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Home My WebLink About03-6322 BOYER SWIMMING POOLS, INC" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA VS. NO. 03 _//:.J~ Cj(.;~ t-~ CIVIL ACTION - LAW FRANCES D. EVERHART, 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 or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (800) 990-9108 NOTICIA Le han demandado a usted en la corte. Si used quiere defenderse deestas demand as expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda via notificacion. U sted debe presentar una apariencia escrita 0 en persone 0 per abogado y archivar en la corte en forma escrite sus defensas 0 sus objeciones alas demanda en contra de su persona. Sea avisado que si usted no se defieade, lacorte torara medicas y puede entra una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que pedido en la peticion de demanda, Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted, LLEVE EST A DEMANDA A UN ABODAGO IMMEDlA T AMENTE. SI NO TIENE ABOGADO 0 SINO TIENE EL DINERO SUFICIENTE DO P AGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELEPHONO A LA OFlCINA CUYA D1RECCION SE ENCUENTR ESCRITA ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. BOYER SWIMMING POOLS, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA vs, NO. O~ - iP3).).. (],,~'~L 1EA.~ FRANCES D. EVERHART, Defendant CIVIL ACTION - LAW COMPLAINT AND NOW, this~ day of December, 2003, comes the Plaintiff, Boyer Swimming Pools, Inc" by and through its attorney, Shaffer & Engle Law Offices and respectfully avers as follows: I, Boyer Swimming Pools, Inc, is a Pennsylvania corporation with its primary offices located at 183 Moore Street, Millersburg, Dauphin County, Pennsylvania 17061. 2. Mrs. Frances D. Everhart is an adult individual residing at 1417 Brandton Road, Mechanicsburg, Cumberland County, Pennsylvania 17055-6739. 3. Boyer Swimming Pools, Inc, was contracted by the Defendant to provide services to her swimming pool located at her address in Cumberland County between May 23 and October 18, 2002, 4, Such services included the maintenance of the pool, as well as advising Mrs, Everhart on possible solutions for problems that arose with her swimming during that period oftime. 5, As of date, the Defendant has failed to pay for services rendered from May 23 thru October 18, 2002. (See attaehed hereto true and correct copies of invoices marked as Exhibit "A"), 6, The total sum due Boyer Swimming Pools, Inc, by the Defendant is $1,199.22. 7, The Plaintiff respectfully requests that he be granted this amount due plus pre- judgment interest in the amount of 1.5% monthly as agreed by the parties. WHEREFORE, Plaintiff, Boyer Swimming Pools, Inc., respectfully request judgment in the amount aforementioned, Respectfully submitted, SHAFFER & ENGLE LAW OFFICES 0/ ......://...~~~~ ~ef&iy B;rtn;..U9le; Esqui~ .. ID # 76644/. / 129 Market Street/ ~i~~~;t~061 li Attorney for Plaintiff By: ,. . im' Boyer Swimming Pools, Inc. 183 Moore Street . Millersburg, PA 17061 (717) 692-2166 Statement Date 8/19/2003 To: Everhart, Wilson 1417 Brandton Rd Mechanicsburg, Pa 17055-6739 Amount Due Amount Ene. $1,199.22 Date Transaction Amount Balance 04/30/2002 Balance forward 1,099.61 05/01/2002 PMT#1047 '1,099.61 0.00 OS/23/2002 INV #4157 184.44 184.44 06/03/2002 INV #4225 75.23 259.67 06/17/2002 INV #4281 0.00 259.67 06/26/2002 INV #4337 137.08 396.75 07/12/2002 INV#4381 0.00 396.75 08/23/2002 INV #4521 71.68 468.43 09/18/2002 INV #4605 125.40 593.83 10/01/2002 INV #4663 0.00 593.83 1 % 1/2002 INV #4664 302.39 , 896.22 03/19/2003 INV #5029 60.42 956.64 03/19/2003 INV #5030 40.28 996.92 03/19/2003 INV #5031 40.28 1,037.20 03/19/2003 INV #5032 92.69 1,129.89 08/19/2003 INV #2002-133 16.95 1,146.84 08/19/2003 INV #2002-134 17.20 1,164.04 08/19/2003 INV #2002-135 17.46 1,181.50 08/19/2003 INV #2002-136 17.72 1,199.22 Terms FINANCE CHARGE: 1-1/2% PER MONTH ON BALANCE OVER 30 DAYS Amount Due Due on receipt ., utJJlrr ,... rt $1,199.22 . VERIFICATION I verify that the averments in this 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 unsworn \~ Brent E, o~er, President Boyer Swimming Pools, Inc, falsification to authorities. Dated: "/~~/ i~ ( /- BOYER SWIMMING POOLS, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA vs, NO. 03-to'd-~ G\Jlller~ FRANCES D, EVERHART, Defendant CIVIL ACTION - LAW ACCEPTANCE OF SERVICE I Elizabeth J. Goldstein , , counsel for Defendant in the above-captioned case, does hereby acknowledge that she/he accepted service on of a true and correct copy of the Complaint which was filed in the above-captioned action, in accordance with the Pennsylvania Rules of Civil Procedure. Dated: January 6, 2004 ~L//4L.u KEE ER WOOD ALLEN & RAHAL, LLP 210 Walnut Street P.O, Box 11963 Harrisburg, P A 17108-1963 717-255-8000 --. .-... ,..., = ,= -""" <- ::OP :;a::::: N -C: -l_ 9n .-< :1: ","i ~~\ -.cC Qh ::? :T.~ ~.~b ty" 5~ '-:':) (~ _I -~ BOYER SWIMMING POOLS, INC, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 03-6322 CNIL TERM FRANCES D. EVERHART, Defendant CNIL ACTION - LAW NOTICE TO PLEAD TO PLAINTIFF: You are hereby notified to file a written response to the enclosed Answer, New Matter and Counterclaims of Defendant, Frances D. Everhart, within twenty (20) days from service hereof or a judgment may be entered against you. KEEFER WOOD ALLEN & RAHAL, LLP By UJ;; / dLt~ . Elizabeth J, Goldstein, Esquire BOYER SWIMMING POOLS, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 03-6322 CIVIL TERM FRANCES D. EVERHART, Defendant CIVIL ACTION - LAW ANSWER., NEW MATTER AND COUNTERCLAIMS AND NOW, this day of January 2004, comes the Defendant, Frances D. Everhart, by and through her attorney, Keefer Wood Allen & Rahal, LLP, and respectfully answers as follows: I. Admitted. 2, Admitted. 3, Denied, It is admitted that Defendant contracted with Boyer Swimming Pools, Inc. and this contract is related to her swimming pool located at her residence address in Cumberland County. It is specifically denied that Defendant was contracted only for general services for the swimming pool. On the contrary, Defendant specifically contracted with Boyer Swimming Pools, Inc, to provide pool maintenance to resolve a problem that the water in the pool was not clean and clear. Boyer Swimming Pools, Inc, did not solve this problem. 4, Admitted. 5. Denied, It is specifically denied that Defendant owes Boyer Swimming Pools, Inc, any money as a result of the work that Boyer Swimming Pools, Inc. did for the Defendant because Boyer Swimming Pools, Inc, failed to solve the problem with the filtering system. After reasonable investigation, Defendant has no knowledge that Boyer Swimming Pools, Inc. provided any services to Defendant except that Boyer Swimming Pools, Inc, loosened the pool's grout by emitting a charge. This made the pool's problems worse. It is specifically denied that the dates specified on Exhibit "A" represent dates that Boyer Swimming Pools, Inc. provided services to Defendant. It is believed and therefore averred that Boyer Pools, Inc, did not perform any work for Defendant on dates specified in Exhibit "A." 6. Denied. The averments of Paragraph 6 are legal conclusions oflaw to which no response is required. By way of further answer, it is specifically denied that Defendant owes Boyer Swimming Pools, Inc. $1,199.22, On the contrary, Defendant does not owe anything to Boyer Swimming Pools, Inc. as it did not provide any services requested by Defendant. 7. Denied. The averments of Paragraph 7 are conclusions of law to which no response is required. By way of further answer, Defendant did not agree to pay any interest to Boyer Swimming Pools, Inc, WHEREFORE, Defendant, Frances D. Everhart, respectfully requests that judgment be given in her favor and against Boyer Swimming Pools, Inc. NEW MATTER 8, Defendant herein incorporates its answers to Paragraphs 1 through 7 of this Answer as though fully set forth herein. 9, Defendant requested and Boyer Swimming Pools, Inc. agreed to bill Defendant monthly. 10, Defendant requested that Boyer Swimming Pools, Inc. solve the problem that the pool's water was not clean and clear. 11. Boyer Swimming Pools, Inc., via Brent Boyer, told Defendant that he would use a charge to blast out the blockage in the pool's pipes, 12. A person working for Boyer Swimming Pools, Inc. did use a charge to blast the pool's pipes. 13. The charge loosened the pool's grout and further clogged up the intersection of pipes. 14. The charging, thus, made the pool's water even dirtier than prior to the charge, 15. Defendant had to hire another contractor to remove the grout loosened by Boyer Swimming Pools, Inc. 16. The problem was fixed when a contractor put in a new filter. 17. The contractor determined that the filter needed to be replaced because it discovered that the filter, which is made out of sand, had become solid and the water had charmeled a hole through the entire filter thus bypassing the pool's filtration system, 18. Defendant raises the affirmative defense of justification. COUNTERCLAIM COUNT I - BREACH OF CONTRACT 19. Defendant incorporates by reference as though fully set forth herein Paragraphs 1 through 18 ofthe Answer as though fully set forth herein, 20. Defendant was damaged by Plaintiff's failure to resolve the pool's filter problem, 21, The damages include the fees paid to other contractors to resolve these problems. 22, Because of Plaintiffs failure to resolve the water problem, Plaintiff did not have full enjoyment of her swimming pool in 2002, WHEREFORE, Defendant requests that the Court issue a judgment in amount less than the amount required for a mandatory arbitration in Cumberland County against Plaintiff and in favor of Defendant. COUNT II - UNFAIR TRADE PRACTICES AC 73 Pa. C.S.A. 201-1. ET SEO, 23, The Defendant incorporates Paragraphs I through 22 of the Answer as though fully set forth herein. 24. Boyer Swimming Pools, Inc. engaged in unfair and deceptive practice by: (a) Failing to bill the Defendant on a monthly basis; (b) Failing to leave at Defendant's residence any written notice contemporaneous with any service provided by it; (c) Providing invoices which fail to identify the date and a description of the work which was performed, 25. The practices listed in Paragraph 24 ofthis Answer provide the consumer with no way to verify if Boyer Swimming Pools, Inc, actually performed the work on the invoice. 26. Defendant is entitled to treble damages and attorney's fees. WHEREFORE, Defendant respectfully requests that the Court issue judgment in its favor in an amount less than the mandatory amount for arbitration and against Boyer Swimming Pools, Inc, KEEFER WOOD ALLEN & RAHAL, LLP Dated: January 2L-, 2004 By ~/~' Elizabeth J, Goldstein, Esquire Attorney ill # 73779 415 Fallowfield Road, Suite 301 Camp Hill, PA 17011 (717) 612-5803 Attorneys for Defendant VERIFICATION I, FRANCES D. EVERHART, the undersigned, acknowledge that: 1, I am an adult individual and the Defendant herein; 2. The averments/responses set forth in the foregoing Answer, New Matter and Counterclaim are true and correct to the best of my knowledge, information, and belief; and 3. I am aware that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. ~u~.&!/> ~ f-vp",.R.,,,r FRANCES D. EVERHART CERTIFICATE OF SERVICE I, Elizabeth J. Goldstein, Esquire, attorney for Defendant, hereby certifY that I have served the Answer, New Matter and Counterclaims upon the following by depositing a true and correct copy ofthe same in the United States mail, postage prepaid, addressed as follows: Jeffrey B. Engle, Esquire Shaffer & Engle Law Offices 129 Market Street Millersburg, P A 17061 KEEFER WOOD ALLEN & RAHAL, LLP Dated: January -M, 2004 By: f4-J4 ! ~A/t Elizabeth J. Goldstein, Esquire Attorney ill #73779 415 Fallowfield Road Suite 301 Camp Hill, P A 17011-4906 (717) 612-5803 Attorneys for Defendant "'T.' ~ ~ ", ,,, C) c_ :::' 1''') (..) c (, c., ..-j i'i -'<, .-;\ <'.;,'" j; ',,:','" q'; ,'Ji..;i,}. lF~~' i;~!i~-r~::r,~:.~>' ::,.::}.:-:;U' ";i".!-io~-' BOYER SWIMMING POOLS, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA vs. NO. 03-6322 Civil Term FRANCES D. EVERHART, Defendant CNIL ACTION - LAW ANSWER TO DEFENDANT'S NEW MATTER AND COUNTERCLAIM AND NOW, this .f- day of February, 2004, comes the Plaintiff, Boyer Swimming Pools, me" by and through its counsel, Shaffer & Engle Law Offices, and respectfully avers as follows: 8. Plaintiff herein incorporates its original pleadings set forth in the Plaintiffs Complaint, paragraphs 1 through 7. 9. Denied. Pursuant to Plaintiffs common practice with the Defendant, the Plaintiff prepared a billing invoice for services rendered and materials used and submitted it to Defendant at the conclusion of the work being performed. This type of conduct in billing had been done by Plaintiff and accepted by the Defendant without complaint in the past. 10, Denied. The Defendant only requested Plaintiff to investigate the problem as to why the pool's water was not clean and clear, The Plaintiff strictly denies that it was ever hired to solve the problem, to the contrary, the Plaintiff offered to solve the problem and the Defendant denied the request because the solution involved draining the pool. This was a course of action that the Defendant expressly did not want to undertake, 11. Denied, The Plaintifftold the Defendant that the proper course of action would be to use low pressure air on the line, No charge, blast, or other explosive device was utilized, Further, it is specifically denied that the low pressure air used on the line could result in a charge or blast. 12, Denied. For the reasons stated above in averment 11, no charge was used at the Defendant's pool. 13. Denied. No charge was used. Moreover, any activity undertaken by Plaintiff did not loosen the grout or further clog the Defendant's line. 14, Denied. For the reasons aforestated, no charge was ever used by the Plaintiff. Strict proof of the damage allegedly caused by the "blast" is requested at the time of trial. 15. Neither admitted nor denied. After a reasonable investigation, Plaintiff is without sufficient information to intelligently respond to this averment. 16. Neither admitted nor denied. After a reasonable investigation, Plaintiff is without sufficient information to intelligently respond to this averment. 17. Neither admitted nor denied. After a reasonable investigation, Plaintiff is without sufficient information to intelligently respond to this averment. Further, strict proof of the findings of the other contractor is requested at the time of trial. 18. Denied. The conclusion stated in this averment is a conclusion oflaw. To the extent a response is necessary, the Defendant is not entitled to the defense of justification based upon the facts of the matter. DEFENDANT'S COUNTERCLAIM COUNT 1- BREACH OF CONTRACT 19. The answers to Plaintiffs response to Defendant's New Matter in paragraphs 1 through 18 are incorporated herein as if set forth below in full. 20. Denied, As stated previously, the Plaintiff was enlisted to investigate the Defendant's problem with the pool. The Defendant refused to abide by Plaintiffs advice to drain the pool and review the filtration system for possible difficulties. 21, Denied. Defendant was not damaged by the services of the Plaintiff. Moreover, strict proof of such damages is demanded at the time of trial. 22. Denied. For the reasons stated previously, the Plaintiff did not cause any damage to the Plaintiffs pool. Moreover, strict proof of any such damages or loss of enjoyment is demanded at the time of trial. WHEREFORE, the Plaintiff requests that this Honorable Court dismiss the Defendant's counterclaim for Breach of Contract. COUNT II- UNFAIR TRADE PRACTICES 23. The responses to Plaintiff s paragraphs 1 through 22 are incorporated herein as if set forth below in full. 24,a-c. Denied. For the reasons previously stated, the Plaintiff provided the Defendant with a timely bill for services rendered in accordance with the accepted business practices of the parties. Further, the Defendant was at home on each occasion that the property was serviced to the best ofthe Plaintiffs knowledge. Therefore, there was no need to leave a notification of services provided at the residence. Finally, the invoices are clear and speak for themselves. 25. Denied. For the reasons stated above, the invoices clearly identify the date the service was provided and the date the bill was prepared, The work done on each date specified is clearly stated in terms understandable by a consumer and the Defendant. 26. Denied. The Defendant is not entitled to treble damages, WHEREFORE, the Plaintiff respectfully requests that this Honorable Court dismiss the Defendant's statutory counterclaim based upon Unfair Trade Practices, Respectfully Submitted, SHAFFER & ENGLE LAW OFFICES //7 ...~,,% 4i.'./ ,;)' , ./ .'" , ,. / /' ~fff..' / ID;1Y79644 }Z9 Market Str~et /MiHerSburgtA 1706 / 71"7-692-23 ; / , VERIFICA TION I verify that the averments in this Answer to Defendant's New Matter & Counterclaim are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. 4904, relating to unsworn falsification to authorities. ! ~~~"( '/ Dated: BOYER SWIMMING POOLS, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA vs. NO, 03-6322 Civil Term FRANCES D. EVERHART, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Jeffrey B, Engle, Esquire, do hereby certify that a true and correct copy ofthe foregoing Answer to Defendant's New Matter and Counterclaim in the above captioned matter in the manner indicated below: u.s. Mail, First-Class Elizabeth J. Goldstein, Esquire KEEFER WOOD ALLEN & RAHAL, LLP 210 Walnut Street P.O, Box 11963 Harrisburg, PA 17108-1963 Attorney for the Defendant Respectfully Submitted, SHAFFER & ENGLE LAW OFFICES ""- .J /1.-7 ,c"."/,, , / ;; ( Jeffre~~le, E~ ill ,'76644 // )Z9 Market St~eet / . /// M,illersburg, l' A 1. 061 1(17-692-2345 / L/ 0 ,....., ,- = 0 ~ '-~ !~~l ~ "TJ .." --j t"T1 -r C:> fTj2J ,-- -om N :00 Or': -n --:1...-> -.,- -, ~- Ci:D ~-;~C) :r:.: r:? c5 fTl ::;J :'.. , (~) ?O 0 -< BOYER SWIMMING POOLS, INC" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA vs. NO, 03-63:z2 Civil Term FRANCES D. EVERHART, Defendant CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the Complaint and New Matter in the above-captioned case with prejudice. Please mark this matter and New Matter settled, Respectfully submitted, SHAFFER & ENGLE LAW OFFICES Lf;{JI / /.,.." '-'7,.-' ,/".,,;/ "/.'./ /' /,/ r:? j" '~ ~~/"E~" - J.-2~ket Stre5l Millersburg, P , 717-692-2345 Attorney }~r the Plaintiff Dated: Dated: ~ _ '5 -u 4 Elifjz~li~ KEEFER WOOD ALLEN & RAHAL, LLP 210 Walnut Street P.O, Box 11963 Harrisburg, P A 17108-1963 Attorney for the Defendant (") ~::: ",,:7 --2. "'" => = ~- o -n .-1 ::r: nl fIJ :T'Q] (.;~\..(' ,=':J't i~s~ .:...-1 .j;'''' :D ~C ~ :;... -< .:::- :'? ~? +" ~ ~ ~ Mz- ~ ~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 18.00 1.78 .50 1.00 9.68 30.00 20.00 .74 9.00 r7 90.70 /)0 J 'F! {;~ .....,,- o I :l d b - NVr qOOl 'Vd ')..1..110:3 OH\nH38Wn3 .:UIH3HS 3H1 .:i0 331.:1.:10 Advance Costs: 150.00 Sheriffs Costs 90.70 59.30 Refunded to Atty on 10/04/06 So Answers; ~~U;~~,o ByCJ a J1A.~ ~~tt / o W \ <" v, \.J (oJ ~ ~ a:=- \1dh.1 \b!h:. ~; ~,rf , Q.. s~ 1"3....... ~ I fl.{?J {,'l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N003-6522 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PLATINUM FINANCIAL SERVICES CORP., Plaintiff (s) From VERONICA L. DAVIS, 601 CUMBERLAND POINTE CIR, # 97, MECHANICSBURG, P A 17055-5456 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 4860 CARLISLE PIKE, MECHANICSBURG, P A 17050-302 - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1693.51 1.1. $.50 Interest FROM 12/18/03 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid $37.25 Plaintiff Paid Date: JANUARY 4, 2006 (Seal) By: Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737