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Home My WebLink About94-02427 - .J C C o C> b cu c o <V t: li5 , (.. f! - .- JI I I ~ (1) I ! , . ' -- ('~l '\ - . ^: '" ~. Ie,,' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GEORGE SIMEONE, A' 'D. ~ I NO. 9i/-.;Jt/.;J) ~~ Plaintiff vs. JURY TRIAL DEMANDED O'DONNELL MOTORS, INC., . . Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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 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 COURT ADMINISTRATOR Cumberland county Courthouse One Courthouse square, 4th Floor Carlisle, PA 170l3-3387 Telephone: (717) 240-6200 - r;* .- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GEORGE SIMEONE, . NO. . Plaintiff . . vs. : . . O'DONNELL MOTORS, INC. , . . . JURY TRIAL DEMANDED . Defendant : COMPLAINT 1. Plaintiff, George Simeone, is an adult individual who currently resides at 25 White Run Lane, Gettysburg, Adams County, Pennsylvania 17325. 2. Defendant, O'Donnell Motors, Inc., is a corporation authorized to do business in the state of Pennsylvania maintaining offices at 6271 Carlisle Pike, Mechanicsburg, Pennsylvania 17055. 3. At all times material to the within cause of action, Plaintiff was employed as the manager of the sales department of defendant's automobile dealership. 4. On or about February 1, 1994, plaintiff met with Sam Glover, general manager of defendant, and Mike Boyd, used car manager of defendant. 5. At that meeting, Mr. Glover informed plaintiff and Mr. Boyd that the economic situation did not warrant retaining both plaintiff and Mr. Boyd. However, Mr. Glover promised to retain plaintiff for at least an additional ninety days, and in exchange therefore plaintiff was to draft a plan to improve business at the dealership. 6. On or about February 10, 1994, plaintiff again met with Mr. Glover and Mr. Boyd, and at that time Mr. Glover told plaintiff that he was being laid-off. 7. At the time that his employment was terminated, plaintiff was earning $4,000.00 per month. 8. Plaintiff has suffered damages in the amount of $12,000.00, which sum equals the amount plaintiff would have received if he has been employed for the ninety-day period promised by Mr. Glover on behalf of defendant. WHEREFORE, plaintiff demands judgment in his favor and against defendant in the amount of $12,0000.00, with interest and all costs of suit. WOLF AND OYLER By: Ral Att n plaintiff 112 Baltimore street Gettysburg, PA 17325 (717) 334-1191 -a; - :s: ..- Of) '::t ('oJ ..... .. >- .., t+- . ~I ~~:.:.: ,. ~"''-' ... '.. '~~ '., .....1'...... .' . " "1" , .J~ ~: J .'" r--I ~- .,~ 15 ..... u t~ ',' Md~t:I.s. \"'ALL,ACE a NURICK 100 PINE STREET P 0 BOlt IIGO HARRISBURG. PA 17108 -. '.. ". -......................-.. . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GEORGE SIMEONE, Plaintiff NO. 94-2427 CIVIL TERM v. O'DONNELL MOTORS, INC., Defendant ANSWER WITH NEW MATTER ANSWER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. S. Denied as Mr. Boyd that sales stated. Mr. Glover informed both Plainti ff and at the dealership were unsatisfactory and that they might be laid off if sales did not improve. Mr. Glover, Mr. Boyd and Plaintiff together developed a sales plan for the dealership. It is specifically denied that Glover gave either manager three months to improve sales or otherwise promised either manager continued employment for any period. 6. Admitted. , I 7. Denied. Plaintiff was paid a salary of $550.00 per week and a bonus of $45.00 for each car sold. At the time of Plain- tiff's termination, Plaintiff's total earnings were less than $4,000.00 per month. 8. Denied as a conclusion of law and a prayer for relief to which no responsive pleading is required. WHEREFORE, Defendant requests that Plaintiff's Compaint be dismissed and that judgment be entered in favor of Defendant and against Plaintiff. NEW MATTER 9. Plaintiff's employment with Defendant was terminable at will. 10. Plaintiff signed a written statement on his application for employment with Defendant which expressly stated that "no representative of the Company has any authority to enter into any agreement for employment for any specified period of time, or to make any agreement contrary to the foregoing, unless it is in writing and signed by an authorized Company representative." 11. Plaintiff had no employment agreement with Defendant. 12. Should it be determined that Plaintiff had a contract of employment with Defendant for a definite period of time, Defendant nevertheless had cause for terminating Plaintiff's employment. 13. Plaintiff has failed to mitigate his damages. - 2 - . ' WHEREFORE, Defendant requests that Plaintiff's Complaint be dismissed and that judgment be entered in favor of Defendant and against Plaintiff. Respectfully submitted, McNEES, WALLACE & NURICK By lizabeth A. erty .D. No. 398 Eric N. Athey I.D. No. 63341 100 pine Street P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Defendant O'Donnell Motors, Inc. Dated: August 1, 1994 - 3 - f....'y,~.'--."-.f . IH HZ COURT 01' COKKOH PLDS CUHBBRLAHD COmITY, PBH1fSYLVAHIA CIVIL DIVISIOH GEORGE SIMEONE, . NO. 94-2427 civil Term . : plaintiff . . vs. . . O'DONNELL MOTORS, INC. , . . JURY TRIAL DEMANDED Defendant . . PLAIN'l'IFF'S REPLY TO DEFENDANT'S PRELIMINARY OBJECTION 1. Admitted. However, plaintiff avers that he has in fact set forth a claim for a breach of an employment contract. 2. Denied. To the contrary, plaintiff has plead facts sufficient to overcome the at will employment presumption. 3. Denied. To the contrary, plaintiff has plead sufficient and specific facts to allege and establish that the parties meant to bind themselves to an employment relationship for a definite period of time. 4. Paragraph four sets forth a legal conclusion to which no response is necessary. WHEREFORE, plaintiff prays This Court overrule defendant's preliminary objections, and direct them to file an answer within twenty (20) days therefrom. By: o ~n for Plaintiff 112 Baltimore street Gettysburg, PA 17325 (717) 334-1191 WOLF IN TBB COURT or COHKON PLBAS CUMBBRLAHD COUHTY, PBIOISYLVUIA CIVIL DIVISION GEORGE SIMEONE, . NO. 94-2427 civil Term . Plaintiff vs. . . . . O'DONNELL MOTORS, INC. , . . Defendant : CERTIFICATE OF SERVICE I, Karen Heflin, Legal Secretary in the law firm of WOLF AND OYLER, do hereby certify that on June 9, 1994, a true and correct copy of Plaintiff's Reply to Defendant's preliminary Objection was mailed to counsel for defendant, addressed as follows: Elizabeth A. Doughe~ty, Esquire MCNESS, WALLACE & NURICK 100 pine street, P. O. Box 1166 Harrisburg, PA 17108-1166 ATTORNEY FOR DEFENDANT WOLI' AND OYLER Date: June 9, 1994 By: ~.D.MJL Ka~~ Legal Secretary for Ralph oyler Ralph Oyler, Esquire Attorney for Plaintiff .~_..,,-,-~ . ......"....; , ;, ";,"'\i,:..,;~,, "".'~", '"" <'""'Y ,,;',' ,; , 2;\ ,": ,'i., "J "0 ."...' ..<.:.",.~L';~4~1:~'~~~\'~;'lil~~~i'Z-i~""lit~, .....,..".-............."" ."...'-~...... -.=-~..,...~-_.._.- .......~.. . ...." .'.~~,~J...~"-\, '.. ;'1.;, ~-~\ c~_" ,~,:.- ., , ..~,~~~~';'.:,_. ','"""fi-'..:1.-", ~~t~i/,:; ,.,',-...J-J>:.,.,/....c" :;I~}?,fl~!ff:,~;: . .,~~{~y,.' ~' . . ' ;> ,1(;5: ~ ".,,:;,:~;r~.~. ", , ,~t~~}\~: :"', /~~;;i7: ",:,,"iF~' ~~~}::i.i;~<;, .. ,)!!}...,.., ,,:"\~::a~i;7~ . '~f:~?~ ,.;.'.., ;''-.i t,~ JUH 13 ,I 111J 4H '9~ . f .,., ,:.f r:tiq' p ~: . ,;'1'01 ! 1,'{['/'''"" ,#->. .. ,',., ), . "1,1) ;,l.~ .~.tJ ('II.'kH .N, "-V(-'. ! :t; ... ., .... .. .., r , .' .:, ,~ ...~ .'.1 ~ ,'1 .' !,j.~ t;' "' " '. , .' ~ . .'. ... ~ . ..... ~.., '.f '..' c' i .._-'.........._'........,. ,~-'~ , . ~ , . " , .---- ":J" ~ >-... ..:r..... ::: " - ,.. D_ ,~, , , In ) , " In '. " " , ~ ,. , ,...., , --, , .- 0'> ,,; '" , :':-.J , " -, ;... I, I i .. , . . . . MCNEES. WALL.ACe: l\ NURICK '00 PINE STREF:T JUN 08 199. dA- ~. Q. BOX I hU~ H"ft'USBURG, PA 17108 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GEORGE SIMEONE, Plaintiff . . NO. 94-2427 CIVIL TERM v. . . . . O'DONNELL MOTORS, INC., Defendant : . . ORDER AND NOW, this day of , 1994, upon considera- tion of Defendant's Preliminary Objections, said Preliminary Objections are SUSTAINED. Plaintiff's Complaint is hereby DISMISSED. J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GEORGE SIMEONE, Plaintiff NO. 94-2427 CIVIL TERM v. O'DONNELL MOTORS, INC., Defendant DEFENDANT'S PRELIMINARY OBJECTION TO PLAINTIFF'S COMPLAINT Defendant O'Donnell Motors, Inc. ("O'Donnell"), by and through its attorneys, McNees, Wallace & Nurick, make the follow- ing Preliminary Objection to Plaintiff's Complaint: PRELIMINARY OBJECTION FOR LEGAL INSUFFICIENCY OF A PLEADING. 1. In his Complaint Plaintiff George Simeone ("Plaintiff") attempts to set forth a claim for breach of an employment con- tract. 2. In his Complaint, however, Plaintiff has not alleged any facts which overcome the presumption in Pennsylvania that all employment is terminable at-will. 3. Plaintiff has not alleged that he provided such special consideration so as to establish that the parties meant to bind themselves to an employment relationship for a definite period. 4. For these reasons, plaintiff has failed to set forth a claim upon which relief can be granted and his complaint must be dismissed its entirety. WHEREFORE, Defendant respectfully requests that this Honor- able Court dismiss Plaintiff's Complaint in its entirety for legal insufficiency. McNEES, WALLACE & NURICK By abeth A. Dough I. . No. 39853 Eric N. Athey I.D. No. 63341 100 Pine Street P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 .3 Dated: June 1, 1994 Attorneys for Defendant O'Donnell Motors, Inc. - 2 - CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing preliminary objections to Plaintiff's Complaint was served by first-class mail, postage prepaid, upon the following: Ralph Oyler, Esquire WOLF & OYLER 112 Baltimore street Gettysburg, PA 17325 (717) 334-1191 (Attorneys for Plaintiff) 3 Dated: June J, 1994 , ~ ,,"';'0. 'f~ :o:h"f' ,,', ,;,','" ",'i ; '~"'\'il'~;~),;~:":'). ,'.... ,',.-, .. ~~..:-." '''':'';P '., !.!l)..,{~""':;'HJ~"':'1":"'~"~:;'~~',;.;:..." , ".._'--",..""'_".";l'I;.'.........~.it!,);!!;,~~"'alli~. " lilt '.....;;;o'j \ ' \ .- -._....~-~_. _._-_._--------~~_.~-.-._.._._--"._._... ._~-_.~...~~ - .. ," :., .f," "":.- .:-~ :- : '. :'\. ~ ,.....' - ", -.,'- ,,< ~ C'\ ,) 1\ 1:1 ilK}9~ ,,' ......:. '" '",,; .' . ~.. JUN 13 '.-: ',r' ,,~:.uft'OE Of TilL h;'lllONCT4!1~ CUHOn,LI.HO UOIJ"lY rEN~S h'JAH1A ::i" !~ ~-'-' f. ~., .)" 'r'. ,:~:. ("ii ;:] ~.--i-','- ..~ _.~;. .{,'1 . " --":~ ;.' "';.' " '." 1",.'"'" .c_ ,"" .. , . ~.. ~- ,~.t! . '1-\~":', jD,;_' ;',',' ,..;, ......- : ~ 0, ...; " .. .. -~-, r 1 , , , ~ ,..: .. " ". ,~ .;... :." l7 """t .',~ t;j 'f::;1 ","' n -~/I>')) 't::::7.:".:"" ;,..f.'-{ :~< ~<, ; ~. .~. .~ ,. t...' . 'i j:, '.::.):;. .,-- C~ ~ ('~ p 'f-,,;. .. .d,.;.-f ..,....{ "'~ " ;~i;l'- ~~..., _;.'.'/1,'..., ,r. NI;;:~<~;i~' '-~'"14- __ NB ,-.jj.:'"'' <.;.~l. ~i'J;'l..t - .'-, J;.~,__~-':' :.~~;'1" . ....1-~, '\'v.' :,~l/:!""C,~!:;':,".;~ ;\ " ~""! -'! ~~ ; .-, ~ j A'..' " . ~ .. , , '. ,. .."!+ , ?/~,;:~!n:""::~-:~'- 'W ._......._~_ .'........, " t~.--,_~:'":':;~:.>. ."~ " -' . : y ~ j't'-....V--:, tio ,'" }~:...;,"':~-: . ./ . ,I.....; - "~-:" t.-1'.: (~ ~~:'~^.\"'- }-:;".^ -",' . " .' " .' ( , '. . ,;;..:. dJ/ , ,,!'"~ " ;.'i' _ " i'~''- ~<{. 'r;";. '" ~n ,Ifl. "'., " v ':~F .: ,~, ~- 1- ~..~': _f; l~_) >:.,: ~o :H '.1;\ , ~-;.- -So,...... ,;\'j >n- .:, ~ " ;..", r .,_.",;-'. ,.-'. - GEORGE SIMEONE, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-2427 CIVIL TERM CIVILACfION - LAW O'DONNELL MOTORS, INC., Defendant IN RE: DEFENDANT'S PRELIMINARY OBJECfIONS BEFORE BAYLEY AND HESS. JJ. ORDER AND NOW, this I '{. day of July, 1994, the preliminary objections of the defendant to the plaintifrs complaint are DENIED. BY THE COURT, eo-p.t-.w t1I'Ul dL Ralph Oyler, Esquire ~ For the Plaintiff (. . Elizabeth A. Dougherty. Esquirg) For the Defendant ~111L/11Y :rlm GEORGE SIMEONE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. I I I I I I I NO. 94-2427 CIVIL 1994 O'DONNELL MOTORS, INC., Dsfsndant CORRECTED NOTICE OF HEARING YOU ARE HEREBY NOTIFIED that ths undersignsd arbitrators appointsd by the Court in the above captioned matter will meet for the purpose of their appointment on Monday, September 19, 1994, at 10100 a.m. in the Old Cumberland County Court House, 2~ Floor, Carlisle, Pennsylvania, at which time and place you may appear and be heard, together with your witneeeee and your counsel, if you so desire. PARTIES WISHING TO ARGUE LEGAL POINTS WILL BE EXPECTED TO HAVE COPIES OF CASES, STATUTES, ETC. WITH RELEVANT PORTIONS HIGHLIGHTED FOR EACH ARBITRATOR AND OPPOSING COUNSEL AT THE COMMENCEMENT OF THE HEARING. ANY NOTICED PERSON REQUESTING A CHANGE OF HEARING DATE MUST CONTACT ALL PERSONS AS TO AN AGREEABLE DATE, PROVIDE WRITTEN NOTICES TO ALL PERSONS AND RESERVE PLACE OF HEARING. Dated I ,~ , ) C. ~-.-,. ~~ 'W.-' W 4 Ruby D. eeks, Esquire, Chairman Christopher Houston, Esquire John Perry, Esquire B-16-94 COPIES TOI Ralph Oyler, Esquire WOLF AND OYLER 112 Baltimore Street Gettysburg, PA 17325 Attorney for Plaintiff Elizabeth A. Dougherty, Esquire McNEES, WALLACE & NURICK 100 Pine Street P.O. Box 1166 HarriSburg, PA 17108-1166 Attorney for Defendant Court Administrator Bulletin Board, Prothonotary's Office CGfolONWEAL'IH OF PENNSYLVANIA: COUNl'Y OF ClMBERLAND SHERIFF'S RETURN In The Court of Common Pleas of Cumberland County, Pennsylvania No. 94-2427 Civil Term Notice to Defend and Claim Rights Complaint George Simeone VS O'Donnell Motors Inc. Philip Baughman , ~~~~ or Deputy Sheriff of Cunberland County, Pennsylvania, who being duly swom according to law, says, that he served the within Notice to Defend and Claim Rights Complaint upon O'Donnell Motors Inc. , the defendant, at 10:20 day of Mav 0' clock A.M. 00f0(/ EDST, on the 16 , 19....9.Aat 6271 Carlisle Pike, Mechanicsburo , Cumberland County, Pennsylvania, by handing to Sam Grover, General Manager at O'Donnell MntnrR. Tnc. a true and attested copy of the Notice to Defend and Claim Rights Compl9int and at the same time directing his attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge r~~~ 14.00 6.16 2.00 22.16 Pd. by Atty. 5-18-94 R. Thomas Kline, Sheriff by -atlf t ~ a.'J fJ Deputy Sheriff Swom and subscribed to before roo this ..I. 3.....L day of 1Lt"1 19 Q'f A.D. ~'J" C. n1.<.(p,. , ~ . Prothonotary GEORGE SIMIONE, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ve. O'DONNELL MOTORS, INC., Defendant NO. 94-2427 CIVIL 1994 NOTICE OF HEARING YOU ARB HEREBY NOTIFIED that the undereigned arbitrators appointed by the Court in the above captioned matter will meet for the purpose of their appointment on Monday, september 1994, at 10:00 a.m. in the Old Cumberland County Court House, 2~ Floor, Carlisle, Pennsylvania, at which time and place you may appear and be heard, together with your witnesses and your counsel, if you so desire. PARTIES WISHING TO ARGUE LEGAL POINTS WILL BE EXPECTED TO HAVE COPIES OF CASES, STATIlTBS, ETC. WITH RELEVANT PORTIONS HIGHLIGHTED FOR EACH ARBITRATOR AND OPPOSING COUNSEL AT THE COMMENCEMENT OF THE HEARING. AMY NOTICED PERSON REQUESTING A CHANGE OF HEARING DATE MUST CONTACT ALL PERSONS AS TO AN AGREEABLE DATE, PROVIDE WRITTEN NOTICES TO ALL PERSONS AND RESERVE PLACE OF HEARING. Dated. 8-16-94 ~~ Ruby D. eeks, Esquire, Chairman Christopher Houston, Esquire John Perry, Esquire COPIES TO. Ralph Oyler, Esquire WOLF AND OYLER 112 Baltimore Street Gettysburg, PA 17325 Attorney for Plaintiff Elizabeth A. Dougherty, Esquire McNEES, WALLACE & NURICK 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Attorney for Defendant Court Administrator Bulletin Board, prothonotary's Office GEORGE SIMEONE, IN niE COURT OF CO~~ON PLiAS OF CmlBERLAND COUNTY, PENNSYLVANIA NO. 94-2427 CIVIL 1994 Plaintiff VS. O'DONNELL MOTORS, INC., Defendant RULE 13l2-l, The Petiti~n Eor Appointment of Arbitrators shall be substantially in the following form: PETI~!ON FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Ralph D. Oyler, Esquire, , counsel for the plaintiff/KK~K in the above action (or actions), respectfully represents that: l. The above-captioned action (or actions) is ~~~ at issue. 2., The ~A:\imcg~t~h.e plaintiff in the action is $ l2. 0$000 '0000 . p' ,,,, i.nterest The countercIaim of the defendant in the action is . The fo1~o~ing attorneys are interested in the case(s) as counselor are other- wise disqualified to sit as arbitrators: Wolf and Oyler, ll2 Baltimore St. Getty~burg, PA,and McNees, Wallace & Nurick, lOO pine St., Harrisburg, PA. WHERE~RE, your ?etitioner prays your arbi!fltors7to whom the case shall be ::c: ~ '.:' ...-r _I;. -i ~~ ,r .: Honorable Court to appoint three (3) suomi teed. '- "., .-. .-. c:::> .' . ~, , '" ORDER OF "' /"'" , 19 94 , in consideration of the Esq., u~."'!'Iu~&t /};Us. in COURT -~ NOW: /1u (:''It sf Esq., and Ru..h V 11/1/ IF~ L,); A n !->U':k: Y foregoing petition, ,Esq., are appointed arbitrators in the above-captioned action (or actions) as prayed for. By P. J. I!r--.. 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' '" , .,;.,. . ..> ~~ , ",\,' F I i I " , ._~A(!..~...~- " -.1 -,-,<,>.~,.- .,....,; " f'~:~' '; 'c'_ ,p:~1;.L', ,: ,,":;, . >"'" "" ;~t~.,7~.r~:)P'?{~;::,: ":~_:L',i. , ,.;, "t'j.i>~':'-;'::~;.I1r :':"~;,,,",,..:l";,J1'~: ".~'$;i;!c...i.01,,j:d.".,,,-,, ,...;w'l';"~ll!l.""''>:"'''~ . . ,Jt'ij~l'f'"",.',~.:#A, .' ;;~t~~~~~",,:"i<;,r~. ,/ \ \ I , J . ,-_.._.._.~'~-_.- n.-r:y~. ~ a,.,.y 'D' ,1'.,., r i 1, OCT 18 1\ 03 'AK '''' t '! .~ ",'\)rfJ'~E Of, 'Hi !'t'r'IOIi~1,lh~ CU~Ut.ltL/j!,O-Cf.;:.!h TV i PEhti3'(L'-~~.if. -, ,.... ,t.' .,. < .-----:~." I . ~_. - 1 UT~'T .~t'" F' ~ ... " - '1 . "; ..,,,.-.......- , ,,_,___L: , "'\' I"~) ......., fCO; I" .' - Cumberland County, Pennsylvania ~o.1y-~;I.)7 19 h In The Court of Cocmon Pleas of ,:'1_, ) ) ) ) ) ) ) @i&;W)/I# ()}J/t.U I"h! ('./ , /l{J<!;/J,'//'t'/,-/- OATH We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitutio~ or this Common- ~ealth and that we will discharge the duties of our ~ffice w~ fidelity. )'-;;); -,'l{O at/w r:nan AWARD Wet the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) oak ,,!..,,-/..rgr: c;>#<-<.,lf/ /~ .a.t'At- / . Arbitrator, i: applicable. ) Date of Hearing: It: ' d' 'j </ Dace of Award: /1, i("/Y NOTICE OF ENTRY OF AWARD ~ow, the day of award was entered upon the docket parties or thei~ attorneys. ,l9 ,at ,.~1., the above and notice :hereof g~ bY-mail to the Arbitrators' compensation to be paid upon appeal: $ Prothonotary 3y: Degut:' t-....".... ,. " . c...c.... Lv CJ~J..7'~ I./~. tir>- {3 J14 jJ.........c-