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Home My WebLink About14-6578 Supreme Co, , f Pennsylvania Co C Pleas et rr CUMBERLA ' 1 �' County JOE n4` „I J` .�. . The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the,filing and service ofleadirigs or other ers as re V&ed by law or rules of court Commencement of Action: ❑Complaint ❑Writ of Summons ❑ Petition ❑ Notice of Appeal ❑Transfer from Another Jurisdiction ❑ Declaration ofTditg Lead Plaintiffs Name: Lead Defendant's Name: SCOTT A. NOSS GARY L`: COLLINS ❑ Check here if you are a Self-Represented(Pro Se)Litigant Name of PlaintiWAppellant's Attorney: MARCUS A. McKNIGHT, III, ESQUIRE Are money damages requested?• 13Yes ❑No 11 Dollar Amount Requested: within arbitration limits (Check one) outside arbitration limits Is this a Class Action Su#? ❑ Yes ® No si2'�«' w"''`�4 �r� (1tL'r,>�*t � 1� t ray ..`x a.o�. .3. k •' 1a +`�y�r.S� '•~�f'�� piY 4". � Gy � " .k.r 2d: t• i,�tY.Y(u...�dYi` {'` TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle Debt Collection:Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include 11 Statutory Appeal:Other mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute:Other Judicial Appeals ❑ MDJ-Landlord/Tenant ❑ Others ❑ MDJ-Money Judgment MASS TORT ❑ Other: ❑ Asbestos ❑Tobacco ❑ Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure Restraining Order PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto ❑Dental ❑ Quiet Title ❑ Replevin ❑Legal ❑ Medical ❑ Other: ❑ Other: ❑ Other Professional: PaRC.R 205.5 212010 SCOTT A.NOSS, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY,PENNSYLVANIA V. NO. CIVIL TERM ,> C") 3 -,T't GARY L. COLLINS and Wife r?sco rn SHARON E. COLLINS, CIVIL ACTION-LAW r c 1 Defendant yam— _ 7 C ,3 �N NOTICE TO DEFEND r10 :) 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, order 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 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, Pennsylvania 17013 (717)249-3166 1-800-990-9108 C� �4- 3133--,-/- 1 Americans with Disabilities Act of 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court,please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 2 SCOTT A.NOSS, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY,PENNSYLVANIA V. NO. CIVIL TERM GARY L. COLLINS and Wife SHARON E.COLLINS, CIVIL ACTION-LAW Defendant COMPLAINT AND NOW, this 12t` day of November 2014, comes the Plaintiff, Scott A. Noss, by his attorneys, Irwin & McKnight, P.C., and makes the following Complaint against the Defendant, Gary Collins and Sharon Collins, as follows: 1. The Plaintiff, Scott A.Noss is a contractor with his principal place of business, 11 Amity Lane, Mechanicsburg, PA 17050. 2. The Defendants, Gary L. Collins and Sharon E. Collins,adult individuals who reside at 1 Lonk Lane, Mechanicsburg, PA 17055. 3. The parties entered into a contract for the installation of deck reconstruction and an extensive outdoor fireplace and barbeque. A copy of the contract is attached hereto and made a part of this Complaint and is marked as Exhibit"A". 3 4. As the job was being completed the Defendant, Gary L. Collins order the Plaintiff off the job site with less than four(4) hours of work to be done until the job was completed. 5. The balance of the agreed contract balance due to the Plaintiff was Six Thousand Two Hundred Ninety One and 501100 ($6,291.50) Dollars plus the cost of this action and reasonable attorney fees together with interest and costs as provided by law. 6. The Plaintiff attempted to contact the Defendant regarding final payment by they have refused to respond on said final payment. WHEREFORE,the Plaintiff, Scott A. Noss, seek damages from the Defendant, Gary L. Collins and Sharon E. Collins, in the amount in excess of Six Thousand Two Hundred Ninety One and 501100 ($6,291.50) Dollars plus the cost of this action and reasonable attorney fees, interest as permitted by law, and the costs of this litigation. Respectfully submitted, IRWIN & IGH ,P.C. By: M cKnight, 11f, uire 60 West Pomfret Street Carlisle, Pennsylvania 17013 1'�7) 249-2353 Supre Court I.D. No. 25476 Attorney for p i Date: November 12, 2014 4 VERIFICATION The foregoing Complaint is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and 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. Section 4904, relating to unsworn falsification to authorities. SCOTT A. NOSS Date: November 129 2014 5 Exhibit "A" SCOTT A. NOSS 35 2ND STREET YORK HAVEN, PA 17370 (717) 891-3262 CLIENT: MR. and MRS. GARY COLLINS DATE: 5/15/2012 ADDRESS: 1 LONK LANE PHONE: 608-1662 CITY: MECHANICSBURG STATE: PA. ZIP: 17055 FORM: 1 of 1 Materials and/or Labor as follows: Proposed Outdoor Fireplace: Estimated Installed Cost $ 1219 N sa Cost includes all needed materials, any tools and/or equipment including usage or rental fees if applicable, labor, delivery fees, and taxes to complete job as necessary. We propose to furnish materials and labor to the above specifications for the sum of ollars !0, Payment to be made as follows: 1/3 down. 1/3 upon starting With balance due upon Completion Of Job ACCEPTANCE OF PROPOSAL: The above prices, specifications and terms are acceptable. You are authorized to do the work specified. Payment will be made as outlined above. Any additional work not listed above will incur additional charges on the final bill Date of Acceptance U/d-1Signature SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson HLEO-OFFiCL, SheriffTHE PROTHONO „ cruito, OFFE QF Jody S Smith Chief Deputy Richard W Stewart Solicitor 2{11ii NOV 20 Pt' 3; 1 6 CUMBERLAND COUNTY PENNSYLVANIA Scott A Noss vs. Gary Lee Collins (et al.) Case Number 2014-6578 SHERIFF'S RETURN OF SERVICE 11/14/2014 05:20 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Gary Lee Collins at 1 Lonk Lane, Lower Allen Twp, Mechanicsburg, PA 17055. JON KINSLER, DEPUTY 11/14/2014 05:20 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Sharon E Collins at 1 Lonk Lane, Lower Allen, Mechanicsburg, PA 17055. ON KINSLER, DEPUTY SHERIFF COST: $55.79 SO ANSWERS, November 18, 2014 CountySuite Sheriff, Tol6osoft Inc. R ANDERSON, SHERIFF