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Home My WebLink About04-0907 DOUBLE GOLD. INC. d/b/a RESTORE CORE, MICHAEL GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: -:J-f' - tJ~7 ~ v. DABISE CAMERO, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense 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 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(s). 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. Dauphin C'Ol1Jlty r ~wyer Refprrat ')t'fYil;e 213 H01lh front Street Harrisburg, Pennsylv<lnia 17101 717 232 7536 Cu..rv. ro-la....r-) d ~-t:.:1 fu.r- ASSn. !3f2 S &:d fbrd Sf c.WIISIe; l'A no 13 24Cl. 31lu\c NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia excrita 0 en persona 0 por abogado y archivar en la corte an forma escrita sus defensas 0 sus objectiones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 aIivio que es predido en Ia peticion de demanda. Usted puede perder dinero 0 sus propriendades 0 stros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABROGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 S1 NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONCO A LA OFICINA CUY A DIRECC10N SE ENCUENTRA EXCRITA ABAJO PARA AVERIGUAR DONDE SE PAUEDE CONSEQUIR ASSISTANCIA LEGAL. Bauphill Cuutlty Lawyer Itdc.uaI Service- 213 Nulll. froot Stroot ftiluisburg, I\-.lu"ylvallia 17101 717 232 7536 tu.rntuLo...nd COu--i1~ 5()J As<;;n. 3'2. .:so Lclh 6eofOrCl ~-\... ~l;S\e1 PA n()(3 In 2--qt;. 3 \ \.p y 2 , DOUBLE GOLD, INC. d/b/a RESTORE CORE, MICHAEL GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 01 - '10/ v. CIVIL ACTION - LAW DABISE CAMERO, Defendant COMPLAINT 1. Plaintiff, Double Gold, Inc. d/b/a Restore Core, d/b/a Michael Goldberg, Contractor ("Plaintiff") is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania being duly registered to do business in the Commonwealth of Pennsylvania in accordance with the Act of Assembly so provided with its principal place of business in Pennsylvania located at 2322 North Seventh Street. Harrisburg, Dauphin County, Pennsylvania 17110. 2. Dabise Camero ("Defendant") is an adult individual residing at 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. On or about September 8, 2002 Plaintiff and Defendant entered into a contract for restoration services and construction repairs of the Defendant's property situated at 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. A true and correct copy of the authorization is attached hereto, made a part hereof and marked as Exhibit" A" . 4. At the time of entering into the contract with the Plaintiff, Defendant was the owner of the property located at 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3 5. On September 8, 2002 Plaintiff entered into the performance of the contract and as called for by the same. 6. In accordance with the contract the Plaintiff did perform the work and provided all material necessary for the restoration/construction repair work in accordance with the contract between the parties. Copies of Invoice worksheets showing cost of structural repairs, restoration services, cleaning, supplemental repairs and credits are attached hereto, made a part hereof and marked as Exhibit "B". 7 . The restoration/construction repair work to the Defendants' property located at 511 Erford Road, Camp Hill. Cumberland County, Pennsylvania was completed by Plaintiff on or about January 16, 2003 at a cost of $11,082.52. 8. Plaintiff has repeatedly demanded payment of the amount due, but Defendant has neglected and refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against Defendant, Dabise Camero for the sum of $11,082.52 with interest to date of $1.371.74 for a balance of $12,454.26 plus costs and attorney's fees. 4 Date: J ~J ~cp Peters & Wasilefski By: 1~ ~> ~~ William J. Peters, Esquire Attorney ID #09983 2931 North Front Street Harrisburg, Pennsylvania 17110 717-238-7555 Attorney for Plaintiff, Double Gold, Inc. d/b/a Restore Core Michael Goldberg Contractor 5 FIB 2 42004 VERIFICATION I hereby affirm that the following facts are correct: I am the Plaintiff and am authorized to make this Verification; the attached Complaint is based upon information which I have furnished to my counsel and information which has been gathered by my counsel in the preparation of the lawsuit. The language is that of counsel and not of me. I have read the Complaint and to the extent that the same is based upon information that I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: //IZ~ YI~) Michael Goldberg (..~ ~~ ,,: ~ ;;. ~ '''\\ ~ '\S "- ,,' "{\. ~ ~ --J \,f'. . '\ '.1\ "'~ \). ~ '" ~ '!"\ ~ ~ i.f"l ~ \j ~~ ~~ ~~ ~ o c- ~ ~/~? -':"';,-.: ' D:; f~\~---, ~~ ;~'-~ ;::,'j '-"'" -' .-'-""-0".. ~-- , w .." -,~ ~ f :~) .(..'- Cr-\ \;:\ "-..".J ....., ~-") C'.:;;) r- -r; =-:3 f{'j :!J j'.- :!;[2J (.=~(~ ::J: ;>>. ~ :;1:; -------..----- SHERIFF'S RETURN - REGULAR CASE NO: 2004-00907 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOUBLE GOLD INC ET AL VS CAMERO DABISE 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 CAMERO DABISE the DEFENDANT , at 1911:00 HOURS, on the 3rd day of March , 2004 at 511 ERFORD ROAD CAMP HILL, PA 17011 by handing to DABISE CAMERO a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 10.35 .00 10.00 .00 38.35 So Answers: r~~'r., R. Thomas Kline 03/04/2004 PETERS & WASIL Sworn and Subscribed to before By: me this ,(k day of ~ ;l(}t>'f A.D. n ,. (1 Jn/~ tt.#. \. I'1"'prothonotary . Double Gold, Inc. d/b/a Restore Core, Michael Goldberg, Contractor, Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAlro COUNTY, PENNSYLVANIA . . . . v. No. 04-907 CIVIL : Dabise Camero, . . Defendant NOTICE TO PLEAD TO NEW Ml~TTER To: Double Gold, Inc. d/b/a Restore Core, Michael Goldberg, Contractor (plaintiff) You are hereby notified to file a written response to the enclosed new matter within twenty (20) daysl from service hereof or a judgment may be entered against you. -&-/ Iff~ Kent H. Patterson Attorney for defendant 221 pine Street Harrisburg, PA 17101 (717) 238-4100 o c ?:"' ..Di.-; C.!)Lt' ,",,-_. :. --:::; ~(. '- ~;f~:- )>~; ~ ,..., = <= .r :!: 0;>" -< ~ -I rn~ -om ..jy 00 :'-~-" ():u -."...(; -c:-rn 9\ '"'" ::'j] -, N U1 :E ..>.. .r:- 1') N Double Gold, Inc. d/b/a Restore Core, Michael Goldberg, Contractor, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAllm COUNTY, PENNSYLVANIA : . . v. : : No. 04-907 CIVIL : Dabise Camero, . . Defendant . . DEFENDANT'S ANSWER WITH NEW ~TTER TO PLAINTIFF'S COMPLAINT And now comes defendant, Dabis Camero, by his attorney, Kent H. Patterson, and files this answer with new matter as follows: 1. Admitted. 2. Admitted but the correct spelliDLg of defendant's name is Dabis Camero. 3. Admitted in part and denied in ];,art. It is admitted that defendant authorized plaintiff to do restoration/construction repair work to defendant's property but it~ is denied that Exhibit A represents the authorization or a contr2Lct for the restoration/construction repair work. 4. Admitted. 5. Denied. It is denied that plaintiff entered into the performance of any contract for restol~ation/construction repair work to defendant's property on Sel~tember 8, 2002. 6. Admitted in part and denied in I~art. Although it is admitted that defendant performed restoral;ion/construction repair - 1 - work, it is denied that the work was done :in accordance with any contract, that the restoration/constructiolo. repair work which defendant requested plaintiff to perform WillS completed and that copies of invoice worksheets attached to plaintiff's complaint and marked Exhibit B show the cost of the restoration/construction repair work and credits. By way of further answer, it is averred that the restoration/construction repair work was not completed and was not done in a good and workmanlike manner. 7. Denied. It is denied that the restoration/construction repair work was completed by plaintiff on or about January 16, 2003 at a cost of $11,082.52. By way of further answer, it is averred that the costs and prices charged by plaintiff for labor and materials are not fair and reasonable costs and prices. 8. Admitted in part and denied in J;lart. It is admitted that defendant has not paid plaintiff, but; it is denied that plaintiff has repeatedly demanded payment from defendant. It is denied that defendant owes plaintiff the !~unts claimed due by plaintiff for the reasons set forth in thiLs answer and new matter. NEW MATTER 9. The authorization signed by defl9ndant as alleged in Exhibit A of plaintiff's complaint was no1: signed for the - 2 - restoration/construction repairs but was signed for authorization to do cleanup work only and was not dated lJY defendant. 10. Defendant signed the authorizati'Jn identified as Exhibit A in plaintiff's COlI\Plaint based Olo. the representation of an agent for plaintiff that it had to be signed so that plaintiff could do cleanup work but the agent did not: allow defendant to read the form and did not give defendant a copy of it. 11. plaintiff did not supply proper :materials and did not charge fair and reasonable prices for the materials and labor for the restoration/construction repair work. 12. Plaintiff failed to give defendant a credit of $99.70 for materials supplied by defendant for wo,rk done by plaintiff which credit plaintiff agreed to give defe,ndant. 13. Plaintiff failed to COlI\Plete the, work that it agreed to perform and further failed to do the we,rk in a good and workmanlike manner. 14. As a result of plaintiff's fail1:Lre to properly install the toilet in the first floor bathroom, dElfendant incurred a cost of $57.73 to reinstall the toilet. 15. As a result of plaintiff's failure to cOlI\Plete the work in a good and workmanlike manner, defend~lt will be required to expend the sum of $3,822.30 to correct thl! following deficiencies in the restoration/construction work perfcJrmed by plaintiff: - 3 - A. Window jam and sill in kitchen were installed in a poor and unworkmanlike manner with inq~roper materials, which will require removal and replacement. B. Kitchen light was improperl:1' installed which will require reinstallation. C. Kitchen door was not painted.. D. Upper kitchen cabinet door cannot be opened as a result of installation of improperly sized cabinets and defective installation which will require removal and replacement of two upper kitchen cabinets. E. Baseboard molding behind refrigerator in kitchen was not installed which will require installation. F. Countertop with backsplash in kitchen is defective and was improperly installed in that the laminate is separating and bubbling and the count:ertop does not fit properly against the wall, which will require removal and replacement of countertop and backspl.ash using existing sink. G. Carpet strip between kitchEln and living room floors was improperly installed and ~dll require replacement. H. Nails are popping from the drywall and areas of the drywall were not painted in the ;living room which will require fixing nail pops and repaint:lng. I. vinyl flooring and vinyl bllse cove were improperly installed in the first floor powder l~Oom, which will require - 4 - removal of floor and underlayment and installation of new vinyl floor, underlayment, vinyl base cove and carpet strip. J. vinyl flooring and underlayrnent, vinyl baseboard and toilet were improperly installed in second floor bathroom which will require detaching and resel;ing of toilet, removal and replacement of flooring and '10" uncierlayment, installation of new vinyl baseboard and installati.:)n of new carpet strip. 16. The condition or need to replace the one half inch underlayment (subfloor under theW' underlayment) in the second floor bathroom cannot be determined until the existing vinyl flooring and %" underlayment are removed during reconstruction and if it needs replacement, there will be an additional cost of $250.00. 17. Defendant has or will be required to expend a total of $4,229.73 to correct the defective constru,ction work done by plaintiff. WHEREFORE, defendant requests that pl.aintiff's complaint be dismissed. L !..!.!{~ AttornE~y for defendant 221 pille Street Harrisburg, PA 17101 (717) 2:38-4100 - 5 - VERIFICATION I, Dabis E. Camero, verify that the statements in the within answer and new matter are true a~1 correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: Double Gold, Inc. d/b/a Restore Core, Michael Goldberg, Contractor, plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAN!l COUNTY, PENNSYLVANIA . . . . . . v. : No. 04-90'7 CIVIL . . Dabise Camero, . . Defendant . . CERTIFICATE OF SERVICE f"'1;:;. //1/ AND NOW, this,L.> day of F'l ~ hereby certify that I this day served ,2004 I, Kent H. Patterson, the within answer with new matter by depositing a copy of same in t;he United States mail, postage prepaid, at Harrisburg, pennsylvanla, addressed to counsel of record for plaintiff as follows: william J. Peters, EsclUire Peters & wasilefski 2931 North Front Stre.!!t Harrisburg, PA 17110-:L250 _IC--f~ _'nt H. Patterson JI.ttorney for defendant ~:21 pine Street Harrisburg, PA 17101 (717) 238-4100 o c; ("--' ,-,: ~~ -<: ....., = ~:J :r.- ::>:: :J;:;- -< ,,-' c..n ~ -t :C,-" np -om :vr C~C) )~~ '...:~ ~;~ -< ::? -:;.. .r- r,) I" DOUBLE GOLD, INC. d/b/a RESTORE CORE, MICHAEL GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF C MMON PLEAS CUMBERLAND CO TY, PENNSYLVANIA DOCKET NO: 04 907 v. DABISE CAMERO, Defendant PLAINTIFF'S REPLY TO NEW MATTER OF DE ENDANT AND NOW, comes Plaintiff, Double Gold, Inc. d/b/a Restore ore, Michael Goldberg Contractor, (collectively "Plaintiff'), by and through its attorney, Peters & asilefski and William J. Peters and files this Reply to the New Matter of Defendants: 9. Denied. Plaintiff is advised by counsel and therefore avers t at said allegations state conclusions of law to which no response is required. To the extent and a r sponse may be required, said allegations are specifically denied and strict proof thereof is demand d at the time of trial if relevant. 10. Denied. After reasonable investigation Plaintiff is witho t knowledge or belief sufficient to form a belief as to the truth of said allegation. Strict proof thereo is demanded at the time of trial if relevant. II. Denied. Plaintiff is advised by counsel and therefore avers t at said allegations state conclusions of law to which no response is required. To the extent and a res nse may be required, it is denied that Plaintiff failed to supply proper materials and failed to charge a air and reasonable price for material and labor for the restoration/construction and repair work. 12. Admitted. 13. Denied. Plaintiff is advised by counsel and therefore avers that said allegations state conclusions of law to which no response is required. To the extent and a esponse may be required, said allegations are specifically denied that Plaintiff failed to complete t work that he agreed to perform or failed to complete the work in a workmanship like manner. 14. Denied. After reasonable investigation Plaintiff is with ut knowledge or belief sufficient to form a belief as to the truth of said allegation. Strict proof there f is demanded at the time of trial if relevant. 15. Denied. Plaintiff is advised by counsel and therefore avers hat said allegations state conclusions of law to which no response is required. To the extent and a res onse may be required, it is specifically denied that the Plaintiff failed to complete the work in a wor anship like manner or that the Defendants needs to spend monies to correct the Plaintiffs work. (a) Plaintiff was not requested nor did it replace w' or sill in the kitchen. (b) After reasonable investigation Plaintiff is without knowledge or belief sufficient to form a belie as to the truth of said allegation. Strict proof thereof is emanded at the time of trial if relevant. (c) Plaintiff was not requested nor required to aint the kitchen door. (d) The upper two kitchen cabinets were selecte by the Defendant (e) Admitted. (f) If separation and bubbling in the laminate of th countertop backsplash in the kitchen has oc urred, it is due to improper maintenance on the p rt of the Defendant. The rest of the allegations conta" ed in this sub-paragraph are denied in that after reasonable investigation Plaintiff is without knowledg or belief sufficient to form a belief as to the truth of said allegation. Strict proof thereof is demanded at the time of trial if relevant. (g) After reasonable investigation Plaintiff i without knowledge or belief sufficient to form a belie as to the truth of said allegation. Strict proof thereof is demanded at the time of trial if relevant. (h) Plaintiff did not, nor was it required to r lace any drywall on the walls in the living room area. A y defects in the nature of nail popping or painting of dry all in the living room is not the responsibility of the Plain iff. (i) Defendant accepted the flooring. (j) Plaintiff did not install the toilet in the sec nd floor bathroom. Defendant was advised that the t1 shing for the toilet was broken and the Plaintiff would ot install the toilet unless the flashing was corrected. efendant installed the toilet in the second floor bathroom. 16. Denied. After reasonable investigation Plaintiff is witho t knowledge or belief sufficient to form a belief as to the truth of said allegation. Strict proof thereo is demanded at the time of trial if relevant. 17. Denied. After reasonable investigation Plaintiff is witho knowledge or belief sufficient to form a belief as to the truth of said allegation. Strict proof thereof' s demanded at the time of trial if relevant. WHEREFORE, Plaintiff demands that judgment be entered in its fa or and against Defendant. By: Date: ;4fvUL S. 2005 Peters & Wasilefski u William J. Peters, Esq ire Attorney ID #09983 2931 North Front Street Harrisburg, Pennsylvani 17110 717-238-7555 Attorney for Plaintiff, Double Gold, Inc. d/b/a estore Core Michael Goldberg Contr tor -..::\ VERIFICATION I hereby affirm that the following facts are cOlTect: I am the Plaintiff :md am authorized to make this Ve ification; the attached Plaintiffs Reply to Defendants' New Matter is based upon information wI ich I have furnished to my counsel and information which has been gathered by my counsel in the preparation of the lawsuit. The language is that of counsel and not of me. I have read t e Plaintiffs Reply to Defendants' New Matter and to the extent that the same is based upon i formation that I have given to my counsel, it is true and correct to the best of my knowledge, i formation and belief. To the extent that the content of the Plaintiffs Reply to Defendants' ew Matter is that of counsel, I have relied upon counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Plaintiffs Reply to Defendants' New Matter is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to au horities. Date: i6 Michael Goldberg DOUBLE GOLD, INC. d/b/a RESTORE CORE, MICHAEL PENNSYL VANIA GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF OMMON PLEAS CUMBERLAND CO TY, DOCKET NO: 04-907 v. DABISE CAMERO, Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoi Plaintiff's Reply to New Matter, has been served on all parties of interest by placing the sa e in the United States mail. first-class postage pre-paid, at Harrisburg, Pennsylvania on this 5th d y of April, 2005, and addressed as follows: Kent Patterson, Esquire 221 Pine Street Harrisburg, Pennsylvania l7l 0 1 Peters & Wasilefski rYl Cv~c C'.OOtL f~, ;'" " ~; ! ~~ -! ....., r.::, (.~') c.n ?- A) o .." -< -,- fi, :!l r- :p",TI r5Y _.,19 ,''OJ :~,~ ~";.-() (--In .> ""' ~o ...<.. I en --r-) ::.r: ~ o CJ DOUBLE GOLD, INC. d/b/a RESTORE CORE, MICHAEL PENNSYLVANIA GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, DOCKET NO: 04-907 v. DABISE CAMERO, Defendant RULE 1312-1 form: The Petition for Appointment of Arbitrators shall be substantially in the following THE PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: William J. Peters, counsel for the Plaintiff in the above action (or actions), respectfully represents that: I. The above.captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $12,454.26 exclusive of interest and costs. 3. The counterclaim ofthe defendant in the action is $4,229.73. The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: William J. Peters, Esquire and Kent Patterson, Esquire. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, By: Peters & W. aSilefs~ C A. /U ..~ "Q ----:::> William J. Peters, Esquire Attorney ID #09983 2931 North Front Street Harrisburg, Pennsylvania 17110 717-238-7555 wjp@pwlegal.com Date: ?1tMd" 2006 Attorney for Plaintiff, Double Gold, Inc. d/b/a Restore Core Michael Goldberg Contractor , "i\ -\PI- -r-\ \") t; fV 7'- . 1l i. B - ":3 -tJ ~ --D D- ~r't: -.n ---J:- ; ~ ,"-, ; .JII. _.. DOUBLE GOLD, INC. d/b/a RESTORE CORE, MICHAEL GOLDBERG CONTRACTOR, Plaintiff v. DABlSE CAMERO, Defendant "-1 " , ~ND NOW, '~' F' . >. /vzu ' ij~'t~1 ht1l ;1 ~ (or actions) as prayed for. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 04-907 ORDER OF COURT , 2006, in consideration of the foregoing petition, Esq., and 71fc1..N/ <t<'5~wvi Esq., and Esq., are appointed arbitrators in the above captioned action BY~~'1~ L1t~' [tl /'J 1~,i~~liQR<;:H !JOfrfR. PJ . j I 1/ f/ f'h L ."...., '\'...... ..: . . . -,-- :'-~, ....... .& .' . DOUBLE GOLD, INe. d/b/a RESTORE CORE, MICHAEL PENNSYLVANIA GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, DOCKET NO: 04.907 v. DABISE CAMERO, Defendant RULE 1312-1 form: The Petition for Appointment of Arbitrators shal! be substantially in the following THE PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: William J. Peters, counsel for the Plaintiff in the above action (Dr actions), respectfully represents that: I. The above.captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $12,454.26 exclnsive of interest and costs. 3. The counterclaim of the defendant in the action is $4,229.73. The following attorneys are interested in the case(s) as counsel Dr are otherwise disqualified to sit as arbitrators: William J. Peters, Esquire and Kent Patterson, Esquire. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, By: Peters & W. aSilef~. {"!u ." ..... "Q .:=:> William J. Peters, Esquire Attorney ID #09983 2931 North Front Street Harrisburg, Pennsylvania 17110 717-238-7555 wip@pwlega1.com Date: 'I1tMd ,. 2006 Attorney for Plaintiff, Double Gold, Inc. d/b/a Restore Core Michael Goldberg Contractor ....... ~ :s 6""'- "'-0 (~'l .~; r' , ~"~ 'Ij J i : : _ iO ti:. n ~ '" ....... :ll .~ ....... 8 ~ ....0 \J [ P= ~ r p~ -t:L Double Gold, Inc. d/b/a Restore Core, Michael Goldberg, Contractor, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 04-907 CIVIL Dabise Camero, Defendant :Civil Action - Law ORDER AND NOW, this ~ day of June, 2006, it is hereby ordered and decreed that the court appointment of Lindsay D. Baird, Esquire, as Arbitrator in the above-captioned matter is vacated. Stacy B. Wolf, Esquire, is hereby court appointed in her stead. J. Cc: H. Anthony Adams, Esq. Lindsay D. Baird, Esq. Stacy B. Wolf, Esq. Kent H. Patterson, Esq. William 1. Peters, Esq. Michael Badowski, Esq. "'" C"-' ~ o -n f',' C'> :r-n 12;~) -. ,c., " I '-", ,'--. c ~ " ~'\l f':? <:~f.t~ ~ ~:Sl 01 C'tl ~'~~\L ~\~~~, &/~(D-- ~€ ~e- ~\CI-) "" l c. \;C\<!? \ Gee,' 0 ~<>.r ~ C' "'^~C' \0 r , Plaintiff \)n..~\ ~e Qa. M~,() Defendant JIIV · .. ill The Court of Common Pleas of Cmnberland County, Pennsylvania No..!i:L- g D-, Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and th!t e will discharge the duties of our office _~Z~~ /[ /i------- Signature Signature lM~LL( m$~JvW(4- &nr~u e. Wot-f Name Name \ t~~;;; a .lJsAi/J Ju?! (( Ii- )0 If l{q U) Dfn.,jP ~ "$q()7~1C<i 10 \lJfE~ WI~&J ;:l)e~\<.~.Q.l' ~}lj/ !q,)}1J/6 C:\~k rA \10\::' ~ z 't 7 JS 7 City, J Zip City, Zip ~ I DO.3~ :# I ~~~l it: ,,., 3Od. We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ~ ~~ir1an ~~Cl 'MS Name (Cha' ) ~ \..~~ Law Firm Date of Hearing: ~-~ ~ \o.~\ ~ Date of Award: ., / 10/ ~ f { ~:;:~~ (~s ~~~~t~~~ ~~~.~:~~;r\^~~~~:?;:~Q \S ~~(?{;) i~ ~ ~~,,\ a.~\..l\."* 0+ 9ocO'o{) . Arbitrator, dissents. (Insert name if applicable.) l .' ,l '. (Chairman) . ~ Now, the ~,ofh day of ~~v>..MhPr, 20 01., , at B:~q , -L.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ ~qD. DO By: Deputy Prothonotary , . ~.~. . . '" t .,.., , ., " ft,; .. ~ "'," '. ~P' f... . 'iI . u)..to : C<>I'~ ~ 1. re~~<I\- ~1'~ ~ q.a.~ ~. i'\ . l' f .I ::t-~e.~6 b~ - . ",. .' t -- ~~. .; () c < '"'tJIT r;' r" i!.. ::.1, ~2~~ r (J">; '. r:' ::~" "','';;'" 1~ ' ~:~,;: z :) ... f'ooo) c::::t c;:t d"" (/) r>i V N -.J ~ ~:D g; ~6 r- -T", a '(5"'1'1 -.. '20 cp Om ~ ~ N "" '~ J "\ '" ~ ..' I: ,t,. \ " .r: ,""..'" '" ..'~ .;," , ..../ '" '. ,. 1"".~. .,"'.' JUL -10-2006 MON 12: 42 PM PETERS AND WAS I Ui'SK I . L ... FAX NO. 7172387750 P. 03 or I' . '. . " .. . .~. : " " .f '~'''''''"''__:'''' '~'. ..,~." ;"rP"'....,. '_,....' , " I. ' . --~"'1 . .. , " _ __r~ UL -1O-20~6 MON 12: 06 PM PETERS AND WAS [ LEFSK! FAX NO, 7172387150 P. 01101 DOUBLE GOLD, INC. d/b/a RBSTORE CORBJ MIcaA'BL GOLDBERG CONTRACTOR, Plaintiff' IN THE COUR.T OF COMlvlON PLBAS CUMBaRLAN'D COUNTY. PENNSYLVANIA v. DOOKET NO: 0+907 DABlSE CAMwtOJ Dert.'i~utBnt (rlPULA TIOl"T . 1. . Judgment shall be entered iu favor of Plaintiff in the total amount of $9,000.00 inC\UbivQ of etlsts. 2. The pi1ttiea request that the appointed aubitrators in the Bbove-Qlptiancd action i9UC! a Report aM Award coDSistcn1 with this stipuJatiOJ1. JUL-IO-2006 MON 12:42 PM PETERS AND WASILifSKI.- t FAX NO. 7172387750 P, 04 ~L/I(j(1~ ~ Counsel for Defendant ..,.... ~'" .. . _.T .._.~ ,~, .,,,,,,,,,~~~....~'"',I''''''''''''I'+''' "0'.'" ...., . ..I "" '" '""'i"" "'~-'III\I.'''I'II'''''''''''Ir'''I''''~.' \~. . .~ DOUBLE GOLD, INC. d/b/a RESTORE CORE, MICHAEL GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO: 04-907 DABISE CAMERO, Defendant PRAECIPE TO ENTER JUDGMENT ON COMPULSORY ARBITRATION AWARD TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter judgment on the award of arbitrators filed in the above matter on September 27,2006, the time for appeal having expired, and assess damages in favor ofthe Plaintiff and against Defendant, Dabise Camero, as follows: Amount of Award: Interest from September 27,2006: Total: $9,000.00~ $72.49 $9,072.49 Peters & Wasilefski By: ~ Adam L. Seiferth, Esquire Attorney ID #89073 2931 North Front Street Harrisburg, Pennsylvania 17110 717-238-7555 Date: 11-") q - ~(}(}{e Attorney for Plaintiff Damages Assessed as Above: Date: I J./J 1/ (){,. ~ p-'- \ l: &"'1'" ~ .-. . ~ ~ c ~ ~ ~ j ". . DOUBLE GOLD, INC, d/b/a RESTORE CORE, MICHAEL PENNSYLVANIA GOLDBERG CONTRACTOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, DOCKET NO: 04-907 v. DABISE CAMERO, Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Praecipe To Enter Jud2ment on Compulsory Arbitration Award, has been served on all parties of interest by placing the same in the United States mail, first-class postage pre-paid, at Harrisburg, Pennsylvania on this ~day of November, 2006, and addressed as follows: Kent Patterson, Esquire 221 Pine Street Harrisburg, Pennsylvania 17101 Peters & Wasilefski _~m:f~ ~ 0 c::> -1'1 t (J ~ cr' ~ Cl :t \ ~ l" r"'"n ~ cJ 'c ~,,,\ C> - ..;JI:(- - D 3q r -- yo .~~121\ -- ~ ...J0o. """" - ty'n ~ ~ '2 .--\ L:-"~ '?Q ~ ...\ c...n ......- o? ;.-<, fU ..c; -< ~ - () ~ - ~