HomeMy WebLinkAbout13-1794 Supreme Co nnsylvania
COUP1»1 leas For Prothonotary Use Only:
t Docket No:
-�� Cu � „�L County I f
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S 0 Complaint 0 Writ of Summons 0 Petition
O Transfer from Another Jurisdiction Declaration of Taking
E Lead Plaintiff s Name: Lead Defendant's Name:
C LEONORA D'AIRO and EDDIE SUTTON, JR. TALIB O. KARIM and BAFRIN A. KARIM
T Dollar Amount Requested: Owithin arbitration limits
I Are money damages requested? M Yes 0 No (check one) [@outside arbitration limits
O
N Is this a Class Action Suit? 0 Yes ll No Is this an MDJAppeal? 0 Yes E No
A Name of Plaintiff /Appellant's Attorney: ULYSSES S. WILSON, ESQUIRE
0 Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
0 Intentional IN Buyer Plaintiff Administrative Agencies
O Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment
0 Motor Vehicle 0 Debt Collection: Other O Board of Elections
0 Nuisance Dept. of Transportation
0 Premises Liability 8 Statutory Appeal: Other
S 0 Product Liability (does not include
❑Employment Dispute:
E mass tort) 0 Discrimination
Slander/Libel/ Defamation
C 0 Other: 0 Employment Dispute: Other 0 Zoning Board
0 Other:
T
I 0 Other:
O MASS TORT
0 Asbestos
N 0 Tobacco
O Toxic Tort - DES
0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
0 Toxic Waste 0 Ejectment 0 Common Law /Statutory Arbitration
0 Other: 0 Eminent Domain/Condemnation Declaratory Judgment
B 0 Ground Rent Mandamus
0 Landlord/Tenant Dispute Non - Domestic Relations
0 Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto
0 Dental 0 Partition 0 Replevin
O Legal 0 Quiet Title 0 Other:
0 Medical ❑ Other:
Other Professional:
Updated 1/1/2011
�t�EQ•O�F! prARY
JOHNSON, DUFFIE, STEWART & WEIDN Co���Y Attorneys for Plaintiffs
By: Ulysses S. Wilson CU Y COU
I.D. No. 312598
301 Market Street - P. O. Box 109
Lemoyne, PA 17043 -0109
(717) 761 -4540
LEONORA D'AIRO and EDDIE SUTTON IN THE COURT OF COMMON PLEAS OF
JR., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V CIVIL ACTION - LAW
TALIB O. KARIM and BAFRIN A. KARIM �3 1 9y
husband and wife, NO.
Defendants
JURY TRIAL DEMANDED
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Complaint and
Notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without 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, 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 MY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
Lawyer Referral and Information Service
32 South Bedford St.
Carlisle, PA 17013
Telephone (717) 249 -3166
Toll Free (800) 990 -9108
41 a kq. I d3.�S�x1 Q
N, 1+ 109 U
i2w 00% %10>
NOTICE
CONCERNING MEDIATION OF ACTIONS PENDING BEFORE
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
The Judges of the Court of Common Pleas of Cumberland County believe that mediation
of lawsuits is a very important component of dispute resolution. Virtually all lawsuits can benefit
in some manner from mediation.
The Court has adopted Cumberland County Local Rule 1001 to encourage the use of
mediation. This early alert enables litigants to determine the best time during the life of their
lawsuit for a mediation session. The intent of this early alert is to help the parties act upon the
requirement to consider good faith mediation at the optimal time.
The Cumberland County Bar Association provides mediation services and can be
reached at (717) 249 -3166. Free mediation sessions for pro bono cases referred by MidPenn
Legal Services are available through the CCBA.
"ISO
LISTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomaraccion dentro
de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte
por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya.
Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso
puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o
cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra
suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros
derechos importantes para usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI
LISTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA
OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS
QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE
CUALIFICAN.
Cumberland County Bar Association
Lawyer Referral and Information Service
32 South Bedford St.
Carlisle, PA 17013
Telephone (717) 249 -3166
Toll Free (800) 990 -9108
2
"ISO
REFERENCES A LA MEDIACION DE LAS ACCIONES PENDIENTES ANTES
LA CORTE DE SOPLICAS COMUNES DEL CONDADO DE CUMBERLAND
Los jueces de la corte de suplicas corn unes del condado de Cumberland creen que la
mediacion de pleitos es un componente rnuy importante de la resolucion del conflicto.
Virtualrnente todos los pleitos pueden beneficiar de cierta manera de la mediacion.
La code ha adoptado la regla local de condado de Cumberland 1001 para animar el use
de la mediaciOn. Esta alarrna tern prana permite a litigantes determiner la rnejor epoca durante
la vida de su pleito para una sesion de la med iacion. El intento de esta alarrna tern prana es
actuar sobre la mediacion de la buena fe en el tiempo Optimo.
La asociacion de la barra del condado de Cumberland proporciona servicios de la
mediacion y se puede alcanzar en (717) 249 -3166 . La sesi6n libre de la rnediaciOn para los
favorables casos del bono se refinio por MidPenn que los servicios juridicos estan disponibles
con el CCBA.
3
JOHNSON, DUFFIE, STEWART & WEIDNER Attorneys for Plaintiffs
By: Ulysses S. Wilson
I.D. No. 312598
301 Market Street - P. O. Box 109
Lemoyne, PA 17043 -0109
(717) 761 -4540
LEONORA D'AIRO and EDDIE SUTTON IN THE COURT OF COMMON PLEAS OF
JR., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. CIVIL ACTION - LAW
TALIB O. KARIM and BAFRIN A. KARIM,
husband and wife, NO.
Defendants
JURY TRIAL DEMANDED
COMPLAINT
AND NOW, come the Plaintiffs, Leonora D'Airo and Eddie Sutton Jr., by and through
their attorneys, Johnson, Duffie, Stewart & Weidner, and respectfully submit the following:
THE PARTIES
1. Plaintiff, Leonora D'Airo, is an adult individual and owner of the residence located
at 349 N. 2 nd Street, Wormleysburg, Cumberland County, Pennsylvania 17043 (hereinafter the
"Property ").
2. Plaintiff, Eddie Sutton Jr., is an adult individual and resides at the residence
located at 349 N. 2 nd Street, Wormleysburg, Cumberland County, Pennsylvania 17043
(hereinafter the "Property ").
3. Defendants, Talib O. Karim and Bafrin A. Karim, husband and wife, are adult
individuals who reside at 117 Dogwood Drive, Pittsburgh, Pennsylvania 15235.
4
FACTUAL BACKGROUND
4. Defendants purchased the Property on or around May 30, 2000.
5. Defendants sold the Property to Plaintiff D'Airo on May 30, 2012 by Deed
#201217105 recorded on June 8, 2012. A copy of the Deed is attached as Exhibit A.
6. Defendants answered "No" in response to the disclosure, "Are you aware of any
water leakage, accumulation, or dampness within the basement or crawl space ?" See Question
4(b) on Seller's Property Disclosure Statement, attached as Exhibit B.
7. Defendants answered "No" in response to the disclosure, "Are you aware of any
past or present water leakage in the house or other structures ?" See Question 6(a) on Seller's
Property Disclosure Statement, attached as Exhibit B.
8. Defendants answered "No" in response to the disclosure, "Do you know of any
past or present drainage or flooding problems affecting the property ?" See Question 16(b) on
Seller's Property Disclosure Statement, attached as Exhibit B.
9. In or around early summer of 2012, after several days of heavy rain, Plaintiffs
discovered water in the Property's basement.
10. In or around late fall of 2012, after several days of heavy rain, Plaintiffs
discovered large amounts of water in the Property's basement.
11. At the request of the Plaintiffs, on or around January 10, 2013 and January 17,
2013, waterproofing and concrete specialists conducted visits to the Property to determine the
extent of the water damage.
12. The specialists discovered that within the last two (2) years the Property's
basement had been "drylocked," a process to repair /remediate wet, flooded, and water prone
basements.
5
13. The specialists discovered the grout between the basement cinderblock walls
had turned into crumbling white powder; a result of the basement being exposed to acidic rain
water over a long period of time.
14. At the same time, the specialists discovered a large squeegee left in the
basement by the Defendants, presumably to move standing water in the basement.
15. The specialists removed wall paneling in the basement and discovered extensive
water damage including mold, mildew, and warped baseboards requiring professional mold
removal and remediation.
16. The basement requires waterproofing and installation of a sump pump at the cost
of $17,679.00. See Proposal for Foundation Waterproofing attached as Exhibit C.
17. Professional mold removal and remediation is estimated to cost six thousand
dollars ($6,000.00).
18. It is believed and therefore averred that the Defendants were aware of the
Property's basement water problems before they sold the Property to the Plaintiffs.
19. These defects were not disclosed to Plaintiff by the Defendants.
20. Rather, the history of water in the basement was concealed by the Defendants
prior to sale.
21. Furthermore, Defendants engaged in fraud, purposeful concealment and failure
to disclose material defects to the Property before its sale to the Plaintiff in 2012, which was
later discovered as pled above.
COUNT I -
(FRAUDULENT CONCEALMENT (§ 550 OF RESTATEMENT OF TORTS)
LEONORA VAIRO v. TALIB O. KARIM and BAFRIN A. KARIM
6
22. Paragraphs 1 through 21 of Plaintiffs' Complaint are incorporated herein by
reference as if set forth in full.
23. The Restatement of Torts 2d § 550 states: "One party to a transaction who by
concealment or other action intentionally prevents the other from acquiring material information
is subject to the same liability to the other, for pecuniary loss as though he had stated the
nonexistence of the matter that the other was thus prevented from discovering."
24. As pled, the Defendants agreed to sell the Property to Plaintiff by an Agreement
of Sale on or about April 17, 2012.
25. Related to that sale, the Defendants completed the required Real Estate Seller's
Disclosure Statement.
26. The same was delivered to Plaintiffs and is dated January 27, 2012 and is
attached hereto as Exhibit B.
27. As indicated on the Seller's Disclosure Statement the Defendants were asked
and answered as follows:
4. BASEMENTS AND CRAWL SPACES
(b) Are you aware of any water leakage, accumulation, or dampness
within the basement or crawl space? Yes X No
See Question 4(b) on Seller's Property Disclosure Statement, attached as
Exhibit
6. STRUCTURAL ITEMS
(a) Are you aware of any past or present water leakage in the house
or other structures? Yes X No
16. LAND (SOILS, DRAIANGE, FLOODING, AND BOUNDARIES)
(b) Flooding /Drainage
7
(2) Do you know of any past or present drainage or flooding
problems affecting the property? Yes X No
28. As pled, drylocking undertaken to conceal and correct water damage to the
basement was discovered by Plaintiffs' experts after Plaintiffs moved into the Property.
29. This repair /remediation was made during the ownership of the Property by the
Defendants.
30. Despite making or causing this repair to be made, the Defendants did not
disclose the same or any suspicions as to basement water issues with the Property on the
Seller's Disclosure Statement or otherwise.
31. Since this repair was made, Defendants knew there was water leakage,
accumulation, or dampness within the basement.
32. Since this repair was made, the Defendants knew there was past and /or present
water leakage in the house.
33. Since this repair was made, the Defendants knew there was past and /or present
flooding or drainage problems affecting the property.
34. The responses of the Defendants to the above questions on the Sellers'
Disclosure Statement were fraudulent and intentional misrepresentations to the Plaintiffs.
35. These representations were made to Plaintiff D'Airo to induce her to purchase
the Property at a price which did not reflect these concealed defects.
36. The fraudulent misrepresentations have caused Plaintiff D'Airo injury in that she
was not aware of the basement water problems with the Property when she purchased the
same at a purchase price which was reflective of no defects known by the Sellers.
8
37. Plaintiff D'Airo has also suffered injury caused by these misrepresentations in the
costs to repair the Property which is substantial.
38. The Defendants conduct in concealing the repairs /remediations of defects in the
home and misrepresenting that there were no known or reasonably discoverable material
defects with the Property amounts to reckless conduct.
39. Based upon the actions and omissions pled herein, Plaintiff D'Airo seeks punitive
damages against the Defendants.
WHEREFORE, Plaintiff D'Airo demands judgment against the Defendants Talib O.
Karim and Bafrin A. Karim, in an amount of $23,679.00 for compensatory damages plus punitive
damages, and such other relief as this Honorable Court deems appropriate.
COUNT II
(FRAUDULENT OR INTENTIONAL MISREPRESENTATION /FAILURE TO
DISCLOSURE ( §551 OF RESTATEMENT OF TORTS))
LEONORA VAIRO v. TALIB O. KARIM and BAFRIN A. KARIM
40. Paragraphs 1 through 39 of Plaintiffs' Complaint are incorporated herein by
reference as if set forth in full.
41. As pled, the Defendants agreed to sell the Property to Plaintiff by an Agreement
of Sale on or about April 17, 2012.
42. Related to that sale, the Defendants completed the required Real Estate Seller's
Disclosure Statement.
43. The same was delivered to Plaintiff and is dated January 27, 2012, and is
attached hereto as Exhibit B.
44. As indicated on the Seller's Disclosure Statement, the Defendants were asked
and answered as follows:
9
4. BASEMENTS AND CRAWL SPACES
(b) Are you aware of any water leakage, accumulation, or dampness
within the basement or crawl space? Yes X No
See Question 4(b) on Seller's Property Disclosure Statement, attached as
Exhibit
6. STRUCTURAL ITEMS
(a) Are you aware of any past or present water leakage in the house
or other structures? Yes X No
16. LAND (SOILS, DRAIANGE, FLOODING, AND BOUNDARIES)
(b) Flooding /Drainage
(2) Do you know of any past or present drainage or flooding
problems affecting the property? Yes X No
45. As pled, drylocking undertaken to conceal and remediate water damage to the
basement was discovered by Plaintiffs' experts after Plaintiffs moved into the Property.
46. This repair /remediation was made during the ownership of the Property by the
Defendants.
47. Despite making or causing this repair /remediation to be made, the Defendants
did not disclose the same or any suspicions as to basement water issues with the Property on
the Seller's Disclosure Statement or otherwise.
48. Since this repair was made, Defendants knew there was water leakage,
accumulation, or dampness within the basement.
49. Since this repair was made, the Defendants knew there was past and/or present
water leakage in the house.
10
50. Since this repair was made, the Defendants knew there was past and /or present
flooding or drainage problems affecting the property.
51. The responses of the Defendants to the above questions on the Sellers'
Disclosure Statement are fraudulent and intentional misrepresentations to the Plaintiffs.
52. These representations were made to Plaintiff D'Airo to induce her to purchase
the Property at a price which did not reflect these concealed defects.
53. These fraudulent misrepresentations have caused Plaintiff D'Airo injury in that
she was not aware of the basement water problems with the Property when she purchased the
same at a purchase price which was reflective of no defects known by the Sellers.
54. Plaintiff D'Airo has also suffered injury caused by this misrepresentation in the
costs to repair the Property which is substantial.
55. The Defendants conduct in concealing the repairs /remediations of defects in the
home and misrepresenting that there were no known or reasonably discoverable material
defects with the Property amounts to reckless conduct.
56. Based upon the actions and omissions pled herein, Plaintiff D'Airo seeks punitive
damages against the Defendants.
WHEREFORE, Plaintiff D'Airo demands judgment against the Defendants Talib O.
Karim and Bafrin A. Karim, in an amount of $23,679.00 for compensatory damages plus punitive
damages, and such other relief as this Honorable Court deems appropriate.
COUNT III
(VIOLATION OF SELLERS DISCLOSURE LAW— 68 PA.C.S.A. §7311 ET SEQ.)
LEONORA D'AIRO v. TALIB O. KARIM and BAFRIN A. KARIM
57. Paragraphs 1 through 56 of Plaintiffs' Complaint are incorporated herein by
reference as if set forth in full.
11
58. The Real Estate Seller Disclosure Law 68 Pa.C.S. §§ 7301 et seq. provides that
any seller who intends to transfer any interest in real property shall disclose to the buyer any
material defects with the property by completing all applicable items in a property disclosure
statement and shall deliver to the buyer a signed and dated copy of the completed statement
prior to the signing of an agreement of transfer by the seller and buyer with respect to the
property.
59. As pled, the Defendants agreed to sell the Property to Plaintiff by an Agreement
of Sale on or about April 17, 2012.
60. Related to that sale, the Defendants completed the required Real Estate Seller's
Disclosure Statement.
61. The same was delivered to Plaintiff and is dated January 27, 2012, and is
attached hereto as Exhibit B.
62. As indicated on the Seller's Disclosure Statement the Defendants were asked
and answered as follows:
4. BASEMENTS AND CRAWL SPACES
(b) Are you aware of any water leakage, accumulation, or dampness
within the basement or crawl space? Yes X No
See Question 4(b) on Seller's Property Disclosure Statement, attached as
Exhibit
6. STRUCTURAL ITEMS
(a) Are you aware of any past or present water leakage in the house
or other structures? Yes X No
16. LAND (SOILS, DRAIANGE, FLOODING, AND BOUNDARIES)
(b) Flooding /Drainage
12
(2) Do you know of any past or present drainage or flooding
problems affecting the property? Yes X No
63. As pled, repairs /remediations undertaken to conceal and remediate water
damage to the basement were discovered by Plaintiffs' experts after Plaintiffs moved into the
Property.
64. This repair was made during the ownership of the Property by the Defendants.
65. Despite making or causing this repair to be made, the Defendants did not
disclose the same or any suspicions as to basement water problems with the Property on the
Seller's Disclosure Statement or otherwise.
66. Since this repair was made, Defendants knew or should have known there was
water leakage, accumulation, or dampness within the basement.
67. Since this repair was made, the Defendants knew or should have known, there
was past and /or present water leakage in the house.
68. Since this repair was made, the Defendants knew or should have known there
was past and /or present flooding or drainage problems affecting the property.
69. The responses of the Defendants to the above questions on the Seller's
Disclosure Statement are negligent misrepresentations to the Plaintiff.
70. These misrepresentations have caused Plaintiff D'Airo injury in that she was not
aware of the basement water problems with the Property when she purchased the same at a
purchase price which was reflective of no material defects known by the Sellers.
71. Plaintiff D'Airo has also suffered injury caused by these misrepresentations in
costs to repair the Property which is substantial.
13
72. The Defendants' conduct in concealing the repairs /remediations to the home and
negligently misrepresenting that there are no known or reasonably discoverable material defects
with the Property amounts to reckless conduct.
73. Based upon the actions and omissions pled herein, Plaintiff D'Airo seeks punitive
damages against the Defendants.
WHEREFORE, Plaintiff D'Airo demands judgment against the Defendants Talib O.
Karim and Bafrin A. Karim, in an amount of $23,679.00 for compensatory damages plus punitive
damages, and such other relief as this Honorable Court deems appropriate.
COUNT IV
(VIOLATION OF THE UNFAIR TRADES PRACTICES AND CONSUMER
PROTECTION LAW — 73 P.S. § 201 -1 ET SEQ.)
LEONORA D'AIRO v. TALIB O. KARIM and BAFRIN A. KARIM
74. Paragraphs 1 through 73 of Plaintiff's Complaint are incorporated herein by
reference as if set forth in full.
75. As pled, the Defendants agreed to sell the Property to Plaintiff by an Agreement
of Sale on or about April 17, 2012.
76. The Property was purchased by Plaintiff D'Airo to be used as a residence by her
and her son, Plaintiff Sutton.
77. The Property continues to be used as Plaintiffs' residence.
78. Related to that sale, the Defendants completed the required Real Estate Seller's
Disclosure Statement.
79. The same was delivered to Plaintiff and is dated January 27, 2012, and is
attached hereto as Exhibit B.
14
80. As indicated on the Seller's Disclosure Statement the Defendants were asked
and answered as follows:
4. BASEMENTS AND CRAWL SPACES
(b) Are you aware of any water leakage, accumulation, or dampness
within the basement or crawl space? Yes X No
See Question 4(b) on Seller's Property Disclosure Statement, attached as
Exhibit
6. STRUCTURAL ITEMS
(a) Are you aware of any past or present water leakage in the house
or other structures? Yes X No
16. LAND (SOILS, DRAIANGE, FLOODING, AND BOUNDARIES)
(b) Flooding /Drainage
(2) Do you know of any past or present drainage or flooding problems
affecting the property? Yes X No
81. As pled, repairs /remediations undertaken to conceal and remediate water
damage to the basement were discovered by Plaintiffs' experts after Plaintiffs moved into the
Property.
82. This repair was made during the ownership of the Property by the Defendants.
83. Despite making or causing this repair to be made, the Defendants did not
disclose the same or any suspicions as to basement water issues with the Property on the
Seller's Disclosure Statement or otherwise.
84. Since this repair was made, Defendants knew or should have known there was
water leakage, accumulation, or dampness within the basement.
15
85. Since this repair was made, the Defendants knew or should have known, there
was past and /or present water leakage in the house.
86. Since this repair was made, the Defendants knew or should have known there
was past and /or present flooding or drainage problems affecting the property.
87. The responses of the Defendants to the above questions on the Seller's
Disclosure Statement are fraudulent misrepresentations to the Plaintiff.
88. Each of these fraudulent misrepresentations are an unfair trade practice under
Pennsylvania law.
89. These misrepresentations have caused Plaintiff D'Airo injury in that she was not
aware of the basement water problems with the Property when she purchased the same at a
purchase price which was reflective of no material defects known by the Sellers.
90. Plaintiff D'Airo has also suffered injury caused by these misrepresentations in
costs to repair the Property which is substantial.
91. The Defendants' conduct in concealing the repairs /remediations to the home and
misrepresenting that there are no known or reasonably discoverable material defects with the
Property amounts to unfair trade practices, fraud, and wanton, willful, and exhibits a reckless
indifference to the rights of the Plaintiffs.
92. Based upon the actions and omissions pled herein, Plaintiffs seek treble or
punitive damages against the Defendants as provided for under the Unfair Trade Practices Act.
93. Plaintiffs also seek their costs of suit and reasonable attorney's fees as provided
for under the Unfair Trade Practices Act.
WHEREFORE, Plaintiff D'Airo demands judgment against the Defendants Talib O.
Karim and Bafrin A. Karim, in an amount of $23,679.00 for compensatory damages plus punitive
16
or treble damages, recovery of litigation costs and reasonable attorney's fees and such other
relief as this Honorable Court deems appropriate.
COUNT V — NEGLIGENT MISREPRESENTATION
EDDIE SUTTON JR. v. TALIB O. KARIM and BAFRtN A. KARIM
94. Plaintiff Sutton incorporates by reference Paragraphs 1 -93 as though fully set
forth herein.
95. Defendants were aware that the Property experienced water leakage,
accumulation, or dampness within the basement.
96. Defendants were aware that the Property experienced past and /or present water
leakage in the house.
97. Defendants were aware of past and /or present flooding or drainage problems
affecting the Property.
98. Defendants made or had made repairs /remediations in the basement as a result
of said water leakage, accumulation, dampness, flooding, and /or drainage problems affecting
the Property.
99. Despite their knowledge of said basement water issues and subsequent repairs,
Defendants each represented that they were not aware of any water leakage, accumulation, or
dampness within the basement or repairs on the Property and that they were not aware of any
repairs as a result of water or dampness within the basement.
100. Defendants had a duty to disclose these defects to the Buyer but each failed to
do so.
101. The Property's history of water leakage, accumulation, dampness, flooding,
and /or drainage problems and the resultant damages were material defects to the Property in
17
that they substantially affected the market value of the property and presented a threat to the
health and safety of the inhabitants, and should have been revealed to the Buyer.
102. Defendants' actions were committed with the intent to induce the Buyer to act on
these misrepresentations and purchase the residence.
103. Buyer relied upon the misrepresentations of Defendants.
104. As a direct and proximate result of the misrepresentations of Defendants, Buyer
entered into an agreement of sale to purchase the Property when she otherwise would not have
done so.
105. As a direct and proximate result of the affirmative concealment, intentional
misrepresentations, and representations made in reckless ignorance, Buyer permitted Plaintiff
Sutton and his three (3) minor children to reside at the Property.
106. Plaintiff Sutton and his children were exposed to excessive mold and mildew, as
the air is circulated from the basement throughout the residence.
107. The required professional mold removal and remediation necessary for safe and
habitable living at the Property is estimated to cost six thousand dollars ($6,000.00).
108. Defendants' misrepresentations and fraudulent inducement were the proximate
cause of the $6,000.00 loss.
WHEREFORE, Plaintiff Sutton requests:
a) An order directing Defendants to pay Mr. Sutton $6,000.00 to reimburse him for the cost
of professional mold removal and remediation; and
b) Such other relief the court deems justified.
18
COUNT VI — FRAUD AND MISREPRESENTATION
EDDIE SUTTON JR. v. TALIB O. KARIM and BAFRIN A. KARIM
109. Plaintiff Sutton incorporates by reference Paragraphs 1 -108 as though fully set
forth herein.
110. Defendants acted in full knowledge and in reckless ignorance, in making false
representations concerning water leakage, accumulation, dampness, flooding, and /or drainage
problems affecting the Property.
111. Defendants acted to affirmatively conceal the Property's basement water
problems by representing to Buyer that each of them did not know of any water leakage,
accumulation, dampness, flooding, and/or drainage problems repairs or attempts to control any
water problems in the basement.
112. Defendants made false representations of existing and prior facts concerning the
Property's basement water problems affecting the Property.
113. Defendants knowingly made false statements and suppressed the truth with the
intention to deceive the Buyer about the Property's basement water problems.
114. Defendants' actions were calculated to deceive the Buyer regarding the
Property's history and to induce her to purchase the Property.
115. Buyer did rely on Defendant's false statements.
116. Buyer's reliance on Defendants' representations was reasonable as the
Property's history of water leakage, accumulation, dampness, flooding, and /or drainage
problems were latent and not by its nature open to inspection. Common prudence and diligence
would not have revealed these issues.
117. Defendants failed to disclose a latent, serious, and dangerous condition with
actual and imputed knowledge of the condition.
19
118. Defendants had a duty to disclose this condition as it was latent and because
they had a statutory obligation to do so.
119. As a direct and proximate result of the affirmative concealment, intentional
misrepresentations, and representations made in reckless ignorance, Buyer entered into the
Agreement of Sale and purchased the property when she would not have done so otherwise.
120. As a direct and proximate result of the misrepresentations of Defendants, Buyer
permitted Plaintiff Sutton and his three (3) minor children to reside at the Property when she
otherwise would not have done so.
121. As a direct and proximate result of the misrepresentations of Sellers, Plaintiff
Sutton and his three (3) minor children did reside at the Property when they otherwise would not
have done so.
122. Defendants' misrepresentations and fraudulent inducement were the proximate
cause of the $6,000.00 estimated expense to be incurred by Plaintiff Sutton consisting of her the
cost of professional mold removal and remediation.
123. Defendants' actions were malicious, willful, and wanton and consisted of both
calculated and reckless disregard for the rights and safety of the Buyer, Plaintiff Sutton, and his
minor children as inhabitants of the Property.
124. Defendants' misrepresentations, concealment, fraud, and deceit as to the facts
alleged above were done by Defendants intentionally, with oppressive intent and malice and
with conscious disregard of the probable damage to be suffered by Buyer and inhabitants of the
Property. Plaintiff Sutton is therefore entitled to compensatory and punitive damages.
WHEREFORE, Plaintiff Sutton requests:
20
a) An order directing Defendants to pay Plaintiff Sutton $6,000.00 to reimburse him for the
cost of professional mold removal and remediation; and
b) An award of punitive damages against Defendants in an amount the court sees fit; and
c) Such other relief the court deems justified.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By: Gy✓
Ulysses S. Wilson
Attorney I.D. No. 312598
301 Market Street
P.O. Box 109
Lemoyne, PA 17043 -0109
Telephone (717) 761 -4540
Date: March 2013 Attorneys for Plaintiffs
:544264
21
03/28/2013 09:59 17175588132 SOUTH 3 PAGE 02/02
I
i
I, Leonora VAiro and Eddie Sutton Jr., have read the foregoing. Complaint and hereby
affirm that It Is true and correct to the best of my personal knowledge, ar informiion and belief.
This Verification and statement Is made subject to the pens llges of 1 a Pa. C,S. § 4904 relating to
unworn faWfIcation to authorities; I verify that all the statements made in the foregoing are true
and correct and that false staterroMs may subject me to the penalties of 1a Pa C,S, §4$04.
Date: �AT By; sf
Leonora `Airo
Da te: 2� ! ? �.--
Eddie Sutton Jr.
22
EXHIBIT A
File No. 7630 Parcel ID No. 47 -19- 1588 -126
Made the /S day of in the year
TWO THOUSAND TWELVE (2012)
36etbnett
TALIB O. KARIM and BAFRIN A. KARIM, husband and wife, of Wormleysburg, Cumberland
County, Pennsylvania, parties of the first part, hereinafter referred to as the GRANTORS
AND
LEONORA S. D'AIRO, single woman, of Summerdale, Cumberland County, Pennsylvania,
party of the second part, hereinafter referred to as the GRANTEE
Vittte0g ;etb, that the said Grantors for and in consideration of the sum of ----------------------------------
----- -ONE HUNDRED TWO THOUSAND DOLLARS and 00/100----- -
---------------------------------------------- - - - - -- ($ 102, 000. 00)------------------------------------ - - - - --
lawful money of the United States of America, unto them well and truly paid by the said Grantees, at or before
the sealing and delivery hereof, the receipt whereof is hereby acknowledged, have granted, bargained and sold,
released and confirmed, and by these presents do grant, bargain and sell, release and confirm unto the said
Grantees, their assigns, the survivor of them and the survivor's personal representatives and assigns,
ALL THAT CERTAIN piece or parcel of land situate in the Borough of Wormleysburg, Cumberland
County, Pennsylvania, being bounded and described according to a survey made by Gerrit J. Betz,
Registered Surveyor, dated February 9, 1979, as follows, to wit:
BEGINNING at a pin formed by the intersection of the eastern line of North 2nd Street (70 feet wide)
with the southern line of Elm Street (40 feet wide); thence extending from said point of beginning and
along the said side of Elm Street, North 65 degrees 30 minutes East, the distance of 150 feet to a hub
on the west side of River Alley (15 feet wide); thence along the said side of River Alley, South 24
degrees 30 minutes East, the distance of 23.80 feet to a drill hole at the corner of lands now or
formerly of John E. Turnbull, being Lot No. 77 on said Plan; thence along said lands, South 65 degrees
30 minutes West, the distance of 150 feet to a hub on the said side of North 2nd Street; thence along
the said side of North 2nd Street, North 24 degrees 30 minutes West, the distance of 23.80 feet to a
point, the place of BEGINNING.
BEING Lot No. 78, Plan of Lots No. 3 of Edgewater recorded in Plan Book 1, Page 71.
BEING THE SAME PREMISES WHICH Khai Ngoc Tran and Nguyet Anh Thi Nguyen, husband and
wife by deed dated May 30, 2000 and recorded May 31, 2000 in the Office of the Recorder of Deeds in
and for Cumberland County, Pennsylvania in Record Book 222, Page 204, granted and conveyed unto
Talib O. Karim and Bafrin A. Karim, husband and wife, Grantors herein.
Togetber Witb 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 all the estate, right, title, interest, property, claim and demand whatsoever of them, the said
grantors, as well at law as in equity, of, in and to the same.
TO babe anb t0 bOlb 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.
ZInb the said Grantors, for themselves and their heirs, executors and administrators, do, by these presents,
covenant, grant and agree, to and with the said Grantees, their heirs and assigns, that they, the said Grantors, and
their 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 them, the said
Grantors, and their heirs, and against all and every other person and persons whosoever lawfully claiming or to
claim the same or any part thereof, by, from or under him, her, it, or any of them, shall and will ...
ftecfallp Varrant anb 32lefenb.
ETC itne�� Vbereof, the parties of the first part have hereunto set their hands and seals. Dated the day
and year first above written.
6ealeb ant; Melibereb
IN THE PRESENCE OF:
{SEAL}
Talib O. Karim
X-- {SEAL}
Bafrin A. Karim
Commonwealth of Pennsylvania
County of : ss
On this, the day of , 2012, before me, a Notary Public for the
Commonwealth of Pennsylvania, the undersigned Officer, personally appeared Talib O. Karim, married man,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
My commission expires
Commonwealth of Pennsylvania
County of Al /�eq l] *f n l : ss
On this, the /5 �A day of , 2012, before me, a Notary Public for the
Commonwealth of Pennsylvania, the unde igned Officer, personally appeared Bafrin A. Karim, married
woman, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument,
and acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
d/
Notary Public
/ NOTARIAL SEAL
My commission expires (D `� /" / _� BERNICE S SMITH
Notary Public
PENN HILLS TWF, ALLEGHENY COUNTY
My Commission Expires Jun 11, 2013
Certificate of Residence
I hereby certify, that the precise res' Cie nce of the grantees herein is as follows:
1
(Axtew} -e� Agent for Grantee)
EXHIBIT B
SELLER'S PROPERTY DTSCLOSURF, STATEMENT SPD
Mil% (*nn rwonintevided and approvod for, but not rostriaod to use by, 1ho members of the Pennsylvania Aaeociwion of RF Al.IY )R8V (PAR).
1 PROPERTY 349 N, 2 acl 9t. 9tosuletr _ a, PA 17043
2 SELLER n Karla
3 I'hc Iteal Estate Seller Disclosure Law (68 P.S. 17301 at seq.) requires "(hat a seller of it property most disclose to a buyer all known
4 material defects about the property being sold that are not readily observable. While the Law requires certain disclosures, this disclosure
5 statement covers common topics beyond the basic requirements of the Law In an effort to assist sellers in complying with disclosure
6 requirements and to assist buyers in evaluating the property being considered. Selena who wish to see or use the basic disclosure form
7 oar find the !brut on the Web site of the Pennsylvania State heal Estate Commission.
8 This Statement discloses Seller's knowledge of the condition of the property as of the date signed by Seiler and is not a substitute
9 for any Inspections or warranties that Bayer may wish to obtain. This Statement is not a warranty of any kind by Seiler or a war.
10 ranty or representation by any listing real estate broker, any selling real estate broker, or their licensees. Buyer is encouraged to address
I I concerns about the conditions of the property that may not be included in this Statement. This Statement does not relieve Seller of the
12 obligation to disclose a material defect that may not be addressed on this form.
13 A Material Defect Is a problem with a residential real property or any portion of it that would have it significant adverse impact on the
14 value of the property or that involves an unreasonable risk to people on the property. The feat that a structural element, system or sub -
15 system is at or beyond the end of the normal useful life of such a structural element, system or subsystem is not by itself a material defeat.
16 1. SELLER'S EXPERTISE Seller does not possess expertise in contacting, engineering, architecaare, environmental assessment or
17 other areas related to the construction and conditions of the property and its improvements, except as follows:
IB
19 2. OWNERSHIP /OCCUPANCY
20 (a) is the property currently occupied? Yes _. No if "yea." by whom? —Seller Other occupants (tenants)
21 If property is not occupied, when was It last occupied?
22 (b) How long have you owned the property?
23 (e) Are you aware of any pets having lived in t! house or other structures during your ownership ?,:.eYea _No
24 If "yes," describe: -& :i a 0- Gn
25 3. ROOF
26 (a) Date roof installed: i c f q 2 Documented? — Yes. �' . No — Unknown
27 (b) Has the rotrf been replaced or n3r hW during your ownership? _ Yes 4 No
28 If "yes," was the existing roofing material removed? _ Yes No Unknown
29 (c) Has the roof ever leaked during ownership? _ Yes _ No
30 (d) Are you aware of any problems with the roof, gutters, flashing or downspouts? _ Yes A No
31 Explain any "yes" answers in this section, Including the location and extent of any problem(s) and any repair or remediation eRor bi
32
33 4. HASXMB,NTS AND CRAWL SPACES (Complete only Ilapplicable)
34 (a) Does the property have a sump pomp? —Yes P eNo —Unknown
35 If "yes," has it ever run? _ Yes —No _Unknown to it in working order? _Yes _No —Unknown
36 (b) Are you aware of any water leakage, accumulation, or dampness within the basement or crawl space? ,_ YC&/ No
37 (c) Do you know of any repairs or other atteurpts to control a water or dampness problem In the basement or crawl space? — Yes _ No
38 Explain any "yes" answers in this section, Including the location and extent of any problem(,) and any repair or rettedlation effentst
39
40 S. TE RMITES/WOOD- DMTROMG INSECTS, DRYROT, PEM
41 (a) Are you aware of any lermites/wood- destroying insects, dryrot, or pests affecting the property? _ Yes /t No
42 (b) Are you aware of any damage to the property caused by termitoa/wood- destroying insects dryrot, or pastel T Yes 4Z No
43 (e) Is your property currently under contract by a licensed pest control company? _ Yes ,4No
44 (d) Ara you aware ofany tamitdpest control reports or treatments for the property'l — Yes 4.4 No
45 Explain any "yes" anmers in this section, including the name of any servke/treatment provider, If applicable-
46
47 6. STRUCTURAL ITEMS
48 (a) Ara you aware of any past or present water leakage in the house or other structures? _ Yes J�--
49 (b) Are you ewers of any past or present movement, shifting, deterioration, or other problems with walls, foundations, or other
50 structural components? _ Yes AeNo
51 (o) Are you aware of any pass or present problems with driveways, watkways, patios, or retaining walls ou the property? _ Yes C,.
52 (d) is your property constructed with an Exterior Insulating Finishing System (EIFS), such as Dryvit or synthetic stucco?
53 _ 'Yes _ No _ Unknown If yes, date Installed, if known
34 (e) Are there any defccu (including stains) In flooring or floor coverings? _ Yes _ No _,,, Unknown
55 (() Are you aware of any fire. storm, water or ke demago to the property? _ Yes *,eNo
36 Explain any "yes" answers in this section, including the location and extent of any problem(s) and any repair or remediation effortar
37
38 Buyer Initislst Rate SPD Page 1 of S Seller initials: _T-n x Date AQI �
'(� K
COPYRtONT PSNNRVLVAN1A ASSOCIATION OR REALTORS® 2009
Permsylvanis Association of REALTORS' 02 M
Prudential HomallelCamp Hill 3435 Market Street Camp Hill, PA 17011
Phone: 717.761.7900 Fax: 717 -761 -8837 Cheryl Bellem 1'allb A Hamm
Produced with ZloFarm* by ZbLoo1K 10070 FIRM Nis Read. Fraser. MICMOan 46020 %WW.ZlcLoWX.00M
59 7, A.DDITIONSIALTERATIONS Have any additions, structural changes, or other alterations been made to the property
60 durin our ownershl ? —Yen No
61 If yes, list additions. struclural ebnage!s, or alterations pproxirnalc Were permits obtained't Were Mal inspections/approvals
62 use additional sheets if notes date of work YaMo/Unknown obtained? mWo/Unknown
63
64
65
66 tj
67 Lj
68 Note to Buyer: The PA Construction Code Act, 35P.1 §72ioniei seq, (effective 2004), and local codes establish standards far building and
69 altering properties. Baye►s should check with the mun /ctpality to determine irperinitr and/or approvals were necessary fir disclosed work and tf
70 so, whether they were obtalned Where required permits were not o6lained the municipally might require the current owner to upgrade or remove
71 changes made by prior owners. Brry+ers can have the property Inspected by an expert in codes compliance to determine if issues arlst. Expanded
72 title Inrruance policies may be avallable for Buyers to cover the risk of work done to the property by previous owners without a permit or approval.
73 8. WATER SUPPLY
74 (a) What is the source of your drinking water? -"blic Water ._ Well on Property Community Water
75 — Nona _ Onccr (explain);
76 (b) When was your water last tested? Test results:
77 If your drinking water source is not public, is the pumping system in working order? Yes _ No
78 If "no," explain:
79 (c) Do you have a softener, filter, or other treatment system? _ Yes _ No
80 If you do not own the system, explain:
81 (d) Have you ever had a problem with your water supply? _ Yes — No
82 (c) Has your well ever run dry? — Yes No _- Not Applicable
93 (f) Is there a well on the property not used as the primary source of drinking water? — Yes _ No
84 if yes, Is the well capped? _ Yes — No
85 (g) Is the water system shared? — Yes ,AeNo
86 (h) Are you aware of any leaks or other problems, past or present, relating to the weter supply, pumping system, and related items?
87 _ Yes — No
88 Explain any "yes" answers in this section, Including the location and extent of any problem(s) and any repair or remedis lion efforts:
89
90
91 9. SEWAGE SYSTEM
92 (a) What Is the type of sewage system? 1,. Sewer _ individual On -lot Sewage Disposal System
93 _ Individual On -lot Sewage Disposal System in Proximity to Well _ Community Sewage Disposal System
94 " Ten -acrd Permit Exemption _ Holding Tank Nona Nona AvailoblaMetmit Limitations In Btibet
95 Other type of sewage system (explain):
96 (b) if individual On -lot sewage systeny what type? — Cesspool -_ Dminfield --.-„ Unknown
97 - - Other (specify):
98 (c) Are there any septic tanks on the Property? , Yes _-., No -r Unknown
99 if "yes." what type of tank(s)? Metal /steel _ Coment/concrcte _ Fiberglass _ Unknown
.00 _ Other (specify):
.01 (d) When was the on -site sewage disposal system lest serviced?
.02 (e) Are there any sewage pumps located on the property? _ Yes _ No
03 If yes, type(s) of pump(s) Are pumps) in working order'? —Yes _No
.04 Who is responsible for maintenance of sewage pumps?
.05 (f) Is the sewage system shared? _ Yes _ No
.06 (g) Ara you aware of any past or present leaks, backups, or other problems relating to the sewage system and related items? _ Yes _ No
.07 Explain any "yes" answers in ebb section, including the location and extent of any problem(s) and any repair or remediation efforts:
.08
.00 10, ;-LWfRING SYMM
.10 (a) 'type of plumbing (check all that apply); _4ZCoppor ,-balvanized - _ ,eLcad PVC Polybutyleno pipe (1`8)
.11 _, Mixed _ Unknown _ Other (explain):
.12 (b) Are you aware of any problems with any of your plumbing fixtures (e g., including but not limited to: kitchen, laundry, or bath -
.13 room fixtures; wet bars; etv.)? — Yes V ,G No
14 If "yes," explain:
.15 11. DOMESTIC WATER HEATING
.16 (a) Type of water heating: _ Electric jZNaturai Gas Oil -_.. Propane _ Solar _ Summer/Winter Hook -Up
.17 Other (explain):
.18 (b) Are you aware of any problems with any water heater or related equipment? „ Yes �9Vo
.19 if "yes," explain:
120 sayer Initials: Date SPD Page 2 ors Seller initial,: T-nA Date
G . /� ► �'
Produced with ZtpFoffS by VpLoOx 18070 Meen Mae Road. Fraser. Mlchiaen 40020 lrOtOt . SpLoulLcorn Talib dt BdHm
.21 12. AIR CONDITIONING SYSTEM
22 (a) Type ^F air conditioning: ._.-, Central Air Walt Unity _ Window units - None
.23 Other (explain):
24 Number of window units Included in sale Looation(s)
.25 (b) Age of Central Air Conditioning Systole: _ Unknown Date last sorvimA. if known
26 (c) List any areas of the house that arc not air conditioned:
.27 (d) Are you aware of any problems with any item in this section? _ Yes _ No
.28 If "yes," explain:
29 13. HEATING SYSTEM
30 (a) Type(s) of beating fltel(s) (check all that apply): _ Electric Fuel Oil _ Natural 0as _ Propane
.31 _ Coal _ Wood _ Other:
.32 (b) Typc(s) of heating systcm(s) (check all that apply): Forced Hot Air _ Hot Water _ Heat Pump
33 _ Electric Baseboard _ Steam _ Wood Stove (How matey? ) _ Coal Stove (How many? )
.34 _ Other:
35 (o) Age of Rating System: Unknown Date last serviced, if known
.36 (d) Are there any fireplaces? _ Yes - yfVo If "yes," how many? Are they working? _ Yes _ No
.37 (e) Are there any ohimneys (from a fireplace, water heater or any other heating system)? 4,- _ No
.38 if "yes," how many? I When wore they last cleaned? Unknown V
.39 Are they working? _L _ No If "no," explain:
.40 (f) List any areas of the house that arc not boated: A 4F r
.41 (g) Are you aware of any heating f l tanks on the property? _ Yes 4,-'No
42 Location(s), including underground tankf i):
.43 If you do not own the tanks, explain:
.44 Are you aware of any problems or repairs needed regarding any item in this section? -Yes 4 o
.45 if "yes," expiaint
.46
.47 14. ELECTRICAL SYSTEM
.48 (a) Type of Electrical System: _ Pum - LAiroult Breakers How Many Amps? I h _ Unknown
.49 (b) Are you aware of any knob and tube wiring in the home? ,-,_, Yes z eNo
.50 Are you aware of any problems or repairs needed In the electrical system? - Yes _ No
.51 If "yes;' explain:
.52 15.OTiilER.1r,Q1JI1PM18IVT AND APPLIANCES
33 This section must be completed tier each Item that will, or may, be sold with the property. The fact that an item Is listed does
54 not mean it Is Included in the Agreement of Sale. Terms of the Agreement of Sale negotiated between Buyer and Seiler will
.55 determine which items, if any, are ineluded In the purchase of the Property.
.56 (a) ElecMc Garage Door Opener Number of Transmitters Keyless Entry _
.57 (b) "4moke Dotcotors . How many? 9 Location(s)
58 (o) _ Security Alarm System - Owned _ Leased (lease information )
.59 (d) _ Lawn Sprinklers) How many? Automatic Timcr _-
.60 (c) _ Swhnming Pool , Hot Tub/Spa . _ Pool/Spa Heater Pool /Spa Cover _ WhhipooVfub
.61 Pool/Spa Equipment and Accessories (list): 7
62 (f) LZRefrigeretor(s) _1,. engdoven Microwave Oven _ Dishwasher _ Trash Compactor
.63 6„d, Garbage Disposal _'ChcA Freezer 1ZWasher !'pryer _ intercom
.64 (g) &ZCoiling Fan(s) How many? Location($)
.65 (h) _ Awnings - Attio Fan(s) - Satellite Dish .Storage Shed - Deck(s) _ Plcciric An mal Fence
.66 (1) Other:
.67 Are you aware of any problems or repairs needed regarding any item in this section? _ Yes _ No
.68 If "Yes," explain:
.69 16. LAND (SOILS, DRAINAGE, FLOODING AND BOUNDARMS)
.70 (a) Land/Solls
.71 1) Are you aware of any fill or cxponsive soft on the property? _ Yes ✓ do
.72 2) Arc you aware of any sliding, settling, earth movement; upheaval, subsidence, or earth stability problems that have
73 oocurred on or affect tha property? -Yes 4g: rWo
.74 3) Are you aware of airy existing, past or proposed mining. ship - mining. or any other cAcav dory that night affect this
75 property? -Yes Jzko
76 Note to Buyer. The properly may be subject to mine subsidence damage. Mapes of the twenties and mines where mine subsidence
.77 damage may occur and mine subsidence Insurance are available through! Department of Environmental Protection, Mine subsidence
.78 Insurance Fund, 25 Technology Drive, California 'technology Park, Coal Center, PA 15423 (800) 922 -1678 (within Pennsylvania) or
.79 (724) 769 -1100 (outside Pennsylvania).
80 Buyer Initials: Date SPD Page 3 of S Seiler loitials: _VEo% k Date
'iK
Produoed watt► 2lpionrlm by ztpt.eptx 18070 Man Nag Read. Fraser. Mkhlpan 48028 MW1WL=kg= 'i alib A Aafriro
81 4) is the property, or a portion of it, preferentially assessed for tax purposes, or subject to limited development rights?
.82 — Yet; ,-No tf "yes', check nil dial apply below:
83 _ Parmlond and Forest Land Assessment Act.: 72 P.S. §5490.1 et seq. (Clean and Green Program)
.84 — Open Space Act - l6 P. S. § 11941 et seq.
.85 — Agricultural Area Security Law - 3 P.S. §901 et seq. (Development Rights)
.86 Other
.87 Nett tomyer: Pe nnwvanf RM enrac ed the Right to Farm A ct 1 3 P . . 9 J- J/) to an #,port to (roar fire ceraenskmaes wider which agnoulnuor
.88 operations may be subject to nuisance suits or ordinances, Buyers are encouraged to (nvortigam whether any agricultural operations covered by
.89 the Act operate in the vicinity of the property,
.90 S) Are you aware of sewage sludge (other than commeroWly availablo tl;rtilizer products) being spread on the property, or
.91 have you rxeived written notice of sewage sludge being spread on an adjacent property? —Yes — No
.92 6) Are you award of the transfer, sale and/or lasso of any of the following property rights (by you or a previous owner of the
.93 properly)? _... Timber _ Coal _ Oil — Natural Gas _ Other minerals
.94 Note to Bayer. Before entering into an agreement of sale, Buyer can investigate the status of these rights by among order means, engaging legal coun-
.95 sel, obtaining a tills examination of unlimited years and searching the official records in the corary Ogee of die Recorder 4fDeeds, and elsewhere. %u "r
.96 Is also advised to investigate the terms of any existing leases, as Buyermay be subject to terms of than leases.
.97 Explain any "yea" answers in this section:
98
.99 (b) Mooding/Drainage
too 1) Is any part of this property located in a wetlands arcs or a FRMA flood zone? _ Yes _ No _ Unknown
!01 2) Do you know of any pest or present drainage or flooding problems affwting the property? _ Yes No
!02 Explain any "yes" answers in this section. including data and extent of flooding:
'.03
!04 (c) Boundaries
!05 1) Do you ?mow of any encroachments, boundary line disputes, or casencnts aflbding the property? — Yes _ No
1 06 Note io Bayer: Mast properties have easements for utility services and other reasons. These easements generally do not rex&*i the ordAa"m ofthe
!07 1»operty and Sellerntay not be aware of them. Drfore entering into an agreement of sale, Buyers can investigate the existence ofeosemenrs andsimilar
!08 resarldlons by ordering an Abstract of Tille or searching the of)?cial records in the eounry Of ee of the Recorder of Deeds.
!09 2) Do you accesl the property from a private road or lane? — Yes _ No
.10 If yes, do you have a recorded right of way or maintenance agreement? _ Yes , No
'.11 3) Are you aware of any shared or common errs (e.g., ddvd ways, bridges. docks, walls, ctc.) or maintenance agreements?
!12 Yes - . - _ No
! 13 Explain any "yes" answers In this section:
!14
,15 17. HAZARDOUS SUBSTANCES AND ENVIRONMENTAL ISSUES
!16 (a) Are you award of any underground tanks (other than home hosting fad or septic tanks disclosed above)? .-._ Yes A_-c::'No
!17 (b) Are you aware of any past or ptemd hazardous substances nsen[ on the property (sOructuro or soil) such as, but not limited to,
!18 asbestos or polychlorfnatcd b1phenyls (PCBs), eta? _Yes lo
'.19 (c) Are you aware of any tests for mold, fungi, or indoor air quality in Use property? _ Yes Q_--No
'
!20 (d) Other than general household claiming, have you taken any efforts to control or remediste mold or mold -Itko substances in the
!21 property? _ Yes — No
!22 Note to Bayer lndividaals may be affected d(i erenily, or not at all, by mold contamination. .{/' contamination or indoor air qualiryls a concern,
123 buyare are encouraged to erogage the .oeroleor 61a qualUtodprofesslonal to do towing. bl fe rmnrinn on that irsuor is avol /able from the United Stales
!24 Envirormenio/ Protection Agency and may be obtained by contacting MQ INFO, P.O. Box 37133, Washington D. C. 20013 -7133, 1.800- 438 -4318.
!25 (e) Are you aware of any dumping on the properly? _ Yes g,
!26 (1) Have you received written notice regarding the prcscnce of an environmental hazard or biohazard on your property or any
!27 Anent prope:rtyl —Yes .4-No
!28 (g) Are you aware of any tests for radon gas that have been performed in any buildings on the property? _„- Yes v No
!29 If "yes," list date, type, and results of all tests below:
' DATE TYPE OF TLtST RF-SULTS (picaauicnAita or working levels) NAME OF TBSTiNO SERVICE
!31
!32
!33 (h) Are you aware of any radon removal system on the property? _ Yes o
34 If "yes," list date Installed and type of system, and whether It In in working order bClow;
!35 D A TA INSTALLED TYPE OF SYmm PROVIDER WORKING O RDSM
!36 _ Ycs _ No
!37 Yes _ No
!38 (1) If property was constructed., or if constriction began. boforo 1978. you must disclose any know1_0ge of lead -based paint on the
!39 property. Are you aware of any lead -based paint or lead -based paint hazards on the property? ^ Yes o
NO if "yes," explain how you know of it, where it is, and the condition of those lead -based paint surfaces:
!4l
!42
!43 Buyer initiais: Date SPD Fags 4 of 5 Seller Initialst Date
�•k
Pioduc ed with Z1pForat® by slpLoglnc IWO FVttron MBe Road, Fraser, Mkhlgan 40028 WMMgRlWkg;m Tolib A Bet'rim
AL /eL.t
A4 0) if property was constructed, or if construction began, before 1978, you must disclose any reports or records of lead -based paint
x45 or lead -based paint bnyArds on [he property. Arc you award of any reports or records regarding land -bused paint or lead - based
!46 point hazards on the propertyl _ Yes ,
!47 If "Yes," list all available reports and records:
!48 (k) Are you aware of testing on the property for any other hazardous substances or environmental concerns ? — Yes - - No
!49 (1) Ara you aware of of any other hazardous substances or environmental concerns that might impact upon the propertyl
150 — Yes .ZNo
151 Explain may "yes" answers is this sectiont
152
153 18. CONDOMINIUMS AND OTH18R HOM>ZOWNSR ASSOCIATIONS (Complete only it spplieable)
154 Type: _ Condominium _ Cooperative Homeowner Association or Planned Community
155 (hher:
156 Notice regarding Conduminiumv, Coeperadws; and Planned Communides :A buyer of a,wale unit in a condominium, cooperative, or planned
'.57 community must receive a copy of the declaration (other than the plats and plans), the by -laws, the rules or repiorto , anda reed 1cate ofresok 1$.jued
158 by the association in the condominium, cooperative; or planned communiry. Buyers may be responsible for oopttal connfbutlaa, bditationfees or alm-
159 filar one-time fees in addition to regular monthly maintenonae fees. The buyer will have the option of oanoeling the agreement with the return of all
!60 deposit monies until dre cert r'eate has been provided to the buyer and far five days thereafter or until conveyance, whichever occurs first,
!61 19. MiSCEL.LANEOUS
!62 (a) Are you aware of any historic preservation restriction or ordinance or archeological designation associated with the property?
!63 — Yes 4,. No
164 (b) Are you aware of any existing or tltreatened legal action affecting the property? ,_ Yes t .%::/ No
!65 (o) Are you aware of any violations of federal, steno, or local laws or regulations rotating to this property? _ Yes EC'No
!66 (d) Arc you award of any public improvement, condominium or homeowner association assossmertts against the property that remain
!67 unpaid or of any violations of zoning, housing, building, safety or fete ordinances that remain uncorrected? _ Yes +4 -No
!68 (e) Are you aware of any Judgment, encumbranco, lien (fbr example, co -maker or equity loam overdue payment on a suppon obli-
!69 gation, or other debt against this property that c mot be smdstiod by the prop ods of this Yes t No
!70 (f) Arc you aware of any reason, including a defect in title, that would prevent you from givng a warranty deed or conveying title to rile
!71 property? — Yes b _ - No
!72 (g) Are you aware of any insurance claims files) relating to the property? _ Yes 4.,CNO
!73 (h) Are you aware of any material defeeta to the property, dwelling, or fixtures which are not disclosed clsowherc on this form?
!74 —Yes .ZNo
!75 A material defect is a problem with a residential real property or any portion of it that would have a significant advcrso impact
!76 on the value of the property or that involves an unreasonable risk to people on the property. Tlie fact that a structural element,
177 system or subsystem is at or beyond the end of normal useful life of such a structural element, system or subsystem is not by
!78 Itself a material defect.
!79 Explain any "yes" ■aswom-in this sertloat
!80
!81 The ooder011ood Seller represents that the information set forth in this disciosure statement is accurate sad complete to the best
!82 of Seller's knowledge. Seller hereby aathorho the Modell Broksr to proalde this information to prospective buyers of the prop -
!83 erty and to other real estate dresses_ SELLER ALONE 1S RRSPONSIBLE FOR THE ACCURACY OF THE iNFORMATiON
!84 CONTAINED V4 TFW STATEMENT. Seller shall eanse Bayer to be noMW in writing of say information supplied on this form
!85 which 'a rem f unto by ' a c n the cpad on 0( t4e property followht repletion of this form.
!86 WITNESS SB,LLER DATE 411-49
WiLf Karin
!87 WITNE83 ' SEL,L,!»;Lt _gesba; dzmr`n uw t rr
` nalicits LC�riw
!88 WITNESS SELLER DA'Z'E
A B oC
!90 According to the provisions of the Real Mato Sellcr Disclosure Law, the undeMped executor, administrator or trustee is not rcquircd
!ril
to fill out r baikrx Property Disuiusurc 3iwaneuh lire encvutur, administruturur or trustm, must, Lvwevw, dimiusa wry luruwn wate-
!92 rial defect(s) of the property.
!93 DATE
94 RECEIPT AND ACHNOWL110GIMPIT 9V BUYE
!95 The undersigned Buyer acknowledges receipt of this Disclosure Statement. Buyer acknowledges that this Statement is not a
!96 warranty and that, unless stated otherwise in the males contract, Buyer is purchasing this property in its present condition. It
!97 is Buyer's responsibility to satisfy himself or herself as to the condition of the property. Buyer may request that the property
!98 he inspected, at Buyer's expense add by qualified professionals, to determine the condition of the structure or its components.
1 99 WITNESS BUYER DATE
100 WITNESS BUYER DATE
101 WITNESS BI1VF.R DATE
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EXHIBIT C
•; MID- ATLANTIC SYSTEMS OF CPA, INC
52 Grumbacher Road, Suite A -3, York, Pennsylvania 17406
Vzk o a bs tW b. (goo) MID - ATLANTIC
Proposal for FOUNDATION WATERPROOFING /WATER MANAGEMENT SERVICE
Name: J Phone (h): Phone (c): Phone (w):
Address: a City ,41 ` CL;, County: ' . +T<" "' State: PC U'
J
Jobsite: Email:
Foundation Type:
Cinder Block WARRANTY and CERTIFICATION
Poured Concrete Filled Area Indlotes n e and warranties apply to wall and /or floor area
Stone �. /
Service Area ` o Free service material and labor replacement
• Brick
• Terra Cotta f y` d transferrable rights apply to completed work
:i Combination d FHA /VA certification issued on completed work upon request
Front of Building/Home
Total Footage: 1 Y.S ft.
Year Built: / `;' Length of Ownership: Basement: /' Crawlspace: Existing Stage of Water Problem: 1/2/0,
Owner Requested Services: Lead Test Required: _ �(ES _ NO Permit Required: /" NO
Wall Service: Floor Service: System Customizations:
❑ Exterior Excavation ❑ Basic Interior French Drain ❑ Window Well Service
• Mida Reinforced Membrane T" ❑ Air Jack Hammer ❑ Check/Clear #—
❑ Drain Shield ❑ 24" Inside Perimeter Walls ❑ High Drain #_
• Footer Drain tile ❑ Low Drain # _
• o ' w a Pressure Relief System ❑ Stairwell Service
• Fireplace Wrap Electric Hammer ❑ Full Stairwell Service
or Perimeter Trench
Water Management fl 'Spee,D– Lhamael
4" PVC Piping
'
❑ iEngineered /Mechanica9�apacers ❑ c+r^UidaOilTartk Wrap
En' 5/8" Weep holes a-* 4" ADS Perforated Aping ❑ Garage Drain
Midalizer'" E2-"Slope Piping to Pits ❑ Heavy Duty PVt
❑ Pea Gravel
❑" Mida Scent'" ❑ Galvanized Steel
Q Mida -Aire– a"3 /4" Washed Stone ❑ Mida Fiber Lock Crack Repair _ft
❑ Polymeric Drain Board I�Tunnel Obstructions and
y ❑Mida Fennell Ledge'" _ft
o�Mida Hydro - Traci" Partitions Where Possible ❑ Box Ledge _ft
❑ Monolithic Hydro- Trac.Systern– d Portland High Strength Concrete ❑ Mida Winterization Package
❑ Base Cove Channel ❑ Mida Reinforced Membrane– ❑ Radon Seal
❑ Top Cove Channel
['Mida Convection Ports'"
o Weeping PortSTM Warranty:
• Mida Reinforced Membrane T"
• Mida Wall
• Rough Casting
Pits and Pumps:
la'Sump Pit #
❑ Standard
o Mida Saber Pitwith sealed clear
lid and bell shape.
or Sump Pump # .-, Special Instructions:
❑ Zoeller 1/3 hp cast iron
(limited to a material warranty of 1 Year)
IZ Mida7500 Stainless Steel
(Limited to a material warranty of 7 Years)
❑ Mida CM5010 Stainless Steel
(Limited to a material warranty of 1 Year)
❑ Emergency Power Back Up
• Mida Power 120 #
(Limited to a material warranty of 2 Years)
• Mida Power 240 #
(Limited to a material warranty of 2 Years)
This proposal is an estimate only and is not a binding agreement between customer and Mid - Atlantic Systems of CPA. This pro-
posal is subject to change by Mid - Atlantic Systems of CPA at any time. If you wish to proceed with service, please contact our
office to request a formal, binding agreement to be signed by you and Mid - Atlantic Systems of CPA.
MID - ATLANTIC'S 110% BEST PRICE GUARANTEE: If within 30 days of having your system installed you find the
same system, service, material and warranty from a qualified licensed and insured competitor we will refund 110% of
the price difference.
i
Total Investment: ' a �v Inspector and Date: f
-�
REV 9/12 0 Mid - Atlantic Waterproofing Registration No. PAOAGHIC: PA0101150
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson '�_� - �
Sheriff OF THE PRO THONOTPORY
Jody S Smith
Chief Deputy 11013 MAY —3 AM (.Q: 19
Richard W Stewart ti ' CUMBERLAND COUNTY
Solicitor OFFICE OF THE S"ERIFF- PENNSYLVANIA
Leonora D'Airo (et al.)
vs. Case Number
Talib O Karim (et al.) 2013-1794
SHERIFF'S RETURN OF SERVICE
0410812013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Talib 0 Karim, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the
within Complaint&Notice according to law.
04/08/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Bafrin A Karim, but was unable to locate the Defendant in the
Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the
within Complaint& Notice according to law.
04119/2013 01:00 PM -The requested Complaint& Notice served by the Sheriff of Allegheny County upon Twan
Karim, son of defendant, who accepted for Bafrin A Karim, at 117 Dogwood Drive, Pittsburgh, PA 15235.
William Mullen, Sheriff, Return of Service attached to and made part of the within record.
04/19/2013 01:00 PM -The requested Complaint&Notice served by the Sheriff of Allegheny County upon Twan
Karim, son of defendant, who accepted for Talib O Karim, at 117 Dogwood Drive, Pittsburgh, PA 15235.
William Mullen, Sheriff, Return of Service attached to and made part of the within record.
SHERIFF COST: $53.46 SO ANSWERS,
May 01, 2013 RONNrY R ANDERSON, SHERIFF
(c)CountySuite Sheriff,'releosoft,Inc.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson �\o QSheriff w,_ d
Jody SSmith -, Richard W Stewart
Chief Deputy 1�0 OFrfcE OF THE SHERIFF Solicitor
Leonora D"Afro(et al.) Case Number
vs.
Talib d Karim (et al.) 2013-1794
SERVICE COVER SHEET
N
a Service Details:
Q Category: Civil Actian -Complaint&Notice Zone:
XManner: Deputize Expires: r" 05/08/2013 Warrant:
Notes:
M -
N
tp
T
a
i (e e To: -- Final Service:
W Name. Bafrin A Karim Served. Personally•Adult in Char a Posted Other
5
m Primary 117 Dogwood Drive Adult In �,_ 1 ''}
' Address: Pittsburgh, PA 15235 Charge: -�J ( ice'
Ij Phone: DOB:
Relation:
o Alternate �j
o Address: 4 Dater Time:
�yJ
O
3: Phone: Deputy. ileage:
0
o Attorney/Originator:
Name: Ulysses Wilson Phone: 717-761-4540
Service Attempts:
Date:
Time:
r`
Mileage:
Deputy �? 3
Notes/Special-Instructions:
Q
Z..............................................................._.-............ --------------------
2 Now,April 08, 2013 1, Sheriff of Cumberland County, Pennsylvania.do hereby deputize the Sheriff of Allegheny County to
mexecute service of the documents herewith and make return thereof according to law.
N Return To:
Y< Cumberland County Sheriffs Office r �_"."- .
One Courthouse Square flt
Carlisle, PA 17013 Ronny R Anderson, Sheriff
ici CountyStnte Sh:-riff,Teleosott.Inc.
JOHNSON, DUFFIE, STEWART &WEIDNER, 42933
'! 04/04/2013
/ENDOR: Sheriff-Allegheny County CHECK NO: 42933
OUR REF.NO. YOUR INVOICE NUMBER INVOICE DATE INVOICE AMOUNT AMOUNT PAID DISCOUNT TAKEN
0879 17566.1 BAF 04/04/2013 $110.00 $110.00 0.00
a
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R AndersonQ of�uitabrp��j`
Sheriff •
Jody S Smith Richard W Stewart
Chief Deputy z p 2 OFFICE OF TPE SRERIFF Solicitor
Leonora D'Airo(et al.)
Case Number vs.
Talib O Karim (et al.) 2013-1794'
0
SERVICE COVER SHEET
N
c Servic e Details:
o Category: ICivil Action -Complaint& Notice Zone:
X Manner: IDeputize Expires: 05/08%2013Y Warrant:
W
Notes:
'n _r-
LAD a
a i
= Serve To: Final Service:
R Name: Italib O Karim Served: Personally Adult In C e Posted Other
m Primary 117.6ogwood Drive Adult In
1
Address: Pittsburgh, PA 15235 Charge:
Phone: DOB: Relation:
W Alternate Date: -� Time: F77P
o Address: �✓
O _ C
O
3: Phone: ~Deputy: Mileage:
O
o Attorney/Originator:
Name: julysses Wilson Phone: 717-761-4540
Service Attempts:
Date:
Time:
Mileage:
A
T-- Deputy: ? Z 3 4 5 a
N
Notes/Special Instructions:
O-------------------------------------------------------------------------------------------------------------------------------------------
m Now,April 08, 2013 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to
-� execute service of the documents herewith and make return thereof according to law.
H
aReturn To: �
� Cumberland County Sheriffs Office
Y One Courthouse Square
Carlisle, PA 17013 Ronny R Anderson, Sheriff
fcl CounfySuae Sheriff,Teleosoft.Inc.