HomeMy WebLinkAbout12-1498
LAWS, STARUCH & PISARCIK C'
C') r
W. Scott Staruch, Esq.
PA Atty ID No. 23887 -
Gerard J. Pisarcik, Esq. =-
PA Atty ID No. 39181
20 Erford Rd., Ste 105
Lemoyne, PA 17043 .?
(717) 975-0600
W. SCOTT STARUCH and
GERARD J. PISARCIK, trading as
LAWS, STARUCH & PISARCIK,
Plaintiffs
V.
BRENDA L. WATSON, Individually,
ROGER C. WATSON, Individually, and
NAVTECH, INC.,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action No. a- 1498 Ci vi (Rexo%
NOTICE
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YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
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OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
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Cumberland County Bar Association
32 S. Bedford St., Carlisle, PA 17013 4103.15 PQ ArN
(717) 249-3166 ## 41-29
(800) 990-9108 P-'v ?'7.7 1,71
LAWS, STARUCH & PISARCIK
W. Scott Staruch, Esq.
PA Atty ID No. 28337
Gerard J. Pisarcik, Esq.
PA Atty ID No. 39181
20 Erford Rd., Ste 105
Lemoyne, PA 17043
(717) 975-0600
W. SCOTT STARUCH and
GERARD J. PISARCIK, trading as
LAWS, STARUCH & PISARCIK,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action No.
V.
BRENDA L. WATSON, Individually,
ROGER C. WATSON, Individually, and
NAVTECH, INC.,
Defendants
COMPLAINT
1. Plaintiffs W. Scott Staruch and Gerard J. Pisarcik, trading as Laws,
Staruch & Pisarcik, are members of a Pennsylvania partnership with its principal place of
business located at 20 Erford Road, Suite 105, Lemoyne, Cumberland County,
Pennsylvania 17043 ("LS&P").
2. At all times relevant herein, Plaintiffs are and have been attorneys-at-
law, duly admitted to practice and practicing in the courts of Pennsylvania.
3. Defendant Brenda L. Watson is an individual residing at 314 West Main
Street, New Bloomfield, Perry County, Pennsylvania 17068. Brenda Watson is President,
Secretary, Treasurer and sole Director of Defendant NavTech, Inc.
4. Defendant Roger C. Watson is an individual residing at 314 West Main
Street, New Bloomfield, Perry County, Pennsylvania 17068. Roger C. Watson is Vice
President in Charge of Field Operations for Defendant NavTech, Inc. (Defendants Brenda
L. Watson and Roger C. Watson are collectively referenced to herein as "Watsons".)
5. Defendant NavTech, Inc. is a Pennsylvania corporation with its principal
place of business located at 314 West Main Street, New Bloomfield, Perry County,
Pennsylvania 17068 ("NavTech")
6. Defendant Roger C. Watson has been a Registered Professional Land
Surveyor in the Commonwealth of Pennsylvania since 1994.
7. Since at least 1997, Plaintiffs have advised, consulted with and
represented Defendants in a variety of legal matters including the organization of
Defendants' businesses (the incorporation of NavTech, Inc. in 1997, the incorporation of
Roger C. Watson Surveying Services, Inc. in 1998, and the merger of the two
corporations in 2002), the prosecution and defense of business related litigation, and
personal matters including the sale and purchase of real estate involving sums in excess
of $1,000,000.00.
8. As of April 2009, Defendants owed Plaintiffs an outstanding balance of
$21,408.34 for legal services which LS&P had provided in preceding years.
9. By telephone calls of 3/31/09 and 4/2/09 to Scott Staruch ("Staruch"),
the first from Roger Watson and the second from Brenda Watson, the Watsons
requested his legal assistance and representation because they had just attended a
3/26/09 hearing at the Department of Labor and Industry ("L&I"); L&I intended to debar
the Watsons and their company, NavTech, from all contracts for public work in
Pennsylvania for a period of three years, as a result of an intentional violation of
Pennsylvania's Prevailing Wage Act, Act of August 15, 1961, P.L. 987, as amended 43
P.S. §§ 165.1 - 165.17. The Watson's further advised Staruch that given the volume of
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public construction surveying work performed by them, a three-year debarment would put
them and their many employees out of business. The Watsons further advised that they
had understood the 3/26/09 hearing to be only a conference for discussion of the issues
and had not appreciated the seriousness of their situation.
10. At the time of the material events of this case, NavTech had
approximately 11 employees as well as the Watsons on its payroll, such that the
livelihood of 12 families was going to be dependent upon the abilities and success of
LS&P in avoiding their debarment.
11. Pennsylvania's Prevailing Wage Act ("PWA") provides that in the event
the Secretary of the Department of Labor and Industry shall determine that any person or
firm has failed to pay prevailing wages intentionally, he or she shall thereupon notify all
public bodies of the names of such persons or firms and no contract may be awarded to
any such persons or firms for a period of three years. In addition, the Secretary may
request the Commonwealth's Attorney General to recover penalties as provided by the
PWA. A "public body" is defined in the PWA to include not only the Commonwealth of
Pennsylvania, but also all of its political subdivisions and authorities.
12. Staruch not only agreed to assist the Watsons, but also forgave
$11,434.00 of their outstanding balance due to LS&P at that time.
13. LS&P thereupon promptly: (1) obtained and reviewed the 11/3/08
Order to Show Cause issued by L&I's Bureau of Labor Law Compliance, and the
approximately 300 pages of exhibits attached thereto; (2) consulted with the Watsons as
to the facts of the situation, and (3) contacted L&I's general counsel and hearing officer to
advise of their representation of Defendants.
-3-
14. The 11/3/08 Order to Show Cause was issued by L&I's Bureau of
Labor Law Compliance against both of the Watsons individually and also their
corporation, NavTech, for intentionally failing to pay the predetermined prevailing
minimum wages to their employees on a particular Turnpike Commission project; in view
of past correspondence, discussions and underpayments by the Defendants on previous
projects, L&I requested that all the Defendants be debarred for a three-year period.
15. Sometime in April of 2009, LS&P received a copy of the 148-page
transcript of the 3/26/09 hearing, together with approximately 700 pages of Exhibits
introduced thereat, as well as correspondence from L&I's Hearing Officer Jackie Lutz
setting the briefing schedule.
16. On 5/8/09 L&I filed its 25-page Bureau of Labor Law Compliance Brief.
17. On 6/15/09 LS&P filed its 21-page Respondents' Brief, Findings of Fact
and Conclusions of Law urging that, under the facts and circumstances, any violation of
the PWA found by the Hearing Officer should be characterized as unintentional rather
than intentional.
18. On 6/20/09 the Bureau of Labor Law Compliance filed a Reply Brief to
which LS&P responded by letter of 6/30/09.
19. On 10/29/09 Hearing Officer Jackie Lutz issued her 27-page Proposed
Report and Order. Her Proposed Order recommended that the Watsons individually and
their company, NavTech, be found to have intentionally violated the Prevailing Wage Act,
be debarred in accordance with the Act, and that no contracts for public work be awarded
to them or any firm in which they have an interest for a period of three years from the
date all public bodies receive notice of this Order, and finally, that the Office of Attorney
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General recover the penalties and statutory liquidated damages provided for in the PWA.
See Exhibit A attached hereto and incorporated by reference.
20. Pursuant to the Administrative Code, LS&P, on behalf of the Watsons
and NavTech, on 11/30/09, timely filed a 41-page Brief on Exceptions. Also on that same
date, 11/30/09, LS&P filed both a Motion for Oral Argument and a Petition to Reopen the
Record, utilizing every avenue possible to avoid a catastrophic debarment.
21. L&I's Bureau of Labor Law Compliance, by filings of 12/4/09 and
12/18/09 filed its Brief and Replies in Opposition to the Brief, Motion and Petition of
LS&P.
22. By Order of 12/30/09, the Honorable Sandy Vito, then Secretary of the
Commonwealth's Department of Labor and Industry, denied the Exceptions filed on
behalf of the Defendants and adopted the Decision and Order of the Hearing Officer in its
entirety. Secretary Vito formally determined that the Watsons and NavTech had
intentionally violated the PWA, were debarred from any contract for public work for a
period of three years and were subject to penalties and liquidated damages enforcement
by the Attorney General.
23. Immediately upon receipt of Secretary Vito's Order, LS&P timely filed a
Notice of Appeal of that Order with the Commonwealth's Prevailing Wage Appeals Board
("Board").
24. On 1/26/10 LS&P filed a 49-page Brief of Appellants with the Board, to
which the Bureau of Labor Law Compliance replied with its 22-page Brief in Opposition
on 2/3/10.
25. Pending oral argument before the Board on appeal, Brenda Watson
discovered that she, her husband and their company had been listed on L&I's
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"Debarments and Settlements" webpage as subject to a three-year debarment which had
commenced on 12/30/09. See Exhibit B, attached hereto and incorporated herein by
reference. Promptly upon receipt of this information, LS&P filed a request to stay this
debarment with Secretary Vito on 3/26/10, which was opposed by the Bureau of Labor
Law Compliance by Answer of 3/29/10 and ultimately denied by Secretary Vito by Order
of 6/1/10.
26. The Bureau of Labor Law Compliance was particularly adamant that
the Defendants' PWA violation on this Turnpike Project constituted an intentional violation
because, as they argued in several of their filings, the Watsons and NavTech had been
the subject of three different L&I Prevailing Wage Act investigations on five other
projects, during which there had been a number of meetings, telephone conversations
and correspondence exchanged.
27. On 5/18/10, Staruch argued the Defendants' appeal before the
Prevailing Wage Appeals Board. As part of the preparation for this appeal, LS&P
prepared a binder highlighting the most significant facts for each of the Board members.
28. By its 20-page Opinion and Order of 7/15/10, the Prevailing Wage
Appeals Board reversed Secretary Vito's determination that the Watsons and NavTech
had committed an intentional violation of the Prevailing Wage Act, and thus reversed the
debarment and referral to the Attorney General to which the Watsons and NavTech had
been subject. Based on the reported decisions, this appears to be only the second
time in the Board's almost half century of existence that a Decision of the
Secretary of Labor and Industry to debar a contractor has been overturned by the
Prevailing Wage Appeals Board.
-6-
29. By email of 7/19/10, Brenda Watson advised Staruch that the Board's
Decision was "great news!!!!!".
30. Subsequently, on 8/25/10 the Pennsylvania Turnpike Commission filed
a 6-page letter (with five exhibits attached) with the Prevailing Wage Appeals Board,
requesting that it issue a revised Opinion and Order, which request necessitated a review
and 9/2/10 response by LS&P to the Board.
31. By subsequent letter of 9/7/10, the Board advised the Turnpike
Commission that it had no legal basis to act on the request, and finally, this litigation was
successfully concluded.
32. When LS&P first agreed to represent the Watsons and NavTech in
these proceedings, LS&P forgave over $11,000.00 of their outstanding indebtedness.
During these lengthy and critical proceedings, given the amount of time and effort
involved in this litigation, LS&P additionally discounted its billings by a total of
$16,306.42. Finally, prior to its 12/09 billing, LS&P agreed to share the risk of success,
i.e., Scott Staruch advised Brenda Watson that she would only be billed for half the fees
due on a monthly basis, with the remaining one-half contingent upon a successful appeal.
To date, however, there remains a principal fee balance due of $41,831.54, which was
due and payable in full as of November 1, 2010, to which prejudgment interest at 6%, or
$3,346.56 as of February 29, 2012, should be added for a total due of $45,178.10.
33. By email of 8/26/10, in response to an inquiry as to the balance due
from Brenda Watson, Scott Staruch not only explained the amount of work performed
and discounts already provided, but further offered to allow the remaining balance to be
paid over a 10-month period without interest. This offer was not accepted and has been
withdrawn. See Exhibit C attached hereto and incorporated herein by reference.
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34. Despite promises of payment since that date, nothing has been paid to
LS&P by the Defendants.
35. By deed of 6/21111, the Defendant Watsons sold to First National Bank
of Mifflintown, slightly less than 6 acres of an approximately 74 acre tract of land owned
by the Watsons, for the sum of $500,000.00. Not a cent of the sale proceeds received by
the Watsons has been paid against the outstanding sum due LS&P.
COUNTI
BREACH OF CONTRACT
36. The averments of Paragraphs 1 through 35 are incorporated herein by
reference as if fully set forth at length.
37. In the aforesaid debarment proceedings, Plaintiffs successfully
prosecuted the appeal of Defendants' three year debarment to the Prevailing Wage
Appeals Board, where Plaintiffs obtained a favorable outcome for Defendants, i.e., the
Board overturned the debarment determination of the Secretary of L&I. In effect,
Plaintiffs saved the livelihood of the Watsons, their company, NavTech, and their
employees.
38. As a result of providing legal services and incurring expenses for the
aforesaid debarment proceedings and subsequent, successful appeal, there remains due
and unpaid from Defendants to Plaintiffs the principal sum of $41,831.54, with
prejudgment interest at the rate of six (6%) percent in the sum of $3,346.56 accruing
through 2/29/12, for a total due and owing Plaintiffs in the amount of $45,178.10.
39. Despite repeated demands by Plaintiffs for payment, Defendants have
failed and continue to fail to pay Plaintiffs the aforesaid sum to which they are rightfully
entitled.
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WHEREFORE, Plaintiffs respectfully request this Honorable Court to enter
judgment in their favor and against Defendants in the sum of $45,178.10 plus interest,
expenses, attorney's fees and such additional relief as this court deems just and proper.
COUNT II
QUANTUM MERUIT
40. The averments of Paragraphs 1 through 35 are incorporated herein by
reference as if fully set forth at length.
41. Defendants accepted the aforesaid legal work of Plaintiffs and received
the benefit thereof.
42. It would be unconscionable for Defendants to retain the value of
Plaintiff's work without making full remuneration to Plaintiffs for that work. Equity
demands that Defendants be compelled to disgorge this benefit.
43. Plaintiffs are thus entitled to be paid the sum of $45,178.10.
WHEREFORE, Plaintiffs respectfully request this Honorable Court to enter
judgment in their favor and against Defendants in the sum of $45,178.10 plus interest,
expenses, attorney's fees and such additional relief as this court deems just and proper.
Respectfully submitted,
LAWS, STARUCH S A
By
W. Scott Staruch, Esq.
Aft y ID No. 23887
By:
and J. Pis r ik, Esq.
Attornev ID No. 39181
20 Erford Rd., Ste 105
Lemoyne, PA 17043
(717) 975-0600
-9-
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF LABOR AND INDUSTRY
BEFORE THE SECRETARY OF LABOR AND INDUSTRY
IN RE:
Commonwealth of Pennsylvania,
Department of Labor and Industry,
Bureau of Labor Law Compliance,
DOCKET No. PW-2008-31
Petitioner
VS.
NAVTech, Inc.
Brenda Watson, Individually
Roger C. Watson, individually
P.O. Box 756
New Bloomfield, PA 17068,
Respondents
PROPOSED ORDER
AND NOW, this 26`h day of October 2009, based upon the foregoing Findings of
Fact, Conclusions of Law and Discussion, it is recommended that Respondents
NAVTech, Inc. and Brenda Watson and Roger C. Watson, individually, shall be found to
have intentionally violated the Prevailing Wage Act.
It is further recommended that Respondents NAVTech, Inc. and Brenda Watson
and Roger C. Watson, individually, shall be debarred in accordance with Section 11(e) of
the Act, 43 P.S. § 165-11(e), and that no contract for public work shall be awarded to
them or to any firm, corporation or partnership in which Respondents have an interest,
until a period of three (3) years has elapsed from the date that all public bodies shall have
received notice of the fact and finding of said intentional violation.
EXHIBIT A
26
In addition, it is recommended that the Secretary shall request the Office of
Attorney General to proceed to recover penalties and statutory liquidated damages for the
Commonwealth of Pennsylvania, pursuant to section 11(e) of the Act, 43 P.S. § 165.11(e).
Ja ie W' st Lutz
Officer
For Respondents: W. Scott Staruch, Esquire
Laws, Staruch & Pisarcik
20 Erford Road, Suite 205
Lemoyne, PA 17043-1163
For the Department: Jason Anderson, Esquire
Assistant Counsel
Office of Chief Counsel
Department of Labor and Industry
Commonwealth of Pennsylvania
Tenth Floor, Labor and Industry Building
651 Boas Street
Harrisburg, PA 17121
Date of Mailing: Oct fie, 2-?
, 2 o0 q
27
Prevailing Wage Page I of 2
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Safety and Labor-Management Relations ? Labor Law Compliance
Department of Labor & Industry
Debarments and Settlements
This notice Is published for the Information and convenience of public bodies subject. to the Act,
Settlements
Worth & Company, Inc., and the Department of Labor & Industry have entered Into a Settlement
Agreement regarding the Amended Order to Show Cause Issued by the Bureau of Labor Law Compliance to
Worth (No, PW-2005-614) In relation to Pennsylvania's Prevailing Wage Act. This Settlement Agreement
does not contain or constitute any admission by Worth & Company, Inc., of any violation of Pennsylvania's
Prevailing Wage Act. The Settlement Agreement will be administered as a voluntary debarment for a period
of 15 months commencing on August 1, 2009 and ending on November 1, 2010. During this period, Worth
& Company, Inc., as well as any firm, corporation, partnership or other entity in which Worth has an
ownership Interest, controls or contains the name "Worth` or any name or word similar thereto, shall not
bid on or be awarded contracts for any projects subject to Pennsylvania's Prevailing Wage Act.
Debarments
Under Section 11(e) of the Act (43 P.S. § 165-1(e)), these persons and firms, or any firm, corporation or
partnership In which such persons and firms have an interest, shall be awarded no contract for 3 years
after the date listed.
CONTRACTOR ADDRESS DATE OF
DEBARMENT
Richard Balsama, Individually 1127 Stratford Road 2/1/2010
Glenolden, PA 19036
Tinney Rebar Services, Inc. 4 Industrial Park Drive 1/26/2010
--AND-- Oakdale, PA 15071
Jami R. Tinney, Individually
NAVTech, Inc. P.O. Box 756 12/30/2009
--AND-- New Bloomfield, PA 17068
Brenda Watson, Individually, Roger Watson,
Individually
Comunale Automatic Sprinkler, Inc, 1180 Sand Run Road 12/11/2009
--AND-- Akron, OH 44313-8014
Mark J. Comunale, Individually
Richard F. Bondurant, LLC 228 Brooke Street 9/28/2009
--AND-- Media, PA 19063-3621
Richard F. Bondurant, Individually
G.F. Insulations, Inc. 1520 Columbiana Lisbon Road 9/23/2009
--AND-- Columbiana, OH 44408
Gregory F. Fernberg, Individually
Barlow Projects, Inc. 2000 Vermont Drive 7/29/2009
--AND-- Fort Collins, CO 80525
James Barlow, Individually
Back Fronts, LLC 6 Corbin Lane 4/16/2009
--AND-- Morrisville, PA 19067
Peter Jach, Individually
D.E.W. Steel Contractors, Inc. 244 Old Hershberger Road 4/712009
--AND-- Hollsoppie, PA 15935
Dale E, Welssner, Individually
Morris Johnson & Sons, Inc. 925 Davisvllle Road 1/13/2009
--AND-- Willow Grove, PA 19090
Albert Johnson, Sr., Individually
Philip Saar Enterprises, Inc. 2036 saxonburg Boulevard 12/15/2008
--AND- Tanentum, PA 15084
EXHIBI B
http://xN,x,"'.portal,state.pa.us/poi-tal/server.pt?open=514&obiID- 55 3544&mode-2 31112/2010
Prevailing Wage
Philip Saar, Individually
PSP Contractors, Inc. P.O. Box 34569
Philadelphia, PA 19101-4569
21st Century Framing, LLC 5740 Wilkes Road
--AND--
Tiffany M. Lynn, Individually Atwater, OH 44201
A. Gallo Contractors, Inc. 427 Glendale Avenue
--AND--
Gary S. Love, Individually Maple Shade, NJ 08052
Comfort Heating and Air Conditioning
Inc
,
.
--AND-- 7532 Pfeffer Avenue
Mark tutcovich, Individually Fairview, PA 16415
Robert A. Passero, Individually 1008 Good Shepherd Road
--AND--
d/b/a Avoca Building Company Montoursvllie, PA 17754
Babich Plumbing Company 625 Narrows Run Road
Ted Babi abich Coraopolis, PA 15108
Powers Welding and Fabrication 805 S. Milton Grove Road
--AND--
Charles Powers, Individually Elizabethtown, PA 17022
M. Smith Concrete 2250 Robert Fulton Highway
--AND--
Michael Smith, Individually Peachbottom, PA 17563
William Crilley Construction 106 Greenhill Road
--AND--
William Crilley and Cindy Zang, Individually Karns City, PA 16041
Conta:l U5 Gonunonwaal!h PC-,to,; Contact the Nleb team pnvacy Po'?cy Di,adnnei
Copyright ® 2010 Commonwealth of Penn svivania
Page 2 of 2
11/1/2007
8/23/2007
8/21®
7/1D- /pp7
6/22/2007
5/9/2007
4/6/2007
4/6/2007
3/13/2007
http;/hvww.portal.siate.pa.us/portal/server.pt?open=514& objlI)-553544&,mode=2 311212010
rage i of i
Subj: Billings
Date: 8/26/2010 9:53:48 A.M. Eastern Daylight Time
From: LSPlaw(tao
To: bwatsondbnavt.com
BCC: MStiely goi.com
Brenda,
Yes, your numbers are partially correct. But they do not reflect the following:
Saving your company took priority over all other work for us during this battle.
Our hours expen4od on your behalf totaled 408.4b.
1 have already discounted your billings on prior statements by mom than $10,000.
1 took the risk of success with you and Roger, when all odds appeared against us, by making
1/2 of the billings contingent.
As you know, we had to file 3 different briefs at 3 levels in the process, with motions for
remand, oral argument and to lift the stay, present oral argument to the PWAB, with exhibits,
contact FHWA, Turnpike, Hempt, Sen. Corman, etc., perform a lot of legal research, especially in
light of the number of adverse cases, etc. We were prepared to file for injunctive relief in court
against the stay If necessary.
If you check with the Senator's staff, I expect them to tell you that they really were not able
to accomplish what they hoped to an your behalf, which left it solely to us to succeed for you.
This is only the second time In history that the PWAB has reversed the Secretary's decision.
Based on what you told me, your company will continue in business because of what
we were able to do.
Yes, we succeeded and the contingent fees are due. I would have expected that you would
be happy to even borrow the money If needed to pay us promptly. However, I have agreed to
finance it for you at no interest, at $4,500 per month payments, while I must pay significant
interest to the bank on my loan. What more can you ask?
Scott
W. Scott Steruch, Esq.
Laws, Staruch 3 Pisarclk
20 Erford Road, Suite 305
Lemoyne, PA 17043
(717)975-0800
(717)975-3871 (fax)
Attorney/Client Privilege - Attorney Work Product
This communication is intended only for the use of the Individual or entity to which it is
addressed and may contain information that is privileged and confidential. If the reader of this
message Is not the intended recipient, you are hereby notified that any dissemination,
distribution, or copying of this communication is strictly prohibited. If you have received this
communication in error, I would appreciate a reply email advising of my mistake. Thank you.
No trees were destroyed in the sending of this message. However, a large number of
electrons were significantly inconvenienced.
EXHIBIT C
Thursday, August 26, 2010 AOL: LSPIaw
VERIFICATION
Subject to the penalties of 18 Pa.C.S. Section 4904 (relating to unsworn falsification
to authorities), I, W. Scott Staruch, hereby declare that, the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge, information and belief.
W. Scott Staruch
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
i'ONAp at ClUtibrr,;rtd
IIE IF OTHOINO
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OFD
2912 MAR 20 AM 10, 45
CUMBERLAND GOiiN'Fl'
PENNSYLVANIA
W. Scott Staruch
vs.
Brenda L. Watson (et al.)
Case Number
2012-1498
SHERIFF'S RETURN OF SERVICE
03/09/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Brenda L. Watson, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Complaint
and Notice according to law.
03/09/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Roger C. Watson, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Complaint
and Notice according to law.
03/09/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: NavTech, Inc., but was unable to locate them in his
bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Complaint
and Notice according to law.
03/12/2012 11:35 AM - Perry County Return: And now March 12, 2012 at 1135 hours I, Carl E. Nace, Sheriff of Perry
County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and
Notice, upon the within named defendant, to wit: NavTech, Inc. by making known unto Brenda L. Watson,
Co-Owner of NavTech, Inc. at 314 W. Main Street, New Bloomfield, Pennsylvania 17068 its contents and
at the same time handing to her personally the said true and correct copy of the same.
03/12/2012 11:35 AM - Perry County Return: And now March 12, 2012 at 1135 hours I, Carl E. Nace, Sheriff of Perry
County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and
Notice, upon the within named defendant, to wit: Brenda L. Watson by making known unto herself
personally, at 314 W. Main Street, New Bloomfield, Pennsylvania 17068 its contents and at the same time
handing to her personally the said true and correct copy of the same.
03/16/2012 11:35 AM - Perry County Return: And now March 12, 2012 at 1135 hours I, Carl E. Nace, Sheriff of Perry
County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and
Notice, upon the within named defendant, to wit: Roger C. Wilson by making known unto Brenda L.
Watson, Wife of Defendant at 314 W. Main Street, New Bloomfield, Pennsylvania 17068 its contents and
at the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $71.25
March 16, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
(C CcuntySuite Sher;ff. Ieleocoft In,.
W. Scott Staruch
Versus
Brenda L. & Roger C. Watson
& NavTech
IN THE COURT OF COMMON PLEAS OF
THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA,
PERRY COUNTY BRANCH
No. 2012-1498 Cumberland Co.
SHERIFF'S RETURN
And now March 12 , 2012: Served the within name NavTech, Inc.
the defendant(s) named herin, personally at his place of residence in New Bloomfield Boro-
314 W. Main Street,
New Blmfd,
Perry County, PA, on March 12, 2012 at 11:35 o'clock AM
by handing to Brenda L. Watson, co-owner 1 true and attested
copy(ies) of the within Complaint
and made known to her the contents thereof
Sworn and subscribed to before me this
day of
kA#
b4l! "-fa
;
COMMONWEALTH OF PENNSYLVANIA
So answers
?k'/
Deputy Sheriff of Perry County
NOTARIAL SEAL
MARGARET F. FLICKINGER, Notary Public
Bloomfield Boro, Perry County
My Commission Expires February 16, 2016
W. Scott Staruch
Versus
Brenda L. & Roger C. Watson
& NavTech
IN THE COURT OF COMMON PLEAS OF
THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA,
PERRY COUNTY BRANCH
No. 2012-1498 Cumberland Co.
SHERIFF'S RETURN
And now March 12 , 2012: Served the within name Roger C. Watson
the defendant(s) named herin, personally at his place of residence in New Bloomfield Boro-
314 W. Main Street,
New Blmfd,
Perry County, PA, on March 12, 2012 at 11:35 o'clock AM
by handing to Brenda L. Watson, defendant's wife 1 true and attested
copy(ies) of the within Complaint
and made known to her the contents thereof
Sworn and subscribed to before me this
day of M (tr'A , 901?
.44 4= ?'1,
Spa ? ?,
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
MARGARET F. FLICKINGER, Notary Public
Bloomfield Boro, Perry County
My Commission Expires February 16, 2016
So answers
Deputy Sheriff of Perry County
W. Scott Staruch
Versus
Brenda L. & Roger C. Watson
& NavTech
IN THE COURT OF COMMON PLEAS OF
THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA,
PERRY COUNTY BRANCH
No. 2012-1498 Cumberland Co.
SHERIFF'S RETURN
And now March 12 , 2012: Served the within name Brenda L. Watson
the defendant(s) named herin, personally at her place of residence in New Bloomfield Boro-
314 W. Main Street,
New Blmfd,
Perry County, PA, on March 12, 2012 at 11:35 o'clock AM
by handing to Brenda L. Watson, defendant
copy(ies) of the within Complaint
and made known to her the contents thereof
Sworn and subscribed to before me this
day of ?GGt? ?Dl?
LIV?
COMMONWEALTH OF PENNSYLVANIA
1 true and attested
So answers
-1% Avex e4lks
Deputy Sheriff of Perry County
NOTARIAL SEAL
MARGARET F. FLICKINGER, Notary Public
Bloomfield Boro, Perry County
My Commission Expires February 16, 2016
LAWS, STARUCH & PISARCIK
W. Scott Staruch, Esq.
PA Atty ID No. 28337
Gerard J. Pisarcik, Esq.
PA Atty ID No. 39181
W. SCOTT STARUCH and IN THE COURT OF COMMON PLEAS
GERARD J. PISARCIK, trading as CUMBERLAND COUNTY, PENNSYLVANIA
LAWS, STARUCH & PISARCIK,
Plaintiffs
Civil Action No. 12-1498 Civil Tern,Ej c =
V.
r,4
C")
BRENDA I. WATSON, Individually,
ROGER C. WATSON, Individually, and
NAVTECH, INC.,
C7 CD r
Defendants
To: Prothonotary
Please enter judgment in favor of the Plaintiff and against the Defendants above-
named for want of an answer, and assess the Plaintiffs damages as follows:
Relief requested in Complaint $45,178.10
Plus Interest from 311/12 to June 30, 2013 $ 3,346.56
TOTAL: $48,624.66
It is certified that a written notice of intention to file this praecipe was mailed (a copy
of which is attached)to the Defendants against whom judgment is to be entered after the
default occurred and at least 10 days prior to the date of the filing of this praecipe.
Laws, S ruch & Pisarcik
ru',
B . 7 7 Kry/dx,
%fWrard J. PisArcik, Esq.
20 Erford Rd., Ste 105
Lemoyne, PA 17043
(717) 975-0600
� 0� � � �`
LAWS, STARUCH & PISARCIK
W. Scott Staruch, Esq.
PA Atty ID No. 28337
Gerard J. Pisarcik, Esq.
PA Atty ID No. 39181
W. SCOTT STARUCH and : IN THE COURT OF COMMON PLEAS
GERARD J. PISARCIK, trading as : CUMBERLAND COUNTY, PENNSYLVANIA
LAWS, STARUCH & PISARCIK,
Plaintiffs
Civil Action No. 12-1498 Civil Tenn
V.
BRENDA L. WATSON, Individually,
ROGER C. WATSON, Individually, and
NAVTECH, INC., ;
Defendants
To: Brenda L. Watson Date of Notice: April 5, 2012
Roger C. Watson
NavTech, Inc.
314 W. Main St.
New Bloomfield, PA 17068
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford St., Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
An Staruch & Pisarcik
l� �il{/J. Pis ik, Esq.
rd Road, Suite 105
Lemoyne, PA 17043
(717) 975-0600
CERTIFICATE OF SERVICE
I, Gerard J. Pisarcik, Esquire, hereby certify that on the 5th day of April,
2012, 1 served a copy of the Notice of Default by United States Mail, first class, postage
prepaid upon the persons indicated below:
Brenda L. Watson Roger C. Watson
314 W. Main St. 314 W. Main St.
New Bloomfield, PA 17068 New Bloomfield, PA 17068
NavTech, Inc.
Brenda L. Watson, President
314 W. Main St.
New Bloomfield, PA 17068
rd J. Pisar k, Esq.
11
•
LAWS, STARUCH & PISARCIK �1 f �'t�7 ;DU°i, t'.,
W. Scott Staruch, Esq. 7014 JAN 1 S b �; ,,
PA Atty ID No. 28337 CUf�E�ER 0�
Gerard J. Pisarcik, Esq. ��,���AND �rU�1��
PA Atty ID No. 39181 A
W. SCOTT STARUCH and : IN THE COURT OF COMMON PLEAS
GERARD J. PISARCIK, trading as : CUMBERLAND COUNTY, PENNSYLVANIA
LAWS, STARUCH & PISARCIK, :
Plaintiffs :
: Civil Action No. 12-1498 CIVIL TERM
v. .
BRENDA I. WATSON, Individually, :
ROGER C. WATSON, Individually, and :
NAVTECH, INC., :
Defendants :
PRAECIPE TO SATISFY, SETTLE AND DISCONTINUE
To: Prothonotary
Please mark the above suit settled and discontinued and the judgment against all
Defendants.
4
LAWS yA RUCH i
�
CIK
Ifl iiiiiirl
J. Pis- , ik, Esq.�
20 Erford Rd., Ste 105
Lemoyne, PA 17043
(717) 975-0600
CERTIFICATE OF SERVICE
I, Mariann L. Stiely, hereby certify that a true and correct copy of the
Praecipe to Satisfy, Settle and Discontinue was served by mailing by U.S. First Class
Mail, postage prepaid, on the 18th day of November, 2013, to the following:
Brenda I. Watson
Roger C. Watson
NavTech, Inc.
PO Box 756
New Bloomfield, PA 17068
Mariann L. Stiely `
20 Erford Road, Suite 105
Lemoyne, PA 17043
(717) 975-0600