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Home My WebLink About99-06317? rN ?? 1`dN ?j f ti ? e 1 i `{kf N 3 X13( E ' "1i ppl[ ..Y t F>. a -w ! A d . fi t. 9:_t t ei t' 1. 5 <i ? ` t4 t?1 f S A 4 + x fte1. ? 1 t 7 x?1 ? ti k ti 1f. me t s+ b w ? ? ? , . . N Y f X fib r r w? a A "? J kRy ' Y ij } 1 ; ? ?( ) YR E ?b k w '3i ? ?f ? j w P( 2i t k i i (}. * ) i ) g Yes ? . 2C ` . ? ;;: l tk ay. r f ? d sq ? ? ;r T u c( Y`, ? A S+ I V C to k ' i ' E 'Ir f ?_ v 1 T? F 1 a s V Q? Eµ COMMONWe ALT II or 1•ENNSYL VAN IA COU{IT UI COMMON PLEAS AVSyQVNTY CUM HP PENNSYLVANIA NOTICE OF APPEAL Ilium /ob51,77 DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. 99• 631 / , •?.,? / T NOTICE OF APPEAL Notice is grven that the appellant has hied nl the above Court of Common Pleas an dlgieal floor the prdgment umdmed by the District Justice on the date and in the case mentioned below. MIYa OI •I?\le.Ml - Y\- oiir-we:o? wIw pr p.r. ALLCRETE DESIGNS, c/o TIM YOHE Sysan K. Day \ep?a.TorTwu•\Nr --in: .-_.__ r\.I u. cool 126 $PFjng_Rd .,_Di.Usburg,--PA___17019-------___.-------,--------- pl.t pI fVpp YlF• 11, 1Nl C\.\ p1 ..... 10? /9g- m-and-Toni -Goril---f- -.v:"__A7-lnruhS'I]nci non ?/ m1 ev 19 1 0000209-99 UNN: LT 19 Sy: Jordan This block will he signed ONLY when this notatiunr is J it muhn Pa. R.C.P.J,P. No. 10088. This Notice of Appeal, when tecd:vetl by dnr )strict lustice•, will upeiaur as a SUPERSEDEAS to the judgment for possession in this case. Sgn.nure of P wh,rnolacy or Oeru•y --- ICOFF, P.C. -Cunningham,--Esq u,i-re--,? If appellant was Claimant (sue Pa. R,C.P.J.P, NO 1001161 in action before District Jusbce,'he' MUST FILE A COMPLAINT within twenty (20) days alter hlinq Iris NOTICE of APPEAL. 1 , PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of lorfn to he used Oft Y when mice/Lint was DEFENDANT (see Pa. R.C.P,J.P. No. 10011/1 in action before District justice. IF NOT USED, detach from copy of notice of appeal to be serreul upon appebeel. PRAECIPE: To Prothonotary Enter rule upon Tim and Toni Gori 1 ppclleelsl, to file a complaint in this appeal Name of Jnpedaeld ) (Common Pleas No. within !wcnty i20) days iflyr'service 10 rule yflP ntry of judgment of non pros. UNNINGHA?d ?C ERNICOFFI, P.C. 7ppMhnt of hit allomey or Jyenr RULE: To-silo an?TOni_Go -_, Jhpeheela'Jordan D. Cunningham, Esquire NJlne of JPPCUPYAIeeril - - (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) It you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECIPE. (3) The date of service of :his rule if service was by mail is the date of mailing. Date: 69C L, '19 I r, . -)1t t ., Alv4 S nhonoalyorDeputy While .... Prothonotary Copy Green --- Court Flo Copy Yellow -•• Appellant's Copy Pink •----- Appolle+c Copy Gold ----• •D J Copy i + PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST DE FILED WITHIN TEN (10) DAYS AFTEn filing the notice of appeal. Chock applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ++ AFFIDAVIT: 1 hereby swear or allrrm that I carved ? a copy of the Notice of Appeal, Common Pleas No. _, upon the District Justice designated therein on (date of service! . 19_, ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, ; Oil , 19 -? by pcrsmwl service ? by (ceriilied) (registered) mail, sender's receipt attached hereto. El and further that I served ilia Rule to Fite a Complaint accompanying the above Notice of Appeal upon the appellees) to' whom the Rule was addressed on,___ , 19__, ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF t9-. ---- Synarun o1 dlianr do a o I 1 Sipnatorr ofolliciar before whom alhUaril war mshr Tifle of official 19_, My commission expires Oil ?p 01 luI V i .I tJ i? > .r1 -rr . 66MMONWEALTH OF PENNSYLVANIA rnl iNTV nF• CUMBERLAND 09-3-03 DJ Nam, Ho,i SUSAN R. DAY AO]'411 229 MILL STREET, BOX 167 MT. HOLLY SPRINGS, PA T,l,one? (717) 486-7672 17065 ATTORNEY DEF PRIVATE : NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME AM ADDAESS rGORIL, TIM A TONI 9 FORGE RD. BOILING SPRINGS, PA 17007 L J VS. DEFENDANT: NAME amADOnESS FALLCRETE DESIGNS C/O TIM YORE 126 SPRING RD. DILLSBURG, PA 17019 JORDON CUNNINGHAM, ESQ. L J 2320 N. 2ND ST. DocketNo.: CV-0000209-99 HARRISBURG, PA 17110 Date Filed: 9 '01/99 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PT.hTNTIFF x] Judgment was entered for: (Name) GnRTT., TTM x: TnmT Fx? Judgment was entered against: (Name) AT.T.rRtzTg ngnTGN>T Inlet TTM VOHR in the amount of $ 7, 22n _ r;n on: (Date of Judgment) 1 n/nB/oa El Defendants are jointly and severally liable. (Date & Time) El Damages will be assessed on: ? This case dismissed without prejudi:e. Amount of Judgment Subject to Attachment/Act 5 of 1996 $- ? Levy is stayed for days or ? generally stayed. ? Objection to levy has been filed and hearing will be held: Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs $ I 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 THE PROTHONOTARY{CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTJRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. Date % District Justice I certify that this'is a 'true and correct copy of the record of the proceedings containing the judgment. C -'Date District Justice My commission expires first Monday of January, 2004 SEAL AOPC 31599 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (f0) DAYS AFTER blinp the rtohco of appeal. Chock applicable boxes) COMMONWEALT OF PENNSYLVANIA + 'r? ;a COUNTY OF AFFIDAVIT: I hereby sweat or alliimn that I eervrd ???yyy n / [jKa opy of the Natic• of Appeal, Cummou PI•as No./ `!??hlion hl.e Distr' •t Justice designated therein an (date ofurvicel p , I9 ? by pel 11,11 service by (certited mail, sender's reee(pt attached her • a, am t on the appellee, (name)./ ?!s'1._._Czho_c%L.. Z=7- All -, nn e r. t 19 ? by personal service by (certified) twystei . fknail, sender's receipt attached (hereto. [vYand further that I served the Rule ycFil a Complaint accnm ianying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on__::I-t- , - , 19. ?, 0 by personal service k';}-by(certified) trej4t"e4l mail, sender's receipt attached hereto. SWORN JAOEFIRMED) AND UBSCRI[l D UEF001 THIS a;iZ7rM1)LW iynewe of ofhcia/belore wham ellydawfwu ode Title or olliciel IF A. Mornson, Notary Public My commhtion expire o,Harrri%u g, Dau n Com jyy em Pennsylvania s on of a s I 1 lS.ynulwr of albenf '? ao lp r ° p ? rl n 0 1 rj ?j ;;s yS 41 COMMONWLALTIf Or PENNSYLVANIA COU111 Of COMMON PLEAS CUN???(?In1tOrlsTitiLiti•I'u7 y ii 1'1 ALJ; ) f VAIN:, NOTICE OF APPEAL r f N0`.1 DISTRICT JUSTICE JUDGMENT" C0161MON PLEAS No r?rl- /i.?(? L-d v•?l ??,-, NOTICE OF APPEAL Notice n rpvrn that the appellant has fled nr the .shove Court of Common flees an ,ggw.il hoar the judgment tendmed by ow District Juwce on till- date and in the case mentioned belA. Fi4. O? .Il.llw M. r O./. ALLCtiiPC i:'_:: TGC+C, r:/o 'iil•l YOH:% r ..7-,? nUCan K Days ToawTiTu?i.iii..a. -?'- -- -"-_--iii.--'"----- .u.r n•cooa 1l6 Spriuy. Rd _- owia a. ru u. Yant -?? -?-? fllj,« rn'a, a a-e?l-•. . CV 19 ?IIL102G9-99 NGI tsy _ LT 19 This block will fire signed ONLY when this mnahor, n n!nunrd w r Pa. R.C.P.J.P. No. 10088. This Notice of Appeal, when received by the Oisti ct Justice, svdl uper,nr as a SLIPEnSEDEAS to the. judgment for possession in this c,/w. -_? SWnafurl•ul P/uflrnnnhpy a/Ur!•u!y GICUFF, P.C. It appellant was Clahnita lsce Pa. R.C.P.J.P. No 1001161 in action before. District Jusrice, he MUST FILC A COMPLAINT within twenty (201 flays after Iding Ills NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of loan to be used ONLY when appepant Iv.ls OFFENDANT (see Pa. R.C.P.J.P. No. 1001171 in action before District Jus rice. IF NOT USED, detach from ropy of notice of appear to be served upon apnelleef. PRAECIPE: To Prothonotary Enter rule upon 'I' I o, and ;'Ott f :;u r i I , appellee(sl, to file a ccmplaint in this appeal IVarrw of appNreenl ? (Cbhmron Pleas No. -1 svithin twenty 1201 days attur"service g9Viuln t?o rChtry of judgment of non pros. lN; i ?ili:r:YICOFNI P.C. ,ry f gnstarFDTJPpl71]mew-hn atforney or ala•nl RULE: Tn_.=11sR_1t1 Try:1L?LLL_____-_-_,apucllccla??ordan6L?.E4Cunninghjam,ELquire Na/ne of appel.'/•01li (1) You jre notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date 61 service of Ihis.(ule upon you by personal service or by certified or registered"muif.-' ,q2) If you do not file a coinplaint within this time, a JUDGMENT OF NON PROS WILD t ,gNTERED AGAINST YOU ON PRAECIPE. ,.ny-t„;;teC+ (3) The date of service of :hls rule if service was by mail Is the date of mailing. Date: i?r /, /, . r'• 19 / `/ r• Whrto•.•• Prothonotaly copy Green--- CouttAleCopy Yollow••. Appellant's Copy Pink •----- Appolloe Copy Gold ••• ••D J Copy j I1 /Il l- r°/r... AIN.Q • _T I Sgnature of Pruthonolaly or Depufy Z 568 367 910 US Postal Service Receipt for Certified Mail No Insurance Coverage Provfdod, Do not use for Inteional Mail Soo ro [Se"*r- rnat r Postage 0 '1$ "/ goo ? I Soedat DON" Poe Restricted Oeovery Fee Reem Recrip SMeirta to ( 45 TOTAL Postage A Fees S Paanark ru DNe u' R R 9 m fel 0 LL a NO. 99-6317 CIVIL • Z 568 367 909 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for latnrnalinnal Nail /.Can ravanaI S n to v?t v. -- St !LN v S )6 f7 P Ke $ die, IP D\W e 4 J I f /? Postage S /7u( ,y Coaled Fee Speaal Delivery Fee Restricted Delivery Fee Return Recapt Mown; 10 W" A Date DeNvmed Petyn nncep Srrerq ro H!m Da!e, a Adinsees Adins TOTAL Passage A Pods S Postman nr Dale P 081 030 832 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. no MI IIRY rnl lnlnmslNnsl ".a /e--.-..... O ' U 1 a f Mer D a. IP PA Postage $ -R-la -7 CanfiM Fes Fipsdal Delivery Fee Restricted Delivery Fee Return S Whom A D?atepDe W DZW A ,Adit j?AAdwe M1 TOTAL Postage & Fans $ Pessimists of Date ,?'d I et lyti4 G 8 so c7 NLL 6 LAW OFFICES DI1S, GUIDO, SNUFF & MASLAND W.HIOHSTRW 2109 MARKET tTR=-. WSLE, PA 17017 CAMP HILL. PA 17011 IN9 (717) 2U-6221 PHONE (717)b7-3405 TIM AND TONI GORIL, HUSBAND AND WIFE PLAINTIFFS V. ALLCRETE DESIGNS AND TIM YOHE DEFENDANTS IN THE COURT OF CC CUMBERLAND COUNTY, NO. 99-6317 CIVIL TERM CIVIL ACTION - LAW You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 SAIDIS, SHUFF & MASLApND' SAIDIS,GUIDO, SHUFF& Date: 1014o By: !!yf(((///111///{{{ MASLAND Richard P. Mislitsky, squire 26 W. High Stmet Supreme Court Id # 28123 Cu1u1a.PA 26 West High Street Carlisle, PA 17013 (717) 243-6222 (telephone) (717) 243-6486 (facsimile) Counsel for Plaintiffs SAIDIS, GUIDO, SHUFF & MASLAND 26 W. I i{h Strce: Culi le. PA TIM AND TONI GORIL, HUSBAND AND WIFE 9 FORGE ROAD BOILING SPRINGS,PA 17007 PLAINTIFFS V. ALLCRETE DESIGNS AND TIM YOHE 126 SPRING ROAD DILLSBURG, PA 17019 DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6317 CIVIL TERM CIVIL ACTION - LAW COMPLAINT GENERAL AVERMENTS 1. Plaintiffs are Timothy and Toni Goril, who reside at 9 Forge Road, Boiling Springs, PA 17007. 2. The Defendants, Allcrete Designs, is believed and therefore averred to be a business operating within the Commonwealth of Pennsylvania with a principal place business located at 126 Spring Road, Dillsburg, PA 17019. Plaintiffs are without sufficient information or knowledge to more specifically plead this averment. 3. Defendant, Tim Yohe, is believed and therefore averred to be owner and/or operator of the Defendant, Allcrete Designs, maintaining a place of business at 126 Spring Road, Dillsburg, PA 17019. Plaintiffs are without sufficient information or knowledge to more specifically plead this Averment. SAIDIS, GUIDO, SHUFF & MASLAND 26 W. Filgh Street Grliile. PA 9. In or about September 1998, the Defendants did contract with the Plaintiffs for installation of a "stampcrete" patio, among other things, at the Plaintiffs' home, situate at 9 Forge Road, Boiling Springs, PA. The Plaintiffs are not in possession of the contract. Attached, hereto, and marked Exhibit "A", is a copy of the Proposal presented to the Plaintiffs by the Defendants dated August 31, 1998. S. At all times material hereto, Defendants, by and through their agents, servants, workmen and/or employees, represented to the Plaintiffs that all work performed under the Contract would be to the 100% satisfaction of the Plaintiffs. 6. Plaintiffs justifiably relied upon the Contract and the representation made by Defendants. 7. In or about September 1998, the Defendants, by and through their agents, servants, workmen and/or employees, began work at the Plaintiffs' home, pursuant to the agreement between the Plaintiffs and the Defendants. 8. In or about December 1998, it became obvious to the Plaintiffs that the workmanship and/or materials utilized by the Defendants were defective, improperly installed 2 and/or installed with improper and adequate workmanship or skill. 9. In or about the same time, the Plaintiffs informed the Defendants of the aforesaid problems. 10. On receiving the aforesaid complaints from the Plaintiffs, the Defendants reiterated their representations that all workmanship and materials would be the 100% satisfaction of the Plaintiffs and further inform the Plaintiffs that the aforesaid defects would be corrected to the satisfaction of the Plaintiffs as soon as time and weather permitted. 11. In or about May/June of 1999 the Defendants on several occasions attempted to correct the defects in workmanship and/or materials. 12. Despite Defendants attempts as aforesaid, Defendants were not able to correct the defects in the workmanship and/or materials. 13. In or about June 1999 the Defendants informed Plaintiffs that Defendants could not or would not continue their SAIDIS, GUH)O, SHUFF & MASLAND 26 w. sigh sues Wide. PA attempts to correct the defects in workmanship and/or materials. 14. During Defendants' attempts to correct the aforesaid and I` satisfy the representations made to the Plaintiffs, 3 Defendants used various chemicals which caused damage to Plaintiffs' property, specifically the driveway. 15. Defendants refused to repair and/or correct the damage to Plaintiffs' driveway despite repeated requests by the Plaintiffs. Attached hereto and marked Exhibit "B" is a copy of an estimate received for the repair of the damage caused by the Defendants. 16. Upon Defendants' refusal to stand by the representations and to correct defects in workmanship and materials, the Plaintiffs, in an effort to correct the aforesaid problems secured the advice and counsel of other experts. Attached hereto and marked Exhibit "C" is an estimate setting forth the cost of removing the defective patio installed by the Defendants for installation of a new stampcrete patio. 17. Plaintiffs have satisfied all conditions precedent and affirmatively aver that they are in no way responsible for the defects in workmanship and/or materials. 18. Plaintiffs affirmatively aver that Defendants have SAIDIS,GUIDO, breached their contract with Plaintiffs. SHUFF & MASLAND 19. Plaintiffs affirmatively aver that Defendants have 26 W. High Seal Wide, PA breached their warranties to the Plaintiffs, both express and implied. 4 , Plaintiffs pray for judgment against the Defendants in the amount of Seven Thousand Six Hundred Fifty Dollars ($7,650.00) plus interest, the costs of litigation and attorney's fees. COUNT I - 20. Paragraphs 1 through 19 above are incorporated herein by reference as though fully set forth herein. 21. Plaintiffs affirmatively aver that the problems as stated in Count I of the Complaint are the result of the negligence and carelessness of the Defendants in the installation of the patio or in the selection of the materials used in the patio. 22. Plaintiffs affirmatively aver that the defects and/or problems specified in Count I hereof are in no way the result of the negligence or carelessness of the Plaintiffs. 23. As a result of the negligence and carelessness of the Defendant, the Plaintiffs hereinbefore set forth. sustained damages as SAIDIS,GUIDO, 11 WHEREFORE, Plaintiffs pray for judgment against the Defendants SHUFF & MASLAND in the amount of Seven Thousand Six Hundred Fifty Dollars 26 W. Mgh Sneer CuUde,PA ($7,650.00) plus the costs of litigation and attorney's fees. 5 SAID1S, GUIDO, SHUFF & MASLAND 26 W. High Seat Carlisle, PA COUNT II - BREACH OF CONTRACT 24. Paragraphs 1 through 23 are incorporated herein as though set forth in full. 25. Plaintiffs and Defendants entered into both a verbal and written agreement. 26. Defendant's refusal to correct and/or replace the defective patio is a breach of the aforesaid contracts. WHEREFORE, Plaintiffs pray for judgment against the Defendants in the amount of Seven Thousand Six Hundred Fifty Dollars ($7,650.00) plus the costs of litigation and attorney's fees. COUNT III - BREACH OF WARRANTY 27. Paragraphs 1 through 26 are incorporated herein as though set forth in full. 28. Defendants made both express and implied, verbal and written, warranties to the Plaintiffs. 29. Defendant's refusal to correct and/or replace the defective patio is a breach of the express, implied, verbal and/or written warranty. 6 WHEREFORE, Plaintiffs pray for judgment against the Defendants in the amount of Seven Thousand Six Hundred Fifty Dollars ($7,650.00) plus the costs of litigation and attorney's fees. SAIDIS, SNUFF & MASLAND Date: q By: /0 21 `I Richard P. Mislitsky, Esqui e Supreme Court Id # 28123 26 West High Street Carlisle, PA 17013 (717) 243-6222 (telephone) Counsel for Plaintiffs SAHHS, GUIDO, SHUFF & : MASLAND i . , - 26 W. M`h Sha: Calble, PA etx 7 I verify that the statements made in the foregoing SAIDIS, GUIDO, SNUFF & MASLAND 26 W. High Sure: Wide. PA Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. DATED: II-3^ / 9 Tim Goril DATED:-9q ?X _4-?',- ToniVoril I PM SHELTER DEVELOPMENT 7174327167 P.01 li4 RLLCRETE DESIGNS 126 SPRING RD. DILLSBURG,PR 17819 (717) 238-2588 to Aug 31, 1990 so to perform the labor necessary for the completion of the it. of brick stamp 458sq. ft. of concrete. 1 rear poarch e guaranteed to be as specified. The above work to performed In h the drawings and sptacifications submitted for nhoue work and substantial workmanlike manner for the sum of $3125. as follows: 50% at start of job; 50% at completion of ,Job. I on square footage. Respectfully submitted: RLLCRETE DESIGNS PER: Timothy Vohe sal may be withdrawn by us If not accepted within 30 days. latlons from above speciticattons involving extra cost, will be executed onlu upon II become an extra charge mier anti abaue the estimate. RII agreements contingent t or delays ocuond our control. owner to carry fire, Inmada and other necessary RLLCRETE DESIGNS IS FULLY INSURED AND COUERED UNUER WORKERS' COMPENS0110N. Receptance of Proposal TM a clflcallons and condlllons are satlsfaclury and are hereby accepted. You are authoNred h do Cllled. Payment will be made as slated abauc. maim Slgnalure '*4. . EXHR31T OAV ` rc q . 1 11f°rC11I; 11/l'5? r?'Ifort II:ZJ, 011 -JG/ - / / c-/ SWEENEY'S SEALCOATING SERVICES 505 Sandbank Road • Mt. Holly Springs, PA 17065 (717) 486-3518 Specializing in Residential & Commercial Sealcoating Services D b Parking Areas ^ n ` i er of Bt hl / cmber of [lencr Dusincss Bureau -h I! Proposal Submitted to Or l? I r, T) I'bonu: C l Dalc: Address: QJ v ?? - j r Job Name: 1 City. Slate. "Lip ?? ? Job Lexalion: C Ili hereby rubma rpectfcanom and en m?W , A..4L C( I TING the aM1ove mentioned lab. /.) Clean ntulJ)11 cracks, as required, using asphaltic crack turd joint compound. IJS :.) .411 areas ojpetroleurn saturation shall he homed, scraped - using a steel bristled 2.) S street broom - and coated with O//sPOT prdmer. 3.) The pavement shall be thomiighly cleaned io remove all dirt and debris. 3.) S 4.) Apply one (1) coat tar enni Lion which meets and exceeds all the requirements of ?') S the U.S. Air Force FAA and the Federal Government specification RP-35SE (GSA-FSS). In acconlarce with rnanu act is specifications, die finishing coating s n represent a coverage rate of quare feet which will require a total (I f gallons jar a one coat app icatrmr. s I !ll??? I? .) lbs. ojSilica san raerS added per gallon of material. ? (-' 4 Cy u 1 A Approximate total square jee r: S ADDITIONrU. WORK TO DG PERFORMED? I /? n We pas to Mplete the share work In accordance with the above spec1`lcatlons, for the ium of: 1?, /?/ I%\y??7-- 77 " ` v l o l 10 Inv L J„(t? ?s __ Payment Terms: Pinment to be node in cash upon completion o work untess otherlrise stated below. PIOY tan M.NN111101 /IYt ---d N maCla 1e w'm1]nwluy.mRyI UNI ?bal lJ,rat?. Nel,aalip(,IIa,1N,nlYlbt In llN f[n{IMRINIII n(IrN maaW rYl a(gb0y)n o(Nily Ally gtff la d[YLPMIadn aVYenM1rI0M YIJINe CYp. Pwb abQQVlm.y?Y YP OMAm.Wwa1 \•nNN C1tl.aWeY.rvp YYt.hF<aIf PNNIt Aa.pmMlb WlOrypl11Q1911t1r0,Yrytplb. aY ?.)1 t!n'p1Q Mf Vl11tlN Ih,1K l Ony filR IimuN. eN Mt1Q n®uYY - U? \ t J, ?, \ I.r A th i dSl t / u or ze Rna ure: Date: (Noce: This pmposa mat, he miltdraa,r ifnot acce ned rithin AcceptanceofEstimate: swNN.r UramnnrYre ._ wlYw.nwhtlMM4MwrYUt wMM NwYr.I.rW tiwre...n tut, tn<..r.e ib MtNFY1MNwrMY ?M,.,^?(H?QR? rRe?a rn.,.wM.w.. { (, r'o_k. IYn,t1wIMI. 4([ • ISIgnature: Date of Acceptance: rt r I i . ,?1 n ) r, `/„ v) ??;,;?.''?; s?j, 7a,f';I ???` ¢?14' ? +?. NUi INC. LANDSCAPE SERVICES 515 Yocumtown Road Etters, Pennsylvania 17319 (717) 938.1113 • (717) 938.2154 FAX Mr. Tim Goril 9 Forge Road Boiling Springs, PA 17007 (717) 249-6122 PROPOSAL Remove Existing Patio: Break out and haul away debris $ 1,800.00 ** Install New Stampcrete Patio: - Ashlar slate pattern - Silver gray color with charcoal release (for grout lines and stone texture) - Medium sheen sealer (2 coats) S 5,600.00 ** **Notes: - Customer agrees to obtain any required permits. - This price is good through September 15, 1999. Terms: One third down on approval of work. One third due at beginning of work. One third due on completion of work. Signature: Date: Kaminek Nursery, Tnc. Signature: Customer Date: PLEASE RETURN ORIGINAL SIGNED PROPOSAL WIT11 YOUR DOONFAYAIENT. THANK YOU. F ) r ? 4 s fisa 0; 3:) i TO A PROOF,OF.SERVICE.'OF NOTLCELRF_.APPEA? AND RULE-TO-Wi -'(This pmol of service MUST BE FILED 1?TH1N TE (10) DAYS AAT R filing the notice of appeal. w 1 ,. .&I •,al,u I14.1vo ' it „0:1,:4ri t,'1: nrl"." Plain A:. •. •• ., r,tt 1 .1 r, J :c••, Al l1,31-tic 11 ? : - -- .- COMMONWEALT OFPENNSVLVANIA, ;:, rb,;'Nri rAA v v; ,ud+yu , ) n}iuI o"li rl ••H1 t'1 '1 •v •.r„ ns,lw $I COUNTY OF "'r''1 ` •` %l% Ti`1s?ri nJ,i/yrtprl gib! ;r,ii .4. 1 3:11?"Ilk VAill IVRb ? . '. AFFIDAVIT: I hereby swear or affirm that I carved F w^-- -' y1yVAgem4c 1 $,%.;/ i .. / ? U'/-_ ?copFot ?o i of Appeal, Commo, as No: /J `-W ?ubon the•Dist -Justlea-di -01 (date ofservlee) t ' u1/.pTVlt?cyl 3 I311% nJq &-IT. tly? tel .• ? •1 .. .. .. 1?,M. ... ?.r 4 •\ Q..r1 w 1 • +?'^' A1.A n..1' ..t s.'Thn .a:e . 19+-_F_U by •eand further that I served the Rule;tp Fi or t, whom the Rule 'was addresi.0.gl) ((a,:.:,11 mail, sender'trecelpt attached hereto. )OFIRMED) ANO BSChIB D BEFOfi 0,4 _ DAY O F , ,19 firle of alliel?l 1'• r81afICh1 ^ .?' Han My commission expire o- e 014 1141 of r vy V. Asa) .. Id, Il,w baltl?r. 17 i \ ly4 to e?npts xa?9?a?zA?'i '` I f4?r„ :!(r.'' IQr ti ?t"I N! ^•i r11' •, ,..._.^...___ ... nr: 1-•J' 1 nCl .rl .(3Q t II?RG(!) SyMfun o/al/ianf ti i7 -:.IIUFI :J)•/r.l.1J 1?qI 1a,r.n \j .lam .. '?•?IwGi;?•C_ ?l?) , '.,•'.a•, c.h_:.., .. .. ?,. ''l•' .. :.i? :rt.•?4: •,?ti 4^•T 13:5 ::T. U0 .,a-, v w... J?p...,,. i•lL V,.M• .:'t./ f;-K- . 0•'lr ..- I- , .1 ... . . ,. .•. ..-. , . r 1 COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM ?0/11'19q CUMk % ?IST&t9VNTY DISTRICT JUSTICE JUDGMENT PENNSYLVANIA COMMON PLEAS No. 9 ?- 6-11 7 C'...a NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned b ., eld?v. ' .e a.......•e•ALLCRETE DE GNS C/o TIM YOHE -•? O1J ~?ew aan wK. DB e Y 126 Spring Rd, _DiM9jLmEg, PA 17019 swv ew rvesras• a twe awu e....n... >..+... -La f.,IOO Tlm ?an11 rP0134 r: muche u..w.ew.NNI•••HA a NICOPP P.C. CV 18 •_0000209 9?.. r?UH UaA Byi9 400R9:= This block will be signed ONLY when this notation it required ur^r Pa. If appellant was C/aimantM7see?Pa „R.C.P.J.P, R.C.P.J.P. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as No. 1001161 in actiod •befo" I Diltii t`+Justrce,:he'• a SUPERSEDERS to the judgment for possession In this case. MUST. FILE A,.COMe A1M1Sl(` nN 42PJ,c- days alter filing his NOTICE of APPEAL; 1 Spn run ofimraonoury or Deputy ."' ^•? 'few+adl ::;•T Ni; riUl'-lj ,:,:.PRA (This section of form to beltised Of lF NOT USED detach I fqM copy of PRAECIPE To Prothonotary Enferruleupon ^'Tim+an 1178 ton Pleas No Nama of appellrebl within twenty (20) days RULE: To Tim and Toni Goril Nama of appelleehl t! tl leefsh?to?'tl lon?be%, District Justice. tri compldht'I this appeal y of judgment of non pros. ;COPY-1,07' L 'y X. (1) Yoy% NUligd )hat a rule is hereby entered upon you to file a complaint in'this a004 after the d0I& service 6hk1y,lule upon you by personal service or by certified or registereq 2) if you do not file arcq YOU ON PRAECIPE; (?3) The fate ok.jeryice of Date: n RULEJO. FILE COF4LAINT'AN(D-PULE TO, lant was DEFENDANT, fsee Pa. R.C.PJ.P. No. 1001171 inra to ye carved upon appellee! ' ?" ?. J< -'-sue plaint within this time, a JUDGMENT OF NON PROS WILYeV,Ab(JERED AGAINST gs rule it service was by mail is the date of mailing. S gnatureo/Prothonofaryoror Dkuy White .... 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QL Jll co IM 111 LaPI• „w"w np L4 pin Idwoa SMOCIV NUnL39 moA q *"AMS ldpoW wnMU Ow.n pj noA 4UKLL 1013 J ?C = Q UO LTE9-66 'OD _ 6 - a b >!96 is .r¦ 9= Cv}1 ` ?? All O of vx tope • n.u.y1 uo Pq dwoa gg3?p'pg?g xwA q 5 i r ? W ~ r ; _ ; , . H m i5 A ? TIM AND TONI GORIL, Plaintiffs V. ALLCRETE DESIGN and TIM YORE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999 - 6317 (CIVIL) CIVIL ACTION - LAW TO: Plaintiffs YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED NEW MATTER WITHIN TWENTY 0) DAYS F OM THE DATE OF SERVICE ERE6 A DEFAULT JUDGMENT MA ENTERED AGAINST YOUI FOR ANSWER TO COMPLAINT 1. Admitted. 2. The averment of Paragraph 2 is partially admitted and partially denied. The identity of the Defendant, Allcrete Design, is admitted. To the contrary, however, the principal place of the operation of the business is at 2018 Berryhill Street, Harrisburg, Dauphin County, Pennsylvania, and not at 126 Spring Road, Dillsburg, York County, Pennsylvania, as set forth in the Complaint. 3. Admitted. 4. Admitted. 5. The averments of Paragraph 5 are denied. To the contrary, the terms and conditions of the contract are as set forth in the proposal dated August 31, 1998 as reflected in Exhibit "A" attached to the Complaint. By way of further pleading, there was never a representation work would be completed to the None hundred percent satisfaction of the plaintiff" as such a standard would be impossible to meet, especially in dealing with concrete work. 6. The averment of Paragraph 6 represents a conclusion I of law or fact to which a response is not required. If it is later judicially determined that a response should have been filed, the averments are specifically denied. 7. Admitted. 8. The averments of Paragraph 8 are denied. To the contrary, it was neither obvious that the workmanship or materials utilized by the Defendants were defective; improperly installed or installed with improper or inadequate workmanship or skill. To the contrary, the only complaint received was a "spotting" of the concrete work and had nothing to do with the integrity of the concrete work performed at Plaintiffs, home. 9. The averments of Paragraph 9 are admitted. By way of further pleading, Plaintiffs informed Defendant of a spotting problem, to which problem the Defendants agents responded they would review the complaint. 10. The averments of Paragraph 10 are partially admitted and partially denied. It is admitted that the Defendant received a complaint regarding "spotting" of the concrete and indicated once the weather became more favorable, the complaint would be investigated and an adjustment, if possible, would be attempted to be made. To the contrary, however, at no time did the Defendant reiterate any representation that workmanship and materials would be "one hundred percent to the satisfaction of the plaintiffs". 3 11. The averments of Paragraph 11 are partially admitted and partially denied. It is admitted that in May and June, 1999, the Defendant, on several occasions, attempted to adjust the "spotting" problem. To the contrary, however, it is denied that there were any defects in the workmanship and/or materials involved in the job. 12. The averments of Paragraph 12 are denied as stated. To the contrary, Defendants did, on several occasions, make attempts to adjust the "spotting" of the concrete used in the job. The "spotting" problem was adjusted as best as it could be addressed short of completely breaking out all of the concrete and replacing the same. it is denied that the "spotting" of the concrete represented a defect in workmanship and/or materials. 13. The averments of Paragraph 13 are partially admitted and partially denied. It is admitted that in June, 1999, the Defendant's agents informed the Plaintiffs that the Defendants have taken every action they could reasonably make to adjust and eliminate the "spotting" situation to an acceptable commercial standard. As a result of reaching a commercially acceptable standard, it is admitted the Defendant admitted 4 that it would not take any further steps to adjust the situation. 14. The averments of Paragraph 14 are partially admitted and partially denied. It is admitted that the Defendants used various chemicals to adjust the "spotting" cccurring in the concrete. To the contrary, however, it is denied that any of the chemicals used on the Plaintiffs' property caused damage to the Plaintiffs' driveway. 15. The averments of Paragraph 15 are partially admitted and partially denied. It is admitted that the Defendant refused to repair and/or correct the damage to Plaintiffs' driveway as it was of the opinion that it was not the Defendant's actions which caused the damage to the driveway but, instead, those of the Plaintiffs' use of various chemicals on the asphalt driveway unrelated to the patio work performed by the Defendants. It is further denied that Exhibit "B" represents an estimate to repair the alleged damage caused by Defendants' actions. Exhibit "B" represents an entire cleaning of the driveway, applying sealer and filler throughout the entire driveway and resealing of the entire driveway, none of which Defendant is not responsible to pay. 5 16. The averments of Paragraph 16 are denied. To the contrary, the Defendant never refused to honor the written warranty contained in Exhibit "A" and attempted and did adjust the "spotting" of the concrete to a commercially acceptable standard. The balance of the averment is denied as to the Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained therein and strict proof thereof, if relevant, is demanded at the time of trial. 17. The averment of Paragraph 17 represents a legal conclusion to which a response is not required. If it is later judicially determined a response should have been filed, the averments are specifically denied. 18. The averment of Paragraph 18 represents a legal conclusion to which a response is not required. if it is later judicially determined a response should have been filed, the averments are specifically denied. 19. The averment of Paragraph 19 represents a legal conclusion to which a response is not required. if it is 6 later judicially determined a response should have been filed, the averments are specifically denied. WHEREFORE, Defendants demand judgment in favor of the Defendants and against the Plaintiffs, together with costs. COUNT I - NEGLIGENCE 20. The averments of Paragraphs 1 through 19 of the Answer are incorporated herein by reference as if more fully set forth herein. 21. The averment of Paragraph 21 represents a conclusion of law or fact to which a response is not required. If it is later judicially determined a response should have been filed, the averments are specifically denied as the workmanship and the installation of the concrete patio and the materials used in the concrete patio were of a good and acceptable quality and the workmanship and materials are those that are generally used in the contracting community in Cumberland County, Pennsylvania. ;.r. 7 22. The averment of Paragraph 22 represents a conclusion of law or fact to which a response is not required. If it is later judicially determined a response should have been filed, the averments are specifically denied. 23. The averment of Paragraph 23 represents a conclusion of law or fact to which a response is not required. If it is later judicially determined a response should have been filed, the averments are specifically denied. WHEREFORE, Defendants demand judgment in favor of the Defendants and against the Plaintiffs, together with costs. NEW MATTER 24. The averments of Paragraphs 1 through 23 of the Answer are incorporated herein by reference as if more fully set forth herein. 25. Any allegations regarding representations made by Defendant's agent of "one hundred percent personal satisfaction" are precluded by the Parole Evidence Rule as e there is a written agreement which within its four corners clearly sets forth the understanding of the parties. 26. Plaintiff reported spotting to the Defendantes agents approximately three (3) months after completion of the job. 27. The spotting was located in an isolated section of the patio. 28. The spotting was of such a nature that it attacked and penetrated the sealer placed upon the concrete. 29. Spotting and penetration of the sealer can be experienced if certain chemicals or foreign materials are allowed to come into contact with the sealer as a result of a spill or splash. 30. The spotting which developed on the patio had a distinct pattern and was isolated such as would be left by a spill or splash. 31. Defendant's agents made a good faith effort to adjust the complaints of the Plaintiffs and adjusted the complaint to an acceptable commercial standard which is all that is required under the law. 32. As concerns the damage to the asphalt driveway, Defendants have been observed using chemical solvents on the driveway to clean the wheels of their automobile. 33. Solvents, such as those used to clean the wheels of an automobile and/or gasoline and petroleum products, will attack the integrity of an asphalt driveway. 34. The chemicals used by the Defendant in attempting to adjust the spotting occurring on the patio are not the type of chemicals which attack the integrity of asphalt. 35. Defendant is of the opinion and therefore avers nothing it did at or near the job site could or did cause the damage alleged to have been incurred on the Plaintiffs, driveway. 10 36. The bid attached to the Complaint for the repair of the driveway includes work not related to repairs but, instead, maintenance which is not related to Plaintiffs' cause of action. 37. Plaintiffs, Complaint fails to set forth a cause of action upon which relief can be granted based upon the Parole Evidence Rule. WHEREFORE, Defendants demand judgment in favor of the Defendants and against the Plaintiffs, together with costs. ted, COFF, P.C. Date:November 30. 1999 H 2320 North Second Street P. 0. Sox 60457 Harrisburg, PA 3.7106-0457 Telephone: (717) 238-6570 (Attorneys for Defendant) 11 VBRIBICATION I, TIMOTHY L. YORE, verify that the statements made in the foregoing ANSWER TO COMPLAINT TOGETHER WITH NSW MATTER are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 54904, relating to unsworn falsification to authorities. Date: ?? 4 TIM AND TONI GORIL, Plaintiffs V. ALLCRETE DESIGN and TIM YORE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999 - 6317 (CIVIL) CIVIL ACTION - LAW CERTIFICATE OF SERVICE I do hereby state that I served a true and correct copy of the Answer to Complaint, together with Ilew Matter in the above captioned matter, by United States mail, first-class, postage prepaid, certified mail, return receipt requested, in Harrisburg, Pennsylvania, on November 29, 1999, addressed to: Richard P. Mislitsky, Esquire Saidis, Shuff & Masland 26 West High Street Carlisle, PA 17013 (Attorneys for Plaintiffs) Respectfully submitted, , P. C. Date: November 29. 1999 By: Jordan/,Z. Cunningham, Esqu I.D. #23144 2320 North Second Street P. O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 (Attorneys for Defendants) TIM AND TONI GORIL, HUSBAND AND WIFE 9 FORGE ROAD BOILING SPRINGS,PA 17007 PLAINTIFFS V. ALLCRETE DESIGNS AND TIM YOHE 126 SPRING ROAD DILLSBURG, PA 17019 DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6317 CIVIL TERM CIVIL ACTION - LAW REPLY OF PLAINTIFFS TO DEFENDANTS NEW MATTER And now, comes the Plaintiffs by and through counsel and responds to Defendants' New Matter as follows: 24. No response required. 25. The averments contained in paragraph 25 are SAIDISe SHUFF & MASLAND ATT?NEYPATtlAW 26 W. FIISh Sired Whit, PA conclusions of law which require no responsive pleading. By way of further answer, Tim Yohe stated before the job was started that he would complete the job "to our satisfaction" and "we would be very pleased with the finished product." After the spotting occurred, he said he would come back and "make the job right to our satisfaction." It was only after several unsuccessful attempts to correct the problem that he stated he would not and could not correct the spotting. He stated he could not correct it and was no longer able to afford to correct it. 26-30. Denied in part, admitted in part. it is admitted that the spotting occurred within three (3) months after the completion of the job. The remaining averments are denied. By way of further answer, spotting appears over the entire surface of the patio. 31. Denied. While Defendants did attempt to correct the problem it is denied that the attempts were successful and the end product is not an acceptable commercial standard. 32-33. Denied. The section of the driveway in question is at the precise location where Defendants' workers spilled chemicals and, in addition, washed their hands with gasoline. 34. Denied. Plaintiffs do not contend that the chemicals used by the Defendants caused the damage to the asphalt. To the contrary, the damage was caused by employees who spilled other chemicals and used gasoline while cleaning. 35. No responsive pleading is required. 36. Denied. The attachment to the Plaintiffs' Complaint SAIDIS, SHUFF & MASLAND AT'rORNEMAMAW_ 26 W. 111911 Stred Carlisle. PA speaks for itself. 37. Denied. No responsive pleading is required. SAID ,GH MA LAND e,51 ?5ro (M , Ric and P. Mislitsky, Esquire Attorney I.D. No.: 28123 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiffs CERTIFICATE OF SERVICE On this day of , 2000, I, Sallie Osman, hereby certify tha I served a true and correct copy of the foregoing Reply to New Matter upon counsel for all parties of record via United States Mail, postage prepaid, addressed as follows: Jordan D. Cunningham, Esquire 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 SAIDIS, SHUFF & MASLAND SAIDIS, SHUFF & MASLAND ATfORHM-AMAW 26 W. 111gh life" Grlhle, PA . ..t}lam );y?M '1 eP? . t ?ik r M1 " c k '' f e ? K. ,r n? _ _ ,+, ?: ? + F ..?_ ". `<x +i b t? , - ? . , ' y <, ? aa;?? ,,•,?. x• . rh , tr. ?? ? t Fa t .f w y, ? ?b ? +. A? ++ . T j s?Y? , ?; 1. Q ? N ? r )x? r .? ? at )C? ?.. f 1?? r.M+ 4 } LL `,? r K?, r1}I:T ??? N?. . ? 1 +I+l? ? ? Ci.?.' U . IL7 p.. .:;???. U. t,1 t?J ? ? ? ??? 5 fi ;' ta. y .,?. iii ?.. '. ? 3r; ? ?, ?i.?.. 'r?zrs `:}t.. v + T .. ??,:.. 'e i nr: .y - -.. w.r r J LAWOFl'ICBS. CERTIFlfiDCOPS i, SNUFF do bfA$GAND Rear :1inMeaRCrstnPr ;,. .:r:<= 17011 CAMP HILL, PA 17011 4))7 PHONE 4717) 737.3403 TIM AND TONI GORIL, HUSBAND AND WIFE PLAINTIFFS V. ALLCRETE DESIGNS AND TIM YOHE, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6317 CIVIL TERM CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY Please enter my appearance on behalf of the Plaintiffs, Tim and Toni Goril in the above-captioned matter. Respectfully submitted, SAIDIS, SNUFF & MASLAND Date -?l ?u r?/? ?? J eph L. Hitc)Lings, Esquire Attorney I.D. No.: 65551 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiffs SAIDIS, SHUFF & MASLAND MiORNIMATNAW 26 W. High Sired Carlisle, PA ERTIFICATE SERVICE qi C AA9- On this C7 day of 2092, I, hereby certify that I served a true and correct copy of the foregoing Entry of Appearance upon all parties of record via United States Mail, postage prepaid, addressed as follows: Jordan D. Cunningham, Esquire CUNNINGHAM & CHERNICOFF 2320 North Second Street Harrisburg, PA 17110 SAIDIS, SHUFF & MASLAND .,.JrAL ) Wo SAIDIS, SHUFF & MASLAND ATMAM-ATNAW 26 W. HI6h 6lreel Grllele. PA _. ?? ti ?.?, ? ? ?,?? N ?: ? ? h- p ?? O , f ?:v . ..... _ . .? rnc. a.-r.-:: a.Y?