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HomeMy WebLinkAbout08-6439STACY B. WOLF, ESQ. SUPREME COURT ID NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 717-241-4436 ATTORNEY FOR PLAINTIFF SNOKE'S EXCAVATING and : IN THE COURT OF COMMON PLEAS OF PAVING, INC., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO.2008- (o 7 3 oJ r l < <"1 MICHAEL F. RONCA & SONS, INC., and DAVID A. RONCA, individually, Defendants : CIVIL ACTION - LAW 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, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR 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 STACY B. WOLF, ESQ. SUPREME COURT ID NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 717-241-4436 ATTORNEY FOR PLAINTIFF SNOKE'S EXCAVATING and : IN THE COURT OF COMMON PLEAS OF PAVING, INC., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . q 39 V. : NO. 2008_ MICHAEL F. RONCA & SONS, INC., and DAVID A. RONCA, individually, Defendants : CIVIL ACTION - LAW COMPLAINT AND NOW comes the plaintiff, Snoke's Excavating and Paving, Inc., by and through its attorney, Stacy B. Wolf, Esquire, and sets forth this complaint averring as follows: 1. Plaintiff, Snoke's Excavating and Paving, Inc., is a corporation doing business within the Commonwealth of Pennsylvania and has a place of business at 33 E. Main Street, Walnut Bottom, Pennsylvania 17266. 2. Defendant, Michael F. Ronca & Sons, Inc., is a corporation doing business within the Commonwealth of Pennsylvania and has a place of business at 179 Mikron Road, Bethlehem, Pennsylvania 18020. 3. Defendant David A. Ronca is the general manager and individual owner of Michael F. Ronca & Sons, Inc. residing at 179 Mikron Road, Bethlehem, Pennsylvania 18020. 4. On or about March 14, 2006, Plaintiff and Defendants entered into a ,Subcontract Agreement requiring Defendants to perform work at the Meadowsgreen subdivision in Shippensburg, Pennsylvania. A true and correct copy of the Subcontract Agreement with the attached Defendants' proposal dated February 24, 2006 is attached hereto as Exhibit A. 5. The subcontract provided Defendants would perform construction of the sanitary sewer line, including providing all materials. 6. The subcontract further provided that Defendants would furnish and install stone bedding/ initial bacldill and that if the excavated material was not suitable for bacgill, Defendants would provide suitable material. 7. Defendants constructed the sanitary sewer line in the summer of 2006. 8. Following the construction of the sanitary sewer line, settlement has occurred due to inadequate compaction. 9. Repairs have been made by Plaintiff to correct the trench settlement in the amount of $10,800.00. 10. As a result of the aforementioned faulty work, Plaintiff has sustained the following damages: a. costs for repairs in the amount of $10,800.00. COUNT I - BREACH OF CONTRACT 4nnke's Excavaf Paying. Inc v Michael F Ronca & Sons Inc., and David IS. Ronca, indivi uallv 11. Plaintiff incorporates by reference paragraphs 1 through 10 as if set forth in full herein. 12. Defendants' breach of their written agreement to construct the sanitary sewer line in the Meadowsgreen subdivision including installing suitable stone bedding/initial backfill in a workmanlike manner and providing a warranty for its work for twelve months following completion have caused the damages suffered by Plaintiff. WHEREFORE, plaintiff, Snoke's Excavating & Paving, Inc., prays that this Honorable Court enter judgment for the plaintiff and against the defendants, Michael F. Ronca & Sons, Inc., and David A. Ronca, individually, in the amount of $10,800.00, plus interest and costs of this action and any additional relief the Court deems appropriate and just. Respectfully submitted, WOLF & WOLF October , 2008 BY: r A44?-l STACY B. LF, ESQUIR4 Supreme Court ID No. 8873 10 West High Street Carlisle, PA 17013 (717) 241-4436 Attorney for Plaintiff Apr. 3. 2008 9.48AM ZULLINGER-DAVIS PC 717-530-5222 No, 7183 P- 6/8 mqlde? SUBCONTRACT AGREEMENT TIRS AGREEMENT made the 14 day of March, 2006 by and between Snoke's Excavating and Paving, Inc., P.Q. Box 247, Walnut Bottom, PA 17266, hereinafter called the "Contractor," and Michael F. Ronea & Sons, Inc., 179 Mikron Road, l3ethlehem, PA 18020, hereinafter called the "Subcontractor". Witnesseth, that the Contractor and the Subcontractor for the considerations named agree as follows: Article 1. Scope of the Work The Subcontractor's scope of work is based on the Subcontractors proposal, dated February 24, 2006, entitled Exhibit A, as annexed hereto as it pertains to work to be performed on property at Meadowsgreen subdivision, located in Shippensburg, PA Article 2. The Contract Price The Contractor shall pay the Subcontractor for the material and labor to be performed under the Base Bid Contract the sum of , , subject to additions and deductions pursuant to authorized change orders. J G 2, eco •rp0 Article 3. Progress Payments Payments of the Contract Price to the Subcontractor shall be paid in the manner following: Invoicing will occur approximately every 30 days, with payment due within 30 days of the invoice date. All invoices not paid in 30 days shall be subject to interest charges of 1-1/2% per month thereafter. Article 4. General Provisions Any alteration or deviation from the above specifications, including but not limited to any such alteration or deviation involving additional material and/or labor costs, will be executed only upon a written order for same, signed by the Contractor and Subcontractor, and if there is any charge for such alteration or deviation, the additional charge will be added to the contract price of this contract. If payment is not made when due, Subcontractor may suspend work on the job until such time as all payments due have been made. A failure to make payment for a period in excess of 30 days from the due date of the payment shall be deemed a material breach of this contract. In addition; the following general provisions apply: 1. All work shall be completed in a workman-like manner and in compliance with all building codes and other applicable laws. 2. The Subcontractor shall complete the work as detailed on their proposal dated February 24, 2006, attached hereto. Further, all provisions detailed in the Subcontractors proposal shall become part of this agreement. 3. To the extent required by law all work shall be performed by individuals duly licensed and authorized by law to perform said work. 4, Subcontractor may, at its discretion, engage further subcontractors to perform work hereunder, provided Subcontractor shall fully pay said subcontractors and in all instances remain responsible for the proper completion of this Contract. 5. Upon completion of the wort: and in conjunction with fmal payment Subcontractor shall furnish to Contractor appropriate releases or waivers of lien for all work performed or materials provided, if required by owner. 6. All change orders shall be in writing and signed both by Contractor and Subcontractor, and shall be incorporated in, and become a part of the contract. 7. Contractor shall provide at its- own expense all required permits necessary for the work to be performed, except permits the Subcontractor may require for drilling/blasting operations 8. Subcontractor agrees to remove all waste debris generated from their 'activities All excess soil materials and the like shall be left on site, at a location designated by the Contractor.' 9. , In the event Contractor shall fail to pay any periodic or installment payment due hereunder, Subcontractor may cease work without breach pending payment or resolution of any dispute. 10. , All disputes hereunder shall be resolved by binding arbitration in accordance with rules of the American Arbitration Association. RW81-T-A 11. Subcontractor shall not be liable for any delay due to circumstances beyond its control including strikes, casualty or general unavailability of materials. 12. Subcontractor warrants all work for a period of 12 months following completion, however, Contractor shall be responsible for protection of subcontractors completed work after work is accepted Article 5. Indemnification To the fullest extent permitted by law, the Subcontractor shall indemnify, defend and hold harmless the Owner and its agents and employees, from and against claims, damages, losses and expenses, including but not limited to attorney's fees, arising out of or resulting from performance of the work or providing of materials to the extent caused in whole or in part by negligent or wrongful acts or omissions of, or a breach of this agreement by, the Subcontractor, its subcontractors, anyone directly or indirectly employed by them or anyone whose acts they are legally responsible. Article 6. Insurance The Subcontractor represents that it has purchased and agrees that it will keep in force for the duration of the performance of the work or for such longer term as may be required by this agreement, in a company or companies lawfully authorized to do business in the State of Pennsylvania, such insurance as will protect the owner, its' agents and the owner of the site, if different than the owner as stated in the contract, from claims for loss or injury which might arise out of or result from the Subcontractor's operations under this project, whether such operations be by the Subcontractor or by its subcontractors. The Subcontractor represents and agrees that said insurance is written for and shall be maintained in an amount not less than the limits of the liability specified below or required by law, whichever coverage is greater. The Subcontractor certifies that coverage written on a "claims made" form will be maintained without interruption from the commencement of work until the expiration of all applicable statutes of limitation. 1) Worker's Compensation $ 500,000.00 2) Comprehensive General Liability with limits of not less than $ 2,000,000.00 per occurrence. 3) Comprehensive Automobile Liability (owned, non-owned, hired) of $ 1,000,000.00 each accident. The Subcontractor shall provide Certificates of Insurance, acceptable to all parties prior to commencement of work, which shall contain a provision that coverages under the policies shall not be cancelled or allowed to expire or permit material changes until final completion and acceptance of work. Signed this I ?- day of /N k4- c.W 1,# 0 ( Signed in the presence of Witness Michael F. Ronca & Sons, Inc. B Signature 179 Mikron Rd. Bethlehem, PA 18020 Witness Snoke's Excavating and Paving, Inc. By: Signature 33 E. Main St. Walnut Bottom, PA 17266 Michael E RONCA It's & Sons, Inc. TELEPHONE 610/759-5100 FACSIMILE 610/746-0974 CONTRACTORS February 24, 2006 Mr. Glenn Snoke Snoke's Excavating & Paving, Inc. P.O. Box 247 Walnut Bottom, PA 17266 Re: Meadowsgreen Subdivision Shippensburg, PA Dear Mr. Snoke: 179 Mikron Road, Bethlehem, PA 18020 Fax 717-530-1088 Pursuant to your request, Michael F. Ronca & Sons, Inc. hereby offers to provide all necessary labor, materials and equipment required to perform the Sanitary Sewer and Water Line construction, in accordance with the plans prepared by Carl D. Bert & Associates, dated May 13, 2005, for the following prices. Base Bid: Item 1 Mobilization = $ 7,000.00 Item 2 Sanitary Sewer Construction = $ 155,000.00 Base Bid Total - S4541te"0 f (c?, OOc7 . «.: Alternate No. 1: Item 1 Sanitary Sewer Construction = Please note, this proposal is based upon the attached Scope of Work, and listing of Clarifications and Exclusions. We thank you for selecting Michael F. Ronca & Sons, Inc. as a potential contractor for this project, and should you have any further questions concerning our proposal, or require additional information, please do not hesitate to contact me. Sincerely, David A. Ronca General Manager cc: misc. prop. February 24, 2006 Snoke's Excavating & Paving, Inc. Re: Meadowsgreen Subdivision Shippensburg, PA Scope of Work: Base Bid: Mobilization Furnish & Install approximately 1,961 LF of 10" SDR 35 PVC gravity sewers, 5 manholes (Stnd. 4'-0" dia), existing manhole connection, stone bedding/initial backfill (1'-0" above pipe) and required pipe & manhole testing. Furnish & Install approximately 1,580 LF of 12" Class 52 DIP and associated fittings, 1- 12" gate valve, 2 fire hydrants, stone bedding/initial backfill (1'-0" above pipe) and required pipe testing. Alternate Bid: Furnish & Install approximately 974 LF of 10" SDR 35 PVC gravity sewers, 3 manholes (Stnd. 4'-0" dia), stone bedding/initial backfill (1'-0" above pipe) and required pipe & manhole testing. Clarifications and Exclusions: • Performance/Payment Bonds are Excluded • Permits, Inspection Fees, Tapping Fees, Compaction Testing and the like are Excluded. • Any Required Clearing & Grubbing is Excluded. • Any Required Soil Erosion Control is Excluded. • Full Depth Stone Backfill, above the initial stone backfill, is Excluded. • Offsite Disposal of excess excavated material is Excluded, or Maintenance of on-site stockpile areas. • Sanitary Laterals or Water Services are Excluded. • It is assumed drilling and blasting for rock removal is permitted. • It is assumed excavated material used for backfill will be suitable, or suitable material will be provided at the work area, if necessary. • It-is assumed all bulk site cut/fills will be completed prior to starting the utility construction. 0 Survey is Excluded VERIFICATION I, the undersigned, hereby verify that I am the President and an authorized representative of Snoke's Excavating & Paving, Inc. and that the facts stated in the above complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. o/ a 9 , 2008 Glenn W. Snoke, President Snoke's Excavating and Paving, Inc. C`y ra r-- ' ' ^? ?T T i i r ?y1 6? W © rn 1 J4 V W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SNOKE'S EXCAVATING and PAVING, INC., NO. 2008-6439 civil term Plaintiff V. MICHAEL F. RONCA & SONS, INC. and DAVID A. RONCA, individually, Defendants PRAECIPE FOR ENTRY OF APPEARANCE TO: PROTHONOTARY/CLERK OF SAID COURT: Kindly enter my appearance for the Defendants, Michael F. Ronca & Sons, Inc. and David A. Ronca, individually, in the above-captioned action. MCLAIN LAW OFFICE, P.C. BY: Erv D. McLain, Esquire I.D. No. 38795 561 Main Street, Suite 275 P.O. Box 1096 Bethlehem, PA 18016-1096 (610) 866-9700 fax (610) 866-9720 Date: December 2, 2008 F7 1 -<4 co SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-06439 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNOKES EXCAVATING AND PAVING VS MICHAEL F RONCA & SONS INC ET 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: RONCA DAVID A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of NORTHAMPTON County, Pennsylvania, to serve the within COMPLAINT & NOTICE On November 20th , 2008 , this office was in receipt of the attached return from NORTHAMPTON Sheriff's Costs: So ans Docketing 6.00 Out of County .00 Surcharge 10.00 as Kline .00 .00 16. 00 ? 11/20/2008 WOLF & WOLF Sworn and subscribe to before me this day of __ off/ of Cumberland County A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-06439 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNOKES EXCAVATING AND PAVING VS MICHAEL F RONCA & SONS INC ET 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: but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of NORTHAMPTON County, Pennsylvania, to serve the within COMPLAINT & NOTICE On November 20th , 2008 , this office was in receipt of the attached return from NORTHAMPTON Sheriff's Costs: So an Docketing 18.00 Out of County 9.00 Surcharge 10.00 f R mas Kline Dep Northampton 75.00 e ff of Cumberland County Postage 2.78 114.78 iala3w? 11/20/2008 WOLF & WOLF Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of Cumberland. County, Pennsylvania Snoke's.Excavating and Paving Inc vs. Michael F. Ronca & Sons Inc et al SERVE: Michael F. Ronca & Sons Inc Now, October3l, 2008 No. 08-6439 civil I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Northampton 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 Now, O(o A/ava , 2067j, at o'clock M. served the within :6 upon f l T t` •ic1Cf? Ql- JC5N?- at Lw IV.4 ZA r M1, by handing to C hjr; c-1i4 1C?-.? ?JorJ rsL. C rr_ *,CrJ a 444, -4- copy of the original /V a c L .? cUyy,? ?c?, ,?T and made known to the contents thereof. So answers, Sheriff of Sworn and subscribed before me this day of , 20 COSTS SERVICE MILEAGE AFFIDAVIT County, PA ORDER FOR SERVICE REQUEST TO BE COMPLETED BY THE REQUESTING ATTORNEY 1. All information from the attorney must be filled-in before 4. When a Deputy Sheriff levys or attaches property, he or she service can be made. 11 will leave the property without a watchman and in custody of 2. Prepare a separate Order for Service form for each defendant to, whomever is found in possession, after notifying the person be served by the Sheriff. the property is under a Sheriff s levy. The Sheriff or 3. When completing location for service, be certain to Deputy is not liable in any way for protecting property. have a valid address or directions. Do not use P.O. 5. Service will be executed in accordance-with Rule 402 and Title Boxes or R.D. - ADDRESSES ONLY. Provide the 231, Pennsylvania Rules of Civil Procedure. 6. The attorney must certify all copies of process. township, if applicable. 7. Supply a self-addressed stamped envelope for return of service. PLAINTIFF: SNOK ' DEFENDANT: MIC o of SERVE UPON: LOCATION: Z ??p MICHAEL F. RONCA & SONS, INC. o 179 MIKRON ROAD r' TYPE OF WRIT c '?V : BETHLEH A 180 20 ? NOTICE AND COMPLAINT h w , ATTORNEY (NAME, ADDRESS, PHONE) ATTORNEY SIGNATURE: 00,1 STACY B WOLF ES 717-241-4436 C ? - J FOR PROTHONOTARY USE ONLY DOCKET NUMBER: LAST DAY FOR SERVICE: FEES PAID: 08-6439 CIVIL I Noy 29. 2008 1 75.00 . RETURN OF SERVICE (To be completed by Sheriff) INDIVIDUAL SERVED: s ) h A DATE: F ME: r o". A- ris (omi a ull LOCATION: (IF DIFFERENT FROM ABOVE) ( ) BOROUGH OF: () CITY OF () TOWNSHIP OF: Served in the following manner: () Other: ( ) Defendant personally served () Not Found () Moved ( ) No Answer () Vacant ( ) Unknown ( ) Adult family member with whom said defendant resides harge of defendant's residence ( ) Ae agger/Clerk () of place of lodging in which defendant resides ( Agent or person in charge of defendant's office or usual place of business ( ) Officer of said defendant company ( ) Posted property ( ) Levy on property (Comments) SO ANSWERS: JEFFREY K HAWBECKER SHERIFF OF NORTHAMPTON BY: W0___ 11V ?41 - COUNTY _!5 J I hereby deputize the Sheriff of County, To execute and make a return on the above and attached action according to law. Deputy She ' Badge # - Sheriff of Northampton Count Date ACCEP TANCE OF SERVICE I accept service of the authorized to do so. on behalf of and certify that I am (Defeo t or Au zed Agent) (Mailing Address) Delivery Attempts: Date: Time: Dep: Date: Time: Dep: Date: Time: Dep: Date: Time: Dep: Date: Time: Dep: Date: Time: Dep: Northampton County Sheriff's Department 669 Washington Street Easton, PA 18042-7483 (610) 559-3084 (610) 559-3781 (REAL ESTATE) In The Court of Common Pleas of Cumberland County, Pennsylvania Snoke's Excavating and Paving Inc vs. Michael F. Ronca & Sons Inc et al SERVE: David A. Ronca No. 08-6439 civil Now, October3l, 2008 hereby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Northampton 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 Now, eZ *6w 1e odene- , 200 OF at //I/ o'clock M. served the within A;4.,-.o oL 1 A-4 ? upon at f-7 1 In I. 2 "4,071 " f n , 6a- /eD G by handing to C-Pr ,,r+) a and made known to 'I) ??c« ,ov County to execute this Writ, this ?« So answers, Sheriff of Sworn and subscribed before me this day of , 20 copy of the original Na-TJ Cc j COSTS SERVICE _ MILEAGE _ AFFIDAVIT the contents thereof. County, PA ORDER FOR SERVICE REQUEST TO BE COMPLETED BY THE REQUESTING ATTORNEY 1. All information from the attorney must be filled-in before 4. When a Deputy Sheriff levys or attaches property, he or she service can be made. will leave the property without a watchman and in custody of 2. Prepare a separate Order for Service form for each defendant to whomever is found in possession, after notifying the person be served by the Sheriff. the property is under a Sheriff s levy. The Sheriff or 3. When completing location for service, be certain to Deputy is not liable in any way for protecting property. have a valid address or directions. Do not use P.O. 5. Service will be executed in accordance-with Rule 402 and Title 231, Pennsylvania Rules of Civil Procedure. Boxes or R.D. - ADDRESSES ONLY. Provide the 6. The attorney must certify all copies of process. township, if applicable. 7. Supply a self-addressed stamped envelope for return of service. PLAINTIFF: SNOKE'S EXCAVATING AND PAVING INC. DEFENDANT: °o pZ m =rte: MICHAEL F R NACA & SONS, SERVE UPON: LOCATION: c rr,3'n DAVID A RONCA 179 MIKRON ROAD ?tC)GM TYPE OF WRIT: BETHL HEM PA 18029 D C =-_ Im rrir-) NOTICE AND COMPLAINT 6A i.) :441 t7°---4 C_ ORNEY (NAME, ADDRESS, PHONE) ATTORNEY SIGNATURLr/ ?rn 7 B WOLF ES 717-241-4436 STACY -A FOR PROTHONOTARY USE ONLY DOCKET NUMBER: LAST DAY FOR SERVICE: FEES PAID: 08-6439 CIVIL Nov 29 2008 75.00 RETURN OF SERVICE (To be completed by Sheriff) INDIVIDUAL SERVED: DATE: )7 TIME: i; -LA l?i4l ?S el A-) D & NW d / ) I LOCATION: (IF DIFFERENT FROM ABOVE) O BOROUGH OF: O CITY OF O TOWNSHIP OF: Served in the following manner: () Other: ( ) Defendant personally served O Not Found O Moved ( ) No Answer O Vacant ( ) Unknown ( ) Adult family member with whom said defendant resides ( ) Ad in charge of defendant's residence () anager/Clerk of place of lodging in which defendant resides (tl) Agent or person in charge of defendant's office or usual place of business ( ) Officer of said defendant company ( ) Posted property ( ) Levy on property (Comments) SO ANSWERS: JEFFREY K HAWBECKER SHERIFF OF NORTHAMPTON COUNTY I hereby deputize the Sheriff of County, BY: To execute and make a return on the above and attached action according to law. iA, Ala De ut Sheriff Badge # Sheriff of Northampton Count Date ACCEP TANCE OF SERVICE I accept service of the on behalf of and certify that I am authorized So. ( fendant or Authorized Agent) (Mailing Address) Delivery Attempts: Date: Date: Time: Time: Dep: Dep: Northampton County Sheriff's Department Date: Time: Dep: 669 Washington Street Date: Time: Dep: Easton, PA 18042-7483 Date: Time: Dep: (610) 559-3084 Date: Time: Dep: (610) 559-3781 (REAL ESTATE) STACY B. WOLF, ESQUIRE ATTORNEY M NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF SNOKE'S EXCAVATING and PAVING, INC., Plaintiff V. MICHAEL F. RONCA & SONS, INC., and DAVID A. RONCA, individually, Defendants : IN THE COUKY Or uummuN rt.r as yr : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-6439 CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Kindly mark this action settled, discontinued and ended. G March ?0 , 2009 STACY B. OLF, ESQUIRE WOLF & WOLF 10 West High Street Carlisle, PA 17013 717-241-4436 SUPREME COURT ID #88732 Attorney for Plaintiff ry c? r ,4"1'1 n rr; Cr%