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Home My WebLink About05-4512 C.E. SUNDAY & SON WELL DRILLING : IN THE COURT OF COMMON PLEAS OF A Partnership : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs vs. : NO. (S- 4f I J.- CIVIL RICHWINE'S BUILDING AND HOME IMPROVEMENTS Defendant 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 YOU AND A JUDGMENT MAYBE 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, 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 MAYBE 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 BAR ASSOCIATION 35 SOUTH BEDFORD STREET CARLISLE, P A 17013 717-249-3166 C.E. SUNDAY & SON WELL DRILLING : IN THE COURT OF COMMON PLEAS OF A Partnership : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. : NO. C1:: - <,/:J- 1-<-. CIVIL RICHWINE'S BUILDING AND HOME IMPROVEMENTS Defendant COMPLAINT I. C.E. Sunday & Son Well Drilling is a Pennsylvania Partnership with its principal office located at 7106 Carlisle Pike, Carlisle, Cumberland County, Pennsylvania. 2. Defendant Richwine's Building and Home Improvements is a business owned by Lee Richwine, with an address of347 Stempstown Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiffs drilled a well in the capacity of subcontractor at the request of Defendant at Shellbark Court, Hickorytown, Middlesex Township, Cumberland County, Pennsylvania on January 2, 2004. An invoice for the work is attached hereto, incorporated by reference and marked Exhibit "A". 4. The total amount due on the invoice was $1,585.00. Defendant paid $1,000.00 towards the account on May 24, 2004. 5. The remainder ofthe amount due in the amount of$585.00 remains unpaid, despite repeated demands for payment. 6. The work done at the request of Defendant was done in a workmanlike manner. 7. Interest has accrued on the amount due at the rate of 1.5% per month since May 24,2004 and will continue to accrue. NOW THEREFORE, Plaintiffs pray the Court award Plaintiff damages in excess of $600.00 plus interest and costs in the above-mentioned matter. Respectfully submitted, VERIFICA nON The undersigned, having read the attached Complaint, hereby verifies that the facts set forth therein are true and correct to the best of his knowledge, information and belief. This verification is made subject to the penalties of2l8 Pa.C.S.section 4904 pertaining to unsworn falsification to authorities. Kirk Sunday, Partner C.E. Sunday & Son Well Drilling Dated: '6130 I 05' ,cF"T, :SUIIDA! I,JELL :JRILLING FAX NO. :7177663294 ,"tar. :: 7 2005 0:; 1.9pr1 P5 C.E Sunday & Son Well Drilling 7106 Carlisle Pike Carlisle. PA 17013 (717) 766-5604 or 766-0294 PA License Number - 0526 #' .-:3-17-rY:5 Invoice DATE INVOICE # 1/20/2004 582 BILL TO CONTACT Richwine's Building &, Home Improvements 347 StwnlmOwo Rd. Mcchanicsburg, P A 17055 Lee Richwine ph: 717-766-9219 job: Seitz job loe. Shellbark Ct Hickorytown Middlesex Twp. TERMS DUE DATE ACCTS OVER 30 DA... 2% 10 Net 30 2/1912004 1.5% per month DESCRIPTION FT/QTY RATE AMOUNT Drill new water supply well at above named job location on 1/2/04 DrilllimestoJJe 145 ft. 145 4.50 65250 Steel casing (6 518' x 0.188' wall thickness: wt, 13 1b.1ft,) 94 ft. 94 6.50 6U.00 6 ,/8 in. steel casing dnve Shoe I 80.00 80.00 HoIeplug casing grOllt: 200 Ibs (4 bags) 4 25.00 100.00 Water tight cast iron conduit well cap 1 45.00 45.00 NEW SUl'l'L Y WELLS AND WATER SYSTEMS CHLORINATED ON 0.00 0,00 COMPLETION OF WORK: NC. well depth: 145 fl., casing 94 ft. formation: clay 0-15 ft, limestone 15-145' water encountctcd: 15 gpm @ 115 ft.., 25 gpm @ US'. meaSured total gal. min. 4{l Sialic water level on completion: 12 ft estimated l'CCOnunended pump setting: set 80-100' note: clay, mud, water filled voids at 30 fl. and 76-80 fl. 1 in, brass male adapter 3 800 24.00 F10matic 1#80 J im;h br4.S check valve, below pitIe.. adaplcr. I 16.00 16.00 LDS-I0 Bras. Piu... adapter. 2000 lb. rated I 44,00 44.00 1 in. brass T 1 6.50 6.50 I x 3 lIL br.... nipple 2 3.00 6.00 PAID $ 1000.00 ON 512412004 - t,OOO.OO -1,000.00 Total mAN!( you Rage 1 FRDr'1 :ciUIIDA{ WELL DRILL1I~G FAX NO. :7177550294 Mar. 172005 01:19PM P5 C.E SUliday & Son Well Drilling 7106 Carlisle Pike Carlisle, PA 17013 (717) 766-5604 or 766-0294 PA License Number ~ 0526 3-/7-a..5 Invoice DATE INVOICE # 1/20/2004 582 BilL TO CONTACT Richwine's Building & Home Improvements 347 Stumpstown Rd, Mechanicsburg, PA 11055 Lee Richwine ph: 717-766-9219 job: Seitz job Iocr Shellbark Ct. Hickory/own Middlesex Twp. TERMS DUE DATE ACCTS OVER 30 DA... 2"10 10 Net 30 2/]9/2004 J.5%per month DESCRIPTION FT/QTY RATE AMOUNT Balance on 5/24/2004 $ 585,00 Int. 6/04 $ 8.78 Int. 7/04 890 Int. 8104 9.04 Int 9/04 9,17 Inl. 10104 9.31 Int. 1l/04 9.45 Int. ] 2/04 9.59 Int. 1/05 9.74 Jnt. 2/05 9.88 Int. 3/05 10.03 Cl'RRENT BALANCE $ 678.89 Total $585.00 THANK YOU Page 2 (;) D --- ~ \" ~ ~ ~> -J'" C:~ O~~ '(g " " :;! ..., C:::? c=;l Cf' U"l r11 -'0 ~ o -n ---< X..,..., 111'-':-' 1=; c-;:: ("':') --c1 ~,~~;:~ _;1 ~fi .< (.11 SHERIFF'S RETURN - REGULAR CASE NO: 2005-04512 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND C E SUNDAY & SON WELL DRILLING VS RICHWINE'S BUILDING & HOME IMP SHANNON SUNDAY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RICHWINES BUILDING AND HOME IMPROVEMENTS the DEFENDANT , at 1728:00 HOURS, on the 8th day of September, 2005 at 347 STUMPSTOWN ROAD MECHANICSBURG, PA 17055 by handing to JULENE RICHWINE, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18,00 8,80 .37 10.00 .00 37,17 r~/~ R. Thomas Kline Sworn and Subscribed to before 09/09/2005 DUN~y: HARL ~. . Deputy Sheriff me this ) ~ day of W4AD. C.E. SUNDAY & SON WELL DRILLING : IN THE COURT OF COMMON PLEAS OF A Partnership : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs ,Vs. : NO. aDOS - ~Sl,,;( CIVIL RICHWINE'S BUILDING AND HOME IMPROVEMENTS Defendant To the Prothonotary, Enter judgment in favor of the plaintiff and against the defendant above named for failure to answer and assess the plaintiffs damages as follows: Amount claimed in plaintiffs complaint Interest from June, 2004 Costs of Suit $585.00 $168.42 $ 92.67 TOTAL $846.09 It is certified that a written notice of intention to file this praecipe was mailed to the defendant against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least 10 days prior of the filing of this praecipe. ,/ Susan 1. H , Esquire Attorney for laintiff I Irvine Row, Carlisle, PAl 70 13 (717) 249-7780 ID#65 I 84 C.E. SUNDAY & SON WELL DRILLING : IN THE COURT OF COMMON PLEAS OF A Partnership : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO. U)' 4';12, CIVIL vs. RICHWINE'S BUILDING AND HOME IMPROVEMENTS Defendant To: Lee Richwine, tdba Richwine's Building and Home Improvements, Defendant Dated: October 4, 2005 IMPORTANT NOTICE YOU ARE IN DEF AUL T 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 MAYBE 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 BAR ASSOCIATION 35 SOUTH BEDFORD STREET CARLISLE, P A 17013 717-249-3166 Susan J. H Attorney r R intiff 1 Irvine Row, Carlisle, PAl 7013 (717) 249-7780 .-> SA ~-:-.;:I +J... cJ1 (:J -I c: 0 -'\- ~ -5J (-, ~.~~ _-l ' :1;'" ~ , 0 C> C~' ~ 0 -.J ~ - ~ ;::::.. .c- O .s.- - '3 ..- - --s:> .- -4=. ::x::...- ,l[:- S> ~ -' - ~ ~ - (i2 f ~ ~.. C.E. SUNDAY & SON WELL DRILLING : IN THE COURT OF COMMON PLEAS OF A Partnership : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. : NO. 2005-4512 CIVIL RICHWINE'S BUILDING AND HOME IMPROVEMENTS Defendant PRAECIPE To the Prothonotary: Please mark the judgment on the above-captioned matter "Satisfied and Paid in Full" Thank you. Susan J. H man, squire Attorney for PI . tiff I Irvine Row, Carlisle, PAl 70 13 (717) 249-7780 ID#65 I 84 ;;7 " 2/1/ D 0 C) S ',} -~ '...-:.::> c;;:::. cr' ..,. 1"1 c;J I o ., .-~ I-n ri1~ TIt,:...: ~::J ~r' \',~C) ,(;~~\ ~:~ "'0 :< =? -'~ Ul -J