The URL can be used to link to this page

Home My WebLink About09-8369WOOLFORD LAW, P.C. ,,,4y-'Iimothy J. Woolford, Esquire Attorney I.D. No. 78941 Robert W. Melick, Esquire Attorney I.D. No. 205972 Wheatland Place 941 Wheatland Avenue, Suite 402 Lancaster, PA 17603 (717) 290-1190 REMCO, INC. 195 HEMPT ROAD MECHANICSBURG, PA 17055 Plaintiff, Attorneys for Plaintiff Remco, Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. No. -$3(09 ;V; i -Farm THOMAS GREEN 337 SWATARA CREEK DRIVE JONESTOWN, PA 17038 Defendant 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 WOOLFORD LAW, P.C. By: Timothy J. Woolford, Esquire Attorney LD. No. 78941 Robert W. Melick, Esquire Attorney I.D. No. 205972 Wheatland Place 941 Wheatland Avenue, Suite 402 Lancaster, PA 17603 (717) 290-1190 REMCO, INC. 195 HEMPT ROAD MECHANICSBURG, PA 17055 Plaintiff, V. THOMAS GREEN 337 SWATARA CREEK DRIVE JONESTOWN, PA 17038 Attorneys for Plaintiff Remco, Ina IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. _04- Defendant COMPLAINT Plaintiff, Remco, Inc. ("Remco' ), by and through its undersigned counsel, Woolford Law, P.C., hereby files this Complaint against Defendant Thomas Green ("Green") and in support thereof, avers as follows: Parties Remco is a construction company organized and existing under the laws of the Commonwealth of Pennsylvania with an address and principal place of business located at 195 Hempt Road, Mechanicsburg, Pennsylvania 17055, and a second Pennsylvania office located at 7264 Penn Drive, Allentown, PA 18106. 2. Upon information and belief, Green is an adult individual who is a Pennsylvania resident with an address of 337 Swatara Creek Drive, Jonestown, Pennsylvania 17038. Venue 3. Venue is appropriate in Cumberland County pursuant to Pa.R.C.P. 1006, because an event or occurrence out of which these causes of action arose occurred in Cumberland County. Factual Back-around 4. Remco is a mechanical contractor that installs and services plumbing, HVAC, refrigeration and electrical systems. 5. Remco has two offices, one in Mechanicsburg and one in Allentown. 6. Remco has been in business since 1977. 7. Green was employed by Remco between April 2003 and November 2008. 8. In October 2006, Remco promoted Green to the title of Service Manager in the Refrigeration Department at Remco's Allentown office. 9. In conjunction with this promotion, Remco required Green to transfer from its Mechanicsburg office to its Allentown office. 10. Green received a $10,000 raise as a part of this promotion. 11. After receiving the promotion, Green informed Remco that he would "never leave Remco." 12. In reliance on this promise and to facilitate his transfer, Remco provided $17,028.93 in improvements to Green's residence in Halifax. 13. Remco and Green understood that the purpose of this $20,000 was to help Green to sell his residence in Halifax. 14. Remco only provided this benefit to Green based on Green's representation that he would "never leave Remco." 2 15. Had Green not made this representation, Remco never would have paid for the improvements to the home. 16. From October 2006 until November 2007, Green worked out of the Allentown office while still residing in his Mechanicsburg area home. IT Green moved into his Jonestown residence in November 2007. 18. From November 2007 until February 2008 Remco paid Green's rent at the Jonestown home. 19. These rent payments totaled $4,000. 20. Remco only provided this benefit of rent payments based on Green's representation that he would "never leave Remco." 21. Had Green not made this representation, Remco never would have made these rent payments. 22. Additionally, Green signed a Personal Account Repayment Agreement with Remco and agreed, among other things, that " [i]n the event of separation, all outstanding balances will be due and payable immediately." This agreement is attached hereto as Exhibit "A." 23. Green continuously borrowed on his personal account throughout his career at Remco. 24. Unfortunately, despite his representation to the contrary, Green abruptly resigned from Remco on November. 10, 2008. 25. Though Green resigned from Remco on November 10, 2008, to date, Green has failed and refused to pay the outstanding balance on his personal account, which is $7,387.47. A record of Green's personal account is attached hereto as Exhibit "B." 3 COUNTI Remco, Inc. v. Thomas Green Uniust Enrichment 26. Remco incorporates Paragraphs 1 through 25 above as if set forth fully herein. 27. As a result of Green's promise to "never leave Remco," Remco expended $17,028.93 to improve his Halifax home. 28. Remco conferred and provided Green with a benefit, the value of which was $17,028.93. 29. Green accepted, retained and appreciated the benefit of these improvements to his Halifax home. 30. When Green resigned from Remco, his failure to compensate Remco for this benefit is inequitable and unjust. 31. Green's acceptance and retention of this benefit is inequitable and unjust. 32. To date, Green has not compensated Remco for these improvements. WHEREFORE, Plaintiff Remco, Inc. respectfully requests that this Court enter judgment in its favor against Defendant Thomas Green and award Remco, Inc. $17,028.93 plus interest, penalties, costs of suit and any further relief as the Court deems just and proper. COUNT II Remco, Inc. v. Thomas Green Uniust Enrichment 33. Remco incorporates Paragraphs 1 through 32 above as if set forth fully herein. 34. As a result of Green's promise to "never leave Remco," Remco expended $4,000 on Green's behalf to pay his rent. 35. Remco conferred and provided Green with a benefit, the value of which was $4,000. 4 36. Green accepted, retained and appreciated the benefit of these rental costs. 37. When Green resigned from Remco, his failure to compensate Remco for this benefit is inequitable and unjust. 38. Green's acceptance and retention of this benefit is inequitable and unjust. 39. To date, Green has not compensated Remco for these rental costs. WHEREFORE, Plaintiff Remco, Inc. respectfully requests that the Court enter judgment in its favor and against Defendant Thomas Green and award Remco, Inc. $4,000, plus interest, penalties, costs of suit and any further relief as the Court deems just and proper. COUNT III Remco, Inc. v. Thomas Green Breach of Contract 40. Remco incorporates Paragraphs 1 through 39 above as if set forth fully herein. 41. On August 27, 2004, Green and Remco entered into a Personal Account Repayment Agreement, which is attached hereto as Exhibit "A." 42. Pursuant to the terms of the Agreement, Remco agreed to loan Green money for Green's personal use. 43. Green continuously borrowed on his personal account throughout his career at Remco. 44. The Agreement provides that "[i]n the event of separation, all outstanding balances will be due and payable immediately." 45. Green resigned from Remco on November 10, 2008. 46. After resigning from Remco, the balance due on Green's account was $7,387.47. See Exhibit "B." 5 47. To date, Green has failed to pay this amount to Remco, which is a breach of the Agreement. 48. As a result of Green's breach of the Agreement, Remco has incurred damages of $7,387.47. WHEREFORE, Plaintiff Remco, Inc. respectfully requests that the Court enter judgment in its favor and against Defendant Thomas Green and award Remco, Inc. $7,387.47, plus interest, penalties, costs of suit and any further relief as the Court deems just and proper. Respectfully submitted, WOOLFORD LAW, P.C. By: -- - Timothy J. Woolford Attorney I.D. No. 78941 Robert W. Melick Attorney I.D. No. 205972 Wheatland Place 941 Wheatland Avenue, Suite 402 Lancaster, PA 17603 P: 717-290-1190 F: 717-290-1196 Date: December 1, 2009 6 rxx?iti,t A m. r w m 0 8 0 0 ? o ? m 'm m MW _..__.,.....__Aa Employee Owned Camperry Refrigeration • Electrical • iWechanical Contractors • Food Service • HtrAC • Plumbing PERSONAL ACCOUNT REPAYMENT AGREEMENT (Borrower), agree to the following conditions: 1. $500 credit limit will apply to personal account. 2. All of current month's charges are to be paid in full by the end of the following month. 3. If balance is not paid in full by end of the following month, weekly payroll deduction will begin at no less than 10% of the total amount until the debt is satisfied. 4. No additional charges will be permitted while payroll deduction is in effect. 5. In the event of separation, all outstanding balances will be due and payable immediately. Date: (Borrower) 7264 Penn Drive Allentown, PA 18106 610-391-9530 Fax 610-391-0954 www.ramcapa.com 195 Hempt Road Mechanlosburg, PA 17050 717-697-0389 Fax 717-697-4154 ,b,? ? x? m n i -, r' rn v, w m 0 8 b o n ? a Fn /AO-1114 - Thomas A Green Invoice6 or Invoice Invoice Credit Paymsnt Account Dab Vendor Check ¦ Amount Balance Amount Amount Balance Iii (ij Ii) li) Iii 0.00 08/25/04 New Account A 40.00 -40.00 Pmt: Derstine's Custom Embroidery 08/25104 TAG 431 0.00 0613/04 07108104 Dersline's 72302131 A 40.00 149.35 06131107 08/15/07 United Re( 17717210- B 149.35 GO." 11130107 11M6107 Jack W119a 3327153 C 491.60 C 50.00 590.95 01/04108 PR 76759 C 80.00 540.95 01/11/08 PR 77025 C 50.00 490.95 01/18/08 PR 77305 C 50.00 440.95 01/25/08 PR 77582 C 80,00 390.95 01131106 Yes, JANOS G/L PR 78085 02/01/08 C 50,00 340.95 02108108 PR 78312 p 671,00 _530,05 ' 02/15108 PR 78817 s account 11322.47 M'DUr9 purchases joumailzed onto Allentown 02/15/08 G/L JE-07( From ROM D 11852.52 7387.47 11423.02 01121/08 Eastern At 3-382379 E 1006 11541.57 01/21/08 Eastern AL 3.382439 F 116.55 02 11141 01/21/08 Eastern AL 3-382549 E 100.55 p . 50.00 11391.02 02/29/08 PR 78931 D 336,00 11058.02 PR 79425 03107108 g 50.00 11008.02 03/14/08 PR 79747 B 99.35 10908.87 03/21/08 PR 80124 C 50,65 10855.02 03121/08 PR 00124 C 50.00 10805.02 03128108 PR 80418 C 50,05 10715.07 04104/08 PR 80717 D 154.06 10556.02 03131108 Yes, MAR08 GIL 04/3/08 PR 80717 p 50,00 10508.02 04/11108 PR 81232 D 50,00 10456.02 04118108 PR 81528 p 50,00 10406.02 04125108 PR 81821 D 50,00 10356.02 0413306 Yes, APR08 G/L 05/02/08 PR 81900 D 50,00 10305.02 05/09/08 PR 82418 p 50,00 10258.02 05/18/08 PR 82722 p 50,00 10206.02 05/23/08 PR 83020 D 50.00 10156.02 05/30/08 PR 83318 D 50.00 10106.02 05131106 Yes, MAY08 G/L 0 PR 83824 /00108 D 500,00 9808,02 06 6/13/08 PR 83928 p 50.00 9558.02 08120/08 PR 64001 p 50.00 9508.02 08/27/08 PR 84304 D 50.00 9456.02 0630108 Yes,JUN0$ G/L 07103/08 PR 84939 D 50,00 9406.02 07/1/08 PR 84918 D 50.00 9356.02 07116108 PR 85481 D 50.00 9308.02 07125/08 PR 85772 p 50,00 9256.02 0731108 Yes, JUL08 GAL 08/01/08 PR 86087 D 50,00 9208.02 08/08/08 PR 88399 D 50.00 9156.02 08115/08 PR 88853 p Sp,OO 9108.02 08122108 PR 86730 D 50.00 9058.02 08/29108 PR 87091 D 50,00 9006,02 0831108 Yes, AUGOS G/L 09/05/08 PR 87810 p 50,00 8956.02 09/12108 PR 87888 p 50.00 8906.02 09/19/08 PR 88211 D 50.00 8856.02 09/28/08 PR 88518 p 50,00 8808.02 10/03108 PR 88542 D 50.00 8756.02 10/17/08 PR 88855 p 50.00 8706.02 1017108 PR D 50.00 8856.02 17/24108 PR D 50.00 8606.02 1031/08 PR F 116.55 8487.47 11/07/08 PR D 900.00 7867.47 11130106 11/14/08 PR p 100.00 7487.47 12131106 12103108 TAG D 100,00 7387.47 02125109 TAG 7387.47 7387.47 7387.47 0 2l0 9 0 C -3 PY,? l CU u `?! *78.50 PD ATr/ u.34 43073 No+fae- 0AaW Fl~.CC~-~~-~.:!~~ Jeffrey T. McGuire, Esquire ~~''- TF!C ~~~T IC~'~'~?','~,RY Attorney I. D. # 73617 Z~ ~ ~ ~ t Caldwell & Kearns, P.C. `"'~ ~ ~ ~'~ ~~ t~ ~ 3631 North Front Street ~, r ^ r Harrisburg, PA 17110-1533 -; -~- ~'~ ~ Y (717) 232-7661 Fax: (717) 232-2766 Attorney for Defendant, Thomas Green REMCO, INC., IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 09-8369 Civil Term THOMAS GREEN, CIVIL ACTION -LAW Defendant. JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Remco, Inc. c/oTimothy J. Woolford, Esquire Robert W. Melick, Esquire WOOLFORD LAW, P.C. Wheatland Place 941 Wheatland Avenue, Suite 402 Lancaster, PA 17603 YOU ARE HEREBY NOTIFIED that the New Matter and Counter-Claim set forth herein contain averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Date: January 14, 2010 By: ~effr Guire, Esquire At rney I. . # 73617 aldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717)232-7661 (717) 232-2766 (fax) jmcguire@caldwellkearns.com Attorney for Defendant, Thomas Green Jeffrey T. McGuire, Esquire Attorney I. D. # 73617 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Fax: (717) 232-2766 Attorneys for Defendant, Thomas Green REMCO, INC., IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA vs. THOMAS GREEN, Defendant. No. 09-8369 Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT, THOMAS GREEN'S ANSWER WITH NEW MATTER AND COUNTER-CLAIM TO PLAINTIFF'S COMPLAINT 1. Admitted. 2. Admitted. 3. Denied as a conclusion of law. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Denied. Defendant was promoted to the position of Service Manager at the end of 2003. 9. Denied as stated. It is admitted that Plaintiff transferred Defendant from Mechanicsburg to Allentown. 10. Denied as stated. It is admitted that Defendant received a Ten Thousand Dollar ($10,000.00) raise as part of the transfer. 11. Denied as stated. 1 1 i ~ A 12. Denied. By way of further answer, Plaintiff provided employees to work on Plaintiff's residence in Halifax so he was free to work on sales for the Allentown office in New York, Delaware, New Jersey and eastern Pennsylvania, and so that Defendant could sell his Halifax home and move to Allentown. Further, Defendant agreed to pay the costs of the materials and Plaintiff agreed to supply the labor. 13. Admitted in part. By way of further answer, it was to allow Defendant more time to work for Plaintiff because prior to the transfer he was personally doing the labor to remodel his home and Plaintiff wanted him to devote more time to fixing the problems at the Allentown office. 14. Denied. 15. Denied. 16. Admitted. 17. Admitted. 18. Admitted. 19. Admitted. 20. Denied. Plaintiff agreed to pay six (6) months rent on Defendant's residence in Jonestown so that Plaintiff did not have to reimburse Defendant for the mileage, eighty-eight (88) miles one way from Halifax to Allentown, and so that Defendant had more time to devote to fixing the problems with the Allentown office. 21. Denied. 22. Denied. Exhibit "A" is a written document that speaks for itself. 2 1 ~ ~ ~ 23. Denied as stated. Defendant did agree to pay the materials used in his Halifax residence. He agrees he owes Seven Thousand Three Hundred Eighty-Seven and 47/100 Dollars ($7,387.47) for these materials which he has offered to pay. 24. Denied. Defendant did resign from Remco. 25. Denied. Defendant has offered to pay the balance, but Plaintiff is claiming more than it is owed. COUNTI Remco, Inc. v. Thomas Green Unjust Enrichment 26. Defendant, Thomas Green incorporates the answers to paragraphs 1 through 25 as though set forth at length. 27. Denied. 28. Denied. 29. Denied as stated. 30. Denied. 31. Denied. 32. Denied. WHEREFORE, Defendant, Thomas Green respectfully requests this Honorable Court dismiss the Complaint and enter judgment in his favor and against Plaintiff without cost to him but together with costs, expenses and attorney's fees that the Court deems necessary, just and appropriate under the circumstances. 3 1 ~ ~ ~ COUNT II Remco, Inc. v. Thomas Green Unjust Enrichment 33. Defendant, Thomas Green incorporates the answers to paragraphs 1 through 32 as though set forth at length. 34. Denied. 35. Denied. 36. Admitted. 37. Denied. 38. Denied. 39. Denied. WHEREFORE, Defendant, Thomas Green respectfully requests this Honorable Court dismiss the Complaint and enter judgment in his favor and against Plaintiff without cost to him but together with costs, expenses and attorney's fees that the Court deems necessary, just and appropriate under the circumstances. COUNT III Remco, Inc. v. Thomas Green Breach of Contract 40. Defendant, Thomas Green incorporates the answers to paragraphs 1 through 39 as though set forth at length. 41. Admitted. 42. Denied. 43. Denied. 44. Admitted. 45. Admitted. 4 46. Denied. By way of further answer, Defendant agrees he owes Seven Thousand Three Hundred Eighty-Seven and 47/100 Dollars ($7,387.47) for the materials used on his Halifax home. 47. Denied. 48. Denied. WHEREFORE, Defendant, Thomas Green respectfully requests this Honorable Court dismiss the Complaint and enter judgment in his favor and against Plaintiff without cost to him but together with costs, expenses and attorney's fees that the Court deems necessary, just and appropriate under the circumstances. NEW MATTER 49. Defendant, Thomas Green incorporates the answers to paragraphs 1 through 48 as though set forth at length. 50. Shortly after Defendant was transferred to Allentown, Plaintiff agreed to pay him Five Hundred Dollars ($500.00) per month for his truck' use and all maintenance expenses due to the increased commute. 51. Plaintiff also provided Defendant a gas card to cover the cost of his gas. 52. Plaintiff failed to reimburse Defendant for the repairs to his truck performed on May 7, 2008, at the total cost of One Thousand Seventy-Five and 54/100 Dollars ($1,075.54). See Exhibit "A" attached. 53. Plaintiff also continued to reimburse Defendant's mileage including his eighty- eight (88) mile commute one way. 54. Plaintiff knew that at the time of his transfer he was in the process of personally remodeling his home in Halifax. 5 55. In order to allow Defendant to devote additional time to fixing the problems in the Allentown office, Plaintiff agreed to provide the labor to complete the remodeling of Defendant's home in Halifax. 56. Plaintiff requested Defendant to move closer to the Allentown office. 57. As part of Defendant's duties as Service Manager in Allentown, Defendant was required to make sales calls in New Jersey, Delaware, New York, and eastern Pennsylvania. 58. In order to move closer to Allentown, Plaintiff knew that Defendant had to sell his home in Halifax. 59. To induce Defendant to move closer to Allentown sooner, Plaintiff agreed to pay Defendant's rent for six (6) months. See Exhibit "B" attached and incorporated herein by reference. 60. Plaintiff only paid four (4) months rent. 61. Despite requests to do so, Plaintiff never paid the other two (2) months rent totaling Two Thousand Dollars ($2,000.00). 62. After Defendant moved to Jonestown, Plaintiff stopped paying Defendant Five Hundred Dollars ($500.00) per month for use of his truck. 63. Defendant listed his home in Halifax for sale for Two Hundred Ten Thousand Dollars ($210,000.00). 64. Defendant sold his home in Halifax at the insistence of Plaintiff for only One Hundred Seventy-Five Thousand Dollars ($175,000.00) so that he could be close to the Allentown office. 65. Defendant is entitled to a set-off for the loss he took on the sale of his home at the insistence of Plaintiff. 6 66. Plaintiff s cause of action may be barred in whole or in part by the applicable statute of limitations. 67. Plaintiff s cause of action may be barred in whole or in part by the doctrine of accord and satisfaction. 68. Plaintiff s cause of action may be barred in whole or in part by waiver and/or estoppel. 69. Plaintiff s cause of action may be barred in whole or in part by the statute of frauds. 70. Plaintiff s cause of action may be barred in whole or in part by the parole evidence rule. 71. Plaintiff failed to state a cause of action upon which relief may be granted under any theory of law. WHEREFORE, Defendant, Thomas Green respectfully requests this Honorable Court dismiss the Complaint and enter judgment in his favor and against Plaintiff without cost to him but together with costs, expenses and attorney's fees that the Court deems necessary, just and appropriate under the circumstances. COUNTER-CLAIM COUNTI BREACH OF CONTRACT 72. Defendant, Thomas Green incorporates the answers to paragraphs 1 through 71 as though set forth at length. 73. Plaintiff agreed to pay One Thousand Dollars ($1,000.00) per month for six (6) months for Defendant's rent and only paid for four (4) months rent. 7 74. Plaintiff owed Defendant Two Thousand Dollars ($2,000.00) for the remaining two (2) months rent. WHEREFORE, Defendant, Thomas Green respectfully request this Honorable Court to find in his favor and award Two Thousand Dollars ($2,000.00) plus interest, costs and attorney's fees that the Court deems necessary, just and appropriate under the circumstances. COUNTER-CLAIM COUNT II BREACH OF CONTRACT 75. Defendant, Thomas Green incorporates the answers to paragraphs 1 through 74 as though set forth at length. 76. Plaintiff agreed to pay Defendant's maintenance costs for his truck. 77. Defendant incurred maintenance expenses of One Thousand Seventy-Five and 54/100 Dollars ($1,075.54) on May 7, 2008. 78. Plaintiff failed to pay the May 7, 2008, expenses. WHEREFORE, Defendant, Thomas Green respectfully request this Honorable Court to find in his favor and award One Thousand Seventy-Five and 54/100 Dollars ($1,075.54) plus interest, costs and attorney's fees that the Court deems necessary, just and appropriate under the circumstances. tted, Date: January 14, 2010 By: T ttr Guire, Esquire Att ey . D. # 73617 ldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 (717} 232-2766 (fax) jmcguire@caldwellkearns.com Attorney for Defendant, Thomas Green 8 VERIFICATION I, Thomas Green, hereby verify that the facts set forth in the foregoing document are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 Pa.C.S § 4904 relating to unsworn falsification to authorities. Dated: l - l y - z o! ~ ~- /~-, Thomas Green SINCE 1921 ~ ~ , ~~ C~EVY TRUCKS .~ .CHEVROLET SERVICE INVOICE Fair People. rQir Pnces. 7831 Main St., P. O. Box 155 Fogelsville, PA 18051-0155 Phone 610-395-3345 Toll Free 8$8-383-3247 www.strohlchevy.com FVO VIN GATE ai 03934 G C E K 1 9 Z 3 5 Z 1 4 1 6 2 4 THOMAS GREEN 05/06/08 YFAR MNCE IAODEL COLOR TIME IN 2005 CHEVROLET K1500 SILV 337 SWATARA CREEK DR 07:15 MILES IN MMES our RRST usE usc. JONE S TOWN PA 17 0 3 8 txosEo 154036 54036 00/00/00 YNV8792 05/07/08 us C: (484) 225-4051 "'~ e Fi : ( ) - W : ( ) - KD SERVICE 4X4 LIGHT ON CK CODE C0327 ENCODER CIRCUIT MALFUNCTION REPLACED ENCODER MOTOR SENSOR (Tech:40) A Labor T40 78.00 88962315 (SENSOR) 1 98.42 Total Labor ............................. 78.00 Total Parts ............................. 98.42 Total Repair (Customer ) ................. 176.42 CHECK STEERING NOISE ON LEFT TURN CR NOISE/COMING FROM STEERING BOX/REPLACED STEERING BOX (Tech:40) A Labor T40 117.00 88965789 (S/GR RE) 1 583.12 89021184 (FLUID) 1 4.80 Total Labor ............................. 117.00 Total Parts ............................. 587.92 Total Repair (Customer ) ................. 704.92 ( ) GET PRICE ON WINDSHIELD' 310.00 INSTALLER/CUSZ`OMER-:DECLINED AT PRESENT Labor T40 TIME (Tech:40) A ............ .(Internal )...... ... ( ) CK NOISE FROM DIFFERENTIAL/DRAIN AIQD FLUSH DIFFERENTIAL Labor T40 54.60 R&R REAR DIFFERENTIAL COVER] CK SPYDER GEARS ,..15807693 (GASKET) 1 8.76 CK BACKLASH / FLUSH REAR DIFFERENTIAL Total Labor ............................. 54.60 REPLACED COVER GASKET AND REFILL DIFFERENTIAL 'Total Parts ........... ................... 8.76 (Tech:40) A Total-Repair (Customer )..... ........ 63.36 ( ) WHEEL ALIGNM)aNT Lobar T34 69.95 Total Labor .... ... ... 69.95 (Tech:34) A Total Rega.r (Customer )... .......'...... 69.95 v C". +~ ti - _ , _~ ~ '1 'QC . a ~ ~n ~_ ~-^ S r .-~ -^ .--1 ~. - ~ 9 J 4f C7 fL Q 'S p A' J .-_ ~ ~ ~ Z M 9 W } -~ L Z =_ .~.1 ~ i7 ~ ~ ' J £ ti M r~l J~• ~ -'.C S ~ 9 '~ `V d - -.-i ~ - - ^.] .-1 VJ .-1 cT -~ -. -'~ d' M J :D CJ - Gil -~ ~ LL i7 t~> =~- ~ ~ ~ . 00 abor 319.55 .00 arts 695.10 DISCLAIMER OF WARRANTIES . 0 0 ubl e t . 0 0 Mywarrarrtlesontheprodudsoldtrerabyaredrosemadebythemanldactlrer.lTreseXaMrebyexpresslydlsclaimsaNwarrantleseiMerexpnrssedorimpiad, pp sate Dispos .Ol) irwludlnp am/ impNedwarranty d merchardabiliry ottitrressfaa partlcWar propose, and rreitler assrarres nor autlaraes airy person lnconrrecaonwitlrthesahofsaidproducts.NNlimitatloncontairedhereindoesnotappywhaeprohibNedbylaw. to assraneiorit arty liabiigy , 00 it/Grease .00 X .00 ub Total 1014.65 CUSTOMER SIGNATURE . 0 0 . 0 0 ax 6 0. 8 9 f 1 JOb 083 1 P .00 otal (Cash) 1075.54 O age 0 3 9 3 4 Cus ts~mer Copy ~ ~ /~EMCO,,N~. September 27, 2007 Hill PHOENIX An Employee Owned Company Refrigeration • Electrical • Mechanical Contractors • Food Service • HVAC • Plumbing To Whom It May Concern: The purpose of this correspondence is to confirm that Remco, Inc. has agreed to pay Thomas Green $1,000.00 per month for a total of six months beginning on November 1, 2007, for the purpose of renting the property at 337 Swatara Creek Drive, Jonestown, PA 17038. If you need any additional information, please contact me. Sincerely, Jai M. Hoover Director of Service Operations ..~ i' ~'~ "' j 7264 Penn Drive Allentown, PA 18106 195 Hempt Road 610-391-9530 Mechanicsburg, PA 17050 Fax 610-391-0954 W W W, r e m C O p a. C O m 717-697-0389 Fax 717-697-4154 ., CERTIFICATE OF SERVICE AND NOW, this 14th day of January 2010, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Timothy J. Woolford, Esquire Robert W. Melick, Esquire WOOLFORD LAW, P.C. Wheatland Place 941 Wheatland Avenue, Suite 402 Lancaster, PA 17603 CALDWELL & KEARNS By: of co David D. Buell- "a 414P' Renee R Simpson Prothonotary ;, y 1St Deputy Prothonotary o , dew-1 _ ,.1 z KirkS. Sohonage, ESQ _;a,. Jam, Irene E. Morrow Solicitor 7750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania 64 — 83L9 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Tac(717)240-6573