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HomeMy WebLinkAbout04-040401/05/04 YORK COUNTY COURTHOUSE CIVIL ACTION DOCKET PASCOE, MARY JANE VS. SALOMONE, WILLIAM K PARTY TYPE ATTORNEY PLAINTIFF FOR CIVI ATTORNEY PLAINTIFF FOR CIVI DEFENDANT FOR CIVI DEFENDANT FOR CIVI ET AL CASE NO: 2003-SU-002824-Y01 YK FILING DATE: 06/19/03 JUDGE: ET AL LITIGANT P00l P00l P002 P002 D001 D002 PARTY NAME PAGE Y01 RESTAK, CHRISTOPHER T PASCOE, MARY JANE RESTAK, CHRISTOPHER T PASCOE, JUANITA SALOMONE, WILLIAM K KEYSTONE FIRE RESTORATION 1 DATE FEE/AMOUNT -------- ---------------------------------- -------------- --------------- 12/24/03 00187 00345 AS TO PASCOE, MARY JANE 23.25 *STIPULATION AND ORDER CASE TRANSFERED TO CUMBERLAND COUNTY BY THE CT JOHN S KENNEDY JUDGE 07/30/03 00114 0482 23.95 SHERIFF RETURN OF SERVICE CMPLT SERVED TO WILLIAM SALOMONE DBA KEYSTONE FIRE RESTORATIO 7/8/03 BY CUMBERLAND CO SHRF 07/30/03 00114 0482 34.26 SHERIFF RETURN OF SERVICE SHERIFF OF CUMBERLAND CO DEPUTIZED 06/19/03 00092 0103 113.75 COMPLAINT IN A CIVIL ACTION TOTAL NUMBER OF ENTRIES: 4 REQUESTED BY: CLS ******* END OF REPORT ******* CERTIFIED frX the records J the Court of Common Pleas of or-County Pennsy anima tltiis 5 day of A.D. 20 a z l^ (J/`q Pamela S. Lee, Protbonotary FROM :GHI ENGINEERS Mary Jane Pascoe and Juanita Pascoe Plaintiffs V. COURT OF COMMON PLEAS YORK COUNTY CIVIL ACTION - LAW DOCKET NO.03-SU-02$24-01 FAX NU. :717-633-9143 Dec. 22 2003 12:09PM P2 04 -- ,4/?kvjj William K. Salomone, an individual { d-b.a. Keystone Fire Restoration JURY TRIAL REQUESTED Defendant i ORDER d AND NOW, TO WIT, this 23 rday of , 2003, upon consideration of Plaintiff's and Defendant's Stipulated concurrence in support of transferring the above referenced matter, from York County to Cumberland County, it is ORDERED that this case be transferred to Cumberland County Court of Common Pleas. :ennedy CER'ITFIE) from the records of the Court of Common Plea! this _ S day of \/A^^ . A.D. 20 0 Y rn -{ G C7 _ 1?1v?? l l Pamela S. Lev, 1'romhouo=y FROM :GHI ENGINEERS Mary Jame Pascoe and Juanita Pascoe Plaintiffs FAX NO. :717-633-9143 CIVIL ACTION - LAW V. William K. Salomoue, an individual d.b.a. Keystone Fire Restoration Defendant StlouhrOon to Transfer Case to Another Jurisdiction c_ n < C. N v s. t N _. The parties, Plaintiffs Mary Jane and Juanita Pascoe and the Ddarr G %.O U r C!> William K. Saloatone, by and through their attorneys, hemby agree to transfer this Else, Dec. 12 2003 12:02PM P2 COURT OF COMMON PLEAS YORK COUNTY DOCKET NO. 03-SU-02824-01 JURY TRIAL REQUESTED w 0 T a originally filed in York County, to Cumberland County as per the specific choice of venue provision in the contract that was entered into between the parties. Subject to the approval of this Court, to transfer the matter, the parties agree to the following: 1. Since there is no dispute as to the condition of the contract, designating Cumberland County to be the venue for any actions for recovery of damages, plaintiffs agree to transfer the case to Cumberland county. 2. Both Plaintiffs attorney, Christopher Rest ak, Esq. And defendant's attorney, Nathan Wolf, Esq., request that the tra nsfer be approved, subject to this Stipulation, and that there be no hearing in the matter. 3. Both plaintiff and defendant, in consideration of this Stipulation, request that the case be transferred to Cumberland County for purposes of adjudication, 358091810345 FROM :GHI ENGINEERS FAX NO. :717-633-9143 Dec. 12 2003 12:03PM P3 Respectfn submi , h er T. Restak, Esq. 213 Carlisle Street Hanover, PA 17331 (717) 637-5188 PA. Supreme Court ID # 81514 NaNtao C. o sq. Irwin Law Office 64 South Pitt Street Carlisle, PA 17013 PA. Supreme Couf_rt ID # 87380 Date: e4W. t? /, , 2003 CHRISTOPHER REsTAK ArrORNEYATLAW Admlued to Pmace in PA, MD and NY www.the oonetnwdomttorney.com 213 Caftle Street, Hanover. PA 17331-2410 Phone: 717-637-5188 • Faz: 717-633.9143 • Emad: ctroatek®nebr nct O December 16, 2003 G H bl J d J K d h enne onora e u ge y o n G, York County District Court House 28 E. Market Street 3 ' York, PA 17405 Re: Mary Jane and Juanita Pascoe v. William K. Salomone An individual d.b.a. Keystone Fire Restoration Docket No. 03-SU-02824-01 Dear Judge Kennedy: I hereby request that the above, captioned case be transferred from York County to Cumberland County, as per the agreement that has been reached by both the plaintiff and defendant. The purpose of the transfer, and the factor contributing to both parties consent to this transfer has to do with a "choice of venue" condition that was included in the original contract that was signed by the parties. The specific venue that was identified was to be "Cumberland County" where the defendant resides and conducts his business. The fact that the work that was the subject of this action was undertaken in York County and the defendants reside in York County notwithstanding, plaintiffs are amenable to this transfer and concur to the transfer to Cumberland County. I spoke with your secretary, Betty, last week, and I was told, by Betty, after conferring with you, I was to obtain a Stipulation, signed by both myself and opposite counsel, agreeing to the transfer. The enclosed Stipulation sets forth the reason for the transfer. I have also spoken to the Cumberland County Prothonotary who told me that we would be assessed a fee of $55.00, following the transfer of the case, that we would be required to remit to them at that time. If you have any questions, concerning this matter, or simply require additional information in order to effectuate this request, please do not hesitate to contact me, directly. Cc: Nathan Wolf, Esq. Mary Jane Pascoe and Juanita Pascoe Plaintiffs v. William K. Salomone, an individual d.b.a. Keystone Fire Restoration Defendant COURT OF COMMON PLEAS YORK COUNTY CIVIL ACTION - LAW DOCKET NO. (7(i05",5j) - 02824 -01 JURY TRIAL REQUESTED Notice to Defend YOU ARE HEREBY NOTIFIED TO PLEAD TO THE WITHIN COMPLAINT WITHIN TWENTY (20) DAYS OF SERVICE UPON YOU OR A DEFAULT JUDGMENT MAY BE ENTERED 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 CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. You should take this paper to your lawyer at once. If you do not have or know a lawyer, then you should go to or telephone the office set forth below to find out where you can get legal help. Lawyer Refererral Service of The York County Bar Association York County Bar Center 137 East Market Street York, PA 17401 tel. # (717) 854-8755 'T cap P J r>? '2 n ? A -J _ lp r' ..C ;C ? 7,= G7 f:,7 fYl •. o 114090920103 "ISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defendrse de las quejas expuestax en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o por abogado y presentar en la Corte por escrito sus defenses o sus objections a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demando o por cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADADES U OTROS DERECHOS IMPORTANTESPARA USTED. LLEVE ESTE DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI USTED NO TIENE 0 NO CONOCE UN ABODAGO, VAYA 0 LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Lawyer Refererral Service of The York County Bar Association York County Bar Center 137 East Market Street York, PA 17401 tel. # (717) 854-8755 Mary Jane Pascoe and Juanita Pascoe Plaintiffs V. William K. Salomone, an individual d.b.a. Keystone Fire Restoration Defendant COURT OF COMMON PLEAS YORK COUNTY CIVIL ACTION - LAW DOCKET NO. O y - yn d JURY TRIAL REQUESTED DATE: June 16, 2003 COMPLAINT Plaintiffs, Mary Jane Pascoe and Juanita Pascoe, by and through their attorney, Christopher Restak, file the following Complaint against Defendant, William K. Salomone, an individual, doing business as Keystone Fire Restoration, and for cause state as follows: JURISDICTION AND BACKGROUND FACTS 1. Plaintiffs are individuals, sisters, currently residing in Hanover, 0 Pennsylvania and owning property located at 114 Fair Avenue, Hanover, York C n County, Pennsylvania. 2. Defendant is an individual, d.b.a. Keystone Fire Restoration, located at 559 Highland Avenue, Carlisle, Cumberland County, Pennsylvania, and conducting business in York County, Pennsylvania. 3. Plaintiffs hired Defendant, under a written proposal, to perform construction 17HU920103 3 c C ; C Ui c l co Services at their residence in Hanover, York County, Pennsylvania (hereinafter referred to as the "premises"). A copy of the Defendant's contract and billing statements are included and incorporated by reference as (Exhibit A). 4. Plaintiffs aver that the proper jurisdiction for this action is York County, where the property is located and where the work was performed. 5. Plaintiffs maintain that the work, undertaken by Defendant, was substandard and the Plaintiff's damages are a direct result of defendant's breach of contract in failing to provide construction services, consistent with the contract requirements, in a manner that would meet reasonable, industry standards. 6. Plaintiffs have suffered damages as a consequence of Defendant's substandard work and the Defendant's inability to correct the deficiencies. 7. That the type of damages that plaintiff's have incurred are not the type of damages that occur in the absence of negligence. 8. Plaintiffs pray for relief, under the following theories, as outlined in Paragraph 8 through ` as hereinafter set forth. 174090920103 4 COUNTI BREACH OF CONTRACT 9. Plaintiffs hereby incorporate by reference the facts and allegations contained in Paragraphs 1 through 8 hereof as if more fully set forth herein. 10. As set forth above, Plaintiffs and Defendant contracted for certain improvements to be completed at Plaintiff's home in York County. Improvements consisted of the repair of the home from the damage done by a fire that occurred at the residence on or about January 27, 2001. 11. In order to obtain Defendant's services, plaintiffs were required to waive their three-day right of cancellation following the execution of the contract, as a consequence of the bona fide need to start repairing the home, "as soon as possible" despite the fact that defendant did not begin work until March 17, 2001. 12. Defendant completed the scope of work, within the period set forth for completion, and Plaintiff s fully compensated defendant for the work. 13. Subsequent to completing the work, plaintiffs suffered two successive, major plumbing leaks that occurred as a consequence of defendant's improper installation of plastic pipe-fittings, causing a flooding of the main living area of the home. 174090920103 14. Subsequent inspection by a certified plumbing contractor noted the improper installation of plumbing parts, in various locations of the home. 15. Defendant had obtained permits for the construction but had failed to obtain any plumbing permits, stating that the work that they were doing was "replacement" work for previously existing plumbing. A copy of the existing permits for this project are attached and included, by reference herein, as (Exhibit B). 16. Plaintiffs also discovered that defendant had either negligently or intentionally covered over heating supply registered with finish carpet, thereby preventing adequate circulation of heat to the rooms at the rear of the home. 17. Defendant's work was substandard and Plaintiffs have been required to expend upwards of $7600.00 to complete the work in the manner that was originally described in the contract. 18. As a consequence of Defendant's substandard work, Plaintiffs have been damaged. Attached hereto and incorporated by reference as (Exhibit Q are invoices, proposals and receipts for the repairs necessary to complete the work and repair the damage that resulted as a direct consequence of defendant's substandard work. 174090920103 6 19. In addition the Exhibit C, detailing the construction costs to repair and replace the damage the plaintiffs were required to make various expenditures to cover the costs of the damage to property that was a direct result of the damage when the flooding occurred. Attached hereto and incorporated by reference as (Exhibit D) are receipts for replacement of furniture, carpeting and for the stay in alternative accommodations for the week immediately following the flooding. 20. Plaintiffs pray for relief from Defendant's actions that have deprived them of the use of their home. Plaintiffs seek delay damages to compensate them for their loss of enjoyment of the facilities for the duration the time during which the home was rendered uninhabitable as a consequence of the flooding, caused by defendant's substandard work. COUNT II NEGLIGENCE 21. Plaintiffs hereby incorporate by reference the facts and allegations contained in Paragraphs I through 20 preceding as if more fully set forth herein. 22. As Set forth above, Plaintiffs and Defendant contracted for certain improvements, otherwise referred to as the project. Plaintiffs relied upon Defendant's superior knowledge, concerning construction matters and details, particularly as those matters related to general carpentry and plumbing and mechanical installation(s). 174490920103 23. Plaintiffs reliance upon Defendant's superior knowledge was reasonable considering Defendant's professed expertise in those matters for which Defendant held themselves out as performing as part of a trade or business. Defendant's given business name "Keystone Fire Restoration" and their advertised claim of being "Carlisle's Only Fire Specialist" would imply a familiarity with work of the nature that was performed, on behalf of plaintiffs, and equal to or superior of other firms performing similar services in their community. 24. As a direct consequence of Defendant's breach of their duty of care to the Plaintiffs in undertaking this project, Plaintiffs suffered damages that were foreseeable to Defendant. 25. Plaintiffs were not responsible for supervising Defendant's work nor did they assume any responsibility for directing Defendant, or any of Defendant's agents, in the execution of their work. Furthermore, Plaintiffs did not interfere with Defendant's access to the site nor did they, during the course of the projected construction schedule, bar Defendant, or Defendant's agents, from the site. 26. Defendant was to complete certain repairs to the plaintiff's home, following a fire that occurred on January 27, 2001. The repairs were to be completed in a workmanlike manner and were to be completed so that plaintiffs could re-occupy their home. The damage that is the sVbiect of this Complaint occurred, following 174090 920103 completion of the work but was caused by a rupture of the bath room plumbing supply line, causing extensive flooding and property damage to plaintiff's home and personal belongings. 27. It is alleged that it was as a direct consequence of defendant's negligent installation of plumbing supply valves that the flooding occurred. 28. Although defendant's contract, with the plaintiffs, warranties the work for one- year from completion of work or occupancy of owner, whichever appears first, the condition complained of, faulty workmanship, was a "hidden condition" that plaintiffs would not have been aware had the flooding not occurred on or about January 3, 2003. 29. Plaintiffs would have been aware that the plumbing was negligently installed, had defendant obtained plumbing permits, as required, and had the work therefore become subject to inspection by the local building department. 30. A copy of expenditures, undertaken by plaintiffs in fixing the work is included herein and incorporated by reference as (Exhibit D). 31. As a direct result of Defendant's negligence Plaintiffs have been greatly damaged. Plaintiffs seek damages in the amounts as enumerated in the following paragraph(s). Attached to this Complaint and incorporated by reference as 114000920103 (Exhibit C) are invoices, proposals and receipts for the repairs necessary to repair the premises and (Exhibit D) covers the costs to replace and/or repair the personal property damages as a consequence of the plumbing failure. WHEREFORE, Plaintiffs, Mary Jane Pascoe and Juanita Pascoe, request that this Honorable Court, award judgment against Defendant, William K. Salomone d.b.a. Keystone Fire Restoration, in favor of Plaintiffs in the following amounts: A. i. $3,900.00 representing the cost to repair the premises following the flooding. ii. $137.00 representing the costs to replace a condensate pump for newly installed air conditioning system. iii. $135.00 representing the costs to reset the toilet and shower in the downstairs bath. iv. $175.45 representing the costs to repair a 3-inch main sewer line connection that had been installed by the defendant. V. $ 48.00 representing the costs to re-hang a thermostat that had been damaged in the flooding. vi. $ 3,300.00 representing the costs to properly reinstall the exterior siding that was incorrectly installed as part of the original work. AiA00?920103 10 vii. $ 671.88 representing the costs to temporarily obtain alternative housing while the house was cleared of debris, following the flooding. viii. $ 829.71 representing the costs associated with replacing the carpeting in the main living room, located immediately under the bathroom that flooded. ix. $ 2,069.95 representing the costs associated with replacing the furniture that was located in the main living area. X. $ 157.00 representing a billing from Service Master indicating an attempt to clean the furniture and a statement that they "could not guarantee that mold spores would not grow" in the furniture, following the flooding. B. Award Plaintiffs reasonable attorney's fees consistent with defendant's contract, paragraph 11. C. Award judgment against defendant, William K. Salomone, t/d/b/a Keystone Fire Restoration, in favor of the plaintiffs, Mary Jane and Juanita Pascoe, in the amount of $11,418.99, consistent with the expenses incurred by plaintiffs and outlined above. Respectfully bmitted By hristo er Restak, Attorney 213 Carlisle Street Hanover, PA 17331 (717) 637-5188 PA Supreme Court IN 81514 Attorney for Plaintiff JIMOO V03 11 VERIFICATION We hereby affirm that the facts contained in the forgoing Answer and Amended Counterclaim are true and correct to the best of our knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. C.S., Section 4904 relating to unworn falsification to authorities. Date: June 6, 2003 By:< Mary J#e Pascoe By: ?ca az_ J ita Pascoe 174094920103 12 EXHIBIT A 174090 920 103 KEYSTONE FIRE RESTORATION 559 HIGHLAND AVENUE (717) 243-9595 CARLISLE, PA 17013 /? 0- CONSTRUCTION AGREEMENT THIS AGREENEM made Mho-da ? by AM Wasw KEYSTONE FIRE RESTORATION of IS HphIeM AVema, CaAiab, Pannaylvanla 1T013(SAGREE nhnmd r'_jb=%Ni ? kv Sti i?c1 5) ACe bf l 'i Fa iY 1.?•- t'?A?yl p 1?>^ 14- I'? I / 3 ! Inmih.4 nfererxed AN varier) In consideration of de muvW comma b ark aproaeme Mein contained and InnMlp m be I Wry bound hereby, ft pertlee hues, do hvaby agree, as fepowa: I' 7a"A 4, m MN 's abv recxuy - 11, seas orb uMmuely dew ark repair de pram", oev ad by Omer ors Imew at I ? / (fin. 1yp??Vy! dz h oomdvo WMdNeWmab•MmM.mpbsotwhld,m Wtlahdby dMiameahvem W apacrsd throb and Inmrporabd by r•Nrvr dnuph Mfr. 2. Ovv"r eluN wAsee eM mynas propvry Faxonm upon tle mswWt aM Imprownenb ImNd on de mummtlon Mb W Me MR Iarnbe blue thereof. Such mAshot shelf ihchd, Me ebrosb d cane, contractor eM an w stoma b s aM shall Insure epWat Me mdb d ea awl bars, msional Fa sed mstabet as Wavl a an HO a3 Special Form Homeownm Poky W h exronded mxrpa and mvarepe "What deft, veclalbm sM mWdcte arsenal, The proceeds of arty I eaW damn was M made payable m oemr, ke,t9si connector or Suocarimw as their eer"b may appear. Ovxer *1 proves Comscmr Wet copies of N appl ca le ineurarce pohoi upon Warm, of Comemr. 3 P me nbr emporay, repays shall by u upon oonplepon. For all olr e. • I pry m Cauacw for his parivmance Aver Mb Agreement de won of (d` Doeal4 u bear,: VLJ?P _M bxD"?-11,. n/Wf, It, Ia(e` ;"!C !i-^nt4,? Cr_ Is) dAN Upon mmnvwnwnt d mutmatlon; (b) OMI upon mmplew as orvrh of the off wo* r dahnined by Cmbtcw;or (c) Or iNrd upon euortlal o Pbtlonof de aoetd work a hwmeed by Cavaobr; w 11 U IN As Marvin dawaNnM by Me larger or eabvta ode of ows, Payment was be Me ion( t 0) days from rears by Amer of Me My a Invoices red ehW bar Interest star SAM tan(10)day "AM vrile rest of ore and bnNwf parent (1 Owner rsraby aright b Cmbaaor YI MIN Perry Argo w that barseWon from laid I keurvwe mmprJe, er tle IIXa eM wthorlzes euM Mkd "rune m make peymx[, wrsn d", dirxtly to Conbuw. e deev"tef MVrg ago usfIuurahmvern OormamOm IN w,pmv Mnbypras•mdepogithasaeWMamuabpY acmpudalinandb ihttlemonnan insurodescrow ecmunt Which requires tpnrMxha of both carer eM Cebu aid . a. The on menoerlis lt under She Agreement ho wall MeMnW in said arm accord Name oafth li dw rshnnmd xdbves, m en w Nwatlmt hor addlwa erweeages. stctma rs or adcSoof St ntnW unlit by sub en ag Meese Me prtlx Mrsm. Any reduWane In ewreno rNmbur"rtenl u a a no wit lt d any such di alNOns or additions rev each In c hav In In Me tle s Wd onsoxdu l w c wmM doe o-ocw. 5, .W Woa work v u " WelI have We yM eComareeeselbn of Me subject proml"s dw4w Ms bra sea WWA Agreement. M Owmr •NNl tot ri e a hwea Mrvx im until mmpNgon of WI of the peed debrtrdnr by Ms Ca""w, uWlacrory in"eWon by th. nbm of age While a w Ma e work end Mount in ANN of YI me due der. , d. TM manure of the m Imvntroer,r"bWnb "ymsm m comply b v Ownerto rayekaaneownwnb ors, of de mnWVb "Wastes • ewbM wr fact, or v o cWma dafeWx morale o or r le Cm ""Wag Wth Within de axoptlon ma (t) yea &far ehar eubnow SMam from compeuun rroew of None She eon h of mtria Ivel "le orafter acmprxy by Ownv whkMewrshell Wet coca. . AN Aq other wvrrma. npru•atlor Implhd,mdu,Sdp Wthwa Slimibdon. implbdwvrsntlx of rstieeliy. Are busby waiei 7 a.. No TMmodieutlon ve wa Apnamen[ ahdl M NMep upon de pvtba hmb mhos Ms •ane ahgl M e wrltlp eM dory approved on ell of "Nx ham. 9. tons"IrM eppmvaldConwcmr. T ranaw ddda b/WII, aurNwrship . wall ta rInpaved ca Agraam " an x autgemtotM rpu*I,lp Me rib mum e, asm &M vpwvof the ar Contrntraetor. or by T NN$ A wall nt s , r spprovef contractor. ahdl al m W in d u our eM M risen Pa mwf d the Corunbeea w Me Ueln aM dab hued addle Drd of ecuou astern b INS e Agareamm In tln court Common of Carave M y he l m M sod Saw be Data Diao-ict Cbu n for IM hatotWi of Pannsylvantis. mia to.acts avertMet om umoraofdepr ovieMtd INS AO wh for Ny mnroaw. AN Mrseb M Invalid. Nl . orux wmaW orotal aN Vna Such ilWimiry or ononwuadury ehan W not m[aded arryothv progelon had; and this Agreement enla mam shot w W Mebwd u If eu,M Imrelg. Nbpal v onenovbM M1M navyMan co mnw Wien. vvat.ay Was, Core aM taf a"x"ma• oe , of fe Ineaeaeary Addition my other WWI b Which he Apro peva"fWbw pbry penty m m o ay vry Its entilled. 12. ThiNs Apraamentmhttlvtx the ands eumedw MnuMV,Me prevelNppvryehYlMandtled mrarmabM sllom ne e smarm In atlm riles he Mr ebaM ndings pre"emof the pum o aupvsedx any pre ugvetrde" orwdlM a vat agreements rseaen the pa.uee WM r"pvl 13. This Agna main and M binding upon rib res"W u Mle. exeww•, Whanimatbt, wmesemt and a Me Bawd aulgrbble, asalgns or na naves of Me "rasa Iweb. 14. You, the Owner, may cancel this transaction at any time prior to midnight of the third business day after the date of this transaction. See the attaached notice of cancellation form for an explanation of this right. r'I , r t" tt ?' I^ J/IritPotlce of.CBncellatlob C N p 4;' i k+n n J7, + , 19- .e/¢? -A)ear You may cancel this transaction, without any pe fly or obligation, within three business days from the above date. It you cancel, any property traded in, any payments made by you under the contract or sale, and any negotiable instrument executed by you will be returned within ten business days following receipt by Contractorof yourcancellation notice, and any security interest arising out of the transaction will be cancelled. If you cancel, you must make available to Contractor at your residence in substantially as good condition as when received, any goods delivered to you under this contract or sale; or you may, N you wish, comply with the instructions of Contractor regarding the shipment of the goods at Contractor's expense and risk. If you do make the goods available to Contractor and Comradordoes not pickthem upwithin twenty daysof the dateof your notice of cancellation, you may retain or dispose of the goods without any further obligation. If you fail to make the goods available to Contractor, or it you agree to return the goods to Contractor and fail to do so, then you remain liable for performance of all obligations under the contract. To cancel this transaction, mail or deliver a signed and dated copy of this cancellation notice or any other written notice, or send a telegram, to Keystone Fire Restoration at 559 Highland Avenue, Carlisle, Pennsylvania 17013, not later than midnight of ,19- I hereby cancel this transaction. `, Owner's Signature IN WITNESS WHEREOF, the partied hereunto set their handsend seals-the day and ear first above written, intending toJ)S-.-, legally bound. WITNESSES: .,,ate - y.lilrliK 7-{lJ' Contractor v A? Waiver of Right of Cancellation I understand that I have the rightto cancel this contractwithout any penalty or obligation within three (3) business days from the date that N was signed. Because of a bonatide Immediate personal emergeneywhich requires immediate remedy, I wish towalve my right of cancellation. The specific nature of the bona fide immediate personal Injury is set forth In my own handwriting, as follows, """'"' 920103 \ y r'sSignature 1T9a?.i to e f?-.•«L ?KEySLONE • CHANGE ORMER' Number l 1052 3IKEKtSLOK,AL70N // ?? __ 2 L/ GENERAL CONTRACTOR 559 HMNIANOAW. CMUSLE PA 17013 JOB NAME /LOCATION _ (717) 243.9595 ?? yam] TO T ..l s?Ani?A -..f-I)v JOB NUMBER JOB PHONE EXISTING CONTRACT NO. DATE OF EXISTING CONTRACT GvrD? d 17 3 / fU/a o/ We hereby agree to make the change (s) specified below: Piz ,>Xf" kv C44 W , ")n W9 - 2#d /-/ - H o r? &,W V't,? UAL.. 944 _ ySoA? wi?dnws no ?r:?/s x7s?.,), 2 fin. -/D 5??ofrdG/ wiirl v1 >,414AA PP AMC, RAWI,00^ It 3 Tkw. )A 9" drr ,- f s ?t,? scrds? W - ? ffy ?1 ??Yf -1 R?s1iiN9? ?I c k 5%GlR 7N? Yl> AML C ilit WAV S ,9nn y ? `aSLt?so . C, p ?n 4 i )I V e ") " ?D'S3 NOTE: This Change Order becomes part of and In conformance with the existing contract. WE AGREE hereby to make the change (a) specified above at this price $ DATE PREVIOUS CONTRACT AMOUNT $ AUTHORIZED SIGNATURE (CONTRACTOR) ?- ??RE?VIISEDCONTRACTTOTAL $ /aessatis above and aand esdspecifications .lwo bepeCrformeedduunddee? Dat'67"tCa?" l\\ same terms and conditions as specified in original contract unless otherwise stipulated. AnyreduadoneInInsurance reimbursement as Signature a result of any of the above changes shag root result In reduction In (OWNER) \tM amounts die convector. KEyStO,A'E SIRE R=09,4 L70N GENERAL CONTRACTOR 559 HIGHLAND AvE., CARLISLE PA 17013 (717) 243-9595 TO lh?. yN a l Y D 6+ Ak, Fkvu4 v ?? ?ou e- iA ) w] d) pood cw r) We hereby agree to make the change (s) specified below: ?5? 0.9-W D H.c CHI` NGE ORDER Number :&:*. 1053 / PHONE JOB NAME/LOCATION NUMBER L DATE I EXISTING CONTRACT NO. JOB PHONE DATE OF EXISTING CONTRACT j G 4 S)?4jA C i-A,? Wa. / Ajj^ •7J4 fY? ? w i7/N ?' 1? ? 1?/.f-rri?? - w?Yllyf? ?i•?k,? ? ??S?.4o 1 #? Thy,??,,?1 Two s?oy??? - ?f?< ii r¢ .-will I/ e 14. ce \l' , (»„?A Yl l c1 NOTE: This Change ,Order becomes part of and In u?? lr conformance with the existing contract. WE AGREE herebyake the change specified above at this price $ DATE Ii /i II PREVIOUS CONTRACT AMOUNT $ AUTHORIZED SIGNATURE (CONTR?LCTOR) I 14 C / ` ,? n A CEPTED - The above pros End specificatio s of this Order j are sa6sfaebryandarehere ted.Allwork tobepe under ? same terms and oondtlons a specified in original co unless otherw(te stipulated. Any ns M Insurance nlm t u a result of any of the above ngaa shall not result In In ualtm \tM amounts due contractor, REVISED CONTRACT TOTAL $ Dal4044OYIO 0§e Signature (OWNERI No fr4aeil- REVsz°NE CHANGE ORDER Number Y 1054 PHONE DATE 37RE RESZOR,AZ'70N GENERAL CONTRACTOR 559 HIIIH N AVE.. CARLIELE. PA 17013 / JOB NAME/LOCATION (7tl) 243-9595 TO I' 1 '1yv ?? s? I JOB NUMBER JOB PHONE EXISTING CONTRACT NO. DATE OF EXISTING CONTRACT j We hereby agree to make the change(s) specified below: r WrliY5 Gtq) 5C P ?e.r? '/i?ar/ C c7'/ii?r. YQ Hivtn (Q?11h, tyj) 5ctlirms r-6 Q-j?t-c -?/ODD 4 dAAiA? JPPA41 YON1??c?! (l Z y ii ?G?I-lA Drr ?v?i ?G ??C.r vi'7? I ?SS ID Z -VU FAA NAB S -l? ?/,J1R C w/ ?` yl-D)?v a- - w?.f p?Cc Lv f C G?.eJ yt VV?nn W LM -bi Scr.?? 6DL -445 4Jvoy - A,-d Dry 6 r d )It0w4 - z r - Y 1.t•iH?/oars - t /- 3' l„?l/w?y *f IW ee4A ?avc ??da,7 S?x3? wi`?6c?? ?- 37? i V /7 k'A I A7 l f? fl ?in N Pc! f)M '# / 4% S6 NOTE: This Change Order becomes part of and in conformance with the existing contract. WE AGREE hereby to make the change (a) specified above at this price $ DATE PREVIOUS CONTRACT AMOUNT $ AUTHORIZED SIGNATURE (CONTRACTOR) ACCEPTED - The above prices and Specifications of this Change Order are satisfactory and are hereby accepted. All work to be performed under same (arms and conditions as specified in original contract unless otherwise, stipulated. Any reducgons In Insurance reimbursement as a result of any of the above changes atoll not vault In reduction In \"* amounts due contractor. REVISED CONTRACT TOTAL $ Signature (OWNER) j KEySCONE f{, I (^ I? ? ?? GENERAL CONTRACTOR 559 HDHIAND ATE, CARLBLE PA 17013 (717) 243.9595-P. 5 I TO M i 1 CHIT NGE ORDER 10?Q Number !""2 PHONE DATE JOB NAME/LOCATION I b 7o UM R EXISTING CONTRACT NO, We hereby agree to make the change (a) specified below: PREVIOUS CONTRACT AMOUNT tr 13 1, m M /4 ;It) mJ 4t,, d, Il?cY PA wr r Yh c ?h ?u c?r bye- YR?I? View adds- 1#,,, ? 7?4eQ yv NOTE: This Change Order becomes part of and In conformance with the existing contract. WE AGREE hereby to make the change(s) specified above at this price DATE AUTHORIZED SIGNATURE (CONTRACTOR) ACCEPTED - The above pries and specifications of this Change Order are satisfactory and are hereby accepted. AN work to be performed under same forms and conditions Be specified in original contract unless otherwise stipulated. Any reductions In Insurance reimbursement as a result of any of Ow above changes shall not result In reduction In \ths amounts due convector. REVISED CONTRACT TOTAL JOB PHONE DATE OF EXISTING CONTRACT j $-3aj730 $ q0,30 Late of $lpance Signaturer?Q,/rt1 7 /?(l tom{ ` , WN_ ?. DV K£ySZON£ W 9I Res OX4 SlON GENERAL CONTRACTOR 559 HDNIANDAW CAALRLE PA 17013 (7171243-9595 T } 11Y :Air Npuk 1 33/ We hereby agree to make the change (e) specified below: ??i)jora) "-PA d-k1 WIAR --::1, 3 wd yA V if I iAe, j Ake, D- C?-0?4n /,) YCL. Z) / ? ? - dip k ??r??cu• cu sue... ?? /1-s? ???? I /h AGd '?iA0 0 oIV41 ?B, q/ifY1 >! r s h, lp'Tu kli, 5 N A N : y?.?Aa 7,94 f 14 kA ON'4 C s9rrw? p?it+t N tc??Nd? w?//-tDr r» ?'-A,??e?i?w/ 111V-I?A, j0d ?W)ft ?ovy ,??L SAAw w y iehbi At v ??v? ' -L` 41op, ` sit, NOTE: This C 7,, Order becomes part of and in conformance with the exia ng contract. WE AGREE hereby to make the change (s) specified above at this price $ DATE AUTHORIZED SIGNATURE (CONTRACTOR) // ACCEPTED - The above pdoes and speoiflcallons of tins Change Order are sailstactory and are hereby accepted. All work to be performed under same terms and conditions as specified In original contract unless otherwise stipulated. Any reductions In Insurance nrlmburasment as a result of any of On above changes shall not result M reduction In \the amounts due oont actor. CHI' `VGE ORDER Number im': 1058 PHONE DPT '?w,e./_/? JOB NAME/LOCATION ?? 50wt--,`- JOB NUMBER JOB PHONE EXISTING CONTRACT NO. DATE OF EXIETINO CONTRACT S/ha, PREVIOUS CONTRACTSIMOUNT $ 9?? era. REVISED CONTRACT TOTAL $ 7 , 5- o.* // 11 Date of accep 7409092013 ce Signature (OWNER( EXHIBIT B 174090920103 "BUILDING ENERGY CONSERVATICG.. ACT" MUST BE COMPLIED WITH AND THE BUILDER MUST PROVIDE THE HOMEOWNER A WRITTEN WARRANTY STATING COMPLIANCE WITH ACT 222. BP DATE Tuesday, March 20, 2001 IMPROVEMENT: Bedroom addition FNAME: Juanita MI: LOC STREET NO.: 114 CNAME: Keystone Fire Restoration CADDRI 559 HIGHLAND AVENUE EXPIRE: 3/7/2002 PERMIT JOB WEATHER CARD LNAME: Pascoe ,>'P PERMIT NOM 2001-0140 MAP: 2 PARCEL: 186 LOC STREET NAME: Fair Avenue C-DBA: CADDR2: CARLISLE, PA INSURANCE: Exempt THIS PERMIT CONVEYS NO RIGHT TO OCCUPY ANY STREET, ALLEY OR SIDEWALK OR ANY PART THEREOF, EITHER TEMPORARILY OR PERMANENTLY. ENCROACHMENTS ON PUBLIC PROPERTY, NOT SPECIFICALLY PERMITTED UNDER THE BUILDING CODE, MUST BE APPROVED BY PENN TOWNSHIP. STREET OR ALLEY GRADES AS WELL AS DEPTH AND LOCATION OF PUBLIC SEWERS MAY BE OBTAINED FROM THE DEPARTMENT OF PUBLIC WORKS. THE ISSUANCE OF THIS PERMIT DOES NOT RELEASE THE APPLICANT FROM THE CONDITION OF ANY APPLICABLE SUBDIVISION OR OTHER DULY ADOPTED RESTRICTIONS. APPROVED PLANS MUST BE RETAINED ON JOB AND THIS CARD KEPT POSTED UNTIL FINAL INSPECTION HAS BEEN MADE. WHERE A CERTIFICATE OF OCCUPANCY IS REQUIRED, SUCH BUILDING SHALL NOT BE OCCUPIED UNTIL FINAL INSPECTION HAS BEEN MADE. POST THIS CARD SO IT IS VISIBLE FROM STREET AND ACCESSABLE TO TOWNSHIP INSPECTORS BUILDING INSPECTION PLUMBING INSPECTION i I 11090 9?0103 BUILDING PERMITS SHALL NOT BE DUPLICATED OR TRANSFERED. "BUILDING ENERGY CONSERVATIO. ACT" MUST BE COMPLIED WITH AND THE BUILDER MUST PROVIDE THE HOMEOWNER A WRITTEN WARRANTY STATING COMPLIANCE WITH ACT 222. BP DATE Wednesday, March 07, 2001 IMPROVEMENT: Siding, window replacement FNAME: Juanita MI: LOC STREET NO.: 114 CNAME: KEYSTONE FIRE RESTORATION CADDRI 559 HIGHLAND AVENUE EXPIRE: 37772002 PERMIT JOB WEATHER CARD LNAME: Pascoe _ PERMIT NO#: MAP: PARCEL: LOC STREET NAME: Fair Avenue C-DBA: CADDR2: CARLISLE, PA INSURANCE: EXEMPT 2001-0104 2 186 THIS PERMIT CONVEYS NO RIGHT TO OCCUPY ANY STREET, ALLEY OR SIDEWALK OR ANY PART THEREOF, EITHER TEMPORARILY OR PERMANENTLY. ENCROACHMENTS ON PUBLIC PROPERTY, NOT SPECIFICALLY PORMITTED UNDER THE BUILDING CODE, MUST BE APPROVED BY PENN TOWNSHIP. STREET OR ALLEY GRADES AS WELL AS DEPTI4 AND LOCATION OF PUBLIC SEWERS MAY BE OBTAINED FROM THE DEPARTMENT OF PUBLIC WORKS. THE ISSUANCE OF THIS PERMIT DOES NOT RELEASE THE APPLICANT FROM THE CONDITION OF ANY APPLICABLE SUBDIVISION OR OTHER DULY ADOPTED RESTRICTIONS. APPROVED PLANS MUST BE RETAINED ON JOB AND THIS CARD KEPT POSTED UNTIL FINAL INSPECTION j HAS BEEN MADE. WHERE A CERTIFICATE OF OCCUPANCY IS REQUIRED, SUCH BUILDING SHALL NOT BE OCCUPIED UNTIL FINAL INSPECTION HAS BEEN MADE. POST THIS CARD SO IT IS VISIBLE FROM STREET AND ACCESSABLE TO TOWNSHIP INSPECTORS BUILDING INSPECTION PLUMBING INSPECTION 114090 920103 BUILDING PERMITS SHALL NOT BE DUPLICATED OR TRANSFERED. EXHIBIT C 174090 920103 AYLOR L MADE ,M April 4, 2003 Invoice # 7296 Submitted To; Ms. Maryjane Pascoe Ms. Juanita Pascoe 114 Fair Ave Hanover, PA 17331 You Are Gonna Love It Description of work completed: 123 Hirdand Avenue Hanover,PA 17331 (717) 646-0947 Removal of drywall in living room area to include ceiling and wall area of thermostat, haul away all debris. Installation of %:" drywall to said areas tape and finishing using drywall compound, prior to introducing a primer to entire room area and a two coat paint system Removal of deteriorated carpet in living room. Scrape floor removing all saturated drywall that had dried, haul away all debris. Installation of fresh Luan board to entire floor area in living room, existing carpet on floor was installed over a painted surface with irregular divots and areas of wood open. Installation of fresh base molding to living room floor wall area (reference thermostat wall) Repair all plumbing in home to include bathroom upstairs toilet repaired was not secure to floor area, plumbing under vanity was removed and replaced with PVC pipe to meet code, Bath tub plumbing was replaced with PVC pipe to meet or exceed code. Application of fresh caulk to bathtub area was never caulked. Remove and replace plumbing under sink area of kitchen. Removed shower glass enclosure from base and cleaned area thoroughly prior to installing shower enclosure using a commercial grade silicone. Installation of all hardware. Remove existing flooring in bathroom due to shower leaking and floor was stained. Installation of new vinyl flooring to entire bathroom area using a floor adhesive. Removal of interior bathroom door, door had to be trimmed at bottom to free up swing, to door was not properly installed j2uazzy ?o??Z171 14(" Home Improvements *Additions* Roofing * Garages * Remodeling * R..:Id:nn P.+vr++rfc * V:nvl Q:d:nn * Tneian Rnad * Rnnlonamnnf wind.v Removal of drywall in laundry room, bedrooms in addition, hallway area leading to bedrooms, upstairs bathroom and child's bedroom. Due to drywall and/or drywall tape was nor properly installed, drywall tape was flaking, Repaired all areas using fresh drywall and drywall tape, sanding of areas prior to applying a primer and paint system to all areas, to include all trim work. Application of a two coat paints system to hallway area, to include a all-trim work. Installation of a new thermostat in living room. Repaired plumbing in laundry room, discharge line from washing machine was not properly installed T-V pM Oa -rL" ' R." f3900.W Deposit draw 52000.00 thank you Balance Due $1900.00 Thank you for giving us the opportunity to serve you. Please note this completed work is guaranteed for a period of one full year, at signing of the work was completed in a very workman like manner and is to the satisfaction of the above homeowners. In the event a problem may occur please call our offiC? at 717.6- 0947. James R. Taylor A-7 -j`- Ms. Juanita Pik `1 - V -C ? date Q zo n-?t Ms. Maryjane Pascoe date 174090920103 D E WILDASIN & SON PLUMBING & HEATING 15 S Main Street Spring Grove, PA 17362 Phone: 225-5397 Sold To: Waynetta Pascoe _ 114 Fair Ave _ Hanover, Pa 17331 Terms Net Cash 06/03/02 The total amount for replacing condensate pump for AC _ system and checked the operation; $137.00 "Yet 141 -Ae- Total amount: $13700 press, Discover We Now accept Visa, Me terCa dd M-/ TERMS: A Charge of one and one half percent er month will be charged on all sums unpaid within thirty days! 6 a ' y7 / STATEiAENT Water Treatment CONTRACT Water Pump Sewer Service Water Heater WILLIAM E. PITTINGER Plumbing Repairs PLUMBING & HEATING CONTRACTORS "Gotta Drip Call Pip" 329 N. Springdale Road Westminster, MD 21158 (717) 359-9877 (410) 848-7368 I DATE --4?,V To J (l C4 A.1 /"// 1 G1 ??s is CJC .. Quantity Description Price Amount Total Material Labor TOTAL AMOUNT DUE ? arJ r- ?? e i?J L/D cad ,:'foo Interest at 2% per month will be charged on all balances for more than 30 days 114090920103 D E WILDASIN & SON PLUMBING & HEATING 15 S Main Street Spring Grove, PA 17362 Phone: 225-5397 Sold To: Juanita Pascoe 114 Fair Ave Hanover, Pa 17331 Terms Net Cash 01/14/03 The total amount for repairing a 3" main sewer line; checked and tightened all connections under sinks; also repaired the shower drain: $175.45 Total amount: $175.45 We Now accept Visa, MasterC04011 f Express, Discover TERMS: A Charge of one and one half percent (M o per month will be charged on all sums unpaid within thirty days! D E WILDASIN & SON PLUMBING & HEATING 15 S Main Street Spring Grove, PA 17362 Phone: 225-5397 Sold To: Juanita Pasco 114 Fair Ave Hanover, Pa 17331 Terms Net Cash 01/09/03 The total amount for rehanging thermostat to wall for htg system (n/c for additional service man who is in training): $48.00 Total amount: $48.00 i We Now accept Visa, MasterC?A American Express, Discover TERMS: A Charge of one and one half perO"90 17? per month will be charged on all sums unpaid within thirty day J (TAYLOR MADETM April 4, 2003 Invoice # 7297 Submitted To: Ms. Juanita Pascoe Ms. Mary June Pascoe 114 Fair Ave Hanover, PA 17331 rr You Are Gonna Love It " Description of extra work completed: 123 Hirdand Avenue Hanover^ 17331 (717) 646-0947 Our original contract had stated to check undeneath crawl space m new addition due to bedrooms were extremely cold. Our finding was no insulation had been installed in framing underneath flooring We had taken pictures of said crawl space prior to agreement of installing R-19 faced insulation 6° in thickness to entire crawl space area using a mechanical nailer for installation. Installation of liquid foam to sill plate area upon inspection of crawl space there was no evidence of sill foam plate barrier on top of block foundation leaving a void Total cost of insulation and IaborS3tF,fl@-.- Thank you for giving us the opportunity to serve you. And once again I am glad to hear you are finally warm in bedrooms and free. 174090910103 ? uazfy qv, ?? At „ Home Improvements *Additions* Roofing * Garages * Remodeling * Building Products * Vinyl Siding * Design Build * Replacement Windows T AYLOR MADETM April 21, 2003 Invoice # 7297 Ms. Maryjane Pascoe Ms. Juanita Pascoe 114 Fair Ave Hanover, PA 17331 123 Hirtland Avenue " You Are Gonna Love It " Hanover,PA 17331 (717) 646-0947 Description of work completed: Removal of existing vinyl siding on front, back and both sides of home. Installation of low a insulation to entire exterior of home using a mechanical nailer for installation. Tape all seams prior to installation of existing siding. Caulking of all windows due to metal work and windows were never caulked and rainwater was evident behind metal work. Remove existing vented sofit on rear of home (addition area), this sofit was changed due to soliit was all vented and only needed to be vented on end comers of home or spaced every sixth panel. Installation of solid sofit according to uWatry standards using only vented sofit on ends of addition and middle area. Cost of insulation wrap on entire home: $2900.00 Cost of caulking all windows: $ 260.00 Cost of replacing vinyl sofit: $ 140.00 Total cost of project: $3300.00 Thank you for giving us the opportunity to serve you. \ [t C1 rtr?0 ?° cCr C- h? -,21 -03 WOW' fl ? 2aa?fy ?o'z?c « 4Y Home Improvements *Additions* Roofing * Garages * Remodeling Building Products * Vinyl Siding * Design Build * Replacement Windows TAYLOR MADETM rr You Are Gonna Love It rr April 31;12003 Invoice # 7298 Ms. Maryjane Pascoe Ms. Juanita Pascoe 114 Fair Ave Hanover, PA 17331 123 Hirdand Avenue Hanover^ 17331 (717) 646-0947 Description of work completed: Removal of existing vinyl siding on from, back and both sides of home. Installation of low a insulation to emire exterior of home using a mechanical nailer for installation. Tape all seams prior to installation of existing siding. Caulking of all windows due to metal work and windows were never caulked and rainwater was evident behind metal work Remove existing vented sofit on rear of home (addition area), this sofit was changed due to sofit was all vented and only needed to be vented on end comers of home or spaced every sixth petrel. Installation of solid sofit according to industry standards using only vented sol t on ends of addition and middle area. Reinstall gutter on rear of home only half of gutter was functional due to a bow in previous installation and holds water. Additional work was needed on north side of home during removal of siding an area of exterior wood lap siding was not installed on home. Pictures were taken of this area prior to authorization of repair to begin. Removal of wood lap siding shims Removal of scabbed in 2 x 4's Installation of 2x4 lumber to said area 16" on center, shore up area on wall due to existing framing was cut and original lumber had no support to the wall system. Installation of R-13 insulation to entire wall area Installation of yr" plywood to complete to exterior Cost of insulation wrap on entire home: $2900.00 Cost of caulking all windows: $ 260.00 Cost of replacing vinyl sofit: $ 140.00 Total cost of project: $3300.00 Deposit Draw $1500.00 Balance $1800.00 Additional work. (wall area) Jr3 -° New baba $2181.00 Please note the above mentioned work is guaranteed for a period of one year. If you have any questions or should there be a problem please do not hesitate to call our office at 717-646- 0947 I hereby Juanita Pascoe a Mary Jane Pascoe are completely satisfied with the above-mentioned work. st? a1a-Gt*-C'_ Home Improvements *Additions* Roofing * Garages * Remodeling Building Products * Vinyl Siding * Design Build * Replacement Windows EXHIBIT D 174090920103 iLll"'e[ii tii I'IC1'1"G:L.. Iii^d':aC)'•'fif?.' I''A !'7'")3J JU A1,411"A P'A5'CUI:C I"t:)!...ID. '5;11.5;'33`7 8100 H. :iJ.!.S pII?;;:, T.J. <# i AYR AVE' ).ID-1AFif pJ.;,(.a?/t)'i IIANWL.R. F`A TCJDF;Y Oit/:t TSI`iE C ECt r-D 11\1 , l0,, 5C) 0A3 TiMG C il7a:: I::L:D OUT. , ?.0 :'•E,:P.S;: I`tOC)I'I "- `..31 I DA'r1'.. CD 1:) I:: E1C:R1`,r.1UI',I AMf:!UP,CT' I'tAL..FII'dC;l_: •.. c, Fy pJ. /C,.4.'tj( J. 1..•..,913 C' 01/04/03 : FClM RLIJ'r :SC.cE; TAX ".21 (:; /04 /03 1 C:(TY 114X it 7 05 . C 'J.,C4./O') I £iAF"fi: WAFiI`ANIT`i 1. ., Cap (7, t:; o1 /04/03 F 3ATIif TAY :iS r75% , . 215 A E, Rl-,11011 RUNT 5o.40 -11 A (11 /015/03 F STATIL TAI Q I 05 /0.') F" .; I. 7 1 T F-, y 1. , TO TAl.-. DUE' '. :}ll FtfCltl I<f_h!l", OO , J:K) 1:4)(311 I`AY„ . . 9 , it t3 i A.1:1if, III-,1 41.2 7 Ct l_. •.r'1 ew ot.i l'- W(-?I F., aAIJG U?L. 1:)i- Viiti".%.. Aoo? a/y -/ Nl, /W7 R60,44 arm- / y N/ ??srs 1,1 #eR511y 6ee4use a?r /le//y ¢?,gt,/t y $/°ei?T o? N/lr?i'Ts D,9vg?Te?P DocTa/? Y/Srls "Ti4Z 1. ? •a.x .a •s 4. ?., ri f; id f-. dpi (71..1f; An 1, 7. .-. i°iU :a with `le'a i .:, 111:, F-?T" CST' i3"J"{`11. 7c1't:. F.-?Fi fild)r C:OI'1't: c,i:: 'l: \%O ll c'?19i?li t. +.]i.1 i?ia f3 - .. qv.-,.-,.. „ :-l r} a l'. J. i.. Fai:i L„.•+li , ?.. I6..T_, :iY pll-L f'P 'i:{i L`:,,,,.i(?. Minr)er;,.t;c.alA[::. 1-o op t, ou't:.,. Vi.faw i?.-u` ':i1.11:)E?r.. i.. :3t),:7t ,, p '9.'.;alcy, 174090920143 f l r)el.:< Accepted OIA.Y if V.I F' 11Fmbey earee?:: t:o :3l.tt;F:r I.:) Debiting- LA1 F1 C.4IJ cI`i i?i:: i:: )J. U.-i LIP) I. c aSince t: 1 & 7/. YF IJPE:R U 116TE_I EIANOVER 40 WETZE::L. DR HANOVER PA 1733:1 (717 ) 630-8808 JUANITA PASCOE: 1.14 FAIR AVE HANOVER, PA 173SI VIP #: TIME CHECKED IN„ ..09:22:3'7 FOLIO. 55953 ROOM, 220 ARRIVE 01/05/03 DEPART 02/07/03 TODAY 01 /07/02 *GUESTS I RATE- 50.40 TIME CHECKED OUT,. REG# 19466 ROOM # SH DATE CD DESCRIPTION AMOUNT BALANCE' "220 D 01 /055 /03 P F'D ONE NIGHT DISC 55.99 -55.99 220 C 01/05/03 E ROOM RENT 50.40 --5.59 220 C 01/05/03 F STATE TAX 3.02 --2.57 220 C 01/05/03 F CITY TAX. 1.51 --1.06, 220 C 01/05/03 I SAFE WARRANTY 1.00 --0106 220 C 01 /05/03 F SAFE TAX, 0.06 --0.00 220 C 01/06/03 E ROOK! RENT 50.40 50.40 220 C 01 /06/03 F STATE. TAX, :3,.02 53.42 220 C OL/06/03 F CITY TAX 1.,51 54..9:3 220 C 01 /06/03 I :SAFE: WARRANTY 1.00 55.92 220 C OL/06/02 F SAFE TAX 0= 55.99 a e•*# r * ?;c•x•? TOTAL. DUE . „ .., ., 55.99 ROOM RENT,.. 100 80 ROOM TAX.... 9.1B SAFE,.. ,. ,. ,... 2.00 DISCO VER., ., „ 55 .99 Writ e Box 279 70,• Mnplm., MN 53427 or view our webs:,ite about: privacy,. Please contact the manager about any issue with your stay. Super 8 Mot.elm, Inc. or affiliates, may contact you about goods: and services unless you c.al.l. 877-244-7633 or write to Box 27970, Minnsapolis, MN 55427-0970 to opt out. View our Super U webasite about privacy. 114090 920103 Checks Accepted ONLY if V..I.P Member agrees to Super B Debiting returned check plus up to $25. See gent card., JUANITA PASC01=:: L14 FAIR AVE: HANOVE:R, FA 17.SSI ;UP ER 0 MW EL I IANOVL" R 40 WE:T iT: L DR HANOVER PA 17331 (717) 630--GGG 0 VIP # TIMF:_ CHECKED IN..16:29:55 FOLIO. 55431 ROOM. 220 F' EG0.. 15'509 ARRIVE 01/09/03 DEPART 01/LL/02 TODAY 01110102 RATE-50.00 TIME CHECKED OUT.... ROOM ,t S13 DATE CD DE SCRIPTION AMOUNT BALANCE 220 D 01/09/03 F' PD DI SC.. 55.56 "55,56 220 C 01 /09 /03 E• ROOM RENT 50.00 -5.56 220 C 01/09/03 F STATE: TAX 00 -0.56 220 C 01/09/03 F CITY TAY. 1.50 -7.,.06 220 C 01/09/03 1 SAFE WARRANTY 1.00 -0.0 , 220 C.: 01/09/03 F SAFE TAX 0.06 ....0.00 2 20 5 01/lo/03 E ROOM RENT 50.00 50, 00 220 B 01 /10/03 F STATE TAX 3.00 53.00 22.0 D 0I /10/03 F CITY TAX L.50 5 So 220 B 01/10/03 1 SiAF'T:: WARRANTY 1.00 55.50 220 D 01/10/03 F SAFE TAX 0.06 55.56 t..K..,?. .K.;f;?..h. ..?.?.. TOTAL . DUE::.,„„.,. 55.56 ROOM RENT. ,. 1= 00 ROOM TAX,... 9.12 SAFE" .. .. .. .. .... .. 2.00 DISCO VER., ., . 571 .56-1 Writ e Box 279 70, Mnp:lm,, MN 55427 or view our website about: privacy, Please contact: the manager about; any issue with your sLay., Super- E3 Motels, Inc. or affiliates may contact you about goods and services unless you call. 877.244--7633 or write to Box ^27970:, Minneapolis, MN 55427--0970 to opt out. View our Super S websife about privacy. Checks Accepted ONLY if V,.1,P Member"1l44;W- J&+ Super- f:3 Debiting returned check plus, up to $25. See tent card, S LJFE.1ID MCC)TE_L. IIAIAily I-" 'rG hff.::T':'CL. DR' IIAN11Vl R PA 1"33i t 71.7 7 ...,::)t") r3r:;:3!i'r JUANITA PASCOE' HANOV11R, PA 11 17 "n 3 1 V): r- #- TIMC:: C;til_:CICP_r) IN. ,. 10. WS. 41 F01-10, >5331'3 RD[tl"I. '12:14 ARPlYE nr_:rArr t?1/c5/o-) TDDAY 01/13 'Cl,:) W31JES)TS it RA 1 E... .5'0,10. C) TIME'. (DUT. RDOM .) SI1 1)A7F. G:) DE.SCRIF171 1\1 AMDUh!'1' DAI-ANCE' =! ). 'F A ! ). /04 /o'') P 1-11) CC: 1. ). 1. ,. `?f:? -:114 C 01/04/03 E ROOM RENT 0„4t) ?1<- C 1./04/oD F 'TAT[:: TAX :).0r' -3 214 C (.-):I /i)4/o r C IT'; 'TAX 1 ..1 1 -57. 0!5 c 14 C; (71 /04,102 ; r;AF E WArJRANTY 1...00 -' jb . ? c'l4 C 01 /o4/0:;1 F SAFE TAX .),!7r) !i' . `?'+ ? .4 A 01 / (.)!cT/C.,D 1 ^'1 ATr:, TAX 2o"'? - 112 15 7 E:'.14 , o l P"'5/r:i.') F CITY T.<1X J. .'; 1. - 1. ,(W. A 01/ )!:;/0:3 T !:)AF:. WARRANTY 1,. f, n_) [L - E" 'I A 0,106 (...0C, w.? x. #(. .; .u. TRTAL r)I.Jf:.:...... -0.0("1 F2DC11°I RISh!1 .. 1 t7(:) . l?C) R001 1 'TAX.. . t? ;iiAP ri ., . .. . ,. . 2 ? 00 U10ClCly :R.... 1.1.1 .9(:3 Writ e Box, 274 °?i), Mrip1s .: MN or View OLlr W+:rl]sia tCr at-70Ltt r)1'-i VaCV. Please con.f:aC't the marlage.1- about: any isi':iue with `/il l11' l.it:a`!., Supel- r? 1'I0tel=i, Inc. or a'f'filiate m6a. ' r.:orlti. iCt you al:10L.lt go0d!ll and :Ti ti r'V 7. iC: ii ullle:iii5 you 'a).1. 0,"'.7-244-76-r) or wr i'f;e 'to Do:} P'7770.. Mi.nneapol ils; MN ;_*154x2'7-01;170 to opf. _nu't,. View our 4 upe'r' E3 174090 920103 Checks Accpp terl ONLY if V.. T . P MrMber agree<.:, t:a E;Lti')F r f:l Del:, i t:.', ng r.:1r'I'It: ;a E.7 ). !.b:Ei Ll.j:i f)0 .}:. c:...., , ..3c7e :t?fit: _, P'Cl •UPLP rs rloTl_L.. HANOVER 40 WE:T a'C"t_ DI=t HANO'dl:_R PA 17331 ('717) 630-4."BOO JUANITA PASCOL' 114 FAIR AVE FJANOVE.R. PA 1.7.':;:;1. V1F> d#: TIME. CHECKED :lh!...16; 50;:224 F'OL.10.. 553512 ROOM, 219 ARRIVE 01/0,51/o3 DEPART o 1. / 11 !03 'T'ODAY #.'.',U-STS :t RATE:., .50..40 T1MFi_ I:FII:cF=:I:a? OUF. ,. REDI# ? 19464 ROOM # SI-I DATE CD DCi: SCRIPTTON AF10t.1N'1" DAL-AFdCE 219 B 0J /05/0 3 P PD ON E: NIGHT DISC 55.'? '1 5`5.97 H19 C 01/05/03 E ROOM RENT 50,. 4C) 9 c'!19 C (I/0F..;103 F ST'AT'E TAY c3,(ii' '..5^ 219 C p1 /05/03 F l.',Il'Y TAX 1 , 5:1 1 .,06 219 C: 01. /05 /03 1: SAFE: WARRANTY I " C 10 0.06 £219 C ol/Or;/o:3 F' SAFE TAX 0.06 -°V.00 219 C 01/06/03 E ROOM RENT 50„40 50,40 219 C 1: 1106/0;:3 F STATE 'TAY, 3, 0u. t{3.42. 219 1: 01 /C!6! 0" F CITY TAX 1..51. c;4 .9 i 3'll9 f.; iia!C?6/li3 :f ':iAl''G: W(-3F:14APJ'1"Y 1.00 1`55 93 219 C 01./06/0:3 F '-;A'E TAX 0,06 715,99 219 C 01/07/03 E ROOM RENT ',0,.40 106.39 219 C 01 /07/03 F STATE TAX 02 109, 41. 219 C 0110'7/03 I" CITY 'TAY. 1..:51 :110.. 1?2 21. C2 C 01 /117!0;:3 I SAFE WARRANTY I.. CIO 11L, 92 P19 C O1 /07/0;:3 F' SAFE 'TAY, 0.OC> 11 , 90 is 1.9 C 01/08/03 E ROOM RENT 50.40 162 .,'30 x9 C 01 /00/0;3 F' STATE TAY, 3. 0112 165.40 a C; 01. /00/03 F CITY TAX 1 51 166. 91 I' :t9 C: Ol/063/o::) I SAFE WARRANTY 1,.00 167.9:1 F2 19 C; ill. /0C1 /OS? F i AFE: 'TAX 0..06 J. 617.19117 '19 C 01/09/03 F ROOM RENT 1_50.. 4 210. 3 F!19 C, 01109!0.') F' s'TAT"E TAY 3,012 2211.39 1:19 C 01 /09/0;3 F 'T'AY. 1 ,.'SI 211!2.9ii :!19 C.: Cif/017/0 3 1: SAFE: WARRANTY ()Cl J., 222 911 219 F, 111/0'?/0.3 F. SAFE TAX 0, 06 2Z-_'3. '?6 219 El 01110/03 E ROOM RENT 5)0 110 274..3.6. 21 C? D 01/act/0$ F STATE TAY, 13 0,12 21.117 ;1313 219 I; 0111.0/0 3 F CITY TAX 1 ,5 1. c2..70.09 219 B Ol/:lo/03 I '.3AF'E WARRANFY 1.(m) 3;'g. SIP E.19 n 01./10/03 F' =SAFE: TAX o..06 27('11. 95 MASEMER'S CUSTOM FLOORS 515-517 u /? Phone 632-2362 Baltimore St, ICA MO HAWK Hanover, PA 17331 WALL-TO-WALL CARPETS AND RUGS RPET VINYL FLOOR COVERING Sold I , Date ?? /d13")(Q ? -ea? ?'?, f??/A•r?s???lD?b° Qxo.?? . Sys 3 ) ? .1 41 ;2 1 Jaw- 9`7 7 TERMS: 30 Dare Net. Balances remaining unpaid at due date are sublett to service charge of 1/r Percent per month until paid. urniturw P Date: 3/31/001 6520 CARLISLE PIKE INVOICE NO. 1 67098-00 Time: 15:09:49 SUITE 400 Gage: 1 of 3 MECHANICSBURG, PA 17050 (717) 766-2700 DEL P/U PASCOE, JUANITA M 114 FAIR AVENUE HANOVER, PA 17331 u u ? v HOME (717) 632-2479 ;E ?( al DEL ??Y9??.99K:F:[•L • YaK399? 1.3.1.?;r • .u3?w9:at??rtl?,ldv[•1[N7ne? Price Hold'NEIDIGH. BOB 31 3/31/2001 SKU ` x"' Ek'a'• f I MA ?6R ITEiN r A t t t AS M+ ft Sf he t}1 ,'?7.{,'t SAL }'f H5 ! 4 21 ekz_ I ? A , '; EXTENSION I : e l a t1 i?ia)? k 5 5 Y +?tw 4 .. 618322 S-1174-G 5 PC DINETTE-SEA ISLAND PINE 1 399.99 399.99 609 TABLE/4 (S1135) SIDE CHAIRS 618128 S-1135 SIDE CHAIR-SEA ISLAND PINE 2 1 69.99 139.98 609 649236 1090-PB RETRO ACCENT CHR-PORT BURGUNDY 843 COVER 3402-24 Guardian - W 537713 00011D0-1M I GLIDER OTTOMAN-MAUVE 24 ,19128 ,Guardian - W 674362 6000E-79 'DUAL RECL/ROCKING LVST-MAX TAP 65 W/TUCKER HUNTER Guardian - S I ; THANK YOU Value City Furniture is an institution dedicated to Better Homes for Better Living. Its object is that your purchase will give you pleasure and complete satisfaction. Remem174090920103 ber you can buy anything for your home on very liberal terns at Value City Furniture. SEE REVERSE SIDE FOR TERMS AND CONDITIONS CUSTOMER - RETAIN THIS COPY FOR YOUR RECORDS 1 199.99 199.99 39.99 1 139.99 139.99 19.99 1 699.99 699.99 49.99 BALANCE DUE e`t OoN1YNUEV a.1!..JFurniture :e: 3/31/2001 le: 15:09:49 3e: 2 of 3 PASCOE, JUANITA M 114 FAIR AVENUE HANOVER, PA 17331 HOME (717) 632-2479 6520 CARLISLE PIKE SUITE 400 MECHANICSBURG, PA 17050 (717) 766-2700 u rr iryi IIs? .V c, INVOICE NO. 1 67098-00 DEL P!U Price old NEIpIPH, POB 31 SKU.-. `irtMA.?Ofi I' M iF k? ,-? r ns ! ''?,'t: Dpp??((!!pp??PTIO'7S;` AMP '' TJ;.:bs.,?ro 743354 60006-88 (DUAL REC SOFA-MAXWELL TAPESTRY 1 699.99 5 W/TUCKER HUNTER 'Guardian - S 26139 VC-104-3P 3PC TABLE SET-CAPRIOLE PINE VP 1 199.00 67 ;COCKTAIL/2 END TABLES 43166 8884-43 NIGHT STAND-WASHED PINE I 109.99 71 40609 4884-17N CHEST-GREEN & NATURAL 3 199.99 '71 j 40668 4884-43 NIGHT STAND-GREEN & NATURAL 3 109.99 ,71 37683 C6847DO-1M SOLID OAK GLIDER ROCKER-MAUVE 1 329.99 '4 19128 'Guardian - W I f ' I i i THANK YOU Value City Furniture is an institution dedicated to Better Homes for Better Living. Its object is that your purchase will give you pleasure and complete satisfaction. Remem- 174090920103 bar you can buy anything for your home on very liberal terms at Value City Furniture. SEE REVERSE SIDE FOR TERMS AND CONDITIONS 3/ 31 /4:001 EXTENS10N L99. 99 59.99 199.00 109.99 599.97 329.97 329 99 29.99 CUSTOMER - RETAIN THIS COPY FOR YOUR RECORDS BALANCE DUE Ti?UEtI`; V:jLj F'urmture ate: 3/31/2001 ime: 15:09:49 age: 3 of 3 / PASCOE, JUANITA M 114 FAIR AVENUE HANOVER, PA 17331 HOME (717) 632-2479 I ?t 6520 CARLISLE PIKE SUITE 400 MECHANICSBURG, PA 17050 (717) 766-2700 Is u W 11 la 4 INVOICE NO. 1 67098-00 DEL P/U DEL Price Hold'NEIDIGH, BOB 31 3/31/2001 SKU ` Malbp ITW I DESCRIPTION IQTY IAMOUNT ?.. EXTENSIONS I ? I This Receipt Must Be Retained For Merchandise Returns Or Refunds. I have received a copy of the Value City Furniture Service Policy I I have read and understand the posted Price Hold Policy C.O.D. AMOUNT 3,950.00 All orders must be prepaid B-4 scheduled Pick-up Hrs Mon-Fri 12-8 Sat 10-8 Sun 12-4. Msde. Pick-ups Held 24hrs... THANK YOU Value City Furniture is an institution dedicated to Better Homes for Better Living. Its object is that your purchase rill give you pleasure and complete satisfaction. Remem- ber you can buy anything for your home on very liberal terms at Veiue City Furniture. SEE REVERSE SIDE FOR TERMS AND CONDITIONS Merchandise Total... Delivery............ Guardian............ Sub-Total.......... Sales Tax 6.0X..... Invoice Total....... T^`-i' Payments...... 114090920103 39848.85 89.99 199.95 4,138.79 248.34 4,387. 13 437.13 BALANCE DUE W?•`i5,:%i °'' CUSTOMER -RETAIN THIS COPY FOR YOUR RJFG10RDS 3 95A. Dim FROM : SERV ICEEMAASSTER CLEAN BY DAN i FAX NO. :7178489570 n. 16 2003 01: 37PM P2 I IJ,P/ ?Zce AffER Disaster Restoration scrvlceMarter Clean Services Ivy Daniels Q?M/l` P.O. Box 7204 ? York, PA 17404-0204 PA: 717/94&9565 ibll Frew 877/582 1 975 Pax: 717/8489570 A C aflAy AwemoMn Vendor 1* January 16,02003 To Whom It May Concern, Please note that we, ServiceMaster Clean by Daniels serviced Mrs. Juanita Pascoe on Wednesday, January 15,02003. The result of our technician is as follows: Sofa - Latex paint on cushion and armrest Chair - Latex paint on cushion and back of chair. Loveseat - Latex paint on every cushion and armrest. Glider Rocker and footstool - Cleaned up well - Mrs. Pascoe was told to wait until it dries to determine whether or not stains did come out. On our follow up call to Mrs. Pascoe she said that there are still 2 marks on the footstool, All furniture was wet and saturated for days. Cannot guarantee mold spores will not grow. Mrs. Pascoe paid $157.00 check #1457 Aline Berenstein Al AAA 1920103 An Indepe"dmi /lkdnnxx lnxnsod In Nrl! Wn1 M'.SNrW(NA7[uttlr (.704n COUNTY OF YORK OFFkvil OF THE SHERL F SER"'CEC"LL ,?- ,(717) 771-960 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE I INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPIES _.. 1_-._.._. 1. PLAINTIFF/S/ 2. COURT NUMBER M/4??JAN JvANfro g S?t? 200 U28 4. TYPE E OF OF WRIT R -2 OR COMPLAINT 3. DEFENDANT/S/ Kf3`FSTfl^t ?r ( V1 ` W a'Km L-0 M. o tJ cb ba I I c1CA SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ET . TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. M t L-l-l A--M I.L , C7 ? "L--c7KoN G fi. ADDRESS ((S REET OR RFO JWITH B'OXXNNUMBj[RR,, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE AT ? 7. INDICATE SERVICE 5IiPE?R50N' ? P RSON Ir CHARGE IXDEPUTIZE. MAILS ?O S7 CLASS ? POSTEDO t OTHER NOW June 30 , 20 03 I, SHERIFF OF YORK COUNTY, PA, do by deputize the sheriff of Cumberland COUNTY to execute this Writ an return the or ing to law. This deputization being made at the request and risk of the plaintiff. d. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. ADVANCE FEE PD BY ATTY $100.00 NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATU 10. TELEPHONE NUMBER 11. DATE FILED ?ik fIZ1Sto I??STi?l? Co3?- Sl 8S G 12. SEND NOTICE MI HC)SE COPY MEnn? ADDRESS IFF,. g s.; Medj(?p1' tob ? P..Ay4Ql? lvGf3`'El+?_ rU ,IC.y?'1'kt C'L !j d i i81rC 1tf0 USV F VHIE1 RDOit?tYT BELt31iVT, LINE 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/1-198e or complaint as indicated above. B. Feeser 6/19/03 7/19/03 16. HOW SERVED: PERSONAL( ) RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFFICE( ) OTHER ( ) SEE REMARKS BELOW 17. U I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 18. NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date f Service 20. Time of Service -Pow 21. ATTEMPTS Date Time Miles Int. I Date Time Miles Int. I Date Time Miles Int. I Date Time Miles Int. I Date Time Miles Int. I Date Time Miles Int. 22. REMARKS:`.. t,0 C) 210091140482 c' Z 23. Advance $75 Q1D 1 Service Costs 25. N/F 26. Mileage Postage 27. 28. Sub ?a? 29. Pound 30. Notary /fur 32. Tot Costs ? /4O'? r Refund ICheck No. I6 1"7q 34. Foreign County Costs 135. Advance Costs 136. Service Costs 137. Notary Cert. 38. Mileage/Postage/Not Found !/ 139. Total Costs 140. Costs Due or Refund 41. AFFIRMED and subscribed to before me this SO ANSWERS 44. Signature of 45. DATE 42. day of , 20 _ 41 Dep. Sheriff PROTHY /NOTARY 46. Signature of York ?? 47. DATE County Sheriff - 7 ^,-1('] ^'? 48. Signature of Foreign 49. DATE ?l.J County Sheriff 50. 1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 151. DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE- Issuing Authority 2. PINK - Attorney 3 . CANARY-Sheriffs Office 4. BLUE - Sheriffs Office G r T cv ?J W" Q 1 N_ 0 E CL. 7 k.- t LLI 4j O -I C.r-' U > ` IL O CO) O os a Wd TT Inn co, SHERIFF'S RETURN - REGULAR CASE NO: 2003-00415 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PASCOE MARY JANE ET AL VS SALOMONE WILLIAM K ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SALOMONE WILLIAM K AN IND D/B/A KEYSTONE FIRE RESTORATIO DEFENDANT , at 0020:12 HOURS, on the 8th day of July at 559 HIGHLAND AVE the 2003 CARLISLE, PA 17013 by handing to w WILLIAM K. SALOMONE rc _1 U a true and attested co ~ z ? copy of COMPLAINT & NOTICE together wzt'h' '-- -9 o -' 3 rT ys rT, N _ -,; u n O and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit 2.50 Surcharge .00 .00 23.95 So A 0482 R. Thomas Kline P 07/09/2003 CHRISTOPHE Sworn and Subscribed to before By: me this day of C l -? __ A.D. YLAUDIAA.8 tEt ( PI?L IC (?,?r I ?KbCR '"r " motar)? F;: 114,2005 Sheriff ¦ Complete Remo 1, 2, and 3. Also complete item 4 if Restricted 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 hack of the maiipiece, or on the front if space permits. 1. Article Addressed to: Xi^'L+ti"r^'w Waj5t'd U Agent Addresses B` 5?170cd 4.rj.7 JUL Ct/?a?All arv D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: C1 No m? R. THOMAS KLINE t CUMBERLAND CO SHERIFF' 1 COURTHOUSE SQUARE CARLISLE PA 17013 3. Service Type XN Certified Mail 0 Express Mail ? Registered 0 Return Receipt for Merchandise 13 Insured Mail ? C.O.D. #2003-SU-2824-01 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number 7001 0360 0000 6230 2668 (Transfer froms -_._-- PS Form 3811, August 2001 Domestic Return Receipt 102595-01-M-2509 ,a,mi rr e rr v. ?., a. re r•e co .n nj #2003-6'U' 82' 10f' C3 Postage $ M 11-t C tifi -.o er ed Fee C3 Rtum ecei Fee (FntloreeemeRnt Required Postmark ) Here C3 Res Mcted Delivery Fee C3 (Entloraement Required) C3 Total Postage a Fees $? M at C3 R. THOMAS KLIN -sin C O M B EP L A N D CO SHERIFF ---•----•-•-••---•--- C3 a'F 1 COUPTHCUSE SQUARE CI c i t y , C A R L I S L E PA 1 V1 1 n --------- 171 Mary Jane Pascoe and COURT OF COMMON PLEAS Juanita Pascoe CUMBERLAND COUNTY Plaintiffs V. CIVIL ACTION - LAW . William K. Salomone, an individual DOCKET NO. 2004-00404 d.b.a. Keystone Fire Restoration JURY TRIAL REQUESTED Defendant Notice to Defend YOU ARE HEREBY NOTIFIED TO PLEAD TO THE WITHIN COMPLAINT WITHIN TWENTY (20) DAYS OF SERVICE UPON YOU OR A DEFAULT JUDGMENT MAY BE ENTERED 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 CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. You should take this paper to your lawyer at once. If you do not have or know a lawyer, then you should go to or telephone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY BAR ASSOSICIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 "ISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defendrse de las quejas expuestax en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o por abogado y presentar en la Corte por escrito sus defenses o sus objections a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demando o por cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTE DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOSICIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 2 Mary Jane Pascoe and Juanita Pascoe Plaintiffs V. William K. Salomone, an individual d.b.a. Keystone Fire Restoration Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW DOCKET NO. 2004-00404 JURY TRIAL REQUESTED DATE: February 02, 2004 FIRST AMENDED COMPLAINT Plaintiffs, Mary Jane Pascoe and Juanita Pascoe, by and through their attorney, Christopher Restak, file the following Complaint against Defendant, William K. Salomone, an individual, doing business as Keystone Fire Restoration, and for cause state as follows: JURISDICTION AND BACKGROUND FACTS Plaintiffs are individuals, sisters, currently residing in Hanover, Pennsylvania and owning property located at 114 Fair Avenue, Hanover, York County, Pennsylvania. 2. Defendant is an individual, d.b.a. Keystone Fire Restoration, located at 559 Highland Avenue, Carlisle, Cumberland County, Pennsylvania, and conducting business in York County, Pennsylvania. 3. Plaintiffs hired Defendant, under a written proposal, to perform construction Services at their residence in Hanover, York County, Pennsylvania (hereinafter referred to as the "premises"). A copy of the Defendant's contract and billing statements are included and incorporated by reference as (Exhibit A). 4. Plaintiffs aver that the proper jurisdiction for this action is Cumberland County, As per the conditions of defendant's contract (Exhibit A, Article 9). 5. Plaintiffs maintain that the work, undertaken by Defendant, was substandard and that the Plaintiff s damages are a direct result of defendant's breach of contract in failing to provide construction services, consistent with the contract requirements, in a manner that would meet reasonable, industry standards. 6. Plaintiffs have suffered damages as a consequence of Defendant's substandard work and the Defendant's inability to correct the deficiencies. 7. That the type of damages that plaintiff's have incurred are not the type of damages that occur in the absence of negligence. 8. Plaintiffs pray for relief, under the following theories, as outlined in Paragraph 8 through 31 as hereinafter set forth. 4 COUNTI BREACH OF CONTRACT 9. Plaintiffs hereby incorporate by reference the facts and allegations contained in Paragraphs 1 through 8 hereof as if more fully set forth herein. 10. As set forth above, Plaintiffs and Defendant contracted for certain improvements to be completed at Plaintiff's home in York County. Improvements consisted of the repair of the home from the damage done by a fire that occurred at the residence on or about January 27, 2001. 11. In order to obtain Defendant's services, plaintiffs were required to waive their three-day right of cancellation following the execution of the contract, as a consequence of the bona fide need to start repairing the home, "as soon as possible" despite the fact that defendant did not begin work until March 17, 2001. 12. Defendant completed the scope of work, within the period set forth for completion, and Plaintiff's fully compensated defendant for the work. 13. Subsequent to completing the work, plaintiffs suffered two successive, major plumbing leaks that occurred as a consequence of defendant's improper installation of plastic pipe-fittings, causing a flooding of the main living area of the home. 14. Subsequent inspection by a certified plumbing contractor noted the improper installation of plumbing parts, in various locations of the home. 15. Defendant had obtained permits for the construction but had failed to obtain any plumbing permits, stating that the work that they were doing was "replacement" work for previously existing plumbing. A copy of the existing permits for this project are attached and included, by reference herein, as (Exhibit B). 16. Plaintiffs also discovered that defendant had either negligently or intentionally covered over heating supply registered with finish carpet, thereby preventing adequate circulation of heat to the rooms at the rear of the home. 17. Defendant's work was substandard and Plaintiffs have been required to expend upwards of $7600.00 to complete the work in the manner that was originally described in the contract. 18. As a consequence of Defendant's substandard work, Plaintiffs have been damaged. Attached hereto and incorporated by reference as (Exhibit Q are invoices, proposals and receipts for the repairs necessary to complete the work and repair the damage that resulted as a direct consequence of defendant's substandard work. 6 19. In addition the Exhibit C, detailing the construction costs to repair and replace the damage the plaintiffs were required to make various expenditures to cover the costs of the damage to property that was a direct result of the damage when the flooding occurred. Attached hereto and incorporated by reference as (Exhibit D) are receipts for replacement of furniture, carpeting and for the stay in alternative accommodations for the week immediately following the flooding. 20. Plaintiffs pray for relief from Defendant's actions that have deprived them of the use of their home. Plaintiffs seek delay damages to compensate them for their loss of enjoyment of the facilities for the duration the time during which the home was rendered uninhabitable as a consequence of the flooding, caused by defendant's substandard work. COUNT II NEGLIGENCE 21. Plaintiffs hereby incorporate by reference the facts and allegations contained in Paragraphs 1 through 20 preceding as if more fully set forth herein. 22. As Set forth above, Plaintiffs and Defendant contracted for certain improvements, otherwise referred to as the project. Plaintiffs relied upon Defendant's superior knowledge, concerning construction matters and details, particularly as those matters related to general carpentry and plumbing and mechanical installation(s). 23. Plaintiffs reliance upon Defendant's superior knowledge was reasonable considering Defendant's professed expertise in those matters for which Defendant held themselves out as performing as part of a trade or business. Defendant's given business name "Keystone Fire Restoration" and their advertised claim of being "Carlisle's Only Fire Specialist" would imply a familiarity with work of the nature that was performed, on behalf of plaintiffs, and equal to or superior of other firms performing similar services in their community. 24. As a direct consequence of Defendant's breach of their duty of care to the Plaintiffs in undertaking this project, Plaintiffs suffered damages that were foreseeable to Defendant. 25. Plaintiffs were not responsible for supervising Defendant's work nor did they assume any responsibility for directing Defendant, or any of Defendant's agents, in the execution of their work. Furthermore, Plaintiffs did not interfere with Defendant's access to the site nor did they, during the course of the projected construction schedule, bar Defendant, or Defendant's agents, from the site. 26. Defendant was to complete certain repairs to the plaintiffs home, following a fire that occurred on January 27, 2001. The repairs were to be completed in a workmanlike manner and were to be completed so that plaintiffs could re-occupy their home. The damage that is the subject of this Complaint occurred, following completion of the work but was caused by a rupture of the bath room plumbing supply line, causing extensive flooding and property damage to plaintiff's home and personal belongings. 27. It is alleged that it was as a direct consequence of defendant's negligent installation of plumbing supply valves that the flooding occurred. 28. Although defendant's contract, with the plaintiffs, warranties the work for one- year from completion of work or occupancy of owner, whichever appears first, the condition complained of, faulty workmanship, was a "hidden condition" that plaintiffs would not have been aware had the flooding not occurred on or about January 3, 2003. 29. Plaintiffs would have been aware that the plumbing was negligently installed, had defendant obtained plumbing permits, as required, and had the work therefore become subject to inspection by the local building department. 30. A copy of expenditures, undertaken by plaintiffs in fixing the work is included herein and incorporated by reference as (Exhibit D). 31. As a direct result of Defendant's negligence Plaintiffs have been greatly damaged. Plaintiffs seek damages in the amounts as enumerated in the following paragraph(s). Attached to this Complaint and incorporated by reference as (Exhibit C) are invoices, proposals and receipts for the repairs necessary to repair the premises and (Exhibit D) covers the costs to replace and/or repair the personal property damages as a consequence of the plumbing failure. WHEREFORE, Plaintiffs, Mary Jane Pascoe and Juanita Pascoe, request that this Honorable Court, award judgment against Defendant, William K. Salomone d.b.a. Keystone Fire Restoration, in favor of Plaintiffs in the following amounts: A. $3,900.00 representing the cost to repair the premises following the flooding. ii. $137.00 representing the costs to replace a condensate pump for newly installed air conditioning system. iii. $135.00 representing the costs to reset the toilet and shower in the downstairs bath. iv. $175.45 representing the costs to repair a 3-inch main sewer line connection that had been installed by the defendant. V. $ 48.00 representing the costs to re-hang a thermostat that had been damaged in the flooding. vi. $ 3,300.00 representing the costs to properly reinstall the exterior siding that was incorrectly installed as part of the original work. 10 vii. $ 671.88 representing the costs to temporarily obtain alternative housing while the house was cleared of debris, following the flooding. viii. $ 829.71 representing the costs associated with replacing the carpeting in the main living room, located immediately under the bathroom that flooded. ix. $ 2,069.95 representing the costs associated with replacing the furniture that was located in the main living area. X. $ 157.00 representing a billing from Service Master indicating an attempt to clean the furniture and a statement that they "could not guarantee that mold spores would not grow" in the furniture, following the flooding. B. Award Plaintiffs reasonable attorney's fees consistent with defendant's contract, paragraph 11. C. Award judgment against defendant, William K. Salomone, t/d/b/a Keystone Fire Restoration, in favor of the plaintiffs, Mary Jane and Juanita Pascoe, in the amount of $11,418.99, consistent with the expenses incurred by plaintiffs and outlined above. Restak, Attorney -_---2'f3 Carlisle Street Hanover, PA 17331 (717) 637-5188 PA Supreme Court ID# 81514 Attorney for Plaintiff February 2. 2004 11 VERIFICATION We hereby affirm that the facts contained in the forgoing First Amended Complaint are true and correct to the best of our knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. C.S., Section 4904 relating to unswom falsification to authorities. Date: February 12, 2004 By:?? _ Mary Jan e Ras oe ?z- By: - J to Pascoe 12 EXHIBIT A KEYSTONE FIRE RESTORATION 559 HIGHLAND AVENUE (717) 243-9595 CARLISLE, PA 17013 //?? CONSTRUCTION UCTION AGREEMENT THISAGREEAIENrmWbwf? 01 :r WAN ,by&Wbe~ xEYSTCNE FIRE FIESTGRATIGNW559 Hgh Awnu,CNisN, ftmVWWa 17013 (MrabwMr nlardw•d w Cmb•eNt 'AND - f* r -C merehW u dembon of ow ?n. clean. u robes: bola at b ba r v wmporary repass atiMl be AS upon mnplalon. For aA o111d wpat, pvanFIl pry b C«N•cbr br lib p•rl«m•np Ixq•r thi• Apu rfl the aunt of Ookwe. u larawc ek-) C-e g l.lp 4 <7rn rn 4:.,;? 1 WM won Ow"M upon connerawn"4oW d! a atn p,* • ft Writ 1 (a•lil+` r'/c ?PMU,) ft_ conrODIWn li rW"fd up«1 suWw VIANUVtlW of orrh n of iM W agmW w t u d*Wn W by by C Cantrau«;oo '«« CI`'//rci I ?+M It, , k7', AsoftrMbedaw tlm Kloo s 1O o wr igey. Mm ""01 by b/OA+wr of o1 to Mw. YmoM bhuwrak G tln• No ion (10 (10) dafwlarg ,poWftInveb"ndo-WIb•vhM Norsendwn(10)drypdodbtlw"of"ubo.WtMront(1 I,ectlv nft Conn0"69M w Contr all INM pedy Md• for Ws b•m•adon iwm I•rw«•, iro r oompw es or IM IM end • nhorixu suds WN pwdn b rn W pa ment, Mn wa muandy acoapwd• Ibwr,dM lodt,dn n an Insured sumo C«,IMlar IIrIIMI .hM not Mutr in fw Mere ntinwu, aM no dw s, Mwrad«w or Wdwons sMll b M*W of n In Inwno MmNes,mem u • .It of Iny $u tl,anpes, •henbn. or a bons Md 14. You, the Owner, transaction. See the as l1 tldrym+A W ?..kr,??-?,?, .Sr n, MI a fw pens, hereto. ramr. Trauf«dddebywlll,eUMWMMp p«ty may M now. prwrudwawndln0sorw wno«MagreemenwbewwenbanrdeswibmsWt upon iM n oCII" Min. •s•obrk Wminlatrwsln,.wo•.«s wM b ft extent as,lynebis, uWgn. or n«niraw. of ft panes hweto. cancel this transaction at any time prior to midnight of the third business day after the date of this d notice of cancellation form for an explanation of this right. lit.. lM JifJr•Notlce of.Cancellatloo C Ga 1A1rr "?1 +41.,Rn+ 19_ 1Ur,., You may cancel this transaction, without any pe fry or obligation, within three business days from the above date. It you cancel, any property traded in, any payments made by you under the contract or sale, and any negotiable instrument executed byyou willbe retumedwithin ten businessdaysfollowing receipt by Contractorof yourcanaellation notice, and any security interest arising out of the transaction will be cancelled. If you cancel, you must make available to Contractor at your residence in substantially as good condition as when received, any goods delivered to you under this contract or sale; or you may, ff you wish, comply with the instn)ctions of Contractor regarding the shipment of the goods at Contractor's expense and risk. It you do make the goods available to Contractor and Contractordoes not pick Them up within twenty days of the date of your notice of cancellation, you may retain or dispose of the goods without any further obligation. If you fail to make the goods available to Contractor, or it you agree to return the goods to Contractor and fail to do so, then you remain liable forperformance of all obligations under the contract. To cancel this transaction, mall or deliver a signed and dated copy of this cancellation notice or any other written notice, or send a telegram, to Keystone Fire Restoration at 559 Highland Avenue, Carlisle, Pennsylvania 17013, rat later than midnight of -.119- I hereby cancel this transaction. 19 'r*---IN WITNESS WHEREOF, the partied herourhorset their hanlds,arfd roe yUx day and ear first above written, intending to,be legally bound. t . WITNESSES: \ A 1 Contractor v? Zn Q r 41 / Qa'l n,.t 7?i..,eet Waiver of Right of Cancellation I understand that I have the rigtn to cancel this contract without any penally or obligation within three (3) business days from the date that it was signed. Because Did bona fide Immediate personal emergencywhich requires immediate remedy, I wishtowaive my right of cancellation. The specific nature of the bona fide immediate personal injury Is set forth in my own handwriting, as follower 7 . rs s nature / pp e. TM making of enl prym•m by Oww W ContractorYa oon.dbniawMvx ofMCWm. by Owrm apdn.t Cenb?CWr wlMi e,. ....... rm?•riMrp brom v,sstd•d keno. Io1w impowmenw ors bompty old,fit roquYMNnbddw s,kmatn ant! Wry crddedva nom sort b WP"HN*Nnone(1)Y•w alwr•uMwMM omd•don of ft perry by Wn«whidwww•hMI Find oo«. All 0001 wwnde., ewrnaW IImplNd, Ino*Aft wibaut brMwtlon. ImpliW warrandn a MNmWity. w hereby wMwM. KB(/SCONE 9/CHANGE ORDER- Zra Karr" L70N GENERAL CONTRACTOR 559HWe DAMCMLMEPA 17013 (717) 243-9595 Number 1052 AS[O-{ 33/ We hereby agree to make the change (a) specified below: -1,L z V i - ?Nef /' - HD r?dN a A F?isl F/ . Corr s 4M AD XU1 9004 ko1. It 3 T ?s ?- `' Y ytp 3 NOTE: This Change Order becomes part of and In conformance with the existing contract. WE AGREE hereby to make the change (a) specified above at this price $ A PREVIOUS CONTRACT AMOUNT $ AUTHORIZED SIGNATURE (CON RACTOR) REVISED CONTRACT TOTAL $ ACCEPTED - The above prices and specifications of this Change Order are satisfactory end are hereby accepted. All work to be performed under same terms and oondtions as specified in original contract unless otherwise stipuWed. Any reductions In Insurance reimbursement as a result of my of the above changes shag not result In reduction M the amounts due comeaobr. Date of Signature (OWNER) TO Kevsrol,N6 IV 7796966r0K,4G4N GENERAL CONTRACTOR 559 HIG ND Ave. GaLaLE PA 17013 (717( 243-9595 CHANGE ORDER Number 1 1053 We hereby agree to make the change (a) speclged below: FpVtA4 441 ire I c W fwd KLd ? V ;6 ca h v? 6A/40-IC-1 c I .L11 t u, nor tW/ 1 1? - W1 -L44,000 ?l .. - 0 Lt/ 61,0141 kk - t91nC Y Q& PA,/ 4Y ilrji 44" or v J ax DS NOTE: This Change rder becomes part of and in conformance with the exlsting contract. WE AGREE hereby ake the change(s) specified above at this price ? $ w PREVIOUS CONTRACT AMOUNT $ AUT?AIZUD 3 A U ( ON R CTOR) REVISED CONTRACT TOTAL $ I - ACCEPTED-The above spedflcatio s ofthis and Order aresstisfacsMandamhe led. All work to bepe under Date of acceptance g same terms and conditio in original con unless othetw?ietiAny neInlinsurancerelmbu ante Signature e result of any of te abo ngaa shall not result In uctlon In (OWNER) tio amounts due contra ArOSCONE 37X6WrOx r MW GENERAL CONTRACTOR 559 NDewro Ave, 3 CARLIKE, Pe 17013 (717) 2439595 TO CHANGE ORDER We hereby agree to make the change (s) specified below: e lr'N Qj WrA d4-V-/ r '/; ,4ikm r^ li Scc?icys r? a ?G -?'lvo? ? dvil/i -?vvr>, p- [? O NTS1CLf Z ? iI a 1M tOt? /a- 11C,.> vi 61 I TS.SSAd P X49 !ne - W1 e- L- 4Ivd,- vej pf olft r # kef4A ID, DYC S4,0147 S?X3? LV/i' ' A/Z 37S- 11 n 14 e' S NOTE: This Change Order becomes part of and In conformance with the existing contract. WE AGREE hereby to make the change (a) specified above at this price $ DATE PREVIOUS CONTRACT AMOUNT $ AUT?RIZED I NA URE(CON RACTORI REVISED CONTRACT TOTAL $ ACCEPTED - The above prices and specifications of this Change Order are satisfactory and are hereby accepted. All work to be performed under same farms and conditions as specified In original contract unless otherwise stipulated. Any redumions M insurance reimbursement as a result of any of the above changes shell not result In reduction In the amounts due contractor. Date of acceptance Signature (OWNER) Number A4 1054 kzlysrONe W -'?- 21.PB C"Mr?T.N v CHANGE ORDER Number i 1056 PNONE DATE GENERAL CONTRACTOR 559HIDHJWDAW.CAm PA 17013 JOB NAME/LOCATION (717) 243-9595 TO b O UMB R JOB PHONE EXISTING CONTRACT NO. DATE OF EXISTING CONTRACT I We hereby agree to make the change (a) specified below: z ? -/Ueeft qc? ; ioI( 7?'? r , r c lH ; vu c bye. ! 4>a,4 r ? A U+' laofj'i idLf? 0 NOTE: This Change Order becomes part of and In conformance with the existing contract. WE AGREE hereby to make the change (a) specified above at this price DATE PREVIOUS CONTRACT AMOUNT 1 I A UR ( ONTRAC OR) \7 REVISED CONTRACT TOTAL $ $ $ 7v 1(,r V ACCEPTED - The above pries and specifications of this Change Order are satisfactory and are hereby accepted. All work to be performed under same terms and Dandllons as specified In original contract unless otherwise stipulated. Any reductions In inesranes rNmbu?esmant es a result of any of the above changes shall not result In reduction In the, amounts due contractor. Date of acceptance Signature ?Lrrh /aa.s-e j r OWN p) 7CIUt..?. KBVM,Ve snreRaso)uuoN GENERAL CONTRACTOR 559Hrt3e1,wDAw.CAR)6LEPA 17013 (7171243-95M TO PHON@ D T JOB NAME/LOCATION .G JOB NUMBER JOB PHONE E%IBTINO CONTRACT NO. DAT@ OF E%IBTINO CONTRACT We hereby agree to make the change (a) specified below: C ra U)GY .? j 0 f Y Sr d.?. ? zS - t- r 41 r ? oUy Jd?W D,o? -t r ? ? o c7? w1 r C9 r, Y Z1z47 if. y -w )ilc i iph-t -? 4 IV Z'- NOTE: This Inge Order becomes part of and in conformance with the exla ng contract. WE AGREE hereby to make the change (a) specified above at this price $ Pip. DATE PREVIOUS CONTRACj?4MOUNT $ 41 AUTHORIZED SIGNATURE (CONTRACTOR) REVISED CONTRACT TOTAL $ O,* ACCEPTED - The above prices and specifications of this Change Order are satisfactory and are hereby accepted. All work to be performed under same forms and conditions as specified In original contract unless otherwise stipulated. Any reductions M Insurance reimbursement as a result of any of ft abe" changes shalt not result In reduction In the amounts due contractor. CHANGE OROE Lis 1058 Number Date of acceptance Signature (OWNER) EXHIBIT B "BUILDING ENERGY CONSERVATION ACT" MUST BE COMPLIED WITH AND THE BUILDER MUST PROVIDE THE HOMEOWNER A WRITTEN WARRANTY STATING COMPLIANCE WITH ACT 222. BP DATE Tuesday, March 20, 2001 IMPROVEMENT: Bedroom addition PERMIT BP PERMIT NOM 2001-0140 MAP: 2 PARCEL: 186 JOB WEATHER CARD FNAME: Juanita MI: LNAME: Pascoe LOC STREET NO.: 114 LOC STREET NAME: Fair Avenue CNAME: Keystone Fire Restoration C-DBA: CADDR1559 HIGHLAND AVENUE CADDR2: CARLISLE, PA EXPIRE:3/'I/2002 INSURANCE: Exempt THIS PERMIT CONVEYS NO RIGHT TO OCCUPY ANY STREET, ALLEY OR SIDEWALK OR ANY PART THEREOF, EITI4ER TEMPORARILY OR PERMANENTLY. ENCROACHMENTS ON PUBLIC PROPERTY, NOT SPECIFICALLY PERMITTED UNDER THE BUILDING CODE, MUST BE APPROVED BY PENN TOWNSHIP. STREET OR ALLEY GRADES AS WELL AS DEPTH AND LOCATION OF PUBLIC SEWERS MAYBE OBTAINED FROM THE DEPARTMENT OF PUBLIC WORKS. THE ISSUANCE OF THIS PERMIT DOES NOT RELEASE THE APPLICANT FROM THE CONDITION OF ANY APPLICABLE SUBDIVISION OR OTHER DULY ADOPTED RESTRICTIONS. APPROVED PLANS MUST BE RETAINED ON JOB AND THIS CARD KEPT POSTED UNTIL FINAL INSPECTION HAS BEEN MADE. WHERE A CERTIFICATE OF OCCUPANCY IS REQUIRED, SUCH BUILDING SHALL NOT BE OCCUPIED UNTIL FINAL INSPECTION HAS BEEN MADE. POST THIS CARD SO IT IS VISIBLE FROM STREET AND ACCESSABLE TO TOWNSHIP INSPECTORS BUILDING INSPECTION PLUMBING INSPECTION BUILDING PERMITS SHALL NOT BE DUPLICATED OR TRANSFERED. "BUILDING ENERGY CONSERVATION ACT" MUST BE COMPLIED WITH AND THE BUILDER MUST PROVIDE THE HOMEOWNER A WRITTEN WARRANTY STATING COMPLIANCE WITH ACT 222. BP DATE Wednesday, March 07, 2001 IMPROVEMENT: Siding, window replacement PERMIT BP PERMIT NO#: 2001-0104 MAP: 2 PARCEL: 186 JOB WEATHER CARD FNAME: Juanita MI: LNAME: Pascoe LOC STREET NO.: 114 LOC STREET NAME: Fair Avenue CNAME: KEYSTONE FIRE RESTORATION C-DBA: CADDRI 559 HIGHLAND AVENUE CADDR2: CARLISLE, PA EXPIRE: 3/7/2002 INSURANCE: EXEMPT THIS PERMIT CONVEYS NO RIGHT TO OCCUPY ANY STREET, ALLEY OR SIDEWALK OR ANY PART TIIEREOF, EITHER TEMPORARILY OR PERMANENTLY. ENCROACHMENTS ON PUBLIC PROPERTY, NOT SPECIFICALLY PhRMITTED UNDER THE BUILDING CODE, MUST BE APPROVED BY PENN TOWNSHIP. STREET OR ALLEY GRADES AS WELL AS DEPTH AND LOCATION OF PUBLIC SEWERS MAYBE OBTAINED FROM THE DEPARTMENT OF PUBLIC WORKS. THE ISSUANCE OF THIS PERMIT DOEIS NOT RELEASE THE APPLICANT FROM THE CONDITION OF ANY APPLICABLE SUBDIVISION OR OTHER DULY ADOPTED RESTRICTIONS. APPROVED PLANS MUST BE RETAINED ON JOB AND THIS CARD KEPT POSTED UNTIL FINAL INSPECTION HAS BEEN MADE. WHERE A CERTIFICATE OF OCCUPANCY IS REQUIRED, SUCH BUILDING SHALL NOT BE OCCUPIED UNTIL FINAL INSPECTION HAS BEEN MADE. POST THIS CARD SO IT IS VISIBLE FROM STREET AND ACCESSABLE TO TOWNSHIP INSPECTORS BUILDING INSPECTION i PLUMBING INSPECTION BUILDING PERMITS SHALL NOT BE DUPLICATED OR TRANSFERED. EXHIBIT C (TAYLOR L MADETM April 4, 2003 Invoice # 72% Submitted To: Ms. Mane Pascoe Ms. Juanita Pascoe 114 Farr Ave Hanover, PA 17331 rr You Are Gonna Love It rr Description of work completed: 123 Hirdand Avenue Hanover^ 17331 (717) 646-0947 Removal of drywall in living room area to include ceiling and wall area of thermostat, haul away all debris. Installation of Ys' drywall to said areas tape and finishing using drywall compound, prior to introducing a primer to entire room area and a two coat paint system Removal of deteriorated carpet in living room. Scrape floor removing all saturated drywall that had dried, haul away all debris. Installation of fresh Luan board to entire floor area in living mom, existing carpet on floor was installed over a painted surface with irregular divots and areas of wood open. Installation of fresh base molding to living room floor wall area (reference thermostat wall) Repair all plumbing in home to include bathroom upstairs toilet repaired was not secure to floor area, plumbing under vanity was removed and replaced with PVC pipe to meet code, Bath tub plumbing was replaced with PVC pipe to meet or exceed code. Application of fresh caulk to bathtub area was never caulked. Remove and replace plumbing under sink area of kitchen. Removed shower glass enclosure from base and cleaned area thoroughly prior to installing shower enclosure using a commercial grade silicone. Installation of all hardware. Remove existing flooring in bathroom due to shower leaking and floor was stained. Installation of new vinyl flooring to entire bathroom area using a floor adhesive. Removal of interior bathroom door, door had to be trimmed at bottom to free up swing, to door was not properly installed Home Improvements *Additions* Roofing * Garages * Remodeling R...IA:.... R...d..Ma * Vinyl QM...n * rlnaion R..ild * Rnnhnomnnt W;.,I.. Removal of drywall in laundry room, bedrooms in addition, hallway area leading to bedrooms, upstairs bathroom and child's bedroom. Due to drywall and/or drywall tape was nor properly installed, drywall tape was flaking, Repaired all areas using fresh drywall and drywall tape, sanding of areas prior to applying a primer and paint system to all areas, to include all trim work. Application of a two coat paints system to hallway area, to include a all-trim work. Installation of a new thermostat in living room. Repaired plumbing in laundry room, discharge line from washing machine was not properly installed Deposit draw $2000.00 thank you Balance Due $1900.00 Thank you for giving us the opportunity to serve you. Please note this completed work is guaranteed for a period of one full year, at signing of the work was completed in a very workman like manner and is to the satisfaction of the above homeowners. In the event a problem may occur please call our offi at 717-646- 0947. James R. Taylor Ms. Juanita - y-O ':?_date Coo-co?-e- Ms. Maryjane Pascoe T AYLOR MADETM April 4, 2003 Invoice # 7297 Submitted To: Ms. Juanita Pascoe Ms. Mary Jane Pascoe 114 Fair Ave Hanover, PA 17331 " You Are Gonna Love It rr Description of extra work completed: 123 Hirtland Avenue Hanover^ 17331 (717) 646-0947 Our original contract had stated to check underneath crawl space m new addition due to bedrooms were extremely cold Our finding was no insulation had been installed in framing underneath flooring. We had taken pictures of said crawl space prior to agreement of tnstalling R-19 faced insulation 6" m thickness to entire crawl space area using a mechanical nailer for installation. Installation of liquid foam to sill plate area upon inspection of crawl space there was no evidence of sill foam plate harrier on top of block foundation leaving a void Total cost of insulation and labor> • -, Thank you for giving us the opportunity to serve you. And once again I am glad to hear you are finally warm in bedrooms and free. Home Improvements *Additions* Roofing * Garages * Remodeling * Building Products * Vinyl Siding * Design Build * Replacement Windows D E WILDASIN & SON PLUMBING & HEATING 15 S Main Street Spring Grove, PA 17362 Phone: 225-5397 Sold To: Waynetta Pascoe 114 Fair Ave Hanover, Pa 17331 Terms Net Cash 06/03/02 The total amount for replacing condensate um for AC s stem and checked the operation; $137.00 Total amount: $137.00 TERMS: We Now acre Visa, MasterCard, American Ex rasa, Discover A Charge of one and one half percent (1-1/2% per month will be charged on all sums unpaid within thirty days! 6?a•a`/7y Water Treatment Water Pump Water Heater (717) 359.9877 (410) 848-7368 DATE -,T;,/ To J(/QA,1/'/Ct f4?c0 c //?/ jc, t l Arc Ouantl Description Price Amount s G? 4^ br, Q „U W1?7 ? Total Material /p. C/o Labor o0 TOTAL AMOUNT DUE J ;'. `'rU STATEMENT CONTRACT Sewer Service WILLIAM E. PITTINGER Plumbing Repairs PLUMBING & HEATING CONTRACTORS "Gotta Drip Call Pip" 329 N. Springdale Road • Westminster, MD 21158 as zee per monm Will be charged on all balances for more than 30 days D E WILDASIN & SON PLUMBING & HEATING 15 S Main Street Spring Grove, PA 17362 Phone: 225-5397 I Sold To: (Juanita Pascoe I 114 Fair Ave Hanover, Pa 17331 I I Terms Net Cash 1 01/14/031 The total amount for repairing a 3" main sewer line; checked and ti htened all connections under sinks; also repaired the shower drain: $175.45 I I Total amount: 1 $175.451 I TERMS: IA Charae of one and one half percent (1-1/2%) per month will be I I n D E WILDASIN & SON PLUMBING & HEATING 15 S Main Street Spring Grove, PA 17362 Phone: 225-5397 Sold To: Juanita Pasco 114 Fair Ave Hanover, Pa 17331 Terms Net Cash 01/09/03 The total amount for rehan in thermostat to wall for ht system n/c for additional service man who is in training): $48.00 Total amount: $48.00 We Now accept Visa, MasterCard, American Express, Discover TERMS: A Charge of one and one half percent (1-1/2%) per month will be charged on all sums unpaid within thirty days! T AYLOR MADE .M April 21, 2003 Invoice # 7297 Ms. Maryjane Pascoe Ms. Juanita Pascoe 114 Fair Ave Hanover, PA 17331 rr You Are Gonna Love It rr Description of work completed: Removal of existing vinyl siding on front, back and both sides of home. ?4a 01 1r Installation of low a insulation to entire exterior of home using a mechanical nailer for installation. Tape all seams prior to installation of existing siding Caulking of all windows due to metal work and windows were never caulked and rainwater was evident behind metal work. Remove existing vented soft on rear of home (addition am), this sofa was changed due to sofit was an vented and only needed to be vented on end corms of home or spaced every sixth panel. Installation of solid soft according to industry standards using only vented soft on ends of addition and middle area. Cost of insulation wrap on entire home: $2900.00 Cost of caulking all windows: S 260.00 Cost of replacing vinyl soft: $ 140.00 Total cost of project: S33MMi, Thank you for giving us the opportunity to serve you. /uazzz o ztc 1.1 123 Hirdand Avenue Hanover^ 17331 (717) 646-0947 let f' Ad I // Home Improvements *Additions* Roofing * Garages * Remodeling * ? Building Products * Vinyl Siding * Design Build * Replacement Windows ]/un r r/? y TAYLOR MADETM " You Are Gonna Love It " April 3IA 2003 Invoice k 7298 Ms. Matyjane Pascoe Ms. Juanita Pascoe 114 Fair Ave Hanover, PA 17331 123 Hirdand Avenue Hanover^ 17331 (717) 646-0947 Description of work completed: Removal of existing vinyl siding on from, beck and both sides of home. Installation of low a insulation to entire exterior of home using a mechanical nailer for installation. Tape all seams prior to installation of existing siding Caulking of all windows due to metal work and windows were never caulked and rainwater was evident behind metal work Remove existing vented sofit on rear of lame (addition area), this sofit was changed due to sofit was all vented and only needed to be vented on end corners of home or spaced every sixth panel. Installation of solid sofit according to in3utry standards using only vented sofit on ends of addition and middle area. Reinstall getter on rear of home only half of gutter was functional due to a bow in previous installation and holds water. Additional work was needed on north side of home doing removal of siding an area of exterior wood lap siding was not installed on home. Pictures were taken of this area prior to authorization of repair to begin. Removal of wood lap siding shims Removal of scabbed in 2 x 4's Installation of 20 lumber to said area 16" on center, shore up area on wall due to existing framing was cat and original lumber had no support to the wall system. Installation of R-13 insulation to entire wall area Installation of W plywood to complete to exterior Cost of insulation wrap on entire home: $2900.00 Cast of taunting all windows: $ 260.00 Cost of replacing vinyl sofit: S 140.00 Total cost of project: $3300.00 Deposit Draw $1500.00 Balance $1800.00 Additional work (wall area) New balance $2181.00 Please note the above mentioned work is guaranteed for a period of one year. If you have arty questions or should there be a problem please do not hesitate to call our office at 717-646- 0947 I hereby Juanita Pascoe a Mary Jane Pascoe are completely satisfied with the above-mentioned work. ?2?sC? E_ Home Improvements *Additions* Roofing * Garages * Remodeling Buildine Products * Vinyl Sidine * Desien Build * Renlacemeat Windows EXHIBIT D iUF9iifR P 11C)'1'L:I_ I1F`INO'.•'I.:IR 40 WE°f"-EL. I) R I IAN D'dl" PA 17'1:31 JUAN!I TrIl PA"COE 114 11'AI:R AYE HANOVER, F-`A 17331 V):R #. 'TII"I£: CHECF::ED IN,, 10.,, i0;0ET F`01...10. ROOM, 2:1'5 APR I VI:: 01, :/04 1/03 [)ErART 01./0(-/0:3 TODAY w /:I ;-l 0r3 .1 1 4 1I:i1.lE:1,"3 T" I RATE:. .`.:f0 40 'TIME CHECKED OUT. 10.;9F.,:;iSF3 11742; ROOM :9 GH DATE CD DEscrzIl'TIOh•1 AMOUI`dT' DA1..AI'tICE I'_ 1- A 71. /04 /0) F'' PI) CC 1 1. 1 » 90 1. 11 , 9C3 C 01 /04/03 E ROOM RENT - 4f .> C O 1. 4 /03 F' S` ATtL .' ..J I TAX I ( ) _. •. C ?:l /04/03 I I::ITY TAX .:) ., . f 1 . 151 Jl ., tel: --57 05 C 01. /04 /03 I. "AFE: WARRANTY . 1, 00 , -.56 05 C p1/04/03 F SAFE 'TAY. 0,. 0E; » ....;iS;S 129 21. `:r /02 E:. RI(.ON RENT 50 , 4.0 ,. 01 /0ii3 F "TATI: TAY. . 3. 02 -c' 7 2 1 A 0/till F C:17Y 'T'AX . .(i6 -1 ?-_l A r.,:l /0;/03 I SAFE WARRAI`ITY 1 ,00 . 06 ..x.:y. r..c... c..v:+Y TO TAI... DUE:.., F'00M RENT,. FUC7,(c30 ROOM TAY... 9,.11:3 SAPT. <', 1? I'd Write D-,;; 2797();. 19nI:;I_I.,, 1911 Cx;k;4i''7 or view ol.n- wed-.)a:ite a bc.t..lL. privacy,. Pbo't, a/q - - / N?6ffT Nr6r<T to Ni?Ts /om? Sao - 'Al HI.4h9' Z29uq?TeR S/°e 7- a 1?1611TS lA/ #eR511y de4945*e a-' DoeTelf 1/15175, 7o-74,Z f''7.eai s contact tjjp ';uper 0 Motels,, Inc. or and ser'v i. r..es Urines YOU 195nriecapolis:i;: MN k;1S42-7__0 websi.te about pr i.•;acy„ manager about any i. siue w..tl'1 you," 5i t:,a,7» aft`iliat.es; may contact yo,.( 4-lbOUt goocis call. 077 c244-.760-1 or write to r)ox E!7`,`701 7'70 to 01:)t 0((t.. View our !:.;uper.. D ?J 6 7/. YF Checks Accepted ONLY if V..I,F` Member_ agrees t0 fi;LAPer- 1:) Debiting 1-e2t'Urned C:hcrcA: filtliri IAFf tit T225., 1:1@e tan t card. SUPER 8 MOTEL HANOVE:R 40 WETZEL. DR HANOVER PA 17331 (717) 630-0008 JUANITA PASCOE 1.14 FAIR AVE HANOVER, PA 17331 VIP #1 TIME CHECKED I N .., 09:22:3'7 FOLIO. 55353 ROOM. 220 ARRIVE 01/05/03 DEPART 02/07/03 TODAY 01/07/03 #GUE::STS 1. RATE-50.40 TIME CHECKED OUT.. REG#.. 1 946'3 ROOM # SH DATE CD DESCRIPTION AMOUNT BALANCE 220 D 01/05/03 P- PD ONE NIGHT DISC: 55.99 -55.99 220 C 01/05/03 E ROOM RENT 50.40 --059 B20 C 01/05/03 F STATE TAX 3.02 -2.57 220 C 01/05/03 F CITY TAY, 1.51 --1.06 220 C 01./0 /03 T. SAFE WARRANTY 1...00 --0.06 220 C 01/05/03 F SAFE TAX 0.06 --0.00 220 C 01/06/03 E ROOM RENT 50.40 50.40 P20 C 01/06/03 F STATE TAY. 3012 53.42 220 C.; 01/06/03 F CITY TAX 1..51 54.93 220 C 01 /06/03 I SAFE: WARRANTY 1.00 55,.93 220 C 01./06/03 F SAFE TAX 0.06 55.99 *+? E•*tr#K•?t TOTAL DUE-- . 55.99 ROOM RENT-... 100 .00 ROOM TAX.... 9110 SAFE...,... , 2.00 DISCO VER.... 55 .99 Write Box 279 70, Mnpls., MN 55427 or view our wehsite about privacy,. Please contract the manager about any issue with your stay. Super 8 Motels, Inc. or affiliates may contact you about good; and services, unless, you r_al.l. 077-244-7633 or write to Box 27970, Minneapolis;, MN 55427-0970 to opt out. View our Super 8 web'site about privacy. Checks Accepted ONLY if V.I,.P Member agrees to Super 8 Debiting returned check plus, up to $25. See tent card. SUPER 8 MOTEL HANOVER 40 WETZEL DR HANOVER PA 173:31 (717) 630-8880 JUANITA PASC:OE 1.14 FAIR AVE HANOVER, PA 17331 VI} # TIME CHECKED I 0.. 1 0f.?C3:55 FOLIO. 55431 ROOM. 220 ARRIVE 01/00/03 DEPART 01/11/03 TODAY 01/10/03 #GUESTS 2 RATE...50..00 TIME CHECKED OU'T'.. REG#.. 1950'7 ROOM S1 SH DATE CD DESCRIPTION AMOUN'T' BALANCE 220 V 01/09/03 N PD DISC. 55.56 -55.56 220 C 01/09/03 E ROOM RENT 50,00 --'ei.,`.`ib 220 C 01/09/0;1 F STATE TAX 31110 -2.54 220 C 01/09/03 F CITY TAY, 1.50 -1..06 220 C 01/09/03 T. SAFE: WARRANTY 1.00 -0.06 220 C 01 /09/03 F SAFE TAY, 0.06 -0100 220 B 01/10/03 E ROOM RENT 50.00 50.00 220 B 01/10/03 F STATE TAX 3.00 53.00 r:!20 B 01/10/03 F CITY TAX 1150 54.50 220 B 01/10/03 I SAFE: WARRANTY 1 00 55 30 220 D 01./10/013 F SAFE TAX . 0.06 .. SEQ.. ,.6 ?...N..K..? ?..?. ?..N.?. ?. -TOTAL. DUI::...... 55,56 ROOM R ENT.. 100.00 ROOM TAX.... 9.12 SAFES:............. 2..00 DISCOV ER .... 55. . 56 Write Box 279 70, Mnpl s.., MN 55427 or view our website about privacy. Please contact; the manager about; any issue with your stray.. Super- Ci Motels,, Inc. or affiliates may contact you about goods and services unless you call 077-°244--7633 or write to Box 27970, Minneapolis, MN 55427-0970 to opt out. View our Super 0 webui.te about privacy. Checks Accepted ONLY if V,.I.P Member agrees to Super- 8 Debiting returned check plum up to $25. See grant card. SUPER 0 &TEL."HANOVER 40 WE::T 'EL. DR HANOVER PA 17331 (717) 630--8080 JUANITA PASCOE 1.14 FAIR AVE HANOVER, PA 17'S31 VIP *- TIME CHECKED IN...10r45:41 FOLIO. 5533B ROOM, 214 ARRIVE 01/04/021 DEPART OL/05/0'.3 TODAY 01/13/03 #GUE:STSi 2 RATE... 50.. 40 TIME CHECKED OUT...:006:39 REG#.. 19452 ROOM •N SH DATE CD DE SCRIPTION AMOUNT BALANCE 214 A 01/04/03 P PD CC 111.98 --111..91-3 214 214 C C 01/04/03 01/04/03 E F ROOM STATE RENT : TAX 50.40 3.02 -61.5P -5B.56 214 214 214 214 214 214 C C C A A A 01/04/03 01/04/03 01 /04/03 01. /05 /03 01 /05/03 01/05/03 F T. F E F F CITY SAFE:. SAFE ROOM STATE CITY TAY. WARRANTY TAY, RENT TAY, TAX 1.51 1..00 11.01., 30.40 3,.02 1.51 -57.03 -56.05 -55,9''? -5,59 --2..57 --1.06, 214 A 01/03/03 1 SAFE: WARRANTY 1.00 -0.06 214 A 01/05/0:3 F SAFE TAX O.. (7f.. -0.00 *tHx• * t. .>f..? TOTAL DUE , ... , . -0.00 ROOM RENT... 1(:10.113(:1 ROOM TAX..... 9.10 SAFE... 2.00 DISCOVER .... 11L.90 Write Box 27970.. Mnp:la., MN 55427 or view our websit:e about privacy.. Please contact the manager about; any i.'_mue with your stay.. Super 0 Motels, Inc. or affiliates may contact you about goods and srer•vices unless s you call 077-244-7633 or write to Dox 279711. Minneapolis, MN ; 5027-0970 to opt out, View our Super Iii wabsi.te ;about: privacy. Checks Accepted ONLY if V..I.P Member agrees to Super- 0 Debiting returned ;:hey-.k: plum up to $25. See tent: card. SUPER 8 MOTEL.. HANOVER 40 WETZEL DR HANOVER PA 17331 (717) 630--8888 .JUANITA PASCOE: 1.14 FAIR AVE HANOVER, PA 173SI VIP #: TIME CHECKED IN.,.16:5% 24 FOLIO, 55352 ROOM. 219 ARRIVE 01/05/03 DEPART OL/L1/03 TODAY OL110101 #GUESTS 1 RATE..50.40 TIME CHECKED OUT.. REG#.19464 ROOM # SH DATE CD DESCRIPTION AMOUNT BALANCE 219 B 01/05/03 P PO ONE NIGHT DISC 55.19 _..55.99 219 C 01/03/03 E ROOM RENT 50.40 -5,.59 219 C 01/05/02 F STATE TAX 3.,02 -2.,57 219 C 01/03/03 F CITY TAX 151 --1.06 219 C; 01/05/03 1 SAFE: WARRANTY 1.00 --0.06 219 C: 01/05/03 F SAFE TAX 0.06 -•0.00 219 C 01/06/03 E = ROOM RENT 50.40 50.40 219 C 01/06/03 F STATE TAY. 3.02 53,.42 219 C 01/06/03 F CITY TAX 1.,51 54.9 219 C 01 /06/03 1 SAFE WARRANTY 1 00 55 92) 219 C 01/06/03 F SAFE TAX . 0.06 , 5509 219 C 01/07/08 E ROOM RENT 50.40 106.39 219 C OL/07/03 F STATE TAX 3.,02 109.,4L 219 C 01 /07/03 F CITY TAX 1.51 110.92 219 C 01/07/01 1: SAFE: WARRANTY 1..00 111..92 219 C 01/07/03 F SAFE TAX 0.06 111,.913 219 C 01/08/03 E ROOM RENT 50.40 162„30 219 C 01 /08/03 F'' STATE TAY. 3.02 165.40 219 C; 01/00/03 F CITY TAX 1.51 166.91 219 C-; 01/00/03 I SAFE WARRANTY 1.00 167.91 219 C 01/00/03 F SAFE TAX O. 06 167.97 219 C 01/09/03 E ROOM RENT 50,40 210.37 219 C 01/09/03 F STATE TAX 3.1312 221„39 219 C 01/09/03 F CITY TAX 1.51 222.90 219 C 01/09/03 1 SAFE WARRANT`( 1.00 223.9o 219 C 01/09/03 F" SAFE TAX 0 06 223 96 219 B 01 / 10 /03 E ROOM RENT . 50 , 40 , 274.36 219 D 01 /10/03 F STATE TAY, 3.02 27.7,.30 219 B 01 /1!.')103 F CITY TAY. I &L 278.239 219 B 01/10/03 I SAFE WARRANTY 1.00 279.89 229 0 01/10/023 F SAFE TAX 0&6 279.95 MASEMER'S CUSTOM 515-517 Baltimore more S/. i% MOHAWK WALL-TO-WALL CARPETS AND RUGS CARPET Sold FLOORS Phone 632-2362 Hanover, PA 17331 VINYL FLOOR COVERING to TERMS: 30 IArn Net. Balances remaining unpaid at due date are subject to service charge of 1% Percent per month until Paid. 010 urniture Date: 3/31/2001 6520 CARLISLE PIKE INVOICE NO. 1 670 98-00 Time: 15:09:49 SUITE 400 Page: I of 3 MECHANICSBURG, PA 17050 (717) 766-2700 DEL P/U , PASCOE, JUANITA M v 114 FAIR AVENUE 'i HANOVER, PA 17331 I` HOME (717) 632-2479 r ) 4 a DEL Price HoIdiNEIDIGH, BOB 81 3/31/2001 SKU' r W'rq i 'i i t}, r ??"EXTENSION 18322 S-1174-6 15 PC DINETTE-SEA ISLAND PINE 1 399.99 399.99 609 STABLE/4 (S1135) SIDE CHAIRS I 618128 S-1135 SIDE CHAIR-SEA ISLAND PINE 2 j 69.99 139.98 609 649236 1090-PB RETRO ACCENT CHR-PORT BURGUNDY 1 199.99 ' 199.99 843 COVER 3402-24 Guardian - W 39.99 I 537713 00011DO-1M !GLIDER OTTOMAN-MAUVE 1 ' 139.99 139.99 24 19128 ;Guardian - W 19.99 674362 60006-79 r !DUAL RECL/ROCKING LVST-MAX TAP 1 699.99 699.99 65 :W/TUCKER HUNTER Guardian - S ? I 49.99 II THANK YOU Value City Furetture Is an Institution dedicated to Better Homes for Better Living. Its object Is that your purchase MII give you pleasure and complete satisfaction. Remem- ber you can buy anything for your home on very liberal terms at Value Cley Furniture. SEE REVERSE SIDE FOR TERMS AND CONDITIONS CUSTOMER - RETAIN THIS COPY FOR YOUR RECORDS BALANCE DUE ?ture urmture :e: 3/31/2001 :e: 15:09:49 3e: 2 of 3 6520 CARLISLE PIKE SUITE 400 MECHANICSBURG, PA 17050 PASCOE, JUANITA M 114 FAIR AVENUE HANOVER, PA 17331 HOME (717) 632-2479 74354 60006-88 5 26139 VC-104-3P 67 43166 8884-43 71 40609 4884-17N 71 40668 4884-43 X71 ,37683 C6847DO-1M '.4 E 0 ?r v INVOICE NO. 1 67098-00 DEL P/U (DUAL REC SOFA-MAXWELL TAPESTRY IW/TUCKER HUNTER 'Guardian - S 3PC TABLE SET-CABRIOLE PINE VP ,COCKTAIL/2 END TABLES NIGHT STAND-WASHED PINE CHEST-GREEN & NATURAL ,NIGHT STAND-GREEN & NATURAL SOLID OAK GLIDER ROCKER-MAUVE 19128 Guardian - W 1 li 699.99 99.99 59.99 1 199.00 199.00 i I 1 109.99 109.99 3 199.99 599.97 I I 3 109.99 329.97 i 1 329.99 329.99 29.99 THANK YOU Value City Furniture is an institution dedicated to Batter Homes for Bever Living. Its object is that your purchase wIW give you pleasure and complete satisfaction. Remem- ber you can buy anything for your home on very liberal terms at Value City Furniture. SEE REVERSE SIDE FOR TERMS AND CONDITIONS CUSTOMER - RETAIN THIS COPY FOR YOUR RECORDS BALANCE DUE urmture Tate: 3/31/2001 6520 CARLISLE PIKE ime: 15:09:49 SUITE 400 'age: 3 of 3 MECHANICSBURG, PA 17050 (717) 766-2700 INVOICE NO. 1 67098-00 DEL P/U _ PASCOE, JUANITA M JE 114 FAIR AVENUE LL. HANOVER, PA 17331 HOME (717) 632-2479 i ? 4 ® DEL TYPE OF SALE SALESPERSON til NAME NO. Price Hold'NEIDIGH, BOB 31 - 3/31/2001 Ku t ,. Ad?Si 77; V lq C:f9 4Y lY q{n t -0EBCRIPf ON YIJrw4. k\ JW'rNr x 1.. - Q , A O ] ,. TY < M UNT EXTENSION j i i i I i i I i i I I i i This Receipt Must, Be Retained For Merchandise Returns or Refunds. i I have received a copy of the Value I City Furniture Service Pol icy I have read and understand the post ed Price Hold Policy C.O.D. AMOUNT 3,950.00 Merchandise Total... ,848.85 Delivery............ 89.99 All orders must be prepaid B-4 scheduled Guardian............ 199.95 Pick-up Hrs Mon-Fri 12-8 Sat 10-8 Sub-Total........... 4,138.79 Sun 12-4. Msde. Pick-ups Held 24hrs... Sales Tax 6.0X..... 248.34 Invoice Total....... 4,387.13 THANK YOU Total Payments...... 437.13 Value Clry Furniture is an Institution dedicated to Bever Homes for Bever Living. Its Object Is that your purchase win give you pleasure and complete satisfaction. Remem. bar you can buy anything for your home on very liberal lerms at Value City Fumlwro. SEE REVERSE SIDE FOR TERMS AND CONDITIONS CUSTOMER - RETAIN THIS COPY FOR YOUR ORDS BALANCE DUE, ., . FROM :SERVICEMASTER CLEAN BY DANIELS FRY, NO. Sffvicewffm Clean 7178489570 San. 16 2003 01:37PM P2 Disaster Rcstoratioa 8orviceM2nter Clean Services Ivy Daniels P.O. Box 7284 York, PA 174()"Z()4 PA: 717/R4"565 Tb1I Prrc: 877/.582.1975 Fax: 717/848,9570 A Qudll(y Xc, kwalMn Vendor January 16,02003 To Whom It May Concern, Please note that we, ServiceMaster Clean by Daniels serviced Mrs. Juanita Pascoe on Wednesday, January 15,02003. The result of our technician is as follows: Sofa - Latex paint on cushion and armrest Chair - Latex paint on cushion and back of chair. Lovescat - Latex paint on every cushion and armrest. Glider Rocker and footstool - Cleaned up well - Mrs. Pascoe was told to wait until it dries to determine whether or not stains did come out. On our follow up call to Mrs. Pascoe she said that there are still 2 marks on the footstool. All furniture was wet and saturated for days. Cannot guarantee mold spores will not grow. Mrs. Pascoe paid $157.00 check #1457 Aline Berenstein An McWwndtlnl W.dnna t;y.1'wWa0fdNiY (hwn CERTIFICATE OF SERVICE ON THIS 23`d day of February, 2004, I, Christopher T. Restak, attorney for the Plaintiffs Juanita and Mary Jane Pascoe, hereby certify that I have served a copy of the Plaintiffs Amended Complaint, by United States mail, postage prepaid, upon the defendant's attorney at the address indicated below: Nathan Wolf, Esq. Irwin Law Office 64 South Pitt Street Carlisle, PA 17013-3220 (717) 243-6090 Restak, Attorney rlisle Street Hanover, PA 17331 (717) 637-5188 PA Supreme Court ID# 81514 Attorney for Plaintiffs 13 l c_, n N --t t?l r t i l. ? 1 cn NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT MARY JANE PASCOE and JUANITA PASCOE, Plaintiffs V. WILLIAM K. SALOMONE, an individual d.b.a. Keystone Fire Restoration, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 2004-00404 CIVIL JURY TRIAL REQUESTED NOTICE TO PLEAL'i TO: Mary Jane Pascoe Juanita Pascoe c/o Christopher T. Restak, Esquire 213 Carlisle Street Hanover, PA 17331 You are hereby notified to file a written response to the enclosed Preliminary Objections within twenty (20) days from service hereof or a judgment may be entered against you. Date: May 77, 2004 N C. OLF, ESQUIRE fo efendant, William K. Salomone anover r Street, Suite 201 PA 17013-3307 (717) 241-4436 Supreme Court ID NO. 87380 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT MARY JANE PASCOE and JUANITA PASCOE, Plaintiffs : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. WILLIAM K. SALOMONE, an individual d.b.a. Keystone Fire Restoration, Defendant DOCKET NO.2004-00404 CIVIL JURY TRIAL REQUESTED PRELIMINARY OBJECTIONS TO PLAINTIFFS' FIRST AMENDED COMPL MNT AND NOW COMES the defendant, William K. Salomon, by and through his counsel, Nathan C. Wolf, Esquire and raises the foregoing Preliminary Objections to Plaintiffs' Fast Amended Complaint, averring as follows: Motion to Dismiss for Failure to join an Indispensable Path[ 1. Plaintiffs entered into a contract with Defendant William K. Salomon to provide restoration services following a fire in their house. 2. After the completion of the initial work, Plaintiffs directed Defendant to perform additional work on their residence. 3. At the completion of the requested services, Defendant released the property to the plaintiffs. 4. Following the completion of the work performed bythe Defendant, Plaintiffs sought additional construction services from a subcontractor of the Defendant named Michael Smetana (hereinafter "Smetana"). 5. The additional services sought by Plaintiffs from Smetana were outside of Defendant's contract with Plaintiffs and was performed without Defendant's knowledge. 6. Defendant was never notified of any deficiencies in the Plaintiffs' home, until he was contacted by Plaintiffs' counsel more than a year after the contract was completed. 7. Plaintiffs notified Smetana when they realized they hadi problems with aspects of the work performed for them 8. Plaintiffs never, however, notified Defendant of the problems to have the conditions addressed under the warranty. 9. Because Plaintiffs independently contracted with Smetana and because Smetana performed work on the Plaintiffs' residence outside of the work contracted with Defendant, Smetana is an indispensable party, who may share in joint and several liability, should such liability be found to exist. 10. The failure to join an indispensable patty provides grounds for the dismissal of the complaint pursuant to Pennsylvania Rule of Civil Procedure 1028. WHEREFORE, Defendant William K. Salomone, respectfully requests that plaintiffs' Fast Amended Complaint be dismissed for failure to join an indispensable parry and that judgment be entered for Defendant William K. Salomone and against the plaintiffs, including an award of attorneys fees, pursuant to paragraph 11 of the contract. Motion to Str_ l r T peal Insufficient; of P eading (Demure 4 as to fount I - Breach of Contract 11. Paragraphs one through ten are hereby incorporated by reference as if set forth fully herein. 12. Plaintiffs executed a contract with defendant which provided for a guarantee against defects in all materials and workamnship which appeared within one year (1) year of after substantial completion of the work or occupancy of the Owner, whichever occurred fast. 13. Plaintiffs maintain an action for breach of contract based on defects that they allege to have appeared on the property but do not state when the defects appeared. 14. Plaintiffs furthermore do not state when they notified the defendant of the defects. 15. Plaintiffs fail to state the date they resumed occupancy, and they fail to state the date when the work was substantially completed. 16. For a breach to have occurred, the plaintiffs would have to show that the defendant failed to perform under a duty imposed by the contract both patties executed. 17. Because Plaintiffs seek to enforce the contract dated February 12, 2001, they are required to establish sufficient facts upon which the Court could grant the relief requested. WHEREFORE, Defendant William K. Salomone, respectfully requests that Count I of Plaintiffs' Fast Amended Complaint, Breach of Contract, be dismissed for insufficiency of pleading in the nature of a demurrer and that judgment be entered for Defendant William K. Salomone and against the plaintiffs, including an award of attorneys fees, pursuant to paragraph 11 of the contract. 18. Paragraphs one through seventeen are hereby incorporated by reference as if set forth fully herein. 19. Plaintiffs allege that defendant breached his duty of care by undertaking the project, namely the repair work contracted for, and that the Plaintiffs suffered damages that were reasonably foreseeable. 20. Plaintiffs allegation is that the defendant breached his duty of care to Plaintiffs therefor, entering into the contract with them. 21. Defendant's actions in engaging in the contract do not constitute a breach of duty in negligence, and therefore, the cause of action for negligence must be stricken for its failure to assert breach of a duty of care which may therefore be evaluated for causation and damages. 22. Plaintiffs fail to assert such a duty and therefore, no relief can be granted without the allegation of a breach of a duty of care owed by Defendant to Plaintiffs WHEREFORE, Defendant William K. Salomone, respectfully requests that Count II of Plaintiffs' First Amended Complaint, Negligence, be dismissed for insufficiency of pleading in the nature of a demurrer and that judgment be entered for Defendant William K. Salomone and against the plaintiffs, including an award of attorneys fees, pursuant to paragraph 11 of the contract. Respectfully Submitted, May 27, 2004 7 WOLF, ESQUIRE or Defendant, William K. Salomone Hanover Street, Suite 201 PA 17013-3307 (717) 241-4436 Supreme Court ID NO. 87380 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT MARY JANE PASCOE and JUANITA PASCOE, Plaintiffs V. WILLIAM K. SALOMONE, an individual d.b.a. Keystone Fite Restoration, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -• LAW DOCKET NO. 2004-00404 CIVIL JURY TRIAL REQUESTED CERTIFICATE OF SERVI as by I hereby certify that a copy of the foregoing answer to new matter was served dd -ss date addressed depositing same in the Post Office at Carlisle, PA, first class mail, postage P Paid, follows: CHRISTOPHERT. RESTAK, ESQ 213 CARLISLE STREET HANOVER, PA 17331-2410 Date: M_ Tv 27.2004 V Q WOLF, ESQUIRE or Defendant, William K Salomone Hanover Street, Suite 201 Carlisle, PA 17013-3307 (717) 241-4436 Supreme Court ID NO. 87380 ?-, ? b .° ?? :'-. Z n,? -. -i ?n N ti , ? a ??? <- -o -ri J ~?- `n a?, Curtis R. Long Prothonotary Offire of the Protbonotarp ?urnberCanb ?QUntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 014 - q04/ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573