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Home My WebLink About06-0336 Christopher E. Rice, Esquire LD. Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiffs : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIANFICHI & SCHOLL ARCHITECTURAL ASSOCIATES, LLC, Plaintiff v. : NO. 2006 - 3 3 C. ~;J, Tv-- JAY BRANDT and KAREN BRANDT Defendants 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 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 Plaintiffs. You may lose money or property or other rights important to you. 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 REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 .' F.\f\LES\DAl AFILE\General\Currcnt\l1 106.4.com/mah Created: )]/05101 09:4953 AM Revised 01/13/0608:4747AM Christopher E. Rice, Esquire 1.0. Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiffs CIANFICHI & SCHOLL ARCHITECTURAL ASSOCIATES, LLC, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO.2006- J.,?,l, ~ 'T;....- JAY BRANDT and KAREN BRANDT Defendants COMPLAINT AND NOW, comes the Plaintiff, Cianfichi & Scholl Architectural Associates, LLC, by and through its attorneys, MARTS ON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: I. Plaintiff, Cianfichi & Scholl Architectural Associates, LLC, is a Pennsylvania limited liability company with a registered address of 1230 Holly Pike, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendants, Jay Brandt and Karen Brandt, are adult individuals residing at 44 Brandt Lane, Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff is in the business of providing, among other things, design services and goods to certain businesses and individuals, 4. Defendants entered into a written contract (the "Contract") with Plaintiff on January 8, 2004, for certain design services and goods as set forth in the Contract. A true and correct copy of the Contract is attached hereto as Exhibit "A" and incorporated herein by reference. S. Plaintiff has provided both design services and goods to Defendants and Defendants have failed to pay an amount still owed, being $10,990.36. A true and correct copy of Plaintiff s invoice is attached hereto as Exhibit "A." 6. Defendants have failed to pay for such design services and goods and therefore are liable to Plaintiff for the amounts owed plus interest and costs of suit. 7. Despite repeated demands, Defendants have not satisfied the amount due. 8. Defendant Jay Brandt has acknowledged the debt and made one partial payment, which has been credited to the amount due. COUNT I - BREACH OF CONTRACT 9. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 8 as if fully set forth. 10. Defendants have breached the Contract to pay for the design services and goods provided to Defendants from Plaintiff and/or Plaintiffs agents. WHEREFORE, Plaintiff demands judgment against Defendants in the total amount of $10,990.36, plus interest at 1.5% per month, costs, and any other relief this Court deems appropriate. COUNT II - QUANTUM MERUIT 11. Plaintiff hereby incorporates by reference the averments contained in paragraphs 1 through 10 as if fully set forth. 12. In the alternative, Defendants are liable to the Plaintiff and/or have been unjustly enriched in the amount of $10,990.36. WHEREFORE, Plaintiff demands judgment against Defendants in the total amount of $10,990.36, plus interest at 1.5% per month, costs, and any other relief this Court deems appropriate. MARTS ON DEARDORFF WILLIAMS & OTTO By Ck~f, 14.~~ Christopher E. Rice, Esquire 1.0. Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiff Dated: :;;,.) It, I 'U~~ In making this communication, we are advising you this firm is attempting to collect a debt. Any information gained from this communication will be used for that purpose. EXHIBIT A Roher! B. (-'iall/iell;. fiE bob lIcianficbischoJ/.com CIA~.FICHI SCHOLL Lam R. Selluli. Jrq .Hi lee {{ cianfichischotl.com /\JcllIleelllul ,'\"oC/dle, 1.1 C 12:lOHoJ/yPike.Carlisle.PA liOn Phone:717-258-1700 Fa,,:iJ7-960-0611 January 6, 2004 Mr. & Mrs. Jay Brandt 168 Rich/and Road Carlisle, PA 17013 RE: PROPOSAL / AGREEMENT FOR DESIGN SERVICES: Design and Construction Documents for Additions and Interior Renovations To Existing Residence 44 Brandt Lane Newville, PA 17241 C&SAA No. 03-132 Dear Jay and Karen: We propose to provide design services for the above referenced project. Per our understanding, you .are requesting services for the following: THE PROIECT Design of a one-story addition, two-story addition and interior renovation to the existing residence. The one-story addition will contain a two-car garage, Mud Room/Laundry, possible screened-in porch and new entrance. The two-story addition will allow for the expansion of the existing bedrooms and bathrooms. The existing balcony off the Second Floor into the Family Room shall be removed. The interior column shall be removed and replaced with a beam to support the second floor. The Family Room shall receive new finishes. The existing Kitchen shall be renovated. The existing living Room shall be converted into the Master Bedroom Suite. The unfinished space below the existing Kitchen & Living Room shall be finished into a Game Room. The existing stairway up to the first floor shall be relocated. The existing decks off the front of the house may be reduced in size or reconfigured. The exterior of the addition may be a combination of a simulated shake siding and stone. Mr. & Mrs. Jay Brandt Additions & Renovations to Existing Residence January 6, 2004 Page 2 SCOPE OF SERVICES We suggest that our services be provided as follows: PHASE ONE - SCHEMATIC DEVELOPMENT SERVICES Establish clients general project scope - programmatic; financial; time and conceptual design (aesthetic, relationship of components, scale and goals). This may include determining site-related limitations and requirements. Phase One services shall include time to produce and develop: . Client meetings as required (2 budgeted) . Field measure existing residence . Floor plans . Elevations . Perspectives and / or design sections . Client approved sketch submission PHASE TWO - CONSTRUCTION DOCUMENTS SERVICES After Phase One approval by the client, Phase Two shall further refine and describe the size and character of the project through the use of working drawings. The drawings will be developed to assist you in the selection of a contractor, during construction and to obtain Municipality building permits. (The quantity of detail(s) and drawings required and the possible involvement of other design consultants shall be verified during Phase One.) Phase Two services shall include time to produce, perform and develop: Client review meetings (2 scheduled) Written meeting minutes, memos and correspondence Floor Plans . Basement Floor (X" scale) . First Floor (J4" scale) . Second Floor ('4" scale) . Roof Plan (X" scale) Exterior Elevations (3 @ X" scale) Building sections (X" scale - thru major components) Construction Details (3/4" or 1" scale) Unique materials (identified on the drawings) Door & Window information (identified on the plans) Finish Schedule Kitchen Elevations Structural Engineering for: Foundation Plan Floor and Roof Framing plans Miscellaneous Details & Notes Mr. & Mrs, Jay Brandt Additions & Renovations to Existing Residence January 6, 2004 Page 3 SERVICES NOT INCLUDED The following services are not included in this proposal and shall be provided by the Contractor, Subcontractor and/or by Cianfichi & Scholl and billed to the client as additional services. . Specifications . Design of Electrical, HVAC, or Plumbing Systems with the exception of plumbing fixture locations shown on the Architectural drawings. . Construction Services (I.e., construction phase site visits, reviewing contractor's payment schedules, shop drawing review, etc.) . Site work plans (grading plans and contours) - Simple Plot plans can be included if desired, INCORPORATING INFORMATION provide by your civil engineer. Full site grading plans and contours shall not be considered part of the services provide in this agreement, No Survey work is included. . Municipal or state fees . Municipal meetings (variances, approvals, etc.) TIME A schedule has not been established. The following is milestones are suggested: Phase One: Sketch Review Meeting #1 Sketch Review Meeting #2 Final Acceptance Meeting january 16, 2004 january 25, 2004 january 30, 2004 February 6, 2004 February 20, 2004 March 5, 2004 March 12,2004 April 2004 September 2004 Phase Two: 35% Review Meeting 65% Review Meeting 90% Review Meeting Final Plan Review Start Construction Finish Construction FORMAT OF AGREEMENT This document, including Attachment "A" Standard Terms and Conditions and Attachment "B" Schedule of Rates, when signed, shall serve as the agreement. Mr. & Mrs. Jay Brandt Additions & Renovations to Existing Residence January 6, 2004 Page 4 COM PENSA TION Initially we will be contracted for Phase One on an hourly basis plus reimbursable costs as listed on the attached Schedule of Rates. The fee for this service is estimated below: Phase One: $ 2,860.00 Phase Two will commence after the scope of the project is clearly defined in Phase One. The fee for Phase Two will be established as either a "Fixed Fee" or a "Fee Not To Exceed" based on the final scope of the project. If the enclosed Phase Two estimated fee is acceptable upon completion of Phase One, design work for Phase Two can continue via this agreement and fees will continue to be invoiced as established herein. If an updated fee is required this Agreement shall be amended prior to commencement of Phase Two services. An estimated Phase Two fee based upon the scope described above is include: Phase Two: $ 4,040.00 Structural engineering services will be provided in Phase Two and are estimated to be: Structural Engineering: $ 1,000.00 Fee Summary: Phase One Phase Two Structural TOTAL $ 2,860.00 $ 4,040.00 $ 1,000.00 $ 7,900.00 PAYMENT An initial payment of $500.00 shall be made upon execution of this Agreement. Refer to Attachment "A", Standard Terms and Conditions, for additional payment information. This Agreement represents the entire understanding between you and Cianfichi & Scholl and may only be modified in writing, signed by both of us. Mr. & Mrs.Jay Brandt Additions & Renovations to Existing Residence January 6, 2004 Page 5 Thank you for your consideration of this Proposal/Agreement for Design Services, please indicate your understanding and acceptance by signing the enclosed copy of this Proposal! Agreement in the space provided below and returning same, Sincerely, ~ lee Scholl, AlA Registered Architect I /'$ J, '? I ' Date u~ If ~r?r Print Name r< ~ wv-..1-0 NfA,nclt Signature 1/ 8/ ~ Date v\6\e.n :5'. br{J..-ffi'\ Print Name CI.\\JF/( III SCll()1 L ATTACHMENT "A" STANDARD TERMS AND CONDITIONS These Standard Terms and Conditions are incorporated by reference into the foregoing agreement, or proposal (the "Agreement") between Cianfichi & Scholl Architectural Associates. LLC and its client 'Jay and Karen Brandt" for the performance of professional services ("Cianfichi & Scholl"), These Standard Terms and Conditions are fully binding upon Client just as if they were fully set forth in the body of the Agreement. 1. Period of Offer. Any proposal by Cianfichi & Scholl to provide professional services must be accepted within thirty (30) days of the date of proposal. This thirty (30) day period may only be extended by mutual written agreement of both Cianfichi & Scholl and Client. Cianfichi & Scholl shall have the option of canceling a Cianfichi & Scholl proposal at any time prior to the original or extended expiration date of the proposal. In the event a Client accepts a Cianfichi & Scholl proposal by executing and delivering either the signed original or copy to Cianfichi & Scholl, the signed Cianfichi & Scholl proposal and the attachments expressly incorporated therein by reference shall constitute the entire agreement between the parties ("Agreement"). The Proposal and these terms and conditions shall also hold even if the Client has not returned an executed copy but has indicated that he expects Cianfichi & Scholl to begin work, and receives work from Cianfichi & Scholl performed in accordance with this Proposal. 2. Additional Services. In addition to those additional services referenced in the Agreement, Cianfichi & Scholl will provide any of the following services, if requested, in accordance with Item S, Fees and Compensation, including, monitoring of construction, design of corrective measures required by Contractor error or unforeseen or unexpected field conditions, services resulting from changes in the extent of the project or required documentation, performance of any portion of the Scope of Services due to changes in codes, standards or government agency requirements, etc. which take effect after the work has begun, and preparing to serve or serving as a consultant or witness in any legal or administrative proceeding or public hearing. 3. Clients Oral Decisions. Client, or any individual or agent having apparent authority from Client, may orally: (a) make decisions relating to Cianfichi & Scholl Services or the Agreement; (b) request a change in the scope of Clanflchi & Scholl Service under the Agreement; or (c) request the performance by Cianfichi & Scholl of additional services under the Agreement. Client may from time to time and at any time limit the authority of any or all persons to act orally on Client's behalf under this Item 3, by giving seven (7) days' advance written notice to Cianfichi & Scholl. 4. Proprietary Rights. Client acknowledges that Cianfichi has proprietary rights in all work produced for Client, and that documents representing such work product, including drawings, specifications, and reports, shall not be furnished to third persons unless written authorization is first obtained from Cianfichi & Scholl or unless by clear implication from the circumstances such work product was intended by Client and Cianflchi & Scholl to be furnished to third persons. S. Fees and Compensation. In the event the Client requests Cianfichi & Scholl to perform services not specifically described in the Agreement, Client agrees to compensate Cianfichi & Scholl for such services in accordance with the hourly rate schedule set forth as Attachment B of this Agreement, or in accordance with a mutually agreed to lump sum price. Hourly rates are subject to annual revision at the discretion of Cianfichi & Scholl. Items of additional service shall be authorized in writing by the Client. Where oral authorization to perform additional services is given by Client (see Item 3), Client agrees to compensate Cianfichi & Scholl for all services provided. Written confirmation of oral authorization and terms of compensation shall be provided to Client bV Cianfichi & Scholl. 6. Sub-Consultant and Contractor Services. Should sub-consultant. laboratory testing, or contractor services be required, their fees plus expenses shall be reimbursable to Cianfichi & Scholl (see Item 8). 7. Construction Costs. Construction costs are defined as the total actual cost or estimated cost to Client of all elements of the project designed or specified by Cianfichi & Scholl excluding Cianfichi & Scholl fees. Cianfichi & Scholl assumes no responsibility for any project or construction costs estimates or opinions given to Client as Cianfichi & Scholl has no control over the cost of labor, materials, equipment, or services furnished by others, or over competitive bidding or market conditions. Attachment A - Standard Terms and Conditions Jay & Karen Brandt - Addition & Renovations to Residence January 6, 2004 Page 2 of 3 8. Reimbursable Expenses. Client shall reimburse Cianfichi & Scholl for all expenses necessarily or reasonably incurred by Cianfichi & Scholl in connection with the performance of professional services for Client. Such expenses include, but are not limited to, the following: transportation expenses, meals and lodging in connection with travel, long-distance telephone charges; extraordinary / computer expenses; photographiC expenses; filing and inspection fees paid by Cianfichi & Scholl on behalf of Client; delivery, shipping and courier expenses; drawings and document reproduction or copying expenses; and other out-of. pocket expenses incidental to performance of Cianfichi & Scholl's services. Cianfichi & Scholl may submit invoices for reimbursable expenses separately from invoices for services. 9. Payment Terms. Cianfichi & Scholl may submit monthly invoices to Client for Cianfichi & Scholl Services and for reimbursable expenses incurred. Invoices are payable upon receipt, and Client agrees to pay a finance charge of one and one-half percent (1.5%) per month on any unpaid balance not received by Cianfichi & Scholl within thirty (30) days of the Invoice date. Invoices may be based either upon Cianfichi & Scholl's estimate of the proportion of the total services actually completed at the time of billing for lump sum or fixed fee contracts, or in the case of an hourly contract, upon actual services completed. In the event any invoice is not paid within thirty (30) days of the invoice date, Cianfichi & Scholl shall have the right either to suspend the performance of further Cianfichi & Scholl Services until all invoices to Client under this or any other agreement more than thirty (30) days past due are fully paid, or to terminate the Agreement and to initiate proceedings to recover amounts owed by Client. Additionally, Cianfichi & Scholl shall have the right to withhold from Client any drawings or documents prepared by Cianfichi & Scholl for Client under this or any other agreement With Client until all delinquent invoices are paid in full. Client shall not set off payments of Cianfichi & Scholl invoices by any amounts due, or claimed to be due, from Cianfichi & Scholl to Client. Client agrees to hold Cianfichi harmless for any and all damages incurred by such suspension of the work. Client agrees to pay all costs and legal fees associated with the collection of past due accounts. 10. Termination. In the even of termination by Client, Client agrees to give Clanfichi & Scholl notice in writing of such intent ten (10) working days prior to termination date. In the even of term ination by Client or by Cianfichi & Scholl, Client shall immediately pay for all services rendered through termination date, reimbursable expenses and all other expenses incurred in the name of Client, including fees and expenses incurred by Clanfichi & Scholl as a result of the termination. 11. Hazardous or Toxic Waste or Substances, Pollution or Contamination. Cianfichi & Scholl shall have no responsibility for searching for or identifying any hazardous or toxic waste or substances or pollution or contamination due to the presence of hazardous or toxic wastes or substances. 12. Severability. If any part, term, or provision of this agreement is held to be illegal or unenforceable, the validity and enforceability of the remaining parts, terms, and provisions of this agreement shall not be affected, and the rights of Cianfichi & Scholl and Client shall be construed and enforced as if the agreement did not contain the illegal or unenforceable part term or provision. 13. Limitations on Liability. The liability of Cianfichi & Scholl for any loss, property damage or bodily injury of or to Client caused in whole or in part by an error or omission of Cianfichi & Scholl, or any of the partners, employees, agents, or subcontractors of Cianfrchi & Scholl, in the performance of this Agreement, as this agreement may from time to time be amended, or in the performance of any supplementary services in any way related to this Agreement, shall be limited to the amount of fees theretofore paid by Client to Cianfichi & Scholl for such services, except for any intentional acts or gross negligence on behalf of Cianfichi lit Scholl. Client releases, waives and shall not seek contribution from or indemnification by Cianfichi & Scholl for any claims of any nature made against Client by any other person who may suffer any loss, property damage or bodily injury in any manner associated With the services rendered by Cianfichi & Scholl, and by its partners. employees, agents and subcontractors under this Agreement, as this Agreement may from time to time be amended or any supplementary services in any way related to this Agreement, except for any intentional acts or gross negligence on behalf of Cianfichi & Scholl. Cianfichi &. Scholl shall not be liable to Client, in any event or for any amounts for delays or for consequential, speCial or inCidental damages, Attachment A - Standard Terms and Conditions Jay & Karen Brandt - Addition & Renovations to Residence January 6, 2004 Page 3 of 3 14. Indemnification. Client shall indemnify and hold Cianfichi & Scholl harmless from and against any and all liability, claims and demands for losses, property damage and bodily injury arising out of work undertaken on the project to which this Agreement relates by Client, or Client's contractor, subcontractor or other independent company or consultant employed by Client to work on this project, or their respective officers, directors, partners, employees, agents or assigns; or arising out of any other operation, no matter by whom performed, for and on behalf of Client, or such contractor, subcontractor or other independent company or consultant, except for any intentional acts or gross negligence on behalf of Cianfichi & Scholl. I S. Integration Clause. The Agreement represents the entire agreement of the parties. No prior representations, statements, or inducements made by either Cianfichi & Scholl, Client, or their respective agent. that is not contained in the Agreement shall enlarge, modify, alter, or otherwise vary the written terms of the Agreement unless they are made in writing and made a part of the Agreement by attachment incorporated by reference in the Agreement or signed or initialed on behalf of both parties. 16. Existing Facilities. When existing facilities are involved in the work, and inasmuch as the evaluation, alteration, rehabilitation or improvements to an existing facility requires that certain assumptions be made regarding existing conditions, and because some of these assumptions cannot be verified without expending large sums of additional money, or destroying otherwise adequate or serviceable portions of the facility, Cianfichi & Scholl shall not be responsible for any claims or damages directly or indirectly resulting from errors or defects that could not be determined by investigations specified for this project. CI.\~FI('III SCIIOLL ATTACHMENT "8" SCHEDULE OF RATES Jay & Karen Brandt, Addition and Renovations to Residence January 1,2004 Through December 31,2004 Architect (Principal)...............................................,.................................$105.00/ hour Architect (Project) ..................,..................................................................$90.00 / hour Intern Architect .......,.................. ............................................................... $65.00 / hour Drafting (CAD) ..........................................................................................$50.00/ hour Administrative / Secretarial......................................................................$40.00/ hour These rates are subject to change; however, we will notify you at least 30 days in advance of invoicing you for services at new rates. Copies Size 8-1/2 X 11 11 X 17 Cost $ 0.1 0 $ 0.20 $ 1.00 $ 1.50 $ 2.00 $ 6.00 $ 9,00 $ 12.00 $ 18.00 As Used As Used $ 1.00 $ o .3S As Used Black Line Prints 18 X 24 24 X 36 30 X 42 Plotting - Black & White (Bond) 24 X 36 30 X 42 Plotting - Color (Bond) 24 X 36 30 X 42 AlA Documents Photographic Expenses FAX Per Sheet Travel Per Mile Meals and Lodging (associated with Travel) Postage, Delivery, Shipping and Courier Services As Used Telephone (Long Distance) As Used Permits, Filing and/or inspection fees - Paid by Cianfichi & Scholl on behalf of client As Used EXHIBIT B " CI\"H( II. S( 1101 I. 1,;;13ntlcnr & ::>cnO/l ArCnrteCtUral Associates, LLC 1230 Holly Pike Carlisle, PA 17013 Statement Date 1/4/2006 To: JAY & KAREN BRANDT 44 BRANDT LANE NEWVILLE, PA 17241 Terms Amount Due Due on receipt $10,990,36 Date Transaction Amount Balance 12/30/2004 03/16/2005 07/20/2005 08/24/2005 09/19/2005 1 0/2112005 01/04/2006 , Balance forward i INV #FC 28 . Finance Charge PMT #16629. INV. 1963 PARTIAL PAYMENT INV #FC 29 - Finance Charge INV #FC 55 . Finance Charge INV #FC 84 - Finance Charge : INV #FC 88 - Finance Charge 1,050.27 -1,000.00 479.77 77.47 95.36 223.49 10,064.00 11,114.27 10,114.27 10,594.04 10,671,51 10,766.87 10,990.36 Amount Due $10,990.36 Please Remit THANK YOU! , , VERIFICATION I, Lee Scholl ofCianfichi & Scholl Architectural Associates, LLC, acknowledge I have the authority to execute this Verification on behalf ofCianfichi & Scholl Architectural Associates, LLC, and certity the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent the Complaint is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent the content of the Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. CIANFICHI & SCHOLL ARCHITECTURAL ASSOCIATES, LLC at/li1/ Lee Scholl l"",) ;-6 (..~ ~ c'- ~o P Q 0J ..... J'i -:, v... "'" .J:) .,. I,': ,s, "" ....c. \' LA. , LA ""'~ , (/, 0 SHERIFF'S RETURN - REGULAR ~ CASE NO: 2006-00336 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CIANFICHI & SCHOLL ARCHITECT VS BRANDT JAY ET AL DOUGLAS RUZANSKI Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BRANDT JAY the DEFENDANT , at 1445:00 HOURS, on the 24th day of January 2006 at 44 BRANDT LANE NEWVILLE, PA 17241 by handing to KAREN BRANDT, ADULT IN CHARGE 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 14.96 .39 10.00 .00 43.35 -? r;;./:7 ,.// ~ r ~~;-"'&d'~ -1'~ R. Thomas Kline 01/25/2006 MDW&O Sworn and Subscribed to before me this SOih Y;{r~~AD ( Prot, otary By: /,I day of \ SHERIFF'S RETURN - REGULAR CASE NO: 2006-00336 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CIANFICHI & SCHOLL ARCHITECT VS BRANDT JAY ET AL DOUGLAS RUZANSKI Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BRANDT KAREN was served upon the DEFENDANT , at 1445:00 HOURS, on the 24th day of January 2006 at 44 BRANDT LANE NEWVILLE, PA 17241 KAREN BRANDT by handing to 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 Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 me this Sworn and Subscribed to before I [,J A ;)C()& day of A.D. So Answers: ~. .Y /~;'/. -r-"'-%-.;?"/.:,,~cc 'l ~J R. Thomas Kline 01/25/2006 MDW&O /} , By: /j /'~"I' //{. t ,.:// Deputy( Sheri ( F:\FILES\DATAFILE\Gencral\Current\lI 106.4.praecipelmah Created: 11/0510109:49:53 AM Revi$ed: 05124/0612:09:13 PM Christopher E. Rice, Esquire 1.0. Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIANFICHI & SCHOLL ARCHITECTURAL ASSOCIATES, LLC, Plaintiff v. NO. 2006 - 336 CIVIL TERM JAY BRANDT and KAREN BRANDT Defendants PRAECIPE To the Prothonotary: Please mark the above captioned matter settled and discontinued. MARTS ON DEARDORFF WILLIAMS & OTTO By C-.e~ 5 K Christopher E, Rice, Esquire 1.D. Number 90916 MARTS ON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiff Dated: May Z'J ' 2006 0 ,..., 0 = ~~ c~ ., "" , ::;: =? ~:~'" n~ -r; -<: -;F.; N -~r U; ., T ':::JC' "'" .:-,~ :2..,' :::r&: ;;?(:s 9 '. 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