HomeMy WebLinkAbout01-0978COM/~O'NW~ALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
DISTRICT JUSTICE JUDGMENT
NOTICE OF APPEAL
-/-m/
This block will be signed ONLY when this nototiofl is required under Po, R.{~J~'."Nd~ ~f al:)l:)ellant was CLAIMANT (see Pa. R.C.P,J.P. No.
1008&
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this cass
Signature of Prothonotary or Deputy
1 O01 (6) in action before District Justice, he MUST
FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
('This section of form to be used ONLY when aPl~ellant was DEFENDANT (see Pa. R.C, RJ.I~ No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Pmthenotary
Nsme of apl~ellee($) · · , appdlee(s), to file a complaint in ~his appeal
(Common Pleas No (~ I ~ q ~ ~ ¢ r,, j ) within twenty (20) days a~t~ service of rule 9r suffer entr× of judgment of non peos.
RULE: To_'~-i-'-/"-+Y-.c/.~'UZ4/7'~.u/~/3~.~ /4/(--. ,c~,pellee(s). ' (' ~eofel~ell~nto~h~sa,omey~err~
(1) You am notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
service of this rule upon you by personal service or by certified or regis~red mail
{2) If you do not file a complaint within this time. a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule If service was by mail is the date of mailing.
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO F~LE COMPLAINT
(Th/s/;~oof~f/~o~viceMUST~3EF ~L'~ W/TH~N TEN IC, D,z~,*S AF/~-F ~ n~: *~ a~pe~ ~f~ c oi~ bo,~e~J
C 0 LtNtcY OF ..... : ~
AFFIDAVIT: i l~e~eby swea~ or aff~m treat t served
acopyof the Notice of Appeal, CommoI Pe~s N~) the l) st~ t
. i9 [}] by pe sona sexwce L} b? (certafied} (registered) mai serde~s eceipt attached hereto
SWORN (AFF~R~,~ }} ahab S~BS(;BB~ } B~:~ORE ME
7~S DA O 9
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF:_ C~3M~ER[~,.N'D
Mag. Dist. NO:
09-1-01
DJ Name: Hon,
CHARLES A. CLEMENT, J~.
A~d~ss: 1106 CAP'ISLE ROAD
CAMP HILL, PA
Telephone: (717) 761-4940 17011
NORTHERN CONSTRUCTION ASSOCIATES
6TH & WATEE ST.
ATTN: HANK WILLIAMs
NEW CUMBEKLAND, PA 17070
CIVIL CASE
~&T INSULATION COMPANY, INC.
4748
EAST HAKEISBDRG PIKE
~EW CUMBERLAND, PA 17070
VS.
DEFENDANT: NAME and ADDRESS
FNORTh~KN CONSTRUCTION ASSOCIATES
6TH & WAT~ ST.
ATTN: HANK WILLIAMS
~EW CUMBF/~.GAND, PA 17070
NOTICE OF JUDGMENT/TRANSCRIPT
IDocket No.: CV-0000675- 00 l ~
lDate Filed: 11/30/00
THIS IS TO NOTIFY YOU THAT:
Judgment: DEPAULT ,JU~]~,l~ PLTF
[~] Judgment was entered for: (Name) .~.~'P T~rFr,I~pTON OftMpl~r: TIU~,
~--~ Judgment was entered against: (Name) NO~,P~,f ~'I~.~'~Tt'~q~TC)'~T A.q~TACp.R.q
(Date of Judgment)
fDate & Time) _
$ 954.00
$ 74.50I
$ .0Dj
$- .0Dj
$ 1 028.50/
Amount of Judgment
Judgment Costs
Interest on Judgmem
Attorney Fees
Total
in the amount of $ _ 1: OgR_,[0 on:
~ Defendants are joinby and severally liable.
] Damages will De assessed on:
j--]This case dismissed without prejudice.
Amount of Judgment Subject to
J-]Attachment/Act 5 of 1996 $.
[] Levy is stayed for days or [] generally stayed.
~--'] Objection to levy has been filed and heanng will be held:
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total ;'~==========l
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OE-.~UDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON P-~I~S, ClVI[ DIVISION. YOU
MUST INCLUDE A COPY OF TTS N~ OTiCE OF JUDGMENT/TRA_~NSCRjPT FORM W_~ iTH YOUR N(i?Si~E
1/23/2001 Date .
~ , rict Ju
I certify that this is a true and correct copy of the record of the proceedings contah~g the judgment. '-]
Date
· DiStrict JusticeI
My commission exo~res first Monday of January,
AOPC 315-99
2002
SEAL
NOTICE OF APPEAL
;OMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
FROM
DISTRICT JUSTICE JUDGMENT
C '*ON'LEAS .... ; ?
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and in the case mentioned below
LTl9 ~ "'~ '
Th~ ~ck will be ~g~ ONLY ~n this ~fi~ is required u~ J ~
1008~ 1001 (6) in acti~ bef~e Dis~ict J~tice, ~ MUST
This ~t~ of A~I, w~n ~ei~ by t~ District Jus~ce, wifl ~te es ~
~PEE~DEAS ~ t~ j~ ~ possessi~ in this cos~ FILE A COMPLAINT within twenty (20) da~ after
filing his NOTICE of A~EAL.
S~ of ~t~y ~ Deity
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section o! form to be us~d ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
w th n twenty (20)dws a.ft~ service of m~le,pr suffer ent~ of
(1) You ~ notir'~l that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) d~¥s ofter the dete of
~er¥ice of this rule upon you by per~r~l service or by cerfifed or registered mail.
(2) I~ yo~ do not file a comp~int within this time, o JUDC.~EN? OF NON PI~O5 WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mailing. /.?,~ ~//~ ,~
COURT FILE
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FiLE COMPLAINT
AFFIDAVIT,': ~ereby swea~ or afrn tha~ t served
~acopyo t e :~oticeof Appeat, Co~}mo~ PJea No,~~:-~ pot the
L.2 by persona~ service~by ~cert~fied) (registered) ~rde~ :eceipt attached hereto
~<~:d ",,rthe theft i served the Rule to File a Cof~ la~ ~ ;con pany ng the above Notce
SWOR~ (AFF MED~AND SL~:SCR~E~ED ~EFORE ME
m
~ ce~lifled Fee I $~, ,~0 0070
~ 02120/2001
$1.90 007~
05
Total Po~tage & Fees $ $~.74 02120/2001
S & T Insulation Co.
VS
NORTHERN CONSTRUCTION
COMPANY
Ina,
:IN THE COURT OF CO~94ON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
~OTICE 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
2 Liberty Avenue
Carlsile, PA 17013
717-249-3166
S & T Insulation Co. Inc.
VS
NORTHERN CONSTRUCTION
COMPANY
: IN THE COURT OF CO~ON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
:
COMPLAINT
AND NOW, this 3r day of March 2001 comes S & T
Insulation Company, Inc., above-named plaintiff, by and through
its attorney, Gall Guida Souders, Esquire, and respectfully avers
the following:
Plaintiff is a corporation having offices at 4748
East Harrisburg Pike, Elizabethtown, PA 17022.
Defendant Northern Construction is a business
owned by Hank Williams and is located at 518
Bridge Street, New Cumberland, PA 17070.
At the specific instance and request of
Defendant, Plaintiff provided insulation services
to Defendant at the times, amounts, and the
prices for these services are indicated in
Plaintiff,s Invoice, a true and correct copy of
which is attached hereto, marked Exhibit A, and
made part thereof.
The prices charged by Plaintiff were fair,
reasonable, and market prices that prevailed at
the times of the transactions.
5. The prices charged by Plaintiff were the prices
that Defendant agreed to pay.
6. Plaintiff avers that the original bill was
$4295.00 and the Defendant did make a payment.
However, there is a remaining balance due in the
amount of $900.00, which is below the limit for
mandatory arbitration. Plaintiff's Invoice
indicating remaining balance, a true and correct
copy of which is attached hereto, marked Exhibit
B, and made part thereof
7. Although repeatedly requested to do so by
Plaintiff, Defendant has willfully failed and
refused to pay the aforesaid balance or any part
thereof to Plaintiff.
8. The interest at the legal rate of six percent a
year is $54.00 as of November 21, 2000.
WHEREFORE, Plaintiff respectfully requests that
judgment be entered in favor of Plaintiff and against Defendant
in the amount of $1028.50 with interest and costs.
Respectfully submitted,
Gail Guida Souders
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
717-236-6440
Identification 968740
Attorney for Plaintiff
T Insulation Co., Inc.
4748 E. Harrisburg Pik~
Elizabethtown, PA 17022
(717) 367-9088 (717) 944-0329
Toll Free (888) 383.WARM
Fax (717) 367-0638
NORTHERN CONSTR, ASSOC,
518 BRIDGE STREET
NEW CUMBERLAND PA 17070
WORK DESORIPTION
INVENTORY ITEM
NORTHN
3255 BA
JOB INFORMATION: LOT NO, 20
TWO AND A HALF STORY
REDWOOD HILLS
CARLISLE, PA
WRAP SOIL PIPES ..........
DORMER CEILING ...........
SLOPE CEILINGS ...........
8nd, FLR, CATHEDRAL CLG,.,
8nd, FLR, CLOSED CLG .....
2nd. FLOOR SLOPE CLG .....
1st, Flr, COLD CEILING,,,
GARAGE CLG,-UNDER LIVING
BAt. ANCE OF GARAGE CEILING
SLOPES OVER GARAGE .......
8' E¥1ERIOR SIDEWALLS ....
9' EXTERIOR SIDEWALLS ....
XRD FLR EXT END WALLS ....
PEN WALLS ...............
OPEN WALLS ...............
, DORMER WALLS .............
8nd FLOOR CATHEDRAL WALLS
2nd FLOOR CATHEDRAL WALLS
OPEN KNEEWALLS ...........
8ND FLR EXT END WALLS ....
1ST & 8ND FLR BATH WALLS,
GARAGE WALLS ............
GARAGE STAIRWELL ........
GARAGE TREADS ...........
FOUNDATION WALLS ........
FRONT OVERHANG ..........
OVERHANG ................
BLOCKERS & RUNNERS ......
BASEMENT STOPS ...........
AT EAVES,., ...............
GARAGECLG,-UNDER LIVING
BALANCE OF GARAGE CEILING
18' GARAGE WALLS .........
GARAGE STAIRWELL .........
GARAGE TREADS ............
OPEN WALLS ...............
R-II
R-38
R-30
R-38
R-30
R-38
R-30
R-19
R-30
R-13
R-t3
R-13
R-13
R-13
R-13
R-13
R-13
R-13
R-13
R-ii
R-13
R-I~
R-19
R-II
R-~O
R-30
R-13
FIBERGLASS
FIBERGLASS
FIBERGLASS
FIBERGLASS
FIBERGLASS
FIBERGLASS
KRAFT FACED BATTS
KRAFT FACED BATTS
KRAFT FACEDBATTS
KRAFT FACED BATTS
KRAFT FACED BATTS
KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
UNFACED FIBERGLASS BATTG
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTG
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTG
FIBERGLASG KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
FIBERGLAWS KRAFT FACED BATTS
FIBERGLAS~ K~A~'T FACED BATTS
FIBERGLAWS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATT8
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
FIBERGLASS KRAFT FACED BATTS
UNFACED FIBERGLASS BATTS
UNFACED FIBERGLASS BATTS
FIBERGLASS KRAFT FADED BATTG
R-13 FIBERGLASS KRAFT FACED BATTS
INSTALL PROPER VENTS AS NEEDED
R-30 UNFAOED FIBERGLASS BA~TS
R-19 FIBERGLASS KRAFT FACED BATTS
R-13 FIBERGLASS KRAFT FACED BATTS
R-13 FIBERGLASS KRAFT FACED BATTS
R-lO FIBERGLASS KRAFT FACED BATTS
va" x 4' x S' SUPER TUFF-R SHEATHING
CONTINUED ON NEXT PAGE
OFFIC.E /~
Elizabethtown, PA 17022 ·
(717) 367-9058 , (717) 944-0329
Toll Free (888) 383-WARM ~
Fax (717) 367-0638
NORTHERN CONSTR. ASSOC.
518 BR1DGE STREET
NEW CUMBERLAND PA 17070
· JOB INFORMATION: LOT NO. 20
TWO AND A HALF STORY
REDWOOD HILLS
C~RLISLE~ PA
INVENTORY ITEM
TOTAL INVOICE: .....
TOTAL DUE .... , ....
* OUR ]ERMS ARE NET 30 DAYS. A 8.0 % DISCOUNT OF $ ' 85.90 MAY BE
DEDUCTED IF PAID IN FULL WITHIN 10 DAYS OF THE INvoICE DATE,
4,295.00
4,895.00
WILL BE CHARGED ON ALL INVOICES OVER 31 DAYS,n ..... ~ -
OFFICE
S & T Insulation Co. Inc.
VS
NORTHERN CONSTRUCTION:
COMPANY
:IN THE COURT OF CO~94ON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
VERIFICATION
I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE
TRUE AND CORRECT. I UNDERSTAND THAT THE STATEMENTS HEREIN ARE
MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S.A. SECTION 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
Printed Na~e '-
Title'
Date
Insulation Co., Inc.
4748 I~, Harrt~urg Pike
Fu (717~ 367-~38
NORTHERN CON~T~.
N~W CUMBERLQND FA 17070
JOB INFORMRTIoN~ LOT NO.
TWO ~fiD'~ HRLF BTORy
RED~IOOD HILL8
~d
C. EI
WILL ~£ ~HAROED ON GiLL INVOICEB OVER ~1 DAY~.
OFFICE
S & T Insulation Co. Inc.
VS
NORTHERN CONSTRUCTION
COMPANY
:IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
No. 01-978
: CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I hereby certify that on March 7, 2001 I served the complaint in above-named
case upon the person and in the manner indicated below, which service satisfies the
requirements of Pa.R.Civ. P. 403:
Service by certified mail to:
Northern Construction
A~iTN: Hank Williams
$18 Bridge Street
New Cumberland, PA 17070
Gall Guida Souders
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
71%236--6440
Dated: Mach 9, 2001
· Complete items 1,2, and3 Al$ocomple~e
item 4 if Restricted Delive~ is desired,
· Print your name and address on the reverse
so that we can return thc card to you.
· At, ach this card to the back of the mallplece,
or on the front if space permits.
[~ Addressee
CyadCreSSdifferentlromttem i? [~ YeS
If YES, enter deltve~ address below: ~ NO
3, Service Type
{::) Certified Mail
[:~ Registered
ID COD
4, Restricted Deliver? (Extra Fee) [~ Yes
2, Article Number (Copy from service la,el)
PS Form 3811, July 1999
Domestic Return Receipt
102595.~0-M.0962
C~,~d ~ ~1.~
IX]It
i 03/07/200!