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HomeMy WebLinkAbout11-4807 n N SERVICE 1 ST RESTORATION AND REMODELING, LLC, Claimant V. MARTIN MENAPACE and TRACI L. MENAPACE, Owners IN THE COURT OF COMMON PIc OF CUMBERLAND COUNTY, .ti. PENNSYLVANIA; .,..Wj MECHANIC'S LIEN CLAIM Lit rn NO. / I- 0O MECHANIC'S LIEN CLAIM 0;71 'T c? { c) _"t i 7 -n AND NOW comes the Claimant, Service 1st Restoration and Remodeling, LLC ("Service First"), who, by and through its attorneys, Thomas A. Beckley, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Mechanic's Lien Claim, and, in support thereof, avers as follows: 1. Claimant, Service 1st Restoration and Remodeling, LLC, is a limited liability company organized and existing under the laws of the Commonwealth of Pennsylvania with a business address of 1441 Stoneridge Drive, Middletown, Pennsylvania 17057. Service 1st is filing this claim as a contractor under the Mechanic's Lien Law of 1963. 49 P. S. § 1101 et seq. 2. The owners of the Property subject to the lien, Martin Menapace and Traci L. Menapace, husband and wife, are adult individuals residing at 108 Harrison Drive, New Cumberland, Pennsylvania 17070. 3. The date on which Service l st completed the work for which this claim is being made was February 15, 2011. 4. Service 1st files this claim under a contract with Martin L. Menapace and Traci L. Menapace wherein Service 1st agreed to provide various restoration services to the Menapace's real property. A detailed description of the work Service 1st performed is set forth in the document which is attached hereto as Exhibit A. The amount claimed to be due is $47,926.70. od 0/1.66 4,0y eA?? i ?3s 5. The improvement and property claimed to be subject to the lien is the real property (including all improvements thereon) located at 108 Harrison Drive, New Cumberland, Pennsylvania 17070. A true and correct copy of the deed to the property subject to the lien is incorporated herein, made a part hereof, and attached hereto as Exhibit B. WHEREFORE, Claimant, Service 1St Restoration and Remodeling, LLC, claims to have a lien upon the premises herein described in the amount of $47,926.70, plus interest, costs of suit and such other and further relief as the Court may deem appropriate. DATED: June 3, 2011 Of Counsel BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717) 233-7691 Respectfully submitted, r Thomas A. Beckley,' quire Thomas S. Beckley, Esquire Attorneys for Claimant Service 1St Restoration and Remodeling, LLC 2 I# VNI V.JI / VAA ,?.?. :?fY ?1 t PAGE 04/04 1, ]*-.xe Novinger, hereby verify that I am an adult individual; that I am President of Service 1" Restoration and Remodeling, LLC; and that I am authorized to make this statement on its behalf, that Z have road the foregoing document, and that the facts set forth in the foregoing document are true to the best of my knowledge, or information and bclirf. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 41904 relating to unworn falsification to authorities. Service lat Restoration and Remodeling, LLIC By: J#dW Novinger6Presi?d 3 ?X???T Service 1st Restoration & Remodeling 1603 N Cameron St Harrisburg, Pa. 17103 717-232-5444 Tax ID#11-3712523 / PA035011 Mercantile License #25977-0 Client: Menapace, Martin Property: 108 Harrison Drive New Cumberland, PA 17070 Operator Info: Operator: PATRICK Estimator: Patrick Connors Business: Reference: Company: Type of Estimate: Date Entered: 1603 N. Cameron St. Harrisburg, PA 17103 American Securities Fire 10/4/2010 Price List: PAHA7X_SEP10 Restoration/Service/Remodel Estimate: 1689-MENAPACE-BILL File Number: 00100888051 Date Assigned: Cellular: (240) 464-5209 Business: (717) 232-5444 Business: (610) 404-7042 1689-MENAPACE-BILL Main Level ROOM : Foyer/Entry Subroom 0: Foyer/Entry 8.0 - Ceiling Height Subroom 2: CL 8.0 - Ceiling Height Subroom 1: STAIRS 16.3 - Ceiling Height Subroom 3: LANDING 7.3 - Ceiling Height Floor SF = 136.56 SF Walls SF = 417.92 SF Walls & Ceiling SF = 526.38 SF Perimeter of Ceiling = 65.50 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 526.38 SF @ 0.31 = 163.18 Clean door / window opening (per side) 4.00 EA @ 8.66 = 34.64 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Clean door hardware - Heavy 2.00 EA @ 6.23 = 12.46 Clean exterior door (per side) 2.00 EA @ 9.52 = 19.04 Clean window unit (per side) 3 - 9 SF - sidelite 2.00 EA @ 7.02 = 14.04 Clean baseboard 47.37 LF @ 0.23 = 10.90 Clean floor - tile - Heavy clean 75.79 SF @ 0.65 = 49.26 Clean closet shelf and rod per lineal foot 3.00 LF @ 0.74 = 2.22 Clean balustrade 5.00 LF @ 1.75 = 8.75 Clean stair stringer - per side 28.00 LF @ 0.59 = 16.52 Clean corner trim 28.00 LF @ 0.25 = 7.00 Clean baseboard heater - interior and exterior 4.00 LF @ 17.27 = 69.08 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Remove Carpet pad 36.00 SF @ 0.08 = 2.88 Remove Carpet 84.00 SF @ 0.19 = 15.96 Clean wood floor 10.00 SF @ 0.53 = 5.30 Deodorize building - Ozone treatment 1,092.51 CF @ 0.03 = 32.78 498.51 ROOM : Living Room Subroom 0: Living Room 8.0 - Ceiling Height Subroom 1: OFFSET 8.0 - Ceiling Height Floor SF = 243.44 SF Walls SF = 416.69 SF DESCRIPTION Walls & Ceiling SF = 660.13 SF Perimeter of Ceiling = 64.67 LF Clean the walls and ceiling - Heavy Clean door / window opening (per side) Clean window unit (per side) 10 - 20 SF 1689-MENAPACE-BILL 660.13 SF @ 3.00 EA @ 2.00 EA @ UNIT COST TOTAL 0.31 = 204.64 8.66 = 25.98 10.03 = 20.06 1/19/2011 Page:2 CONTINUED - Living Room Floor SF = 243.44 SF Walls SF = 416.69 SF Walls & Ceiling SF = 660.13 SF Perimeter of Ceiling = 64.67 SF DESCRIPTION NTY UNIT COST TOTAL Clean window unit (per side) 21 - 40 SF 1.00 EA @ 13.39 = 13.39 Clean drapery hardware 1.00 EA @ 11.23- 11.23 Clean baseboard 47.51 LF @ 0.23 = 10.93 Clean base shoe 47.51 LF @ 0.20 = 9.50 Clean wood floor 243.44 SF @ 0.53 = 129.02 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean baseboard heater - interior and exterior 8.00 LF @ 17.27 = 138.16 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Seal/prime the walls and ceiling - one coat 660.13 SF @ 0.40 = 264.05 Paint the walls and ceiling - two coats - 2 colors 660.13 SF @ 0.78 = 514.90 Paint door or window opening - 2 coats (per side) 3.00 EA @ 22.42 = 67.26 Paint baseboard - two coats 55.51 LF @ 1.04 = 57.73 Seal & paint base shoe or quarter round 55.51 LF @ 0.58 = 32.20 Deodorize building - Ozone treatment 1,947.56 CF @ 0.03 = 58.43 1638.47 ROOM : Dining Subroom 0: Dining 8.0 - Ceiling Height Floor SF = 139.19 SF Walls SF = 295.32 SF Walls & Ceiling SF = 434.51 SF Perimeter of Ceiling = 47.20 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 434.51 SF @ 0.31 = 134.70 Clean door / window opening (per side) 3.00 EA @ 8.66 = 25.98 Clean drapery hardware 1.00 EA @ 11.23 = 11.23 Clean chair rail 37.86 LF @ 0.23 = 8.71 Clean baseboard 29.86 LF @ 0.23 = 6.87 Clean base shoe 37.86 LF @ 0.20- 7.57 Clean wood floor 139.19 SF @ 0.53 = 73.77 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Plumber - per hour - cut and replace waste line in wall 4.00 HR @ 70.36 = 281.44 Clean baseboard heater - interior and exterior 6.00 LF @ 17.27 = 103.62 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Floor protection - plastic and tape - 10 mil 139.19 SF @ 0.22 = 30.62 Seal/prime the walls and ceiling - one coat 434.51 SF @ 0.40 = 173.80 Paint the ceiling - two coats - 2 colors 139.19 SF @ 0.78 = 108.57 Paint the walls - one coat 295.32 SF @ 0.43 = 126.99 Paint part of the walls - one coat 147.66 SF @ 0.43 = 63.49 Paint chair rail - two coats 37.86 LF @ 1.02 = 38.62 Paint baseboard - two coats 37.86 LF @ 1.04 = 39.37 1689-MENAPACE-BILL 1/19/2011 Page:3 CONTINUED - Dining Floor SF = 139.19 SF Walls SF = 295.32 SF Walls & Ceiling SF = 434.51 SF Perimeter of Ceiling = 47.20 SF DESCRIPTION QNTY UNIT COST TOTAL Seal & paint base shoe or quarter round 37.86 LF @ 0.58 = 21.96 Deodorize building - Ozone treatment 1,1 13.51 CF @ 0.03 = 33.41 1371.71 ROOM : Family Room Subroom 0: Family Room 8.0 - Ceiling Height Subroom 1: BAY 8.0 - Ceiling Height Floor SF = 403.87 SF Walls SF = 550.66 SF Walls & Ceiling SF = 954.52 SF Perimeter of Ceiling = 85.05 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 954.52 SF @ 0.31 = 295.90 Clean door / window opening (per side) 8.00 EA @ 8.66 = 69.28 Clean window unit (per side) 10 - 20 SF - Heavy 5.00 EA @ 14.10 = 70.50 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Clean exterior door (per side) 2.00 EA @ 9.52- 19.04 Clean door hardware - Heavy 2.00 EA @ 6.23 = 12.46 Clean patio door (sliding glass) (per side) 1.00 EA @ 26.39 = 26.39 Clean window stool & apron 15.00 LF @ 0.59 = 8.85 Clean drapery hardware 2.00 EA @ 11.23 = 22.46 Clean baseboard 42.67 LF @ 0.23 = 9.81 Clean floor - the - bay window floor 31.98 SF @ 0.49 = 15.67 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Remove Carpet pad 403.87 SF @ 0.08 = 32.31 Remove Carpet 403.87 SF @ 0.19 = 76.74 Clean baseboard heater - interior and exterior 16.00 LF @ 17.27 = 276.32 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Deodorize building - Ozone treatment 3,230.93 CF @ 0.03 = 96.93 1128.05 ROOM : Kitchen Subroom 0: Kitchen Subroom 3: OFFSETI Floor SF = 267.48 SF DESCRIPTION 8.0 - Ceiling Height 8.0 - Ceiling Height Walls SF = 542.13 SF Walls & Ceiling SF = 809.61 SF Perimeter of Ceiling = 83.97 LF UNIT COST TOTAL 1689-MENAPACE-BILL 1/19/2011 Page:4 CONTINUED - Kitchen Floor SF = 267.48 SF Walls SF = 542.13 SF Walls & Ceiling SF = 809.61 SF Perimeter of Ceiling = 83.97 SF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 809.61 SF @ 0.31 - 250.98 Clean door / window opening (per side) 3.00 EA @ 8.66 == 25.98 Clean exterior door (per side) 2.00 EA @ 9.52- 19.04 Clean baseboard 34.38 LF @ 0.23 = 7.91 Clean sink - double 1.00 EA @ 11.53 = 11.53 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean countertop 34.00 SF @ 0.49 = 16.66 Clean floor - tile - Heavy clean 258.48 SF @ 0.65 = 168.01 Deodorize building - Ozone treatment 2,139.83 CF @ 0.03 = 64.19 Clean baseboard heater - interior and exterior 6.00 LF @ 17.27 = 103.62 Clean thermostat 1.00 EA @ 8.50 = 8.50 Remove Hanging light fixture 1.00 EA @ 9.11 = 9.11 Remove Ceiling fan without light 1.00 EA @ 13.64 = 13.64 Remove Recessed light fixture 2.00 EA @ 8.06 = 16.12 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Plumber - per hour - cut and replace waste line in wall 4.00 HR @ 70.36 = 281.44 (Material Only) Vinyl window - double hung 2.00 EA @ 257.09 = 514.18 Remove Casing - 2 1/4" - windows 28.00 LF @ 0.36 = 10.08 Remove Window stool & apron 6.00 LF @ 0.54 = 3.24 Floor protection - plastic and tape - 10 mil 267.48 SF @ 0.22 = 58.85 Seal/prime part of the walls and ceiling - one coat 669.61 SF @ 0.40 = 267.84 Paint part of the walls and ceiling - two coats - 2 colors 669.61 SF @ 0.78 = 522.30 Detach & Reset Cabinetry - tower (base) units - CHARGES ARE FOR 20.00 LF @ 28.15 = 563 00 DETACH ONLY . Detach & Reset Cabinetry - upper (wall) units - CHARGES ARE FOR 19.25 LF @ 24.07 = 463 35 DETACH ONLY . Detach & Reset Cabinetry - full height unit - CHARGES ARE FOR 4.00 LF @ 28.02 = 112 08 DETACH ONLY . Cabinetry - per hour - additional time to save & move cabinets and 10.00 HR @ 62.23 = 622 30 detach top without damaging cabinets . Remove Cabinetry - full height unit - built in wall unit - in alcove with 3.00 LF @ 6.52 = 19 56 trim . Countertop - cultured marble - Detach & reset - CHARGES ARE FOR 34.00 SF @ 4.20 = 142 80 DETACH ONLY . Remove Countertop - Tile - High grade 20.00 SF @ 2.18 = 43.60 Detach & Reset Sink - double - CHARGES ARE FOR DETACH ONLY 1.00 EA @ 50.17 = 50.17 Detach & Reset Sink faucet - Kitchen - CHARGES ARE FOR 1.00 EA @ 37.65 = 37 65 DETACH ONLY . Remove Plumbing fixture supply line 2.00 EA @ 3.62 = 7.24 Remove P-trap assembly - ABS (plastic) 1.00 EA @ 5.43 = 5.43 Remove Dishwasher 1.00 EA @ 19.37 = 19.37 Remove Range - built in unit - hot wired direct - no plug 1.00 EA @ 14.57 = 14.57 Remove Microwave oven - over range w/built-in hood 1.00 EA @ 21.70 = 21.70 Remove Refrigerator - bottom freezer - 25 to 30 cf 1.00 EA @ 50.00 = 50.00 4564.10 1689-MENAPACE-BILL 1/19/2011 Page:5 ROOM : Powder Subroom 0: Powder 8.0 - Ceiling Height Floor SF = 16.32 SF Walls SF = 114.89 SF Walls & Ceiling SF = 131.21 SF Perimeter of Ceiling = 16.17 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 131.21 SF @ 0.31 = 40.68 Clean door / window opening (per side) 1.00 EA @ 8.66- 8.66 Clean door (per side) 2.00 EA @ 7.20-- 14.40 Clean toilet 1.00 EA @ 14.54 = 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink - pedestal 1.00 EA @ 16.46 = 16.46 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean medicine cabinet 1.00 EA @ 9.38 = 9.38 Clean baseboard 11.00 LF @ 0.23 = 2.53 Clean floor - the - Heavy clean 16.32 SF @ 0.65 = 10.61 Clean bath accessory 2.00 EA @ 4.75 = 9.50 Clean baseboard heater - interior and exterior 2.00 LF @ 17.27 = 34.54 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Deodorize building - Ozone treatment 130.56 CF @ 0.03 = 3.92 194.94 ROOM : Master Bedroom Subroom 0: Master Bedroom 8.0 - Ceiling Height Subroom 1: CLOSET 8.0 - Ceiling Height Subroom 2: VANITY-AREA 8.0 - Ceiling Height Floor SF = 242.86 SF Walls SF = 591.59 SF Walls & Ceili ng SF = 834.45 SF Perimeter of Ceiling = 95.77 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 834.45 SF @ 0.31 = 258.68 Clean door / window opening (per side) 7.00 EA @ 8.66 = 60.62 Clean window unit (per side) 10 - 20 SF - Heavy 3.00 EA @ 14.10 = 42.30 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Detach & Reset Interior door - Colonist - pre-hung unit - CHARGES 1.00 EA @ 34.00 = 34 00 ARE FOR DETACH ONLY . Detach & Reset Casing - 2 1/4" - CHARGES ARE FOR DETACH 34.00 LF @ 0.82 = 27 88 ONLY . Clean door hardware - Heavy 2.00 EA @ 6.23 = 12.46 Clean window stool & apron 15.00 LF @ 0.59 = 8.85 Clean drapery hardware 2.00 EA @ 11.23 = 22.46 Clean shelving - wood - closet linen 16.00 LF @ 0.61 = 9.76 Clean closet organizer and rod 6.00 EA @ 25.41 = 152.46 Clean baseboard 70.09 LF @ 0.23 = 16.12 Clean cabinetry - lower - inside and out 3.00 LF @ 8.09 = 24.27 1689-MENAPACE-BILL 1/19/2011 Page:6 CONTINUED - Master Bedroom Floor SF = 242.86 SF Walls SF = 591.59 SF Walls & Ceiling SF = 834.45 SF Perimeter of Ceiling = 95.77 SF DESCRIPTION NTY UNIT COST TOTAL Clean countertop 12.00 SF @ 0.49 = 5.88 Clean sink 1.00 EA @ 8.66 = 8.66 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean mirror 15.00 SF @ 0.49 = 7.35 Clean floor - the 33.97 SF @ 0.49 = 16.65 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean floor 242.86 SF @ 0.33 = 80.14 Clean baseboard heater - interior and exterior 8.00 LF @ 17.27 = 138.16 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Clean wood floor 242.86 SF @ 0.53 = 128.72 Deodorize building - Ozone treatment 1,942.85 CF @ 0.03 = 58.29 1215.56 ROOM : Shower Subroom 0: Shower 8.0 - Ceiling Height Floor SF = 41.85 SF Walls SF = 180.08 SF Walls & Ceiling SF = 221.93 SF Perimeter of Ceiling = 25.98 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 221.93 SF @ 0.31 = 68.80 Clean door / window opening (per side) 2.00 EA @ 8.66 = 17.32 Clean window unit (per side) 3 - 9 SF - sidelite 1.00 EA @ 7.02 = 7.02 Clean baseboard 14.32 LF @ 0.23 = 3.29 Detach & Reset Baseboard - 2 1/4" - CHARGES ARE FOR DETACH 14.32 LF @ 1.16 = 16 61 ONLY . Clean stud wall 10.00 SF @ 0.52 = 5.20 Seal stud wall for odor control 10.00 SF @ 0.62 = 6.20 Remove Batt insulation - 4" - RI 1 10.00 SF @ 0.25- 2.50 Detach & Reset Toilet - CHARGES ARE FOR DETACH ONLY 1.00 EA @ 76.50 = 76.50 Clean toilet 1.00 EA @ 14.54 = 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean shower curtain rod 1.00 EA @ 4.68 = 4.68 Clean medicine cabinet 1.00 EA @ 9.38 = 9.38 Clean bath accessory 3.00 EA @ 4.75 = 14.25 Remove Fiberglass shower unit - 3 piece unit 1.00 EA @ 54.27 = 54.27 Remove P-trap assembly - ABS (plastic) 1.00 EA @ 5.43 = 5.43 Clean floor - tile - Heavy clean 41.85 SF @ 0.65 = 27.20 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Deodorize building - Ozone treatment 334.79 CF @ 0.03 = 10.04 Clean stud wall 45.00 SF @ 0.52 = 23.40 Clean wall and floor sheathing 57.00 SF @ 0.19 = 10.83 1689-MENAPACE-BILL 1/19/2011 Page:7 CONTINUED - Shower Floor SF = 41.85 SF Walls SF = 180.08 SF Walls & Ceiling SF = 221.93 SF Perimeter of Ceiling = 25.98 SF DESCRIPTION NTY UNIT COST TOTAL Seal walls behind shower that was removed - spray cans will be used to 1.00 EA @ 180.00 180.00 get all structural items Remove Batt insulation - 4" - R 13 behind shower area 45.00 SF @ 0.25---- 11.25 583.47 ROOM : Hallway Subroom 0: Hallway Subroom 1: CLOSET 2nd Level 8.0 - Ceiling Height 8.0 - Ceiling Height Floor SF = 79.90 SF Walls SF = 329.53 SF Walls & Ceiling SF = 409.44 SF Perimeter of Ceiling = 56.77 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 409.44 SF @ 0.31 = 126.93 Clean door / window opening (per side) 8.00 EA @ 8.66 = 69.28 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Clean door hardware - Heavy 1.00 EA @ 6.23 = 6.23 Clean baseboard 35.08 LF @ 0.23 = 8.07 Clean shelving - wood 12.00 LF @ 0.61 = 7.32 Remove Carpet pad 79.90 SF @ 0.08 = 6.39 Remove Carpet 79.90 SF @ 0.19 = 15.18 Clean floor 79.90 SF @ 0.33 = 2637 Clean baseboard heater - interior and exterior 3.00 LF @ 17.27 = 51.81 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Deodorize building - Ozone treatment 639.23 CF @ 0.03 = 19.18 371.26 ROOM : FR BdRm Subroom 0: FR BdRm 8.0 - Ceiling Height Subroom 1: CLOSET 8.0 - Ceiling Height Subroom 2: CL3 8.0 - Ceiling Height Floor SF = 191.92 SF Walls SF = 512.00 SF Walls & Ceiling SF = 703.92 SF DESCRIPTION QNTY Clean the walls and ceiling - Heavy 703.92 SF @ 1689-MENAPACE-BILL Perimeter of Ceiling = 79.83 LF UNIT COST TOTAL 0.31 = 218.22 1/19/2011 Page: 8 CONTINUED - FR BdRm Floor SF = 191.92 SF Walls SF = 512.00 SF Walls & Ceiling SF = 703.92 SF Perimeter of Ceiling = 79.83 SF DESCRIPTION NTY UNIT COST TOTAL Clean door / window opening (per side) 8.00 EA @ 8.66 = 69.28 Clean window unit (per side) 10 - 20 SF - Heavy 2.00 EA @ 14.10 = 28.20 Clean door (per side) 8.00 EA @ 7.20 = 57.60 Clean door hardware - Ileavy 4.00 EA @ 6.23 = 24.92 Clean window stool & apron 6.00 LF @ 0.59 = 3.54 Clean drapery hardware 2.00 EA @ 11.23 = 22.46 Clean closet shelf and rod per lineal foot 6.00 LF @ 0.74 = 4.44 Clean closet organizer and rod - Small 1.00 EA @ 19.52 = 19.52 Clean phone, TV, or speaker outlet 1.00 EA @ 1.77 = 1.77 Clean baseboard 55.83 LF @ 0.23 = 12.84 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean baseboard heater - interior and exterior 8.00 LF @ 17.27 = 138.16 Clean thermostat 1.00 EA @ 8.50- 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Seat/prime the walls and ceiling - one coat 703.92 SF @ 0.40 = 281.57 Paint the walls and ceiling - two coats - 2 colors 703.92 SF @ 0.78 = 549.06 Paint door/window trim & jamb - 2 coats (per side) 8.00 EA @ 22.42 = 179.36 Paint baseboard - two coats 55.83 LF @ 1.04 = 58.06 Seal & paint base shoe or quarter round 55.83 LF @ 0.58 = 32.38 Seal & paint closet shelving - single shelf 2.00 EA @ 37.20 = 74.40 Detach & Reset Shelving - wire (vinyl coated) 3.00 LF @ 7.88 = 23.64 Clean wood floor 191.92 SF @ 0.53 = 101.72 Deodorize building - Ozone treatment 1,535.33 CF @ 0.03 = 46.06 2028.19 ROOM : FM BdRm Subroom 0: FM BdRm 8.0 - Ceiling Height Subroom 1: CLOSET 8.0 - Ceiling Height Floor SF = 150.62 SF Walls SF = 414.25 SF Walls & Ceiling SF = 564.87 SF Perimeter of Ceiling = 61.50 LF DESCRIPTION QNTY UNIT COST TOTAL Deodorize building - Ozone treatment 1,204.94 CF @ 0.03 = 36.15 36.15 ROOM : FL BdRm Subroom 0: FL BdRrn 8.0 - Ceiling Height 1689-MENAPACE-BILL 1/19/2011 Page:9 Subroom 2: CLOSET 8.0 - Ceiling Height Subroom 1: CIA 8.0 - Ceiling Height Floor SF = 191.69 SF Walls SF = 487.27 SF Walls & Cei ling SF = 678.96 SF Perimeter of Ceili ng = 81.13 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 678.96 SF @ 0.31 = 210.48 Clean door / window opening (per side) 8.00 EA @ 8.66 = 69.28 Clean window unit (per side) 10 - 20 SF - Heavy 2.00 EA @ 14.10 = 28.20 Clean door (per side) 4.00 EA @ 7.20 = 28.80 Clean door hardware - Heavy 2.00 EA @ 6.23 = 12.46 Clean window stool & apron 6.00 LF @ 0.59 = 3.54 Clean drapery hardware 2.00 EA @ 11.23 = 22.46 Clean closet shelf and rod per lineal foot 10.00 LF @ 0.74 = 7.40 Clean baseboard 51.87 LF @ 0.23 = 11.93 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean baseboard heater - interior and exterior 8.00 LF @ 17.27 = 138.16 Clean thennostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Seal/prime the walls and ceiling - one coat 678.96 SF @ 0.40 = 271.58 Paint the walls and ceiling - two coats - 2 colors 678.96 SF @ 0.78 = 529.59 Paint door/window trim & jamb - 2 coats (per side) 8.00 EA @ 22.42 = 179.36 Paint baseboard - two coats 51.87 LF @ 1.04 = 53.94 Paint door slab only - 2 coats (per side) 4.00 EA @ 21.95 = 87.80 Seal & paint base shoe or quarter round 51.87 LF @ 0.58 = 30.08 Seal & paint closet shelving - single shelf 2.00 EA @ 37.20 = 74.40 Clean wood floor 191.69 SF @ 0.53 = 101.60 Deodorize building - Ozone treatment 1,533.53 CF @ 0.03 = 46.01 1988.06 ROOM : Bath 4 Subroom 0: Bath 4 8.0 - Ceiling Height Subroom 1: SWR 8.0 - Ceiling Height Floor SF = 22.79 SF Walls SF = 165.70 SF Walls & Ceiling SF =188.49 SF Perimeter of Ceiling = 26.60 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 188.49 SF @ 0.31 = 58.43 Clean door / window opening (per side) 2.00 EA @ 8.66 = 17.32 Clean drapery hardware 1.00 EA @ 11.23 = 11.23 Clean window unit (per side) 3 - 9 SF 1.00 EA @ 7.02 = 7.02 Clean cove base molding - rubber or vinyl 18.04 LF @ 0.22 = 3.97 Clean floor - tile - Heavy clean 22.79 SF @ 0.65 = 14.81 Clean ceramic tile 83.93 SF @ 0.36 = 30.21 Clean tub / shower faucet 1.00 EA @ 9.37 = 9.37 Clean shower door 1.00 EA @ 11.86 = 11.86 1689-MENAPACE-BILL 1/19/2011 Page: 10 CONTINUED - Bath 4 Floor SF = 22.79 SF Walls SF = 165.70 SF Walls & Ceiling SF = 188.49 SF Perimeter of Ceiling = 26.60 SF DESCRIPTION QNTY UNIT COST TOTAL Clean bath accessory 2.00 EA @ 4.75 = 9.50 Clean toilet 1.00 EA @ 14.54 = 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink 1.00 EA @ 8.66 = 8.66 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean medicine cabinet - Large 1.00 EA @ 14.12 = 14.12 Clean vanity - inside and out 1.50 LF @ 7.09 = 10.64 Clean baseboard heater - interior and exterior 3.00 LF @ 17.27 = 51.81 Clean thermostat 1.00 EA @ 8.50- 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Floor protection - plastic and tape - 10 mil 15.60 SF @ 0.22 = 3.43 Seal/prime the surface area - one coat 104.56 SF @ 0.40 = 41.82 Paint the surface area - two coats - 2 colors 104.56 SF @ 0.78 = 81.56 Paint door or window opening - 2 coats (per side) 1.00 EA @ 22.42 = 22.42 Deodorize building - Ozone treatment 182.35 CF @ 0.03 = 5.47 457.91 ROOM : RL BdRm Subroom 0: RL BdRm 8.0 - Ceiling Height Subroom 1: CLOSET 8.0 - Ceiling Height Floor SF = 121.99 SF Walls SF = 375.90 SF Walls & Ceiling SF = 497.89 SF Perimeter of Ceiling = 58.33 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 497.89 SF @ 0.31 = 154.35 Clean door / window opening (per side) 6.00 EA @ 8.66 = 51.96 Clean window unit (per side) 10 - 20 SF - Heavy 2.00 EA @ 14.10 = 28.20 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Clean door hardware - Heavy 1.00 EA @ 6.23 = 6.23 Clean door - bypass set (per side) 2.00 EA @ 11.69 = 23.38 Clean window stool & apron 6.00 LF @ 0.59 = 3.54 Clean drapery hardware 2.00 EA @ 11.23 = 22.46 Clean baseboard 41.72 LF @ 0.23 = 9.60 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean closet shelf and rod per lineal foot 16.00 LF @ 0.74 = 11.84 Clean baseboard heater - interior and exterior 6.00 LF @ 17.27 = 103.62 Clean thenmostat 1.00 EA @ 8.50- 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Seal/prime the surface area - one coat 401.50 SF @ 0.40 = 160.60 Paint the surface area - two coats - 2 colors 401.50 SF @ 0.78 = 313.17 Remove Cedar closet lining 96.40 SF @ 0.27 = 26.03 1689-MENAPACE-BILL 1/19/2011 Page: 11 Floor SF = 121.99 SF CONTINUED - RL BdRm Walls SF = 375.90 SF Walls & Ceiling SF = 497.89 SF Perimeter of Ceiling = 58.33 SF DESCRIPTION QNTY UNIT COST TOTAL Detach & Reset Trim board - 1" x 6" - installed (pine) - CHARGES ARE 16.00 LF @ 1.12 == 17.92 FOR DETACH ONLY Detach & Reset Shelving - 16" - in place - CHARGES ARE FOR 16.00 LF @ 3.47 = 55.52 DETACH ONLY Paint door/window trim & jamb - 2 coats (per side) 6.00 EA @ 22.42 = 134.52 Paint baseboard - two coats 41.72 LF @ 1.04 == 43.39 Paint door slab only - 2 coats (per side) 2.00 EA @ 21.95 = 43.90 Paint bypass door set - slab only - 2 coats (per side) 2.00 EA @ 34.14 = 68.28 Seal & paint base shoe or quarter round 39.72 LF @ 0.58 = 23.04 Clean wood floor 121.99 SF @ 0.53 = 64.65 Deodorize building - Ozone treatment 975.94 CF @ 0.03 = 29.28 1490.87 ROOM : Bathroom 2 Subroom 0: Bathroom 2 8.0 - Ceiling Height Subroom 1: CLOSET 8.0 - Ceiling Height Floor SF = 61.83 SF Walls SF = 295.3 3 SF Walls & Ceiling SF = 357.16 SF Perimeter of Ceiling = 44.83 LF DESCRIPTION QNTY UNIT COST TOTAL Clean more than the ceiling - Heavy 220.60 SF @ 0.31 = 68.39 Clean door / window opening (per side) 4.00 EA @ 8.66 = 34.64 Clean door (per side) 4.00 EA @ 7.20 = 28.80 Clean window unit (per side) 10 - 20 SF 1.00 EA @ 10.03 = 10.03 Clean drapery hardware 1.00 EA @ 11.23 = 11.23 Clean floor - tile - Heavy clean 61.83 SF @ 0.65 = 40.19 Clean ceramic tile 136.56 SF @ 0.36 = 49.16 Clean shelving - wood 12.00 LF @ 0.61 = 7.32 Clean medicine cabinet 1.00 EA @ 9.38- 9.38 Clean mirror 6.00 SF @ 0.49 = 2.94 Clean vanity - inside and out 3.00 LF @ 7.09 = 21.27 Clean tub 1.00 EA @ 14.07 = 14.07 Clean tub / shower faucet 1.00 EA @ 9.37- 9.37 Clean shower curtain rod 1.00 EA @ 4.68 = 4.68 Clean toilet 1.00 EA @ 14.54 = 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink 1.00 EA @ 8.66- 8.66 Clean countertop 6.00 SF @ 0.49 = 2.94 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean baseboard heater - interior and exterior 4.00 LF @ 17.27 = 69.08 Clean thermostat 1.00 EA @ 8.50- 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 1689-MENAPACE-BILL 1/19/2011 Page: 12 CONTINUED - Bathroom 2 Floor SF = 61.83 SF Walls SF = 295.33 SF Walls & Ceiling SF = 357.16 SF Perimeter of Ceiling = 44.83 SF DESCRIPTION QNTY UNIT COST TOTAL Floor protection - plastic and tape - 10 mil 61.83 SF @ 0.22 _ 13.60 Seal/prime the surface area - one coat 220.60 SF c>) 0.40 = 88.24 Paint the surface area - two coats - 2 colors 220.60 SF @ 0.78 = 172.07 Paint door or window opening - 2 coats (per side) 4.00 EA @ 22.42 = 89.68 Paint door slab only - 2 coats (per side) 4.00 EA @ 21.95 = 87.80 Detach & Reset Door knob - interior 2.00 EA @ 24.87 = 49.74 Seal & paint closet shelving - linen closet 1.00 EA @ 63.89 = 63.89 Deodorize building - Ozone treatment 494.61 CF @ 0.03 = 14.84 1016.27 ROOM : RR BdRm Subroom 0: RR BdRm 8.0 - Ceiling Height Subroom 1: CLOSET2 8.0 - Ceiling Height Subroom 2: CLOSET 8.0 - Ceiling Height Floor SF = 148.10 SF Walls SF = 507.33 SF Walls & Ceiling SF = 655.44 SF Perimeter of Ceiling = 78.00 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and ceiling - Heavy 655.44 SF @ 0.31 = 203.19 Clean door / window opening (per side) 7.00 EA @ 8.66 = 60.62 Clean window unit (per side) 10 - 20 SF - Heavy 1.00 EA @ 14.10 = 14.10 Clean door (per side) 6.00 EA @ 7.20 = 43.20 Clean door hardware - Heavy 3.00 EA @ 6.23 = 18.69 Clean window stool & apron 3.00 LF @ 0.59 = 1.77 Clean baseboard 56.00 LF @ 0.23 = 12.88 Clean closet shelf and rod per lineal foot 8.00 LF @ 0.74 = 5.92 Move then reset items as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean baseboard heater - interior and exterior 6.00 LF @ 17.27 = 103.62 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Seal/prime the surface area - one coat 449.33 SF @ 0.40 = 179.73 Paint the surface area - two coats - 2 colors 449.33 SF @ 0.78 = 350.48 Paint door/window trim & jamb - 2 coats (per side) 7.00 EA @ 22.42 = 156.94 Paint baseboard - two coats 56.00 LF @ 1.04 = 58.24 Paint door slab only - 1 coat (per side) 6.00 EA @ 14.54 = 87.24 Seal & paint base shoe or quarter round 54.00 LF @ 0.58 = 31.32 Remove Cedar closet lining 101.40 SF @ 0.27 = 27.38 Detach & Reset Trim board - 1" x 6" - installed (pine) - CHARGES ARE 16.00 LF @ 1.12 = 17.92 FOR DETACH ONLY Detach & Reset Shelving - 16" - in place - CHARGES ARE FOR 8.00 LF @ 3.47 = 27.76 DETACH ONLY Clean wood floor 148.10 SF @ 0.53-- 78.49 1689-MENAPACE-BILL 1/19/2011 Page: 13 CONTINUED - RR BdRm Floor SF = 148.10 SF Walls SF = 507.33 SF Walls & Ceiling SF = 655.44 SF Perimeter of Ceiling = 78.00 SF DESCRIPTION QNTY UNIT COST TOTAL Deodorize building - Ozone treatment 1,184.83 CF @ 0.03-- 35.54 1596.02 ROOM : Bathroom Subroom 0: Bathroom 8.0 - Ceiling Height Subroom 1: TUB 8.0 - Ceiling Height Floor SF = 51.11 SF Walls SF = 226.44 SF Walls & Ceiling SF = 277.56 SF Perimeter of Ceiling = 34.00 LF DESCRIPTION QNTY UNIT COST TOTAL Clean part of the walls and ceiling - Heavy 227.56 SF @ 031 = 70.54 Clean door / window opening (per side) 3.00 EA @ 8.66-- 25.98 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Clean window unit (per side) 10 - 20 SF 1.00 EA @ 10.03 = 10.03 Clean door / window opening (per side) 1.00 EA @ 8.66 = 8.66 Clean floor - tile - Heavy clean 52.44 SF @ 0.65 = 34.09 Clean ceramic tile 50.00 SF @ 0.36 = 18.00 Clean tub 1.00 EA @ 14.07 = 14.07 Clean tub / shower faucet 1.00 EA @ 9.37 = 9.37 Clean shower curtain rod 1.00 EA @ 4.68 = 4.68 Clean toilet 1.00 EA @ 14.54 = 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink - pedestal 1.00 EA @ 16.46 = 16.46 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean medicine cabinet 1.00 EA @ 9.38 = 9.38 Clean bath accessory 2.00 EA @ 4.75 = 9.50 Clean baseboard heater - interior and exterior 4.00 LF @ 17.27 = 69.08 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Floor protection - plastic and tape - 10 mil 51.11 SF @ 0.22 = 11.24 Seal/prime part of the walls and ceiling - one coat 227.56 SF @ 0.40 = 91.02 Paint part of the walls and ceiling - two coats - 2 colors 227.56 SF @ 0.78 = 177.50 Paint door or window opening - 2 coats (per side) 3.00 EA @ 22.42 = 67.26 Paint door slab only - 2 coats (per side) 2.00 EA @ 21.95 = 43.90 Detach & Reset Door knob - interior - CHARGES ARE FOR DETACH 1.00 EA @ 12.44 = 12.44 ONLY Deodorize building - Ozone treatment 408.89 CF @ 0.03 = 12.27 774.13 1689-MENAPACE-BILL 1/19/2011 Page: 14 Basment ROOM : Basement Subroom 0: Basement 7.5 - Ceiling Height Subroom 1: OFFSET REAR 7.5 - Ceiling Height Subroom 2: STAIRS 17.0 - Ceiling Height Floor SF = 1,118.88 SF Walls SF = 1,150.85 SF Walls & Ceiling SF = 2,252.85 SF Perimeter of Ceiling = 228.50 LF DESCRIPTION QNTY UNIT COST TOTAL Clean floor or roof joist system 1,102.00 SF @ 0.65 = 716.30 Clean sheathing between joists 1,102.00 SF @ 0.19 - 209.38 Clean masonry 1,150.85 SF @ 0.39 = 448.83 Clean concrete on the floor 1,118.88 SF @ 0.20 = 223.78 Clean stair stringer - per side 48.00 LF @ 0.59 = 28.32 Clean stair tread - per side - per LF 72.00 LF @ 0.43 = 30.96 Remove Outlet/switch 15.00 EA @ 164 = 54.60 Remove 220 volt copper wiring run, box and receptacle 1.00 EA @ 5.43 = 5.43 Remove Clothes dryer vent - installed 1.00 EA @ 3.64 = 3.64 Remove Porcelain light fixture 8.00 EA @ 6.03 = 48.24 Remove wiring - average residence - copper wiring 1,118.88 SF @ 0.67 = 749.65 Remove Rough in plumbing 1,118.88 SF @ 0.75 = 839.16 Remove Water heater - 60 gallon - Electric 1.00 EA @ 41.83 = 41.83 Remove Laundry tub 1.00 EA @ 27.13 = 27.13 Remove Washing machine outlet box with valves 1.00 EA @ 19.73 = 19.73 Remove Sump pump - 1 1/2" discharge 1.00 EA @ 39.00 = 39.00 Clean I-beam and ]allay column - exposed 66.00 LF @ 1.00 = 66.00 Deodorize building - Ozone treatment 8,391.56 CF @ 0.03 = 251.75 Remove Dryer - Electric 1.00 EA @ 50.00 = 50.00 Remove Washer/Washing Machine - Top-loading 1.00 EA @ 50.00 = 50.00 Remove Freezer 1.00 EA @ 50.00 = 50.00 3953.73 ROOM : Storage 1 Subroom 0: Storage 1 7.5 - Ceiling Height Floor SF = 361.06 SF Walls SF = 529.02 SF Walls & Ceiling SF = 890.08 SF Perimeter of Ceiling = 77.00 LF DESCRIPTION QNTY UNIT COST TOTAL Clean floor or roof joist system 361.06 SF @ 0.65 = 234.69 Clean sheathing between joists 361.06 SF @ 0.19 = 68.60 Clean masonry 529.02 SF @ 0.39 = 206.32 Clean concrete on the floor 361.06 SF @ 0.20 = 72.21 Seal floor or ceiling joist system 361.06 SF @ 0.74 = 267.18 1689-MENAPACE-BILL 1/19/2011 Page: 15 CONTINUED - Storage 1 Floor SF = 361.06 SF Walls SF = 529.02 SF Walls & Ceiling SF = 890.08 SF Perimeter of Ceiling = 77.00 SF DESCRIPTION QNTY UNIT COST TOTAL Paint plywood sheathing 361.06 SF @ 0.41 = 148.03 Seal block with masonry sealer 529.02 SF @ 0.62 = 327.99 Paint concrete the floor 361.06 SF @ 0.47 = 169.70 Clean I-beam and lallay column - exposed 24.00 LF @ 1.00 = 24.00 Seal & paint I-beam and tally column 24.00 SF @ 1.39-- 33.36 (Material Only) Vinyl window, horizontal sliding, 3-11 sf 2.00 EA @ 83.39 = 166.78 Deodorize building - Ozone treatment 2,707.92 CF @ 0.03 = 81.24 1800.10 ROOM : Storage 2 Subroom 0: Storage 2 7.5 - Ceiling Height Floor SF = 149.54 SF Walls SF = 359.03 SF Walls & Ceiling SF = 508.57 SF Perimeter of Ceiling = 50.83 LF DESCRIPTION QNTY UNIT COST TOTAL Clean masonry 359.03 SF @ 0.39 = 140.02 Seal block with masonry sealer 359.03 SF @ 0.62 = 222.60 Clean concrete on more than the floor 299.08 SF @ 0.20 = 59.82 Paint concrete more than the floor 299.08 SF @ 0.47 = 140.57 Deodorize building - Ozone treatment 1,121.56 CF @ 0.03 = 33.65 596.66 Attic ROOM : Attic Subroom 0: Attic 5.0 - Ceiling Height Floor SF = 1,116.97 SF Walls SF = 168.72 SF Walls & Ceiling SF = 1,353.78 SF Perimeter of Ceiling = 140.71 LF DESCRIPTION QNTY UNIT COST TOTAL Deodorize building - Ozone treatment 5,584.86 CF @ 0.03 = 167.55 167.55 ROOM : Miscellaneous Subroom 0: Miscellaneous 1689-MENAPACE-BILL 0.0 - Ceiling Height 1/19/2011 Page: 16 DESCRIPTION QNTY UNIT COST TOTAL Cleaning - further work - contents 1.00 EA @ 8,409.23 = 8,409.23 Single axle dump trick - per load - in cluding dump fees 2.00 EA @ 234.97 = 469.94 Emergency Services bill 1.00 EA @ 5,455.36 = 5,455.36 14334.53 Summary Line Item Total 41,806.24 Material Sales Tax @ 6.000% x 3,450.80 207.05 Cleaning Mtl Tax @ 6.000% x 355.34 21.32 Subtotal 42,034.61 Overhead @ 10.0% x 24,648.89 2,464.89 Profit @ 10.0% x 27,113.78 2,711.38 Cleaning Sales Tax @ 6.000% x 11,930.36 715.82 Total Estimated Cost $47,926.70 Total $47,926.70 1689-MENAPACE-BILL 1/19/2011 Page: 17 INVOICE SERVICElst Restoration & Remodeling 1441 Stoneridge Drive Middletown, PA 17057 Phone No. 717-232-5444 Fax 717-232-1123 Fed I.D. 11-3712523" Bill To: Martin Menapace 108 Harrison Drive New Cumberland,PA 17070 Customer No: 1354 Job No.: 1675 Invoice No: 3528 Invoice Date:12/13/10 Service: Martin Menapace 108 Harrison Drive New Cumberland,PA 17070 Due Date:12/28/10 EMERGENCY SERVICE 5455.36 Billing for Emergency Services. Replacing Invoice V3,436. STRUCTURE REPAIR 42471.34 Billing for Structure repair services completed. Replacing Invoice #3445 Subtotal 47926.70 Sales Tax 0.00 Total Invoice Amount 47926.70 .e0o goc1aq w Prepared bv: Law Office of Darrin C. Dinelfo 5405 Jonestown Road Suite 101 Harrisburg, PA 17112 (7V" t'D'A kInA ee, made the . 3www- day of THE BRODY KHALSA REAL ESTATE TRUST (hereinafter called the Grantor), of the one part, and MARTIN MENAPACE AND TRACI L. MENAPACE, HUSBAND AND WIFE (hereinafter called the Grantees), of the other part, Alw,wA that the said Grantor for and in consideration of the sum of Two Hundred Fifty Seven Thousand Dollars 00/100 ($257,000.00) lawful money of the United States of America, unto him well and truly paid by the said Grantees, at or before the sealing and delivery hereof, the receipt whereof is hereby acknowledged, has granted, bargained and sold, released and confirmed, and by these presents does grant, bargain and sell, release and confirm unto the said Grantees, as tenants by the entirety ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, bounded and described as follows: BEGINNING at a point on the easterly line of Harrison Drive one hundred eighty (180) feet measured northwardly along said line from the northerly line of Harrison Drive and at the northerly line of Lot No. 10, Block "H" on the hereinafter mentioned Plan; thence northwardly along the easterly line of Harrison Drive by a curve to the left having a radius of two hundred ninety (290) feet an arc distance of seventy0 (70) feet to a point; thence northeastwardly along the southerly line of Lot No. 12, Block "H", one hundred forty-one and twenty-eight one-hundredths (141.28) feet to a point; thence southeastwardly along the westerly line of Lots Nos. 4 and 5, Block "H", one hundred six and seventeen one-hundredths (106.17) feet to a point; thence westwardly along the northerly line of Lot No. 10, Block "14 one hundred fifty-four and sixteen one-hundredths (154.15) feet to the Place of BEGINNING. BEING Lot No. 11, Block "H" on the Plan of Section 4, Drexel Hills, said Plan being recorded in Plan Book 11. Page 11, Cumberland County Records. BEING the same premises which Siri Neel Kaur Khalsa and James M. Brody, Husband and Wife, by Deed dated September 25, 2003 and recorded October 14, 2.003 in Cumberland County Record Book 259, Page 4388, granted and conveyed unto The Brody Khalsa Real Estate Trust, in fee. r ,yooGor uc4 all and singular the buildings and improvements, ways, streets, alleys, driveways. passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or, in anywise appertaining, and the reversions and remainders, rents, issues, and profits thereof, and ail the estate, right, title, interest, property, claim and demand whatsoever of him, the said grantor, as well at law as in equity, of, in and to the same. r?,Fo' 4aue and & Aola! the said lot or piece of ground described above. with the buildings and improvements thereon erected, hereditaments and premises hereby granted, or mentioned and intended so to be, with the appurtenances, unto the said Grantees, their heirs and assigns, to and for the only proper use and behoof of the said Grantees, their heirs and assigns, forever. r= iw,(Ithe said Grantor, for himself and his heirs, executors and administrators, does, by these presents, covenant, grant and agree, to and with the said Grantees, their heirs and assigns, that he, the said Grantor, and his heirs, all and singular the hereditaments and premises herein described and granted, or mentioned and intended so to be, with the appurtenances, unto the said Grantees, their heirs and assigns, against him, the said Grantor, and his heirs, will warrant and defend against the lawful claims of all persons claiming by. through or under the said Grantor but not otherwise. ?5;, ?Xf?P -1/4emll',the party of the first part has hereunto set his hand and seal. Dated the day and year first above written. IN THE PRESENCE OF US: {SEAL} Siri Neel Kaur K alsa, trustee Jam"es Mansbaclk Brody, trustee AUA FYI<. U Commonwealth of ?e++r+syk++ama ss County of Gnn+bertwd pu f 54,474 G'r". X IA /170 ! On this, the day of Xbefore me, the undersigned Notary Public, personally appeared Siri N Kaur Khalsa, trustee and James Mansback Brody, trustee, known to me {or satisfactorily prov?e.?'? the person whose name is subscribed to the within instrument, and acknowledged that he execute for the purposes therein contained. r 5 IN WITNESS WHEREOF, I hereunto set my hand and official sea).'' }. r .. Notary Public My commission expires 0 The precise residence and the complete post office address of the above-named Gran7y5 s: A ??°`?' ?, ?{m? ??, ? 7? ice' On half of the Grantees Igea Parcel ID # y_ 1 v oz The Brody Khalsa Real Estate Trust TO Martin Menapace and Traci L. Menapace Law Office of Darrin C. Dinello 5405 Jonestown Road Suite 101 Harrisburg, PA 17112 ti ' ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200740924 Recorded On 10/29/2007 At 10:48:33 AM * Instrument Type - DEED Invoice Number - 7596 User ID - KW * Grantor - BRODY KHALSA REAL ESTATE TRUST * Grantee - MENAPACE, MARTIN * Customer - SUPREME SETTLEMENT SERVICES * FEES STATE TRANSFER TAX $2,570.00 STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $1,285.00 DISTRICT NEW CUMBERLAND $1,285.00 BOROUGH TOTAL PAID $5,179.50 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O D DS "` - information denoted by an asterisk may change during the verification process and may not be reflected on this page. I OW11HO 1111111111111111 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF CE. F T..c c-. 14:F it f> I JUN 22 AH g: ? ANO ? ?? ? Uj, 6 F1 Service 1 st Restoration and Remodeling, LLC Case Number vs. Traci L. Menapace (et al.) 2011-4807 SHERIFF'S RETURN OF SERVICE 06/17/2011 06:39 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2011 at 1839 hours, he served a true copy of the within Notice of Mechanics' Lien Claim and Mechanics' Lien Claim, upon the within named defendant, to wit: Traci L. Menapace, by making known unto Martin Menapace, Husband of Defendant at 108 Harrison Drive, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true an( correct copy of the same. AeA , - I--- GE LD WORTHING , DEPUTY 06/17/2011 06:39 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2011 at 1839 hours, he served a true copy of the within Notice of Mechanics' Lien Claim and Mechanics' Lien Claim, upon the within named defendant, to wit: Martin Menapace, by making known untc himself personally, at 108 Harrison Drive, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. GERALD WORTHINGTON, D UTY SHERIFF COST: $61.44 SO ANS RS June 20, 2011 R R ANDERSON, SHERIFF NOTARY Affirmed and subscribed to before me this day of ici Goun?,Suite Sheriff. Tele^„ul ln-; 0 SERVICE " RESTORATION AND REMODE ING, LLC, Plaintiff V. MARTIN MENAP.? APACE and TRACI L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MECHANIC'S LIEN CLAIM t 7 ra 2 MM E NO. 2011-04807 rzr' r? M yz - QF?z NOTICE --? -' ' Defendants YO forth in the and Notice writing wit warned the entered age or any othe right impox YO NOT HA` OFFICE Sl 1 HAVE BEEN SUED IN COURT. If you wish to defend against the claims set following pages, you must take action within twenty (20) days after this Complaint are served, by entering a written appearance personally or by attorney and filing in the Court your defenses or objections to the claims set forth against you. You are if you fail to (to so, the case may proceed without you and a judgment may be nst you by the Court without further notice for any money claimed in the Complaint claim for relief requested by the Plaintiff. You may lose money or property or other ant to you. SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU DO NOT HAVE A LAWYER CONTACT: CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SERVICE ST RESTORATION AND IN THE COURT OF COMMON PLEAS REMODELING, LLC, OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. MECHANIC'S LIEN CLAIM MARTIN ENAPACE and TRACI L. MENAPA .E, NO. 2011-04807 Defendants COMPLAINT IN ACTION UPON MECHANIC'S LIEN CLAIM AN NOW comes the Plaintiff, Service 1St Restoration and Remodeling, LLC, who, by and throug its attorneys, Thomas A. Beckley, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint in Action Upon Mechanic's Lien Claim, and in supp rt thereof, avers as follows: 1. Plaintiff, Service 1St Restoration and Remodeling, LLC ("Service 1st"), is a limited liability company organized and existing under the laws of the Commonwealth of Pennsylvania with a business address of 1441 Stoneridge Drive, Middletown, Pennsylvania 17057. 2. The Defendants, Martin Menapace and Traci L. Menapace, husband and wife, are both adult ndividuals with an address of 108 Harrison Drive, New Cumberland, Pennsylvania 17070. 3. service 1St filed a mechanic's lien claim in the Court of Common Pleas of Cumberland County, Pe Sylvania as of 2011 Term, docket number 2011-04807, a true and correct copy of which lien i incorporated herein, made a part hereof, and attached hereto as Exhibit A. REFORE, Plaintiff, Service 1St Restoration and Remodeling, LLC, respectfully requests the Court to enter a judgment in its favor, and against the Defendants, Martin Menapace and Traci L. Menapace, in the principal amount of $47,926.70 plus interest, costs of suit and such other ?nd further relief as the Court may deem appropriate. DATED: J4ne 29, 2011 Of BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717) 233- 691 Respectfully submitted, ? L 1h4 xo?", Thomas A. Beckley, Es re Thomas S. Beckley, Esquire Attorneys for Plaintiff Service 1" Restoration and Remodeling, LLC 2 VERIFICATION I, Jaime Novinger, hereby verify that I am an adult individual; that I am the President of Service I ` Restoration and Remodeling, LLC; that I am authorized to make this statement on behalf of ervice I" Restoration and Remodeling, LLC; that I have read the foregoing document, and that he facts set forth in the foregoing document are true to the best of my knowledge, informati n and belief. I understand that false statements herein are made subject to the penalties f 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Service ls` Restoration and Remodeling, LLC B. aime Novinger, President 3 SERVICE', I' RESTORATION AND IN THE COURT OF COMMON PLEAS REMODELING, LLC, OF CUMBERLAND COUNTY, Claimant PENNSYLVANIA V. rMECHANIC'S LIEN CLAIM C--) MARTIN ENAPACE and TRACI L. MENAPA F,, NO. Owners cn r' i - c. ?- er+ t. r'a MECHANIC'S LIEN CLAIM A NOW comes the Claimant, Service 1" Restoration and Remodeling, LLC ("Service First"), who, by and through its attorneys, Thomas A. Beckley, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Mechanic's Lien Claim, and, in support thereof, avers as follows: 1. laimant, Service 1St Restoration and Remodeling, LLC, is a limited liability company organized nd existing under the laws of the Commonwealth of Pennsylvania with a business address of 1441 Stoneridge Drive, Middletown, Pennsylvania 17057. Service 1St is filing this claim as a contractor under the Mechanic's Lien Law of 1963. 49 P. S. § 1101 et seq. 2. The owners of the Property subject to the lien, Martin Menapace and Traci L. Menapace, husband and wife, are adult individuals residing at 108 Harrison Drive, New Pennsylvania 17070. 3. was Febru 4. Menapace real prope document date on which Service I" completed the work for which this claim is being made 15, 2011. 1St files this claim under a contract with Martin L. Menapace and Traci L. Service 1St agreed to provide various restoration services to the Menapace's A detailed description of the work Service 1St performed is set forth in the is attached hereto as Exhibit A. The amount claimed to be due is $47,926.70. 5. The improvement and property claimed to be subject to the lien is the real property (including all improvements thereon) located at 108 Harrison Drive, New Cumberland, Pennsyl 17070. A true and correct copy of the deed to the property subject to the lien is herein, made a part hereof, and attached hereto as Exhibit B. Claimant, Service 1st Restoration and Remodeling, LLC, claims to have a lien upo7 and such c DATED: Of BECKLEY 212 North' Post Office Harrisburg, (717) 233 the premises herein described in the amount of $47,926.70, plus interest, costs of suit and further relief as the Court may deem appropriate. 3, 2011 & MADDEN ,hird Street Box 11998 Pennsylvania 17108-1998 691 Respectfully submitted, Thomas A. eckley,, squire Thomas S. Beckley, Esquire Attorneys for Claimant Service 1st Restoration and Remodeling, LLC 2 -AAkIt T(A/ Ta T., Jaime Novinger, hereby verify that I am an adult individual; that I am President of I" Restoration and Remodeling, LLC; and that I ann authorized to make this statement on its behalf, that I have read the foregoing document, and that the facts set forth in The foregoing document are true to the best of my knowledge, or information and belief. I understanij that false hcrein are made subject to the penalties of 18 P&C.S. § 44904 relating; to unworn I to authorities. Service l" RestaMion and Remodeling, LLC By. J Novinger, Presid EXHIBIT A ® ervice 1st Restoration & .Remodeling 1603 N Cameron St I arrisburg, Pa. 17103 17-232-5444 Tax ID#11-3712523 / PA03501 1 ?ercantile License #25977-0 Client: Menapace, Martin Property: 108 Harrison Drive New Cumberland, PA 17070 Operator Info: Operator: PATRICK Estimator: Patrick Connors Business: Reference: Company: Type of Estimate: Date Entered: 1603 N. Cameron St. Harrisburg, PA 17103 American Securities Fire 10/4/2010 Date Assigned: Price List: PAHA7X_SEP10 Restoration/Service/Remodel Estimate: 1689-MENAPACE-BILL File Number: 00100888051 Cellular: (240) 464-5209 Business: (717) 232-5444 Business: (610) 404-7042 F 1689-MENAPACE-BILL Main Level ROOM : Subroom 0: Fo yer/Entry 8.0 - ceiling Height Subroom 2: C 8.0 - Ceiling Height Subroom 1: ST IRS 16.3 - Ceiling Height Subroom 3: LA NDING 7.3 - Ceiling Height Floor SF = 136.56 F Walls SF = 417.92 SF Walls & Cei ling SF = 526.38 SF Perimeter of Ceili ng = 65.50 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and eiling - Heavy 526.38 SF @ 0.31 = 163 18 Clean door / windo opening (per side) 4.00 EA @ 8.66 = . 34 64 Clean door (per side 2.00 EA @ 7.20 = . 14 40 Clean door hardware - Heavy 2.00 EA @ 6.23 = . 12 46 Clean exterior door ( per side) 2.00 EA @ 9.52 = . 19 04 Clean window unit (p er side) 3 - 9 SF - sidelite 2.00 EA @ 7 02 = . Clean baseboard . 14.04 Clean floor - the - He avy clean 47.37 LF @ 0.23 = 10.90 Clean closet shelf an rod per lineal foot 75.79 SF @ 0.65 = 49.26 Clean balustrade 3.00 LF @ 0.74 = 2.22 Clean stair stringer - er side 5.00 LF @ 1.75 = 8.75 Clean corner trim 28.00 LF @ 0.59 = 16.52 Clean baseboard heat er - interior and exterior 28.00 LF @ 4 00 LF @ 0.25 = 17 27 = 7.00 Clean thermostat . . 69.08 Clean outlet or switch 1.00 EA @ 8.50 = 8.50 Remove Carpet pad 5.00 EA @ 2.32 = 11.60 Remove Carpet 36.00 SF @ 0.08 = 2.88 Clean wood floor 84.00 SF @ 0.19 = 15.96 Deodorize building - zone treatment 10.00 SF @ 1,092.51 CF @ 0.53 = 0 03 = 5.30 . 32.78 498.51 ROOM : Livi ng Room Subroom 0: Subroom 1: Floor SF = 243.44 S DESCRIPTION Clean the walls and c Clean door / window Clean window unit (I 1689-MENAPACE-BI] Room 8.0 - Ceiling Height :T 8.0 - Ceiling Height Walls SF = 416.69 SF Walls & Ceiling SF = 660.13 SF ling - Heavy iening (per side) side) 10 - 20 SF Perimeter of Ceiling = 64.67 LF UNIT COST TOTAL 660.13 SF @ 0.31 = 204.64 3.00 EA @ 8.66 = 25.98 2.00 EA @ 10.03 = 20.06 1/19/2011 Page:2 CONTINUED - Living Room Floor SF = 243.44 4 Walls SF = 416.69 SF Walls & Ceiling SF = 660.13 SF Perimeter of Ceiling = 64.67 DESCRIPTION SF Clean window unit per side) 21 - 40 SF QNTY UNIT COST TOTAL Clean drapery hard are 1.00 EA @ 13.39 = 13.39 Clean baseboard 1.00 EA @ 11.23 - 11.23 Clean base shoe 47.51 LF @ 0.23 = 10.93 Clean wood floor 47.51 LF @ 0.20 = 9.50 Move then reset itet is as needed to clean structure 243.44 SF @ 0.53 = 129.02 Clean baseboard he ater - interior and exterior 1.00 EA @ 60.89 = 60.89 Clean thermostat 8.00 LF @ 17.27 = 138.16 Clean outlet or switc h 1.00 EA @ 8.50 = 8.50 Seal/prime the wall and ceiling - one coat 5.00 EA @ 660 13 SF @ 2.32 = 0 40 = 11.60 Paint the walls and c eiling - two coats - 2 colors . 660.13 SF @ . 038 = 264.05 Paint door or windo w opening - 2 coats (per side) 3.00 EA @ 22 42 = 514.90 Paint baseboard - tw o coats 55.51 LF @ . 1.04 = 67.26 57 73 Seal & paint bases a or quarter round 55.51 LF @ 0.58 = . 32 20 Deodorize building Ozone treatment 1,947.56 CF @ 0.03 = . 58.43 1638.47 ROOM : Di ning Subroom 0: Din ing 8.0 - Ceili ng Height Floor SF = 139.19 S Walls SF = 295.32 SF Walls & Ceiling SF = 434.51 SF Perimeter of Ceiling = 47.20 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and c eiling - Heavy 434.51 SF @ 0.31 = 134 70 Clean door / window opening (per side) 3.00 EA @ 8 66 = . Clean drapery hardw are 1.00 EA @ . 11.23 = 25.98 11 23 Clean chair rail 37.86 LF @ 0.23 = . 8 71 Clean baseboard 29.86 LF @ 0.23 = . 6 87 Clean base shoe 37.86 LF @ 0.20 = . 7 57 Clean wood floor 139.19 SF @ 0.53 = . 73 77 Move then reset item as needed to clean structure 1.00 EA @ 60.89 = . 60 89 Plumber - per hour - ut and replace waste line in wall 4.00 HR @ 70.36 = . 281 44 Clean baseboard heat er - interior and exterior 6.00 LF @ 17 27 = . Clean thermostat 1.00 EA @ . 8.50 = 103.62 8 50 Clean outlet or switc 5.00 EA @ 2.32 = . 11 60 Floor protection - pla tic and tape - 10 mil 139.19 SF @ 0.22 = . 30 62 Seal/prime the walls a nd ceiling - one coat 434.51 SF @ 0.40 = . 173 80 Paint the ceiling - two coats - 2 colors 139.19 SF @ 0.78 = . 108 57 Paint the walls - one at 295.32 SF @ 0.43 = . 126 99 Paint part of the walls - one coat 147.66 SF @ 0.43 = . 63 49 Paint chair rail - two c oats 37.86 LF @ 1.02 = . 38 62 Paint baseboard - two oats 37.86 LF @ 1.04 = . 39 37 1689-MENAPACE-BIL L . 1/19/2011 Page:3 Floor SF = 139.19 SF DESCRIPTION CONTINUED - Dining Walls SF = 295.32 SF Walls & Ceiling SF = 434.51 SF Seal & paint base shoe or quarter round Deodorize building jI Ozone treatment 37.86 LF @,) 1,1 13.51 CF (ay) Perimeter of Ceiling = 47.20 SF UNIT COST TOTAL 0.58-- 21.96 0.03 = 33.41 ROOM : Fa Subroom 0: Fam Subroom 1: BA Floor SF = 403.87 DESCRIPTION mily Room ily Room 8.0 - Ceiling Height 8.0 - Ceiling Height Walls SF = 550.66 SF Walls & Ceiling SF = 954.52 SF QNTY 1371.71 erimeter of Ceiling = 85.05 LF UNIT COST TOTAL Clean the walls and eiling - Heavy 954.52 SF @ 0.31 = 295 90 Clean door / window opening (per side) 8.00 EA @ 8.66 = . 69 28 Clean window unit ( er side) 10 - 20 SF -Heavy 5.00 EA @ 14.10 = . 70 50 Clean door (per side) 2.00 EA @ 7.20 = . 14 40 Clean exterior door er side) 2.00 EA @ 9.52 = . 19 04 Clean door hardware - Heavy 2.00 EA @ 6.23 = . 12 46 Clean patio door (slid ing glass) (per side) 1.00 EA @ 26.39 = . 26 39 Clean window stool apron 15.00 LF @ 0.59 = . 8 85 Clean drapery hardw are 2.00 EA @ 11.23 = . 22 46 Clean baseboard 42.67 LF @ 0.23 = . 9 81 Clean floor - tile - ba window floor 31.98 SF @ 0.49 = . 15 67 Move then reset item as needed to clean structure 1.00 EA @ 60.89 = . 60 89 Remove Carpet pad 403.87 SF @ 0.08 = . 32 31 Remove Carpet 403.87 SF @ 0.19 = . 76 74 Clean baseboard heat er - interior and exterior 16.00 LF @ 17.27 = . 276 32 Clean thennostat 1.00 EA @ 8.50 = . 8 50 Clean outlet or switch 5.00 EA @ 2.32 = . 11 60 Deodorize building - zone treatment 3,230.93 CF @ 0.03 = . 96.93 1128.05 ROOM : Kitc hen Subroom 0: Kitch en 8.0 - Ceiling Height Subroom 3: OFF ETl 8.0 - Ceiling Height Floor SF = 267.48 SF Walls SF = 542.13 S F Walls & Ceiling SF = 809.61 SF Perimeter of Ceilin g = 83.97 LF DESCRIPTION QNTY UNIT COST TOTAL 1689-MENAPACE-BIL 1/19/2011 Page:4 CONTINUED - Kitchen Floor SF = 267.481SF Walls SF = 542.13 SF Walls & Ceiling SF = 809.61 SF DESCRIPTION QNTY Perimeter of Ceiling = 83.97 SF UNIT COST TOTAL Clean the walls and ceiling - Ileavy 809.61 SF @ 0.31 250.98 Clean door / windo w opening (per side) 3.00 EA @ 8.66--- 25 98 Clean exterior door (per side) 2.00 EA @ 9.52 = . 19.04 Clean baseboard 34.38 LF @ 0.23 = 7.91 Clean sink - double 1.00 EA @ 11.53 = 11.53 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean countertop 34.00 SF @ 0.49 = 16.66 Clean floor - the - I eavy clean 258.48 SF @ 0.65 = 168.01 Deodorize building Ozone treatment 2,139.83 CF @ 0.03 = 64.19 Clean baseboard hea ter - interior and exterior 6.00 LF @ 17.27 = 103.62 Clean thermostat 1.00 EA @ 8.50 = 8.50 Remove Hanging lig ht fixture 1.00 EA @ 9.11 = 9.11 Remove Ceiling fan without light 1.00 EA @ 13.64 = 13.64 Remove Recessed li ght fixture 2.00 EA @ 8.06 = 16.12 Clean outlet or switc h 5.00 EA @ 2.32 = 11.60 Plumber - per hour cut and replace waste line in wall 4.00 HR @ 70.36 = 281.44 (Material Only) Vin yl window - double hung 2.00 EA @ 257.09 = 514.18 Remove Casing - 2 /4" - windows 28.00 LF @ 0.36 = 10.08 Remove Window st of & apron 6.00 LF @ 0.54 = 3.24 Floor protection - pt stic and tape - 10 mil 267.48 SF @ 0.22 = 58.85 Seal/prime part oft walls and ceiling - one coat 669.61 SF @ 0.40 = 267.84 Paint part of the wal s and ceiling - two coats - 2 colors 669.61 SF @ 0.78 = 522.30 Detach & Reset Cab netry - lower (base) units - CHARGES ARE FOR 20.00 LF @ 28.15 = 563 00 DETACH ONLY . Detach & Reset Cab netry - upper (wall) units - CHARGES ARE FOR 19.25 LF @ 24.07 = 463 35 DETACH ONLY . Detach & Reset Cab netry - full height unit - CHARGES ARE FOR 4.00 LF @ 28.02 = 112 08 DETACH ONLY . Cabinetry - per hour - additional time to save & move cabinets and 10.00 HR @ 62.23 = 622 30 detach top without d amaging cabinets . Remove Cabinetry - ill height unit - built in wall unit - in alcove with 3.00 LF @ 6.52 = 19 56 trim . Countertop - culture marble - Detach & reset - CHARGES ARE FOR 34.00 SF @ 4.20 = 142 80 DETACH ONLY . Remove Countertop Tile - High grade 20.00 SF @ 2.18 = 43.60 Detach & Reset Sink - double - CHARGES ARE FOR DETACH ONLY 1.00 EA @ 50.17 = 50.17 Detach & Reset Sink faucet - Kitchen - CHARGES ARE FOR 1.00 EA @ 37.65 = 37 65 DETACH ONLY . Remove Plumbing fi xture supply line 2.00 EA @ 3.62 = 7.24 Remove P-trap assem bly - ABS (plastic) 1.00 EA @ 5.43 = 5.43 Remove Dishwasher 1.00 EA @ 19.37 = 19.37 Remove Range - buil t in unit - hot wired direct - no plug 1.00 EA @ 14.57 = 14.57 Remove Microwave oven - over range w/built-in hood 1.00 EA @ 21.70 = 21.70 Remove Refrigerator - bottom freezer - 25 to 30 of 1.00 EA @ 50.00 = 50.00 4564.10 1689-MENAPACE-Bllfl, 1/19/2011 Page:5 ROOM : Powder Subroom 0: Poivder 8.0 - Ceiling Height Floor SF = 16.32 S Walls SF = 114.89 SF Walls & Ceiling SF = 131.21 SF Perimeter of Ceiling = 16.17 LF DESCRIPTION _ QNTY UNIT COST TOTAL Clean the walls and eiling - Heavy 131.21 SF @ 0.31 = 40.68 Clean door / windo opening (per side) 1.00 EA @ 8.66 - 8 66 Clean door (per side 2.00 EA @ 7.20- . 14.40 Clean toilet 1.00 EA @ 14.54- . 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink - pedestal 1.00 EA @ 16.46 = 16.46 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean medicine cabi net 1.00 EA @ 9.38 = 9.38 Clean baseboard 11.00 LF fin; 0.23 = 2.53 Clean floor - tile - H avy clean 16.32 SF @ 0.65 = 10.61 Clean bath accesso 2.00 EA @ 4.75 = 9.50 Clean baseboard hea er - interior and exterior 2.00 LF @ 17.27 = 34.54 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switc h 5.00 EA @ 2.32 = 11.60 Deodorize building - Ozone treatment 130.56 CF @ 0.03 = 3.92 194.94 ROOM : M ster Bedroom Subroom 0: Mas ter Bedroom 8.0 - Ceiling Height Subroom 1: CLO SET 8.0 - Ceiling Height Subroom 2: VA ITY_AREA 8.0 - Ceiling Height Floor SF = 242.86 S Walls SF = 591.59 SF Walls & Ceiling SF = 834.45 SF Perimeter of Ceiling = 95.77 LF DESCRIPTION - QNTY UNIT COST TOTAL Clean the walls and c iling - Heavy 834.45 SF @ 0.31 = 258.68 Clean door / window pening (per side) 7.00 EA @ 8.66 = 60.62 Clean window unit (p ,-r side) 10 - 20 SF - Heavy 3.00 EA @ 14.10 = 42.30 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Detach & Reset Interi r door - Colonist - pre-hung unit - CHARGES 1.00 EA @ 34.00 = 34 00 ARE FOR DETACH ONLY . Detach & Reset Casin g - 2 1/4" - CHARGES ARE FOR DETACH 34.00 LF @ 0.82 = 27 88 ONLY . Clean door hardware Heavy 2.00 EA @ 6.23 = 12.46 Clean window stool apron 15.00 LF @ 0.59 = 8.85 Clean drapery hardwa a 2.00 EA @ 11.23 = 22.46 Clean shelving - woo - closet linen 16.00 LF @ 0.61 = 9.76 Clean closet organize and rod 6.00 EA @ 25.41 = 152.46 Clean baseboard 70.09 LF @ 0.23 = 16.12 Clean cabinetry - low r - inside and out 3.00 LF @ 8.09 = 24.27 1689-MENAPACE-BIL 1/19/2011 Page:6 CONTINUED - Master Bedroom Floor SF = 242.86I DESCRIPTION SF Walls SF = 591.59 SF Walls & Ceiling SF = 834.45 SF NTY Perimeter of Ceiling = 95.77 SF UNIT COST TOTAL Clean countertop 12.00 SF @ 0.49 = 5 88 Clean sink 1.00 EA @ 8.66 = . 8 66 Clean sink faucet 1.00 EA @ 6.46 = . 6 46 Clean mirror 15.00 SF @ 0.49 = . 7 35 Clean floor - tile 33.97 SF @ 0.49 = . 16 65 Move then reset iter >s as needed to clean structure 1.00 EA @ 60 89 = . Clean floor . 60.89 242.86 SF @ 0.33 = 80 14 Clean baseboard hea ter - interior and exterior 8.00 LF @ 17 27 = . Clean thermostat . 138.16 1.00 EA @ 8.50 = 8 50 Clean outlet or switc h 5.00 EA @ 2.32 = . 11 60 Clean wood floor 242.86 SF @ 0.53 = . 128 72 Deodorize building Ozone treatment 1,942.85 CF @ 0.03 = . 58.29 1215.56 ROOM : Sh ower Subroom 0: Sb wer 8.0 - Ceiling Height Floor SF = 41.85 S Walls SF = 180.08 SF Walls & Ceili ng SF = 221.93 SF Perimeter of Ceiling = 25.98 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and c eiling - Heavy 221.93 SF @ 0.31 = 68 80 Clean door / window opening (per side) 2.00 EA @ 8.66 = . 17.32 Clean window unit ( per side) 3 - 9 SF - sidelite 1.00 EA @ 7.02 = 7 02 Clean baseboard 14.32 LF @ 0.23 = . 3.29 Detach & Reset Bas board - 2 1/4" - CHARGES ARE FOR DETACH 14.32 LF @ 1 16 = ONLY . 16.61 Clean stud wall 10.00 SF @ 0.52 = 5.20 Seal stud wall for odo r control 10.00 SF @ 0.62 = 6.20 Remove Batt insulati n - 4" - R I I 10.00 SF @ 0.25- 2.50 Detach & Reset Toil t - CHARGES ARE FOR DETACH ONLY 1.00 EA @ 76 50 = Clean toilet 1.00 EA @ . 14.54 = 76.50 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean shower curtain rod 1.00 EA @ 4.68 = 4.68 Clean medicine cabin et 1.00 EA @ 9.38 = 9.38 Clean bath accessory 3.00 EA @ 4.75 = 14.25 Remove Fiberglass sh ower unit - 3 piece unit 1.00 EA @ 54.27 = 54.27 Remove P-trap assem bly - ABS (plastic) 1.00 EA @ 5.43 = 5.43 Clean floor - tile - He ivy clean 41.85 SF @ 0.65 = 27.20 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Deodorize building - zone treatment 334.79 CF @ 0.03 = 10.04 Clean stud wall 45.00 SF @ 0.52 = 23.40 Clean wall and floor s heathing 57.00 SF @ 0.19 = 10.83 1689-MENAPACE-BI L 1/19/2011 Page:7 Floor SF = 41.85 $F DESCRIPTION _ Seal walls behinds o get all structural itet r Remove Batt insula it 2nd Level ROOM : H; Subroom 0: Ha Subroom 1: CI Floor SF = 79.90 Si DESCRIPTION 8.0 - Ceiling Height 8.0 - Ceiling Height Walls SF = 329.53 SF Walls & Ceiling SF = 409.44 SF Clean the walls and eiling - Heavy 409.44 SF @ 0.31 = 126 93 Clean door / window opening (per side) 8.00 EA @ 8.66 = . 69 28 Clean door (per side 2.00 EA @ 7.20 = . 14 40 Clean door hardware - Heavy 1.00 EA @ 6.23 = . 6 23 Clean baseboard 35.08 LF @ 0.23 = . 8 07 Clean shelving - wo d 12.00 LF @ 0.61 = . 7 32 Remove Carpet pad 79.90 SF @ 0.08 = . 6 39 Remove Carpet 79.90 SF @ 0.19 = . 15 18 Clean floor 79.90 SF @ 0.33 = . 26 37 Clean baseboard beat er - interior and exterior 3.00 LF @ 17.27 = . 51 81 Clean thermostat 1.00 EA @ 8.50 = . 8 50 Clean outlet or switch 5.00 EA @ 2.32 = . 11 60 Deodorize building - zone treatment 639.23 CF @ 0.03 = . 19.18 371.26 ROOM : FR dRm Subroom 0: FR dRm 8.0 - Ceiling Height Subroom 1: CLOSET 8.0 - Ceiling Height Subroom 2: CL3 8.0 - Ceiling Height Floor SF = 191.92 S Walls SF = 512.00 SF Walls & Ceiling SF = 703.92 SF DESCRIPTION Clean the walls and ceiling - Heavy 1689-MENAPACE-BILL CONTINUED - Shower Walls SF = 180.08 SF Walls & Ceiling SF = 221.93 SF Perimeter of Ceiling = 25.98 SF ONTV UNIT C(lfiT rngr A v .r that was removed - spray cans will be used to 1.00 EA (u - 4" - R13 behind shower area 45.00 SF (a) 703.92 SF @ 180.00 180.00 0.25 - 11.25 583.47 Perimeter of Ceiling = 56.77 LF UNIT COST TOTAL Perimeter of Ceiling = 79.83 LF UNIT COST TOTAL 0.31 = 1/19/2011 218.22 Page: 8 CONTINUED - FR BdRm Floor SF = 191.92 SF Walls SF = 512.00 SF DESCRIPTION Walls & Ceiling SF = 703.92 SF NTY Perimeter of Ceiling = 79.83 SF UNIT COST TOTAL Clean door / window opening (per side) 8.00 EA @ 8.66 = 69 28 Clean window unit per side) 10 - 20 SF - Heavy 2.00 EA @ 14.10 = . 28 20 Clean door (per side 8.00 EA @ 7.20 = . 57 60 Clean door hardwar e - Heavy 4.00 EA @ 6.23 = . 24 92 Clean window stool & apron 6.00 LF @ 0.59 = . 3 54 Clean drapery hardw are 2.00 EA @ 11.23 = . 22 46 Clean closet shelf an d rod per lineal foot 6.00 LF @ 0.74 = . 4 44 Clean closet organiz r and rod - Small 1.00 EA @ 19.52 = . 19 52 Clean phone, TV, or speaker outlet 1.00 EA @ 1.77 = . 1 77 Clean baseboard 55.83 LF @ 0.23 = . 12.84 Move then reset iten s as needed to clean structure 1.00 EA @ 60.89 = 60 89 Clean baseboard hea er - interior and exterior 8.00 LF @ 17.27 = . 138.16 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switc 5.00 EA @ 2.32 = 11.60 Seal/prime the walls and ceiling - one coat 703.92 SF @ 0.40 = 281.57 Paint the walls and c iling - two coats - 2 colors 703.92 SF @ 038 = 549.06 Paint door/window tr im & jamb - 2 coats (per side) 8.00 EA @ 22.42 = 179.36 Paint baseboard - two coats 55.83 LF @ 1.04 = 58.06 Seal & paint base sh or quarter round 55.83 LF @ 0.58 = 32.38 Seal & paint closet s elving - single shelf 2.00 EA @ 37.20 = 74 40 Detach & Reset Shel ving - wire (vinyl coated) 3.00 LF @ 7.88 = . 23.64 Clean wood floor 191.92 SF @ 0.53 = 101 72 Deodorize building - Ozone treatment 1,535.33 CF @ 0.03 = . 46.06 2028.19 ROOM : FN% BdRm Subroom 0: FM dRm 8.0 - Ceiling Height Subroom 1: CL SET 8.0 - Ceiling Height Floor SF =150.62 S11 Walls SF = 414.25 SF Walls & Ceiling SF = 564.87 SF Perimeter of Ceiling = 61.50 LF DESCRIPTION QNTY UNIT COST TOTAL Deodorize building - zone treatment 1,204.94 CF @ 0.03 = 36.15 36.15 ROOM : FL dRm Subroom 0: FL dRm 8.0 - Ceiling Height 1689-MENAPACE-BILE; 1/19/2011 Page:9 Subroom 2: C1IOSET Subroom 1: CIA Floor SF = 191.69 DESCRIPTION 8.0 - Ceiling Height 8.0 - Ceiling 1-Icight Walls SF 487.27 SF Walls & Ceiling SF = 678.96 SF Clean the walls and °eiling - heavy Clean door / window opening (per side) Clean window unit per side) 10 - 20 SF - heavy Clean door (per side Clean door hardware - Heavy Clean window stool & apron Clean drapery hard are Clean closet shelf a rod per lineal foot Clean baseboard Move then reset ite s as needed to clean structure Clean baseboard heater - interior and exterior Clean thermostat Clean outlet or switch Seal/prime the walls acid ceiling - one coat Paint the walls and c fling - two coats - 2 colors Paint door/window t im & jamb - 2 coats (per side) Paint baseboard - two coats Paint door slab only 2 coats (per side) Seal & paint base shoe or quarter round Seal & paint closets elving - single shelf Clean wood floor Deodorize building - Ozone treatment 678.96 SF @ 8.00 EA @ 2.00 EA @ 4.00 EA (cr) 2.00 EA @ 6.00 LF @ 2.00 EA @ 10.00 LF @ 51.87 LF @ 1,00 EA @ 8.00 LF @ 1.00 EA @ 5.00 EA @ 678.96 SF @ 678.96 SF @ 8.00 EA @ 51.87 LF@ 4.00 EA @ 51.87 LF @ 2.00 EA @ 191.69 SF@ 1,533.53 CF @ 0.31 - 210.48 8.66- 69.28 14.10 = 28.20 7.20- 28.80 6.23 = 12.46 0.59 = 3.54 11.23 = 22.46 0.74 = 7.40 0.23 = 11.93 60.89 = 60.89 17.27 = 138.16 8.50 = 8.50 2.32 = 11.60 0.40 = 271.58 0.78 = 529.59 22.42 = 179.36 1.04 = 53.94 21.95 = 87.80 0.58 = 30.08 37.20 = 74.40 0.53 = 101.60 0.03 = 46.01 1988.06 ROOM : Ba h 4 Subroom 0: Bat 4 8.0 - Ceiling Height Subroom 1: SW 8.0 - Ceiling Height Floor SF = 22.79 SF Walls SF = 165.70 SF Walls & Ceiling SF =188.49 SF Perimeter of Ceiling = 26.60 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and W iling - Heavy 188.49 SF @ 0.31 = 58 43 Clean door / window opening (per side) 2.00 EA @ 8.66 = . 17 32 Clean drapery hardwa re 1.00 EA @ 11.23 = . 11.23 Clean window unit (pe r side) 3 - 9 SF 1.00 EA @ 7.02 = 7 02 Clean cove base mold ng - rubber or vinyl 18.04 LF @ 0.22 = . 3.97 Clean floor - tile - Hea vy clean 22.79 SF @ 0.65 = 14.81 Clean ceramic tile 83.93 SF @ 0.36 = 30.21 Clean tub / shower fau cet 1.00 EA @ 9.37 = 9 37 Clean shower door 1.00 EA @ 11.86 = . 11.86 1689-MENAPACE-131L 1/19/2011 Page: 10 Perimeter of Ceiling = 81.13 LIT UNIT COST TOTAL CONTINUED - Bath 4 Floor SF = 22.79 SF Walls SF = 165.70 SF Walls & Ceiling SF = 188.49 SF Perimeter of Ceiling = 26.60 SF DESCRIPTION QNTY UNIT COST TOTAL Clean bath accessor y 2.00 EA @ 4.75 = 9.50 Clean toilet 1.00 EA @ 14.54 = 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink 1.00 EA @ 8.66 = 8.66 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean medicine cabi net - Large 1.00 EA @ 14.12 - 14.12 Clean vanity - inside and out 1.50 LF @ 7.09 = 10.64 Clean baseboard hea ter - interior and exterior 3.00 LF @ 17.27 = 51.81 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or swit h 5.00 EA @ 2.32 = 11.60 Floor protection - pl stic and tape - 10 mil 15.60 SF @ 0.22 = 3.43 Seat/prime the surfa a area - one coat 104.56 SF @ 0.40 = 41.82 Paint the surface are - two coats - 2 colors 104.56 SF @ 0.78 = 81.56 Paint door or windo w opening - 2 coats (per side) 1.00 EA @ 22.42 = 22.42 Deodorize building Ozone treatment 182.35 CF @ 0.03 = 5.47 457.91 ROOM : R1 , BdRm Subroom 0: RL BdRm 8.0 - Ceiling Height Subroom 1: CL OSET 8.0 - Ceiling Height Floor SF = 121.99 S Walls SF = 375.90 SF Walls & Ceiling SF = 497.89 SF Perimeter of Ceiling = 58.33 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and eiling - Heavy 497.89 SF @ 0.31 = 154.35 Clean door / window opening (per side) 6.00 EA @ 8.66 = 51.96 Clean window unit ( er side) 10 - 20 SF -Heavy 2.00 EA @ 14.10 = 28.20 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Clean door hardware - Heavy 1.00 EA @ 6.23 = 6.23 Clean door - bypass et (per side) 2.00 EA @ 11.69 = 23.38 Clean window stool apron 6.00 LF @ 0.59 = 3.54 Clean drapery hardw are 2.00 EA @ 11.23 = 22.46 Clean baseboard 41.72 LF @ 0.23 = 9.60 Move then reset item s as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean closet shelf an rod per lineal foot 16.00 LF @ 0.74 = 11.84 Clean baseboard hea r - interior and exterior 6.00 LF @ 17.27 = 103.62 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 Seal/prime the surfac e area - one coat 401.50 SF @ 0.40 = 160.60 Paint the surface area - two coats - 2 colors 401.50 SF @ 0.78 = 313.17 Remove Cedar closet lining 96.40 SF @ 0.27 = 26.03 1689-MENAPACE-BI L 1/19/2011 Page: 11 CONTINUED - RL BdRm Floor SF = 121.99 8F Walls SF = 375.90 SF Walls & Ceiling SF = 497.89 SF Perimeter of Ceiling = 58.33 SF DESCRIPTION NTY UNIT COST TOTAL Detach & Reset Tri m board - 1" x 6" - installed (pine) - CHARGES ARE 16.00 LF @ 1.12 17 92 FOR DETACH ON LY . Detach & Reset She lving - 16" - in place - CHARGES ARE FOR 16.00 LF @ 3.47 = 55 52 DETACI I ONLY . Paint door/window rim & jamb - 2 coats (per side) 6.00 EA @ 22.42 -= 134.52 Paint baseboard - t ,, W coats 41.72 LF @ 1.04 =- 43.39 Paint door slab only - 2 coats (per side) 2.00 EA @ 21.95 _ 43.90 Paint bypass door s - slab only - 2 coats (per side) 2.00 EA @ 34.14 = 68.28 Seal & paint base sh a or quarter round 39.72 LF @ 0.58 = 23.04 Clean wood floor 121.99 SF @ 0.53 = 64.65 Deodorize building Ozone treatment 975.94 CF @ 0.03 = 29.28 1490.87 ROOM : Ba throom 2 Subroom 0: Bat room 2 8.0 - Ceiling Height Subroom 1: CL OSET 8.0 - Ceiling Height Floor SF = 61.83 S Walls SF = 295.33 SF Walls & Ceiling SF = 357.16 SF Perimeter of Ceiling = 44.83 LF DESCRIPTION QNTY UNIT COST TOTAL Clean more than the eiling - Heavy 220.60 SF @ 0.31 = 68.39 Clean door / window opening (per side) 4.00 EA @ 8.66 = 34.64 Clean door (per side 4.00 EA @ 7.20 = 28.80 Clean window unit (p er side) 10 - 20 SF 1.00 EA @ 10.03 = 10.03 Clean drapery hardw re 1.00 EA @ 11.23 = 11.23 Clean floor - tile - He avy clean 61.83 SF @ 0.65 = 40.19 Clean ceramic tile 136.56 SF @ 0.36 = 49.16 Clean shelving - woo 12.00 LF @ 0.61 = 7.32 Clean medicine cabi et 1.00 EA @ 9.38 = 9.38 Clean mirror 6.00 SF @ 0.49 = 2.94 Clean vanity - inside nd out 3.00 LF @ 7.09 = 21.27 Clean tub 1.00 EA @ 14.07 = 14.07 Clean tub / shower fa cet 1.00 EA @ 9.37 = 9.37 Clean shower curtain rod 1.00 EA @ 4.68 = 4.68 Clean toilet 1.00 EA @ 14.54 = 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink 1.00 EA @ 8.66 = 8.66 Clean countertop 6.00 SF @ 0.49 = 2.94 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean baseboard heat er - interior and exterior 4.00 LF @ 17.27 = 69.08 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switch 5.00 EA @ 2.32 = 11.60 1689-MENAPACE-BI L 1/19/2011 Page: 12 CONTINUED - Bathroom 2 Floor SF = 61.83 SP Walls SF = 295.33 SF Walls & Ceiling SF = 357.16 SF Perimeter of Ceiling = 44.83 SF DESCRIPTION NTY UNIT COST TOTAL Floor protection - pla stic and tape - 10 mil 61.83 SF 0.22 13.60 Seal/prime the surfac e area - one coat 220.60 SF @ 0.40 - 88.24 Paint the surface are - two coats - 2 colors 220.60 SF L? 0,78-- 172.07 Paint door or window opening - 2 coats (per side) 4.00 EA @ 22.42 = 89.68 Paint door slab only 2 coats (per side) 4.00 EA @ 21.95 == 87.80 Detach & Reset Doo r knob - interior 2.00 EA ( 24.87 = 49.74 Seal & paint closet s lelving - linen closet 1.00 EA @ 63.89 = 63.89 Deodorize building Ozone treatment 494.61 CF @ 0.03 = 14.84 1016.27 ROOM BdRm Subroom 0: RR BdRm 8.0 - Ceiling Height Subroom 1: CL SET2 8.0 - Ceiling Height Subroom 2: CL SET 8.0 - Ceiling Height Floor SF = 148.10 S Walls SF = 507.33 SF Walls & Ceiling SF = 655.44 SF Perimeter of Ceiling = 78.00 LF DESCRIPTION QNTY UNIT COST TOTAL Clean the walls and eiling - Heavy 655.44 SF @ 0.31 = 203.19 Clean door / window opening (per side) 7.00 EA @ 8.66 = 60.62 Clean window unit (p er side) 10 - 20 SF - Heavy 1.00 EA @ 14.10 = 14.10 Clean door (per side) 6.00 EA @ 7.20 = 43.20 Clean door hardware - Heavy 3.00 EA @ 6.23 = 18.69 Clean window stool apron 3.00 LF @ 0.59 = 1.77 Clean baseboard 56.00 LF @ 0.23 = 12.88 Clean closet shelf an rod per lineal foot 8.00 LF @ 0.74- 5.92 Move then reset item as needed to clean structure 1.00 EA @ 60.89 = 60.89 Clean baseboard heal er - interior and exterior 6.00 LF @ 17.27 = 103.62 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switc 5.00 EA @ 2.32 = 11.60 Seal/prime the surfac area - one coat 449.33 SF @ 0.40 = 179.73 Paint the surface are - two coats - 2 colors 449.33 SF @ 0.78 = 350.48 Paint door/window tr im & jamb - 2 coats (per side) 7.00 EA @ 22.42 = 156.94 Paint baseboard - tw coats 56.00 LF @ 1.04 = 58.24 Paint door slab only 1 coat (per side) 6.00 EA @ 14.54 = 87.24 Seal & paint base sho e or quarter round 54.00 LF @ 0.58 = 31.32 Remove Cedar closet lining 101.40 SF @ 0.27 = 27.38 Detach & Reset Trim board - 1" x 6" - installed (pine) - CHARGES ARE 16.00 LF @ 1.12 = 17.92 FOR DETACH ONL Y' Detach & Reset Shelv ing - 16" - in place - CHARGES ARE FOR 8.00 LF @ 3.47 = 27.76 DETACH ONLY Clean wood floor 148.10 SF @ 0.53 = 78.49 1689-MENAPACE-BI L 1/19/2011 Page: 13 CONTINUED - RR BdRm Floor SF = 148.10 S F Walls SF = 507.33 SF Walls & Ceiling SF = 655.44 SF Perimeter of Ceiling = 78.00 SF DESCRIPTION QNTY UNIT COST TOTAL Deodorize building - Ozone treatment 1,184.83 CF @ 0.03--- 35.54 1596.02 ROOM : Ba hroom Subroom 0: Bat room 8.0 - Ceiling Height Subroom 1: TU 8.0 - Ceiling Height Floor SF = 51.11 S Walls SF = 226.44 SF Walls & Ceiling SF = 277.56 SF Perimeter of Ceiling = 34.00 LF DESCRIPTION QNTY UNIT COST TOTAL Clean part of the wal s and ceiling - Heavy 227.56 SF @ 0.31 = 70.54 Clean door / window opening (per side) 3.00 EA @ 8.66 = 25.98 Clean door (per side) 2.00 EA @ 7.20 = 14.40 Clean window unit ( er side) 10 - 20 SF 1.00 EA @ 10.03 = 10.03 Clean door / window opening (per side) 1.00 EA @ 8.66 = 8.66 Clean floor - tile - He avy clean 52.44 SF @ 0.65 = 34.09 Clean ceramic tile 50.00 SF @ 0.36 = 18.00 Clean tub 1.00 EA @ 14.07 = 14.07 Clean tub / shower f cet 1.00 EA @ 9.37 = 9.37 Clean shower curtain rod 1.00 EA @ 4.68 = 4.68 Clean toilet 1.00 EA @ 14.54-- 14.54 Clean toilet seat 1.00 EA @ 3.16 = 3.16 Clean sink - pedestal 1.00 EA @ 16.46 = 16.46 Clean sink faucet 1.00 EA @ 6.46 = 6.46 Clean medicine cabin et 1.00 EA @ 9.38 = 9.38 Clean bath accessory 2.00 EA @ 4.75 = 9.50 Clean baseboard heat er - interior and exterior 4.00 LF @ 17.27 = 69.08 Clean thermostat 1.00 EA @ 8.50 = 8.50 Clean outlet or switc 5.00 EA @ 2.32 = 11.60 Floor protection - pla tic and tape - 10 mil 51.11 SF @ 0.22 = 11.24 Seal/prime part of the walls and ceiling - one coat 227.56 SF @ 0.40 = 91.02 Paint part of the wall and ceiling - two coats - 2 colors 227.56 SF @ 0.78 = 177.50 Paint door or window opening - 2 coats (per side) 3.00 EA @ 22.42 = 67.26 Paint door slab only - 2 coats (per side) 2.00 EA @ 21.95 = 43.90 Detach & Reset Door knob - interior - CHARGES ARE FOR DETACH 1.00 EA @ 12.44 = 12.44 ONLY Deodorize building - zone treatment 408.89 CF @ 0.03 = 12.27 774.13 1689-MENAPACE-BIL? 1/19/2011 Page: 14 Basment ROOM : Basement Subroom 0: Bas Subroom 1: OF Subroom 2: STA Floor SF = 1,118.88 DESCRIPTION ment 7.5 - Ceiling Height FSET-REAR 7.5 - Ceiling Height IRS 17.0 - Ceiling Height SF Walls SF = 1,150.85 SF Walls & Ceiling SF = 2,252.85 SF QNTY erimeter of Ceiling = 228.50 LF UNIT COST TOTAL Clean floor or roof j ist system 1,102.00 SF @ 0.65 = 716.30 Clean sheathing betw een joists 1,102.00 SF @ 0.19-- 209.38 Clean masonry 1,150.85 SF @, 0.39 = 448.83 Clean concrete on th floor 1,118.88 SF @ 0.20 = 223.78 Clean stair stringer - per side 48.00 LF @ 0.59 = 28.32 Clean stair tread - pe • side - per LF 72.00 LF @ 0.43 = 30.96 Remove Outlet/switc h 15.00 EA @ 3.64 = 54.60 Remove 220 volt cop per wiring run, box and receptacle 1.00 EA @ 5.43 = 5.43 Remove Clothes dry r vent - installed 1.00 EA @ 3.64 = 3.64 Remove Porcelain lig ht fixture 8.00 EA @ 6.03 = 48.24 Remove wiring - ave rage residence - copper wiring 1,118.88 SF @ 0.67 = 749.65 Remove Rough in pl umbing 1,118.88 SF @ 0.75 = 839.16 Remove Water heate - 60 gallon - Electric 1.00 EA @ 41.83 = 41.83 Remove Laundry to 1.00 EA @ 27.13 = 27.13 Remove Washing ma chine outlet box with valves 1.00 EA @ 19.73 = 19.73 Remove Sump pump - 1 1/2" discharge 1.00 EA @ 39.00 = 39.00 Clean I-beam and lal ay column - exposed 66.00 LF @ 1.00 = 66.00 Deodorize building - Ozone treatment 8,391.56 CF @ 0.03 = 251.75 Remove Dryer - Elec tric 1.00 EA @ 50.00 = 50.00 Remove Washer/Was hing Machine - Top-loading 1.00 EA @ 50.00 = 50.00 Remove Freezer 1.00 EA @ 50.00 = 50.00 3953.73 ROOM : Storage 1 Subroom 0: Stor age 1 7.5 - Ceiling Height Floor SF = 361.06 S Walls SF = 529.02 SF Walls & Ceiling SF = 890 .08 SF Perimeter of Ceiling = 77.00 LF DESCRIPTION QNTY UNIT COST TOTAL Clean floor or roof j 'st system 361.06 SF @ 0.65 = 234.69 Clean sheathing betw een joists 361.06 SF @ 0.19 = 68.60 Clean masonry 529.02 SF @ 0.39 = 206.32 Clean concrete on the floor 361.06 SF @ 0.20 = 72.21 Seal floor or ceiling j ist system 361.06 SF @ 0.74 = 267.18 1689-MENAPACE-BI L. 1/19/2011 Page: 15 CONTINUED - Storane 1 Floor SF = 361.06 ? F Walls SF = 529.02 SF Walls & Ceiling SF = 890.08 SF Perimeter of Ceiling = 77.00 SF DESCRIPTION QNTY UNIT COST TOTAL Paint plywood sheath ing 361.06 SF @ 0.41 = 148.03 Seal block with maso nry sealer 529.02 SF @ 0.62 = 327.99 Paint concrete the flo or 361.06 SF @ 0.47 = 169.70 Clean I-beam and la lay column - exposed 24.00 LF @ 1.00 = 24.00 Seal & paint I-beam and tally column 24.00 SF @ 1.39 = 33.36 (Material Only) Viny l window, horizontal sliding, 3-11 sf 2.00 EA @ 83.39 = 166.78 Deodorize building Ozone treatment 2,707.92 CF @ 0.03 = 81.24 1800.10 ROOM : Sto rage 2 Subroom 0: St0 age 2 7.5 - Cei ling Height Floor SF =149.54 Walls SF = 359.03 SF Walls & Ceiling SF = 508.57 SF Perimeter of Ceiling = 50.83 LF DESCRIPTION QNTY UNIT COST TOTAL Clean masonry 359.03 SF @ 0.39 = 140.02 Seal block with maso nry sealer 359.03 SF @ 0.62 = 222.60 Clean concrete on m ore than the floor 299.08 SF @ 0.20 = 59.82 Paint concrete more than the floor 299.08 SF @ 0.47 = 140.57 Deodorize building - Ozone treatment 1,121.56 CF @ 0.03 = 33.65 596.66 Attic ROOM : At is Subroom 0: Atti c 5.0 - Ceiling Height Floor SF = 1,116.97 SF Walls SF = 168.72 SF Walls & Ceiling SF =1,353.78 SF Perimeter of Ceiling =140.71 LF DESCRIPTION QNTY UNIT COST TOTAL Deodorize building - Ozone treatment 5,584.86 CF @ 0.03 = 167.55 167.55 ROOM : Mi scellaneous Subroom 0: Mis cellaneous 0.0 - Ceil ing Height 89-MENAPACE-BI L 1/19/2011 Page: l DESCRIPTION QNTY UNIT COST TOTAL Cleaning - further wlbrk - contents 1.00 EA O 8,409.23 8,409.23 Single axle dump truck - per load - including dump fees 2.00 EA (cr) 234.97 469.94 Emergency Service bill 1.00 EA @ 5,455.36 - 5,455.36 14334.53 Line Item Total Material Sales Tax Ca), 6.000% x Cleaning Mtl Tax Ca), 6.000% x Subtotal Overhead @ 10.0% x Profit a) 10.0% x Cleaning Sales Tax @ 6.000% x Summary 3,450.80 355.34 24,648.89 27,113.78 11,930.36 41,806.24 207.05 21.32 42,034.61 2,464.89 2,711.38 715.82 Total Estimated Cast Total $47,926.70 $47,926.70 1689-MENAPACE-13I?1, 1/19/2011 Page: 17 INVOICE ";CI RV 1 1.71 st Restoration & Remodeling 41 3-t.oaeridge Drive M.[: ddlL -town,. PA 17057 1:l ,one Nb. 717-232-5444 Fi.x 7L'7-232-1123 Fed I.D. 11-3712523 B: 11 'ro : _ _ Martin Menapace 108 Harrison Drive New Cumbelrland,PA 17070 Invoice No: 3528 Invoice Date:12/13/10 Service: Martin Menapace 108 Harrison Drive New Cumberland,PA 17070 Customer o: 1354 Job No.: 1675 Due Date:12/28/10 -W V-91 EMERGENCY SERVICE 5455'.36 Billing for Emergency Services. Replacing Invoice # 3436. STRUCTURE REPAIR 42471.34 Billing for Structure repair services completed. Replacing Invoice #3445 Subtotal I 47926.70 Sales Tax 0.00 Total Invoice Amount 47926.70 Prepared by; Law Office f Darrin C. Dinello 5405 Jones# wn Road Suite 101 Harrisburg, OA 171 12 xkpxe, made the ;1/d y of de'rio BRODY KHALSA REAL ESTATE TRUST .,1j,)7 (hereinafter called the Grantor), of the one part, and MENAPACE AND TRACK L. MENAPACE, HUSBAND AND WIFE (hereinafter called the Grantees), of the other part, 'Woawd, that the said Grantor for and in consideration of the sum of Two Hundred Fifty Seven Thousand ollars 001100 ($257,000.00) lawful money of the United States of America, unto him well and truly p id by the said Grantees, at or before the sealing and delivery hereof, the receipt whereof is hereby ack owledged, has granted, bargained and sold, released and confirmed, and by these presents does grant, argain and sell, release and confirm unto the said Grantees, as tenants by the entirety ALL THAT CERTAIN piece or parcel of land situate in the Borough of New Cumberland, Cumberland County, bounded and described as follows: BEGINNIN at a point on the easterly line of Harrison Drive one hundred eighty (180) feet measured northward! along said line from the northerly line of Harrison Drive and at the northerly line of Lot No. 10, Block "H" on the hereinafter mentioned Plan; thence northwardly along the easterly line of Harrison Drive by a curve to the left having a radius of two hundred ninety (290) feet an arc distance of seventy0 (70) feet to a point; thence northeastwardly along the southerly line of Lot No. 12, Block "H", one hundred fo -one and twenty-eight one-hundredths (141.28) feet to a point; thence southeastwardly along the wester) line of Lots Nos. 4 and 5, Block "H", one hundred six and seventeen one-hundredths (106.17) feet to a point; thence westwardly along the northerly line of' Lot No. 10, Block "H", one hundred fifty-four and sixteen one-hundredths (154.15) feet to the Place of BEGINNING. BEING Lot No. 11, Block "H" on the Plan of Section 4. Drexel Hills, said Plan being recorded in Plan Book 11, P ge 11, Cumberland County Records. BEING th same premises which Siri Neel Kaur Khalsa and James M. Brody, Husband and Wife, by D?eed dated September 25, 2003 and recorded October 14, 2003 in Cumberland County Record Book 259, Page 4388, granted and conveyed unto The Brody Khalsa Real Estate Trust, in fee. r 'yet,4ew ??'d all and singular the buildings and improvements, ways, streets, alleys, driveways, passages, w ters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders, rents, issues, and profits thereof; and ail the estate, right, title, interest, property, claim and demand whatsoever of him, the said grantor, as well at law as in equity, of, in and to the same. laves ml to ,fold the said lot or piece of ground described above, with the buildings and improveme is thereon erected, hereditaments and premises hereby granted, or mentioned and intended so to be, with he appurtenances, unto the said Grantees, their heirs and assigns, to and for the only proper use and beh f of the said Grantees, their heirs and assigns, forever. =l-t!rd the s?id Grantor, for himself and his heirs, executors and administrators, does, by these presents, covenant, g nt and agree, to and with the said Grantees, their heirs and assigns, that he, the said Grantor, and his heirs, all and singular the hereditaments and premises herein described and granted, or mentioned and intendeAl so to be, with the appurtenances, unto the said Grantees, their heirs and assigns, against him, the said Grantor, and his heirs, will warrant and defend against the lawful claims of all persons claiming by, through or under the said Grantor but not otherwise. rfn -M?ia •'i-the party of the first part has hereunto set his hand and sea(. Dated the day and year first ab ve written. IN HE PRESENCE OF US: {SEAL} Siri Neel Kaur IS: alsa, trustee Jamess Mansbacik %Wy, trustee 2 Commonwte nsyfi+arria ss County of On day of , before me, the undersigned Notary Public, personally appeared Siri N i Kaur Khaand James Mansback Brody, trus tee, known to me (or satisfactorily proveq the person is subscribed to the within instrument, and acknowledged that he executeEY.???'?.. M:qr for the purposes therein contained. = ` '+ '• IN WITNESS WHEREOF, I hereunto set my hand and official seal. t J;? Atl Notary Public' My commission expires The precise esidence and the complete post office address of the above-named Grantees/is: l!, 4 w A On! of the Grantees 3 i I Instrument N Recorded On * Instrument T Invoice Numl * Grantor - BR * Grantee - MI * Customer - S' * E`EES STATE TRAP STATE WRIT STATE JCS/ JUSTICE RECORDING RECORDER C COUNTY A ROD ARCH WEST SHO DISTRICT NEW CUPS BOROUGH TOTAL PA :OBERT P. ZIEGLER ECORDER OF DEEDS MBERLAND COUNTY OURTHOUSE SQUARE "ARLISLE, PA 17013 717-240-6370 ber - 200740924 79/2007 At 10:48:33 AM : - DEED -7596 User ID - KW iY KHALSA REAL ESTATE TRUST ?PACE, MARTIN KEME SETTLEMENT SERVICES rER TAX $2,570.00 TAX $0.50 CCBSS TO $10.00 EES - $12.50 DEEDS HOUSING $11.50 IVES FEE $2.00 S FEE $3.00 SCHOOL $1,285.00 $1,285.00 $5,179.50 I Certify this to be recorded in Cumberland County PA RECORDER O /D2, * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0"HO 11111111210111111 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r•,; n n Sheriff ti,• of?urulrfi?, ?'? '' ??- iIi_s,.,%r?`;l Jody S Smith °` `? ?.. Chief Deputy Richard W Stewart C Solicitor?? Pr N SLV,..a,? Service 1st Restoration and Remodeling, LLC Case Number vs. Traci L. Menapace (et al.) 2011-4807 SHERIFF'S RETURN OF SERVICE 08/02/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 2, 2011 at 1530 hours, he was unable to serve a true copy of the within Notice and Complaint in Action Upon Mechanic's Lien Claim, upon the within named defendant, to wit: Martin Menapace. After several attempts the Notice and Complaint in Action Upon Mechanic's Lien Claim has expired. 08/02/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 2, 2011 at 1530 hours, he was unable to serve a true copy of the within Notice and Complaint in Action Upon Mechanic's Lien Claim, upon the within named defendant, to wit: Traci L. Menapace. After several attempts the Notice and Complaint in Action Uoon Mechanic's Lien Claim hac aYnirari SHERIFF COST: $61.44 August 02, 2011 NOTARY Affirmed and subscribed to before me this day of ?- oo v , tr ?nerir7 E.e. ,rt(, I I SERVICE 1 ST RESTORATION AND REMODELING LL IN THE COURT OF COMMON PLEAS , C, OF CUMBERLAND COUNTY Claimant PENNSYLVANIA , V. MARTIN MENAPACE and TRACI L 'MECHANIC'S LIEN CLAIM ,_.. _ . MENAPACE, NO. 2011-04807 M Owners ; = C= .<> PRAECIPE TO REINSTATE COMPLAINT -s, CD iZ TO THE PROTHONOTARY: Please reinstate the Complaint in the above-referenced matter. DATED: August 15, 2011 Thomas S. Beckley, Esquire BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, PA 17108-1998 (717) 233-7691 Attorney for Claimant Service I" Restoration & Remodeling, LLC QM E- D.w P CkN ? SERVICE lst RESTORATION AND REMODELING, LLC, Plaintiff V. MARTIN MENAPACE and TRACI L. MENAPACE, Defendant : IN THE COURT OF COMMON PLEA; : CUMBERLAND COUNTY, PEN1q ,VJikIA= • rn ? F '' ._..Jr r- No. 2011-04807 < C=) c MECHANIC'S LIEN CLAIM PRELIMINARY OBJECTIONS OF DEFENDANTS TO PLAINTIFF'S COMPLAINT IN ACTION UPON MECHANIC'S LIEN CLAIM AND NOW comes defendants, Martin Menapace and Traci L. Menapace, by their attorney, Kent H. Patterson, and file these preliminary objections. 1. Plaintiff's complaint requests judgment in the amount of the mechanic's lien claim of $47,926.70 which it filed and which is attached as an exhibit to the complaint. 2. Paragraph 4 of the mechanic's lien claim states that it is filed under a contract between defendants and plaintiff wherein plaintiff "agreed to provide various restoration services to Menapace's real property." Attached to the mechanic's lien claim is an exhibit containing a "bill" which purports to set forth the description of the work performed and prices charged which totals $47,926.70. Also attached as part of the exhibit is an "invoice" for the total amount of $47,926.76 which is itemized as $5,455.36 for emergency services and $42,471.34 for structural repair. The "bill" does not describe any emergency services. FAILURE OF PLEADING TO CONFORM TO LAW OR RULE OF COURT 3. Plaintiff's complaint does not comply with The Mechanics' Lien Law of 1963, 49 P.S. Section 1503(5) in that it does not properly identify the contract between plaintiff and defendant. It does not provide the date, the agreed amount or the terms of the contract. 4. Plaintiff's complaint is contrary to The Mechanics' Lien Law of 1963, 49 P.S. Section 1503(6) in that it does not state the character of the labor and/or materials furnished and prices charged for the emergency services. INSUFFICENCY IN A PLEADING 5. Plaintiff's complaint is contrary to Pa.R.C.P 1019(h) and (i) in that it does not state whether the contract between the parties is oral or written and if written, does not attach a copy of the contract. LEGAL INSUFFICANCY OF COMPLAINT (DEMURRER) 6. Plaintiff's complaint fails to state a cause of action in contract in that it does not state any agreement between the parties as to the work to be performed, the prices to be charged or any terms of the agreement. - 2 - WHEREFORE, defendant requests your honorable court to dismiss plaintiff's complaint and discharge the mechanic's lien. Respectfully submitted, Kent H. Patterson Attorney for Defendants 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 - 3 - SERVICE 1st RESTORATION AND REMODELING, LLC, Plaintiff V. MARTIN MENAPACE and TRACI L. MENAPACE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2011-04807 MECHANIC'S LIEN CLAIM CERTIFICATE OF SERVICE AND NOW, this o day of 195kL,4.? 2011 I, Kent H. Patterson, hereby certify that I this day served the within defendants' foregoing preliminary objections to plaintiff's complaint by depositing a copy of same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to counsel of record for plaintiff as follows: Thomas S. Beckley, Esquire Beckley & Madden P.O. Box 11998 Harrisburg, PA 17108-1998 - /A,-,?A?Or7 K nt H. Patterson Attorney for Defendants 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 SERVICE 1ST RESTORATION AND REMODELING, LLC, Plaintiff V. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants 0000 "ft"%I%t *00 ait.0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION NO: 2011-4807 IN RE: DEFENDANTS' PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT IN ACTION UPON A MECHANIC'S LIEN BEFORE EBERT, MASLAND and PLACEY, JJ. • . 0 eitsi•PIf1 AND NOW, this 9th day of January, 2012, upon consideration of Defendants' Preliminary Objections to Plaintiff's Complaint in Action Upon a Mechanics Lien, and following oral argument held on January 6, 2012, Defendant's Preliminary objections are overruled. By the Court, Thom A Placey C.P.J. Distribution List: ? Thomas S. Beckley, Esq. -0X ?- 212 North Third Street ; Harrisburg, PA 17101 For Plaintiff ?" - Xo OD CD ? Kent H. Patterson, Esq. 221 Pine Street 0 Harrisburg, PA 17101 For Defendants 60p;,-s iKa de-d / ?9?ia I, SERVICE 1st RESTORATION AND : IN THE COURT OF COMMON PLEAS REMODELING, LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 2011-04807 MARTIN MENAPACE and TRAC I L. MENAPACE, Defendant MECHANICS' LIEN CLAIM -a= - n cA a ANSWER WITH NEW MATTER TO COMPLAINT IN ACTION ;0 c mt= c) UPON MECHANIC'S LIEN CLAIM 37 ??- i =-n 320 c)-r, ?? AND NOW come defendants, Martin Menapace and Traci o0 ? - rn Menapace, by their attorney, Kent H. Patterson, and file this answer as follows: 1. Admitted. 2. Admitted. 3. Admitted in part and denied in part. It is admitted that plaintiff filed the mechanic's lien claim. It is denied that the lien was properly filed, that the work performed by plaintiff was as described in the claim, that the work which plaintiff claims to have performed was completed on the date alleged or on any other date, that plaintiff performed work in the amount claimed to be due and that defendants' owe plaintiff the amount claimed to be due. NEW MATTER 4. The averments set forth in paragraphs 1 through 3 of defendants' answer are incorporated by reference. 5. Plaintiff breached its contract to perform restoration and other work and services to defendants' real property by stopping work in December, 2010 and failing to complete the work which it had agreed to perform and the materials it had agreed to supply. 6. Plaintiff expressly and impliedly warranted that it would do the work on defendants' real property in a good and workman like manner and plaintiff breached its warranties by failing to do the work in a good and workman like manner. 7. The work done by plaintiff on defendants' real property was defective. 8. The work done by plaintiff on defendants' real property was negligently performed. 9. Plaintiff's failure to perform the work in a good and workmanlike manner and otherwise providing negligent and defective work has resulted in damages to defendants in that they have or will have to expend monies to correct the work. 10. The failure of plaintiff to complete the work which it had agreed to perform has resulted in damages to defendants in that they have or will have to expend monies to complete the work. 11. The costs and damages which defendants have incurred as a result of plaintiff's failure to properly perform and complete the work constitute a setoff against the amount plaintiff claims is owing to it or any other amount which would be determined defendants owe plaintiff. 12. During the course of doing work at defendants' real property, plaintiff negligently and/or intentionally destroyed and discarded numerous items of tangible personal property owned by defendants which has resulted in loss and damages to - 2 - defendants and defendants are entitled to the fair market value for those items. 13. Defendant Traci L. Menapace has no liability to plaintiff in that she is not a party to any contract or agreement with plaintiff. 14. Plaintiff does not have a proper lien against the real estate at 108 Harrison Drive, Borough of New Cumberland, Cumberland County, PA. WHEREFORE, defendants request your honorable court to dismiss plaintiff's complaint. Respectfully submitted, Kent H. Patterson Attorney for Defendants 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 - 3 - VERIFICATION I, Martin Menapace, verify that the statements in the within answer are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Mar in Menap ce Date: 2- 1 6 2 012 ..t SERVICE 1St RESTORATION AND REMODELING, LLC, Plaintiff V. MARTIN MENAPACE and TRACI L. MENAPACE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2011-04807 : MECHANICS' LIEN CLAIM CERTIFICATE OF SERVICE AND NOW, this /b day of F14`7 , 2012 I, Kent H. Patterson, hereby certify that I this day served the within defendants' answer to plaintiff's complaint by depositing a copy of same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to counsel of record for plaintiff as follows: Thomas S. Beckley, Esquire Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 Kent H. Patterson Attorney for Defendants 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 SERVICE IT RESTORATION AND REMODELING, LLC, Plaintiff V. MARTIN MENAPACE and TRACI L. MENAPACE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -0 rnw ^ _;.. mrn ? MECHANIC'S LIEN CLAIM n N rV rn NO. 2011-04807 vyco r PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER AND NOW comes the Claimant, Service 1St Restoration and Remodeling, LLC ("Service First"), who, by and through its attorneys, Thomas A. Beckley, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Reply to Defendants' New Matter, and, in support thereof, avers as follows: 4. Service 1St hereby incorporates the averments made in its Mechanic's Lien Claim and in its Complaint in Action Upon Mechanic's Lien Claim as though set forth here at length. 5. The allegations contained in paragraph 5 of Defendants' New Matter constitute legal conclusions to which no response is necessary. By way of further response, Defendants have failed and refused to pay Service 1St anything for its work on Defendants' real property. 6. The allegations contained in paragraph 6 of Defendants' New Matter constitute legal conclusions to which no response is necessary. 7. The allegations contained in paragraph 7 of Defendants' New Matter constitute legal conclusions to which no response is necessary. 8. The allegations contained in paragraph 8 of Defendants' New Matter constitute legal conclusions to which no response is necessary. 9. The allegations contained in paragraph 9 of Defendants' New Matter constitute legal conclusions to which no response is necessary. By way of further response, after reasonable investigation, Service 1St is without information or knowledge sufficient to form a belief as to whether Defendants have expended any monies to correct any alleged defective work. 10. The allegations contained in paragraph 10 of Defendants' New Matter constitute legal conclusions to which no response is necessary. By way of further response, after reasonable investigation, Service 1St is without information or knowledge sufficient to form a belief as to whether Defendants have expended any monies to correct any alleged defective work. 11. The allegations contained in paragraph 11 of Defendants' New Matter constitute legal conclusions to which no response is necessary. By way of further response, Defendants have failed to allege the amount of any setoff. 12. It is denied that Service 1St destroyed or discarded any of Defendants' tangible personal property. By way of further response, Defendants have failed to identify any tangible personal property which Service 1St allegedly destroyed or discarded. 13. The allegations contained in paragraph 13 of Defendants' New Matter constitute legal conclusions to which no response is necessary. By way of further response, this is an action against the real property owned by Defendants. 14. The allegations contained in paragraph 14 of Defendants' New Matter constitute legal conclusions to which no response is necessary. WHEREFORE, Plaintiff, Service 1St Restoration and Remodeling, LLC, respectfully requests the Court to enter a judgment in its favor, and against the Defendants, Martin Menapace and Traci L. Menapace, in the principal amount of $47,926.70 plus interest, costs of suit and such other and further relief as the Court may deem appropriate. 2 DATED: March 19, 2012 Of Counsel BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717) 233-7691 Respectfully submitted, Thomas A. Beckley, Esqu Thomas S. Beckley, Esquire Attorneys for Plaintiff Service 1 st Restoration and Remodeling, LLC VERIFICATION I, Jaime Novinger-Toigo, hereby verify that I am an adult individual; that I am President of Service 1" Restoration and Remodeling, LLC; and that I am authorized to make this statement on its behalf; that I have read the foregoing document, and that the facts set forth in the foregoing document are true to the best of my knowledge, or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Service 1st Restoration and Remo eling, LLC By: J ' e Novinger-Toigo, f9esident 4 SERVICE 1ST RESTORATION AND REMODELING, LLC, Plaintiff V. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants *000vom4b ""Jk4 2t %IALO INOW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY MECHANIC'S LIEN CLAIM CIVIL ACTION NO: 2011-4807 IN RE: PLAINTIFF'S MOTION TO COMPEL DISCOVERY RESPONSES AGAINST DEFENDANTS RULE TO SHOW CAUSE AND NOW, this 16th day of May, 2012, upon consideration of Plaintiffs' Motion to Compel Discovery Responses Against Defendants, a RULE is issued upon Defendants to show cause why the relief requested in Plaintiffs' Motion to Compel should not be granted. RULE RETURNABLE within 20 days from the date of this order. By the Court, Thomas A. Distribution List: ?Thomas S. Beckley, Esq. Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 For Plaintiff C.P.J. -<Y C1 ?} W Z s ? Kent H. Patterson, Esq. 221 Pine Street Harrisburg, PA 17101 For Defendants .? J ml 1, SERVICE I" RESTORATION AND REMODELING, LLC, Plaintiff V. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MECHANIC'S LIEN CLAIM NO. 2011-04807 ORDER AND NOW, this day of , 2012, after consideration of Plaintiffs, Service 1St Restoration & Remodeling, LLC. ("Service 1st"), Motion to Make This Court's Rule Issued on May 16, 2012, Absolute Regarding Plaintiff's Motion to Compel Defendants, Martin Menapace and Traci L. Menapace ("Defendants") to provide Answers to Plaintiffs First Set of Interrogatories and First Request for Production of Documents, it is hereby ORDERED that said Motion is GRANTED. Defendants shall provide Answers to Plaintiffs First Set of Interrogatories and First Request for Production of Documents within ten (10) days of the date of this Order. Thomas A. Piacey °*,mmon Pleas Judge Distribution: Thomas S. Beckley, Esquire P.O. Box 11998 N { Harrisburg, PA 17108-1998 zcu n- I/ Kent Patterson, Esquire :) 221 Pine Street s> ,t Harrisburg, PA 17101 =C) t ? ? 1 a `@s ma.14 '71 1 = We 1 SERVICE 1sT RESTORATION AND REMODELING, LLC, Plaintiff v. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants IN THE COURT OF COMMON P~A? OF CUMBERLAND COUNTY,-~;;`~~ ~~~ PENNSYLVANIA 6~., ~. c`~' .Y i~ ~ ~ MECHANIC'S LIEN CLAIM ~ ~.- ~' 2011-04807 NO ~ . ~~„. _, .. ~ ,~- .~~- PLAINTIFF'S MOTION FOR SANCTIONS TO PRECLUDE DEFENDANTS FROM INTRODUCING ANY EVIDENCE RELATING TO ANY DEFENSES, CLAIMS AND DAMAGES AS PLEADED BY DEFENDANTS PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 4019 ON ACCOUNT OF DEFENDANTS' FAILURE TO COMPLY WITH THIS COURT'S ORDER DATED JULY 18, 2012 Plaintiff, Service 1St Restoration & Remodeling, LLC, ("Service 1St"), by and through its attorneys, Thomas A. Beckley, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, moves this Court pursuant to Pennsylvania Rule of Civil Procedure 4019 for an Order precluding Defendants from introducing evidence relating to any claims, defenses and damages as pleaded by Defendants in their Answer and New Matter on account of Defendants' failure to provide Answers to Plaintiff s First Set of Interrogatories and First Request for Production of Documents, failure to respond to the Court's Rule, and failure to comply with the Court's Order dated July 18, 2012, and, in support thereof, avers as follows: 1. The underlying dispute arises out of the repairs Service 1St made to Plaintiffs' residence after Plaintiffs' residence suffered a fire ("Project"). .; .a: .a `~ ~~~ := ~ •-~~~ s,i 2. Due to Defendant's failure to pay Service ls`, Service ls` stopped working on the Project on February 15, 2011. To date, Service ls` has not received any payments from the Defendants for its work. 3. On June 6, 2011, Service ls` filed a mechanic's lien claim against Defendants' real property located at 108 Harrison Drive, New Cumberland, Pennsylvania, and on July 1, 2011, Service ls` filed a Complaint in Action Upon its Mechanic's Lien Claim. 4. On or about February 16, 2012, Defendants filed an Answer with New Matter in response to Service ls`'s Complaint. Service 15` filed a Reply to Defendants' New Matter on March 21, 2012. 5. In their New Matter, Defendants alleged that Service 1 S`'s work was defective, incomplete, and resulted in damage to Defendants' property. Defendants also alleged that Service 1 S` destroyed "numerous items" that belonged to Defendants. (Defendants' New Matter, ¶¶ 7-12.) The following are the relevant allegations Defendants made: 7. The work done by plaintiff on defendants' real property was defective. 8. The work done by plaintiff on defendants' real property was negligently performed. 9. Plaintiff s failure to perform the work in a good and workmanlike manner and otherwise providing negligent and defective work has resulted in damages to defendants in that they have or will have to expend monies to correct the work. 10. The failure of plaintiff to complete the work which it had agreed to perform has resulted in damages to defendants in that they have or will have to expend monies to complete the work. 11. The costs and damages which defendants have incurred as a result of plaintiff's failure to properly perform and complete the work ~ Defendants had originally filed preliminary objections to Service 15tis Complaint, however, by Order dated January 9, 2012, this Court (Judge Placey) overruled Defendants' preliminary objections in their entirety. 2 constitute a setoff against the amount plaintiff claims is owing to it or any other amount which would be determined defendants owe plaintiff. 12. During the course of doing work at defendants' real property, plaintiff negligently and/or intentionally destroyed and discarded numerous items of tangible personal property owned by defendants which has resulted in loss and damages to defendants and defendants are entitled to the fair market value for those items. 6. Defendants failed, however, to identify specifically any work that was defective, and they failed to state any specific personal items that Service 1 S` allegedly destroyed. 7. On March 16, 2012, because Defendants failed to identify any work which was allegedly defective, and failed to identify any personal items that were allegedly destroyed, Service ls` served its First Set of Interrogatories and First Request for Production of Documents on the Defendants. Pursuant to Pennsylvania Rules of Civil Procedure 4006 and 4009.12, Defendants' responses to Service 1 S`'s discovery requests were to be provided within 30 days (on or before April 16, 2012). A true and correct copy of Service ls`'s discovery requests are attached hereto as Exhibit A. 8. The following are the relevant discovery requests Service ls` made upon Defendants: Interrogatories 4. Set forth the basis for your allegation that Service ls` breached the contract as alleged in Paragraph 5 of your New Matter, and identify the work which you alleged Service ls` failed to complete and the materials which it failed to supply. 5. State in each and every way how Service 1 S`'s work was defective as alleged in Paragraph 7 of your New Matter. 6. Set forth your basis for alleging that Service 15`'s work was "negligently performed" as alleged in Paragraph 8 of your New Matter. 3 7. Set forth the exact amount of money you allegedly expended to correct Service lst's work as alleged in Paragraph 9 of your New Matter. For each amount identified, set forth the following: (a) To whom the payment was made and when it was made; (b) The reason for making the payment; and (c) The materials and/or labor supplied for the payment. 8. Identify all estimates (if any) you have obtained to correct and/or finish Service lst's alleged deficient and/or uncompleted work. 10. Set forth each and every item of "tangible personal property" which you allege Service 1St either negligently or intentionally discarded (see New Matter, Paragraph 12). 11. Set forth the value of each item identified in the preceding Interrogatory and your basis for each value listed. 15. Identify all home inspectors or other professionals you engaged to evaluate Service 1 St's work. For each person (or entity) identified, state whether the person (or entity) identified provided you with a written analysis or other opinion, and, if they did, the nature of the opinion or analysis. Document Requests 8. Copies of all purchase orders, contracts, work orders, or similar documents exchanged between you and any other contractor (if any) you hired to complete or repair Service lst's work on the Project. 9. Copies of all payment applications, invoices, requisitions for payment or similar documents which you received relating to the completion and/or correction of Service lst's work on the Project, if any. 10. All documents evidencing any payments you made to any third party relating to the completion or repair of Service lst's work on the Project, if any. 11. All photographs relating in any way to Service 1 St's work on the Project. 12. All documents identified in or requested to be identified in Service lst's First Set of Interrogatories directed to you. 4 __ _ _ ~ _ _ i 13. All documents that you intend to introduce at the trial of this matter. 14. All expert reports relating to the Project in any way regardless of whether the report relates to Service ls`'s work. 15. All documents evidencing the alleged costs and damages which you have incurred as set forth in Paragraph 11 of your New Matter. 16. All documents evidencing the items referenced (as well as their value) in Paragraph 12 of your New Matter which were allegedly destroyed and/or discarded. 9. After not receiving responses to its discovery requests and after several letters inquiring into their status, Service ls` filed a Motion to Compel on May 14, 2012. 10. On May 16, 2012, this Court (Judge Placey) entered a Rule to Show Cause on Defendants directing them to show cause why Service 15T's motion to compel should not be granted. The Rule was returnable within 20 days from the date of the Order. A true and correct copy of the Court's Rule is attached hereto as Exhibit B. 11. Defendants failed to respond to the Court's Rule. 12. After not having received a response to the Rule and/or to its discovery requests, Plaintiff filed a Motion to Make Rule Absolute on July 13, 2012. 13. On July 18, 2012, this Court (Judge Placey) entered an Order directing Defendants to file Answers to Service 1 S`'s First Set of Interrogatories and First Request for Production of Documents within ten (10) days of the date of the Court's Order. A true and correct copy of the Court's Order is attached hereto as Exhibit C. 14. On August 3, 2012, Service ls`'s counsel wrote a letter to Defendant's counsel requesting Defendants to provide answers to Service ls`'s discovery requests, or 5 Service 1St would have no choice but to file a motion for sanctions. A true and correct copy of Defendant's August 3, 3012, letter is attached hereto as Exhibit D. 15. Despite the Court's Order and several written requests from Service lsc's counsel, Defendants have failed and refused to supply any written responses to Service 1 Sc's discovery requests. 16. Defendants have had more than sufficient time to prepare and serve answers to Service 1 St's discovery requests. Furthermore, Defendants' answers to a lot of the discovery requests should be readily apparent (e.g., what personal property did Service lsc allegedly destroy). 17. Pennsylvania Rule of Civil Procedure 4019 provides as follows: (a)(1) The court may, on motion, make an appropriate order if (i) a party fails to serve answers, sufficient answers or objections to written interrogatories under Rule 4005; *** (viii) a party or person otherwise fails to make discovery or to obey an order of court respecting discovery. *** (c) The court, when acting under subdivision (a) of this rule, may make *~* (2) an order refusing to allow the disobedient party to support or oppose designated claims or defenses, or prohibiting such party from introducing in evidence designated documents, things or testimony, or from introducing evidence of physical or mental condition; *** (5) such order with regard to the failure to make discovery as is just. 6 Pa.R.C.P. No. 4019. 18. Under Rule 4019, the Court has the discretion to preclude a party from introducing evidence supporting a claim or defense where that party fails to comply with a court's discovery order. Hutchison by Hutchison v. Luddy, 611 A.2d 1280, 1292 (Pa.Super. 1992), appeal granted, 533 Pa. 660, 625 A.2d 1193 (1993), appeal dismissed, 538 Pa. 484, 649 A.2d 435 (1994) ("When a party or person fails to permit discovery, or fails to obey a court order respecting discovery, a court, on motion, may issue an order refusing to allow the disobedient party to support or oppose designated claims or defenses or prohibiting him from introducing in evidence designated, things or testimony.") See also, Smith v. Philadelphia Gas Works, 740 A.2d 1200 (Pa.Cmwlth. 1999) (court may preclude party from entering evidence where party fails to comply with a discovery order). 19. In this case, Defendants (1) failed to respond to the discovery requests, (2) failed to respond to the Court's Rule, and (3) failed to respond to the Court's Order. 20. Therefore, Defendants should be precluded from entering into evidence any documents, testimony or other evidence relating to the alleged defective work Service 1st performed, and the alleged damage Service 1st caused to their residence and/or to their personal property. 21. Pursuant to Local Rule 208.2(d), counsel for Service 1st faxed a copy of this motion to counsel for the Defendants to seek his concurrence in the motion. The undersigned did not hear back from Defendants' counsel prior to mailing the motion to the Prothonotary's Office for filing. 7 WHEREFORE, Plaintiff, Service ls` Restoration & Remodeling, LLC, respectfully requests the Court to enter an Order precluding the Defendants, Martin Menapace and Traci L. Menapace, from introducing evidence relating to any defenses, claims and damages as pleaded in their Answer and New Matter, for an award of its attorneys' fees, and for such other and further relief as this Court deems appropriate. DATED: August 31, 2012 Of Counsel BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717) 233-7691 Respectfully submitted Thomas A. eckley, ire ~~c~~ Thomas S. Beckley, Esquire Attorneys for Plaintiff Service ls` Restoration & Remodeling, LLC 8 V ~-'' BECKLEY& MADDEN ATTORNEYS AT LAW CxnxHExxY CoVRT 212 Noama Tsatn 9mIt~nT POET OFFIQEHOR 1199A HARRISBURG, PENNSYLVANIA 17108-1998 PHONE: (7171238-7891 FA%: 17171238-3740 E-MaII.: bOC~CyQpfl.OC[ 461013 March 16, 2012 Kent H. Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 RE: Service First Restoration & Remodeling, LLC v. Menapace Dear Kent: Enclosed you will find Service ls`'s First Set of Interrogatories and First Request for Production of Documents in the above-referenced matter. Very truly yoti~rs, BECKLEY & MADDEN v .._ .: ~ r „.- _:.-- Thomas S. Beckley Enclosure Cc: Service 1 S` Restoration & Remodeling, LLC ..., , ,, P, ~, SERVICE 1 s ~ RhS'hURA'1'ION AND IN 'TIiE COURT OI{ COMMON PLEAS REMODELING, I,L,C, OF CUMBERLAND COUNTY, Plaintiff PF,NNSYLVANIA v. MECHANIC'S LIEN CLAIM MARTIN MENAPACE and TRACI L. MENAPACE, NO. 2011-04807 Defendants DATED: March 16, 2012 TO: Martin and Traci L. Menapace c/o Kent Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 FROM: Service 15` Restoration & Remodeling, LLC SERVICE 1sT .RESTORATION & REMODELING, LLC'S, FIRST SET OF INTERROGATORIES TO DEFENDANTS MARTIN MENPACE AND TRACI L. MENAPACE You are required to respond to these Interrogatories within thirty (30) days of pursuant to Pennsylvania Rule of Civil Procedure 4005. I. DEFINITIONS AND INSTRUCTIONS 1. "Documents" is used in its broadest sense and means the original, or, unavailable, a complete copy, and each copy which is non-identical because of margin notations, revisions or otherwise, of any medium, upon which anything is recorded or fro: which anything can be recorded to include, without limitation, the following: letter correspondence, memorandum, notes, reports, records, pictures, videos, e-mails, electronic ar other recordings, diaries, calendars, papers, data sheets, bills, contracts, computer printout information in computers, information stored on any electronic media, inter-office and intr. if __ _ _ _, ~~. ,. .~ ~ office communications, logs, drawings, graphs and charts. 2. "Person" means any natural person, corporation, partnership, association, or of entity. 3. "You" means Defendants, Martin Menapace and 'Traci L. Menapace., incl without limitation, your managing agents, agents, employees, and/or representatives. 4. "Identify," when used in reference to a communication, means to set forth: a. The identification of the person by whom, and each person, to whom ear such communication was made and all persons present at the time; b. The date and time the communication was made or activity tools place; c. The place at which it occurred; d. The means by which it occurred (e.g., by telephone, electron transmission, letter, or in person); acid e. The substance of the communication or activity. 5. "Identity" or "Identification," when used in reference to a person, means to s forth the person's: a. Full name; b. Present or last known home address and telephone number; c. Present or last known business address and telephone number; d. Present or last kno~tni employer or affiliation; e. Title, rank or position at time of involvement with you; and f. For persons other than natural persons the name and address of officer and general manager. 6. "Identify," when used in reference to documents, means to set forth: a. The nature of the documents (e.g., letter, memorandum, contract, per 2 ~, notes); b. The date thereof; c. 1'he identification of each author, addressee, and recipient; d. The title of the document and short description of its subject matter; e. Any file number, identifying marls, or code of the document; and f. The location of the document by address, city, and state, and t e identification of the present custodian. 7. The plural includes the singular, and vice versa. Masculine includes feminin , and vice versa. 8. The conjunctive includes the disjunctive, and vice versa. 9. "Everything" when used herein means all things, including, but not limited t , communications, activities and documents, contracts, and telephone calls. 10. "Every" means the same as "everything." 11. "Activity" when used herein means every contract, event, or thing other than a communication or document. 12. These Interrogatories are continuing in nature which requires you to suppleme t your answers should you and/or your agents obtain further information at any point. 3 II. INTERROGATORIF,S I. Identify all documents constituting or evidencing communications (including, wi limitation, letters, emails, and fax transmissions) exchanged between you and Service 1 S` Restoration & Remodeling, LLC ("Service 1 s~") relating to the work that Service I st perform d or was supposed to perform on your residence located at 108 I iarrison Drivc, New Cumber Pennsylvania ("Project") 2. Identify all insurance carriers that provided insurance on your residence which in any way to the Project. For each carrier identified, set forth the limits of the coverage, type of coverage provided, and the name of the carrier. In answering this Interrogatory, you simply provide a copy of the policy(ies). 3. Set forth the total amount of payments you received from any insurance carrier for t damage caused to your residence which relate in any way to the work Service ls` performed. forth the amount of each payment, and the date you received each payment. State whether payments are still owed to you from an insurance carrier. 4. Set forth the basis for your allegation that Service ls` breached the contract as alleg 4 ,-.,. in Paragraph 5 of your Ncw Matter, and identify the work which you alleged Seiwicc 1" failed f complete and the materials which it failed to supply. 5. State in each and every way how Service ls`'s work was defective as alleged Paragraph 7 of your New Matter. 6. Set forth your basis for alleging that Service 15`'s work was "negligently as alleged in Paragraph 8 of your New Matter. 7. Set forth the exact amount of money you allegedly expended to correct Service 15 's work as alleged in Paragraph 9 of your New Matter. For each amount identified, set forth t e following: (a) To whom the payment was made and when it was made; (b) The reason for making the payment; and (c) The materials and/or labor supplied for the payment. 5 8. Identify all estimates (if any} you have obtained to correct and/or finish Scivice lst,hs alleged deficient and/or uncompleted work. 9. Identify all contracts (including any and all amendments thereto) between you Service 1st relating to the Project. 10. Set forth each and every item of "tangible personal property" which you Service 1St either negligently or intentionally discarded (see New Matter, Paragraph 12). 11. Set forth the value of each item identified in the preceding Interrogatory and basis for each value listed. 12. Identify each person you intend to call as anon-expert witness at the trial of tl case, and for each person identified, state your relationship with the witness and the substance 6 the facts to which the witness is expected to testify. 13. Identify all exhibits you intend to introduce during the trial of this matter. 14. Identify all persons who have any knowledge of the claims you made against Servi~ 1st, and, for each person so identified, briefly summarize the substance of the person's knowledge, and his or her involvement with the Project. 15. Identify all home inspectors or other professionals you engaged to evaluate 1 St's work. For each person (or entity) identified, state whether the person (or entity) provided you with a written analysis or other opinion, and, if they did, the nature of the opi or analysis. 7 __ E..~. 16. Identify each person who assisted in the preparation of your answers to Interrogatories, and, for each person identified, state the substance of the person's knowle and the basis therefor. DATED: March 16, 2012 Of Counsel BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717) 233-7691 Respectfully submitted, `/ ` ,//f'/~~ l '~_ ~'~' l i''/ ~' l Thomas A. Beckley, Es`q ire :,-x-, - ~~- .i%2x Thomas S. Beckley, Esquire Attorneys for Plaintiff Service 1St Restoration & Remodeling, 8 ,--- i SERVICI I si RI,S'I'URA`I'ION AND REMODII,INCr, LLC, Plaintiff v. MARTIN MF,NAPACE and TRACI L. MF,NAPACE, Defendants IN THE COURT OF COMMON PIJI:AS OF CUMBERLAND COUNTY, PENNSYLVANIA MECHANIC' S LIEN CLAIM NO. 2011-04807 DATED: March 16, 2012 TO: Mas-tin and Traci L. Menapace c/o Kent Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 FROM: Service 1st Restoration & Remodeling, LLC SERVICE 1sT RESTORATION & REMODELING, LLC'S FIRST SET OF DOCUMENT REQUESTS TO DEFENDANTS MARTIN AND TRACI L. MENAP. You are required to respond to these document requests within thirty (30) days of pursuant to Pennsylvania Rule of Civil Procedure 4009.12. I. DEFII~TITIONS AND INSTRUCTIONS 1. "Documents" is used in its broadest sense and means the original, or, unavailable, a complete copy, and each copy which is non-identical because of notations, revisions or otherwise, of any medium, upon which anything is recorded or which anything can be recorded to include, without limitation, the following: le correspondence, memorandum, notes, reports, records, pictures, videos, electronic and ~ recordings, diaries, calendars, papers, data sheets, bills, emails, contracts, computer print information in computers, information stored on any electronic media, inter-office and i .~ office commlmications, logs, drawings, graphs and charts. 2. "Person" mcans any natural person, corporation, partnership, association, or entity. 3. "You" mcans Defendants, Martin Menapace and Traci I,. Menapace, managing agents, agents, employees, and/or representatives. 4. "Identify," when used in reference to a communication, means to set forth: a. The identification of the person by whom, and each person, to whom ear such communication was made and all persons present at the time; b. The date and time the communication was made or activity tools place; c. The place at which it occurred; d. The means by which it occurred (e.g., by telephone, electror. transmission, letter, or in person); and e. The substance of the communication or activity. 5. "Identity" or "Identification," when used in reference to a person, means to forth the person's: a. Full name; b. Present or last known home address and telephone number; c. Present or last known business address and telephone number; d. Present or last known employer or affiliation; e. Title, rank or position at time of involvement with you; and f. For persons other than natural persons the name and address of officer and general manager. 6. "Identify," when used in reference to documents, means to set forth: 2 a. The nature of the documents (e.g., letter, memorandum, contract, personal notes); b. The date thereof; c. The identification of each author, addressee, and recipient; d. The title of the document and short description of its subject matter; e. Any file number, identifying mark, or code of the document; and f. The location of the document by address, city, and state, and t e identification of the present custodian. 7. The plural includes the singular, and vice versa. 8. Masculine includes feminine, and vice versa. 9. The conjunctive includes the disjunctive, and vice versa. 10. "Everything" when used herein means all things, including, but not limited o, communications, activities and documents, contracts, and telephone calls. 11. "Every" means the same as "everything." 12. "Activity" when used herein means every contract, event, or thing other th a communication or document. 3 __ - _- - _ _ . ~'; II. REQUESTS Plaintiff, Service 15L Restoration & Remodeling, LLC ("Service ls`"), requests that produce the following documents at the law offices of Beckley & Madden, 212 North Street, Post Office Box 11998, I-Iarrisburg, Pennsylvania 17108, or at a mutually agreed place within thirty (30) days: 1. All documents constituting or evidencing communications exchanged between and Service ls` for the work Service ls` was to perform on your residence located at 108 Drive, New Cumberland, Pennsylvania ("Project") 2. All documents constituting or evidencing the contract and any amendments (including change orders) between you and Service ls` relating to the Project. This includes, is not limited to, all change orders or other amendments or additions to the contract. 3. All documents constituting or evidencing any communications exchanged you and any third party, including, without limitation, any insurance carrier, home inspecto~, home improvement contractor (or any other contractor) regarding or relating to the work 1S` performed or was supposed to perform on the Project. 4. Copies of all invoices, and/or requisitions for payment you received from Service 1 relating to the Project. 4 • T '' 5. Copies of all checks and/or other correspondence and/or documents evidencing 11 payments you made to Service 1`` for its work on the Project. 6. All documents evidencing any insurance you have on the Property which relate in a. way to Service 151's work on the Project. 7. Copies of all reports prepared by you or any third parties relating to Service lst's on the Project. 8. Copies of all purchase orders, contracts, work orders, or similar documents exch between you and any other contractor (if any) you hired to complete or repair Service lst's on the Project. 9. Copies of all payment applications, invoices, requisitions for payment or s documents which you received relating to the completion and/or correction of Service 1S~'s on the Project, if any. 5 10. All documents evidencing any payments you made to any third party relating to completion or repair ol~ Service ls`'s work on the Projcci, if any. 11. All photographs relating in any way to Service lst's work on the Project. 12. All documents identified in or requested to be identified in Service 1 St's First Set Interrogatories directed to you. 13. All documents that you intend to introduce at the trial of this matter. 14. All expert reports relating to the Project in any way regardless of whether the relates to Service 1 St's work. 15. All documents evidencing the alleged costs and damages which you have incurred set forth in Paragraph 11 of your New Matter. 6 16. All documents evidencing the items referenced (as well as their value) in 12 of your New Matter which were allegedly destroyed and/or discarded. 17. All documents exchanged (including, without limitation, estimates) between you any insurance carrier relating to the Project. 18. To the extent not already identified or produced, all documents supporting claims and defenses against Service 1 S` DATED; March 16, 2012 Respectfully submitted, Of Counsel BECKLEY & MADDEN 212 North Third Street Post Office Box 11998 Harrisburg, Pennsylvania 17108-1998 (717)233-7691 r"" / ~ ~ ° ~' ; n. Thomas A. Beckley, Esquire .; f j. Thomas S. Beckley, Esquire Attorneys for Plaintiff Service l5c Restoration & Remodeling, 7 CERTIFICATE OF SERVICE I, Thomas S. Beckley, Esquire, hereby certify that on this day a true and correct copy of the foregoing document was served upon the person and in the manner indicated below: SERVICE BY FIRST CLASS MAIL Kent H. Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 DATED: May 11, 2012 •--'~' Thomas S. Beckley, Esquire y/ r f SERVICE 1ST RESTORATION AND REMODELING, LLC, Plaintiff v. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants C IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY MECHANIC'S LIEN CLAIM CIVIL ACTION N0: 2011-4807 IN RE: PLAINTIFF'S MOTION TO COMPEL DISCOVERY RESPONSES AGAINST DEFENDANTS RULE TO SHOW CAUSE AND NOW, this 16th day of May, 2012, upon consideration of Plai Motion to Compel Discovery Responses Against Defendants, a RULE is issued u Defendants to show cause why the relief requested in Plaintiffs' Motion to should not be granted. RULE RETURNABLE within 20 days from the date of this order. By the Court, Distribution List: Thomas S. Beckley, Esq. Beckley & Madden 212 North Third Street P.0. Box 11998 Harrisburg, PA 17108 For Plaintiff Thomas A. placey °'e )Y ' ~'1 t ./" OF C.P.J. c a `= ~~ ~ -~ z ~ -` ~ `~`'r cn r ~ ~ _ ~ ~ rr: °~ r - 0 2'y © zC, 3 ~~ r -+ a -~ ap __. _ _ ,_ _ __ T_ , r Kent H. Patterson, Esq. 221 Pine Street Harrisburg, PA 17101 For Defendants _ ~ 1 \' SERVICE 1sT RESTORATION AND REMODELING, LLC, Plaintiff v. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MECHANIC'S LIEN CLAIM NO. 2011-04807 ORDER ~* AND NOW, this ' ~ day of , 2012, after consideration of Plaintiff s, Service 1 S` Restoration & Remodeling, LL,C. ("Service 15`"), Motion to Make This Court's Rule Issued on May 16, 2012, Absolute Regarding Plaintiff's Motion to Compel Defendants, Martin Menapace and Traci I,. Menapace ("Defendants") to provide Answers to Plaintiffs First Set of Interrogatories and First Request for Production of Documents, it is hereby ORDERED that said Motion is GRANTED. Defendants shall provide Answers to Plaintiff's First Set of Interrogatories and First Request for Production of Documents within ten (10) days of the date of this Order. „~,,,.~..W,~..~._r....,.~~ _~_ . - ..,, i ~"~~mas A. Place -~~y-~mor~ Pleas ~~r~c Distribution: C ~ ~.. Thomas S. Beckley, Esquire ~~ ~~- P.O. Box 11998 ~rZ, ~ Harrisburg, PA 17108-1998 <~ ~ 3> c-a Z Kent Patterson, Esquire ~~ ~ 221 Pine Street ~ .~ Harrisburg, PA 17101 -~ Q' ~~ `~ ~.: ~~ =~ _° o-n ~ c=: ---r r`' a _~ BECKLEY~ MADDEN ATTORNEYS AT LAW CRANBERRY COURT 212 NORTH THnto STREET P06T OFFICE BO% 11998 HARRISBURG, PENNSYLVANIA 1710 8-19 9 8 PHONE: 1717) 833-7891 FAIL: (7171833-3740 E-MAIIr bec{dey(_,pB.IIeY 461013 August 3, 2012 Kent H. Patterson, Esquire VIA FAX AND FIRST CLASS MAIL 221 Pine Street Harrisburg, PA 17101 RE: Service First Restoration & Remodeling, LLC v. Menapace Dear Kent: As you know, on July 18, 2012, the Court entered an Order directing the Menapaces to provide answers to Service 1S`'s discovery reduests within 10 days (by July 28, 2012). 'Iodate, we have not received any answers. As a matter of courtesy to you. this is to advise •.-oii that we will file a second motion for sanctions next week unless we receive the l~ -enapaces' answers early next week. Very truly yours, BECKLEY & MADDEN _.~ G^~ : _ _• C /;~~,,% Thomas S. Beckley CERTIFICATE OF SERVICE I, Thomas S. Beckley, Esquire, hereby certify that on this day a true and correct copy of the foregoing document was served upon the person and in the manner indicated below: SERVICE BY FIRST CLASS MAIL Kent H. Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 6~~f .-~ DATED: August 31, 2012 „~ Thomas S. Beckley, Esquire fi' ii.,~ ~~U~~D1~Lr~ r.. `1 :..:~' ~ ~'i~ ~~~~K~~~ ,r~rt 's 2~t2 SEP -6 PM ~+~ 4 9 SUM E1 ~~(~~,,,~~~t A T ~' SERVICE 1st RESTORATION AND ~ ~N THE COURT OF COMMON PLEAS REMODELING, LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants No. 2011-04807 MECHANIC'S LIEN CLAIM AMENDMENT TO MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY REQUESTS AND NOW come defendants, Martin Menapace and Traci L. Menapace, by their attorney, Kent H. Patterson, and file this amendment to motion for extension of time to respond to discovery requests, by adding the following paragraph: 11. The judge who ruled on the motion to compel and issued the order referred to in paragraph 5 above was the Honorable Thomas A. Placey. Respectfully submitted, Kent H. Patterson Attorney for Defendants 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 SERVICE lgt RESTORATION AND REMODELING, LLC, Plaintiff v. MARTIN MENAPACE and TRACI L. MENAPACE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2011-04807 : MECHANIC'S LIEN CLAIM CERTIFICATE OF SERVICE AND NOW, this ~ day of ~.a 2012 I, Kent H. Patterson, hereby certify that I this day served the within amendment to motion by depositing a copy of same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to counsel of record for plaintiff as follows: Thomas S. Beckley, Esquire Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 ~- ~ _, Kent H. Patterson Attorney for Defendants 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 0 SERVICE 1sT RESTORATION AND IN THE COURT OF COMMON PLEAS REMODELING, LLC, OF CUMBERLAND COUNTY, I Plaintiff PENNSYLVANIA P1 r"I V M r-i . MECHANIC'S LIEN CLAIM MARTIN MENAPACE and TRACI L. rte-- -' . MENAPACE, NO. 2011-04807 >° +- Defendants =C:) PLAINTIFF'S ANSWER TO DEFENDANTS' MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY REQUESTS Plaintiff, Service 1St Restoration & Remodeling, LLC ("Service 1St"), by and through its attorneys, Thomas A. Beckley, Esquire, Thomas S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Answer to Defendants' Motion for Extension of Time to Respond to Discovery Requests, and, in support thereof, avers as follows: 1. It is admitted that this dispute involves work done by Service I" on Defendants' residence which suffered fire damage in or around September, 2010. It is also admitted that Service 1St stopped working on Defendants' residence solely because Defendants never paid Service 1St for any of its work. Service 1St stopped working on Defendants' residence in February, 2011, approximately 18 months ago, and filed a mechanic's lien claim on June 6, 2011, over 14 months ago. Service 1St is owed the principal amount of $47,926.70 which has been due for over 18 months. To date, Service 1St his not received any payments from the Defendants for its work. It is denied that Service 1" did not supply the contract until after Defendants filed preliminary objections. To the contrary, Defendants had a copy of the contract on or about the time Service I 't commenced working. By way of further response, Defendants alleged in paragraph 2 of their motion that their alleged expert, William S. Miller, IV, reviewed the contract documents at or before the time Service 1St filed its mechanic's lien claim (June, 2011). 2. After reasonable investigation, Service 1St is without information or knowledge sufficient to form a belief as to when or whether Defendants ever engaged William S. Miller, IV, to inspect Defendants' residence. By way of further response, if Defendants engaged Mr. Miller in the timeframe alleged in their Motion (in or before June, 2011), he has now had over 14 months to issue a report, which, evidently, he has not done. Defendants have had sufficient time to find another alleged expert, or to simply identify the areas of alleged deficient work. By way of further response, Defendants could have provided Service 1St with the documents they allegedly provided to Mr. Miller in June, 2011 (Service I 't requested copies of all of these documents in its document requests). 3. After reasonable investigation, Service 1St is without information or knowledge sufficient to form a belief as to when or whether William S. Miller, IV, ever reported any deficiencies in Service 1 St's work. By way of further response, if he did report any deficiencies, Defendants could have clearly identified those deficiencies had they filed ansNwers to Service I"'s discovery requests. 4. After reasonable investigation, Service 1St is without information or knowledge sufficient to form a belief as to what efforts Defendants have made to contact Mr. Miller. Furthermore, Defendants did not list the dates, method or frequency of attempted contact with. Mr. Miller. By way of further response, Defendants have now had over 18 months since; Service 1St stopped working on their residence, and at least 14 months since Mr. Miller allegedly inspected Defendants' residence. If, after 14 months, Mr. Miller was not 2 being responsive, Defendants should have retained another person to review Service Is"s work. 5. It is admitted that Service I" served Interrogatories and Document Requests on Defendants, and that Defendants failed to respond. It is also admitted that (a) Service 1st filed! a motion to compel which Defendants failed to answer, (b) the Court issued a Rule to Show cause to which Defendants failed to respond, and (c) the Court issued an Order (Julys 18, 2012) directing Defendants to file answers to Service 1 st's discovery requests on or before July 28, 2012. Defendants have failed to comply with the Court's July 18 Order. Defendants are seeking an additional thirty (30) days despite the existence of the Court's Order only because Service 1st filed a second motion for sanctions in which Service 1st has requested the Court to preclude Defendants from entering any evidence supporting their claims and/or defenses due to Defendants' failure to comply withjthe Court's Order dated July 18. 6. Denied as stated. Defendants could have responded to every one of Service 1 st's' discovery requests in a timely manner. Defendants could have supplemented their answers if they learned more after providing answers. Furthermore, if Defendants truly needed an additional thirty (30) days to respond, they should have requested an extension at the time Service 1st filed its original motion to compel, not months after the fact. Defendants are now requesting the Court to ignore its Order of July 18, 2012, and give Defendants thirty additional days (which they had when Service 1st served its discovery requests in March, 2012). 3 a. Denied as stated. If Service lst's work was truly deficient, Defendants could identify what was deficient. An expert report could simply "fill in details," if needed. Indeed, Defendants alleged that Mr. Miller verbally told them about the deficiencies (Motion, ¶ 2). Furthermore, Service 1st requested copies of all emails, contracts, invoices from third parties, and a list of the personal items which Service 1st allegedly damaged. Clearly these are all items within Defendants' knowledge and/or possession, and an expert is not required. b. It is admitted that Service 1st has what it believes is the contract and various emails from Defendants. Service 1st is entitled, however, to obtain a copy of the emails and contract from Defendants to verify that Service I" has a complete file. Again, these are all documents which Defendants have had in their possession for at least 18 months, and there is absolutely no reason Defendants could not have already produced these as required by the Court's Order dated July 18. Indeed, an expert report is not requred to simply produce copies of documents (several of which Defendants showed the alleged expert). c. It is admitted that Service 1st has a copy of what it believes to be the contract. Service 1St is entitled, however, to obtain a copy of what the Defendants believe is the contract. Indeed, Defendants alleged that they showed the contract to Mr. Miller at least 14 months ago, therefore, there is absolutely no reason they could not have produced it. Instead of actually producing it, Defendants have chosen to delay this matter further and by filing a motion for an extension of time. d. Denied as stated. If Defendants have not yet identified their expert or trial' witnesses, they could have so stated had they served answers to Service lst's 4 discovery requests. By way of further response, if Defendants want to serve discovery requests, they remain free to do so. Finally, if Defendants have performed additional work: on their residence (as their motion implies), there is no reason why they failed to produce those records. e. Denied as stated. It is believed that Defendants may have received payments from their insurance carrier, but failed to forward those payments to Service 1st By way of further response, there is absolutely no reason why Defendants could not have supplied this information in a timely manner (i.e., an expert is not required). 7. The time for Defendants to respond to Service Is" s discovery requests has now passed. Defendants' responses were originally due in April, 2012. Defendants chose to ignore a motion to compel, a Rule to Show Cause, and the Court's Order dated July 18. The items listed by Defendants in paragraph 7 are all items which they knew or should have known by now (i.e., what they paid to other contractors, what personal property was alle4edly discarded by Service 1St). By way of further response, Defendants have had sufficient time to provide full and complete answers to Service Is" s discovery requests. 8. Denied as stated. Defendants have had over eighteen months to retain an expert. As mentioned above, Service 1St stopped working in February, 2011. By way of further response, Service 1 St's discovery requests did not require Defendants to identify an expert by a particular date certain, they merely requested Defendants to identify the alleged deficiencies in Service Is" s work which would not require an expert. 9. Defendants should not be given any additional time, let alone thirty days to respond. If Defendants truly needed additional time, they should have requested it either before or when Service 1st filed its motion to compel. 5 10. Admitted. By way of further response, Service I"'s second motion for sanctions is currently pending before the Court. It is believed and therefore averred that the only reason Defendants filed a motion for extension of time was because Service 1st filed] a motion for sanctions. WHEREFORE, Plaintiff, Service 1st Restoration and Remodeling, LLC, respectfully requests the Court to deny Defendants' Motion for Extension of Time, and to grant the relief requested by Service 1St in its Motion for Sanctions filed on September 4, 2011. DAJ'ED: September 5, 2012 Respectfully submitted Of Counsel BEaKLEY & MADDEN 212 North Third Street PostjOffice Box 11998 Harrisburg, Pennsylvania 17108-1998 (7171) 233-7691 C ,?LZ44 V Thomas A. Beckley, Esq ire Thomas S. Beckley, Esquire Attorneys for Plaintiff Service 1St Restoration & Remodeling, LLC 6 CERTIFICATE OF SERVICE I, Thomas S. Beckley, Esquire, hereby certify that on this day a true and correct copy of the foregoing document was served upon the person and in the manner indicated below: SERVICE BY FIRST CLASS MAIL Kent H. Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 DAtED: September 5, 2012 2!' Thomas S. Beckley, Esquire