsel
for Plaintiff knew at all relevant times counsel for Defendant desired to engage in
discovery. Furthermore, no discovery order, status conference, or other judicial
determination has been made regarding the scheduling and timing of this case.
10. Admitted.
II. Denied. The avennents in this paragraph contain a conclusion of law
which need not be answered. By way of further answer, Defendant's Notice of
Deposition is not untimely. By way of further answer, there is no indication that
Defendant's Notice of Deposition is untimely other than Plaintiffs subjective and
unsupported allegation. There have been no status conferences, scheduling
conferences, or other judicial detenninations as to a discovery schedule. From the time
period between Plaintiffs Reply to New Maller and Defendant's discovery request,
the parties attempted to negotiate and resolve this mailer.
3
4. Admitted.
5. Denied as stated. Exhibit "A" is a document whieh speaks for itself. To
the extent the averments in this paragraph are ineonsistent with same, they are
specifically denied.
6. Denied as stated. Exhibit "A" is a document which speaks for itself. To
the extent the avemlents in this paragraph are inconsistent with same, they are
specifically denied.
7. Denied as stated. Exhibit "A" is a document which speaks for itself. To
the extent the avennents in this paragraph are inconsistent with same, they are
specifically denied.
8. Denied. It is specifically denied that no discovery requests were
forthcoming. By way of further answer, counscl for Defcndant has forwarded to
counsel for Plaintiffs:
a. A request for Production of Documents;
b. Interrogatories;
c. Notice of Deposition.
9. Admitted in part, denied in part. It is admitted that Plaintiff's attorney has
2
listed this matter for trial. It is further admitted that counsel for Defendant indicated
to counsel for Plaintiff that he wishcd to engage in discovery. Furthermorc, counsel
for Plaintiff knew at all relevant times counsel for Defendant desired to engage in
discovery. Furthermore, no discovery order, status conference, or other judicial
determination has been made regarding the scheduling and timing of this case.
10. Admitted.
II. Denied. The averments in this paragraph contain a conclusion of law
which need not be answered. By way of further answer, Defendant's Notice of
Deposition is not untimely. By way of further answer, there is no indication that
Defendant's Notice of Deposition is untimely other than Plaintiffs subjective and
unsupported allegation. There have been no status conferences, scheduling
conferences, or other judicial detenninations as to a discovery schedule. From the time
period between Plaintiffs Reply to New Matter and Defendant's discovery request,
the parties attempted to negotiate and resolve this matter.
3
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STEVEN N. GOUDSOUZIAN
AlIORNEY AT LA\\:'
70 EAST BROAD STREET, 1'.0. Box 1426
BETIlI,EIIEM, PA 18016,1426
I:
C. Lee Anderson, Esquire
Smigel, Anderson and Sacks
2917 North Front Street
Harrisburg, P A 17110-1260
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Thomaa E. Chelllna, Esq.
Court Administralor
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY
COURT OF COMMON FlEAS
1 Courthous. Squa,o . Carlisi.. PA 17013
Phone
(717) 240.6200
(717) 697,0371
(717) 532.7286
(717) 240.6462 FAX
Dorio J. March
Stall Assistant
Rlcha/d J. Plerco
Assistant Court Administrator
Oeboreh L Rombergor
Legal Secretary
January 23, 1995
MEMO TO: All Counsel
FROM: Tho~effins, Esq., Court Administrator
IN RE: Change in Local Practice
Effective immediately, the court has adopted the following
policy to comply with Pa. R,C.P. 236a:
RULE 206-6. Where notice of entry of any judgement,
decree or order is required under Pa. R.C.P. 236a, the
petitioner or moving party shall include in the proposed
order, judgement or decree, the name of the persons
and/or attorneys who are required to be notified and
shall provide duplicate copies of the proposed order and
stamped envelopes addressed to the said persons and/or
attorneys.
Please note: This notification is Dot a substitute for
servico of process as required by Pa. R.C.P. 400 et.Beq.
This procedure will become a local rule when the local rules
are updated. Your cooperation in implementing this procedure will
be greatly appreciated.
TEC:djm
cc: Hon. Harold E. Sheely, P.J.
Prothonotary
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Steven N. Goudsouzian, Esquire
LO.# 74831
70 East Broad Street
P.O. Box 1426
Bethlehem, PA 18016,1426
(610) 882-1180
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HINTON & ASSOCIATES, INC.,
Plaintiff
No: 99-2741
v.
NOR-CAR FEDERAL CREDIT UNION,
Defendant
QRllKR~F COURT
AND NOW, this ___ day of
, 2000, Plaintiffs Motion for
Protective Order is hereby DENIED and DISMISSED.
BY THE COURT:
..
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4. Admitted.
5. Denied as stated. Exhibit "A" is a document which speaks for itself. To
the extent the avennents in this paragraph are inconsistent with same, they are
specifically denied.
6. Denied as stated. Exhibit "A" is a document which speaks for itself. To
the extent the averments in this paragraph are inconsistent with same, they are
speci fically denied.
7. Denied as stated. Exhibit "A" is a document which speaks for itself. To
the extent the avennents in this paragraph are inconsistent with same, they are
specifically denied.
8. Denied. It is specifically denied that no discovery requests were
forthcoming. By way of further answer, counsel for Defendant has forwarded to
counsel for Plaintim:
a. A request for Production of Documents;
b. Interrogatories;
c. Notice of Deposition.
9. Admillcd in part, denied in part. It is admitted that Plaintiff's attorney has
2
listed this matter for trial. It is further admitted that counsel for Defendant indicated
to counsel for Plaintiff that he wished to engage in discovery. Furthennore, counsel
for Plaintiff knew at all relevant times counsel for Defendant desired to engage in
discovery. Furthemlore, no discovery order, status conference, or other judicial
determination has been made regarding the scheduling and liming of this case.
10. Admitted.
II. Denied. The avennents in this paragraph contain a conclusion of law
which need not be answered. By way of further answer, Defendant's Notice of
Deposition is not untimely. By way of further answer, there is no indication that
Defendant's Notice of Deposition is untimely other than Plaintiffs subjective and
unsupported allegation. There have been no status conferences, scheduling
conferences, or other judicial detenninations as to a discovery schedule. From the time
period between Plaintiffs Reply to New Matter and Defendant's discovery request,
the parties attempted to negotiate and resolve this matter.
3
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HINTON & ASSOCIATES, INC.,
PLAINTIFF
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
V.
NO. 99-2741
NOR-CAR FEDERAL CREDIT UNION,
DEFENDANT
CIVIL ACTION - AT LAW
JURY TRIAL DEMANDED
PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO STRIKE TRIAL
LISTING
1. Admitted.
2. Admitted.
3. Admitted.
4. It is admitted that Defendant has propounded written discovery upon Plaintiff, said
di.scovery requests being received on February 7, 2000. They have not been answered.
5. The contents of Lecal Rule 213,2 speak for themselves. Defendant was given an
opportunity to conduct discovery, but chose Ilotto avail itsclfofthat opponunity. Defendant was
notified thatthi.s malleI wcuId be listed fOltlial during thc March teml ofceurt ifit did not initiate
discovery proceedings.
6. Admilled.
7. Denied. Defendants failed to engage in discover)' when given an opportunity to do so,
and thus this mailer is rcady for trial.
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Sleven N. (;cnltl~f1I1/.i""1 E~llllirc
1.1111 74K.l1
70 E"~II1","t1 Sltee!
1'.0. IInx 14U,
lIelhlehelll.I'^ IKOI(,-14U,
((,Ill) KR2.11 RO
IN TIII~ COURT OF COMMON PLEAS
OF CUMIUCRLANI> COUNTY, I'ENNSYLV ANIA
CIVIL ACTION - LAW
IIINTON & ASSOCIATI~S, INC.,
Plaintiff
v.
No: 99-2741
(Preliminary Objections
Decided by The Honorable
Kevin A. Hess)
NOR-CAI{ FimEl{AL CIUWIT UNION,
I)cfcmlant
ORDER.QE_CnURT
AND NOW, this . ....'u. dayof
, 2000, it is hcrcby ORDERED
and DIRECTED Ihat thc ahuvc-captioncd mattcr is strickcn from thc March Trial List.
13Y THE COURT:
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dale, this discovery remains outslanding.
5. Pursuant 10 Local Rule 213-2, at the call oflhe trial list. counsel for all
parties shall indicate that discovery has been completed, that all pre-trial actions have
heentaken, and thaI {:ase is ready for trial in all respects. In this matter, discovery has
not been completed, pre-trial actions have not been completed, and the case is not
ready for trial.
6. Counsel for Defendant, Stevcn N. Goudsouzian, attempted to obtain the
concurrence of opposing counsel, C. Lee Andcrson, altomey for the Plaintiff, pursuant
to Local Rule 20(j-2(c). However, Altomey Anderson has refused to voluntarily
remove this malleI' from the triallisl.
7. This case is not ready for trial.
WHEREFORE, it is respectfully requcstcd that this matter be stricken froll,1 the
trial list until discovery is complete.
Date: Fehruary 4, 2000
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Sleven N. Goudsouzian, Esquire
ID# 74831
70 East Broad Strect
1'.0. Box 1426
13ethlehcl11, I' A 18016-1426
(610) XH2-11 XO
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Steven N. (i()lId~oIl7.i"n. E.qllire
1.1>." 74R)1
70 E..lllro.d Street
r.().llo~ 142f,
Ilelhlehem. r^ IROIC,.142C,
((,Ill) RR2.IIRO
IN THE COURT OF COMMON PLEAS
OF CUMmmLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
I1INTON & ASSOCIATES, INC.,
Plaintiff
.
.
No: 99-2741
v.
NOR-CAR FlmERAL CREDlT.UNION,
Defendant
.
.
CERTJFlCATLOJLSERYlCE
I hereby certily that I am this day serving the foregoing MOTION TO STRIKE
lIponthe persons indicated below, via fax and first class mail, postage prepaid, which
service satislles the requirements of Pa. R.C.P. 440:
C. Lee Anderson, Esquire
Smigel, Anderson amI Sacks
2917 North Front Street
Harrishurg, I' A 17! 10-1260
Steven N. Goudsouzian, Esquire
J.D. No. 74831
70 East Broad Street
P.O. Dox 1426
Bethlehem, PA 18016-1426
(610) 882-1180
Fehruary 4, 2000
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4lJ26.3.I/CLA/tkcIIComplaintMIlY 5. 19999:44 AM
HINTON & ASSOCIATES, INC.,
PLAINTIFF
IN THE COURT OF COMMONS PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
V.
No.4' r, . 2 7'/1
~L
NOR-CAR FEDERAL CREDIT UNION,
DEFENDANT
CIVIL ACTION - AT LAW
JURY TRIAL DEMANDED
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set fOl1h 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 Iiling in writing with the Com1
your dcfenses or objections to the claims set forth against you. You are wamed 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. Yeu may lose money or property or other rights important to yeu.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A T 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.
Cumbcrland County Lawycr Refcrral Scrvice
Court Administrator
4th FI., Cumbcrland Counly Courthouse
Carlisle.PA ]7013 (717) 240-6200
NOTICIA
Le han demandado a usted en la corte. Si listed quicre defenderse de estas demandas expuestas
en Jas paginas siguienles, usted tiene viente (20) dias de plaza al partir de la facha de la demanda y la
notificacion. Usted debe presentar una apariencia cscrila 0 cn Persona 0 por abogado y archivar cnla
corte ell fomla cscrita sus dcfensas 0 sus objcctiones alas demandas encontra de su persona. Sca
avisado que si ustcd no se defiendc, la cortc tomara mcdidas y puedc cntrar una ordcn contra llsted sin
previo aviso 0 notificacioll y por cualquicr qucja 0 alivio que es pedido en la peticion de demanda.
Usted puede perder dinero 0 sus propiedades 0 olros dcrechos importantcs para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TlENE
ABOGADO 0 SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL SERVICIO, V A Y A EN
PERSONA 0 LLAME pOR TELEFONO A LA OF:CINA CUY A DIRECC10N Sf ENCUENTRA
I ESCRIT A A8AJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumbcrland COllllly Lawyer Referral Scrvice
I[ Court Administrator
I 41h FI.. Cumberland County Courthouse
Carlish:.PA 17013 (7I 7) 240-(,200
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Exhibit A
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HilltOIl & Associates, IlIc.
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7 E3stwick Court. P,Q. Bo~ 488
Carlisle, PA 17013
(717)258.1573 Fax: (717)24J.9371
Confidential Network Proposal
Nor Car Federal Credit Union
Revised February5, 1999
Executive Summary
Hinton & Associates, Inc. is submitting this confidential network proposal to Nor-Car Federal
Credit Union and its contents are based on our initial needs analysis meeting held on August
14, 1998. To bring on the Cuna Mutual Group's Automated Lending Software solution (ALWIN)
it was decided that a dedicated Microsoft NT file server with a total of (10) users networked at
the Easton main branch office and at the Lehighton branch office. It is our understanding that
(4) users will require access to the ALWIN software with (3) users at Easton and (1) at
Lehighton. A Wide Area Frame Relay Network is being recommended to connect the branch
office to the main office. To provide emailto end users, we are recommending Microsoft's
Exchange software that we will configure for network access by all designated end users. Also
included in this proposal is a network-based virus protection solution that initially is optional;
however, as end users are given Internet access, it is highly recommended. At the main office,
EDS will be accessed by both dumb terminals and PC workstations. The PC workstations will
be replacing the existing dumb terminals since we will be integrating the EDS connection
capability into the PC workstations. This solution will save valuable desk space and will provide
a single tool with which to perform daily job functions. At the branch office, EDS will only be
accessed by the PC workstations through the Wide Area Frame Relay Network connection to'
the main office. Prior to installation of the proposed network, all other software applications will
need 1.0 be upgraded to Windows95 capability. It is further recommended that all DOS
applications that are not in use be removed from each PC workstation. Initially, there will be (3)
printers configured for network access. On the last day of installation, basic network
administration training will be provided for up to h'Vo designated personnel at each location. All
items listed in this proposal have a 1 year warranty excluding the HP NetServer which has a 3
year warranty all serviceable by Hinton & Associates, Inc. All items are currently in stock,
therefore; delivery would be a standard 3 to 5 business day time frame. All items presented
here are Year 2000 compliant and if requested by the credit union, a 2000 compliance
document can be provided. .
After the initial installation has been completed by Hinton & Associates, Inc., we recommend
that the on-site application training of end users in the Office97 application take place. After the
application training has taken place then the Cuna Mutual Group's Automated Lending
Software installation and training can take place. We will be performing the Cuna Mutual
ALWIN software install. We will continue to be available as a network resource to the Credit
Union for on-going support after the network and lending software has been successfully
installed.
Nt'IWOlk Inltgration !'('rvice and Surport
Some future credit union needs may include network-based Internet access, faxing, remote
communications, network management, disaster recovery, Y2K auditing, etc. all of which, we
will be more than happy to provide assistance in designing, implementing and supporting. And
as soft\vare versions are upgraded, we will be available to provide hardware upgrades, if
needed, to support the new software requirements.
Network Cabling Services Estimate
Our cabling contractor will install, test and terminate single category 5 cable for 15 drops and 3
phone connections at the Easton office. The Lehighton office will require 1 drop and 1 phone
connection.
Total Network Cabling Services Cost: $2720.00
Easton Office - File Server and Associated Server Items
(1) #D6030A HP NetServer E50, Pentium II 333MHz, 64MB RAM, $1830.00
4.2GB Hard Drive, Ethernet 10/100MB Adapter, CDROM.
(2) #D4290A HP 64MB RAM Upgrade...TotaI192MB RAM. $ 500.00
(1) #C1528H HP SureStore DAT 81 4/8GB Tape Drive. S 816.00
(2) #92300A HP Tapes 5Pack. $ 114.00
(1) #92283K HP Cleaning Tapes 2Pack. $ 22.00
(1) #227-01011 Microsoft Windows NT 4.0 with 10 Client Licenses $ 999.00
(1) #CKA4217 Samsung 14" Color SVGA Monitor $ 148.00
(3) #005686.0 US Robotics External 56k Sportster Modem $ 375.00
(1) #70001361 Digi Acceleport 4R920/PCI $ 486.00
.required to attach modems to server.
(1) #SBENTSE2 Seagate BackupExec for NT Single Server $ 429.00
(1) #SU1000NET APC UPS 1000 Backup Unit $ 481.00
(1) #EE110TX12 Intel 12Port Ethernet 10/100 Hub $ 747.00
.only 1 port will be left available when install is
completed... additional hubs can be purchased at a
later date is more ports are needed.
(13) #3827GY-3 Patch Cables 3' $ 130.00
(7) #3827GY-7 Patch Cables 7' $ 140.00
(2) #3827GY-10 Patch Cables 10' $ 50.00
(2) #3827GY-25 Patch Cables 25' $ 80.00
(1) #SP32-202 SpartaCom SAPS la-User $ 509_00
(1) #T1SYNC BARR T1 Sync for SNA Server Adapter w/RS232 Cable $ 700_00
(1) #211-00148 Microsoft SNA Server 4.05 Client Licenses $1166.00
(1) #122015.52 Attachmate Extra v6.4 for Windows/95 CDROM $ 295.00
(4) #150242-52 Attachmate Extra v6.4 License Only. $ 408.00.
(1) #312-00693 Microsoft Exchange with 10 Client Licenses $1223_00
(1) #LDVPV50 Intel Virus Protect Single Server/Unlimited Clients. $ 913.00
(1) #D4963A HP 4.2GB Hard Drive - for fault tolerance mirroring. $ 583.00
Total File Server Cost with options... $13,124.00
NtIWOIl. Inlt,r,r:'IHIll Sc'r"j('(. ;md $UpP,)11
2
WAN Items
(2) #CISCO 2524-CH Cisco 2524 Router $3194.00
(2) #CD25-A-11.2= Cisco 109 Enterprise Router Software $1976.00
(2) #MEM-1X8D Cisco Dram memory upgrade $ 234.00
(2) #SM25-T1 Cisco T1/Fraclional T1 WAN Module $2434.00
(2) #CON-SNT -PKG5 Cisco SmartNet Coverage 8x5xNBD $ 690.00
Total WAN Option Cost with options... $8528.00
Easton Office - Workstation items
(4) #356010-004 Compaq DeskPro 333MHz, 64MB RAM, 604GB $3716.00
Hard Drive, 32xCDROM, Win95.
(4) #CKA5227L Samsung 15' SVGA Color Monitor. $ 676.00
(4) #PER7T APC Surge w/Modem Protection. $ 80.00
(1) #PILA8460PK5 Intel Ethernet 10/100 Adapter 5Pack $ 381.00
(1) #Memory 16MB RAM Upgrade for Mr. Symon's PC. $ 62.00
(1) #588-00265 Microsoft Office97 Professional Upgrade Full $ 229.00
Copy for Mr. Symon's PC.
(1) #588-0360 Microsoft Office97 Professional Upgrade $ 218.00
License for Lauren's PC.
(4) #588-00363 Microsoft Office97 Professional License Only $1412.00
"for the new PCs as discussed in our last
meeting.
Lehighton Office - Workstation Items
(1) #356010-004 Compaq DeskPro 333MHz, 64MB RAM, 604GB $ 929.00
Hard Drive, 32xCDROM, Win95.
(1) #CKA5227L Samsung 15' SVGA Color Monitor. $ 169.00
(1) #PER7T APC Surge w/Mcdem Protection. $ 20.00
(1) #PILA6460PK5 Intel Ethernet '/0/100 Adapter 5Pack $ 381.00
(1) #005667-0 US Robotics Sportster Internal 56k Modem $ 105.00
(1) #EE130TX8US Intel8Port Ethernet 10/100 Hub $ 495.00
(5) #3827GY-3 Patch Cables 3' $ 50.00
(4) #3827GY-7 Patch Cables 7' $ 80.00
(1) #3827GY-10 Patch Cables 10' $ 25.00
(2) #Memory 16MB RAM Upgrade. $ 124.00
(3) #654-00212 Microsoft Windows95 Upgrade. $ 294.00
(3) #588-0360 Microsoft Office97 Professional Upgrade $ 654.00
License.
(1 ) #353-00005 Microsoft Office97 Professional Full Copy $ 552.00
with Media.
Total Workstation Cost: $10,652.00
Nt'twOlL. Inlt'gr:ation Sr-n'ic'( and S\Jppon
3
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Leighton Office:
Day 1... a Hours
Day 2... 8 Hours
Systems Engineer
Office97, Network card and memory installation and configuration on (4)
workstations. Set up of network printers.
Installation and configuration of Virus Protect and Exchange on (4)
workstations. Final testing.
Senior SE 44 Hours at $125/Hour
16 Hours ALWIN Install
Systems Engineer 40 Hours at $110/Hour
Hardware Technician 16 Hours at $95/Hour
Travel, Lodging and Meals
Total Non Contract Installation Cost:
$5,500.00
$1,000.00
$4,400.00
$1,520.00
$2,314.00
$14,734.00
Vs.
Network Support Contract $15,000.00 Rates...contract does not expire until all monies have
been used for network support.
Senior SE 44 Hours at $80/Hour
16 Hours ALWIN Install
Systems Engineer 40 Hours at $65/Hour
Hardware Technician 16 Hours at $50/Hour
Travel, Lodging and Meals
Total Contract Installation Cost:
$3,520.00
$1,000.00
$2,600.00
$ 800.00
$2,314.00
$10,234.00
Cost savings of $4,500.00 from non-contract rates with $4,766.00 remaining for on-going
support.
Training
Our training resources group offers a high-qua!ity, instructor-led training program in step with
your business requirements. The end users of Nor-Car will be training on-site. All training
course materials will be included and are designed to provide step-by-step, easy to follow
instructions and can be developed as per your request, so that the proper material is covered
during training. Our goal is to provide the best possible training available to Nor-Car Federal
Credit Union. A later date will be determined by the Credit Union to complete training of end
users in Excel, Access and Powerpoint. Intermediate and advanced classes are available, if
needed.
Train (6) full day on-site classes for up to (10) students per class on the following topics:
Windows95 Introduction
Word Introduction Outlook/Exchange Introduction
Travel fees, lodging and meals
On-site setup and testing of training equipment and softlvare
(6) Full day on-site classes @ $950.00 each
Total Training Cost:
$1000.00
$1050.00
$5700.00
$7,750.00
NC'IWOlk IntC'gu.tion Ser\'icr and Suppor1
5
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-02741 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HINTON & ASSOCIATES INC
VS.
NOR-CAR FEDERAL CREDIT UNION
R. Thomas Kline , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: NOR-CAR FEDEIV'.L CREDIT UNION
but was unable to locate
deputized the sheriff of
to serve the within NOTICE
Them
in his bailiwick.
He therefore
Pennsylvania.
NORTHAMPTON
AND COMPLAINT
County,
On May 25th, 1999
the attached return from
, this office was in
receipt of
Pennsylvania.
NORTHAMPTON
County,
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Northampton
So answe;r:s.,' /'/ . ;/
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52.00
~b/.UU SM~GE4, ANDERSON & SACKS
05(25(1999
Sworn and subscribed to before me
this .:2:'-~ day of J 1". }.
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o r:.ary'
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provide installation of a computer network system at Nor-car.
4. The Complaint alleges the Plaintiff perfonned the work requested and
supplied Defendant with goods and services.
5. Any work that was perfonned by Plaintiff was perfonned at Nor-Car's
place of business.
6. Any services the Plaintiffperfonned were perfonned at Nor-Car's place
of business. In support of the above paragraphs, Defendants attach and incorporate an
affidavit from Michael 1. Symons, President of Nor-Car Federal Credit Union.
7. Pursuant to Pa.R.C.P. No. 1028 (a)(1) Plaintiff has filed preliminary
objections alleging this Honorable Court lacks subject matter jurisdiction to hear this
action.
8. Pursuant to Pa.R.c.p. No. 1028 (a)(I) Plaintiff has filed preliminary
objections alleging improper venue.
9. Trial in Cumberland County would not an inconvenient forum for the
witnesses and the parties.
10. The only connection Cumberland County has with this action is that
Plaintiff's business is located in Cumberland County.
2
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WHEREFORE, it is respectfully requested that this Honorable Court transfer
tIJis matter to Northampton County where Nor-Car has its principal plaee of business.
18016-1426
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COlJNTY, PENNSVLVANIA
CIVIL ACTION. LAW
HINTON 01: ASSOCIATES, INC.,
PlailltlfT
: No: 99-1741
Y.
:
NOR.CAR FEDERAL CREDIT UNION, :
~ead.ct :
:
AEEWM!1I
I, Michael 1. Symons. President of Nor-Car Federal Credit Union, hereby stale
and affirm as follows:
I. I BIll the President of Nor-Car Federal Credit Union.
2. Nor-Car Federal Credit Union lias offices in Northampton County and
Cmbon County.
3. Any work provided by Plaintiffwith regards to the above-captioned ease
was perfonned at the offices of Nor-Car
4. Niy eoods and services that P1aintitrprovided in the abovc-captioned ca~c
were provided at the offices of Nor-Car.
S. Any instaUation of a compuh:r network system provided by Plaintiff in the
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extent the avemlents in this paragraph arc inconsistent with same, they are
specifically denied.
5. Denied. The agreement is a document which speaks for itself. To the
extent the averments in this paragraph are inconsistent with same, they are
specifically denied.
6. Denied. It is specifically denied that Plaintiffperformed the work in a
timely and workmanlike fashion. By way of further answer, the work performed
was incomplete, unsatisfactory, and not workmanlike.
7. Denied. It is specifically denied that Plaintiffperfol'med the work in a
contract. As noted above, the work performed was incomplete, unsatisfactory, and
not workmanlike. As a result of the improper and substandard work performed by
Plaintiff, Nor-Car is not responsible to Plaintiff for any charges. As noted below,
due to Plaintiffs actions, Defendant was forced incur costs and expenses.
8. Denied as Statcd. It is admitted that Defendant paid Plaintiff the sum
of $10,000 and has refused to pay Plaintiff any additional funds. It is spccifically
dcnied that Plaintiff is cntitled to any additional funds. As outlined above, thc work
perfomlcd by Plaintiff was incomplete, unsatisfactory, and not workmanlike.As
2
13. Defendant, Nor-Car, raises the affinnative defense of fraud.
14. Defendant, Nor-Car, raises the affirmative defense of justification.
15. Defendant, Nor-Car, raises the affimlative defense of payment.
16. Defendant, Nor-Car, raises the affirmative defense of release.
WHEREFORE, it is respectfully requested that this Honorable Court deny
and dismiss Plaintiffs complaint.
COUNTERCLAIM
17. Defendant, Nor-Car, incorporates the preceding paragraphs as if set
forth at length.
18. Plaintiff installed various computer items to Nor-Car at its place of
business in Easton, Northampton County, Pennsylvania.
19. Plaintiff infomled Nor-Car that the system was complete and
functional.
20. The placement of wiring and outlets was improper.
4
21. The program did not work consistently.
22. The program did not print in other offices.
23. Nor-Car was unable to aeeess certain programs and systems.
24. The programs did not work properly.
25. Plaintiff did not provide Nor-Car with documentation with regards to
these programs.
26. Plaintiff did not provide Nor-Car with passwords with regards to these
programs.
27. Plaintiff did not provide Nor-Car with service with regards to these
programs.
28. Plaintiff did not provide Nor-Car with any licenses or program disks..
29. Nor-Car has not received any support for the hardware that has been
installed.
30. As a result of the incomplete, unsatisfactory, and non-workmanlike
fashion of the work provided by Plaintiff, Nor-Car was forced to expends costs in
the amount of five thousand ($5000.00) dollars as outlined below in order to correct
the incomplete, unsatisfactory, and non-workmanlike services provided by Plaintiff.
5
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29. Plaintiff is without knowledge or infol1nation sufficicnt to form an opinion as 10 the lluth
fthis allcgation, and strict proofis demanded at trial. Furthel1nore, Plaintiff does not understand what
. s meant by tel1ns "support" and "hardware", and is unable to properly respond to this allegation.
30. Plaintiffis without knowledge or inl<lI1nation sufficient to fOl1n an opinion as to the tmth
of this allegation, and strict proofis demanded at trial. Furthel1nore, it is denied that Plaintiffs work
was incomplete, unsatisfactory or non-workmanlike.
WHEREFORE, Plainliffdemands that Defcndant's counterclaim be dismissed.
SMIGEL, ANDERSON_ & SACKS
Datc:~ 21, /0q1
I
0:-
lderson,
I.D.#; 1315
2917 North Front Strcet
Hanisburg, P A 17110
(717) 234-2401
Attol1leys for Plaintiff
outstanding discovery. This date, the Court has denied
plaintiff's request for protective order on discovery, thus
enabling defendant's discovery to proceed. Currently there
is a defense set of interrogatories given to plaintiff, and
unanswered to this point. Plaintiff's counsel suggests
that he can answer these interrogatories and deliver the
requested documents, asked for, within seven days of
today's date. In any event, defense counsel will have 45
days to complete discovery after delivery of the documents
requested.
In view of the uncompleted discovery
situation, the case is stricken from the trial list and
either counsel is free to relist the case for the May term
of court.
By the Court,
C. Lee Anderson, Esquire
For the plaintiff
Steven N. Goudsouzian, Esquire
Fo~ th0 Defendant
Prothonotary ~
Court Administrator
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HINTON & ASSOCIATES, INC.,
Plaintiff
No: 99-2741
v.
NOR-CAR FEDERAL CREDIT UNION,
Defendant
CERTIFICATE OF SERVICE
I, C. Lee Anderson, Esquire, hereby certify that a true and correct copy of
Plaintiffs Response to Defendant's Request for Production of Documents was served
upon the following as addressed below by depositing the same in the United States Mail,
first class, postage prepaid, at Harrisburg, Pennsylvania on ..2f) ctu::A <, .zveJO
2000:
Steven N. Goudsouzian, Esquire
70 East Broad Street
P.O. Box 1426
Bethlehem, PA 18016-1426
Date: ''I1)O(,iu.l, (, 20L>>
SMIGEL ANDE ON & SACKS
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C. L nderson, Esquire
J.D. #: _1315
2917 North Front Street
Harrisburg, P A 17110
(717) 234-2.101
Attomeys for Plaintiff
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STEVEN N. GOUDSOUZIAN
AlTORNEY AT LAW
70 EAST BROAD STREET, P.O. Box 1426
BliTIILEHEM, P^ J8016-H26
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70 East Broad Street
P.O. Box 1426
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Steven N. Goudsouzian, Esquire
I.D.# 74831
70 East Broad Street
P,O, Box 1426
Bethlehem, P A 18016.1426
(610) 882-1180
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HINTON & ASSOCIATES, INC.,
Plaintiff
v.
No: 99-2741
(Preliminary Objections
Decided by The Honorable
Kevin A. Hess)
NOR-CAR FEDERAL CREDIT UNION,
Defendant
MOTIO~TO-.STRlKE J'RIAL LISTING
AND NOW comes, Defendant, Nor-Car Federal Credit Union, by and through
its attorney Stevcn N. Goudsouzian, and motions the Court as follows:
1. The plcadings in this matter were closcd on or about Novembcr 29, 1999.
2. No discovery has takcn place.
3. Dcfendant, Nor-Car Fcdcral Credit Union, has provided Plaintiff with a
Noticc of Dcposition scheduling his dcposition for March 14, 2000, at 10:00 a.m.
4. Dcfendant has propoundcd writtcn discovery upon Plaintiff. As of this
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date, this discovcry remains outstanding.
5. Pursuant to Local Rule 213-2, at the call ofthc trial list, counscl for all
partics shan indicatc that discovcry has bccn complcted, that all prc-trial actions have
becn takcn, and that easc is ready for trial in an respects. In this mattcr, discovery has
not been complcted, pre-trial actions have not been eompletcd, and the case is not
ready for trial.
6. Counsel for Defendant, Steven N. Goudsouzian, attempted to obtain the
concurrence of opposing counsel, C. Lee Anderson, attorney for the Plaintiff, pursuant
to Local Rule 206.2(c). However, Attorney Anderson has refuscd to voluntarily
remove this mattcr from the trial list.
7. This case is not ready for trial.
WHEREFORE, it is respectfully requested that this matter be stricken from the
trial list until discovery is completc.
- -
Steven N. Goudsouzian, Esquire
10# 74831
70 East Broad Street
P.O. Box 1426
Bl'thlehc111, PA 18016-1426
(610) 882-1180
Datc: Fcbruary 4, 2000
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PRAECIPE FOR LISTING CASE FOR TRIAL
(Must be typewritten and sutrnitted in duplicate)
TO THE PICl'I-MWl'ARY OF CUMBERLAND COUNTY
Please list the following case:
(Check one)
x
for JURY trial at the next tenn of civil court.
for trial without a jury.
-----------------------------------------
CAPTION OF CASE
(entire caption !lUst be stated in full)
(check one)
Hinton & Associates, inc.
( X) Civi1 Action - Law
Appeal fran Arllitration
(other)
( Plaintiff)
VS.
Nor-Car Federal Credit Union
The
and
trial list will be called on
if
April ,~ 2000
(Defendant)
Trials COllmence on MaY 1. 2000
Pretrials will be held on ~il 4 2000
(Briefs are due 5 days before pretrials. )
(The party listing this case for trial shall
provide forthwith a copy of the praecipe to
all counsel, pursuant to local Rule 214.1.)
vs.
No. 2741 Civil
19 99
Indicate the attorney who will try case for the party who files this praecipe,
C. Lee Anderson, Smiqel, Anderson & Sacks, 2917 North Front Street,
Harrisburg, PA 17110
Indicate trial counsel for other parties if known: Steven N. Goudsouzian,
70 East Broad Street, PO Box 1426, Bethlehem, PA
18016-1426
1his case is ready ~or trial.
-
"nderson
Date:
/117(1.1 'l 1 () (1 c\
Attorney for: Plaintiff
HINTON & ASSOCIATES, INC.,
PLAINTIFF
V.
NOR-CAR FEDERAL CREDIT UNION,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-2741
CIVIL ACTION - AT LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, C. lee Anderson, Esquire, hereby certliy tnat I have served a true and correct
copy of Notice of Oral Deposition upon counsel for Defendant as addressed below by
depositing the same in the U.S. Mail, first class, postage prepaid, on 'If!t11 1'-/ ,
2000:
Steven N. Goudsouzian
70 East Broad Street
PO Box 1426
Bethlehem, PA 18016-1426
Date: ~'1~d rCj I ) Jl[,()
I
SMIGEL, ANDERSON & SACKS
L~
By:
C. lee n erson, Esquire
1.0. No.: 1315
2917 North Front Street
Harrisburg, PA 17110-1223
(717) 234-2401
Attorneys for Plaintiffs
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Hinton & Associates, Inc.
: IN THE COURT OF COMMON PLEAS OF
: CUMBER!..AND COUNTY, PENNSYLVANIA
V
Nor-Car Federal Credit Union
: NO. 99-2741 CIVIL TERM
QFDER OF COURT
AND NOW, April II , 2000, counsel having failed to call the above case for trial,
the case is stricken from the May I, 2000 trial tenn. Counsel is directed to relist the case when
ready.
C. Lee Anderson, Esquire
For the Plaintiff
c..cx.,c..."::> ~,.., \e..d.
I..\_\u.-OO
Steven N. Goudsouzian, Esquire
For the Defendant
Court Administrator
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