HomeMy WebLinkAbout03-6482COMMONWEALTH OF PENNSYLVANIA
JUDICIAL DISTRICT
NOTICE OF APPEAL
DiSTRiCT JUSTICE JUDGMENT
NOTICE OF APPEAL
Notice is given that the appe/lant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on
date and in the case mef~oned belo~
cv D oo o /-o
Thb ~ck wi~ ~ ~ O~Y ~ ~is ~fi~ is required u~ P~ R.C~3~. ~
1~8~
~is ~ti~ of A~I, w~ mccad by t~ Disk~ Justice, will ~ as a
~DEAS ~ ~ ju~t ~ ~ssess~ in ~is case
Signature of Prothono~/ o~ Deity
/70
If appellant was CLAIMANT (see Pa. R.C.P,J,P. No,
I O01 (6) in action before District Just/ce, he MUST
FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when aPl~llant was DEFENDANT (see Pa. R.C. RJ, R No. 1001(7) in action before District Justice.
IF NOT USED, de~ach from copy of notice of appeal to be se~,ed upon appellee).
PRAECIPE: To Prothonotary
Name ot aopeltee(s)
(Common Pleas No, D~-- CL~ ~ ~ O ~ ffi } ) w/thin twenty (20) days after__of non pros.
Netne of ~oe#eefs)
(1) You am notF~-d that a rule is hereby entered upon you ta file a complaint in I~s appeal within twemy {20) days after the dote of
service of fhls role upon you by personal service or by certified or registamd m~l.
/)e¢om o. 3
(2) If you do not file a comp/aint within this time, a JUDC-MENT Of: NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of s~'vice of this rule if service ~ by mall is the date of mailing, i;
kopc3~2-~0 COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULETO FILE COMPLAINT
(This proof o/ service MUST BE FILED WtTH~N TEN (10) PAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ; SS
AFFIDAVIT: I hereby swear or affirm that I served
[~ a copy oI the Notice ¢ Appeal, Common Pleas No upon the District ,Justice designated therein on
(;date Cservice) [] by personai service [] by ('certified, (registered, mail senders
receipt attached hereto, and upon the appellee, (namt~i on
[] by personal service [~ by (certified) (registered) mail, sender's receipt attached hereto.
~ and further that I served the Rule to File Ct Complaint accompanying the above Notice ct Appeal upon the appellee(s) to whom
the Rule was addressed on ~ by personae ser¢ce ~ by (certified) (registered)
mail, sender's receipt attached hereto,
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS OAS OF
Signature
P~GE 0i
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF; COMB~.~,LA.ND
09-1-02
EOB~T V. MANLOVE
(7174 761-0583
17011-0000
NOKT~EAgT~KN ~OME IM~ROVJ~IENTB
125 N ENOLA D~ ~- )49(~
ENOLA, PA 17025
THIS IS TO NOTIFY YOU THAT:
....... ' J'~3gflle]l .t~ ....
[~ Judgment was entered for:
[~X--'} Judgment was entered against; (Name)
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF;
108 LAUP~L
ENOLA, PA 17025
VS.
DEFENDANT',
~O~, PA 17025
L
in the amount of $
Docket No.: CV- 0000401- 03
Date F ed: 8/28/03
(Name)
R,114.;O On:
[] Defendants are jointly and severally tiable.
~] Damages will be assessed on:
[] This case dismissed without prejudice,
Amount of Judgment Subject to
Attachment/4~ Pa.C.$. § 8127 $
~'---] Portion of Judgment for physical
damages arising out of residential
~ease $
(Date of Judgment) 11,/1 ?/o;~
(Date & Time)
Amount of Judgment $ 8, 000.00
Judgment Costs $ 11~.. 50
Ini'erest on Judgment $ .0 0
Attorney Fees $ , g. gO
Total $. 8,114.50
Post Judgmenf Credits
Post Judgment Costs
Certified JudgmeRt Tota!
$
$
$
ANY PARTY HAS THE RIGHT TO APPEA~. WITHIN ~0 DAYS APTER THE ENTRY OF JUDGMENT eY PILING A NOTICE
OF APPEAL WITH'THE PRO?HONOTARY/CL~K OF THE COURT DE COMMON PLEAS, C{~/IL' DIViSiON.:~¥OU ....
MUST INCLUDE A COPY OF THIS NOT[CE OF dUDGMENTFFRAN?~{~p~ F~RM'WITH YoUR NOTICE OF A[b/~EAL..
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF. CI~IL PROCED'~R~E FOR D ETR CT JUST CEE, ~.THE JUDGMEN~'HO~DER
ELECTS TO ENTER THE JUDGMENT (N THE COURT OF COMMON PLEAS ALL:FURTH'ER PROCESS.MUST COME FROM ~'~COURT' ;
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE I~UED BY THE DISTRICT JUSTICE. "~ .
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE'INTERESTEC l~4 THE JUDGMEN~ MAY
A REQUEST FOR ENTRY OF SAT SFAGT ON WITH THE DISTRICT dU~},"rIcE'IF ~HE JUDGMENT DEBTOR PAYS IN FULL, SE~CrLI--'S,
~,E COMPLIES WITH THE~I)DGMENT': ,; ...... ~.. /..?, .
.... ., · .... . , ; · ',~'.J..,~'.'~" :. !;'' L~.*. /~,,;.~ ...... ~'r ..... ~; .;,-~, -
.!. .................. .- ..... . - ..... r
[ . .... -.,.
O ~. /0 ~ ' ' ' * .- . >. .;,:,. ,,/ . ,,'c .
AOPC3~5-03 DATE PJtT. NTED: 11/17/03 310112=30 ~M
NOTICE OF APPEAL
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS FRON~
JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT
NOTICE OF APPEAL [~C lb ~ClO3
Notice is given that the appellant has filed ;n the above Coud of Common Pleas an appeal from the judgment rendered by the District Justice on the
date ond in the case mantioned below.
This block will be s~g~ed ONLY when this notati~ is required under Pa. R.C?J.P.
10088.
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the ]udgmant for possession in this case
$/gnature o! Prothcnotary c~ Deputy
If appellant was CLAIMANT (see Pa. R.C.P.J.P. No.
1001 ( 6 ) in action before District Justice, he MUST
FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of fc~Tn to be used ONlY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. I 00 t ( 7 ) in sction before Distdct Just/ce.
IF NOT USED, detach from Copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
/~ ~J/~/c~. ~ ~/.. ~ ~../'~ , appellee(s), to file a compleint in this appeal
Neme of el~oellee~s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days af~' the date of
service of this rule upo~ you by personal service er by certified or registered mail
(2) If you do not. file a cOmplaint within this time. a JUDGMENT Of: NON PROS W1LL BE ENTERED AGAINST YOU.
~3) The date of service of this tale if service was by
is
the
date
of
moiling.
AO~C 312-90 COURT FILE
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ~,,~ ~,./,~,,:~ ;SS
AFFIDAVIT: I hereby swear or affirm that I served
[~]' a copy of the Notice of Appeal, Common Pleas No. o~:~'.2 ~;~il ........ upon t~Le Dis~rict Justice designated therein on
(date o~ service) _ ~.¢~¢ ~E I~, ~ ........ ~ by personal se~ice ~y (certified) (registered) mail, sender's
receipt attached hereto, and upon the appellee (name) Rn, ~ S ~_ , on
~m bec I~., ~ . B by personal service ~y~rti~ied)~r~d/~ ;~S~e~ipt attach'~%~reto.
~ and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal uPon the appellee(s) to whom
th~ Rule ~a~ addr~s~e~ o~ _7;~~ Iff ....2~.., ~ by personal service ~y (certifie~gistered)
mall, senaer s recelp[ a[[acnea nere[o. ~ /
THIS._ ~ DAY OF ~_~m&~ .... ~ /.~~
My commissiof~ expires on
NOTARIAL SEN-
NANCY L. ~, Notary Public
Hampden Twp,, ~nd County
My Comrnl~ek:~ ~ J, an~,,28, 2007
· Complete items 1, 2, and 3. Aisc complete
item 4 if Restricted Detlve~ is desired.
· Print your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Arth31eAddrssssdto:
2..Article Number (Copy from service ~abe0
P~ase Print Clearly) B. Date of Detivery
C. Signature
[] Addressee
D. Isdelive~yaddreesdlffemntfiomiteml? [] Yes
If YES, enter delivery address below: [] No
3. Service Type
[] Certified Mail [] Express Mail
[] Registered [] Return Receipt for Merchandise
[] Insured Mail [] C.O.D.
4. Restrfcted Delivery? (Ex/fa Fee) ~] Yes
PS Form 3811, July 1999 Domestic Return Receipt 10~5~5~9-M-1789
~.m ~l.~ F~e Sl. 75
(Endoreen~t
'r~l I~e & Fees $4 · 4~
· Complete items 1, 2, and ~. hmo
item 4 if Flestricted Delivery is desired.
· Print your name and address on the reverse
so that we can return the card to you,
· Attach this card to the back of the maiipiece,
or on the front if space permits,
1. Article Addressed to:
C. SIg re ~, ..~,
O. Is delivery addmss diffa~ from item l ? nyes
If YES, enter delivery address below: [] No
3. Service Type
[~ertified Mail [] Express Mail
[] Registered [] Return Receipt for Merchandise
[] Insured Mail [] C.O.D.
4. Restricted Delivery? (Extra Fee)
2. Article Number (Copy from se~ice label)
qoo~ ~/~6 6oo7 d~¥~ 47~7
PS Form 3811, July 1999 Domestic Return Receipt
in the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
iN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CIVIL ACTION - EQUITY
PRAECIPE FOR APPEARANCE PRO SE
To the Prothonotary of Common Pleas Coup1:
Date: January 2, 2004.
I enter my appearance in the above-captioned matter, pro se.
Anne S. Alger
An adult individual residing at:
108 Laurel Drive
Enola, Cumberland County,
Pennsylvania 17025
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CIVIL ACTION - EQUITY
COMPLAINT
AND NOW, comes Appellee, Anne S. Alger, pro se, and files this Complaint, and
states the following:
1. Appellee, Anne S. Alger, is an adult individual who resides at 108 Laurel
Drive, Enola, Cumberland County, Pennsylvania 17025.
Appellant, Northeastern Home Improvements, is a company conducting
business with an office address of 125 North Enola Drive, Enola, Cumberland
County, Pennsylvania, 17025.
Appellee and Appellant entered into a written agreement dated March 23,
2002 for home improvements at 108 Laurel Drive, Enola, Cumberland
County, Pennsylvania, 17025. (Exhibit B)
Appellee is the owner of the above-described premises on which the home
improvements were to be performed.
Appellant is a contractor engaged in the business of and representing itself to
the Appellee as an expert in home improvements.
1 .That on the 17th day of November, 2003, a judgment was therein obtained and
entered against the Appellant, and in favor of the said Appellee, for the sum of
$8,114.40 and costs of suit. A true and correct copy of the judgment of the
District Justice is hereto attached, made a part hereof~ and marked Exhibit A.
2. Appellant has filed a Notice of Appeal from Distdct Justice Judgment with this
court.
3.Appellee files this Complaint as required to by Appellant's filing Praecipe to
Enter Rule to File Complaint and Rule to File.
III
1. In reliance upon the Paragraph t above and believing that said Appellant was
an expert in accordance with said agreement, the Appellee paid sums of
$500.00 and $5,200.00 pdor to commencement of work. (Exhibit B)
Further, Appellee, relying upon Appellant's representations made both
verbally and written, allowed Appellant to enter the above-described premises
at Appellant's recommendation and commit~,ent to perform and complete
said work under the agreement without the benefit of Appellee's presence.
IV
1. On or about June 9, 2002, Appellant commences demolition work on said
premises without the necessary permits as required under Prevision I of the
agreement and by the Township of East Pennsboro. (Exhibits B and F)
V
Appellee believes and avers that the property damage to her premises was
the direct and proximate result of and due to the negligence,
misrepresentation, breach of contract and poor workmanship of Appellant as
foilows:
· . . ~..,,'Tn,,..~ t ..... the ~7ownshiD of East
P~nn~bolo (Exhibit F)
b) A~pellant did not engage individuals licensed to ~e~orm such electrical or
p~umu.]g' ' ' work 'a~- required by the Township of East Pennsboro,
c) Appellant did not dispose of hazardous materials under Provision 8 of the
agreement causing harm to Appellee, Appellee's family members and pets.
d} ~Dellant did not exercise the care of a ~rudent ~emon in the re~ards of
the Appellee's pemonal belongings and thereby, ~used damage and
e~, Appellant was neqli.clent bv not obtainin~ the proper permits and therebv,
causing ciestructlon avo~3able it the proper perm,s, inspections anti
engagement cf professional p,3rs~nn~ ~ per;~r,m wor~ coa[ract~ Poi w~r~
fl ADpellant misreDresented itself as disclosing it employed experts in the
areas needed to perform the work for the home improvements under the
agreement.
e) Appellant misrepresented itseff as havin(~ the proper insurance covera(!e.
(Exhibit E)
h~ Appellant has not performed the work under provision of the agreement to
the satisfaction of the Appellee. (Exhibit B)
VI
1. As a result of Aopellant's negligence, misrepresentation, breach of contract
and poor workmanship, Appellee and her family were without the enjoyment
a.a benetr( pt premises as tully Oe6cribc-~ ar~ ~et tortr~ ~n ~-xniDtts L; ar~ U}.
2. Further, Appellant failed to respond verbally or in writin(~ to ApDellee's
and former legal counsel's requests for relief. (Exhibits C and G)
3. Further, Appellee suffered financial hardship and loss of personal property as
a result of Appellant's negligence, misrepresentation, breach of contract and
poor workmanship. (Exhibits C, D and H).
As a direct and proximate result of the negligence, misrepresentation, breach of
contract and poor workmanship of Appellant, Northeastern Home Improvements,
Appellee, Anne S. Alger has sustained contract damages and significant property
damage in the amount of $8,114.40.
WHEREFORE, Appellee, Anne S. Alger, demands judgment in its favor and
against Appellant, No~lheastem Home Improvements in the amount of $8,114.40
Date: January 2, 2004 BY: -
Anne S. Alger, Pro Se
108 Laurel Drive, Enola, Cumberland County,
Pennsylvania 17025, (717) 732-5993
Copy to Appellant's Attomey:
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
VERIFICATION
I hereby affirm that the foregoing facts are true and correct to the best of my
knowledge and belief. I hereby acknowledge that the facts set forth in this Complaint
are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom
falsification to authorities.
4
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CIVIL ACTION - EQUITY
PRAECIPE
To the Prothonotary of Common Pleas Court:
Date: March 5, 2004
Reinstate the Complaint in the above-referenced matter.
Anne S. Alger
An adult individual residing at:
108 Laurel Drive
Enola, Cumberland County,
Pennsylvania 17025
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CP-21 -MD-6482-2003
CIVIL ACTION - EQUITY
Motion
NOW COMES, Appellee, Anne S. Alger, pm se, seeking a final order be entered
in the above-referenced matter.
WHEREAS, Appellee filed a Complaint in said Court on January 6, 2004,
reinstated on March 17, 2004; and
WHEREAS, Appellant, Northeastern Home Improvements, has failed to file an
Answer to said Complaint within the required time; and
WHEREAS, Appellee, under Rule 208-2, submits to the Court Proof of Service to
Appellant's counsel, Gregory R. Reed, Esquire in this matter; and
WHEREAS, Appellee, under Rule 206-6, includes the name of the attorney who
is required to be notified and a duplicate copy of the proposed order with a self-
addressed, stamped envelope to said attorney;
THEREFORE, APPELLEE seeks this Court's relief and judgment in its favor and
against Appellant, in the amount of $8,114.40 exclusive of interest and costs.
Respectfully submitted,
Anne S. Alger, Pre Se
108 Laurel Drive, Enola, Cumberland County
Pennsylvania, 17025 (717) 732-5993
Copy to Appellant's Attorney:
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
VERIFICATION
I HEREBY AFFIRM THAT THE FOREGOING FACTS ARE TRUE AND CORRECT TO THE
BEST OF MY KNOWLEDGE AND BELIEF. I HEREBY ACKOWLEDGE THAT THE FACTS SET FORTH
IN THIS MOTION ARE MADE SUBJECT TO THE PENALITIES OF 18 PA. C.S. SECTION 4904
RELATING TO UNSWORN FALSIFACTION TO AUTHORITIES.
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CP~21-MD-6482-2003
CIVIL ACTION - EQUITY
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving the foregoing document upon
the person(s) and in the manner indicated below:
Service by first class mail addressed as follows:
Gregory R. Reed, Esq.
3120 Parkview Lane
Harrisburg, PA 17111
(Appellant's attorney)
Date: May 20, 2004
Anne S. Alger
Pro Se
108 Laurel Drive
Enola, PA 1702§
(717) 732-5993
In the Court of Common Pleas of Cumberland Coun~bj, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURTOF COMMON PLEAS
CUMBERLANDCOUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CIVIL ACTION - EQUITY
- Order
It is hereby ORD/~;)~at~ppellee~.~i~st for i~,l~mer'~he ount
Improvements is ~TED. ~',i~d-~RTHER~"~r~) t f
the Court s~otif-y ~nt of this~'~;;ce ,pt
requested~ ~ ........ ~,~un uy
Court of Common Pleas
of Cumberland County, Pennsylvania
Dated:
J:
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
V=
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CP-21-MD-6482-2003
CIVIL ACTION -- EQUITY
Motion
NOW COMES, Appellee, Anne S. Alger, pm se, seeking a final order be entered
in the above-referenced matter.
WHEREAS, this Court issued a Rule against defe~ndant to show cause why
requested relief should not be granted on June 1,2004 to be answered twenty (20)
days from service in the above-referenced matter; and
WHEREAS, Appellant, Northeastern Home Improvements, has failed to file an
Answer to said Rule within the required time; and
WHEREAS, Appellee, under Rule 206-6, includes the name of the attorney who
is required to be notified and a duplicate copy of the proposed order with a self-
addressed, stamped envelope to said attorney;
THEREFORE, APPELLEE seeks this Court's relief and judgment in its favor and
against Appellant, in the amount of $8,114.40 exclusive of interest and costs.
Respectfully submitted,
Anne S. Alger, Pre Se
108 Laurel Ddve, Enola, Cumberland County
Pennsylvania, 17025 (717) 732-5993
Copy to Appellant's Attorney:
Grego~ R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
VERIFICATION
I HEREBY AFFIRM THAT THE FOREGOING FACTS ARE TRUE AND CORRECT TO THE
BEST OF MY KNOWLEDGE AND BELIEF. I HEREBY ACKOWLEDGE THAT THE FACTS SET FORTH
IN THIS MOTION ARE MADE SUBJECT TO THE PENALITIES OF 18 PA. C.S. SECTION 4904
RELATING TO UNSWORN FALSIFACTION TO AUTHORITIES.
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIIA
DOCKET NO: 03-6482 Civil
CP-21-MD-6482-2003
CIVIL ACTION .- EQUITY
CERTIFICATE OF SERVICF
I hereby certify that I am this day serving the foregoing document upon
the person(s) and in the manner indicated below:
Service by first class mail addressed as follows:
Gregory R. Reed, Esq.
3120 Parkview Lane
Harrisburg, PA 17111
(Appellant's attorney)
Date: July 12, 2004
Anne S. Alger
Pm Se
108 Laurel Drive,
Enola, PA 17025
(717) 732-5993
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CP 21 MD 6482-2003
CIVIL ACTION - EQUITY
Motion
NOW COMES, Appellee, Anne S. Alger, pm se, seeking a final order be entered
in the above-referenced matter,
WHEREAS, this Court issued a Rule against defendant to show cause why
requested relief should not be granted on June 1,2004 to be answered twenty (20)
days from service in the above-referenced matter; and
WHEREAS, Appellant, Northeastern Home Improvements, has failed to file an
Answer to said Rule within the required time; and
WHEREAS, Appellee, under Rule 206-6, includes the name of the attorney who
is required to be notified and a duplicate copy of the proposed order with a self-
addressed, stamped envelope to said attorney;
THEREFORE, APPELLEE seeks this Court's relief and judgment in its favor and
against Appellant, in the amount of $8,114.40 exclusive of interest and costs.
Respectfully submitted,
Anne S. Alger, Pre Se
108 Laurel Ddve, Enola, Cumberland County
Pennsylvania, 17025 (717) 732-5993
Copy to Appellant's Attorney:
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
VERIFICATION
I HEREBY AFFIRM THAT THE FOREGOING FACTS ARE TRUE AND CORRECT TO THE
BEST OF MY KNOWLEDGE AND BELIEF, I HEREBY ACKOWLEDGE THAT THE FACTS SET FORTH
IN THIS MOTION ARE MADE SUBJECT TO THE PENALITIES OF 18 PA. C.S. SECTION 4904
RELATING TO UNSWORN FALSIFACTION TO AUTHORITIES.
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CP-21-MD-0482-2003
CIVIL ACTION - EQUITY
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving the foregoing document upon
the person(s) and in the manner indicated below:
Service by first class mail addressed as follows:
Gregory R. Reed, Esq.
3120 Parkview Lane
Harrisburg, PA 17111
(Appellant's attorney)
Da~:July12,2004
Anne S. Alger
Pro Se
108 Laurel Drive
Enola, PA 17025
(717) 732-5993
In the Court of Common Pleas of Cumberland County, Pennsylvania
ANNE S. ALGER,
Appellee
NORTHEASTERN HOME
IMPROVEMENTS
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
DOCKET NO: 03-6482 Civil
CP 21 MD 6'182 2000
CIVIL ACTION - EQUITY
JUL
Order
It is hereby ORDERED that Appellee's request for judgment in the amount of
$8,114.40 exclusive of interest and costs and against Appellant, Northeastern Home
Improvements is GRANTED. It is FURTHER ORDERED that the appropriate officer of
the Court shall notify Appellant of this decision by certified mail, return receipt
requested.
Dated:
Court of Common Pleas
of Cumberland County, Pennsylvania