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HomeMy WebLinkAbout14-2200 Supreme Court off' >,Pennsylvania Co urt- o CommoftT1eas For Prothonotary Use Only: GAF Cove Sheet �. t Docket No: CA'berland" County 1 Y 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 El Complaint 0 Writ of Summons Q Petition E © Transfer from Another Jurisdiction Q Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T John's Mobile Repair Service, Inc. Moving Experts, LLC Dollar Amount Requested: within arbitration limits I Are money damages requested? Ix, Yes No Cx O ❑ (check one) outside arbitration limits N Is this a Class Action Suit? Yes El No Is this an MDJAppeal? 0 Yes x, No A Name of Plaintiff /Appellant's Attorney: David H. Martineau Check here if you have no attorney (are a Self - Represented [Pro Se] 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 (] Intentional Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle 0 Debt Collection: Other Board of Elections 0 Nuisance Commercial Services Dept. of Transportation S 0 Premises Liability Statutory Appeal: Other l� Product Liability (does not include ® Employment Dispute: E mass tort) 0 Slander/Libel/ Defamation Discrimination C El Other: [ Employment Dispute: Other [Zoning Board T Other: I J Other: O MASS TORT ® Asbestos N 10 Tobacco Toxic Tort - DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Ejectment L� Other: Ejectment Law /Statutory Arbitration B 1 1 Eminent Domain/Condemnation 0 Declaratory Judgment Ground Rent Mandamus 0 Landlord/Tenant Dispute C' Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto �- Dental 0 Partition ❑ Replevin 0 Legal 0 Quiet Title 0 Other: ® Medical 0 Other: 0 Other Professional: Updated 1/1/2011 Salzmann Hughes, P.C. BY: David H. Martineau, Esquire Attorney I.D. No. 84127 354 Alexander Spring Road, Suite I Carlisle, PA 17015 Telephone: (717) 249-6333 RL A Attorney for Plaintiff PDY'I'Y!Syl , E-mail: dmartineau@salzmannhu%zhes.com N I A JOHN'S MOBILE REPAIR SERVICE, INC., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO: MOVING EXPERTS, LLC., Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Moving Experts, LLC 4477 Westview Drive North Olmsted, OH 44070 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 you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone Nos. (717) 249-3166 (800) 990-9108 Salzmann Hughes, P.C. BY: David H. Martineau, Esquire Attorney I.D. No. 84127 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 Telephone: (717) 249 -6333 Attorney for Plaintiff E -mail: dmartineau(@,salzmannhughes.com JOHN'S MOBILE REPAIR SERVICE, INC., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO: 9 —jd-6c) MOVING EXPERTS, LLC., Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW comes the Plaintiff, JOHN'S MOBILE REPAIR SERVICE, INC., by and through its counsel, SALZMANN HUGHES, P.C., and files this Complaint and in support thereof avers the following: 1. Plaintiff, John's Mobile Repair Service, Inc. (hereinafter "John's Mobile "), is a Pennsylvania business corporation with its registered address at 1511 East Commerce Avenue, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant, Moving Experts, LLC is an Ohio limited liability company, with its registered address at 4477 Westview Drive, North Olmsted, Ohio, 44070. 3. Defendant is registered to conduct business in the Commonwealth of Pennsylvania. A true and correct copy of the information available regarding Defendant's registration from the Pennsylvania Department of State is attached hereto as Exhibit "A." 4. Defendant has a registered office in the Commonwealth of Pennsylvania at 201 Penn Center Bldg, Suite 400, Pittsburg, Pennsylvania 15235. s 5. Defendant operates a moving company. 6. As part of its business, Defendant operates one or more commercial trucks. 7. John's Mobile is in the business of, inter alia, providing recovery, repair, storage and related services to commercial trucks. 8. On or about January 25, 2013, Defendant's 1999 Ford F Series truck, Serial No. 3FENF80Z6XMA21306 (the "Truck ") experienced a mechanical malfunction of its breaks. 9. The Truck broke down on the Pennsylvania Turnpike, in the vicinity of mile post 203 West, near the Blue Mountain Service Plaza, in Cumberland County, Pennsylvania. 10. At Defendant's request, John's Mobile towed Defendant's Truck to John's Mobile's repair facility on East Commerce Avenue, Carlisle, Pennsylvania for repairs. 11. Defendant authorized John's Mobile to repair the Truck. 12. John's Mobile repaired the Truck. 2 13. John's Mobile's fees and expenses for the repair of Defendant's Truck are Three Thousand Two Hundred Seventy -Eight and 73/100 Dollars ($3,278.73). A true and correct copy of an invoice to Defendant is attached hereto as Exhibit `B." 14. At all times since January 25, 2013, John's Mobile has provided Defendant with storage for the Truck at its facility at 1511 East Commerce Avenue, Carlisle, Cumberland County, Pennsylvania. 15. John's Mobile charges Forty Dollars per day ($40 / day) for storage of the Truck beginning on February 8, 2013. 16. Storage fees for the Truck as of April 7, 2014 are Sixteen Thousand Nine Hundred Twenty and 00 /100 Dollars ($16,920.00) and continue to accrue at the rate of Forty Dollars ($40) per day until all fees due to John's Mobile are paid and Defendant removes the Truck from John's Mobile's property. 17. John's Mobile's charges for the repair of the Truck up are reasonable and within industry standards. 18. John's Mobile's charges for the storage of the Truck are reasonable and within industry standards. 3 19. Defendant has made two (2) payments to John's Mobile, totaling Seven Hundred Fifty and 00 /100 Dollars ($750.00). 20. As of April 7, 2014, the total amount due and owing from Defendant to John's Mobile is Nineteen Thousand Four Hundred Forty -Eight and 73/100 Dollars ($19,448.73). 21. Plaintiff has made demand upon Defendant for payment. 22. Defendant has failed to pay the full amount due to Plaintiff. 23. The breakdown, recovery of the Truck, repairs of the Truck and storage of the Truck all occurred and /or are still being conducted in Cumberland County, Pennsylvania 24. Venue for this claim is proper in Cumberland County, Pennsylvania. COUNT BREACH OF CONTRACT 25. Paragraphs 1 through 24 are incorporated herein as if set forth in full. 26. Defendant requested that John's Mobile perform the repairs to the Truck as set forth above on or about December 29, 2012. 4 27. John's Mobile accepted Defendant's offer, performing the services set forth above, forming an oral contract for the repair and storage of the Truck. 28. Despite John's Mobile's demand for payment, Defendant has failed to pay John's Mobile the sum of Nineteen Thousand Four Hundred Forty -Eight and 73/100 Dollars ($19,448.73). 29. Defendant has breached its contract with John's Mobile by failing to pay for the services rendered by John's Mobile when due. 30. As a result of Defendant's breach of contract, John's Mobile has been damaged in the amount of Nineteen Thousand Four Hundred Forty -Eight and 73/100 Dollars ($19,448.73) plus additional storage fees accruing at the rate of Forty Dollars ($40) per day from April 7, 2014 until such time as said judgment is paid and Defendant's Truck is removed from Plaintiffs property. WHEREFORE, Plaintiff, John's Mobile Repair Service, Inc. prays this Honorable Court to enter judgment in its favor and against Defendant, Moving Experts, LLC in the amount of Nineteen Thousand Four Hundred Forty -Eight and 73/100 Dollars ($19,448.73) plus additional storage fees accruing at the rate of Forty Dollars ($40) per day from April 7, 2014 until such time as said judgment is paid and Defendant's Truck is removed from Plaintiffs property, plus reasonable attorney fees and costs of suit. COUNT II QUANTUM MERUIT 31. Paragraphs 1 through 30 are incorporated herein as if set forth in full. 5 32. John's Mobile conferred a benefit upon Defendant in the performance of repairs and storage of the Truck as set forth above. 33. Defendant accepted the benefit conferred upon it by John's Mobile. 34. The fair and reasonable value of the repairs provided is Three Thousand Two Hundred Seventy -Eight and 73/100 Dollars ($3,278.73). 35. The fair and reasonable value of the storage provided is Forty Dollars ($40) per day, totaling Sixteen Thousand Nine Hundred Twenty and 00 /100 Dollars ($16,920.00) as of April 7, 2014. 36. Despite Plaintiffs reasonable demands, Defendant has failed to pay fully for the benefit conferred upon it and accepted by it. WHEREFORE, Plaintiff, John's Mobile Repair Service, Inc. prays this Honorable Court to enter judgment in its favor and against Defendant, Moving Experts, LLC in the amount of Nineteen Thousand Four Hundred Forty -Eight and 73/100 Dollars ($19,448.73) plus additional storage fees accruing at the rate of Forty Dollars ($40) per day from April 7, 2014 until such time as said judgment is paid and Defendant's Truck is removed from Plaintiff's property, plus reasonable attorney fees and costs of suit. COUNT III UNJUST ENRICHMENT 37. Paragraphs 1 through 36 are incorporated herein as if set forth in full. 6 38. As more fully set forth above, the recovery and storage services provided by John's Mobile to Defendant for which Defendant has not paid, has enriched Defendant in the amount of Nineteen Thousand Four Hundred Forty -Eight and 73/100 Dollars ($19,448.73) plus additional storage fees accruing at the rate of Forty Dollars ($40) per day from April 7, 2014 until such time as said judgment is paid and Defendant's Truck is removed from John's Mobile's property. 39. Such enrichment of Defendant would be unjust if Defendant were permitted to retain the benefit of John's Mobile's services without paying John's Mobile for the fair value of such services. WHEREFORE, Plaintiff, John's Mobile Repair Service, Inc. prays this Honorable Court to enter judgment in its favor and against Defendant, Moving Experts, LLC in the amount of Nineteen Thousand Four Hundred Forty -Eight and 73/100 Dollars ($19,448.73) plus additional storage fees accruing at the rate of Forty Dollars ($40) per day from April 7, 2014 until such time as said judgment is paid and Defendant's Truck is removed from Plaintiff s property, plus reasonable attorney fees and costs of suit. SALZMANN HUGHES, P.C. By: ! David H. Esquire Attorney I.D. No. 84127 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249 -6333 Attorneys for Plaintiff Date: April 10, 2014 7 EXHIBIT "A" 4/312014 Business Entity r.c 7' pennsylvania { I)EPARTMENTOF STATE - r Corporations Online Services I Corporations Forms I Contact Corporations I Business Services -arch Business Entity Filing B i Business Name History r:;/ BUSiness Entity ID Date: 413/2014 Select the link above to view the Business Entity's ,Verify Certi',ication Filing History) Online Orders Registe, fear Online Orders Business Name History Order Good Standing Order Certified Documents Name Name Type Order Business List Nly iy -nages Moving Experts L.L.C. Current Name Search 'ior timeges Limited Liability Company - Foreign - Information Entity Number: 4072096 Status: Active Entity Creation Date: 11/17/2011 State of Business.: OH Registered Office Address: 201 Penn Center Bldg Suite 400 PA 15235 Allegheny Mailing Address: No Address Copyright © 2002 Pennsylvania Department of State. All Rights Reserved. Privacy Policy I Security Policy https: / /www.corporations. state. pa .us /corp /soslb /Corp.asp ?3002487 1/1 EXHIBIT "B" JOHN'S MOBILE REPAIR SERVICE, INC. 1511 EAST COMMERCE AVE. CARLISLE, PA 17015 www.jmrsinc.com (717) 245 -0076 • FAX: (717) 245 -0648 Cust. P/ O # Invoice Number: 173084 Invoice Date: 1/25/2013 Page 1 of 2 Bill To: OT Vehicle No. 0 MOVING EXPERTS Make: FORD Phone: 440 - 463 -1133 4477 WESTVIEW DR Model: F SERIES License: PHM9993 Mechanic: MS / JS Year: 1999 N OLMSTED OH 44071 Serial #: 3FENF8OZ6XMA21306 Mileage: 153331 WORK PERFORMED /COMMENTS - CUSTOMER WAS TOWED TO JMRS WITH BRAKE SYSTEM CONCERN / NO BRAKES - PERFORMED BRAKE SYSTEM DIAGNOSTICS - FOUND HYDRO BOOST PUMP LEAKING - FOUND BRAKE LINE FROM FRONT TO REAR RUSTED AND LEAKING - REMOVED AND REPLACED HYDRO BOOST ASSEMBLY - REMOVED DAMAGED BRAKE LINE / FABRICATED NEW BRAKE LINE AND INSTALLED - FOUND LEFT REAR WHEEL CYLINDERS NOT CONNECTED / DUE TO BEING INOPERABLE - ADVISED CUSTOMER / CUSTOMER REQUESTED REPLACING BACKING PLATE ASSEMBLY - REMOVED AND REPLACED LEFT REAR BACKING PLATE ASSEMBLY - BLED BRAKE SYSTEM - ROAD TEST OK - STORAGE BEGINS 2/8/13 @ $40 PER DAY - RECEIVED CK # 4882 $500.00 TOWARD BALANCE 4/5/13 - RECEIVED CK # 4845 $250.00 4/17/13 -- -NOTE 12/19/2013 - AS PER OUR CONVERSATION I HAVE REDUCED THE STORAGE BY 200 DAYS AND THE NEW TOTAL IS AS FOLLOWS 7278.73 - 750.00 PREVIOUSLY PD. BALANCE 6528.73 - WHEN YOU SURRENDER THE CLEAN TITLE TO US WITHIN 30 DAYS OF YOUR RECEIPT OF THIS FINAL INVOICE I WILL RELEASE FROM YOU ANY FURTHER COST OR OBLIGATION. I WILL INTURN RESALE THE TRUCK FOR WHAT EVER VALUE IT BRINGS AT AUCTION. SHOULD THAT VALUE NOT EQUAL THE BALANCE OWED YOU WILL NOT BE RESPONSIBLE FOR THE OWED BALANCE. Part Number Part Description Quantity Price Amount STORAGE STORAGE OF VEHICLE ON LOT 421 $40.00 $16,840.00 0 1/4 " BRAKE LINE 1 $50.12 $50.12 BRAKE FLUID DOT 3 (QT) 4 $9.99 $39.96 BLF44C5 ADAPTER TUBE NUT 2 $3.56 $7.12 XC3Z- 20256 -AA HYDRO BOOST ASSY 1 $401.02 $401.02 68021283NFP BRAKE ASSY 1 $786.00 $786.00 HE FACTORY WARRANTY CONSTITUTES ALL OF THE WARRANTIES WITH RESPECT TO THE SALE OF THIS TEWIiEMS. THE SELLER REPLACED PARTS WILL BE DISCARDED UNLESS CHECKED HERE �- EREBY EXPRESSLY DISCLAIMS ALL WARRANTIES, EITHER EXPRESSED OR IMPLIED, INCLUDING ANY IMPLIED WARRANTY OF IERCHANTABILRY OR FITNESS FOR A PARTICULAR PURPOSE AND THE SELLER NEITHER ASSUMES NOR AUTHORIZES ANY OTHER SAVE BY MY SIGNATURE I ACKNOWLEDGE RECEIPT OF THE VEHICLE ERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION WITH THE SALE OF THIS ITEMnTEMS. AND AGREE THAT AFTER EXAMINING IT I FIND THE VEHICLE It hereby authorize therepair work hereinafter sat forth to be done along wlth the necessary matelot and agree that you are not responsible SATISFACTORY CONDITION AND I AM SATISFIED W ITH THE QUALITY O i .r loss or damage to vehlde or ertkles left In vehicle In case o1 Ilre, theft or any other cause beyond your control or for any delays caused y unevalleblllty of pads or delays In pads sh¢ments by the supplier or trensponer. I hereby grant you anNor your employees permisskrn to WORK AND MATERIAL. oerete the vehlde herein descrbed on streets, highways or elsewhere for the purpose of testing andior Inspactbn. An express mechanic's m Is hereby acknowledged on above vehlde to secure the amount of repairs thereto. CUSTOMER'S SIGN HERE ACCEPTANCE JOHN'S MOBILE REPAIR SERVICE, INC. 1511 EAST COMMERCE AVE. CARLISLE, PA 17015 www.jmrsinc.com (717) 245 -0076 9 FAX: (717) 245 -0648 Invoice Number: 173084 Invoice Date: 1/25/2013 Page 2 of 2 Part Number Part Description Quantity Price Amount 370023A WHEEL SEAL 1 $49.20 $49.20 10392 LUCAS TOOL BOX BUDDY AEROSOL 11 1 $5.90 $5.90 LABOR ALL WORK PERFORMED 18 $95.00 $1,710.00 75W90 75W90 SYNTHETIC (QT) 1 $9.80 $9.80 ATF TRANS FLUID ( QUART) 6 $5.67 $34.02 Taxable Parts: $1,383.14 Taxable Labor: $1,710.00 Non Taxable Parts: $16,840.00 Non Taxable Labor: $0.00 Sub Total: $19,933.14 Sales Tax: $185.59 Tire Tax: $0.00 Total Due: $20,118.73 HE FACTORY WARRANTY CONSTITUTES ALL OF THE WARRANTIES WITH RESPECT TO THE SALE OF THIS ITEM/ITEMS. THE SELLER REPLACED PARTS WILL BE DISCARDED UNLESS CHECKED HERE C fEREBY EXPRESSLY DISCLAIMS ALL WARRANTIES, EITHER EXPRESSED OR IMPLIED, INCLUDING ANY IMPLIED WARRANTY OF AERCHANTABIL1TYORFITNESSFORAPARTICULARPURPOSEANDTHESELLERNEI THERASSUMESNORAUTHORIZESANYOTHER SAVE BY MY SIGNATURE I ACKNOWLEDGE RECEIPT OF THE VEHICLE PERSON TO ASSUME FOR IT ANY LIABILITY IN CONNECTION wITH THE SALE OF THIS ITEMnTEMS, AND AGREE THAT AFTER EXAMINING IT I FIND THE VEHICLE It hereby authorize the re ppall work hereinafter set forth to be done along with the necessary matenal and agree that you are not responsible SATISFACTORY CON DITI ON AN D I AM SATISFI E D W ITH THE QUALITY Of x loss or damage to vehicle or ankles left In vehicle lo case of lire, theft or any other cause beyond your control or for any delays caused y unavallablll o1 pens or delays in pa is a11P is by the su �puer or transporter. l hereby grant you and/or your employees permission to WORK AND MATERIAL. Palate the vehicle herein descrbed on stre915. Alghweys ore ewhere for the purpose of esting and/or Inspection. An express mechanic's en is hereby acknowledged on above vehicle to secure the amount of repairs thereto. CUSTOMER'S K SIGN HERE 1 ACCEPTANCE VERIFICATION 1, John A. Cunningham, Jr., President of John's Mobile Repair Service, Inc., Plaintiff in the attached Complaint, certify that I have read the statements made in this Complaint and that they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. JOHN'S MOBILE REPAIR SERVICE, INC. BAo A. Cunningham, Jr., resident Date: April ' , 2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY t0I-i6'71, riU Y 20 PH 3: 10 CUMBERLAND COUNTY PENNS YLVANIA John's Mobile Repair Service, Inc. vs. Case Number Moving Experts, LLC 2014-2200 SHERIFF'S RETURN OF SERVICE 04/14/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Moving Experts, LLC, 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. 05/08/2014 The requested Complaint & Notice returned by the Sheriff of Allegheny County, the within named Defendant Moving Experts, LLC, not found. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.49 May 16, 2014 (c) CountySuite Sherif`, Teleosoft, Inc. SO ANSWERS, X RONNR ANDERSON, SHERIFF onny R Anderson Sheriff Jody S Smith chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Of E.o�t��t�, uoiai ��pr�G /\ ° OFFICE OF THE SHERIFF Richard W Stewart Solicitor John's Mobile Repair Service, Inc. vs. Moving Experts, LLC Case Number 2014-2200 SERVICE COVER SHEET [Service Details: Category: Manner: Notes: Civil Action - Complaint & Notice Deputize Expires: 05/09/2014 Zone: Warrant: Please serve at address below they are the registered agents for the defendant. !Also $5 notary fee included. Thank you. ;Serve To: vc Name: w - Primary • dress: CD 5 w - Phone: w one: Alternate Address: ] [Final Service Moving Experts, LLC 201 Penn Center Building Suite 400 Pittsburgh, PA 15235 DOB: z Attorney / Originator: z� a Name: N Service Attempts: Salzmann Hughes, PC Served: Adult In Charge: 717-263-2121 Date: "o Time: N Mileage: N Deputy: U J J [Notes I— / Special Instruuctnsstio� ,s: Ce a No +�- 4014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to w execute sere of the documents herewith and make return thereof according to law. 0 z Return To: p Cumberland County Sheriffs Office 2 One Courthouse Square 5 4a it c9A0 11 7L COMMONWEALTH -OF PENNSYLVANIA Notarial Seal Eda Jean Woodward, Notary Public City of Pittsburgh, Allegheny County My Commission Expires May 28, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Carlisle, PA 17013 (0ConntySune Sheriff Te.eo.<.utt. me Ronny R Anderson, Sheriff Salzmann Hughes, P.C. BY: David H. Martineau, Esquire Attorney I.D. No. 84127 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 Telephone: (717) 249-6333 Attorney for Plaintiff E-mail: dmartineau@salzmannhughes.com JOHN'S MOBILE REPAIR SERVICE, INC., v. MOVING EXPERTS, LLC., HE PROTHONo TAR 201 11 JUL 30 Pti I: 4 8 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NO: 14-2200 Defendant : JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed by Plaintiff in the above captioned matter. Respectfully submitted, SALZMANN HUGHES, P.C. Date: July 30, 2014 By: David H. Martineau, Esquire Attorney I.D. No. 84127 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorneys for Plaintiff #. ris,� c/ iffy C# -2 73e5-- ei&-340r/9.,