HomeMy WebLinkAbout10-5230IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FUEL CITY TRUCK STOP, INC.
Plaintiff Civil Action - ( X ) Law - ( ) Equity
versus /?
JOHN SAYED No. to -501W l,ivilTerm
t/d/b/a BAHEER CONSTRUCTION,LLC
4451 Motter Lane C, 1
Camp Hill, PA. 17011, `_-
Defendant
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue writ of summons in the above-caption C ?
? Writ of Summons shall be issued and forward rd2t)jtft ney ) Sheriff
Robert Radebach, Esquire
912 North River Road
Halifax, PA 17032
Supreme Court ID No. 19255
Date: August /0, 2010
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE
COMMENCED AN ACTION AGAINST Y U.
Prothonotary
Date: Oho
by
Deputy
( Check here if reverse is issued for additional information.
PROTHON. - 55
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
~i ltd.
Ronny R Anderson ~~~~~~~~(
Sheriff ~~,~~~~tn nt ~«~nbr~,~~~~ ~ ~, ~'`,i .. _.
Jody S Smith , ~ M ~ ~
Chief Deputy '~ ~ °'~ ~ ~ {~ ~ Q ~~ ~ 3
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Richard W Stewart ~ , ;,.:> ~~~ t ~~ t^,Q
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Solicitor ~F~~.Et. °~e.,~-~iFt: p~~ySYC.VAN~
Fuel City Truck Stop, Inc.
vs. Case Number
John Sayed 2010-5230
SHERIFF'S RETURN OF SERVICE
08/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: John Sayed, but was unable to locate him in his
bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant John Sayed.
Request for service at 4451 Molter Lane, Camp Hill, PA 17011 the defendant was not found. The Camp
Hill Postmaster has confirmed, John Sayed has moved and left no forwarding address.
SHERIFF COST: $46.94 SO ANSWERS, ,~7
August 26, 2010 RON R ANDERSON, SHERIFF
(c} CountySuite Sheriff. Teleosoft. Inc.
OF THELPROTHONTARY
Z I 0 AN 28 PM 3- v !
CU,"ISERLAND COUNT v,
oili-i
: Civil Term
NOTICE TO DEFEND
20
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 AN ATTORNEY AND FILLING 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 JUDGEMENT 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 PEOPERTY
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 THE TELEPHONE OR THE OFFICE
SET FORTH BELOW TO FIND WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
FUEL CITY TRUCK STOP, INC.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JOHN SAYED,t/d/b/a BAHEER CONSTRUCTION, LLC : NO 10-5230-CIVIL
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FUEL CITY TRUCK STOP, INC.
Plaintiff .
V.
CIVIL ACTION - LAW
JOHN SAYED t/d/b/a
BAHEER CONSTRUCTION, LLC
Defendant
NO. 10-5230 - CIVIL TERM
COMPLAINT
1. Plaintiff, Fuel City Truck Stop, Inc., is a Pennsylvania corporation with its principal
place of business at Routes 11 & 15 South, Liverpool, Perry County, Pennsylvania 17045.
2. Defendant, John Sayed, is an adult individual trading and doing business as Baheer
Construction, LLC ("Sayed"), with a contact address at 4451. Motter Lane, Camp Hill, PA
17011.
3. On or about September 14, 2009, Plaintiff and Defendant contracted for the
performance of numerous remodeling jobs to Plaintiff's building located at 611 North Enola
Road, Enola, Cumberland County, Pennsylvania involving a variety of construction-related work
including but not limited to the removal of certain improvements, furnishing and installation of a
window frame wall and concrete slabs to support a commercial cooler, installation of steel
beams, repair of flooring and plaster ceiling, installation of insulation, chimney repairs, lighting
and electrical upgrades, door frames and bullet-resistant glass doors, heating and air
conditioning, roofing and other related renovations in accordance with contract specifications
and engineered prepared site plans.
4. Plaintiff paid Defendant Sayed the sum of One Hundred Thirty-Five Thousand and
00/100 Dollars ($135,000.00).
5. Defendant Sayed never completed the work nor returned Plaintiff's payment made to
him.
6. On or about October 20, 2009, Plaintiff and Defendant Sayed contracted for the
installation of a new indoor expandable longdoor walk-in 8 display cooler for a total price of
Twenty-Four Thousand Four Hundred Sixty-Two and 00/100 Dollars ($24,462.00), a self-
service island for a price of Fifteen Thousand Two Hundred Eighty-Five and 00/100 Dollars
($15,285.00) and a shelving unit for a price of Eight Thousand and 00/100 Dollars ($8,000.00) as
evidenced by a certain Agreement attached hereto as Exhibit ".A" which is hereby made a part
hereof.
7. Defendant Sayed never delivered the equipment nor returned Plaintiff's payment
made to him.
8. Of the work performed by Defendant Sayed, the majority was performed in a less than
workmanlike manner and will need repaired, completed, or redone.
9. Defendant agreed to perform the improvements and repairs and install the equipment
and shelving by December 25, 2009.
10. Defendant failed to perform the work in a workmanlike manner and failed to deliver
and install the equipment prior to December 25, 2009.
11. As a result of Defendant's actions, Plaintiff was unable to open the convenience store
on the date specified.
12. On May 12, 2010, Plaintiff, through legal counsel, John T. Robinson, forwarded a
Notice to Defendant indicating that Defendant was in a breach of contract, ordered Defendant off
the jobsite, and demanded the following:
" 1. return all items purchased with my clients' funds which are not on site;
2. provide to my clients a written accounting of all funds paid to you and materials and
services claimed to have been purchased or expended by you;
I provide my client with all drawings, plans, sketches, permits or other documents in
your possession - either in kind or in digital form - regarding this project; and
4. immediately return to my clients all funds they have paid you for materials which
have not yet been purchased or for labor not yet performed. "
13. Defendant has failed to respond to Plaintiff's demand.
14. As a result of Defendant's breach of contract and negligent performance, Plaintiff
was required to repair the damage caused by Defendant, replace the defective construction, and
purchase replacement parts.
15. At all times material to this action, Plaintiff relied upon the knowledge and expertise
of the Defendant in construction, repair, renovation, and purchase of the contracted goods.
COUNTI
BREACH OF CONTRACT
16. Averments 1 through 15 are incorporated herein by reference as if the same were set
forth in their entirety.
17. The Defendant herein failed to fulfill his contractual obligation by failing to
complete the renovation job in a workmanlike manner according to standard practices.
18. The Defendant failed to properly perform the repairs and improvements to the
property by failing to perform the jobs contracted in a workmanlike manner according to
standard practices and procedures readily used in the performance of such standard
improvements.
WHEREFORE, Plaintiff respectfully requests the Court to enter an Order for judgment in
favor of Plaintiff and against Defendant for breach of contract.
COUNT II
NEGLIGENCE
19. Averments 1 through 18 are incorporated herein by reference as if the same were set
forth in their entirety.
20. The hazardous, unusable and non-commercial conditions left at the building owned
by Plaintiff were directly and proximately caused by the negligence and carelessness of
Defendant Sayed which consisted, among other things, of the following:
a. Performing renovations without care, regard or respect for common standards
of workmanlike conduct;
b. Performing renovation work without due regard to the rights, safety, and
position of the Plaintiff and/or Plaintiff's invitees;
c. Failing to use due care under the circumstances.
d. Failing to complete the work as promised.
21. At all times material hereto, Plaintiff acted with due care and was not contibutorily
negligent.
22. As a result of the Defendant's negligence, Plaintiff is forced to obtain different
subcontractors to rectify all facets of the renovations of the property in order to make it
appropriately safe for Plaintiff's invitees and to open the business to the public.
COUNT III
CONVERSION
23. Averments 1 through 22 are incorporated herein by reference as if the same were set
forth in their entirety.
24. Plaintiff owned and had the right to possess the personal property purchased with the
funds from his account and prior to work having been started by Defendant Sayed.
25. Defendant Sayed intentionally interfered with the Plaintiff's personal property by
absconding with the funds delivered to Defendant Sayed or the equipment and merchandise
purchased with Plaintiff's funds.
26. The Defendant's interference deprived the Plaintiff of possession or use of the
personal property in question.
27. Such interference and deprivation has caused damages to the Plaintiff.
COUNT IV
DAMAGES
28. Averments 1 through 27 are incorporated herein by reference as if the same had been
set forth in their entirety.
29. As a result of the Defendant's breach of contract, negligence and conversion,
Plaintiff has incurred damages for loss of income in its convenience store when it delayed
opening and was forced to hire workers to repair the deficiencies in the work performed by
Defendant Sayed and forced to purchase replacement equipment, merchandise and shelving.
30. As a result of the Defendant's breach of contract, negligence and conversion,
Plaintiff has incurred damages according to the following:
a. Value of items belonging to Plaintiff removed by Defendant Sayed. $20,000.00
b. Total amount to finish renovations per attached Exhibit "B". $31,154.00
c. Cooler, self-service island, and shelving unit per attached
Exhibit "C". $47,747.00
d. Loss of income. $65,850.00
e. Purchase of replacement equipment and merchandise including
defective HVAC system $10,568.33
TOTAL $175,319.33
WHEREFORE, Plaintiff respectfully requests the Co enter ju nt in favor of
Plaintiff and against Defendant in the amount of $1 ,319.3 , plu intere ;and reasonable
attorneys fees. /,
A/
Robert G. IXadebach, Esquire
912 North River Road
Halifax, PA 17032
(717) 896-2666
Supreme Court ID No. 19255
Ralph A. &ermak, Esquir
Box 249
McAlisterville, PA 17049
(717) 463-3686
Supreme Court ID No. 19593
Attorneys for Plaintiff
Dated: January _, 2011
VERIFICATION
I understand that false statements made in the foregoing Complaint will subject me to
penalties for perjury. I declare under penalty of perjury that the information contained in the
foregoing Complaint is true and correct to the best of my knowledge, information and belief.
FUEL CITY TRUCK STOP, INC.
BY:
Exhibit "A"
BAHE'ER CONSTRUCTION LLC
Description: Monday September 14, 2009
Shamser:.Sing and Jasbir Nagra, owners
Fuel city truck stop, INC
P.O. Box 263 LIVERPOOL, PA 17045 .
Telephone: (570) - 768-2422
Specifications:
Any upgrades, not addressed here, required meeting inspector requirements or for completion of
project would be extra charge.
Site Preparation:
Supply dumpster
Clean out all trash exiting home
I . Indicates segmental retaining wall. Contractor shall verify and coordinate grades as
shown on site plan drawing prepared by Thomas H. Metz Engineering, Inc. Retaining
wall shall be as manufactured by Allan Block Retaining Wall System. (952-83 5-53 09)
2. Remove existing construction shown dashed. Repair all disturbed areas to match existing.
3. Remove existing masonry wall. (salvage all brick for reuse) See Section 2, furnish all
material and, install new window frame wall, maintain all existing trim profiles. Provide
new concrete slabs as indicated taaiupport cooler. Verify all conditions with cooler
installer and opener: Repair`all disturbed areas.
4. Remove portion of existing masonry wall, (salvage all brick for reuse) Provide shoring
and supports as required. Furnish and install steel beams as indicated on the drawings.
Provide new cor}crete slab to support,cooler. Verify all conditions with cooler and
installer owner.lepaW all disturbed areas.
5. Repair and.level existing floor to receive finish floor material.
6. Repair and seal existing plaster ceiling in its entirety. Install insulation above existing
ceiling to bring the total insulation to R-38 value.
7. Remove existing chimney to below existing floor. Repair all disturbed areas.
8. Remove existing ceiling access papel. Provide new ceiling access panel (20"X30"min.)
in room 109. Verify location with; respect to mech. Equip. ductwork and light fixtures.
Repair all disturbed areas.
9. Remove existing masonry wall to below new counter height. Repair all disturbed areas
including ceiling and floor.
10. Remove existing wndow glass and frame. Close up opening as indicated on drawings..,
Repair all disturbed 'areas,
11. Remove existing door and frame, close up opening as indicated on drawings. Repair all
disturbed areas.
12. Remove existing glass and frame, install new frame (60" high) with bullet resistant glass
and new money drawer. (verify all conditions with owner) Installation of drawer shall
meet ICC/ANSI Al 17.1-2003. Repair all disturbed areas.
13. Remove existing overhead door and frame; install new album, and glass entrance door
with sidelights, close balance of opening as indicated. Repair all disturbed areas.
14. Remove existing overhead door and frame, remove existing pass door and frame. Install
new alum window frame with 1" insulated "B" glass. (frame 60" high) Close balance of
opening as indicated on drawings: '
15. The contractor and owner shall contact the East Pennsboro Township Health offices;
Karen Dunkle (717)-909-5612 to discuss all food sales, equipment utilized for food
preparation, storage and sanitation fixtures.
16. The contractor shall contact the fire code official, James Bumgardner (717)-732-0711 to
discuss the location of the required "Knox" box.
17. Fire extinguisher shall be 10# 2-A mounted at 42" to the top of handle Provide any
additional extinguishers as may be required by the local five code official.
Electric:
Complete rough wiring receptacles and ceiling lights
Framing.
Complete framing for the interior
Doors & windows: Window Schedule
Tag Manufacturer Type Size Vent Screen Glazing Remarks
W-1 Kawneer 450 As - NO NO 1" insul, Color as
listed low "E" selected
W-2 Kawneer 450 As - NO NO I", Low Color as
listed "E" Selected
W-3 Kawneer 450 As NO NO Bullet Color as
listed resistant Selected
-- I
I lass
W-4 Kawneer 1 410 As NO
-] NO 1" insul, Color as
listed Low "E" Selected
Door Schedule
Tag Size Material Type Kind Frame Hardware Remarks
D-1
Pr. 3-
Alum. &
1
Swing
Alum.
Set B -
1" insulated
0x7- GI. GI., Low
Ox I 3/4 "E" (Not an
active door
D-2 3-0x7- Alum. & 1 Swing Alum. Set A l" insulated
0x1 3/4 GI. - GI., Low
«E„
D-3 Pr. 3- Hol. Met'l. 1 Swing Alum. Set C '/. plate GI.,
0x7- Tempered as
0x1 3/4 re 'd
D-4 3-ox6- Hol. Met'1 2 Swing Hol. Set E "C" label
8x1 3/4 Met'l assembly
D-S 3-ox6- Hol. Met'l 3 Swing Hol. Set F 24"X18"
8x1 3/4 Met'1 Fusible link
Drywall fire damper
"C" Label
D-6 3-ox6- Hol. Met'l 3 Swing Hol: Set F 24"X18"
8x1 3/4 Met'1 Fusible link
Drywall fire damper
"C" Label
D-7 3-ox6- Hol. Met'1 3 Swing Hol. Set E 24"X18"
8x1 3/4 Met'1 Fusible link
fire damper
"C" Label
D-8 3-ox6- Hot. Met'1 3 Swing Hol. Set E "C" label
8x 13/4 Met'1 assembly
Drywall
D-9 3-ox6- Hol. Met'l 2 Swing Hol. Set E
8x13/4 Met'1
Drywall
D-10 3-ox6- Hol. Met'l 2 Swing Hol. Set D Insulated
8xl 3/4 Met'1 door and
frame
Flooring.
1. Make a leveled floor and put the concrete 3 inch on the whole floor 18,000 sq. ft.
2. Install ceramic tiles (13x13 ceramics) as per store layout
Sidewalk:
Make a concrete sidewalk (mix 3,000)
Drywall:
All walls will be drywall
Walking Cooler:
Install brand new 8 door walking cooler from Bush Refrigeration and 19x8 outdoor
Counter Tops:
New cabinet with counter tops for soda area, condominiums, sweets, coffee, cappuccino and
cash register (All counter tops are granite)
Ceilin :
Complete new drop ceiling (2x4, American Arms ceiling tiles)
Plumbing:
Complete plumbing for water supplies, coffee makers, soda machine, box fridge, and drainage
for box fridge.
Paint:
Complete inside paint.
Concrete:
Make a concrete slab for the walk in cooler.
HVAC:
1. Install a 90+80,000 Btu (ADP electric heat pump)
2. Deck work for 10 vents, 12x12 and one return 18x32 and one vent for bathroom and one
for office
3. Outside Air Louver, rainproof and screen (340 cfm)
4. 12"x 6" V sidewall with volume damper (30 cfm)
5. 12"x 6" V sidewall with volume and fire damper (60 cfm)
6. 12"x 8" V sidewall with plume and fire damper (100 cfin)
7. Indicates required fire damper
8. 24"x24" step down lay in grid diffuser with 5" neck and volume damper (70 cfm)
9. 24"x24 step down lay in grid diffuser with 8" neck and volume damper (163 cfm)
10.20" w x 28"h return air grille with fire damper accessible thru grille (1780 cfm)
11. Modulating return air damper (1780 cfm)
12. Modulating outdoor air damper, low leak (340 cfm)
13. Nat. gas furnace, Frigidaire FG 75C 120, 120,000 btu,, 2000 cfm with C68BAX60CD
coil, 60000 btu.
14. A/C outdoor unit F54BDG 60,000 btu
15. C02 sensor, Honeywell C7232A1.008. or.approved alternate. Shall control demand control
ventilation (DCV). '
16. Filter Rack
Roofing:
1. Remove existing chimney to below first floor. Repair all disturbed areas to match
existing.
2. Remove existing gable sltown dashed.
3. Install new gable roof 2x6 WD. Framing at 16"o, c. with 5/8" plyw'd, sheathing, match
existing trim and profile.
4. Vert. vinyl siding, color, and profile as selected.
5. Repair and replace existing rain water gutter/ conduction system; maintain existing, storm
water system. Verify all condition in field.
Note: Install matching brick for front area and side area to close the bathroom doors and
windows.
Total Labor and Material (Package Deal) $135,000
Invoice: Half of the total amount is due upon signing of this service agreement and when half the job is finished the
next 25% is due and before the job Is done, 15%o is due and the final inspection 10% is due when the job is finished.
Canceling fees: Contractor and client will mutually agree on a date for commencing and finishing the project. If
client cancels any of the above without a good reason after the signing of agreement, the client will be billed a fee of
$1,000. Any upgrades, not addressed here, required meeting inspector requirements or for completion of project
would be extra charge.
Con ed
Q?70
Client:
Fuel City Truck Stop
611 N Enola RD `
Enola Pa, 17025
To Whom It May Concern:
The project for renovating the Sunoco Store in Enola, PA is scheduled to begin on
October 12, 2009. The estimated completion date is expected on or prior to
December 25, 2009. Both the builder and the owner have agreed on these dates and
will begin the preparation for this project in the near future
Date ld
President (Fuel City Truck Stop)
Jasbir K. Nagra
Date /d
"ter
Builder (Baheer Construction)
John Sayed
Exhibit "B"
Fuel City Truck Stop Inc.
Enola Sunoco .
611 North Enola Road
Enola Pa, 17025,1!'.
To whom it may concern:
The following lists all incomplete work that remained subsequent to the
extermination of. BaheeiConstruction's contract. (Post May 7 2010)
The Storage Room
Finish hanging missing pieces of,drywall. Tape and mud drywall and prep.
Entire room. Install waterline for ice machine. Install icemaker. No cove base in
storage room. t
Men's Bathroom
Install toilet paper holderAnstall mirror supplied by property owner. Install
baby-changing station.
Women's Bathroom
Install toilet paper holder. Install mirror supplied by property owner. Install
baby-changing station.
.rtt4.
Office . ?' }. ...
... T as V?s3/.Ll fir. A,:'4i1?-i?1?,1??•?.?,S:t6T ??i; 'i: `. {, t.i .. ?:.
.i
Insulatiall walls.to'pas"s.inspection: Hangdrywall and all walls. Tap, mud,
and prep. Paint entire room. Install drop'ceiling, new cove base. Install steel door
and frame.
Storage Closet
Finish hanging drywall. Tape, mud, and prepare for painting. Paint drywall
and hang steel door Install transition strip. Change entire light box to manual shut
offs.
Main Convenient for
Finish trim around freezer doors. Silicone cracks on fridge door. Cove the
entire store. Install five 110=watt outlets` throughout the store, along with installing
all machinery and appliances.. Install two bar lights above main island countertop.
if
Finish installing cabinet-island and countertop. Build column at countertop. Install
weather stripping at rear exit door. Install door sweep at rear exit door.
1
Exterior of Building
Finish and recoat stucco all over building. Install one-inch drain line that is
five feet long. Install flashing around complete freezer exterior. Install gable vent on
freezer side of building. Fix all windows inside and out. Apply new trim and
caulking. Paint eight inches by thirty feet of soffit. Install four lights in soffit. Install
porch soffit, five feet by fifteen feet by thirty feet of soffit. Install new lights in
breezeway. Brick work around money dispenser. Install new gutter and drainage
around whole building. Hang Sunoco sign. Install new floodlights in front and rear of
building.
Note: The above mentioned is a mandatory task that needs to be completed
in order to receive the Certificate of Occupancy from the township.
Total Investment: $31,154.00
Ventilation System
Baheer Construction installed incorrect cooling system - one that is too small
to meet the demands of the building. Replace old system with a bigger unit.
This will cost an additional $10,568.33. This figure came directly from a quote given
by local service mechanic.
Exhibit "C"
6LLC
4451 Motter Lane Camp Hill, PA 17011
E-mail: Dodamast@,Yahoo.com' ; Phone: (717)-379-8711
October 20, 2009
Client: Sham Sher,Singh ,
1
Address: 611 North Enola, Sunoco gas station
Phone: 570-768-2422
Install a new Indoor Expandable lonadoor Walk-In 8 Display Cooler
EQUIPMENT (1)Indoor,Expandable LoOgdoor Walk-in 8 Display Cooler/Fioorless
*Overall Dimensions: 22'4"x8x8" high
(7) Anthony Model 401,2 pane warm edge ARGON GAS FILLED, REFLECTIVE, non
heated glass, BLACK heated frame,LEFT hinged, display doors
Dimensions: $0 Y." x79:' high.. .
(10) LED LIGHTING SYSTEM
(7) 27":deep adjustabte.wire display shelves per door
(1) 3 horsepower, med-temp,'air-cooled, outdoor condensing unit, R-440a, with
sight glass;,drier pressu p control, crankcase heater, low ambient fan cycling
control;`def44rost timer, PSC MOTOR and weather hood
(2),Mahing evaporator coils with expansion
I valves, solenoid valve, EC MOTORS,
tt ...... Y.f. ...... ..
and therm ostat'
(1) Anthony Model 403, Heated Frame, Non Heated Glass, Black, Left Hinged, all
glass personel entry door with a 5 tier roll away beverage cart
Dimensions: 36" x81" high
R VALUE 29/ 3.5" CFC. FREE ENCAPSULATED URETHANE INSULATION
l NEVER LOSES R-VALUE
A 3" clearance is required between the panels and walls in the building for air circulation.
Exterior Finish: Galvanized Steel
Interior Finish: Galvanized Steel
ELECTRIC: This consists of a 40 amp, 208/230v. A.C., THREE phase disconnect box located
within 5 feet of compressor location with 8 feet of wire for compressor hook-up,
and a 15 amp, 115v. A.C. electric line with a safety switch and sufficient wire to
reach the top center of cooler for evaporator coil hook-up. Customer's -
electrician must also run 15 amp, 115v. A.C., grounded, branch circuit inside
cooler to power display lighting and door frame heaters. It is also necessary to
run a control wire between the evaporator coil and the condensing unit.
DRAINAGE: We are responsible for all drainage hook-up.
Total Price: $24,462
Self-Service Island Merchandiser with 1 Shelf and Choice of Temperature
• Choice of 4', 5' or 6' depths
• Painted metal exterior and interior
• Stainless steel trim
• Curved bubble dieboard Plexiglas
• One row cart bumper
• 1 row, fixed, flat painted metals, 9" shelf on 4' models
• 1 row, fixed, flat painted metals, 12" shelf on *S"and 6' models
• Stainless steel shelves on hot sections
• Plexiglas product-stop on.shelves
• Undershelf lighting
• Canopy lighting
• Solar digital thermometer
• Conforms to UL standard 471, NSF
H?Shelvtng black
andy
X
3 Gondolas of shelving 54"x3o" dual;sided, ith 13" base decks and 12" upper shelves..
6 double back end caps'54"x ''. with 16" base and 14" upper shelves.
1 9 foot run wall shelving"48"x19".with 16" decks and 14" shelves
72 DSF 12x48 shelves, 2414x3O'shelves^9,14060"",shelves.
Total Pricle.00
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FUEL CITY TRUCK STOP, INC
Plaintiff
versus
JOHN SAYED
t/d/b/a BAHEER CONSTRUCTION, LLC
4451 Molter Lane
Camp Hill, PA. 17011,
Defendant
:Civil Action - ( X ) Law - ( ) Equity
No. 10-5230-CIVIL
CERTIFICATE OF SERVICE
AND NOW, January 28, 20111, Robert G. Radebach, Esquire, Attorney for Plaintiff
hereby certify that I served a copy of the Complaint in the above-captioned matter upon
John Sayed, Defendant, on January 28, 2011, by depositing the same in the United States
Mail, postage prepaid, in the post office at Harrisburg, Pennsylvania, addressed as follows:
JOHN SAYED
t/d/b/a BAHEER CONST CTIl N,L
4451 Motter Lane
Camp Hill, PA. 17011
Robert G. Radebach,
912 North River Road
Halifax, PA 17032
(717) 896-2666
I.D.# 19255
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U. S. POSTAL SERVICE CERTIFICATE OF MAILING Affix fee here in stamps 71 " 4 E `C
j MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT or meter postage and
I PROVIDE FOR INSURANCE-POSTMASTER. post mark. Inquire of ?Postmaster for currP*+t
I Received From:
ROBERT G. RADEBACH, ESQUIRE
912 North River Road, Halifax, PA 17032
One piece of ordinary mail addressed to:
JOHN SAYED
7dlb/a BAHEER CONSTRUCTION,LLC t6
4451 Molter Lane y
Camp Hill, PA. 17011
1 PS Form 3817, Mar. 1989
U' j?
I
Robert Radebach, Esquire
912 North River Road
Halifax, PA 17032
717-896-2666
robradebachatty@aol.com
Attorney for Plaintiff
OF THE p ? ? p?(j"'"E.
??1 f APR 28 PM 12:
CUMBERLAND CU?J is
r ENNSYLV/aflA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
FUEL CITY TRUCK STOP, INC.
Plaintiff
Civil Action - Law
V.
JOHN SAYED t/d/b/a
BAHEER CONSTRUCTION, L.L.C.,
Defendant
No. 10-5230-CIVIL
CERTIFICATE OF SERVICE
AND NOW, April 27, 2011, I, Robert G. Radebach, Esquire, Attorney for Plaintiff
hereby certify that I served a copy of the Reinstated Complaint in the above-captioned
matter upon John Sayed, Defendant, on April 21, 2011, by depositing the same in the
United States Mail, postage prepaid, in the post office at Halifax, Pennsylvania,
addressed as follows, with proofs of mailing attached hereto, which are hereby made a
part hereof:
John Sayed John Sayed
4451 Motter Lane Apt. 1
Camp Hill, PA 17011 480 Oliv reet
North onaw nda, N 0-6967
;
Rdbert G. Radebach,
912 North River Road
Halifax, PA 17032
(717) 896-2666
I.D.# 19255
Attorney for Plaintiff
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2313 OCT 21 IMII: 55
CUMBERLAND COUNTY
PENNSYLVANIA
FUEL CITY TRUCK STOP, INC., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 10-5230-CIVIL
JOHN SAYED t/d/b/a : CIVIL ACTION - LAW
BAHEER CONSTRUCTION, L.L.C.,
Defendant
PRAECIPE FOR SUBSTITUTION OF COUNSEL
TO THE PROTHONOTARY:
WITHDRAWAL OF ' OUNS
Please withdraw the appearance of Robert . Rad:each squirr, as counsel for the
Plaintiff, Fuel City Truck Stop, Inc. in the above capt'one. .ction.
R sp-ctf• ly su• itted,
By: ��
4r, Radebach, Esquire
:up. 't. .D. No. 19255
Date:s2 4 cJo 13 91 No h River Road
Halifax, PA 17032
(717) 896-2666
WITHDRAWAL OF COUNSEL
Please withdraw the appearance of Ralph A. Germak, Esquire as counsel for the Plaintiff,
Fuel City Truck Stop, Inc. in the above-captioned action.
'es.-ctfully submitted 4101P
4
By: , 1`-
Ralph A. &•rmak, Esquire
Sup. Ct. I.D. No. 19593
Date: 10-10— 1 3 304 Westfall Street
P.O. Box 249
McAlisterville, PA 17049
ENTRY OF APPEARANCE
Please enter the appearance of Ronald L. Finck, Esquire and the law firm of Mette, Evans
& Woodside. Papers may be served on the Plaintiff at the address below.
Respectfully submitted,
METTE, EVANS & WOODSIDE
By: RAAAL/c 4 #,..1...
Ronald L. Finck, Esquire
Sup. Ct. I.D. 89985
3401 North Front Street
Harrisburg, PA 17110
(717)232-5000
Attorneys for Plaintiff
Fuel City Truck Stop, Inc.
Date: to/ts-f l3
CERTIFICATE OF SERVICE
I certify that I am this day serving a copy of the foregoing document upon the person(s)
and in the manner indicated below, which service satisfies the requirements of the Pennsylvania
Rules of Civil Procedure, by depositing a copy of same in the United States Mail at Harrisburg,
Pennsylvania, with first-class postage, prepaid, as follows:
John Sayed John Sayed
4451 Motter Lane Apt. 1
Camp Hill, PA 17011 480 Oliver Street
Pro Se Defendant North Tonawanda,NY 14120-6967
Pro Se Defendant
Robert G. Radebach, Esquire Ralph A. Germak, Esquire
912 North River Road 304 Westfall Street
Halifax, PA 17032 P.O. Box 249
McAlisterville, PA 17049
Respectfully submitted,
METTE, EVANS & WOODSIDE
By: /1 -C- �_ #AA:a-
Ronald L. Finck, Esquire
Sup. Ct. I.D. No. 89985
3401 North Front Street
Harrisburg, PA 17110
(717)232-5000
Attorneys for Plaintiff,
Fuel City Truck Stop, Inc.
Date: 10/1,%1 0
669838v1