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Home My WebLink About06-0344 'MONWEAl TH OF PENNSYLVANIA (' COURT OF CO~ON PLEAS '(i.JA-'l7..j Ct-:- c'(j/r}(3~K{.fI JUDICIAL DISTRICT u-., NOTICE OF APPEAL FROM DISTRICT JUSTICIE JUDGMENT COMMON PLEAS No. Ole - ~ I./Lf C c..>~L ~ E..ti-Yl i Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the jUdrment rendered by the Dis- trict Justice on the date and in the case mentioned below. I NOTICE OF APPEAL CLAIM NO. LT YEAR This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No.1 008B. This notice of Appeal, when received by the District Justice. will operate as A SUPERSEDEAS to the Judgment for possession in this case. I appellant II< s Clai ant (see PA R.C.P.J.P. No. 1001(6)) in acti belore district Justice, he MUST FILE A CO LAtNT wilhin twenty (20) days alter liling his OnCE 01 APPEAL. ::>tgnalUre Oll-'romonorary Of uepuly PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO F LE (This section of form to be used ONLY when appellant was DEFENDANT (see PA R.C.P..J.P. No. 1001 (7) in action efore District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To prothonoJ"J, . Enterruleupon ctiL(, 5/~ CH~E Name of appel/ee(s) (Common Pleas No.(')/.,-_ ~lJ~:,,~ within twenty (20) days after service of rule 0 RULE: To II; l{j/ ~F C4~ ,appellee(s) Name of appel/ee(s) _' appellee(s), to file a complaint in this appeal (1) You are notified that a rule is hereby entered upon you to file a compiaint in this appeal wthin twenty(20) days after the date of service of this rule upon you by personal service or by certified or registe ed mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS Will BE E TERED AGAINST YOU UPON PRAECIPE. (3) The date of service of this rule if service was by mail is the date of the mailing. Date~d.2l J P , Year ;)?Y')~ White Green Yellow Pink Gold Prothonotary Copy Court File Copy Appelant's Copy Appellee Copy D. J" Copy Proth. - 76 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This prool 01 service MUST BE FILED WITHIN TEN (lO) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; 55 AFFIDAVIT: I hereby swear or aflirm that I served o a copy of the Notice of Appeal, Common Pleas No. t upon the District Justice designated therein on (date of service) , year __' Dby personal service Dby (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name .._' on __,___.____~_, year ___' 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto. D and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appeUee(s) to whom the Rule was addressed on , year _.._' D by personal service Dby (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ~, YEAR __" Signature of official before whom affidavit was made Title of official My commission expires on ,year __" X::JD t-t ~ 6"- -... "- "-J U ..() --0 ---0 Signature 01 Affiant -<Q ~ ~ t--> = c:::< '.::,..-.. o C' ~~;,~; ::::' '- :;..:;. rri ill ~ r- ~ -f-- -.:z:- ~;: C') -, - "'~"'~C"'._""c~~~___,__~___."". "'j .-'l ..11, Ll1 ~! ~ m\ ITl ITl ITl lr lr .-'l , r-1 ITl ", r",", ITl 0 \::1 0 D D 0 D 0 ITl ITl Ll1 , j Ll1 .-'l .-'l \ D "~ ; "~ ~ CJ 0 <, 1 0 <. D 0 f'- , " '.-'.. f'- l.hL . ~ i ~ ~ I' I l'", Yr:,'c;'1~;__'::'~~i[~~~ , &'Tfj~~~~,lIl cJl OJ, .,.r, " 10, ~ ".. ,0, " l' s I &.1_ : ~d~) --..... ..._.._-----~.-'-"--- ---. !, f ( :,~oi'o(~blc Qa.tJkt(brecl1JI ')1' ,r ,-<, '\1.< ~(), ......" ,_ I , " CJLll +nC'l)S( '::)9-.UQf<: , \ ... 1\ '::" " I i';: f;;l;;i~:1~<~F'm~~~~ PROUI' Ul- ::>t:.Rlllt;f.: OF NOTICE OF APPEAL "NO RULE TO FILE COMPLAINT (This prcot 01 service MIJST fiE "'.cD 'N'THiI' H, (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF F'ENNSYLV,"II,' !'\ .., COUNTY OF ..J..)6J~~'hi_(L ____;55 AFFIDAVIT: I hereby swear or aft "r, 'hat i se""",, Ja copy 01 the Notice of Appei!l, ',:(lr''1mOn Pleas i"O _t!_I4'" 3,.," l i"~---.ll1_, upon the District Justice designated therein on JJq (date ot service) ~ g(\L~1"1l ,y'ar a~~(p. ' Oby Pfr: service ~ (certified) (registered) mail, sender's ~ejpt attached hereto, and Jpfn the appc-'!IIHe !12nle 4-, S,~ ~tJ '" ,on ~0ll4L~ -~A/- . Ie, ..~~, [] by personal servlceJa'b'y (certified) (registered) mail, sender'S receipt attached hereto. ~nd further that f seNed the Ruro to FiIE~. a. Co~nt accom. panying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed ("1 ~ ~_~_, _ __, year ~ OOln, 0 by personal service >>y (certified) (registered) mail, sender's receipt attached hmelo, SWORN (Ar-FIRMED) AND SUBSeRiBE[ EEFOf'E ME 'HIS d 4'!'h:_ DAYO~R"~~~"" ..., . ~d..-LL< ') ___ _ _ _, _ nature of offiCial tH>/CrP whom alfidavir was made ~a.~ My commission e~p~~~~?~_,__... \KY;AFli/\L,~;!~i\ _' year ____,____",..,' t,i'J',j(:: fl,:'--" n,\~ !-j'~i ;'i'J ("', .. ~ '''';', ;:-) 'i1 1"",' (.:.,. -',-1 .,) , , -.~ "'< COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM DISTRICT JUSTICE JUDGMENT JUDICIAL DISTRICT COMMON PLEAS No. " '- NOTICE OF APPEAL J , Notice is given Ihallhe appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Dis- trict Justice on the date and in the case mentioned below. NAME OF APPELLANT MAG. 015T. NO. OR NAME OF D.J. ADDRESS OF APPELLANT CITY STATE ZiP CODe . .' "" DATE OF JUDGMENT IN T,I'U,.I1ASE OF rPLAINTlFrJ (DEFENDANT) / ,. " , I , ..- . ~ ., '( J. / . , . VS" i . " CtAIM NO. SIGNATURE OF APPELLANT OR HIS ATTORNEY OR AGENT CV YEAR I L T YEAR i ( I This block will be signed ONLY when this notation is required under PA. .' R.C.P.J.P. No. 1008B. If appellant was Claimant (see PA R.CPJ.P. This notice of Appeal. when received by the District Juslice, will operale as No. t001(6)) in action belore dislrict Justice. he A SUPERSEDEAS to the Judgment for possession in this case. MUST FILE A COMPLAINT within Iwenty (20) days after filing his NOTICE of APPEAL ::>/fInafure 01 f-'romonorary or uepucy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see PA R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be selVed upon appellee. PRAECIPE: To Prothonotary Enter rule upon " . appellee(s), to tiie a complaint in this appeal Name of appel/ee(s) (Common Pleas No.: ", ) within twenty (20) days aller service 01 rule or suller entry ot judgment of nOHpros. SignarJire of appellant or'fu~ attorney p(~ent; RULE: To / , appellee(s) Name of appeffee(s) (1) You are notified that a rule is hereby entered upon you to file a compiaint in this appeal within twenty(20) days aller the date 01 service of this rule upon you by personal service or by certified or registered mail. (2) It you do nol file a complaint within fhis time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECIPE. (3) The date of service of this ruie if service was by mail is the date of the mailing. Date:'....., i I 'I , Year $ignature of F;'fathamtary or,Dwufy, Whne Green Yellow Pink Gold Prothonotary Copy Court File Copy Appelant's Copy Appellee Copy D. J. Copy Proth. - 76 '-""'~~'~--~'-~.',"""'-~"".'-"~""""""~"''';'''''''-;~-"~-_........ NOTICE OF JUDG~ENT/TRANSCRIPT PLAINTIFF/JUDGME~YJJ,.O~ SE fiILLSIDB CUB NAME and ADDRESS ..., 5S9 SALD IilOAD BTTERS, PA 17319 L .~ . COMMONWEALTH OF PENNSYLVANIA COUNTY OF: ctJID.lmLA1IP Mag. [)is\. No.: 09-2-01 MDJ Name: lion. PAULA P. CO~.L Add".." 1 COURTHOUSB S<l! CARLISLB, PA " DEFENpANT/JUDGMENT c~ ,!jOI'J!'JlAB JlBCIWU 625 lDIIILTOR S CARLISLE, PA.170 L Docket No.: CV-OOOO'" Date Filed: 11/29/0 CROSS COMPLAINT ..... .T~~i'tl'7T'nc)~6564: ,.. '. . 17013~.OOOO. BOI'PIIAR IlBCBAIfICAL, IDC. 625 BAIlJ:LTOR STREBT CARLISLB, PA 17013 ~ THIS IS TO NOTIFY YOU THAT: Judgment: ..,. . . [i] Judgment was entered for: (Name) [i] Judgment was entered against: (Name) --"," ~_.- . in the amount of $ (Date of Judgment) 1 'rAil; nn on: o Defendants are jointly and severally liable. o Darnageswillbeassessed on:>: D This case dismissed withe'~t prejudice. D Amount of Judgment Subject to Attachment/42 Pa,C.S. ~ :3127 $ o Portion of Judgment for physical damages arising out of residential lease $ (Date & Time) ~.< . Amount of Judg Judgment Costs .Interest on Judg Attoml!Y Fees Total Post Judgment Credits Post Judgment C sts Certified Judgm nt Total $ ..., ~ .. - ;. Inr; . $ 1.786.00 $ .00 $ .00 $ .00 $ 1.786.00 $ $ -------- ------- Arw..!'NlJY H.,A!l, TtlE Fl[GHTTO ~PI>E)\L ~IT.H..!!!.3p ~!,YS~~,,=, THE .!'~Tfl.YpF.JlJEG~EN.T BY fll:! ~_A N<?!1CE ... _. _.. OF APPEAL WITH THE PROTHONOTAI~YICLERK OF THE COURT OF COMIIIION PLEAS, CIVIL DIVISION. OU MUST INCLUPE A COPY OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NonCE OF A PEAL EXCEPT AS OTHERWISE PROVIDE['IN THE RULES OF CIVIL PROCEPURE FOR IIIIAGISTERIAL D1STRI JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENrER THE JUPGMENT IN THE COURT OF COMMON PLEAS, ALL FU ER PFIOCESS MUST COME FROM THE COURT OF COMMOI~ PLEAS AND NO FURTHER PROCESS MAY BE ISSUEP BY THE M GISTERI,~L PISTRICT JUDGE, UNLESS THE JUPGMENT IS ENTERI:D IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN HE JUOOMENT MAY FILE A REQUEST FOR ENTRY OF SATISFAC;T10N WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGME DEBTOR PAYS IN FULL, SETTl.ES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ~Date4;5~~-~~-e ,Magisteri I District Judge I certify that this is a true and cl)rrect copy..o. f the record of th.6 proceedings containing th judgment. .' -' , . . , " . . Date , Magisteri I District'Judge My commission expires first Me.nday of January, 2006 . EAL AOPC 315-05 12/21/05 11:10:"'9 AM " " ~-----_.. _I..... a'.... .......... .......... ...._".. DATB PlUlI'1"lm: - __I HOFFMAN MECHANICAL, INC., Plaintiff v. HILLSIDE CAFE, Defendant SENPER COMPLETE THIS SECTION . Complete items 1,2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1-h~~~~e~~o\?l~ Pa.LlIa. CD({(a. I 011.<" ('6Ur-tf10c&" SDUQ(( ton;sll",9A 1"1613 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (j., CASE NO. ~-344 Civil Term . . . . . '-AfJU..1..o.tj o Agent o Addressee B. Received by (Printed Na~ ~elC( J [OI..L1er D" C. Date of Delivery / -;';if'-b/c Is delivery address diff,rent,ffom item ,jl~. 0 . Yes If YES, enter delivery Lddr~ss b..e~;;, :0 No \ <2'3.. 'b:? 3. .S~ce Type .-10 Certified Mail o Aegistered o Insured Mail o Express Mall -'f1"'Return Receipt for MerchandL ,- o C,OD" 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Art\c\e Number I J/"l (Tnlnsfer fmm service label) '16tD IS2[) 6CD3 3/9.3 3~/ PS Form 3811, August 2001 Oomestic Return Receipt 102595-02-M ,C,.j Complete items 1,2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: .-I-ll\S;~ ('-L 5~q Sa.lL<<l (<a1.d. [+tUS; PA 1''13/1 ~ L4- 3. ,Srice Type A Certified Mail 0 Express Mail o Registered X1 Return Receipt for Merchandise o Insured Mail /" d C.O.D. 4. Restricted Delivery? (Extra Fee) o Yes 2 _ Article Number (Transfer from service label) "1 C:;06 1S;36 {)063 3/93 3-4& ~ 102595.Q2.M.1540 Domestic Re\urn Receipt PS Form 3811, August 2001 6~\ ~ "'" d"' <- ~ c..: c () ~-n ,...\ ::C :-11 (') c: :So "'O~'P ~-':.y\ zC~, t.J;"'-. 00.1' . 1.::.;::'. )?C) .~() 'YC:. ;~ ~ ','j -< ~ - '- C \-. Nicholas Law Offices, PC Steve C. Nicholas, Esquire Pa. Supreme Court 10 #06845 2215 Forest Hills Drive, Suite 37 Harrisburg,PA 17112-1099 (71 7) 540-7746 - phone (717) 541-1527 - fax steve _nicholas@comcast.net Attorney for Plaintiff 589 SALEM ROAD, INC., a Pennsylvania Business Corporation t/d/b/a HILLSIDE CAFE STEAKHOUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-344 Civil Term HOFFMAN MECHANICAL, INC., a Pennsylvania Business Corporation, Defendant CIVIL ACTION - LAW 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 or relief requested by the Plaintiff. You may 10se 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 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 (800)990-9108 NOTICIA Le han demandado a Usted en la corte. Si Usted quiere defenderse de estas demandas expuestas en las paginas siguientes, Usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su personal. Sea avisado que si U sted no se defiende, la corte tomara medidas y puede entrar una orden contra Usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para Usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 (800)990-9108 NICHOLAS LAW OFFICES, P.c. By: ~ (N,'~ Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, P A 17112-1099 (717)540-7746 Attorney for Plainti 1'1' Nicholas Law Offices, PC Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 (717) 540,7746 - phone (717) 541-1527 - fax steve _ nicholas@comcast.net Attorney for Plaintiff 589 SALEM ROAD, INC., a Pennsylvania Business Corporation t/d/b/a HILLSIDE CAFE STEAKHODSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-344 Civil Term HOFFMAN MECHANICAL, INe., a Pennsylvania Business Corporation, Defendant CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiff, 589 Salem Road, Inc., t/d/b/a Hillside Cafe Steakhouse, by and through its attorneys, Nicholas Law Offices, P.C., and files this Complaint against Defendant, Hoffman Mechanical, Inc., and in support thereof avers the following: 1. Plaintiff, 589 Salem Road, Inc., is a Pennsylvania business corporation, trading and doing business as Hillside Cafe Steakhouse at 589 Salem Road, Etters, York County, Pennsylvania 17319-9548. George K. Sgagias is the principal officer of 589 Salem Road, Inc. 2. Defendant, Hoffman Mechanical, Inc., is a Pennsylvania business corporation with a principal place of business located at 625 Hamilton Street, Carlisle, Cumberland County, Pennsylvania 17013-1925. 3. On or about March 17, 2004, Plaintiff telephoned Defendant and requested service at its restaurant business premises to inspect and repair a deep freezer unit that was not holding its cold temperature required to keep foods frozen. 4. Frozen foods were stored in this freezer and it was located in an area immediately accessible to the kitchen staff. Other freezers were located in more inconvenient locations in the restaurant premises. 5. During the initial call for service, Plaintiff advised Defendant that it was not an emergency situation since all food products stored in the deep freezer had been moved to other freezers on the premises for continued storage. Defendant advised Plaintiff that a technician could be dispatched that same day. 6. Defendant's repair technician arrived at the premises on the same day as the call was placed and, after inspecting and working on the deep freezer unit, advised Plaintiff that the unit was leaking coolant fluid and the cause was a compressor coil which needed to be replaced but the part was not immediately available and would have to be ordered. 7. The Plaintiff requested that he be provided with an estimate for the cost of the part explaining that the freezer was an older unit and it may be more economical to replace rather than repair it. 8. The following day, Plaintiff was advised it would be about 4 days before the part would be received from the manufacturer/distributor and installed. Plaintiff was further advised that the cost ofthe part would be "several hundred dollars." 9. Defendant's repair technician returned 8 to 10 days later and replaced the coil he said was malfunctioning, added coolant to the system; and reported to the Plaintiff that the freezer was now working, and left the premises. 10. The Defendant's repair technician took the original part with him when he departed rather than leave it with the plaintiff as is customary in the business trade. 11. Near the close of business that evemng, In reliance upon Defendant's employee/agent's assurances that the freezer was repaired and working, and upon determining that the freezer temperature was lowering, Plaintiffs employees reloaded the deep freezer with frozen foods. 12. The following morning, Plaintiffs employees discovered that the freezer was again malfunctioning and the frozen foods placed in the freezer had thawed. Due to health concerns in preparing frozen foods that were thawed, the Plaintiff determined that the thawed food products could not be served to customers without a health risk, so he disposed of those thawed foods. 13. The cost of the food disposed of totaled $1,786.00. 14. The Plaintiff called the Defendant to speak with the employer, who never returned the Plaintiffs call. 15. The Plaintiff thereafter called and spoke with the Defendant's technician and reported that the freezer was not working. The Plaintiff also asked that the original part be returned to the Plaintiff. 16. Defendant's technician returned to the restaurant premises during business hours and again examined and worked on the freezer. The Defendant's technician left complaining the area was too crowded with Plaintiffs employees and he could not work on the freezer properly. The original replaced part was not returned. 17. Defendant's technician returned early the following morning and again worked on the freezer. After a period of time, Defendant's technician announced it was finally repaired and could be used as it was intended as a freezer. 18. Plaintiff placed a few frozen foods in the freezer to see if the system was, in deed, working. After several hours, the freezer was not working and the temperature was rising. 19. The Plaintiff, still unable to reach and speak with the technician's employer, called and again spoke with the Defendant's technician. 20. Plaintiff was advised by Defendant's repair technician to the effect that "if you really need this unit up and running, you better call another company. Do not call me or this company." 21. Plaintiffreminded the Defendant's technician that he agreed to return the original part to the Plaintiff. Defendant's technician agin agreed to return the part but has never done so. 22. Plaintiff proceeded to call another service company who immediately came to the premises and properly repaired the deep freezer unit. 23. Plaintiff was advised by the second service company that after examination of the freezer, the part replaced was not malfunctioning and that the system was overloaded with coolant fluid that caused it to continue to malfunction. 24. Defendant failed to repalf Plaintiffs deep freezer unit In a proper and workmanlike manner in accordance with acceptable standards in the trade. 25. As a result of Defendant's negligence, Plaintiff suffered a loss of food products in the amount of $1,786.00. WHEREFORE, Plaintiff respectfully demands judgment in its favor in the amount of $1,786.00, plus interest and costs of suit and that this honorable Court grant any other such relief as it deems appropriate. The amount at issue is less than $35,000.00, exclusive of interest and costs, and per Cumberland County Rule of Court No. 1301-1, should be submitted for hearing and award to a designated Board of Arbitrators consisting of three members of the Bar of Cumberland County. Respectfully submitted, NICHOLAS LAW OFFICES, P.C. By: ~ (N;~ Steve C. Nicholas, Esquire Pa. Supreme Court ill #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PA 17112-1099 (717)540-7746 Attorney for Plaintiff Dated: February 9,2006 . VERIFICATION I George K. Sgagias, President of 589 Salem Road, Inc., verify that the statements made in foregoing Complaint are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 589 SALEM ROAD, INC. Dated: February 9, 2006 ~ B - " y: C~~7/ ,"I _: George K. Sgagias, re:lent 589 SALEM ROAD, INC., a Pennsylvania Business Corporation t/d/b/a HILLSIDE CAFE STEAKHOUSE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. HOFFMAN MECHANICAL, INC., a Pennsylvania Business Corporation, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Steve C. Nicholas, Esquire, do hereby certify that on this, the 10th day of February, 2006, I served a true and correct copy of the foregoing Complaint by sending the same by certified mail, return receipt requested, addressed to the party or attorney ofrecord, as follows: Kelly M. Knight, Esquire Cunningham & Chernicoff, PC PO Box 60457 Harrisburg, PA 17106-0457 NICHOLAS LAW OFFICES, P.c. By: P-:-("'A!. d Steve C. Nicholas, Esquire Pa. Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, P A 17112-1099 (717)540-7746 Attorney for Plaintiff C) ~, \~;:~ (-) ';;-n .... ':.!: -r\ c.l1 :~.,:=- __;"1 ..,., rq W co ::':"'''' 1.-0 ",;1 f'-' 589 SALEM ROAD, INC., a Pennsylvania Business Corporation tJd/b/a HilLSIDE CAFE STEAKHODSE, Plaintiff v. HOFFMAN MECHANICAL, INC., a Pennsylvania Business Corporation, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-344 Civil Term CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT To the Prothonotary: On behalf of Plaintiff and Defendant, please mark the above-captioned case as settled, satisfied and withdrawn. NICHOLAS LAW OFFICES, PC By: if;;;< CAi,' ~ Steve C. Nicholas, Esquire P A Supreme Court ID #06845 2215 Forest Hills Drive, Suite 37 Harrisburg, PAl 7112-1 099 Attorney for Plaintiff Dated: AtM / 2 ~ Zf)O' Attorney for Defendant Dated: ffJ ~! !li1% (") ~ ~ c::: <:::::> -,....... 0" ~) ~>... .:J: :t! CCi fT. r-;- , :.0.. m::tJ '-:;,.. -< - r- ":::::."" /'\u '"01"T1 (/'1 =no ." 0") /_;; (~) ;--.:' ~~ h 'T, oO ::5 '-ri ~. (') "S' C -tQ '.:;1-<> ..<-- rn r'" c::9 0 '-.- -?" 5;! ~::j a .""( ::0 \,Q -<