HomeMy WebLinkAbout01-0898ZEPL1N'S SECURITY GROUP, 1NC.,
Plaintiff
THOMAS CRABTREE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
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 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 Plaintiffs. 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.
COURT ADMINISTRATOR
4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere 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 escrita o en
persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las
demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara
medidas y puede entrar trna orden contra usted sin previo aviso o notificacion y por cualquier
queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus
propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVIC10,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIC1NA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
COURT ADMINISTRATOR
4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
2
ZEPL1N'S SECURITY GROUP, INC.,
Plaintiff
THOMAS CRABTREE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.
COMPLAINT
Plaintiff, Zeplin's Security Group, Inc. ("Zeplin"), by and through its attorneys,
Buchanan Ingersoll Professional Corporation, hereby files the within Complaint as follows:
1. Plaintiff, Zeplin, is a Pennsylvania corporation with a principal place of business
located at 2026 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant, Thomas Crabtree ("Crabtree"), is an adult individual residing at 5 Sara
Drive, Dover, York County, Pennsylvania 17315.
3. Zeplin is engaged in the alarm security business and provides installation and
service on residential and commercial burglar and fire alarm systems.
4. On June 5, 1998, Zeplin and Crabtree entered into an Alarm System Agreement
for the installation and service of an alarm system at Crabtree's residence. A true and correct
copy is attached hereto as Exhibit "A."
5. The total fees for installation and sale of the alarm system at Crabtree's residence
were $5,751.00.
6. In addition to installation and service of the Alarm System Agreement, Zeplin and
Crabtree agreed that Zeplin would provide monitoring service to Crabtree for a period of five
years beginning on February 1, 1999 at the amount of $32.25 per month or $1,935.00 over the
five year term.
7. Crabtree paid $4,876.00 of the $5,751.00 installation and sale amount, but failed
to pay the remaining $875.00.
8. Crabtree has failed to perform under the agreement and, to date, has not paid for
any of the monitoring agreed to in the Alarm System Agreement.
9. Paragraph six of the Alarm System Agreement provides, inter alia,
If the customer fails to perform its obligations, the company will give the
customer written notice of defanlt. If the customer does not fix the default within
30 days, the company can end this agreement. If the company ends this
agreement, the customer must pay the company: (a) all amounts then due; (b)
80% of the amount due to the company for the remainder of this agreement (as an
agreed upon amount of damages and not as a penalty); and (c) the company's
reasonable collection costs, including attorney's fees.
10. On or about July 2, 1999, Zeplin gave written notice to Crabtree of the default.
11. Crabtree did not fix the default.
12. Accordingly, Zeplin ended the agreement on August 2, 1999 (30 days after the
July 2, 1999 notice), and is entitled to all amounts then due; 80% of the amount due to Zeplin for
the remainder of the agreement; and Zeplin's reasonable collection costs, including attorney's
fees.
13.
To date, Crabtree owes Zeplin the following liquidated damages:
a. Installation and sale of system - $875.50;
b. Standard monitoring fee due at termination - $193.50;
c. Standard monitoring fee for the remaining 54 months of the Alarm
System Agreement - $1,741.50 (80% = $1,393.20).
2
14. Zeplin continues to have unliquidated damages pursuant to the Alarm System
Agreement for its reasonable collection costs and attorney's fees.
WHEREFORE, Zeplin's Security Group, Inc. respectfully requests that this Court enter
judgment in the amount of $2,462.20 of liquidated damages and for unliquidated damages
including reasonable collection costs and attorney's fees as will be proved at trial and any other
relief as this Court deems just and appropriate.
BUCHANAN INGERSOLL
PROFESSIONAL CORPORATION
.,}ei~t t hew'"C. ~ rown~'o~'t, Esquire
I.D. #81915
One South Market Square
213 Market Street
3rd Floor
Harrisburg, PA 17101
(717)237-4800
DATE: February 14, 2001
VERIFICATION '
I, Fred W. Zeplin, have read the foregoing document and verify that the facts set forth are
true and correct to the best of my knowledge, information and belief. To the extent that the
foregoing document and/or its language is that of counsel, I have relied upon counsel in making
this Verification.
I understand that any false statements made herein axe subject to the penalties of 1 g Pa.
C.S.A. § 4904, relating to tmswom falsification ;o authorities.
DATE:
February 14, 2001
Exhibit A
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I~D '~ UNDEr. OD ~IS ,AGRE~M~. ESpE~ALLy.~HOSE
' CANCEL ~IS T~N~A~bN
AYE OF THIS TRANSACTION."?LEASE"SE~:THE ,
Z~PUN SECUR~ G~OUP, INC,
'
CERTIFICATE OF SERVICE
I, Matthew C. Browndorf, Esquire, certify that I have this date, served a copy of the
foregoing document upon the following counsel by United States mail, first class, postage
prepared:
Anthony J. Nestico, Esquire
Nestico & Dmby, LLP
840 East Chocolate Avenue
Hershey, PA 17033
DATE: Febmmry 14, 2001
ZEPL1N' S SECURITY GROUP,
Respondent
THOMAS C. CRABTREE,
Movant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 01~898 CIVIL TERM
ANSWER TO NEW MATTER WITH COUNTERCLAIM
AND NOW, the Defendant, Thomas Crabtree by and through his undersigned
counsel hereby files the folloxving Answer With New Matter and Counterclaim and avers
in support thereof the following:
1. Admitted, based on information and belief.
2. Admitted.
3. Admitted, based on information and belief.
4. Denied as stated. It is admitted that on or about June 5, 1998 Zeplin and
Crabtree entered into an agreement for the installation and service of an alarm system at
Crabtree's residence. It is denied that Zeplin performed as required under the contract.
The contract attached is Exhibit A is a matter of record before this Honorable Court and
its terms speak for themselves.
5. Denied as stated. The contract is a matter of record before this Honorable
Court and its terms speak for themselves. The PlaintifI's characterization of the terms
thereof is specifically denied.
6. Denied as stated. It is admitted that the parties contemplated a monitoring
service, it is denied that Zeplin performed sufficiently to require monitoring services.
The balance of the paragraph is specifically denied and strict proof thereof is demanded
at trial.
7. Denied as stated. It is admitted that Defendant Crabtree paid $4,876.00.
By way of further answer, this amount represents an overpayment to the Plaintiff. By
was of still further answer, Plaintiff is not entitled to any additional payments from the
Defendant.
8.
of law to which no response is required. To the extent that they are deemed to be
averments of fact, they are specifically denied and strict proof thereof is demanded at
trial.
9. Denied. The averments contained in paragraph 9 reflect the language of
the contract alleged in paragraph 4 of the complaint. Said contract is a matter of record
before this Honorable Court and its terms speak for themselves. By way of further
response, Plaintiff's allegation that he is entitled to any penalties or reasonable costs or
attorney's fees is a conclusion of law to which no response is required.
10. Admitted in part and denied in part. It is admitted that on July 2, 1999
Zeplin purportedly gave notice to Crabtree of an alleged default under the contract. It is
specifically denied that Crabtree defaulted under the terms of the contract.
Denied. It is specifically denied that Crabtree defaulted under the
I1.
contract.
12.
Denied. The averments contained in this paragraph constitute conclusions
Denied. The averments contained in this paragraph constitute conclusions
of law to which no response is required. To the extent a response is required, the
averments are specifically denied and strict proof thereof is demanded at trial.
13. Denied. The averments contained in this paragraph constitute conclusions
of law to which no response is required. To the extent a response is required, the
averments are specifically denied and strict proof thereof is demanded at trial.
14. Denied. The averments contained in this paragraph constitute conclusions
of law to which no response is required. To the extent a response is required, the
averments are specifically denied and strict proof thereof is demanded at trial.
WHEREFORE, Crabtree respectfully request this Honorable Court dismiss the
Plaintiff's complaint and enter judgment in its favor, together with any other relief this
Honorable Court deems just and appropriate.
NEW MATTER
The forgoing numbered paragraph are incorporated herein by reference.
The Plaintiff's claims are barred by the doctrine of estoppel.
The Plaintiff's claims are barred by the doctrine of failure of
15.
16.
17.
consideration.
18.
19.
20.
The Plaintiff's claims are barred by the doctrine of justification.
The Plaintiff's claims are barred by the doctrine of latches.
The Plaintiff agreed to install a whole-house security and monitoring
system for the Defendant's property.
21. As a part of the agreement, Plaintiff agreed to install a temporary alarm
system in the house during its construction.
22. As a part of the permanent system, Plaintiff agreed to install a driveway
alarm system.
23. Plaintiff breached the contract by failing to install the temporary security
system to protect the residence during construction.
24. As a result of the Plaintiff's failure to install the temporary system, the
house was burglarized several times during construction.
25. Plaintiff failed to install the driveway system.
26. Plaintiff installed the permanent system improperly and failed to install it
in a workman like manner.
27. As a result of the Plaintiff's failure to properly install the system, the
system malfunctioned repeatedly.
28. As a result of the failure of the Plaintiff to properly install the permanent
system, the Defendant experienced repeated false alarms and malfunctions.
29. The repeated false alarms required substantial time and effort on the part
of the Defendant to notify local police as to the reasons for the repeated false alarms.
30. The Defendant has employed Plaintiff for nearly 20 years with various
security systems in Defendant's prior homes.
31. Defendant had over the course of those 20 years been generally satisfied
with Plaintiff's work.
32. Plaintiff installed the current system in such a poor and unworkman like
manner that the system was virtually worthless as of the time of its installation.
33. Defendant has expended and will continue to expend substantial additional
monies to correct the shoddy, poor, unworkman like product the Plaintiffhas installed in
the Defendant's home.
34. Defendant notified the Plaintiff on numerous, repeated occasions that the
system had been installed improperly and was not operating properly.
35. PlaintiWs employees acknowledged that the system had been installed
incompletely and improperly.
36. Plaintiff has failed to correct the numerous and significant deficiencies in
the system.
COUNT I
DEFENDANT V. PLAINTIFF, BREACH OF CONTRACT
37. The forgoing numbered paragraphs are incorporated herein by reference.
38. Plaintiff failed to completely install the security system and as a result
broached the contract.
39. Plaintiff accepted payment from the Defendant for the majority of the
system even though the Plaintiff had failed to install the driveway alarm.
40. Plaintiff accepted payment from the Defendant even though the Plaintiff
failed to properly install the system.
41. Plaintiff has been overpaid by the Defendant.
42. Defendant has incurred and will continue to incur substantial additional
expenses to correct the Plaintiff's shoddy workmanship and complete the installation of
the system.
WHEREFORE, Defendant is entitled to judgment against the Plaintiff in an
amount that requires that this matter be set down for mandatory arbitration.
COUNT II
NEGLIGENCE
43. The fbrgoing numbered paragraphs are incorporated herein by reference.
44. The Plaintiff was negligent in that it:
a.) Failed to install the required temporary system;
b.) Failed to install the driveway alarm;
c.) Installed a system that malfunctioned repeatedly;
d.) Installed a system that experienced repeated false alarms; and
e.) Installed a system that did not function properly and required
substantial repair and renovation.
45. As a result of the Plaintiff' s negligence, the Defendant has incurred and
will continue to incur substantial expenses and damages.
WHEREFORE, Defendant respectfully demands judgment against the Plaintiff in
an amount that requires this matter to be set forth fbr mandatory arbitration.
Respectfully submitted,
NESTICO & DRUBY, L.L.P.
BY: ~~.~5,8'~uir[ e~
840 East Chocolate Avenue
Hershey, Pennsylvania 17033
(717) 533-5406
(717) 533-5717
Attorney for Movant
6
MAR-1~-~00111:~A FROM:NEST~CO+DRUSY-LLP 7175335717 T0:9~35605 P:9~10
VERIFICATION
I verity that the statements made in the forgoing document are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4904 relating to unsworn falsification to authorities.
Thomas C. Crabtree
CERTIFICATE OF SERVICE
I, Anthony J. Nestico, of the law firm of Nestico & Druby, L.L.P., hereby certify
that on the '~O day of March, 2001, a copy of the foregoing document was sent via
First Class U.S. Mail, postage paid, to the following:
Matthew C. Browndorf, Esquire
Buchanan Ingersoll
P.O. Box 12023
One South Market Square
213 Market Street, 3rd Floor
Harrisburg, PA 17108-2023
ZEPLIN'S SECURITY GROUP, 1NC.,
Plaintiff
THOMAS CRABTREE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-898 Civil
PLAINTIFF'S REPLY TO NEW MATTER AND
COUNTERCLAIM OF DEFENDANT THOMAS CRABTREE
Plaintiff, Zeplin's Security Group, Inc. ("Zeplin"), by and through its attorneys,
Buchanan Ingersoll Professional Corporation, hereby files the within Reply to New Matter and
Counterclaim as follows:
16. Denied. The averments contained in paragraph 16 constitute legal conclusions to
which no response is required. To the extent a response is required, the averments contained in
paragraph 16 are denied and strict proof thereof is demanded at trial.
17. Denied. The averments contained in paragraph 17 constitute legal conclusions to
which no response is required. To the extent a response is required, the averments contained in
paragraph 17 are denied and strict proof thereof is demanded at trial.
18. Denied. The averments contained in paragraph 18 constitute legal conclusions to
which no response is required. To the extent a response is required, the averments contained in
paragraph 18 are denied and strict proof thereof is demanded at trial.
19. Denied. The averments contained in paragraph 19 constitute legal conclusions to
which no response is required. To the extent a response is required, the averments contained in
paragraph 19 are denied and strict proof thereof is demanded at thai.
20. Admitted in part and denied in part. It is admitted that Plaintiff and Defendant
entered into an Alarm System Agreement for the installation and service of an alarm system at
Defendant's residence. The terms of that agreement are embodied in the Alarm System
Agreement attached to Plaintiff's Complaint at Exhibit "A" and the terms speak for themselves
and, therefore, Defendant's characterization that "Plaintiff agreed to install a whole-house
security and monitoring system for the Defendant's property" is specifically denied.
21. Admitted in part and denied in part. It is admitted that Plaintiff and Defendant
entered into an Alarm System Agreement for the installation and service of an alarm system at
Defendant's residence. The terms of that agreement are embodied in the Alarm System
Agreement attached to Plaintiff' s Complaint at Exhibit "A" and the terms speak for themselves
and, therefore, Defendant's characterization that "Plaintiff agreed to install a temporary alarm
system in the house during its construction" is specifically denied.
22. Admitted in part and denied in part. It is admitted that Plaintiff and Defendant
entered into an Alarm System Agreement for the installation and service of an alarm system at
Defendant's residence. The terms of that agreement are embodied in the Alarm System
Agreement attached to Plaintiff' s Complaint at Exhibit "A" and the terms speak for themselves
and, therefore, Defendant's characterization that "Plaintiff agreed to install a driveway alarm
system" is specifically denied.
23. Denied. The averment in paragraph 23 that Plaintiff"breached the contract" is a
legal conclusion to which no answer is required. To the extent an answer is required, the
averments contained in paragraph 23 are denied and strict proof thereof is demanded at trial.
2
24. Denied. Plaintiff is without knowledge or information as to whether the house
was burglarized several times during construction and, therefore, cannot admit or deny that
averment. Under any circumstance, however, Plaintiff's alleged failure to install the alleged
temporary system, which is denied, was not the cause of the burglaries alleged in paragraph 24 of
Defendant's New Matter.
25. Denied. It is denied that Plaintiff failed to install the driveway system. To the
contrary, Plaintiff complied with all the terms of the Alarm System Agreement attached to
Plaintiff's Complaint as Exhibit "A."
26. Denied. It is denied that Plaintiff installed the permanent system improperly and
failed to install it in a workman like manner. To the contrary, Plaintiff complied with all the
terms of the Alarm System Agreement attached to Plaintiff's Complaint as Exhibit "A."
27. Denied. It is denied that Plaintiff failed to properly install the system or that
Plaintiff's alleged failure to properly install the system was the cause of any alleged system
malfunction. To the contrary, Plaintiff complied with all the terms of the Alarm System
Agreement attached to Plaintiff's Complaint as Exhibit "A."
28. Denied. It is denied that Defendant experienced repeated false alarms and
malfunctions as a result of the alleged failure of Plaintiff to properly install the permanent
system. To the contrary, Plaintiff complied with all the terms of the Alarm System Agreement
attached to Plaintiff's Complaint as Exhibit "A."
29. Denied. It is denied that the alleged repeated false alarms were the fault of
Plaintiff. To the contrary, Plaintiff complied with all the terms of the Alarm System Agreement
attached to Plaintiff's Complaint as Exhibit "A." Plaintiff is without knowledge or information
3
as to the remaining averments alleging substantial time and effort on the part of the Defendant to
notify local police as to the reasons for the alleged repeated false alarms and, therefore, those
averments are denied and strict proof thereof is demanded at trial.
30. Admitted.
31. Admitted.
32. Denied. It is denied that the system referred to in paragraph 32 of Defendant's
New Matter was installed in a poor and unworkman like manner or that the system was virtually
worthless at the time of its installation. To the contrary, Plaintiffcomplied with all the terms of
the Alarm System Agreement attached to PlaintiWs Complaint as Exhibit "A."
33. Denied. It is denied that the product installed by Plaintiffwas shoddy, poor or
unworkman like as installed in Defendant's home. To the contrary, Plaintiffcomplied with all
the terms of the Alarm System Agreement attached to PlaintiWs Complaint as Exhibit "A."
Plaintiffis without knowledge or information as to the alleged substantial additional monies that
Defendant has paid and, therefore, those averments are denied and strict proof thereof is
demanded at trial.
34. Denied. It is denied that Defendant notified Plaintiffon numerous, repeated
occasions that the system had been installed improperly and was not operating properly. To the
contrary, Plaintiff complied with all the terms of the Alarm System Agreement attached to
Plaintiff's Complaint as Exhibit "A.'
35. Denied. It is denied that Plaintiff's employees acknowledge that the system had
been installed incompletely and improperly. To the contrary, Plaintiff complied with all the
terms of the Alarm System Agreement attached to Plaintiff's Complaint as Exhibit "A."
4
36. Denied. It is denied that Plaintiff failed to correct numerous and significant
deficiencies in the system. To the contrary, Plaintiff complied with all the terms of the Alarm
System Agreement attached to Plaintiff's Complaint as Exhibit "A."
COUNT I
BREACH OF CONTRACT
37. Plaintiff Zeplin's Security Group, Inc. hereby incorporates by reference its
averments in paragraphs 1-15 and its responses to paragraphs 16 through 36 as if fully set forth
herein.
38. Denied. It is denied that Plaintiff failed to completely install the security system.
To the contrary, Plaintiff complied with all the terms of the Alarm System Agreement attached to
Plaintiff's Complaint as Exhibit "A." The remaining averments in paragraph 38 constitute legal
conclusions to which no answer is required. To the extent an answer is required, the remaining
averments contained in paragraph 38 are denied and strict proof thereof is demanded at trial.
39. Admitted in part and denied in part. It is admitted that Plaintiff accepted payment
from the Defendant for some of the work performed under the Alarm System Agreement
attached to Plaintiff's Complaint as Exhibit "A.' It is denied, however, that Plaintiff accepted
payment from the Defendant for the "majority" of the system or that the system failed to comply
with the terms of the agreement between Plaintiff and Defendant. To the contrary, Plaintiff
complied with all the terms of the Alarm System Agreement attached to Plaintiff's Complaint as
Exhibit "A."
40. Admitted in part and denied in part. It is admitted that Plaintiff accepted payment
from Defendant for some of the work performed. It is denied, however, that Plaintiff failed to
5
properly install the system. To the contrary, Plaintiffcomplied with all the terms of the Alarm
System Agreement attached to Plaintiff's Complaint as Exhibit "A."
41. Denied. It is denied that Plaintiffhas been overpaid by Defendant. To the
contrary, Defendant has failed to make payment pursuant to the terms of the Alarm System
Agreement attached to Plaintiff's Complaint as Exhibit A."
42. Denied. It is denied that the product installed by Plaintiffwas shoddy, poor or
unworkman like as installed in Defendant's home. To the contrary, Plaintiffcomplied with all
the terms of the Alarm System Agreement attached to Plaintiff's Complaint as Exhibit "A.'
Plaintiff is without knowledge or information as to the alleged substantial additional monies that
Defendant has paid and, therefore, those averments are denied and strict proof thereof is
demanded at trial.
WHEREFORE, Plaintiff, Zeplin Security Group, Inc., respectfully demands judgment in
its favor and against Defendant in the amount of $2,462.20 of liquidated damages and for
unliquidated damages including reasonable collection costs and attorney's fees as will be proved
at trial and any other relief that this Court deems just and appropriate.
COUNT II
NEGLIGENCE
43. Plaintiff Zeplin's Security Group, Inc. hereby incorporates by reference its
averments in paragraphs 1 through 15 and responses to paragraphs 16 through 42 as if fully set
forth herein.
44. The averments contained in paragraph 44 constitute legal conclusions to which no
answer is required. To the extent an answer is required, the averments contained in paragraph 44
are denied and strict proof thereof is demanded at trial.
45. The averments contained in paragraph 45 constitute legal conclusions to which no
answer is required. To the extent an answer is required, the averments contained in paragraph 45
are specifically denied and strict proof thereof is demanded at trial.
WHEREFORE, Plaintiff, Zeplin Security Group, Inc., respectfully demands judgment in
its favor and against Defendant in the amount of $2,462.20 of liquidated damages and for
unliquidated damages including reasonable collection costs and attorney's fees as will be proved
at trial and any other relief that this Court deems just and appropriate.
eROEESS O ¢O O TXON
4VIatthew C. Browndorf, Esquire I.D. #81915
One South Market Square
213 Market Street - 3rd Floor
Harrisburg, PA 17101
(717)237-4800
DATE: April 3, 2001
VERIFICATION
I, Fred Zeplin, verify that the statements made in the foregoing document, of which I
have first-hand knowledge, are true ~nd correct to th~ best of my knowledge, iz~ormation zud
belief. I understand that false statements herein a~e made subject to the penalties of 18 Pa. C,S,
§4904, relating to unswom falsific~tlon to authorities.
CERTIFICATE OF SERVICE
I, Matthew C. Browndorf, Esquire, certify that I have this date, served a copy of the
foregoing document upon the following counsel by United States mail, first class, postage
prepared:
Anthony J. Nestico, Esquire
Nestico & Dmby, LLP
840 East Chocolate Avenue
Hershey, PA 17033
DATE: April 3, 2001
ZEPLIN'S SECURITY GROUP, INC.,
Plaintiff
V.
THOMAS CRABTREE,
Defendant
: IN THE COURT OF COMMON PLEAS
:
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 01-898 Civil
TO: PROTHONOTARY
PRAECIPE
Please mark the above-captioned action, both claims and counter-claims, as settled,
discontinued and ended with prejudice.
DATE: [~ /~/~/
DATE:
BUCHANAN INGERSOLL
PROFESSIONAL CORPORATION
-4Xlatthew C. BrowffdorfTEsquire
I.D. #81915
One South Market Square
213 Market Street - 3rd Floor
Harrisburg, PA 17101
(717)237-4800
NESTIC~~/~ 7/
--Anthony J. N0~co, Esquire
840 East Choc61ate Avenue
Hershey, PA 17033