HomeMy WebLinkAbout07-6280n
PETER & KAREN COLLINS, : IN THE COURT OF COMMON PLEAS
Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
? a gd
OLYMPIC REALTY & : NO. 07- CIVIL TERM
DEVELOPMENT CORPORATION :
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served, by entering a written appearance personally or by attorney and filing in
writing with 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 of 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.
Cumberland County Bar Association
32 Bedford Street
Carlisle, PA 17013
(717) 249-3166
i
PETER & KAREN COLLINS, : IN THE COURT OF COMMON PLEAS
Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
OLYMPIC REALTY & : NO. 07- 6- CIVIL TERM
DEVELOPMENT CORPORATION :
Defendant
COMPLAINT
1. Plaintiffs are Peter and Karen Collins ("The Collinses"), who reside at 34 Linn Drive,
i
Carlisle, Pennsylvania, 17013.
I ?
2. Defendant is Olympic Realty & Development Corporation ("Olympic"), the principal
place of business of which is 424 East 52nd Street, Suite 1 B, New York, New York,
10022.
3. On June 8, 2000, the Plaintiffs entered into a contract with the Defendant, a copy if
which is attached (Exhibit A).
4. The specifications of the June 8, 2000 contract at issue are as follows:
a. The property that is the subject of the contract is located at 34 Linn Drive,
Carlisle, Pennsylvania, 17013, which Defendant needed to utilize and improve in
order to develop the Home Depot, located at 1013 South Hanover Street, Carlisle,
Pennsylvania, 17013.
b. The granting to Olympic a temporary construction easement as set forth in
Exhibits A and B of said contract. (Exhibit A).
c. The Collinses agree to execute any other documents as reasonably requested by
Olympic.
d. The Collinses agree to convey to the Pennsylvania Department of
Transportation a right-of-way easement in the form set forth in Exhibit C of the
contract, and a release in the form of Exhibit D of the contract (Exhibit A).
e. In consideration of granting the right-of-way and grading easements, Olympic
agrees to construct vegetative screening as set forth in Exhibit E of the contract;
arrange for the removal of a dying tree on the Collinses property, of the Collins'
choosing, with the Collinses retaining the right to keep any wood from said tree;
and pay the Collinses the sum of five thousand dollars ($5,000.00) (Exhibit A).
f. The Collinses agree to, upon request, sign any and all necessary governmental
permits of subdivision/land development plans required; sign any and all
temporary construction easments or grading easements; and sign any and all
rights-of-way easements and release forms in connection with the transaction
(Exhibit A).
5. The Collinses have provided all signatures needed for the completion of their part of
bargain.
b. To date, Olympic has paid the Collinses five thousand ($5,000.00) as set forth on
Paragraph 3A of the contract (Exhibit A).
7. In breach of the contract, Olympic has to date failed to construct in the area of the
grading easement vegetative groundcover in accordance with the landscaping plan in
Exhibit E of the contract, as set forth in Paragraph 3B of the contract (Exhibit A).
8. In breach of the contract, Olympic has failed to arrange for the removal of a dying tree
of the Collinses choosing from the Collinses' property as set forth in Paragraph 3C of the
contract (Exhibit A).
9. Completion of the work contemplated in Paragraph 3B of the contract would cost an
estimated eight thousand five hundred dollars ($8,500.00).
10. Completion of the work contemplated in Paragraph 3C of the contract would cost an
estimated one thousand five hundred ten dollars ($1,510.00).
11. The anticiated cost to finish any and all work not yet completed by Olympic under the
contract is less than fifty thousand dollars ($50,000.00).
WHEREFORE, the Plaintiffs, Peter and Karen Collins, asks for a judgment in their favor
against the Defendant, & Olympic Realty & Development Corporation, in a sum not to
fifty thousand dollars ($50,000).
Respectfully Submitted,
w s D 4t"'? 40' • -
Date Michael M. Jeromins Esquire
Turo Law Offices
28 South Pitt Street
Carlisle, PA 17013
Supreme Court I.D. No. 92977
(717) 245-9688
Olympicl l OEasementAgmt
? y0
Afi$EIMi? Jk_ THIS AGREEMENT made this Q day of A t- , 2000, between Peter
Collins and Karen E. Collins Collins mberland
(Collectively, ) ofCu County, Pennsylvania
AND
Olympic Realty & Development Corporation (Olympic) of New York, New York.
WITNESSETH
WHEREAS, Collins is the owner of real estate located within the Borough of Carlisle as noted
in deed recorded at the Cumberland County Recorder of Deeds office at Deed Book 166, Page
808, and located at 34 Linn Drive, Carlisle, Pennsylvania (hereinafter referred to as "Collins
Property"); and
WHEREAS, Olympic is in the process of developing a commercial Home Depot development
on real estate across Pennsylvania Route 34 from the Collins Property (hereinafter referred to as
the "Home Depot Project'); and
WHEREAS, in conjunction with the Home Depot Project, Olympic must perform certain
roadway improvements on Pennsylvania Route 34 which is immediately adjacent to the Collins
Property on the eastern side; and
WHEREAS, the original roadway improvements contemplated for the Home Depot Project
included the construction of a retaining wall immediately adjacent to the Collins Property; and
WHEREAS, in order to eliminate the retaining wall, Collins is willing to convey a right-of-way
and grading easements so that the roadway modifications at Pennsylvania Route 34 adjacent to
the Collins Property can be accomplished without the-construction of a retaining wall; and
WHEREAS, in consideration for Collins conveyance of the mentioned right-of-way and grading
easements, Olympic has agreed to perform various work as set forth herein; and
WHEREAS, the parties have reached an agreement in this matter and desire to set forth herein
the terms of that agreement.
NOW, THEREFORE, the parties hereto intending to be legally bound hereby agree as follows:
EXHIBIT
A
{
a
Collins hereby conveys to Olympic, or Olympic's assigns at the sole discretion of Olympic, a
temporary construction grading easement as set forth on the attached Exhibit "A" and the
attached Exhibit "B". The grading easement shall be for the exclusive use of Olympic and its
tenants, successors and assigns in connection with the Home Depot Project and, at Olympic's
option, may be assigned to Home Depot, U.S.A., Inc., the Borough of Carlisle (Carlisle) or the
Pennsylvania Department of Transportation (PennDOT), as necessary. In connection with this
conveyance, Collins agrees to execute any other docutnPnts as reasonably requested by Olympic,
Carlisle or PennDOT to confirm this conveyance of the grading easement.
2
Collins hereby agrees to convey a right-of-way easement to PennDOT in the form set forth in
Exhibit "C'' for the area shown on Exhibits "A" and "B" and a release to PennDOT in the form
set forth in Exhibit "D".
3
In consideration of Collins conveyance of the right-of=way and grading easements, Olympic
agrees to the following:
A. Olympic will construct in the area of the grading easement vegetative screening in
accordance with the landscaping plan as attached hereto and marked Exhibit "E".
B. Olympic will, in conjunction with construction of the Home Depot Project,
arrange for removal of an existing dead tree on the Collins Property as designated
by Collins. At Collins option, Collins may retain the wood from said tree. The
removal of the tree by Qlyrnpie shall not include removal of the stump, vvhlch
shall be the sole responsibility of Collins.
C. Olympic will make a cash payment to Collins in the amount of FIVE
THOUSAivu DOLLARS ($5,000.00) which wiii represent payment to Collins for
care require to ensure maintenance of the vegetation as set forth in Paragraph 3A
above. This payment shall be made upon Collins signing all documents as
required by this Agreement and shall be made pursuant to the timetable as set
forth in Paragraph 6 below.
f_? C) 4 e3 3u'J;ti u,,) a. rALE on,)
.
4
?n additio: tV the AYIJVcyailcv of the light-ol wdy wid grading easements, Collins agrees as
follows:
A. Promptly upon request, sign any and all necessary governmental permits of
subdivision/land development plans that would be required in connection with
this transaction.
B. Promptly upon rmiie.Ct Q'arn nnv ntbo-r tpmnnr%mr nnne+1nvr.+;^- o.,?,......?.
L --d -.r - 7"'---y -!Cr- -'.I ••a.av. wsaajrvaauJ wuou uvHVll 1.0%,1 1,11W V1
grading easements to make the necessary or intended improvements as
c^nte::p1atK? :;r Pi,ij;lsyivailia Route 3 + cold as set lor[ll on [Ile attached V-xtubit
C. Promptly upon request, sign any and all necessary rights-of-way easements and
release forms to the PennDOT.
5
At the option of Olympic, this Agreement may be recorded in the Cumberland County Recorder
of Deed-, Offine and as C11rIk Cull ant no raao+rr n+:?n -n +I,- (? .?1:... D-...w.. -1 1_11 • t
.+ aa.a 4 lt.J l11 V11V/1 WAX UL%1 11V111113 1 L%Jp%,Lty aLLU Jlldll 1U11 WILn
the land and shall be binding upon the executors, heirs, beneficiaries, successors in title and
assigns GL k-GMIII).
6
The obligations of the parties pursuant to this Agreement shall be come effective and operative
upon Olympic obtaining final unappealable approval of the Home Depot Project as a rnmmPrninl
center, acquiring the Home Depot Tract, and the recording of a subdivision/land development
plan in conjunction with the Home T)Pnnt Prmi-M
Upon vly-unpic's ac:.quisiiion of the Home Depot T race and the recording of the subdivision/land
development plan for the Home Depot Project, Collins and Olympic agree that this document
may be construed as a de facto conveyance of the grading easement from Collins to Olympic, or
Olympic's assigns. Notwithstanding, Collins agrees to execute any and all documents at time of
recording of the mentioned subdivision/land development plan in order to consummate the
conveyance of the grading easement and performance of the mvidwny imnrnvpmant ; ,-A,
shown on attached Exhibit LB" and the right-of-way form and release form as set forth in
Rxhihitq "tC" nnd "°r)"
8
This Agreement shall be binding upon and inure to the benefit of the parties, their heirs,
v vvu°v afira viuicw, sU??cssVls LlI LLUG a.iLU ri551g11J.
y
By execution ent, Collins hereby grants 01 successors and assigns an
irrevocable limited power of attorney o alf of Collins, anv and all agreement. ?nd
documents reasonably M.1=1inq e teyeP.ntpt tuate t he inent o es as set forth in this
Agreement in the itq t(1 gnm. nrnr"nt1v ,wnnn ron,iact t prn
iN WITN c Wi•7Ti?1?nV ..,, t ._ ..._._ __.3_ , _ t
tenC. V"- l t,.,tavV IIVLVUIILV set Viu L11AllUb ar1U sCdIS ule uay and year first
above written.
Witness
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Attest
Peter Collins
4?' (
Karen E. Collins
Olvmaic Realty & Development Corporation,
ley.
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On this, the Q, -- day of `j, kA/ o _ 2000, before me a Notary Public, the
undersigned officer, personally appeared Peter Collins and Karen E. Collins. known to me (nr
satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and
acknowledged that they executed the same for the niirnnCP thj- ;n nnnt?innr?
TN WiTNFRC WNRRRn>~ r -_.S _ ---,I
L1..l bualLV a&4 LLLY IUU1 1/wM? IU LLULi ILU 5VUL.
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Notarial Seal f
Bridttet Ann Corcoran. Notary Puhlir. s.??....1
Caaisle Boro, Cumberland trouniy Notary Plolic
My Commission Expires June 10, 2002
Commonwealth of Pennsylvania
ss
t/LL UUb LIM v uay U LUUU, before me, a notary public in and for the County
of Cumberland, Commonwealth of Pennsylvania, the undersigned office, personally appeared
David j. Schwartz, who acknowledged himself to be President of Olympic Realty & -
Development Corporation, •`'
and that he being authorized to do so executed the fores?oin?_°'?,? instrument for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal. `.y
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Notanai 5eaj LjQJ Lkl(-/-
Bridget Ann Corcoran, Notary Public
Carlisle Bom Cumberland county ^^ Voary Pu iC
my Vommission i=xpires Ju+1& 0, e-uu?
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PB.AFOSED GRADWG EASENE T
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All ckw ewtain awiioa of a m= of land situate is the Boraab of Carlisle, C.ambaeind
Coum. Pea:uylvsnss. ww or Eme dy of Pater aad Kam E. Coltia, a r carded to ttrC
oft e of the R*co 4w of Doors for Cw d County: PaaDayivsnuk in PW Book "7".
?Wc "29r', wore Wtioutaiy bo[sndad sod dcwto"d as fctilows to wit:
atKiniN1Na a s paint oa tba vioam ripta-af wuy tine of Soucb Nsaovar Sheet; 714M
4kog *0 wwtsro sight-ol wsy line of SGWJI iianow Su+ca Sauh OS daWm 49 was
41 womb Weer 111.12 foal to a po* Thos don& o a wnhem tWa-o$4W Me of
Acre Dnw a? w*pmW Urm North 94 deem 1 I WbUM 00 som& West 22.04 fact
to 4 PWW Tbw acm" lads Ww Or fotmeft of POW aid Xuo F- Ceiba North OS
depivo4 49 ndr?q 02 asoioo>e!s FAR II I.Oi fieot tQ t T'boo the sexslbaa
nVW-c [avsy two of Seoul tbWW &I= Sash 94 dagm 17 wiausw 23 aaooe4s UX
22.00 feet to s point; THE PLACE OF NXM. Ca=kkg 2.444 sgmm Boot.
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and Operations
(Central Fer,.it Off-Lee)
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EVRl NO. (Consequent AGREEMENT. OF RELEASE
Y_,_ n Damages Free easel
EPIrIZTT a
67 l with Code Section 4: 8 Access
(d) U) , (m) and (n
THTs TVnrVTtTvr
owner(s) of property Affected by the construction or improvement of
the above lnentinneA
permit by the -- "''v"' aY Pursuant to the above referenced
permittee, heirs, executors, aeuninistrators, successors
and/or assigns, hereinaftert1%f-he;
-46vUl- v4 plural, called the OWNER,
and
the Commonwealth of Pennsylvania, Department of Transoortation.
hRresi natter -t, .. LL__
..., Ra4G%41e sinqular or plural, called the CommoNWEALTA,
W T ." -
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In consideration of the tna-fi
as a result of the aforesaid construction, theLOWNER4doeseheaDOVe reby OWNER
remise, release, quitclaim s.nd forever discharare rh.. r_n_it_mAmwrer.arv 44-
aged-U-8-4 employees and representatives of and from all suits, damages,
claims and demands of any type arising against it as a result of.arantina
of ±kft C"`•°'•L to Yc=mittes including any claim which the OWNER might
otherwise have been entitled to assert under the provisions of the Eminent
Domain Cnc'e; nct oc ?u;,e 22%, 196'4, P.L. na as amended (26 P.S. 1--101 et.
seq. as amended), for or on account of any injury, destruction or
interference with access f^ the µF..r,._.: s < <
by reason of the aforesaid construction jorrimprovementcunderNthetreferencced
highway occupancy permit.
EX- H--•
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IN WITNESS Ws4roone
W be leisaltY bound tht•nAby. vsswcn has executed Of caused to be executed these presents, intending
VAtrless
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Witness
1
ISEALI
(SEAL!
tsEa L1
{SEAL!
t attest to the Atpnature of the officer who has
?Yl?L]ft+R (hie vw.??__ __
hereof has been duly authorized by thig
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CO?trOAA n, AG 14 t h, Give.ttG
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President
141CAL1
ACCEP CkO on :ehalf of tha COMMONWEALTH:
??•. r?wa..r ici.M:iG 1.1dtK,
CUMMONWEALTH OF PENNSYLVANIA:
COUNTY OF a'
On before me,
tN undersigned Officer, personally ippeared
knnwn rn n n rn? •.•7J?__? •?
w• w u - -kvt u y proven) to be the
person(a) whose name(s) subscribed to
t.7e within instrumenr 3nr4 fPt.nn...re A._J
. ?..........,cvycu u?ai
executed the same.
IN WITNESS WHEREOF, (hare horeunto set
my hand and official seal.
(SEAL)
fllntarv P?.?ri,.
MY Commission Expirtrs:
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF
" io. use 1i? the V Trice for Recording of Oeeds
in and for aforesaid County in Oeedbook
Paas
Witness mY hand and seat of Office on
R"order of Weems
COMMnNWXel Tai ne ae&,a,r..., .
COUNTY OF U:
On , before ,•ne,
1111 ?_n??i?:?n?v °vffltcr, VC1win4lly Appeared
. who acknowledged
himself to be the
QI
a corporation, and that he At such officer, being
authorized to do so, executed the foregoing instrument
v,-, Lcnii; of sale said corporation.
IN WITNFC1wuCacnc
?v• , •?•yc l?areunto set my
hand and official seal.
(SEAL)
Notary Public
My Commission Expires:
I certify that, upon recording, the within instrument
should be meifed to:
uistrict permit !`anarer
Pennsyfvania Department of Transportation
Agent for Commonwealth of Pennsylvania
Ocpartr"ent of Transportation
Boor 6 S, 1 PAGE ? 9 10
1 376'11 -:+
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1 5? 1 . Lac - 1 lTi: ?5 it =.
f A
DEED OF EASEMENT
{NO anetary Cona deratihni
THIS INDENTURE, made this -? day of Ion
b_v
owner(s) of property affected
the above mentioned State Highway Route; underltheoreferencedehighway
occupancy permit,
„___ heirs, executors;
ardu,0r assigns, hereinafter, whether singular orVplural,fcalled$sors
GRANTOR, and the Commonwealth of Pennsylvania, Department of
Trengnnrr-tiW+., ic`cinalter called the COMMONWEALTH,
w T T L, v n n
•1 as G J G 1 11
:
WHEREAS the COMMONWEALTH hx a rana-i _,-,e v:
permittee for iesuan^e of a highway occu anc a.. aFr11caLion trom th
above mentioned state highway; and p Y permit for access to the
WHEREAS the parties hereto have agreed that, as a condition
to i6suann__o AP , _
COMMONW$ALTB an easement forutpermi Pt, theoGRANTOR will Convey to the-imited vertical dimension and a„nh i o,--_.,_.._. g
purposes nated, if an
from the property or portion Tthereof ?requiredab
b' s'
yatheCOMMONWEALTH,
ivuw, THEREFORE, in consideration of the benefits to the
property of the GRANTOR, the GRANTOR does hereby grant and convpj t-n
rh_,? Cn w.m0"^•`,E;:.T ; aii easement for transportation
vertical dimension from that purposes unlimited in
portion of the aforesaid property
designated as rr+n„i.-o_A_ ..• ,...__?
-and made a part hereof; and?thossaareas, ifpany,pdesignated eas require
for other than right-of-wav in the AAcamon*/c1 tA--JLa.Ca_-s plan attached hereto as Exhibit "A" bein a-, °i'°LL1G4 by L`ne plot
conveyed or devised to the GRANTOR $ Portion of the property
blf
r1 or
dated recorded in book
page
together with the improvements, heredi tampnt s and
said easement(s), except those which may have been agreedto4be Lv Li . t ae
retained by the GRANTOR. And the GRANTOR warrants generally the
.",.ere! by
Provided, however that the GRANTOR shall retain the right to
deep mine minerals; ;ncluda,.- ,
ac•?vYQ1 ui gas ana oil by means of wells
located off the right-of-way, from a minimum depth to be determined by
the COM"ONWEALTH.
The GRANTOR does further indemnify the COMMONWEALTH, its
employees, agents and representatives against any claim. demand- or
?udg,adel?t 0i any type made by any lessee or easement holder of the
aforesaid property who is not a permittee under the referenced permit
and who may bb ad=*er? z Offec;t.ed by construction of the improvements
to the demiead premises or in the State highway right of way, pursuant
to the referenced permit-
ff1fT
EX'HUBI T
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IN WITNESS WHERFnc Ts._ P. in
? nruv e u n. HAS =uecuted or caused to be execvted these prt:ser,?
intending to be legally bound thereby,
Vlrtneta '
?:?ins-sat -
Witness
x
(SEAL)
J SEALS
- - (aEp?L3
" tiYitnets
-------------
(SEAS.)
attest to the signature of the officer Whn kne
srcecuied tnisdeed and certify that exccutPon?
heraaf has been duty authorised, by the
v
s0•.
$ Secretary
(SEAL)
sr -
President
INDIVIDUAL(S), ASSOCIATION. CLUB_ etc
COMMONWEALTH OF PENNSYLVANIA;
COUNTY OF
na ,before rna,
the undersigned Officer, perwnally appeared
known to me (or fatisfMorily prorenj to be the
PC114ntit Wnou namejej tubacribad to
the within instrument. and acknowledged that
executed the ss.ns
IN WITNESS WHEREOF. I have herpt,ntr....
my hand and official teal - -- '_
--q-,
Notary Public
MY Cornmission ExDineft:
COMIAOMYEALTH OF IENNSYLVANIA
COUNTY OF ts'
Recorded In the Office for Recording Of pis
in and for aforesaid County in Deedbook
avga
Witness my hand and seal of Office on
prow-nvr(A. - wa'i,Q3
CORPORATION
COMMONWEALTH OF PFW cYt var,itA .
COUNTY OF
R'
On before me.
Me undersigned officer. personally ann.,r.ri
himself to be the . who 4 knorvtedged
of
I eorporation. and that he sc .i,f k :.W:__ #_ -'_ _
avd+Otited to do so. executed the foregoing instrument
on behalf of the said corporation.
IN WITNESS WHEREOF. I have hereunto set my
hand anei MV4.191 =:t
(SEAL)
Notary Public
my '-:Omrnluion Expires;
inst. upon recording, the within instrument
should be -mailed to.
Right-Of-Way Administrator
Pennsylvania Ocpartment of Trancnnrtziinn
Agent for Cammonvvealth of Pennsyivanis
Department of Transportation
`!J?r 8 PACE `?91 P
o? r.odo/ucs F-602
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i Certify this to be recorded
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VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904
relating to unworn falsification to authorities.
v//7/;- 007
Date
1() /1 /acO7
Date
Peter Collins
Karen Collins
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Complaint upon
Olympic Realty & Development Corporation via United States Mail, first class, postage
pre-paid, return receipt, on the -LO' day of 06 ?e/ ,
2007, addressed as follows:
Olympic Realty & Development Corporation
Authorized Agent
424 East 52nd Street
Suite I B
New York, New York 10022
TURO LAW OFFICES
1%44/
Michael M. Jeromins Esquire
Turo Law Offices
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Petitioner
Supreme Court I.D. No. 92977
Cam; ? 'ti'!
--? rrt ":
PETER & KAREN COLLINS, : IN THE COURT OF COMMON PLEAS
Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
OLYMPIC REALTY & : NO. 07- 6280 CIVIL TERM
DEVELOPMENT CORPORATION
Defendant
PRAECIPE
TO THE PROTHONOTARY:
Please settle, withdraw and discontinue the above-captioned matter on behalf of the
Plaintiffs, with prejudice.
Date
Submitted
on Turo, Esquire
8 South Pitt Street
arlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
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