HomeMy WebLinkAbout08-2978WOOLFORD LAW, P.C.
By: Timothy J. Woolford, Esquire
Attorney I.D. No. 78941
Ciara C. Young, Esquire
Attorney LD. No. 202994
Wheatland Place
941 Wheatland Avenue, Suite 402
Lancaster, PA 17603
SECCO, INC.
1111 Primrose Avenue
Camp Hill, PA 17011,
Plaintiff,
V.
A&A DESIGNS, INC.
HCR 67 Box 34
Mifflin, PA 17058
Defendant.
Attorneys for Plaintiff
SECCO, Inc.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
JURY TRIAL DEMANDED
No. p$ - aq'78 C: ivi l der'
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, entering a written appearance personally or by attorney and filing and writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
1-800-990-9108
WOOLFORD LAW, P.C.
By: Timothy J. Woolford, Esquire
Attorney I.D. No. 78941
Ciara C. Young, Esquire
Attorney I.D. No. 202994
Wheatland Place
941 Wheatland Avenue, Suite 402
Lancaster, PA 17603
SECCO, INC.
1111 Primrose Avenue
Camp Hill, PA 17011,
Attorneys for Plaintiff,
SECCO, Inc.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff, JURY TRIAL DEMANDED
V.
A&A DESIGNS, INC.
HCR 67 Box 34
Mifflin, PA 17058
Defendant.
No. D - 2 97 FQ ?tw
COMPLAINT
AND NOW, comes Plaintiff, SECCO, Inc. ("SECCO"), by and through its undersigned
counsel, Woolford Law, P.C., who hereby files this Complaint against Defendant, A&A
Designs, Inc. ("A&A" or the "Defendant"), and in support thereof, avers the following:
Parties
1. Plaintiff, SECCO, is a business corporation duly organized and existing under the
laws of the Commonwealth of Pennsylvania with a business address of 1111 Primrose Avenue,
Camp Hill, Pennsylvania, 17011.
2. Defendant, A&A, is a business corporation duly organized and existing under the
laws of the Commonwealth of Pennsylvania with a business address of 1817 Fox Hunt Lane,
Harrisburg, Pennsylvania, 17110. Attached hereto and incorporated herein as Exhibit "A" is a
copy of the Pennsylvania Department of State business information sheet for A&A.
Jurisdiction and Venue
3. Venue is proper in Cumberland County because it is the county where the
transaction or occurrence took place (failure to make payment) out of which this cause of action
arose.
4. In the absence of an agreement to the contrary, payment is due at SECCO's place
of business and venue is proper there in a breach of contract action alleging failure to make
payment.
Factual Background
5. SECCO is a well-established HVAC, plumbing and electrical contractor who
performs work throughout the greater Harrisburg area.
6. In the summer of 2004, SECCO entered into an oral contract with A&A to
perform various plumbing and electrical work (the "Contract") on a project located at 3960
North Sixth Street, Harrisburg, Pennsylvania, 17110 (the "Project"). Attached hereto and
incorporated herein as Exhibit "B" are copies of executed work orders detailing the work
performed and A&A's acceptance of such work.
7. SECCO performed its work in a timely, good and workmanlike manner.
8. Pursuant to the Contract, SECCO submitted five invoices to A&A for the work
that it performed on the Project (the "Invoices"). True and correct copies of the Invoices are
attached hereto and incorporated herein as Exhibit "C."
9. The total amount of the Invoices is $11,076.04.
10. The Invoices clearly stated when payment was due and that interest would accrue
on any outstanding balance at the rate of one and one-half (1.5) percent per month.
11. Payment was due in Fall, 2004.
2
12. To date, SECCO has not received any payments from A&A.
13. As of April 2008, interest has accrued in the amount of $7,032.18.
14. Therefore, the total amount due and owing SECCO is $18,108.22.
15. Inclusive of interest and penalties pursuant to the Contractor and Subcontract
Payment Act, 73 Pa.C.S.A. §501, et. seq., SECCO is due $22,796.35.
16. Defendant has failed and refused to pay SECCO the amount due.
17. SECCO completed its work in accordance with the requirements of the parties'
agreement and is entitled to payment in full.
COUNTI
Breach of Contract
18. Plaintiff incorporates by reference Paragraph Nos. 1 through 17 as if set forth
fully herein.
19. A valid contract existed between SECCO and A&A.
20. Pursuant to the terms of the Contract, Defendant had a duty to pay SECCO all
amounts due and owing for the labor, equipment, materials and tools SECCO provided to the
Project within thirty (30) days of receipt of an invoice.
21. Despite repeated requests and demands, Defendant failed and refused to pay
SECCO the amounts due under the Contract.
22. At all material times, SECCO performed in accordance with the terms of the
Contract and provided labor, equipment, materials and tools in a timely, good and workmanlike
manner.
23. Defendant materially breached the terms of the Contract by failing and refusing to
pay SECCO.
3
24. As a result of the Defendant's breach of contract, SECCO suffered damages in
excess of $18,108.22.
WHEREFORE, Plaintiff, SECCO, Inc., respectfully requests that this Honorable Court
enter judgment in its favor and against Defendant, A&A Designs, Inc. and award SECCO, Inc.
damages in excess of $18,108.22, plus interest, penalties, attorneys' fees, costs of suit and any
other further relief the Court deems just, proper and equitable.
COUNT II
Unjust Enrichment/Ouantum Meruit
25. SECCO incorporates by reference Paragraph Nos. 1 through 24 as if set forth
fully herein.
26. SECCO supplied labor, equipment, materials and tools to the Project for
Defendant's benefit and fully expected compensation for such work.
27. All of the work discussed above was performed at the direction of Defendant.
28. The amounts charged by SECCO for its work on the Project were fair and
reasonable.
29. Defendant accepted and retained the benefits conferred upon it by SECCO,
including repairs and upgrades to Defendant's plumbing and electrical systems.
30. The benefits conferred by SECCO increased the value of the Defendant's
property. Therefore, it would be inequitable for Defendant to retain the benefits without
payment for the value of the labor and materials provided by SECCO.
31. If Defendant does not compensate SECCO for the work that it performed on the
Project, Defendant will be unjustly enriched by SECCO's work.
32. Defendant's retention of the benefits of the labor and materials supplied by
SECCO without compensating SECCO would result in gross inequities.
4
33. Defendant wrongfully received the benefits of the improvements to its plumbing
and electrical systems by not paying for the labor and materials that SECCO supplied to the
Proj ect.
34. It would be unconscionable for Defendant to retain the benefits of the improved
electrical and plumbing systems without paying for such services and materials.
35. Defendant misled SECCO to believe that it would be paid in full for all the labor
and materials provided to the Project.
36. The reasonable value of the unpaid labor and materials supplied to the Project by
SECCO is in excess of $18,108.22.
WHEREFORE, Plaintiff, SECCO, Inc., respectfully requests that this Honorable Court
enter judgment in its favor and against Defendant, A&A Designs, Inc. and award SECCO, Inc.
damages in excess of $18,108.22, plus interest, penalties, attorneys' fees, costs of suit and any
other further relief the Court deems just, proper and equitable.
COUNT III
Violation of the Contractor and Subcontractor Payment Act
37. SECCO incorporates by reference Paragraph Nos. 1 through 36 as if set forth
fully herein.
38. The Contractor and Subcontractor Payment Act, 73 Pa.C.S.A. §501, et. seq. (the
"Payment Act") is applicable to this Contract.
39. Under the Payment Act, SECCO is entitled to payment for the work it performed.
40. Pursuant to the Payment Act, SECCO is entitled to recover attorneys' fees and a
penalty at the rate of one percent per month for all Contract funds unlawfully withheld by
Defendant.
5
41. Defendant, A&A, is an "owner" and SECCO is a "contractor" as defined by the
Payment Act, 73 Pa.C.S.A. §502.
42. Defendant, A&A, as owner, was required to pay SECCO for the materials and
labor supplied by SECCO within thirty (30) days of its receipt of SECCO's invoices for
payment.
43. Defendant failed to timely pay SECCO for the full value of its invoices relating to
the Project as required by the Payment Act.
44. Defendant did not provide any written notice of any deficiency items to SECCO
relating to its work and it has no justification or excuse for failing to timely pay SECCO.
45. Defendant's failure and refusal to pay SECCO for its materials and labor
constitutes a breach of the Contract and a violation of the Payment Act.
46. Pursuant to the Payment Act, SECCO is entitled to the contractual interest rate of
one and one-half (1.5) percent per month and an additional statutory penalty of one (1) percent
per month - an amount in excess of $11,720.31 as of April 9, 2008.
47. In the event that SECCO is not entitled to the contractual interest rate of one and
one-half (1.5) percent, which is strenuously denied, SECCO can collect interest at the rate of one
(1) percent pursuant to the Payment Act.
48. Inclusive of interest pursuant to the contact and penalties pursuant to the Payment
Act, SECCO is entitled to an amount in excess of $22,796.35.
WHEREFORE, Plaintiff, SECCO, Inc., respectfully requests that this Honorable Court
enter judgment in its favor and against Defendant, A&A Designs, Inc. and award SECCO, Inc.
damages in excess of $22,796.35, plus interest, penalties, attorneys' fees, costs of suit and any
other further relief the Court deems just, proper and equitable.
6
VERIFICATION
I, Fran Gilbert, am the Controller for SECCO, Inc., and I verify that I am authorized to
make this Verification on behalf of Plaintiff. I verify that the language of the document is that of
counsel and not my own; and that the facts set forth in the foregoing document are true and
correct to the best of my knowledge, information and belief. I understand the statements herein
are made subject to the penalties of perjury and 18 Pa. C.S.A. § 4904 relating to unworn
falsification to authorities.
n. It A
Fran Gilbert Date: 5 - q - C
8
Respectfully submitted,
WOOLFORD LAW, P.C.
By:
Timothy J. Woolford
Attorney I.D. No. 78941
Ciara C. Young
Attorney I.D. No. 202994
Wheatland Place
941 Wheatland Avenue, Suite 402
Lancaster, PA 17603
(717) 290-1190
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Page 1 of 1
usiness Entity
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Business Corporation - Domestic - Information
Entity Number: 3139545
Status: Active
Entity Creation Date: 4/25/2003
State of Business.: PA
1817 FOX HUNT LANE
Principal office Address:
HARRISBURG PA 17110-
Mailing Address: No Address
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INVOICE
To A & A DESIGNS
3301 A HOFFMAN
HARRISBURG, PA
17110
Job Location 3960 N 6TH ST
HARRISBURG, PA
17110
MOVE EQUIPMENT FROM OLD BLDG TO NEW BLDG
No/ W34064
Inv. Date Aug 18/04
HVACR SERV
W/O No. 024712
Cust Code 7178057094
Called by OLGA
Terms NET 30
Reference # 39431
Start Date Jul 8/04
End Date Jul 12/04
MATERIALS Qty
---------
----- Price
------------- Total
-----------
-------------------------------------
BLK NIPPLE 3/4 X 4 --
1.00 2.20 E 2.20
BLK FTG CAP 3/4 1.00 3.37 E 3.37
BLK FTG VALVE GAS 3/4 BALL 1.00 23.20 E
- 23.20
-----------
Total Materials 28.77
"A" TECH HVACR 1.00 Hrs 66.00
"A" TECH HVACR 3.50 Hrs 231.00
"A" TECH HVACR 3.50 Hrs 231.00
"A" TECH HVACR 3.50 Hrs 231.00
"A" TECH HVACR 1.00 Hrs 66.00
DISPATCH FEE 79.00
TOTAL INVOICE AMOUNT DUE 09/17/04
A 1.5% PER MONTH FINANCE CHARGE WILL BE ADDED TO ANY
INVOICE NOT PAID IN FULL BY DUE DATE.
------------
Subtotal 932.77
Tax on 932.77 55.97
------------
Total Billing 988.74
INVOICE
No/ W34065
Inv. Date Aug 18/04
HVACR SERV
W/O No. 024896
Cust Code 7178057094
To A & A DESIGNS
3301 A HOFFMAN
HARRISBURG, PA
17110
Called by OLGA
Terms NET 30
Job Location 3960 N 6TH ST
HARRISBURG, PA
17110
TRACING LINES FOR BASEMENT PANEL
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
DISPATCH FEE
Start Date Jul 20/04
End Date Jul 22/04
4.00 Hrs 224.00
3.50 Hrs 196.00
79.00
TOTAL INVOICE AMOUNT DUE 09/17/04
A 1.5% PER MONTH FINANCE CHARGE WILL BE ADDED TO ANY
INVOICE NOT PAID IN FULL BY DUE DATE.
Subtotal
Tax on 499.00
Total Billing
------------
499.00
29.94
------------
528.94
INVOICE
No/ W34114
Inv. Date Aug 23/04
HVACR SERV
W/O No. 025172
Cust Code 7178057094
To A & A DESIGNS
3301 A HOFFMAN Called by OLGA
HARRISBURG, PA Terms NET 30
17110 Reference # 40020
Job Location 3906 N 6TH ST
HARRISBURG, PA Start Date Aug 19/04
17110 End Date Aug 19/04
REACH IN REF - UP IN TEMP
"A" TECH HVACR 2.00 Hrs 132.00
DISPATCH FEE 79.00
TOTAL INVOICE AMOUNT DUE 09/22/04
A 1.5% PER MONTH FINANCE CHARGE WILL BE ADDED TO ANY
INVOICE NOT PAID IN FULL BY DUE DATE.
------------
Subtotal 211.00
Tax on 211.00 12.66
------------
Total Billing 223.66
INVOICE
To A & A DESIGNS
3301 A HOFFMAN
HARRISBURG, PA
17110
Job Location 3960 N 6TH ST
HARRISBURG, PA
17110
MISCELLANEOUS ELECTRICAL WORK AND PLUMBING FOR SINK
No/ W34168
Inv. Date Aug 30/04
ELEC SERV
W/O No. 024688
Cust Code 7178057094
Called by OLGA
Terms NET 30
Start Date Aug 26/04
End Date Aug 18/04
MATERIALS
-------------------------------------- Qty
------------- Price
---------
---
-- Total
-
--
--
WALL BOX
9.00
3.32 -
E -
--
---
29.88
WALL BOX WITH BRACKET 6.00 3.99 E 23.94
DUPLEX REC 21.00 3.71 E 77.91
IVORY WALL PLATE 8.00 2.66 E 21.28
4X4 BOX 1.00 1.89 E 1.89
DUPLEX BOX COVER 1.00 2.34 E 2.34
4X4 WALL BOX WITH CLAMPS 1.00 0.66 E 0.66
12/3 MC 165.00 1.36 E 224.40
MC CONNECTORS 29.00 0.98 E 28.42
12/2 MC 340.00 0.73 E 248.20
IVORY 15A SINGLE POLE SWITCH 4.00 3.62 E 14.48
ELEC JB 4SQ 2-1/81) 1/2&3/4KO'S 6.00 3.62 E 21.72
ELEC JB COVER 4SQ BLANK 6.00 1.61 E 9.66
ELEC HANDY BOX 1-7/8D W-1/2KO 4.00 3.17 E 12.68
ELEC HANDY BOX COVER SGL RECPT 1.00 1.24 E 1.24
SQD BKR 1P 20A 11.00 15.73 E 173.03
ELEC CONN MC 1/2 9.00 4.77 E 42.93
ELEC CONDULET LB 1/2 1.00 9.22 E 9.22
ELEC CONDULET LB COVER 1/2 1.00 6.25 E 6.25
ELEC NIPPLE CHASE 1/2 1.00 1.50 E 1.50
ELEC CONDUIT EMT 1/2 40.00 1.38 F 55.20
ELEC CONN EMT 1/2 SETSC 7.00 0.52 E 3.64
ELEC COUP EMT 1/2 TO MC 3/8 5.00 2.93 E 14.65
ELEC COUP EMT 1/2 SETSCR 6.00 0.58 E 3.48
ELEC PVC LB 1/2 W/COV 1.00 6.50 E 6.50
ELEC PVC ADPT TERM 1/2 1.00 0.33 E 0.33
(Continued)...
INVOICE
No/ W34168
Inv. Date Aug 30/04
Continued ...Pg2
ELEC WALLPLATE RECEPT DUP 1G I
20A 125/250V 3P 4W TWLK PLUG
3P 4W 20A 125/250V TWLK SINGLE
WIRE THHN #12 STR COPPER BLACK
WIRE THHN #12 SOL COPPER WHITE
WIRE THHN #12 STR COPPER GREEN
ELEC RECEPT 20A 125V GFI IV
HORIZONTAL DUP. W/P COVER
ELEC SW SPST 20A 120-277V BR
ELEC JB COVER 4SQ DBL SW
ELEC HANDY BOX COVER BLANK
ELEC WALLPLATE SW BLANK 1G IV
ELEC HANDY BOX COVER SWITCH
Total Materials
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
"A" TECH ELECTRICIAN
DISPATCH FEE
ELECTRICAL INSPECTION
TOTAL INVOICE AMOUNT DUE 09/30/04
A 1.5% PER MONTH FINANCE CHARGE
INVOICE NOT PAID IN FULL BY DUE
1.00 0.92 E 0.92
1.00 46.35 E 46.35
1.00 54.48 E 54.48
30.00 0.23 F 6.90
30.00 0.18 F 5.40
30.00 0.24 E 7.20
4.00 25.74 E 102.96
1.00 3.01 E 3.01
2.00 7.61 E 15.22
1.00 3.28 E 3.28
2.00 1.09 E 2.18
1.00 1.27 E 1.27
1.00 0.74 E
- 0.74
-----------
1,285.34
0.25 Hrs 14.00
4.75 Hrs 266.00
5.25 Hrs 294.00
6.00 Hrs 336.00
3.75 Hrs 210.00
5.50 Hrs 308.00
4.25 Hrs 238.00
4.00 Hrs 224.00
4.75 Hrs 266.00
3.50 Hrs 196.00
6.50 Hrs 364.00
3.25 Hrs 182.00
4.50 Hrs 252.00
2.00 Hrs 112.00
9.25 Hrs 518.00
4.50 Hrs 252.00
7.25 Hrs 406.00
79.00
1.00 77.00 77.00
WILL BE ADDED TO ANY
DATE.
Subtotal
Total Billing
------------
5,879.34
------------
5,879.34
INVOICE
No/ W34239
Inv. Date Aug 31/04
HVACR SERV
W/O No. 025350
Cust Code 7178057094
To A & A DESIGNS
3301 A HOFFMAN
HARRISBURG, PA
17110
Called by SMO
Terms NET 30
Job Location 3906 N 6TH ST
HARRISBURG, PA
17110
MISC PLUMBING/ELECTRICAL
MATERIALS
Start Date Sep 2/04
End Date Sep 9/04
Qty Price Total
--------------------------------------
WIRE MC CABLE 10/2 -------------
55.00 ---------
3.12 ------
F -----------
171.60
ELEC JB 4SQ 2-1/8D 1/2&3/4KO'S 1.00 3.62 E 3.62
ELEC JB COVER 4SQ BLANK 1.00 1.61 E 1.61
ELEC CONN MC 3/8 2.00 1.09 E 2.18
ELEC COUP EMT 1/2 TO MC 3/8 1.00 2.93 E 2.93
ELEC CONN EMT 1/2 SETSC 1.00 0.52 E 0.52
ELEC CONDUIT EMT 1/2 5.00 1.38 F 6.90
BRACKET STRAINER KIT 1.00 27.81 E 27.81
DOUBLE FLANGE 1.00 7.49 E 7.49
PVC FTG EL 45D 3 1.00 4.02 E 4.02
PVC FTG COUP RED 3 X 2 1.00 5.76 E 5.76
PVC FTG EL 45D ST 2 1.00 2.38 E 2.38
11211" GALV PIPE STRAP" 2.00 0.91 E 1.82
PVC PIPE 2X20 SCH 40 20.00 1.39 E 27.80
"3"" PVC PIPE" 35.00 2.59 E 90.65
3" SHOULDER VENT 1.00 87.18 E 87.18
PVC FTG BUSH 25LP * 1-1/2SLP 1.00 3.15 E 3.15
PVC FTG TEE 1-1/2 1.00 3.49 E 3.49
1-1/2 DWV PVC 45 ELL 4.00 1.05 E 4.20
"1 1/211" PVC FEMALE ADAPT" 2.00 1.12 E 2.24
"1 1/211" AIR VENT TRAP" 2.00 4.44 E 8.88
HDWR THRD ROD 3/8 X 6 ZINC 12.00 6.04 E 72.48
"3/411" X 1/211" RUBATEX INSULAT 100.00 7.00 E 700.00
BLK FTG VALVE GAS 1/2 BALL 7.00 15.48 E 108.36
1 1/2 S X MIP SCH 80 PVC ADAPT 1.00 12.81 E 12.81
COPW FTG TEE 1/2 4.00 1.32 E 5.28
(Continued) ...
INVOICE
No/ W34239
Inv. Date Aug 31/04
Continued...Pg2
COPW FTGEL90D 1/2 28.00 1.69 E 47.32
COPW PIPE TYPE L 1/2 WATER HAR 130.00 1.76 E 228.80
BLK FTG VALVE BOILER DRAIN 1/2 2.00 8.69 E 17.38
COPW FTG CAP 1/2 2.00 0.73 E 1.46
BLK NIPPLE 1/2X1-1/2 1.00 1.10 E 1.10
PVC FTG EL 90D 1-1/2 1.00 2.90 E 2.90
PVC FTG TRAP P 2" 1.00 6.07 E 6.07
PVC FTG EL 90D 2 2.00 2.04 E 4.08
111-1/2"" 17GA CHROME P-TRAP" 1.00 29.34 E 29.34
PVC FTG PLUG 1-1/4MPT 1.00 2.38 E 2.38
EXPANDING FOAM SEALANT CAN 2.00 14.70 E 29.40
3X2 WYE 2.00 10.39 E 20.78
3X2 BELL 1.00 11.79 E 11.79
WALL PLATE 24.00 1.08 E 25.92
1/2 SPLIT RING 26.00 0.73 E 18.98
Total Materials ------------
1,812.86
"A" TECH HVACR 2.25 Hrs 148.50
"A" TECH HVACR 6.00 Hrs 396.00
"A" TECH HVACR 0.75 Hrs 49.50
"A" TECH HVACR 8.75 Hrs 577.50
"A" TECH ELECTRICIAN 7.00 Hrs 392.00
DISPATCH FEE 79.00
TOTAL INVOICE AMOUNT DUE 10/02/04
A 1.5% PER MONTH FINANCE CHARGE WILL BE ADDED TO ANY
INVOICE NOT PAID IN FULL BY DUE DATE.
Subtotal
Total Billing
------------
3,455.36
------------
3,455.36
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11. SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-02978 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SECCO INC
VS
A&A DESIGNS INC
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
A&A DESIGNS INC
but was unable to locate Them
deputized the sheriff of JUNIATA
in his bailiwick. He therefore
serve the within COMPLAINT & NOTTCR
County, Pennsylvania, to
On June 17th , 2008 , this office was in receipt of
attached return from JUNIATA
Sheriff's Costs: So answers:
Docketing 18.00
Out of County 9.00''e!1
Surcharge 10.00 R. Thomas Kline
Dep Juniata Co 35.15 Sheriff of Cumberland County
Postage 2.19
7 4 . 3 4 ? ??/gyp
06/17/2008
WOOLFORD LAW PC
Sworn and subscribe to before me
this day of
A. D.
r
?rY
In The Court of Common Pleas of Cumberland County, Pennsylvania
SECCO Inc
vs.
A&A Designs Inc
Now, May 16, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Juniata
No. 08-2978 civil
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff. //.
Sheriff of Cumberland County, PA
Please mail return of service to Cumberland County Sheriff. Thank you.
Affidavit of Service
I
Now, may 29 , 20o8 , at 4:21 o'clock P. M. served the
Within Notice & Complaint
Upon A&A Designs, Inc.
at HC 67, Box 34, Mifflin PA 17058
by handing to Olga Lembesis, president/owner of A&A Designs, Inc.
a true and attested
copy of the original
Notice & Complaint
and made known to her the contents thereof.
So answers,
? GZo (? q D ?
Sheriff of Juniata L.Z County, PA
Sworn and subscribed before
me this _ZL_ day of , 20 0
COSTS
SERVICE
MILEAGE
JOYCE PAGE
nPel TY PROTHONOTARY
MY COMMISSION EXPIRES
FIRST MONDAY IN 1Ah1„PnnQ
$ 18.00
15.15
2.00
$ 35.15
$ 39.85
ATTEMPTED SERVICE
MAY= Tlugf Ull FAtIF INITIALS
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FRIEDMAN & KING, P.C.
Richard S. Friedman, Esquire
ID #07176
3820 Market Street
Camp Hill, PA 17011
Tel.: (717) 236-8000/Fax: (717) 236-8080
e-mail: fziedmanandking@botmail.com
SECCO, INC.,
V.
Plaintiff
A&A DESIGNS, INC.,
Defendant
Attorney for Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-2978 Civil Term
CIVIL ACTION - LAW
ENTRY OFAPPEARANCE
Kindly enter my appearance on behalf of the Defendant, A&A Designs, Inc.
Respectfully submitted,
FRIEDMAN & KINGeP.C.
Date:
Ricl &d S.1? edman,
390 Market Street
Camp Hill, PA 17011
(717) 236-8000
Esquire
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SECCO, INC., : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA.
V.
A&A DESIGNS, INC.,
Defendant
: NO. 08-2978 Civil Term
CIVII, ACTION - LAW
Ile parties hereby agree and stipulate to the following:
1. The Plaintiff filed a Complaint against the Defendant alleging that Defendant failed to
pay for vatious plumbing and electrical work performed by Plaintiff
2. The Plaintiff and Defendant have agreed that judgment would be entered against the
Defendant in the amount of $22,796.35.
3. It is agreed that tie judgment will be satisfied upon payment of $15,000.00 to Plaintiff
by Defendant, at $500.00 per month beginning fuly 15, 2008. Payments far July 15, 2008 and
August 15, 2008 have been made.
4. In the event of non payment by Defendant, Plaintiff will provide written notice to
Defendant with a five (5) day opportunity to cure. In the event the default is not cured within
said five (5) day period, Plaintiff may execute on any and all assets of Defendant up to
$22,796.35, less payments received, and Defendant waives any right to attempt to open the
judgment.
Ciara C. Young, Esq*e U
Attorney I.D. No. 202994
Woolford Law, P.C.
941 Wheatland Ave., Suite 402
Lancaster, PA. 17011
(717) 290-1190
Attorney for Plaintiff SECCO, Inc.
Date: Q - 5 - (0 `._.._
7
tau, Bsquire
Attorney I.D. No.. 07176
Friedman & King, P.C.
3820 Market 8t.
Camp Hill, PA 17011
(717) 236-8000
Attorney for D da tq A&A Designs, Inc.
Date: C1 6 16f
r.
40
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24
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WOOLFORD LAW, P.C.
By: Timothy J. Woolford, Esquire
Attorney I.D. 78941
By: Ciara C. Young, Esquire
Attorney I.D. 202994
Wheatland Place
941 Wheatland Avenue, Suite 402
Lancaster, PA 17603
tLEU"??° ? tGc. ?,
lotI DEC 29 PM z
GUITg E??RLO C.'00 V
PE0511
Attorneys for Plaintiff,
Secco, Inc.
SECCO, INC.
Plaintiff
V.
A&A DE,,IGNS, INC.
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 08-02978
PRAECIPE
TO: Prothonotary 4-
Kindly 8 e Kindly mark the above-captioned matter settled, discontinued and ended with prejudice.
Respectfully submitted,
WOO ORD LAW, P
By:
Timothy J. Woolford
Attorney I.D. No. 789 1
Ciara C. Young
Attorney I.D. No. 202994
Wheatland Place
941 Wheatland Avenue, Suite 402
Lancaster, PA 17603
P: (717) 290-1190
F: (717)290-1196
1. . s
CERTIFICATE OF SERVICE
I, Ciara C. Young, an attorney with Woolford Law, P.C., certify that on this date, I served
a true and correct copy of the foregoing Praecipe upon the party listed below, by depositing the
same in the United States mail, postage prepaid, addressed as follows:
Richard S. Friedman, Esquire
Friedman & King, P.C.
3820 Market Street
Camp Hill, PA 17011
6, L 0?
Ciara C. Young
Date: December 28, 2011
2