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Home My WebLink About09-7322Burton Neil & Associates, P.C. By: Brit J. Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff WHITNEY, BAILEY, COX & MAGNANI 849 Fairmont Ave Baltimore MD 21286 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BINK PARTNERSHIP, INC. d/b/a BINK ARCHITECTURAL PARTNERSHIP NO. OR -'1.3Z ?i V t Ti° t'M 133 South 32nd Street, Camp Hill Pa 17011 Defendant CIVIL ACTION -LAW Complaint - 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 (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 claim 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 120027 Burton Neil & Associates, P.C. Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for: Plaintiff WHITNEY, BAILEY, COX & MAGNANI IN THE COURT OF COMMON PLEAS 849 Fairmont, Avenue Baltimore, Maryland Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09- '732Z &;;,J Ai,., BINK PARTNERSHIP, INC. d/b/a BINK ARCHITECTURAL PARTNERSHIP 133 South 32"d Street Camp Hill, Pennsylvania Defendant : CIVIL ACTION - LAW Complaint 1. The plaintiff is Whitney, Bailey, Cox & Magnani with place of business located at 849 Fairmont Avenue, Baltimore, Maryland. 2. The defendant is Bink Partnership, Inc., d/b/a Bink Architectural Partnership with place of business located at 133 South 32"d Street, Camp Hill, Cumberland County, Pennsylvania. Count I - Coudersport School District Project 3. Plaintiff herein incorporates by reference the averments of paragraphs 1 and 2. 4. At the instance and request of the defendant, plaintiff provided structural engineering services to defendant for defendant's Coudersport School District project, for the prices, on the dates, and at the terms set forth in the Coudersport School District Proposal. A true and correct copy of this proposal is attached hereto, made a part hereto, and is marked Exhibit A. 5. Plaintiff s services were rendered to defendant in a good and workman-like fashion and were the services both parties had agreed upon pursuant to the Exhibit A proposal. 6. The prices plaintiff charged defendant were fair and reasonable and were the prices defendant had agreed to pay plaintiff. 7. From time to time, plaintiff sent to defendant invoices reflecting a balance due plaintiff in the total sum of $14,000.00, which invoices defendant received without protest. True and correct copies of the invoices are attached hereto, made a part hereof, and are collectively marked Exhibit B. 8. Although demand was made by plaintiff upon defendant to pay the sum of $14,000.00, the defendant failed and refused to pay all or any part thereof. 9. Plaintiff is entitled to interest at 6% per annum from thirty (30) days after the invoice date. WHEREFORE, plaintiff demands judgment against defendant on Count I in the sum of $14,000.00, together with interest at 6% per annum from thirty (30) days after the invoice date and the costs of this action. Count II - St. Nicholas Serbian Eastern Orthodox Church Project 10. Plaintiff herein incorporates by reference the averments of paragraphs I and 2. after invoice date. 11. At the instance and request of the defendant, plaintiff provided structural engineering services to defendant at defendant's St. Nicholas Serbian Eastern Orthodox Church project for the prices, on the dates and at the terms set forth in the St. Nicholas Serbian Eastern Orthodox Church proposal. A true and correct copy of the St. Nicholas Serbian Eastern Orthodox Church proposal is attached hereto, incorporated herein and marked Exhibit C. 12. Plaintiff's services were rendered to defendant in a good and workman-like fashion and were the services both parties had agreed upon pursuant to the Exhibit C proposal. 13. The prices plaintiff charged defendant were fair and reasonable and were the prices defendant had agreed to pay plaintiff. 14. From time to time, plaintiff sent to defendant invoices reflecting a balance due plaintiff in the total sum of $6,200.00, which invoices defendant received without protest. True and correct copies of the invoices are attached hereto, made a part hereof and are collectively marked Exhibit D. 15. Although demand was made by plaintiff upon defendant to pay the sum of $6,200.00 the defendant failed and refused to pay all or any part thereof. 16. Plaintiff is entitled to interest at 6% per annum from thirty (30) days after the invoice date. WHEREFORE, plaintiff demands judgment against defendant on Count II in the sum of $6,200.00 together with interest at 6% per annum from thirty (30) days after the invoice date and the costs of this action. Burton Neil & Associates, P.C. By, ? Brit J Suttell, Esquire Attorney for Plaintiff JTJJ WHITNEY BAILEY COX MAGNANI March 26, 2007 '200ee e'1 ?r3 ENGINEERS i PLANNERS I SURVEYORS Bink Architectural Partnership 133 S. 32nd Street Camp Hill, PA 17011 Attn: Mr. Doug Tilley Re: Coudersport School District WBCM No. 07.0069 Mr. Tilley, Whitney, Bailey, Cox & Magnani, LLC (WBCM) is presenting the following proposal for structural engineering services associated with various renovations and additions in the Coudersport School District. PROJECT DESCRIPTION The scope of our services will include projects at 3 locations: 1. Stadium - Structural engineering for a new locker room and support facility of approximately 28'x157' under the new bleacher seating. Services will include design of foundations for the new bleachers and coordination of the bleacher support columns with the new building. 2. Classroom Addition - Single story classroom addition to the elementary school approximately 94'x109' (8 classrooms) using steel framing or masonry bearing structural support system. Alternate services may be requested to design the roof of the single story addition for a future second floor. 3. Cafeteria Addition - A single story 600 square foot addition to the existing high school cafeteria. Services will also include the removal of an interior bearing wall. SCOPE OF SERVICES In coordination-with the architectural requirements and schematic documents, WBCM will: 1. Provide structural engineering and drafting services for all structural portions of the project identified by the project description, and attendance at meetings during the development of the contract documents as required. 2. Provide the structural design portion of the specifications conforming to the architectural specification format. 355 N. 21st Street Suite 100 Camp Hill, PA 17011 P 717.730.6032 F 717.730.0S16 www.wbcm.com offices: Baltimore, MD Camp Hill, PA Pittsburgh, PA ACEC .??_?.?.. EXHIBIT-----.L--- WHITNEY BAILEY COX MAGNANI JTJ( Attn: Mr. Doug Tilley March 26, 2007 Page 2 of 3 ENGINEERS I PLANNERS I SURVEYORS 3. During the Bidding Phase, W8CM will provide addenda items, sketches and/or other services necessary to clarify the contract documents. 4. Construction phase services will include review of submittals associated with structural items and responding to contractor questions. Site visits will be provided during construction as an additional service if requested to address structural issues during construction. The following items are specifically excluded from WBCM's basic scope of services: 1. Preparation of alternate designs. 2. Design of site related structures unless connected to the building. 3. Redesign services during construction resulting from discovery of hidden or changed field conditions or contractor error. 4. Redesign services if estimated construction cost exceeds project budget. 5. Analysis of existing framing for support of new mechanical units or other equipment. 6. Site visits during design to verify existing conditions or during construction to address specific issues or otherwise observe construction. COMPENSATION WBCM will provide the previously noted basic services for the lump sum fee of Fourteen Thousand ($14,000.00) Dollars. The fee will be broken down by phase and location as follows: 1. Stadium - Design Phase - $5,800.00 Construction Phase - $800.00 6 $6,600.00 2. Classroom Addition - Design Phase - $4,800.00 Construction Phase - $600.00 $5,400.00 ICJ A. Fee for the design of the classroom addition to include plans and details for a future 2"a floor : Design Phase - Construction Phase - 3. Cafeteria Addition - Design Phase - Construction Phase - $6,400.00 $600.00 $7,000.00 $1,600.00 $400.00 $2,000.00 WHITNEY BAILEY COX MAGNANI JTJ( Attn: Mr. Doug Tilley March 26, 2007 Page 3 of 3 ENGINEERS I PLANNERS I SURVEYORS Additional services will be provided when authorized by the architect at the following hourly rates: Project Manager/Sr. Engineer - $125.00 Registered Engineer - $105.00 Designer - $ 85.00 Drafter - $ 60.00 It is our understanding that upon acceptance of this agreement WBCM will enter into a standard AIA consultant agreement (C141) based on the terms and conditions of the Architects agreement with the owner. Thank you again for allowing us the opportunity to provide structural engineering services for this project. It is always a pleasure working with your office. If you have any questions, comments, or require additional information, please contact me at your convenience. Respectfully, WHITNEY, BAILEY, COX & MACNANI, LLC Shawn D. Weber, P.E. Vice President 07.0069.01-P-0301 Invoice Bink Partnership 133 South 32nd Street Attn: Doug Tilley Camp Hill PA 17011 WHITNEY, BAILEY, COX & MAGNANI, LLC CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MO 21286 (410) 512-4500 July 23, 2007 Project No: 20070069.00.0 Invoice No: 0053543 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Coudersport School District Professional services from June 1. 2007 to June 30 2007 .......... . . . _ _ ....... - - - - - ... - - - Task: 0300 Stadium Building- Design Stadium Building- Design Fee Percent Phase Fee Complete Earned Contract Documents 51800.00 20.00 1,160 00 Total Fee 51800.00 Total Earned 1,160.00 Previous Fee Billing 0.00 Current Fee Billing 1,160.00 Total Fee 1,160.00 . ...... .. .. Total this task $1,160.00 Task: 0301 Stadium Building- Construction - Stadium Building- Construction Fee Phase Construction Admin. Total Fee Percent Fee Complete Earned 800.00 0.00 0.00 800.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee Total this task EXHIBIT 0.00 $0.00 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0053543 Task: 0302 Elementary School Addition- Design - - - ... ... .. ..... . Elementary School Addition- Design Fee Percent Phase Fee Complete Earned Contract Documents 4,800.00 20.00 960.00 Total Fee 4,800.00 Total Earned 960.00 Previous Fee Billing 0.00 Current Fee Billing 960.00 Total Fee 960,00 Total this task $960.00 Task: 0303 Elementary School Addition- Construction .. .. . Elementary School Addition- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 600.00 0.00 0.00 Total Fee 600.00 Total Earned 0.04 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 _ Total this task $0.00 Task: 0304 High School Cafeteria Addition- Design High School Cafeteria Addition- Design Fee Phase Contract Documents Total Fee Percent Fee Complete Earned 1,600.00 20.00 320.00 11600.00 Total Earned 320.00 Previous Fee Billing 0.00 Current Fee Billing 320.00 Total Fee 320.00 Total this task $320.00 Page 2 zaoTOOeom.o couosrswrtT SHOa osrACr „.e,n HO. amw r mm won sewn cwrr ca.w.?on Hon sem cr.s„a rmm,. w.,nwm ? E..r ca.mm?m?.,. 'oom oao ox TWIFr n00m TWI F.THa P.. .-m Wm Pw TMe gYIYI bA TebIFYYwals {lAplp Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0053543 .................................................•................................ Task: 0305 High School Cafeteria- Construction High School Cafeteria Addition- Construction Fee Phase Construction Admin. Total Fee Percent Fee Complete Earned 400.00 0.00 0.00 400.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Total this invoice $2.440.00 Page 3 Invoice WHITNEY, BAILEY, COX & MAGNANI, LLC CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MD 21286 (410) 512-4500 Bink Partnership 133 South 32nd Street Attn: Doug Tilley Camp Hill PA 17011 August 24, 2007 Project No: 20070069.00.0 Invoice No: 0053883 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Coudersport School District Professional services from July 1. 2007 to July 31, 2007 •---• ...............................................................•--•-•-••----- Task: 0300 Stadium Building- Design Stadium Building- Design Fee Percent Phase Fee Complete Earned Contract Documents 5,800.00 60.00 3,480.00 Total Fee 5,800.00 Total Earned 3,480.00 Previous Fee Billing 1,160.00 Current Fee Billing 2,320.00 Total Fee 2,320.00 Total this task $2,320.00 Task: 0301 Stadium Building- Construction - . Stadium Building- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 800.00 0.00 0.00 Total Fee 800.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0053883 .....................•---.......-----... Task: 0302 Elementary School Addition- Design ................... ........---•-•----•.... Elementary School Addition- Design Fee Percent Phase Fee Complete Earned Contract Documents 4,800.00 60.00 2,880.00 Total Fee 4,800.00 Total Earned 2,880.00 Previous Fee Billing 960.00 Current Fee Billing 1,920.00 Total Fee 1,920.00 Total this task $1,920.00 ......--••-• .......................•..............................---•--.......... Task: 0303 Elementary School Addition- Construction Elementary School Addition- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 600.00 0.00 0.00 Total Fee 600.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task :0.00 Task: 0304 High School Cafeteria Addition- Design .. .. . • • High School Cafeteria Addition- Design Fee Percent Phase Fee Complete Earned Contract Documents 1,600.00 60.00 960.00 Total Fee 1,600.00 Total Earned 960.00 Previous Fee Billing 320.00 Current Fee Billing 640.00 Total Fee 640.00 Total this task $640.00 Page 2 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0053883 Task: 0305 High School Cafeteria- Construction . High School Cafeteria Addition- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 400.00 0.00 0.00 Total Fee 400.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee Total this task Total this invoice Outstanding Invoices Number Date Balance 0053543 7123107 2,440.00 Total 2,440,00 Total now due 0.00 $0.00 $4,880.00 $7,320.00 Page 3 Invoice Bink Partnership 133 South 32nd Street Attn: Doug Tilley Camp Hill PA 17011 WHITNEY, BAILEY, COX & MAGNANI, LLC CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MD 21286 (410) 512-4500 October 16, 2007 Project No: 20070069.00.0 Invoice No: 0054481 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Coudersport School District Professional services from September 1 2007 to September 30, 2007 Task: 0300 Stadium Building- Design . .. - - . . . - . . . .. - _ . Stadium Building- Design Fee Percent Phase Fee Complete Earned Contract Documents 5,800.00 100.00 5,800.00 Total Fee 5,800.00 Total Earned 5,800.00 Previous Fee Billing 3,480.00 Current Fee Billing 2,320.00 Total Fee 2,320,00 .... Total this task $2,320.00 Task: 0301 Stadium Building- Construction .. . . Stadium Building- Construction Fee Phase Construction Admin. Total Fee Percent Fee Complete Eamed 800.00 0.00 0.00 800.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task ;0,00 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0054481 Task: 0302 Elementary School Addition- Design .. . . - Elementary School Addition- Design Fee Phase Contract Documents Total Fee Percent Fes Complete Earned 4,800.00 100.00 4,800.00 4,800.00 Total Earned 4,800.00 Previous Fee Billing 2,880.00 Current Fee Billing 1,920.00 Total Fee ........................................... Task: 0303 Elementary School Addition- Construction Elementary School Addition- Construction Fee 1,920.00 Total this task $1,920.00 Percent Phase Fee Complete Earned Construction Admin. 600.00 0.00 0.00 Total Fee 600.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 - Total this task $0.00 Task: 0304 High School Cafeteria Addition- Design ' ' " ' ' High School Cafeteria Addition- Design Fee Percent Phase Fee Complete Eanwd Contract Documents 1,600.00 100.00 1,600.00 Total Fee 1,600.00 Total Earned 1,600.00 Previous Fee Billing 960.00 Current Fee Billing 640.00 Total Fee 640.00 Total this task $640.00 Page 2 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0054481 Task: 0305 High School Cafeteria- Construction ... .. .. . . . High School Cafeteria Addition- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 400.00 0.00 0.00 Total Fee 400.00 Total Eamed 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Total this invoice $4,880.00 Outstanding Invoices Number Date Balance 0053543 7123107 2,440.00 0053883 8/24/07 4,880.00 Total 7,320.00 Total now due $12,200.00 Page 3 Invoice Bink Partnership 133 South 32nd Street Attn: Doug Tilley Camp Hill PA 17011 WHITNEY, BAILEY, COX & MAGNANI, LLC CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MD 21286 (410) 512-4500 March 18, 2008 Project No: 20070069.00.0 Invoice No: 0055887 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Coudersport School District Professional services from February 1. 2008 to February 29, 2008 Task: 0300 Stadium Building- Design .. .. . . . . . . . . . . . Stadium Building- Design Fee Percent Phase Fee Complete Earned Contract Documents 5,800.00 160.00 5,800.00 Total Fee 5,800.00 Total Earned 5,800.00 Previous Fee Billing 5,800.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Task: 0301... Stadium Building- Construction ... . Stadium Building- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 800.00 50.00 400.00 Total Fee 800.00 Total Earned 400,00 Previous Fee Billing 0.00 Current Fee Billing 400.00 Total Fee Total this taste 400.00 $400.00 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0055887 . .... .. ... . . ................... . Task: 0302 Elementary School Addition- Design Elementary School Addition- Design Fee Percent Phase Fee Complete Earned Contract Documents 4,800.00 100.00 4,800.00 Total Fee 4,800.00 Total Earned 4,800.00 Previous Fee Billing 4,800.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Task: 0303 Elementary School Addition- Construction Elementary School Addition- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 600.00 50.00 300.00 Total Fee 600.00 Total Earned 300.00 Previous Fee Billing 0.00 Current Fee Billing 300.00 Total Fee 300.00 Total this task 5300.00 Task: 0304 High School Cafeteria Addition- Design ..... . High School Cafeteria Addition- Design Fee Percent Phase Fee Complete Earned Contract Documents 1,600.00 100.00 1,600.00 Total Fee 1,600.00 Total Earned 1,600.00 Previous Fee Billing 1,600.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Page 2 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0055887 Task: 0305 High School Cafeteria- Construction High School Cafeteria Addition- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 400.00 50.00 200.00 Total Fee 400.00 Total Earned 200.00 Previous Fee Billing 0.00 Current Fee Billing 200.00 Total Fee 200,00 Total this task $200.00 Total this invoice $900.00 Outstanding Invoices Number Date Balance 0053543 7/23/07 2,440.00 0053883 8/24/07 4,880.00 0054481 10/16/07 4,880.00 Total 12,200.00 Total now due $13,100.00 Page 3 If1VOICe WHITNEY, BAILEY, COX & MAGNANI, LLC - CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MD 21286 (410) 51241500 Bink Partnership 133 South 32nd Street Attn: Doug Tilley Camp Hill PA 17011 July 21, 2008 Project No: 20070069.00.0 Invoice No: 0057209 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Coudersport School District Professional services from June 1. 2008 to June 30, 2008 Task: 0300.. Stadium Building- Design ... . Stadium Building- Design Fee Percent Phase Fee Complete Earned Contract Documents 5,800.00 100.00 5,800,00 Total Fee 5,800.00 Total Earned 5,800.00 Previous Fee Billing 5,800.00 Current Fee Billing 0.00 Total Fee 0,00 _ .. .. . Total this task $0.00 Task: 0301 Stadium Building- Construction .. . . . Stadium Building- Construction Fee Phase Construction Admin. Total Fee Percent Fee Complete Earned 800.00 100.00 800.00 800.00 Total Famed 800.00 Previous Fee Billing 400.00 Current Fee Billing 400.00 Total Fee 400.00 Total this task $400,00 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0057209 Task: 0302 Elementary School Addition- Design . Elementary School Addition- Design Fee Percent Phase Fee Complete Earmed Contract Documents 4,800.00 100.00 4,800,00 Total Fee 4,800.00 Total Earned 4,800.00 Previous Fee Billing 4,800.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 _ • • " . ... . . .. . .......... ' ' ' • _ _ _ ' ' . - - • • " _ . Task: 0303 Elementary School Addition- Construction Elementary School Addition- Construction Fee Percent Phase Fee Complete Earned Construction Admin. 600.00 100.00 600.00 Total Fee 600.00 Total Earned 600.00 Previous Fee Billing 300.00 Current Fee Billing 300.00 Total Fee 800,00 Total this task $300.00 Task: 0304 High School Cafeteria Addition- Design . . . ............. . High School Cafeteria Addition- Design Fee Phase Contract Documents Total Fee Percent Fee Complete Earned 1,600.00 100.00 1,600.00 1,600.00 Total Earned 1,600,00 Previous Fee Billing 1,600.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Page 2 Project: 20070069.00.0 COUDERSPORT SCHOOL DISTRICT Invoice No: 0057209 Task: 0305 High School Cafeteria- Consbitchon ..... . . . . . . . . . ........ . . . High School Cafeteria Addition- Construction Fee Phase Construction Admin. Total Fee Outstanding Invoices Number 0053543 0053883 0054481 0055887 Total Date 7/23/07 8/24/07 10/16/07 3/18/08 Percent Fee Complete Earned 400.00 100.00 400.00 400.00 Total Earned 400.00 Previous Fee Billing 200.00 Current Fee Billing 200.00 Total Foe 200.00 Total this task $200.00 Total this invoice Balance 2,440.00 4,880.00 4,880.00 900.00 13,100.00 $900.00 Total now due $14,000.00 Page 3 w?Mir?naarcax a w?aw??. LLD WBCM ALIOJCNMWAWmawmoim ? ? w Attp: Mr. fra * Marshal Domnbar 3,2W7 Page 3`of 3 !t is our Won Soeptanoa 4f this a8rwnwg lAfBCMzxiA 'ic?0 a d AiA CM@Ldho s of 'tC144) Maid Oft terms and oandttlats 4616 Aid" a0reemer whti:6 -Owner Thank YOP egakdort" ac?m,??.r+?tra:aek p :the:app i provide shish i er gri aes i?r le®isune: o0ioe. N you have. 4tiy<*?tf1. me aty?axrv?r?r;o !E3 S. epNrt.D:'Weber NO PMN.kW- 07.0674.OQ-P?ti301 dg- iFt,,'??`'i.~a??Xe '7'.•'ILi^4?• • :t•'i Y ,. ?•. •y.?:'1. i'.?.'•b'y ? r:_.;;:. ?,.- (?:4-, fix. ?? :5' •, yam? ? ?` '^:,?' =?'"? -: Invoice WHITNEY, BAILEY, COX & MAGNANI, LLC CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MD 21286 (410) 512-4500 Bink Partnership 133 South 32nd Street Attn: Mr. Harrison Bink (:amp Hill PA 17011 February 26, 2008 Project No: 20070674.00.0 Invoice No: 0055712 Project: 20070674.00.0 ST. NICHOLAS SERBIAN EASTERN ORTHODOX ST. NICHOLAS SERBIAN EASTERN ORTHODOX CHURCH Professional services from January 1 2008 to January 31, 2008 - ............... - ........... ...... Task: 0300 Design Phase Design Phase Fee Phase Percent Fee Complete Earned CONTRACT DOCUMENTS 6,200.00 50.00 3,100 00 Total Fee 6,200.00 Total Earned 3,100.00 Previous Fee Billing 0.00 Current Fee Billing 3,100.00 Total Fee 3,100.00 ...... ... Total this task $3,100.00 Task: 0301 Construction Phase ........................................."--'_.... Construction Phase Fee Phase CONSTRUCTION PHASE Total Fee Percent Fee Complete 800.00 0.00 800.00 Total Earned Previous Fee Billing Current Fee Billing Total Fee Earned 0.00 0.00 0.00 0.00 0.00 Total this task $0.00 EXHIBIT D Project: 20070674.00.0 ST. NICHOLAS SERBIAN EASTERN ORTHOD Invoice No: 0055712 Total this Invoice $3,100.00 Page 2 Invoice WHITNEY, BAILEY, COX & MAGNANI, LLC CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MD 21286 (410) 512-4500 Bink Partnership 133 South 32nd Street Attn: Mr. Harrison Bink Camp Hill PA 17011 March 25, 2008 Project No: 20070674.00.0 Invoice No: 0055993 Project: 20070674.00.0 ST. NICHOLAS SERBIAN EASTERN ORTHODOX ST. NICHOLAS SERBIAN EASTERN ORTHODOX CHURCH Professional services from February 1 2008 to February 29.2M . ............... Task: 0300 Design Phase Design Phase Fee Percent Phase Fee Complete Earned CONTRACT DOCUMENTS 6,200.00 80.00 4,960.00 Total Fee 6,200.00 Total Earned 4,960.00 Previous Fee Billing 3,100.00 Current Fee Biting 1,860.00 Total Fee 1,860.00 - . Total this task $1,860.00 Task: 0301 Construction Phase . . . ... ... - . . Construction Phase Fee Phase CONSTRUCTION PHASE Total Fee Percent Fee Complete Earned 800.00 0.00 0.00 800.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0,00 Total Fee 0.00 Total this task $0.00 Project. 20070674.00.0 ST. NICHOLAS SERBIAN EASTERN ORTHOD Invoice No: 0055993 Total this invoice $11860.00 Outstanding Invoices Number Date Balance 0055712 2126/08 3,100.00 Total 3,100.00 Total now due $4,960.00 Page 2 Invoice WHITNEY, BAILEY, COX & MAGNANI, LLC ---- --- CONSULTING ENGINEERS 849 FAIRMOUNT AVENUE, SUITE 100 BALTIMORE, MD 21286 (410) 512-4500 Bink Partnership 133 South 32nd Street Attn: Mr. Harrison Bink Camp Hill PA 17011 April 28, 2008 Project No: 20070674.00.0 Invoice No: 0056256 Project: 20070674.00.0 ST. NICHOLAS SERBIAN EASTERN ORTHODOX ST. NICHOLAS SERBIAN EASTERN ORTHODOX CHURCH Professional services from March 1 2008 to March 31, 2o0a ........- - .... _..... .. Task: 0300 Design Phase Design Phase Fee Percent Phase Fee Complete Earned CONTRACT DOCUMENTS 6,200.00 100.00 6,200 00 Total Fee 6,200:00 Total Earned 6,200.00 Previous Fee Billing 4,960.00 Current Fee Billing 1,240.00 Total Fee 1,240.00 Total this task $1,240.00 ...... . . ..... . . . ...... Task: 0301 Construction Phase - -... ...... Construction Phase Fee Percent Phase Fee Complete Earned CONSTRUCTION PHASE 800.00 0.00 0.00 Total Fee 800.00 Total Earned 0.00 Previous Fee Billing 0.00 Current Fee Billing 0.00 Total Fee 0.00 Total this task $0.00 Project: 20070674.00.0 ST. NICHOLAS SERBIAN EASTERN ORTHOD Invoice No: 0056256 Total this invoice $1,240.00 Outstanding Invoices Number Date Balance 0055712 2126/08 3,100.00 0055993 3/25/08 1,860.00 Total 4,960.00 Total now due $6,200.00 Trans?roro?gs.ems 'I C-. 106964 111 4?131 ?5 Verification I, G-yiz6k L, A3CMW am the C Fc> [title/position] for Whitney, Bailey, Cox & Magnani the plaintiff. I verify that the statements of fact In the within, pleading are true and correct to my knowledge, information and belief. This verification is made subject to the penalties of 18 pa. C.S. Section 4904, relating to unsworn falsifieatien to authorities. Date: 16b3&2 J Received Time Oct, 8. 2009 8:56AM No,7631 $178.50 PfS A" co 583 4 Rx* masocp Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Whitney Bailey Cox & Magnani vs. Bink Partnership, Inc. oMce 7,1 -E .mERIFF T H' A r'? rOTARY 2009 NOV -6 PM 2: 58 PEI- Case Number 2009-7322 SHERIFF'S RETURN OF SERVICE 10/28/2009 10:33 AM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 28 2009 at 1033 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bink Partnership, Inc. d/b/a Architectural Partnership, by making known unto Harrison Bink, Owner at 133 South 32nd Street Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, October 29, 2009 R THOMAS KLINE, SHERIFF BY ?? Deputy Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~, ~~-~'~~~ ~~,,~1,1r qt 4tripGrp~~~b Jody S Smith ~ ~~ ~fl~;~~a~~Y Chief Deputy Edward L Schorpp Z~~Q MAR " ~ PM I ~ 51 Solicitor ~~r,~ ~= -~~~ ~=~'-~~.+~~ CUM3~i~''•su ~JUMY FENtv~Y1.V~tv~1 Whitney Bailey Cox & Magnani Case Number vs. Bink Architectural Partnership, Inc. 2009-7322 SHERIFF'S RETURN OF SERVICE 02/23/2010 11:51 AM -Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2010 at 1151 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Bink Architectural Partnership, in the hands, possession, or control of the within named garnishee, Metro Bank, 1130 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Eric Inaza, Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. SHERIFF COST: $103.44 SO ANSWERS, February 24, 2010 RON ANDERSON, SHERIFF U '" Valerie Weary, Deputy fr,) Ccu,~iySuit~ 5henfl, 76~eos~tT. In;;. r SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson M-0MFE Sheriff OF TPFF P ",", )TAARY Jody S Smith 2; Chief Deputy 10 wSEEP-9 PM tf Richard W Stewart OFFICE .ct.iFF CVMB? "?': ri1 r??lJ1V1 Solicitor PEINMVANIA Whitney Bailey Cox & Magnani Case Number vs. 2009-7322 Bink Architectural Partnership, Inc. SHERIFF'S RETURN OF SERVICE 02/23/2010 11:51 AM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on February 23, 2010 at 1151 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Bink Architectural Partnership, in the hands, possession, or control of the within named garnishee, Metro Bank, 1130 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Eric Inaza, Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. 09/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as EXPIRED. Despite numerous attempts at service on Bink Architectural Partnership, 133 S 32nd Street, Camp Hill, PA 17011, the writ expired before it could be successfully served. SHERIFF COST: $133.95 SO ANSWERS, September 09, 2010 RON R ANDERSON, SHERIFF . zo,? B>Aaron R. Lantz 0 4 79We ;c CoimhjSuite Shenft. 1'e ;eno`t. Inc.