HomeMy WebLinkAbout06-53691 t
Scott Harper, Esq.
1701 W. Market St.
York, PA 17404
717-718-8672 phone
717-718-1634 fax
sharperlawftmac.com
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BRENDA NEWMAN,
PLAINTIFF
V. No.
RLH CONTRACTORS LLC,
DEFENDANT
CIVIL ACTION COMPLAINT
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take prompt action within (20) twenty 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 wamed 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 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.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
C a m LA"zIvFT-
AND NOW comes plaintiff, Brenda Newman, by its undersigned counsel,
and complains against defendant, RLH Contractors LLC, as follows:
1. Plaintiff, is a Pennsylvania resident who resides 21 Noble Lane, Shippensburg,
Franklin County, PA.
2. Defendant is a business entity with a principle place of business at 112 Big Pond
Rd., Shippensburg, Cumberland County, PA.
3. Plaintiff purchased real property from the defendant on March 28', 2006 located
and known as 21 Noble Lane, Shippensburg, PA..
4. Defendant developed the Thomwood Development and is still in the process of
developing and building.
5. Defendant built plaintiffs house located at 21 Noble Lane and conveyed the
property to the plaintiff
6. Plaintiffs property was not completely finished at the time the sales agreement
was executed.
7. Plaintiff's property was only partially graded at the time the sales agreement was
executed.
-2-
8. Defendant's agent orally promised plaintiff that the front and back yards would
be properly filled and graded at the time the sales agreement was executed and
at the final closing on the property.
9. Plaintiff has repeatedly complained to the seller/developer/builder defendant
about the unfinished grading of the front and back yard.
10. Defendant has responded twice to plaintiff's complaints, the last date being July
7', 2006, by grading a small and inadequate amount of fill on the front yard only
and has refused to do anymore filling and grading of the plaintiffs yards.
11. Plaintiff avers the inadequate grading and filling causes substantial puddling of
water in her yards.
12. Plaintiff avers she had relied on defendant's assurances that the yards would be
properly filled and graded when she agreed to the purchase and close on the
property at the agreed upon price.
13. Additionally, defendant had warranted the house from defects as the builder and
seller of the property for a period of one year.
12. Plaintiff has repeatedly complained to defendant of defects with the house that
required professional correcting.
13. Specifically, plaintiff complained of water entering through the back door of the
house when it rains.
14. Defendant's agents have attempted to fix the back door water leak but with no
success.
15. Defendant's agents have bent and visibly damaged the back door in their
attempts to correct the water leak.
16. Plaintiff has resorted to purchasing and professionally installing a storm door to
stop the water leaking problem, but is still stuck with a damaged door that is
improperly sealed.
-3-
17. Additionally, plaintiff had complained to defendant about the looseness of the
safety railing attached to the front exterior steps of the house.
18. Defendant has not corrected plaintiffs loose railing as promised by the warranty
and it still remains a safety hazzard.
19. Plaintiff avers the amount of damages does not exceed the jurisdictional amount
requiring arbitration.
19. WHEREFORE, plaintiff respectfully request this Honorable Court to issue an
Order:
(a) Granting judgment for the plaintiff and against defendant for damages not yet
fully determined or calculated so as to compensate her for her damages related
to defendant's breach; and
(b) Granting plaintiff any other relief the Court deems appropriate.
J ?-
Attorney for plaintiff:
ft A. Harper, sq.
PA #200461
S. Harper Law Office
1701 W. Market St.
York, PA 17404
717-718-8672 phone
717-718-1634 fax
sharperlawQmac.com
-4-
VERIFICATION
I, SceV A, hereby state that the facts above set forth are
true and correct (or are true and correct to the best of my knowledge, information and belief)
and that I expect to be able to prove the same at a hearing held in this matter. I understand that
the statements herein are made subject to the penalties of 18 Pa.C.S. §4904 (relating to
unworn falsification to authorities).
Date: Q t 3 -O G
(Signature)
Lrl
BRENDA NEWMAN,
Plaintiff
V.
RLH CONTRACTORS LLC,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
0( - 53109
NO. 96-4935 CIVIL TERM
PRELIMINARY OBJECTIONS
Turo Law Offices, on behalf of Defendant, RLH Contractors LLC, sets forth the
following Preliminary Objections-
1 . Plaintiff has failed to state a claim upon which the Defendant can provide relief
and the Defendant demurs to Plaintiffs claim.
A. The Final Subdivision Plan for Thornwood is set forth in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, at Plan Book
Volume 2881, Page 989.
B. The final grading as required by the erosion and sedimentation control
plan for the subject development, which is set forth on Sheet 6 of 13 of the Plan,
is the responsibility of Grove Farm Development Corporation and not the
Defendant.
C. Grove Farm Development Corporation has informed Plaintiff of this
responsibility by letters from Stephen D. Tiley, Esquire, dated October 3, 2006
and October 6, 2006. See Exhibits "A' and "B" attached hereto.
D. Sediment Basin 1, of which Plaintiff is complaining, cannot be removed
until approved by the Franklin County Soil Conservation District, which has told
Grove Farm Development Corporation not to do so until the spring of 2007.
E. The swales along Noble Drive of which Plaintiff is complaining are
permanent requirements of the Plan, as shown on Sheet 7 of 13 thereof.
Its ?3 D
Date
Respectfully Submitted
TURO LAW OFFICES
(717) 245-9688
Attorney for Defendant
FREY & TILEY
ATTORNEYS-AT-LAW
5 SOUTH HANOVER STREET
CARLISLE, PENNSYLVANIA 17013
ROBERT M. FREY
OF COUNSEL
STEPHEN D. TILEY
ROBERT G. FREY
October 3, 2006
Scott A. Harper, Esquire
1701 West Market Street
York, PA 17404
Re: Newman v. RLH Contractors, LLC
Cumberland County No. 2006-53..69
Dear Attorney Harper:
TELEPHONE (717) 243-5838
FACSIMILE (717) 243-6441
We are shareholders in, and represent, Grove Farm Development
Corporation which is the developer of the Thornwood Subdivision in
Southampton Township, Franklin County, Pennsylvania. Grove Farm
Development Corporation sold Lot No. 68, situate in Phase 2 of the Thornwood
single-family Subdivision, to RLH Contractors, LLC. A copy of your Complaint
has been sent to me. I believe that it concerns Lot 68.
Some of the averments of your Complaint concern improper grading and
seeding of the front and back yards of the lot. I do not know specifically what the
alleged defects are, but there may simply be a miscommunication.
Enclosed please find two reduced copies of portions of sheet seven of the
Thornwood Phase 2 Plan. The first page is simply to show the title block, page
number, and recording information. The second sheet shows the Noble Drive
cross-section. As you can see, there is a swale on either side of Noble Drive. It
may be that your client believes that the lot should be level in front when, in fact,
there is a swale required to be installed.
Next enclosed please find a number of reduced copies which together
consist of most of sheet six of the Thornwood Subdivision Plan for Phase 2. The
first sheet is the upper left hand side of the Plan. The second sheet is the lower
left hand side of the Plan, and then the sheets continue along the bottom of the
Plan to the lower right hand side which sets forth the title block, page number,
and recording information. As you can see, the erosion and sedimentation
control plan calls for sediment basin number one to be located on, roughly, the
ko.
Frey & Trey
Attorneys-At-Law
Scott A. Harper, Esquire
Re: Newman v. RLH Contractors, LLC
Cumberland County No. 2006-5369
October 3, 2006
Page 2
rear half of Lot 68. The first sheet shows the Sequence of Construction. I have
highlighted a portion of note 16. As you can see, sediment basin number one is
to be removed and the area re-graded after the area included in Phase No. 2 has
been "stabilized." That is defined as uniform 70% vegetative cover of erosion
resistant perennial species. That relates not simply to this lot, but to the entire
Phase 2 area. I have contacted the engineer and he indicates that that standard
has just recently been met, and so filling and re-grading of sediment basin
number one can now proceed. However, that could not have been done
previously.
Finally, please find enclosed a reduced portion of sheet four of the
Thornwood Phase 2 Plan showing the final grading plan for Lot 68. That does
show how the lot is to ultimately be graded.
I do not know if RLH Contractors, LLC, or the real estate agent, knew the
details of this grading sequence, nor do I know the factual basis for your client's
Complaint. Nevertheless, I suspect that this explanation will go a long way
toward alleviating your client's concerns with regard to grading issues, as grading
is, literally, proceeding according to plan. Should you have any questions,
please do not hesitate to contact me.
Sincerely yours,
40?
Stephen D. Tiley
SDT/tl
Encls.
cc: Mr. Wilbert L. Diehl, Ebener & Associates
Mr. Roger L. Hosfelt
Ron A. Turo, Esquire
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SEPTEMBER 21, 2004
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File No.
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No.
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6 SHOW D BE OBSERVED.
SHOWN ON SHEET 4. AS
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THE CONTRATOR SHALL:
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DAYS NOTICE IN DESIGN STAGE STOP CALL
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PA 1 CALL SERIAL NUMBER: 2866130
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INES AS SHOWN ON SHEET 3. THE TRENCHING GUIDELINES LISTED IN STAGE 6 SHOUI.D BE OBSERVED.
MAINING STORM SEWER PIPES, INLETS, MANHOLES, AND END-SECTIONS AS SHOWN ON SHEET 4. AS
SHALL BE CONSTRUCTED WHERE NECESSARY AND FILTER BAGS INSTALLED AS DETAILED ON SHEET 13.
DNE BASES AND PAVE NOBLE DRIVE, GROVE DRIVE, AND EDISON DRIVE.
JRBED AREAS AND THOSE AREAS SHALI BF. SEEDED IN ACCORDANCE WITH PERMANENT SEEDING
L TRIBUTARY AREAS TO THE E&s FACILITIES (SEDIMENT BASIN, SEDIMENT TRAP, SILT FENCES) ARE
VER OF EROSION RESISTANT PERRENIAL SPECIES HAS BEEN ACHIEVED), THE CONTRATOR SHALL:
ITE, (2) REMOVE SEDIMENT BASIN I AND REGRADE THE AREA TO MATCH THE GRADES SHOWN ON
4ND REGRADE THE AREA TO MATCH THE GRADES SHOWN ON SHEET 4, (4) REMOVE STONE FILTER
4 3, AND (5) REMOVE TDC 1 AS SOON AS THE E&S FACILITIES ARE REMOVED, THE CONTRACTOR
,H WERE DISTURBED DURING THE REMOVAL PROCESS. THIS SHALL BE DONE IN ACORDANCE WITH
FOUND HEREON.
GENERAL EBBS NOTES
ND SEDIMENTATION CONTROL FACILITIES SHOULD BE INSPECTED
AS WELL AS ON A WEEKLY BASIS. MAINTENANCE AND REPAIRS
,MED AS DIRECTED IN BMP DETAILS. SEDIMENT REMOVED DURING
SHALL BE SPREAD OVER AN AREA NOT SUBJECT TO CON-
HALL THEN BE SEEDED, FERTILIZED, AND MULCHED.
IDLE FOR PERIODS EXCEEDING 20 DAYS SHALL BE SEEDED IN
!Y SEEDING SPECIFICATIONS SHOWN HEREON.
:RETION, MAY USE STRAW BALE BARRIERS TO ADDRESS AREAS
IMITS OF DISTURBANCE WILL BE PERMANENTLY STABILIZED AFTER
.D. GRASS WILL BE PLANTED AND MAINTAINED AS LAWN IN
d.
VIOUSLY BEEN SECURED FOR THIS PROJECT. THE PERMIT No.
THE BOUNDARY OF THE NPDES PERMIT IS SHOWN ON SHEET 1
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PA 1 CALL. SERIAL NUMBER: 2866130
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1. SEEDBED PREPARATION:
LOOSEW UPPER 2 INCHES MINIMUM BY DISCING, RAKING, OR OTHER MEANS
2. SOIL SUPPLEMENTS:
LIME AND FERTILIZE ACCORDING TO SOIL TESTS. TESTING MAY BE PERFORMED
BY A SOIL TESTING LABRATORY. IN LIEU OF SOIL TEST RESULTS, APPLY SOIL
SUPPLEMENTS AS SPECIFIED IN TEMPORARY SEEDING (SOIL TESTING IS HIGHLY
RECOMMENDED). SOIL SUPPLEMENTS MAY BE BLENDED INTO THE SOIL DURING.
TILLAGE.
3. SEEDING:
TYPES do RATES- (MOST SITES) (ADVERSE SITES)
_ .. _ TALL_FESCUE _ 60 lbs. cc. 75 Ibs. ac.
_ _ _ FINE FESCUE t0 lbsloc. 15 Ibs cc._ -OR - KENTUCKY BLUEGRASS AN 25 Ibs. c.
T-----30 Ibs./ac.
REDTOP• AND 3 Ibs./oc. 3 Ibs./oc.
PERENNIAL RYEGRASS OR 15 Ibs./oc. 20 Ibs./oc.
• KEEP SEEDING RATE TO THAT SHOWN ABOVE. THESE SPECIES HAVE
MANY SEEDS PER POUND AND ARE VERY COMPETITIVE. TO SEED SMALL
QUANTITIES OF SMALL SEEDS SUCH AS REDTOP, DILUTE WITH DRY SAWDUST,
SAND, RICE HULLS, BUCKWHEAT HULLS, ETC.
4. MULCHING:
APPLY 3 TONS/ACRE (70 TO 90 Ibs/1000 sq. ft.) OF UNROTTED GRAIN STRAW
IMMEDIATELY AFTER SEEDING. ANCHOR MULCH IMMEDIATELY AFTER APPLICATION
USING 150 GALLONS PER ACRE (3 1/2 GALLONS PER 1000 sq. ft.) OF
EMULSIFIED ASPHALT.
•• THE SEEDING SPECIFICATIONS LISTED ABOVE WERE TAKEN FROM THE "PENN
STATE AGRONOMY GUIDE' AND THE SOIL SUPPLEMENTS SPECIFICATIONS WERE
TAKEN FROM SECTION 804 OF PennDOT PUBLICATION 408.
12. THE CONTRACTOR SHALL INSTALL WATER LINES AS SHOWN ON SHEET 3 f
13. THE CONTRACTOR SHALL INSTALL THE REMAINING STORM SLWER PIPES. it,
SOON AS EACH INLET IS INSTALLED, BERMS SHALL BL CONSTRUCTED WHERE
14. THE CONTRACTOR SHALL INSTALL THE STONE BASES AND PAVE NOBLE DI
15. TOPSOIL SHALL BE PLACED ON ALL DISTURBED AREAS AND THOSE ARE/
SPECIFICATIONS FOUND HEREON.
16. STAGE 16 CANNOT BE STARTED UNTIL ALL TRIBUTARY AREAS 10 THE FE
STABILIZED (UNIFORM 70X VEGETATIVE COVER OF EROSION RESISTANT PE
(1) REMOVE ALL SILT FENCE FROM THE SITE. (2) REMOVE SEDIMENT BAS)
SHEET 4, (3) REMOVE SEDIMENT TRAP 1 AND REGRADE THE AREA TO MA
DIKE FROM STORMWATER DETENTION BASIN 3, AND (5) REMOVE TDC 1.
SHALL SEED AND MULCH ALL AREAS WHICH WERE DISTURBED DURING THE
THE PERMANENT SEEDING SPECIFICATIONS FOUND HEREON.
GENERAL EBBS
AT MINIMUM, ALL EROSION AND SEDIMENTATION C
AFTER EACH STORM EVENT, AS WELL AS ON A V
TO BMP'S SHALL BE PERFORMED AS DIRECTED IN
MAINTENANCE AND REPAIRS SHALL BE SPREAD
CENTRATED EROSION AND SHALL THEN BE SEEC
G ANY DISTURBED EARTH LEFT IDLE FOR PERIODS
ACCORDANCE WITH TEMPORARY SEEDING SPECIFICF
CONTRACTOR, AT THEIR DISCRETION, MAY USE S
OF LOCALIZED EROSION.
C AREAS SHOWN INSIDE THE LIMITS OF DISTURBANC
CONSTRUCTION IS COMPLETED. GRASS WILL BE
THESE AREAS AS A MINIMUM.
G AN NPDES PERMIT HAS PREVIOUSLY BEEN SECU
IS PAG-2 0028-03-043. THE BOUNDARY OF TI
E&S CONTROL PLAN FOR INDIVIDUAL LOTS
1. INSTALL SILT FENCE ON LOWER SIDE OF CONSTRUCTION SITE. SILT FENCE SHALL REMAIN
IN PLACE UNTIL THE SITE IS STABILIZED (70%+ VEGETATION ESTABLISHED).
2. STRIP TOPSOIL FROM PROPOSED DRIVEWAY AND COVER WITH SHALE. ONLY STRIP THAT
PORTION OF THE DRIVEWAY WHICH CAN BE COVERED WITH SHALE THE SAME DAY. IF
NECESSARY, CONSTRUCT A MOUNTABLE BERM WHICH WILL PROHIBIT RUNOFF FROM
FLOWING ONTO THE CARTWAY OF ANY PUBLIC ROADS. FOR INDIVIDUAL LOTS, THE SHALE
DRIVEWAY WILL SERVE AS A STABILIZED CONSTRUCTION ENTRANCE. GRADES OF DRIVEWAYS
SHALL NOT EXCEED 10% AND NOT MORE THAN 7% WITHIN ANY PUBLIC RIGHT-OF-WAY.
3. ALL STRIPPED TOPSOIL SHALL BE PLACED ON A STOCKPILE ALONG THE LOWER SIDE OF
THE CONSTRUCTION SITE. STOCKPILES MAY NOT EXCEED 35 FEET IN HEIGHT AND THE
SLOPES OF THE STOCKPILE MUST BE 2:1 OR FLATTER.
4. STRIP SUBSOIL AS NEEDED AND PLACE ON CONTOUR ALONG THE UPPER SIDE OF THE
CONSTRUCTION SITE.
5. TO ADDRESS MINOR, LOCALIZED AREAS OF EROSION, THE CONTRACTOR MAY AT THEIR
DISCRETION, USE STRAW BALE BARRIERS.
6. PERMANENT SEEDING WILL BE APPLIED TO ALL DISTURBED AREAS AS SOON AS POSSIBLE
7. ALL DISTURBED EARTH LEFT IDLE FOR PERIODS EXCEEDING 20 DAYS SHALL BE STABILIZED
IN ACCORDANCE WITH THE TEMPORARY SEEDING SPECIFICATIONS FOUND HEREON.
8. THE LOT OWNER AND/OR THEIR CONTRACTOR IS RESPONSIBLE FOR ENSURING THE PROPER
CONSTRUCTION AND MAINTENANCE OF THE EROSION CONTROL MEASURES ON THEIR
INDIVIDUAL LOT AS OUTLINED ABOVE.
9. AT MINIMUM, ALL EROSION AND SEDIMENTATION CONTROL FACILITIES SHOULD BE INSPECTED
AFTER EACH STORM EVENT AS WELL AS ON A WEEKLY BASIS.
10. ANY DISTURBED EARTH LEFT IDLE FOR PERIODS EXCEEDING 20 DAYS SHALL BE STABILIZED
BY SEEDING WITH ANNUAL RYEGRASS.
CONSTRUCTION & BUILDING WASTES NOTES
CONSTRUCTION WASTES AND BUILDING WASTES, WHICH INCLUDE BUT ARE NOT LIMITED TO, EXCESS
PIPING (PVC, DIP, SLCPP, RCP, ETC.), CEMENT, BRICK, BLOCK, CERAMICS, LINOLEUM, GYPSUM
BOARD, RUBBER, PLASTIC, ETC. SHALL BE REMOVED FROM THE SITE, RECYLCLED, OR DISPOSED OF
BY THE CONTRACTOR/OPERATOR IN ACCORDANCE WITH DEP's SOLID WASTE MANAGEMENT REG-
ULATIONS. THESE REGULATIONS MAY BE FOUND AT THE 'PA CODE' WEBSITE (www.pocode.com)
UNDER 25 PA Code 260.1 et seq., 271.1 et seq.. AND 287.1 et seq. THE CONTRACTOR SHALL
NOT BURY, DUMP, OR DISCHARGE ANY BUILDING MATERIALS OR WASTES AT THE SITE.
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SEPTEMBER 21, 20(
File No.
02039-2A
Drawing Nome
02039-2A-GRADIN
Town
J.B.M.
Checked By
E.L.D.
Sheet No.
4 OF 1
o ? ? 8k1 ? 8
FREY & TILEY
ATTORNEYS-AT-LAW
5 SOUTH HANOVER STREET
CARLISLE, PENNSYLVANIA 17013
ROBERT M. FREY
OF COUNSEL
STEPHEN D. TILEY
ROBERT G. FREY
October 6, 2006
Scott A. Harper, Esquire .
1701 West Market Street
York, PA 17404
Re: Newman v. RLH Contractors, LLC
Cumberland County No. 2006-5369
Dear Attorney Harper:
I am writing as a follow-up to my letter of October 3, 2006.
TELEPHONE (717) 243-5838
FACSIMILE (717) 243-6441
As I indicated in my prior letter, our engineer felt that we could, just now,
begin the process of filling in Basin One which exists behind your client's
property. Our site contractor contacted the Franklin County Soil Conservation
District to confirm permission to do this and they have asked us not to fill this
Basin in until next spring. Even though Basin One (and your client's lot) are part
of Phase 2, the Conservation District desires that we have Phase 3 at a further
state of completion before Basin One is removed. That is because the
Conservation District believes that some water from Phase 3 may end up being
handled by Basin One until the site improvements for Phase 3 are completed.
Therefore, we do need to delay filling in Basin One until next spring. You should
know that we are actively engaged in infrastructure development of Phase 3, and
hope to have it completed soon.
Furthermore, Wib Diehl, the Vice President of Grove Farm Development
Company, has spoken with our site contractor concerning the swale in the front
of your client's property. Evidently, there is some ponding which occurs in the
front Swale. Our contractor believes that this is because Phase 3 has not been
completed and therefore, the water that is in that swale does not have a place to
go. Again, that problem should be solved within the next several months.
Wib Diehl met with your client. Evidently one of your client's main
concerns is that the ponds could become breeding grounds for mosquitoes. At
this point we are pretty much beyond that season and not only hope, but expect,
wmnvmmft?
Frey &Tiley
Attorneys-At-Lan,
Scott A. Harper, Esquire
Re: Newman v. RLH Contractors, LLC
Cumberland County No. 2006-5369
October 6, 2006
Page 2
that we will have sufficient work completed in Phase 3 such that we will have the
swale in front of your client's house continued into Phase 3, and be in a position
to fill in Basin One, by the time mosquito season begins again in the spring.
This will also confirm, as a result of Wib Diehl's conversation with your
client, that Grove Farm will be mowing Basin One.
Please feel free to-contact me should you have any questions.
Sincerely y urss,,
44 -,4
Stephen D. Tiley
SDT/tl
Encls.
cc: Mr, Wilbert L. Diehl, Ebener & Associates
Mr. Roger L. Hosfelt
Ron A. Turo, Esquire
CERTIFICATE OF SERVICE
I, James M. Robinson, Esquire hereby certify that I served a true and correct
copy of the foregoing Preliminary Objections by first class, postage pre-paid and
depositing same in the United States Mail, first class, postage pre-paid on the
13 1+4 day of October, 2006, from Carlisle, Pennsylvania, addressed as follows:
Scott Harper, Esquire
1701 W. Market Street
York, PA 17404
TURO LAW OFFICES
ta: s M Robi son, Esquire
outh Pitt treet
Carlisle, PA 1 013
(717) 245-9688; FAX (717) 245.2165
Attorney for the Defendant
,....
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SHERIFF'S RETURN - REGULAR
CASE NO:'2006-05369 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NEWMAN BRENDA
VS
RLH CONTRACTORS LLC
WILLIAM CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
RLH CONTRACTORS LLC the
DEFENDANT , at 1408:00 HOURS, on the 21st day of September, 2006
at 112 BIG POND ROAD
SHIPPENSBURG, PA 17257
by handing to
ROXANNE HOSFELT, OWNER'S WIFE 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: So Answers:
Docketing 18.00
Service 26.40
Postage .39
Surcharge 10.00 R. Thomas Kline
.00
54.79- 09/22/2006
to f p t,] b( SCOTT HARPER
Sworn and Subscibed to By: '
before me this day Deputy Sheriff
of A. D.
Curtis R. Long
Prothonotary
office of the Protbonotarp
Cumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
j_CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573