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HomeMy WebLinkAbout14-4999 Supreme Co ;ennsylvania Cour f,,Calmmo leas For Prothonotary Use Only: Docket No: f CUMBERLAND County The information collected on this form is used solely,for court administration purposes. This form does not supplement or replace thefiling and,service of leadin s or other papers as required by law or rules of court. Co encement of Action: Complaint [3Writ of Summons ® Petition S;. Transfer from Another Jurisdiction Declaration of Taking E+ - Lead Plaintiff's Name: STEVEN HOWELL Lead Defendant's Name: MARK G. DORWARD D/B/A SANDELMAN ASSOCIATES Dollar Amount Requested: ithin arbitration limits Y Are money damages requested? Yes ® No (check one) ®outside arbitration limits O`. Y. Is this a Class Action Suit? ®Yes N0 Is this an MDJAppeal? ® Yes XNo A Name of Plaintiff/Appellant's Attorney: STEVEN HOWELL, ESQUIRE ® 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) Cw_,Buyer TRACT (do not include Judgments) CIVIL APPEALS ® Intentional Plaintiff Administrative Agencies ® Malicious Prosecution Debt Collection:Credit Card ® Board of Assessment ® Motor Vehicle ® Debt Collection:Other 13 Board of Elections 0 Nuisance ® Dept.of Transportation ® Premises Liability © Statutory Appeal:Other E3 Product Liability(does not include mass tort) 0 Employment Dispute: ® Slander/Libel/Defamation Discrimination C ® Other: ® Employment Dispute:Other ® Zoning Board T 0 Other: I 12 Other: 0 MASS TORT ® Asbestos N © Tobacco ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste ® Other: ® Ejectment 0 Common Law/Statutory Arbitration 1B ® Eminent Domain/Condemnation ® Declaratory Judgment ® Ground Rent ® Mandamus ® Landlord/Tenant Dispute ® Non-Domestic Relations ® Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure:Commercial n Quo Warranto ® Dental 0 Partition 13 Replevin Legal ® Quiet Title ®Other: ® Medical ® Other: l3 Other Professional: Updated 1/1/2011 NOTICE Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part: Rule 205.5. Cover Sheet (a)(1) This rule shall apply to all actions governed by the rules of civil procedure except the following: (i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq. (ii) actions for support, Rules 1910.1 et seq. (iii) actions for custody, partial custody and visitation of minor children, Rules 1915.1 et seq. (iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq. (v) actions in domestic relations generally, including paternity actions, Rules 1930.1 et seq. (vi) voluntary mediation in custody actions, Rules 1940.1 et seq. (2) At the commencement. of any action, the party initiating the action shall complete A the cover sheet set forth in subdivision (e) and file it with the prothonotary. (b) The prothonotary shall not accept a filing commencing an action without a completed cover sheet. (c) The prothonotary shall assist a party appearing pro se in the completion of the form. (d) A judicial district which has implemented an electronic filing system pursuant to Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the provisions of this rule. (e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be published on the website of the Administrative Office of Pennsylvania Courts at www.12acourts.us. c�* STEVEN HOWELL IN THE COURT OF COMMON ASS PLAINTIFF CUMBERLAND COUNTY 55 u r- PENNSYLVANIA CD CD V. CIVIL ACTION-LAW v ' -' zc: c�1` MARK G. DORWARD, d/b/a SANDELMAN ASSOCIATES DEFENDANT NO. 14- 4Q Q9 aivi i lem NOTICE TO DEFEND 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 RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PENNSYLVANIA 17013 (717) 249-3166 rTq 4 116, r15 Pt A` at 11'7`73 e1 310 a35 STEVEN HOWELL, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. MARK G. DORWARD, d/b/a SANDELMAN ASSOCIATES, DEFENDANTS CIVI ACTION -LAW COMPLAINT 1. Steven Howell,Esquire is an adult individual with a business address of 619 Bridge Street,New Cumberland,Cumberland County, Pennsylvania 17070. 2. Mark G. Dorward is an adult individual with a business address of 505 South Third Street,Lemoyne,Cumberland County, Pennsylvania 17043. 3. Mark G. Dorward conducts business under the name of SandeIman Associates with a principal place of business located at 505 South Third Street, Lemoyne,PA 17043. 4. in early October 2013 Plaintiff and Defendant entered into an oral contract in York County for the total sum of Twelve Thousand Seven Hundred Ninety Five and 00/100 ($12,795.00) Dollars for the following work to be performed in New Cumberland,York County, Pennsylvania: a. Excavation and installation of a parking pad adjacent to a garage; b. Excavation and installation of a retaining wall on concrete footers at rear of garage to support parking pad and decorative concrete wall described in Paragraph 4 c; C., Installation of a decorative concrete wall (approximately 42"in height) on the parking pad at the rear of the garage; d. Excavation and installation of stamped concrete from parking pad adjacent to a garage to the driveway; e. Excavation of two trenches and installation of underground conduits enabling Plaintiffs electrician to run circuits to pool heater,filter and landscaping lights for a pool to be installed in the Spring of 2014 by Crystal Pools; f. Installation of a metal landscaping border between crushed stone and new vinyl fence installed around pool area; g. Power washing and painting masonry walls; h. Excavation and installation of concrete pad for mailbox and brick pylon; i. Removal and reinstallation of a section of vinyl stair railing adjacent to the retaining walls; and j. Excavation and installation of an 8'x 4'foot section of concrete sidewalk between mailbox pylon and stamped concrete. 5. For this work,Plaintiff paid Mark Dorward Eleven Thousand Two Hundred Eighty Three and 00/100 ($11,283.00) Dollars in the following checks: a. Three Thousand and 00/100 ($3,000.00) Dollars on October 9, 2013 which was by Check No. 162 and is marked in the memo section of the check as"concrete driveway/front wall'; b. Three Thousand Two Hundred Seventy and 00/100 ($3,270.00) on October 21, 2013 which was by Check No. 163 for the second payment allocated in the memo section of the check as 1270-conduit/3K Pad (2nd Pmt)"; C. Four Thousand Four Hundred Fifty and 00/100 ($4,450.00) Dollars on October 31, 2013 by Check No. 11297 for the third payment towards the work with a notation in the memo section of"balance 1700+ 375"; d. Two Hundred and 00/100 ($200.00) Dollars on November 22, 2013 by Check No. 11341 for the fourth payment towards the work which is labeled "concrete"in the memo section; and e. Three Hundred Sixty Three and 00/100 ($363.00) Dollars on May 20,2014 by Check No. 11630 for the fifth payment towards the work with"Balance 310.66 (pad/wall) + 375 (steel)"in the memo section. 6. On October 31-November 1,2013 Defendant poured a retaining wall at the rear of the garage which was 6"out of square from the brick wall of the garage. 7. On November 2,2013 Defendant poured the concrete pad on top of the retaining wall which continued the 6"out of square line from the brick wall of the garage. 8. Defendant essentially left Plaintiff with a pad that was not square but trapezoidal in shape. 9. Defendant then failed to obtain or install the 2"drainage pipe for installation in the concrete pad on November 2, 2013 because he"forgot" that Pennsy Supply is not open on Saturdays after October 31st. Defendant appeared inebriated on the morning of November 2, 2013. 10. Defendant utterly failed to conduct the pour in a professional manner leaving Plaintiff with a shoddy and unprofessional looking pad and retaining wall. 11. Immediately after the work on November 2, 2013 Defendant agreed the concrete retaining wall and concrete pad were shoddy,unprofessional and unacceptable and he agreed to do the following: a. Remove the concrete pad at the rear of the garage and install a new pad atop a decorative wall which would conceal the"out of square"retaining wall; b. Then install a decorative wall consisting of landscaping bricks adjacent to the retaining wall to"hide"the out of square retaining wall so long as Plaintiff purchased the blocks which Plaintiff did at the cost of$826.34 from Budding Company in Camp Hill, PA 17011 in an Invoice dated November 16, 2013; C. Remove the crooked pad and pour a new pad with the correct drainage pipe;and d. Complete all other work before the excavation and installation of an in ground pool in April 2014. 12. Defendant's work was the product of poor planning,poor supervision of employees and inattention to detail. 13. None of these traits had been evident in prior work performed by the Defendant in the summer of 2013 before the events of late October 2013 -early November 2013. 14. Defendant was told no more funds would be advanced until he made substantial progress on correcting the work improperly installed in late October 2013 -early November 2013. 15. The$200.00 payment by Plaintiff on November 22, 2013 was only made after Defendant rented a diamond blade saw and removed the concrete pad. 16. Defendant then used most of November 2013 and all of December 2013 to install the landscaping bricks purchased by Plaintiff on November 16, 2013. 17. Defendant repeatedly had to be told how to properly cut and install the landscaping bricks but eventually he completed the task. 18. Defendant,however,failed to complete his work by the end of April 2014 because the in ground pool was installed in nine days with no problems. 19. After repeated phone calls and text messages the Defendant finally appeared and poured the concrete pad and installed the drainage pipe on or about May 20, 2014 for which he was paid$363.00 (cost of concrete). 20. Defendant was then told he had to complete the work before Hemlock Landscaping commenced their work in the last two weeks of June 2014. 21. Defendant agreed that he would complete all work before Hemlock Landscaping commenced their work. 22. As usual, Defendant failed to abide by his promises and Hemlock Landscaping commenced and completed their work by July 14, 2014. 23. Defendant's failure to complete the lower retaining wall and the upper decorative wall caused delays and problems for Hemlock Landscaping. 24. Defendant was provided with repeated warnings that he needed to complete the project and he ignored those requests. 25. Defendant was told on more than one occasion if he did not complete his work another contractor would be used and he would have to pay the costs. 26. Defendant agreed that if he failed to perform he would reimburse Plaintiff having to employ another contractor to complete the work. 27. After months of delays,failed promises by the Defendant and efforts to reach a compromise with the Defendant,Plaintiff paid Hemlock Landscaping to install the decorative wall on the pad for the sum of $2,285.00 on July 3, 2014. 28. After months of delays,failed promises by the Defendant and efforts to reach a compromise with the Defendant, Plaintiff paid Hemlock Landscaping to complete the lower retaining wall for$770.00 on July 24, 2014. 29. Plaintiff must also pay to have Elite Vinyl Fence and Railing to reinstall the stair rails and this cost is estimated at$450.00. 30. Defendant also broke one of the caps for the stair posts and the cost for a replacement is$9.00. 31. Plaintiff held back$685.66 that represents the difference between the contract price ($12,795.00) and what Defendant was paid ($11,283.00) and the price of the landscaping blocks purchased by Plaintiff($826.34) on November 16,2013. 32. Plaintiff expended$3,OS5.00 with Hemlock landscaping to complete the work the Defendantrwas supposed to finish. 33. Defendant is expected to expend$450.00 to reinstall the vinyl stair rail. 34. Defendant expended$9.00 to purchase a replacement cap for the stair Post. 35. Deducting the$685.66 from the$3,514.00 leaves the sum of$2,828.34 that Defendant owes Plaintiff. Count is Breach of Contract 36. Plaintiff and Defendant entered into a contract as described above in Paragraphs 1-3S. 37. Defendant breached the contract as described above in Paragraphs 1-35. 38. Plaintiff suffered losses of$2,828.34. 39. Defendant owes Plaintiff the sum of$2,828.34. WHEREFORE, Plaintiff demands judgment against Defendant for$2,828.34 plus costs and statutory interest. Count II:Violation of the Home Improvement Consumer Protection Act(HICPA),73 P.,&_'4511.1 et segs 40. Plaintiff incorporates by reference I1-139 as'though fully set forth. 41. HICPA defines a home improvement contract to include the construction of driveways,retaining walls and drainage systems if the price involved is more than$500.00. 42. HICPA defines a contractor as"any person who undertakes,offers to undertake or agrees to perform any home improvement". 43. In this case, Defendant is a-contractor and agreed to perform a home improvement covered by HICPA. 44. -HICPA at§517.3 requires anyone who holds themselves out as a contractor to be registered with the Bureau of Consumer Protection in the Office of the Attorney General for the Commonwealth of Pennsylvania. 45. Mark G.Dorward is not registered with the Bureau of Consumer Protection as shown on Exhibit"A"(printout dated`8/18/14). 46. Sandelman Associates is not registered with the Bureau of Consumer Protection as shown on Exhibit"B"(printout dated 8/18/14). 47. HICPA requires all contracts to be in writing. 48. 141CPA requires all contracts to include certain information including the starting and completion dates,the description of work performed,the 57. The UTPCP Law defines a deceptive act as "engaging in any other fraudulent or deceptive conduct which creates a likelihood of confusion or misunderstanding". 58. Defendant has a history of fraudulent business practices. 59. In Christine Myers v.Mark Forward d/b/a Sandleman Associates,No. 2005-6649 (Cumberland County), Defendant accepted a deposit and failed to perform the work. 60. In Paul Trapido v Mark G.Dorward d/b/a Sandleman Associates,No. 2006-5168 (Cumberland County),Defendant failed to perform the work in a professional manner. 61. In Cumberland Masonry v.Mark Dorward and Darinda Sue Dorward, No. 2012-5150 (Cumberland County), Defendant removed tiles at night from another contractor without paying for them. 62. Defendant's actions are fraudulent in that he accepts money and then fails to perform the work 63. Defendant's actions are fraudulent in that he promises to complete work by certain time deadlines and routinely fails to do so. 64. Defendant's statements to Plaintiff in November 2013 indicate that his practice is to use deposits received from new customers to pay for his living expenses while he finishes prior customers work. 65. Defendant's actions are per se fraudulent in that he pocketed$2,828.34 but failed to deliver the goods and/or services. 66. Plaintiff has been compelled to expend now or in the near future $2,828.34 to complete the upper decorative wall and lower retaining wall and the reinstallation of the stair railing. 67. Plaintiff has incurred legal fees to research and draft this Complaint in an amount of$1,000:00. 68. . The Unfair Trade Practices and Consumer Protection Law provides at §201.9.2 that triple damages and reasonable attorney fees may be awarded to a private party. WHEREFORE, Plaintiff demands judgment against Defendant for$9,485.02 plus costs and statutory interest Respectfully submitted, By: Steven well, quire Horil Law Fi 9 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff Date: August 20, 2014 Home Improvement Contractor Search 8/18/14 3:27 PM •. , E 1M - � � ONSUMER ORMf O Home Complaints Consumers Crime Drtt!nc kick; Parpntc R. Crhni Find nearest contractor No home improvement contractors found. Keyword(s): rh;s information was provided by the contractor on the iegistr:, ..,the iequrrcm . e.g.Electrical Plumbing Improvement Consumer Protection Act, Location: 1 Registration under HICPA is not an endorsement,recommendation or approval by the Office of Attorney General of i,;e contractor',competency or skirl e.g.Harrisburg,PA 02134 Find a specific contractor $ HIC Number: Business Name: Dorward Mark City: i Zip: Phone Number(including area code): Helpful Links Better Business Bureau Pennsylvania District Attorneys Association Bucks County Office of Consumer Protection Delaware County Consumer Affairs Lehigh County Office of Consumer Protection Montgomery County Consumer Affairs Philadelphia County Office of Consumer Protection http://hicsearch.attorneygeneral.gov/ Page 1 of 1 Home Imp#ovement Contractor Search 8/18/14 3:28 PM 4 - CONSUMER INFORMATION Home Complaints Consumers Crime Find nearest contractor Business Barry Lee Dorward Keyword(s): HIC# PA084460 Expiration 9/2/2013 e.g.Electrical Plumbing Phone 570-778-0270 Fax Location: Address 1 1293 Germans Rd. e.g.Harrisburg,PA 02134 City Lehighton State PA Zip 18235 Description General Construction-Carpentry-Roofing-Siding-Etc. View Mao (The accuracy of distance is based on provided address.) Find a specific contractor W _. Business Dorward's Roofing and Construction HIC Number: HIC# PA033961 Expiration 7/21/2013 Business Name: Phone 570-401-1302 Fax Dorward Address 1 902 Rock st. City: City Lehighton State PA Zip 18235 roofing,siding,interior and exterior construction,doors,windows,slate repair,minor Zip: Description plumbing,minor electrical,drywall installation,spackleing,interior and exterior painting,remodeling,and grass cutting. Phone Number(including area code): View Mao (The accuracy of distance is based on provided address.) Helpful Links Better Business Bureau Pennsylvania District Attorneys Association Bucks County Office of Consumer Protection Delaware County Consumer Affairs Lehigh County Office of Consumer Protection Montgomery County Consumer Affairs Philadelphia County Office of Consumer Protection http://hicsearch.attorneygeneral.gov/ Page 1 of 1 Home Improvement Contractor Search 8/18/14 3:29 PM CONSUMER INFORMat ION Home complaints Consumers Crime Drugs IfitIc, Harpnrc tc erhnr Find nearest contractor No home improvement contractors found. Keyword(s): e.g.Electrical Plumbing Location: e.g.Harrisburg,PA 02134 nearestFind . . � Find a specific contractor HIC Number: Business Name: Sandelman Associates City: Zip: Phone Number(including area code): Helpful Links Better Business Bureau Pennsylvania District Attorneys Association Bucks County Office of Consumer Protection Delaware County Consumer Affairs Lehigh County Office of Consumer Protection Montgomery County Consumer Affairs Philadelphia County Office of Consumer Protection http://hicsearch.attorneygeneral.gov/ Page 1 of 1 Ronny R Anderson Sheriff Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY vox 01 C.C.FiCE• OF m45. S-HERFP _'_ iuFPRI-WO/jIT:``^' lS/kOP--< Pfl 2: I: 0 CUMBERLAND 7Y PENNSYLVANIA Steven Howell vs. Mark G. Dorward d/b/a Sandelman Associates Came Number 2014-4999 SHERIFF'S RETURN OF SERVICE 09/24/2014 O1:OGPM'Sheriff Ronny RAnderson, being duly sworn according to Iaw, states he made dUigent search and inquiry for the within named Defendant to wit: Mark G. Donwanjd/b/n Sandelman Associates, but was unable to Iocate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 505 South Third Street, Lemoyne Borough, Lemoyne, PA 17043. Deputies were unable to make contact with anyone at the residence to make service and the Complaint has since expirod. SHERIFF COST: $8416 SO ANSWERS, September 25.2014 RONNYRANDERSON, SHERIFF STEVEN HOWELL, PLAINTIFF VS. MARK G. DORWARD, djbja SANDELMAN ASSOCIATES, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 14-4999 CIVIL TERM CIV! ACTION - LAW PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: PLEASE REINSTATE THE COMPLAINT. Respectfully submitted, By: Date: September 30, 2014 7'1 rn -°r• r Ste n How , Esquire o e 1 Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff a Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY i ;LED -01 0 N PROTHGidO,At ,F, OFCg OF i 4 $HERIFF ZO14 NOV -3 PH 3: 55 CUMBERLAND COUNTY PENNSYLVANIA Steven Howell vs. Mark G. Dorward d/b/a Sandelman Associates Case Number 2014-4999 SHERIFF'S RETURN OF SERVICE 10/24/2014 06:45 PM - Deputy Jamie DiMartile, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Darinda Dorward, Wife, who accepted as "Adult Person in Charge" for Mark G. Dorward d/b/a Sandelman Associates at 505 South Third Street, Lemoyne Borough, Lemoyne, PA 17043. IE DIMARTILE, DEPUTY SHERIFF COST: $46.57 SO ANSWERS, October 27, 2014 (c) CountySu%te Sheriff, Teleosoft, Inc. RONI�Y R ANDERSON, SHERIFF STEVEN HOWELL, PLAINTIFF V. MARK G. DORWARD, d/b/a SANDELMAN ASSOCIATES, DEFENDANTS, TO: Mark G. Dorward d/b/a Sandelman Associates 505 South Third Street Lemoyne PA 17043 DA I E OF NOTICE: November 14, 2014 THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION — LAW NO. 14-4999 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 AVISO IMPORTANTE A: Mark G. Dorward d/b/a Sandelman Associates 505 South Third Street Lemoyne PA 17043 ECHA DEL AVISO: November 14, 2014 USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO 0 A TRAVES DE UN ABOGADO Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS IMPORTANTES. USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN A130GADO, LLAME 0 VAYA A LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE. INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDE PRO VEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE PA 17013 (717) 249-3166 Date: November 14, 2014 Respectfully submitted, By: enH l,!q owe!!aw Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: Mark G. Dorward d/b/a Sandelman Associates 505 South Third Street Lemoyne PA 17043 Date: November 14, 2014 S 7eV e ,d v✓tZ 1 PLq-,fir r F mAm6 De Arc7 cil // 1 el San�/c l / kliJ /as s ear47r No, or/if-gem 61v& '7ytA4 WRITTEN APPEARANCE Docket # 14-4999 1. Admitted 2. Admitted 3. Denied Mark G Dorward d/b/a Sandelman Associates does not conduct business under said d/b/a nor have 505 south third street Lemoyne pa 17043 as a principal place of business for d/b/a Sandelman assoc 4. Denied 5. Denied 6. Denied 7. Denied 8. Denied 9. Denied 10. Denied 11. Denied 12. Denied 13. Denied 14. Denied 15. Denied 16. Denied 17. Denied 18. Denied 19. Denied 20. Denied 21. Denied 22. Denied 23. Denied 24. Denied 25. Denied 26. Denied 27. Denied 28. Denied 29. Denied 30. Denied 31. Denied 32. Denied 33. Denied 34. Denied 35. Denied Defective Service of Due Process. ( response is same for a -j under 4 ) Defective Service of Due Process. ( response is same for a -e under 5 ) Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. ( response is same for a -d under 11 ) Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. Defective Service of Due Process. 36-39. Denied Defective Service of Due Process. CD m _.t_ "r; O "r • Count 1: Breach of Contract Count II: Violation of HICPA 40-48. Denied Defective Service of Due Process. 49-56. Denied Defective Service of Due Process. Note: These numbers are not included in complaint nor available for viewing on-line 57-68. Denied Defective Service of Due Process. #41-71 6.