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HomeMy WebLinkAbout13-0094IN THE COURT OF COMMON PLEAS, LANCASTER COUNTY, PENNSYLVANIA UGI HVAC ENTERPRISES, INC. d/b/a UGI HEATING & COOLING, vs. Plaintiff, Civil Action - I aw ROBERT HARBINGER, Defendant. ARBITRATION COMPLAINT NOTICE You have been sued in Court If ~~ou wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance. personalh~ or by attorney, and filing, in writing with the Court, your defenses or objections to the claims set forth against you. You are WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT you and a Judgment may be entered against ti~o^ by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Lancaster Bar Association 28 East Orange Street Lancaster, PA 17602 (717)393-0737 c -~ ~~ ; t-n~ ~-- rat--: ~e-y. 1 ~ ~ r~ ~?~ ..r r,~ -°.~ ~:.. ~~f ~,~ ~; r~ z - y -< -- ~"' _,-. ', o,a~~ ~~~3. ~s~~- °~'1 ~#a$9s IN THE COURT OF COMMON PLEAS, LANCASTER COUNTY, PENNSYLVANIA UGI HVAC ENTERPRISES, INC. d/b/a UGI HEATING & COOLING, Plaintiff, Civil Action - In Law No.: vs. ARBITRATION ROBERT HARBINGER, Defendant. COMPLAINT This is an action by Plaintiff, UGI HVAC ENTERPRISES, INC. DB/A UGI HEATING & COOLING, to recover damages from Defendant arising out of a debt Defendant owes to Plaintiff by virtue of appliance service. 2. UGI HVAC ENTERPRISES, INC. D/B/A UGI HEATING & COOLING is a domestic corporation duly organized and existing and licensed to do business as a public utility under the laws of the Commonwealth of Pennsylvania with a principal place of business at P.O. Box 12407, Reading, Pennsylvania, 19612. ~. Defendant, ROBERT HARBINGER, is an adult individual residing at 206 Lamp Post Lane, Camp Hill, Pennsylvania, 1701 I. 4. At all times relevant hereto, Plaintiff was engaged in the business of producing, furnishing, supplying and distributing utility service and selling appliances to persons and businesses who requested utility service and appliances in accordance with the Rate Schedules and General Rules and Regulations of Plaintiff s Tariff presently on file with the Public Utility Commission. COUNTI BREACH OF COhTTRACT UGI HVAC ENTERPRISES, INC. D/B/A UGI HEATING & COOLING VS. ROBERT HARBINGER 5. Paragraphs 1 through 4 are incorporated as referenced as if fully set forth herein. 6. On or about February 4, 2011, Plaintiff installed a furnace to Defendant, ROBERT HARBINGER. The remaining balance for this appliance is $11,000. 7. Attached hereto and marked Exhibit "A" is a copy of the installation contract. 8. The installation and sale provided by the Plaintiff to the Defendant aforesaid were received, accepted and utilized for the benefit of said Defendant, ROBERT HARBINGER 9. Defendant, ROBERT HARBINGER, is in default of his/her obligation, having failed to make the payments as they became due. 10. Plaintiff made demands on Defendant, ROBERT HARBINGER, to repay the sums then due and owing to Plaintiff, but Defendant, ROBERT HARBINGER, has not made any making payments and continues to refuse to pay Plaintiff. 11. Despite demands upon Defendant, ROBERT HARBINGER, for payment by the Plaintiff, Defendant, ROBERT HA:RRINGER, has failed and refuses to pay Plaintiff the balance due and owing on said account(s). 12. Defendant, ROBERT HARBINGER, has received the benefit of the installation of the furnace being attached to the real estate as a permanent fixture. 1>. Defendant, ROBERT HARBINGER, materially and substantially breached the Agreement by failing to make payments to Plaintiff as required under the Agreement. WHEREFORE, Plaintiff demands judgment against Defendant for damages in the following sums for which Plaintiff demands judgment against the Defendant, ROBERT HARBINGER: Amount Past Due: $ 11,000.00 Attorneys Fees: $ 3,700.00 Court Costs: $ 103.75 Service Costs: __ $ 150.00 TOTAL: $ 14,953.75 COUNT II UNJUST ENRICHMENT UGI HVAC ENTERPRISES, INC. DB/A UGI HEATING & COOLING VS. ROBERT HARBINGER l 4. Paragraphs 1 through 13 are incorporated as referenced as if fully set forth herein. 1 S. Plaintiff provided material and labor for the renovations to the existing building for a new furnace in the vicinity of 206 Lamp Post Lane, Camp Hill, Pennsylvania. 16. The work performed on the project by Plaintiff was a benefit to the real estate which increased its useful life and value. 17. The work performed on the project by Plaintiff was received, accepted, and utilized for the benefit of said Defendant, ROBERT HARBINGER. 18. Plaintiff made demand on Defendant, ROBERT HARBINGER, to repay the sums then due anal owing to Plaintiff, but Defendant has never made any payments and refuses to pay Plaintiff. 19. Defendant, ROBERT HARBINGER, has been unjustly enriched by receiving renovation services without payment. 20. Defendant, ROBERT HARBINGER, had knowledge of the services before they were provided and encouraged the performance of the project. 21. Defendant, ROBERT HARBINGER, received the benefit of work performed to its building in the form of an increased value of the property, and an extension of the useful life of the building. WHEREFORE, Plaintiff demands judgment against Defendant for damages in the following sums for which Plaintiff demands judgment against the Defendant, ROBERT HARBINGER: Amount Past Due: $ 1.1,000.00 Attorneys Fees: $ 3,700.00 Court Costs: $ 103.75 Service Costs: __ $ 150.00 TOTAL: $ 14,953.75 Respectfully submitted, KRZYWICKI & ASSOCIATES, P.C. DATED: January 2, 2013 By: thony P r wic uire .O. B 5 N op , l8 8 215) 862-4390 Attorney for Plaintiff Attorney I.D. 23754 EXHIBIT A SALES PROPOSAL i ORDER 1lGt HVAC 5etvices, Inc. t 50 [l Love ~ioad P q Bax 12407 Reading. FA 1fi6?2-24~t e~rsaa.aezE r ~ u~ ~ ~-~} Data ~j / t f .i t s----- ,-~-~------- /t f `~`~'' `'~ ~~_ Satnsperso+t ~ ~~ t -.._ __ ~~ ~' .tJ is ~~'~ ~ _A ti ~ iiCi __S__.~'= f l `t ~ ~ _._._..._ PhD!tU _ ,.. , .. _. _ ".___._. _~.__ ~. __ _.._______._ Cell ..-._.---- '_.,,...:" ~~_~ ,.mail ____._._._.- P0+ .-- tech _._.._._._._._~ 'rirC „"„o~:. °~.. . ,... ;; vJUJSoI ;7r fhf3 lOlfOwin(f: ",.... , , . .r , ,:: r: tv~';s ir± a Hoar and workmansr p lrke manner ar,C :~9al1 gave a full one war warrnnty on ar'i aquipmBrtt. material and labor Nrth a;r'! r a y'; ","'; " '. ' .~ arr<;n;rOS as allowed by the respective mantfiacturar ~'r ~ ~. t ==e~ , f tr;irs as rtrtluired. V/e will remove an y and a7i dytvis crsre;ed 6r UGt HVAG as G+art o1 the installation. a'3flf./81 :lrl Yu:lon,^. arlin+nay tiRCrs' ;;,; ~.,,r;grin ~.ty',i 1!~C'.~i(a C11;I1!AHy lirl4r Ot 'f.Ci°% CFfiC~BN haI:3B fiYdtars when n!E@53yy and ppsalhie.ltoweV&. 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C , ~ ~' _. ~____ aufltpraivs vAU~ ~ox:u~ oars j L'~ ~~ f~vis ~~ {t~^~}" -----~-1- d'~" ~='---~~ - - tfPdTAT1VE: tNSTAIL GATE _ L??t~j ~~ ------L_.~i.-.,;'/~£:L-_f.~i-_-----, emn_,gzncvw~~kAf,~ttnrita±inn ____.___------- !iSA.i ~%.^,' ;^.."c_'F;` :'r`35?? rViA'/ 8_° USED FOR TFIE RBOVE TOTAi fNVESTMElJT WTfF/THE FOLLOWING COMPLETED ANA ,?~'i rYriR;._~?- r3r 7:i;'^ rftFdli'CARD COMP,4Ny, `1''r^~ =' r~.4fe:: _`'_~_.~_ r'ARrJ NUME3EK a rf ~i k~,`•r?7~ -7 jri .-,.;d/ ~~ ~ // ---.~-.~~ _ _._EXPlfiA7TON-~-~4UTHURIZ<1i70N~'~ ;~~c~ ~! OS. term~~ a:~d cbndit;orts as set forth nr+ Trio trort a ,d reverse side arP satist~ctory and are hereoy ~~ - ~ . - - - -, ,U(ZS'rL`'<J 30 Slls vat7f4 aS ;J~~sCf*f/?},', an~i pr~~"tnont v."f ~( ,,;, .,^sds 35 stsicid 3uCV9. ~_._t f t ~,..f frri~, - C , trnctite-ESr~tnz:"~ Gaw-__.____ a ;~ ` .. .~ ._..!°r;a35;: ire,' a' r!sr ;.; s~;, iMe w>ifl ;i±?r76R17`I atscf rnstatl the i`nf1©Wfng equipment: WORK TiCKET# CHECK LIST `r VOLTS U AMPS __._ L7 CHECK ELECTRICAL GDNNFCTIONS I..) DIL LEYE18 CONDITION tJ VOLtS L] AMPS -.__.. CtIECX ELECTRICAL CONNECTIONS !SLOWER MOTOR ----7 SOLUTION 'Q VO!TS _____ `~] AMPS --•- i OUANITY U CNECXELECTRICALCONNFCTiONS I _ INSPECT PULLEYS & fiELT 0 INSPECT MOTOR BEARINGS i _ BLOWER WHEELOK? YES NO EVAPOR COIL L~. fNSFECT CDR & FIN CUNa1710N ! CHECK REf'N 9UL$ CONDiTiON I TECN~tfCIANS REPORT _ acn+n.pcrax.,.r.r~u, ~~. ~~ ~g-~~~~~~ ~~` ~ ~9~ CAII ]-877-UGl-NVAC - ----~---- FDR ALLYflUR NEATfN6 AND CDDLiN6 SERVICE NEEDS ~ ~' ~ _s:~ ~."r:a~,,ea~ ~f;/, N IC#PAO i 559& r ' -- ~ ~ ;~. ~ '-- _~.~ t~~ ~saL~ lr ~~/ ~'7 f7.r!~s.I ~+i.vY..+~ 1 PART NUMBER & DESCRtPTlON _ _~~ _,~,•a- CiTY .__ J~ .. ~_~. i.. ~MAKF 7YEt SERViCP PLAN A _-_R „ U _-- F G :i NONE PROFESSIONAL DIAGNOSIS -_-_-` DESCAtpitON ------~_.__r.`T T_, i [.i INSPECT OAAfN PAN !... __ ~ ~-----...- -. _.__ -_~ ~ ^ INSPECT DAAiN LINES 1 --~--__.._.~ -__. -. _.,._-_._.__ ._....__.___ ~.~ ~.__ AIR FILL i RATION ITECHNkC1AN ,~~ ,,~,~, ~ r ,~~ WORK PREFORMED --- _ CI OISPD.sat ' TM NfiN DSPACERFP(YRT REPIUANUM6EA ~-_ _____ GG$CRIPTIINt ---T-~ - !.' WASHAOC£ '~.~ ELECTRONIC, i TLIAYEL CONF. SPACE IVES OA NO) - Sf1F __--- CTY --_ ttMF _-~_~ ..~ ----___--_ CGR°,ADiNG AS FOUNO _. PPM _ _. _ -_--_- SIZE OtY ~ TIME ~ - _. ARRfiJEO _- __ .__.~~,_ CO READING AS lEF7 PPM -_ .~~.._-- -` ..___ __ _ -.---- ,_,.,- GAS FURNACE : nMF vELLDwrAG fees GR Nr,I ~ ! INSPECT FUEL SUPPLY PRESSURE ~ DEPARTED ~____.._^_. AED TAG ~YFS OR K4! .~ .__ ."- _.. .~. _ __ ... ~____.__._ L.1 INSPECT HEAT EXCHANGER YfARRANTY TERM$ --""' ---'~'-'-- ---~~- -_ CHECK SAFETY CONTROLS ~ We wish to provide the Righesc lave? of profassiodalism am) quaiN sercacd avang wrhthe hea! customer _ rn WATER NEATER assurance policy in the indusary. par se;viod repair warranty poi cy is: - ` ~""°---"--------- -- t. Ailpana rdP~aced byosvaRhewarrsMedto be heetrreperiod of TB MfABOR $-____T:St L2 HUURa.____-_.AL'UITIONAL I;+HvURS 7(5,~,-,.,-.PER t14l10UR Q THFRMO COUPLE ---. Marty servico companies provide 3p,W, ar 9D day warranties. lNa teal That the parts w8 instaAed lave -'- -------~---- ~ _ __ REl1Ef VALVE ~ bten cardfuf!y salecte0 anil meet or ezcedd maneFacaaer speciEcations. For~LS reason vee kei CUSTOMFA `"`"' -"" TOTS I..i FLt1E VIV;: ,~ caalortable offerinp this eYCelidm warranty. Tha laoor to V!staq the warraraed ~ RECUEST r ~ THERMOSTAT bekw. Datt(sjrcu'iseossedml2 i DatE I / 2~ -- --d°-~' GATE OIiDEREO i ~ _ i~ ._ iaTESDHEDUtc-c 1 ~~~'__L HONE U WAPoLtNtt ^ CDO SEP.YICE CONTRA;:T 'BILL CUSTOMER RES. La COMM. roTu Z. Our raper iaoor is warranted for a GarL:d of Sub-TOTAL PILOT ~ This is tha laborto repair or rapfaea fl:e part wu insiai~ed ir. iha mtial repair, and norm correct other ~ MOILER ! problems that may have arisen in the in,erim. TFCHNIC(AN ~'~ ' !~ INSPECT PUMPING SYSTEM ^ INSPECT IOW WATER CUTOFF {~ INSPECT EJCPANSION TANK ~ ) , REFRlGERANT La INSPECT SAFETY C.flMRl1tS R RECOVERED? ~,_ ~ , ELECTRIC NEAT E ~ aTr ^ lNSPF'CT NFAT STR?PS ; E . L7 iNSPECrEUSes ; H 2. RFCyctEaa ;.] ~.,~ OT Y D CRECK SAFETY Cr'NiROtS ~ YES , NG THERMOSTAT I ! G 3. REC?AtMEO7 ^ `~ uTY O ctlEClcDreRAnDty L BPo4TC I ~~ . NG E Q ~L t R AE7URNEU 10 ^ Q DTY ZONING ; A L~srsTTMT yFS . ND C3 RISPECTACTUA70RS&DAMPEfiS 4NSPECT CONTROLLER (] CHECKELECTRiCALCONNECTIO I N Q. NDN USEABLE { il P^SA (_, t_7 orY. NS rT itt.DKfl ft+/Fgai+i:DCga~inlnl ~ , y ~~ vE$ ND siGNAntRE DIAGNOSTIC CEtARGE r CHANGED __ ~._._ ...--.."~ ^r....-.._. ""~ ----- _ _ _-_ TAX DDT;DR! ~ --~-- PRE-AUT R(ZATiON J J__.__ __ ___ RE•rLAr,LVt YES ND j !HAVE THE AUTHORITY TD ORDER THE ABOVE ~VORlC AND OD 50 T4Tkt ORDER AS OUTLINED ABOVE.171S AGREED THAT THE SELLER WILL AAdf3UNT DISMaNTLEm Q l~ ~ RETAIN TITLE TO ANY EoU1PMENT OR MATERIAL FURNISHED UNTI[. Yes ND ~ F7NAL AND COMPLETE PAYMENT IS MADE, AND IF SETTLEMENT DDE REPRIGERANr DispusaL iS NOT MADE AS AGREED, THE SELLER SHALL HAVE THE RIGHT TO 5, ~ REMOVE SAME AND THE SELLER W€LL 8E HELD HARMLESS FOR BALANCE DUE UPON COMPLETION ourvFas fNIT~d7 C ~ ANY DAMAGES RESULTING FROM THE REMOVAL THEROF. --4r_ DATF - a1rrRDRrz£asIGNATGRE --- CC Dr CNECK AUTH:~ `HaEg'AEOVE uR W RAS OEEN OMPL£Y A. {ACKNO l iTE EITYpFMY COPY '~~~-~"--- A VERIFICATION Pursuant to Rule 1024 (c), I, ANTHONY P. KRZYWICKI, ESQUIRE, verify that I am the attorney for Plaintiff in the within case; that the appropriate officers of the Plaintiff are not available within the time for serving the foregoing to provide their verification; that I am sufficiently familiar with the facts set forth in the foregoing Pleading to take this verification; and that such facts are true and correct to the best of my knowledge, information and belief, based upon the company's business records and matters of public record. I understand that the statements herein are made subject to the penalties of 18 Pa. Consol. Stat. Ann. § 4904 relating to unsworn falsification to authorities. DATED: January 2, 2013 KRZYWICKI &ASSOCIATES,P.C. 1 Anthony P. Krzywicki,Esquire ;,f r Attorney for Plaintiff 6 �`yy 7 P.O. Box 505 New Hope, PA 18938 (215) 862-4390 PA Attorney ID 23754 IN THE COURT OF COMMON PLEAS,CUMBERLAND COUNTY,PENNSYLVANIA UGI HVAC ENTERPRISES, INC. d/b/a UGI HEATING& COOLING, Plaintiff,. Civil Action—In Law No.: 13-94 Civil vs. : ARBITRATION ROBERT HARRINGER, Defendant. MOTION TO COMPEL DISCOVERY Pursuant to Pa.R.C.P. 4019, Plaintiff, UGI HVAC Enterprises, Inc. d/b/a UGI Heating & Cooling, moves the Court to enter an order in the form attached, directing Defendant, Robert Harringer, to comply with Plaintiff's discovery requests within thirty (30) days of the entry of the Order, and to pay to Plaintiff costs incurred in preparing this motion and supporting memoranda. In support of this motion Plaintiff alleges as follows: 1. Plaintiff served Request for Documents and Interrogatories directed to Defendant, Robert Harringer, on May 1, 2013 and June 24, 2013. See Exhibit A. 2. No answers or objections to Plaintiff's Request for Documents and Interrogatories directed to Defendant, Robert Harringer, have been received by Plaintiff as of the date of this motion. 3. A Judge has not ruled upon any other issues in this matter. 4. There is no opposing counsel of record. WHEREFORE, Plaintiff, UGI HVAC Enterprises, Inc. d/b/a UGI Heating & Cooling respectfully requests the Court to enter an order-directing Defendant, Robert Harringer, to comply with Plaintiff's discovery requests within thirty (30) days of the date of order, and to pay Plaintiff costs incurred in preparing this motion and supporting memoranda. Respectfully submitted, KRZYWICKI OCIATES, P.C. DATED: August 7, 2013 By: Anthony zywic squire Atto y or P t' KRZYWICKI &ASSOCIATES,P.C. Anthony P. Krzywicki,Esquire Attorney for Plaintiff P.O. Box 505 New Hope,PA 18938 (215)862-4390 PA Attorney ID 23754 IN THE COURT OF COMMON PLEAS,CUMBERLAND COUNTY,PENNSYLVANIA UGI HVAC ENTERPRISES,INC. d/b/a UGI HEATING&COOLING, Plaintiff, Civil Action—In Law No.: 1')-94 Civil VS. ARBITRATION ROBERT HARRINGER, Defendant. MEMORANDUM IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL DISCOVERY 1. STATEMENT OF FACTS This case arose from an action brought by Plaintiff, UGI HVAC Enterprises, Inc. d/b/a UGI Heating& Cooling,to recover sums due from damages to their property. Plaintiffs Request for Documents and Interrogatories directed to Defendant, Robert Harringer, were served on Defendant on May 1, 2013 and June 24, 2013. Plaintiff has received no answers or objection to Plaintiffs Request for Documents and Interrogatories directed to Defendant, Robert Harringer, no answers have been produced and no extension of time to answer has been requested by the Defendant. 11. DISCUSSION - Defendant's failure to answer Plaintiffs Request for Documents and Interrogatories directed to Defendant,Robert Harringer, is in violation of Pa'.R.C.P. 3117, 4006 (a)(2)and 4009. Rule 4019(a) (1) (I) and 4019 (a) (1) (vii) permit the court, upon motion, to impose sanctions against a party who fails to respond to discovery requests. Additionally, Rule 4019 (c) (5) states that "[t]he Court, when acting under subdivision (a) of this rule, may make...such order with regard to the failure to make discovery as is just." In Gonzalez v. Procaccio Brothers Trucking Co., 268 Pa. Super. 245, 407 A.2d 1338 (1972), the Court Stated: Pa.R.C.P. 4019 is clear. It establishes an unequivocal and mandatory procedure. Where [a party fails to comply with a discovery request] a motion must be presented to the court to determine the default. [Citation omitted.] Upon finding that a default has occurred, "the court may...make an appropriate order." The imposition of specific sanctions, however, is largely within the discretion of the court. [Citations omitted]. 407 A.2d at 1341. III. CONCLUSION For the foregoing reasons, Plaintiff requests that the Court enter an order, in the form attached, directing Defendant to comply with Plaintiff s discovery requests. Respectfully submitted, KRZYWICKI SSOCIATES, P.C. DATED: August 7, 2013 BY• 4VKr Esquire EXHIBIT A KRZYWICKI &ASSOCIATES,P.C. By: Anthony P. Krzywicki,Esquire Attorney for Plaintiff P.O.Box 505 New Hope,PA 18938 (215) 862-4390 PA Attorney ID 23754 IN THE COURT OF COMMON PLEAS,CUMBERLAND COUNTY,PENNSYLVANIA UGI HVAC ENTERPRISES, INC. d/b/a UGI HEATING&COOLING, Plaintiff, Civil Action—In Law No.: 13-94 Civil vs. ARBITRATION ROBERT HARRINGER, Defendant. REQUEST FOR DOCUMENTS AND INTERROGATORIES DIRECTED TO DEFENDANT,ROBERT HARRINGER Pursuant to the Pennsylvania Rules of Civil Procedure, Plaintiff hereby serves on Defendant the following set of first request for documents and interrogatories, to be answered separately by each defendant. Definitions I. The term "incident/accident" as used hereinafter refers to the subject of this litigation,the events or occurrences of which are set forth in the complaint filed in this matter, 2. The term "identify" means the party served with these Interrogatories must identify all documents, things and persons known to that party or to that party's attorney, and the addresses of all persons identified must be set forth. 3. The term"address or location" as hereinafter used shall mean the last known address or location, giving the street number,name of street, city and state. 4. The term "defendant" as used hereinafter shall mean the defendant, its officers, directors, agents, servants, employees, attorneys,representatives, or anyone acting on its behalf Instructions 1. All information is to be divulged which is in the possession of the Defendant,his/her attorney or former attorneys, investigators, agents, employees, or other representative of the Defendant or his/her attorneys. 2. These interrogatories are intended as continuing requiring that they be supplemented within 30 days with such information within their scope as may be acquired following your original answers by you,your agents, attorneys, or representatives. INTERROGATORIES & DOCUMENTS TO BE PRODUCED 1. Please state and produce the facts, documents, letters, telephone logs, written statements, memoranda, pictures, opinions, or other information upon which you relied that support your contention in Count I, paragraph 10 of the Defendant's Answer to Complaint that "It is admitted that several months after Plaintiff left the job, Plaintiff demanded full payment for the work that was not completed...Defendant offered to pay for the completed job after Plaintiff actually completed the job." KRZYWICKI & ASSOCIATES, P.C. Dated: May 1, 2013 By: Anthony P. Krzywicki, Esquire Attorney for Plaintiff CERTIFICATE OF SERVICE I certify that on this date I served a copy of the foregoing Request for Documents and Interrogatories Directed to Defendant, by depositing a true copy of same in a depository under the exclusive care and custody of the United States Postal Service, via prepaid, first class mail, and addressed as follows: Mr. Robert Harringer 206 Lamp Post Lane Camp Hill, PA 17011 Pro Se KRZYWICKI&ASSOCIATES,P.C. Dated: May 1,2013 BY: Anthony P. Krzywicki,Esquire Attorney for Plaintiff LAW OFFICES KRZYWICKI & ASSOCIATES, P.C. P.O.sox 505 NEW HOPE,PA 18938 (215)862-4390 FAX:(215)862-4393 June 24, 2013 Mr..Robert Harringer 206 Lamp Post Lane Camp Hill, PA 17011 RE: UGI HVAC Enterprises,Inc. d/b/a UGI Heating& Cooling vs. Robert Harringer Civil Action No.: 13-94 Civil Our File No.: 4031 UH Dear Mr. Harringer: On May 1, 2013, the attached Plaintiff's Request for Documents and Interrogatories Directed to Defendant, were forwarded to your attention. Time for answering has expired. When can we expect answers? Thank you for your cooperation. Very truly yours, KRZYWICKI&ASSOCIATES,P.C. Anthony P. Krzywicki,Esquire Attorney for Plaintiff APK/amg Enclosure M CERTIFICATE OF SERVICE I, Anthony P. Krzywicki, Attorney for Plaintiff, hereby certifies that a true and correct copy of the foregoing Motion to Compel, Memorandum in Support thereof and a form of Order were placed in a depository under the exclusive care and custody of the United States Postal Service to deliver via First Class Mail to the following: Mr. Robert Harringer 206 Lamp Post Lane Camp Hill, PA 17011 Pro Se KRZYWICKI & ASSOCIATES, P.C. DATED:August 7, 2013 ByJewony zywi quire ox 5 Hope, PA 18 (215) 862-4390 Attorney for Plaintiff Attorney ID 23754 UGI HVAC ENTERPRISES, INC. IN THE COURT OF COMMON PLEAS OF d/b/a UGI HEAING AND CUMBERLAND COUNTY, PENNSYLVANIA COOLING, Plaintiff CIVIL ACTION-LAW NO. 13-094 CIVIL vs. ROBERT HARRINGER, Defendant IN RE: PLAINTIFF'S MOTION TO COMPEL ORDER AND NOW, this /�v` day of August, 2013, a rule is issued on the defendant to show why the relief requested in the within Motion to Compel ought not to be granted. This rule returnable twenty (20) days after service. BY THE COURT, "�z - "�-4 Kevi . Hess, P. J. rrnr-�I acs , • ,wit v.R ._ = IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA UGI HVAC ENTERPRISES, INC d/b/a . UGI HEATING& COOLING, Civil Action - In Law :• No. 13-94 Civil Plaintiff, . • vs. • ARBITRATION • ROBERT HARRINGER, . Defendant. : PRAECIPE TO SETTLE,DISCONTINUE,AND END TO THE PROTHONOTARY: Kindly mark this matter Settle, Discontinue, and End against the Defendant without prejudice upon payment of your costs only. KRZYWICKI & _:SSOCIATES,P.C. DATED: December 23,2013 .41V/` BY: A thony P. w - . .'re P.O.B. - 50, Hope top "- 1:• 8 (215) 862-4391 Attorney for ' :• tiff Attorney I.D. 23754 < > yyC: co c:.>C , ...< co •