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IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6849 CIVIL TERM
CIVIL ACTION - LAW
ALEX R, SZELES, INC.,
Plaintiff
ZONA D. LANDIS,
Defendant
ANSWER WITH NEW MATTER AND COUNTERCLAIM
AND NOW, comes Defendant, Zona D, Landis, by and through her
attorney, Stephen C. Nudel, Esquire, and files an Answer to
Plaintiff's Complaint as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted in part and denied in part.
It is admitted
that services were required on the days indicated in "Exhibit A".
It is denied that Defendant agreed to pay the amount indicated in
"Exhibit A". By way of further response, "Exhibit A" is dated
two months after the services were performed.
7. Denied. It is denied that Defendant relinquished all
authority to her insurance company to approve work to be done.
It is further denied that "Exhibit B" is an authorization by
Defendant which appoints her insurance company as her agent; the
document speaks for itself.
B. Admitted in part and denied in part. It is admitted
that "Exhibit C" sets forth an estimate for repairs to
Defendant's house and a total price for those repairs. It is
denied that Plaintiff made any indication to Defendant that the
August 11, 1992, estimate was not complete as stated.
9. Admitted in part. Defendant agreed to pay for the work
when it was completed in a satisfactory manner.
10. Admitted in part. "Exhibit D" does not contain the
entire document; the missing parts (invoices) are relevant and
material to this action.
11, Admitted in part. Defendant agreed to pay for the work
when it was satisfactorily completed.
12. Admitted in part and denied in part. It is admitted
that an estimate was presented to Defendant's insurance company.
It is denied that the work was substantially completed at the
time Plaintiff discovered the miscalculation of the installed
carpet.
13, Denied. Defendant's New Matter and Counterclaim are
incorporated herein by reference as if fully set forth at length.
14. Denied. Defendant's New Matter and Counterclaim are
incorporated herein by reference as if fully set forth at length.
15. Admitted in part. It is admitted that Defendant has
paid $14,000.00 to Plaintiff. It is denied that the work has
been completed.
COUNT I - CONTRACT
16, paragraphs 1 through 15 of Defendant's Answer are
incorporated herein by reference.
17. Denied. Defendant's New Matter and Counterclaim are
incorporated herein by reference as if fully set forth at length.
18. Admitted. By way of further response, the credit
issued does not cover the total amount of setoffs which are due
Defendant, Defendant's New Matter is incorporated herein by
reference as if fully set forth at length.
19. Admitted in part and denied in part. It is admitted
that Defendant is entitled to a $14,000.00 credit. It is denied
that Plaintiff and Defendant reached an oral agreement.
20. Denied. Defendant does not owe Plaintiff. Defendant's
New Matter and Counterclaim are incorporated herein by reference
as if fully set forth at length.
WHEREFORE, Defendant requests your Honorable Court to
dismiss Plaintiff's Complaint and enter judgment in favor of
Defendant plus costs of suit and attorney fees.
COUNT II - OUANTUM MERUIT
21. Paragraphs 1 through 20 of Defendant's Answer are
incorporated herein by reference.
22. Denied. plaintiff has not completed the work it agreed
to do. In addition, much of the work which was completed was of
a 8ubstandard quality and is in need of repair. By way of
further response/ Defendant/s New Matter and Counterclaim are
incorporated herein by reference as if fully set forth at length.
23. Denied, Defendant's New Matter and Counterclaim are
incorporated herein by reference as if fully set forth at length.
24. Admitted in part and denied in part. It is admitted
that Defendant will not pay $8/890.21 to Plaintiff. It is denied
that Defendant owes $8,890.21 to Plaintiff or that the amount
claimed by Plaintiff is the reasonable value for the work done by
Plaintiff on Defendant's home. By way of further response/
Defendant's New Matter and Counterclaim are incorporated herein
by reference as if fully set forth at length.
25, Denied. Defendant/s New Matter and Counterclaim are
incorporated herein by reference as if fully set forth at length.
WHEREFORE, Defendant requests your Honorable Court to
dismiss Plaintiff's Complaint and enter judgment in favor of
Defendant plus costs of suit and attorney fees.
NEW MATTER
26. Paragraphs 1 through 25 are incorporated herein by
reference.
27. Plaintiff charged for services and materials which were
performed by other contractors and suppliers.
2B. Plaintiff overcharged for said services and materials
performed and supplied by others.
29. Plaintiff agreed to charge only amounts authorized by
Defendant's insurance company.
30. Plaintiff's estimates and invoice totals are in excess
of the amount authorized by Defendant's insurance company.
31, Defendant is entitled to setoffs in the amount of
$2,563.02.
WHEREFORE, Defendant requests your Honorable Court to
dismiss Plaintiff's Complaint and enter judgment in favor of
Defendant plus costs of suit and attorney fees.
COUNTERCLAIM
COUNT I - BREACH OF CONTRACT
32. Paragraphs 1 through 31 of Defendant's Answer and New
Matter are incorporated herein by reference.
33. Plaintiff agreed to complete the work contained in
Plaintiff's "Exhibits A, C, D and E".
34. Plaintiff failed to complete the work set forth in its
estimates.
35. Accordingly, Plaintiff is in default of its agreement
to perform work.
36. In addition the work performed is deficient and was not
performed in a workmanlike manner.
37. Plaintiff is in default of its agreement to perform
work in a workmanlike manner.
3B. Plaintiff is liable to Defendant for damages sustained
by reason of its failure to construct the property in accordance
with the agreements.
WHEREFORE, Defendant demands judgment in favor of Defendant
and against Plaintiff in an amount less than $20,000.00 plus
interest, costs of suit and attorney fees.
COUNT II - BREACH OF CONTRACT
39, Paragraphs 1 through 38 of Defendant's Answer with New
Matter and Counterclaim are incorporated herein by reference.
40. In a letter dated June 3, 1993, Plaintiff subsequently
agreed to complete specific items which had not been completed by
Plaintiff. A true and correct copy of the letter is attached
hereto and made a part hereof as "Exhibit A".
41. Plaintiff failed to complete those items.
42. Plaintiff breached its agreement to Defendant.
43. Plaintiff is liable to Defendant for the damages
sustained by reason of its failure to construct the property in
accordance with the agreement.
WHEREFORE, Defendant demands judgment in favor of Defendant
and against Plaintiff in an amount less than $20,000.00 plus
interest, costs of suit and attorney fees.
COUNT III - BREACH OF IMPLIED WARRANTIES
44. Paragraphs 1 through 43 of Defendant's Answer with New
Matter and Counterclaim are incorporated herein by reference.
45. Plaintiff performed work.
46. The work performed was warranted to be in all respects,
fit and proper for finished work in a home restored after water
damage.
47. The work that was performed by Plaintiff proved to be
unsound and unsuitable in that the workmanship was of an
unacceptable inferior nature. The work performed was not
completed in a workmanlike manner.
4B. Defendant notified Plaintiff of the defects.
49. Plaintiff failed to correct the defects.
50. As a result of the defects, Defendant will be required
to expend large amounts of time and monies to corr.ect the defects
in an amount approximately $6,000.00.
WHEREFORE, Defendant demands judgment in favor of Defendant
and against Plaintiff in an amount less than $20,000.00 plus
interest, costs of suit and attorney fees.
COUNT IV - UNFAIR TRADE PRACTICES
51. Paragraphs 1 through 50 of Defendant's Answer with New
Matter and Counterclaim are incorporated herein by referenced.
52. Defendant, Zona D. Landis, is a person who is a
consumer under the Unfair Trade Practices and Consumer Protection
Law as found in 73 P.S. 201-1 et. seq.
53. Defendant's purchase of water damage restoration
services from Plaintiff was for personal, family and household
purposes.
54. Plaintiff's failure to provide fit and suitable
workmanship throughout the restoration process was an unfair and
deceptive trade practice in the following respects, to wit:
a. Representing that the restoration work had
characteristics, uses and benefits that it did not
have;
b. Representing that the restorations were of a
particular standard, quality or grade, when the
Premises were of another;
c. Failing to comply with the terms of a written
agreement given at the time Defendant contracted to
purchase Plaintiff's services;
d. Failing to comply with the terms of a written
agreement given subsequently;
e, Engaging in fraudulent conduct by failing to
disclose the defects surrounding the restoration of the
premises;
f. Making repairs, improvements or replacements on the
premises of a nature or. quality inferior to or below
the standard agreed to in writing;
g. Representing that Plaintiff had the skills
necessary to complete the restoration;
h. Engaging in fraudulent conduct by overcharging for
materials and services; and
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ALEX R. SZELES, INC., ) IN THE COURT OP COHHON
Plaintiff ) PLEAS OP CUMBERLAND
) COUNTY, PENNSYLVANIA
VB. )
) CIVIL ACTION - LAW
)
ZONA D. LANDIS, ) NO. 94- 1.P'i?1Q CIVIL TRRM
Defendant )
NOTICB
TO DBPBNDANT NAMED HBRRIN:
YOU HAVE BEEN SUED IN COURT. IP YOU WISH TO DEPEND AGAINST THE CLAIMS SET PORTH IN
THE POLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (30) DAYS APTER THIS COHPLAINT
AND NOTICE ARE SBRVED, BY ENTBRING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
PILING IN WRITING WITH THE COURT YOUR DEPENSBS OR OBJBCTIONS TO THB CLAIMS SET PORTH
AGAINST YOU. YOU ARB WARNED THAT IP YOU PAIL TO DO SO. THE CASE HAY PROCEED WITHOUT
YOU, AND A JUDGMENT HAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT PURTHER NOTiCE POR
ANY HONEY CLAIMED IN THE COMPLAINT OR POR ANY OTHER CLAIM OR RELIEP REQUESTED BY THE
PLAINTIPP. YOU MAY LOSE HONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IP YOU DO NOT HAVE A LAWYER OR
CANNOT APPORD ONE, GO TO OR TELEPHONE THE OPPICE BET PORTH BELOW TO PIND OUT WHERE YOU
CAN GET LEGAL HELP.
COURT ADMINISTRATOR
POURTH PLooR, CUMBERLAND COUNTY COURT HOUSE
CARLIBLE. PENNSYLVANIA 17013
TELEPHONE: (717) 340-6300
1
ALBX R. SZBLBS, INC., I IN THB COURT OF COHHON
Plaintiff I PLEAB OP CUHBBRLAND
I COUNTY, PENNSYLVANIA
vs. I
I CIVIL ACTION - LAW
I 94- (pg~q CIVIL TBRH
ZONA D. LANDIS, I NO.
Defendant I
COttPLAINT
AND NOW comes the above-named Plaintiff, by its attorneys, Andes, Vaughn & Bangs,
and makes the following complaint in this matter:
1. The Plaintiff is Alex R. Szeles, Inc., a corporation organized and doing
business under the laws of the Co..onwealth of Pennsylvania with its principal offices
at 5110 Lancaster Street, Dauphin County, Pennsylvania.
2. The Defendant is Zona D. Landis, an adult individual who resides at 116
Lancaster Boulevard, Hechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff is a construction company engaged in fire, water, and other casualty
damage to real and personal property.
4. Defendant is the sole owner of the real estate located at and known and
numbered as 116 Lancaster Boulevard in Hechanicsburg, Pennsylvania.
5. In the suamer of 1992, Defendant's home in Hechanicsburg was extensively
damaged by water. As a result of that damage, Defendant contacted Plaintiff and
requested Plaintiff to prepare an estimate to do certain repair and restoration work.
6. At Plaintiff's first inspection of Defendant's home, Plaintiff identified work
that had to be done to prevent further loss and damage to the house. At that meeting,
Defendant authorized Plaintiff to do that work and agreed to pay Plaintiff for that
work. Thereafter, Plaintiff did the repair work necessary to prevent further loss and
damage to Defendant's home. Attached hereto and marked as Exhibit "A" is a written
estimate outlining that work which was done by Plaintiff and showing a cost or price
2
for that work of $1,351.02. Exhibit "A" describes the work done by Plaintiff .nd the
price which the Defendant agreed to pay for that work.
7. Thereafter. Defendant appointed her insurance company and its representative
as her agent to authorize and approve additional repair and restoration work to be done
by Plaintiff. Attached hereto and marked as Exhibit "B" is a copy of that
authorization.
8. By a written estimate dated 11 August 1992, Plaintiff proposed to Defendant
that it do certain repair and restoration work in Defendant's home in Hechanicsburg for
the price of $21,198.81. Plaintiff advised Defendant that its estimate was not
c~plete and that additional work might be necessary to repair all the damage done to
her residence. l\ copy of that estimate is attached hereto and marked as Exhibit "C".
9. FOllowing a review of the Plaintiff's estimate, Defendant, by her authorized
agent, requested and authorized Plaintiff to commence the repair and restoration work
and agreed to pay for that work by Plaintiff.
10. After completing a portion of the work on Defendant's residence. Plaintiff
discovered additional damage which required repair and submitted an estimate dated 16
October 1992 proposing to do that repair work for the total price of $3.069.54.
Attached hereto and marked as Exhibit "0" is a copy of Plaintiff's estimate of 16
October 1992.
11. FOllowing a receipt and review of Plaintiff's estimate of 16 October 1992,
Defendant's agent authorized and requested Plaintiff to do the repair work described on
said estimate and agreed to pay Plaintiff's price for that work.
12. After SUbstantially completing its work on Defendant's home, Plaintiff
discovered that it had miscalculated the carpet it installed in Defendant's home
pursuant to the contract between the parties. Plaintiff notified Defendant's insurance
J
carrier of that mistake and requested an additional payment of $459.BO for the carpet
installed above and beyond the contract between the parties. Attached hereto and
Marked as Bxhibit "B" is a copy of Plaintiff's letter explaining the lIistake and
requesting paYRent for the carpeting,
13. Plaintiff well and truly performed its obligations under the agreements
between tbe parties and has cOllpleted its work for Defendant in compliance with those
agreements in a good and workmanlike lIanner.
14. Defendant has received and retained all of tbe benefit of the work done by
Plaintiff to restore Defendant's home and repair the damage to it.
15. To date, Defendant has paid Plaintiff a sum of $14,000.00 for and toward the
work done by Plaintiff on Defendant's home.
COUNT I - CONTRACT
16. The averments contained in Paragraphs 1 through 15 hereinabove are
incorporated herein by reference.
17. By virtue of tbe oral agreement between tbe parties, Defendant is Obligated
to Plaintiff in the total amount of $26,085.23.
18. Plaintiff bas extended to Defendant a credit in the amount of S3.l95.02, for
work which the Plaintiff and Defendant agreed Plaintiff would not have to perform.
Attached hereto and marked as Exhibit "P" is a copy of the credit lIemo issued by
Plaintiff to Defendant listing the work for wbich credit was given.
19. Defendant is entitled to a credit in the amount of S14,OOO.00 for the
payments sho made to Plaintiff pursuant to their oral agreement.
20. Defendant owes Plaintiff a balance of S8,890.21, and has owed that balance
since 28 Hay 1993.
4
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ALEX R. SZELES, INC..
'\ I:IUILOERS' AI'f'RAISC:RS . HOME IMPROVEMENTS
SIlO LancBSler$lreet. Box 4456A ,
Harrlsburg,I'a,I7111
, (717) 561.()230
Sub.ldlnry ,
PRO-CLEAN
. IPAOFESSIO,NAlCLEANING SeRVICE)
2001 Oorn Road
Wyam'Slilng, 1'0,10610,
12151373-3709,
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SPEC,'ALlSTS,IN FIRE, SMOKE, AND W""rf=R DAMAGE RESTORATION
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FIRE DAMAGE EXPERTS
FULL SERVICE COMPANY
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CUSTOMER: 20 IV l} J). L .a 11 cA ,oJ.
1/10 /"Co(\c.<;lS1e", gLI';,
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We authorize Alex R. Szeles, Inc. to pro,ceed with all work
pertaining to:. ,
'~CI:~ANING .lv~.;.,-(,,... ~'1~(lC11~W' . -
8i(CONSTRUCTlON
lIR'REDECORA TI NG
l\;(DEODQRIZING
o ASSISTING US IN lOCATING A
TEMPORARY RESIDENCE
according to our discussion.
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It is our understanding that the only services to be
performed ,are those for which payment has been and/or will
be authorized by our Insurance Company. '
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We a/so hereby authorize our Insurance Company to pay
directly for ser.vlces performed to Alex R. Szeles, Inc. and/or
Include Alex ~. Szeles, Inc;'s name on the face of the Draft of
payment.
CUSTOMERrGNATURE "..", "',D.,~,&..,
WITN'" d'~~};;&~""""""'''''''' ~
, Plalntlff'a Exhibit
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Landin
KITCIIEN 13' X 11' X 0' WITII
5' X 5' X 0' OFFSET
.Remove ceiling lath with thin coat
plaster swirled finish - include.
protection of cabinets
.Install lath with thin coat plaster
swirled finish to ceiling
.prime and paint swirled ceiling
.Remove paper from upper walls
.Prep walls for paper
.Install vinyl paper
.Remove and replace chair rail
.prime and paint chair rail'
.Remove vinyl floornig on wainscoting
.Rep~ir drywall corner beads at archway
.Remove and replace vinyl floor
.Remove and replace ill undorlaymcnt
.Remove and replace baseboard
.prime and paint baseboard
.Remove and replace soffit trim
.Remove and replace hanging kitchen
light II P5025)
.Remove and replace vinyl base at
cabinets
^lIqUBt 11, 1992
QUANTITY
UNl'r
PRICE
~
MlITERIAL
5 hr9. 21. 00 105.00
160 sq. ft. 3.00 504.00
160 sq. ft. .60 100.00
220 sq. ft. .30 60,40
220 sq. ft. .20 45.60
220 sq. ft. 1.25 285.00
36 lin. ft. 1.50 54.00
36 lin. ft. .75 27.00
12 yds. 25,50 306.00
min.chg, 65.00 65.00
24 yds. 25.50 612.00
160 sq. ft. 1.10 184.80
36 11n. ft. 1.50 54.00
36 lin. ft. .75 27.00
22 lin.ft. 1. 20 26.40
1 ea. 147.50 147,50
18 lin. ft. 1.95 35.10
POWDER ROOM 7' X 4' X 8'
. Remove lath ceiling with thin coat
swirled plaster 2 hra. 21. 00 42,00
.Install lath with thin coat swirled
plaster on ceiling 28 sq.ft, 3.00 84.00
. Prime and paint ceiling 28 sq. ft. .60 16.80
. Removo paper from walls 176 sq. ft, .30 52.80
. Prep walls for paper 176 sq, ft. ,20 35.20
. Install vinyl paper 176 sq, ft. 1. 25 220.00
. Remove and reset ceiling Qxhnunl 1 hr, 21.00 21. 00
. Removo and replace vinyl floor 5 1/3 yds. 25.50 136.00
. Remove and replace I" undorlnymcnt 20 sC]. ft. 1.10 30,00
. Removo and rosot toilet 1 ca. 35.00 35.00
. Remove and replace baseboard 22 Un. ft. 1. 50 33.00
.prime and pilint bllscboard 22 Jin.ft. .75 16.50
.Refit door 1 hr. 21. 00 21.00
.Sand, stnin and varnish door 1 C~l. J2 .00 32.00
.Install v iny 1 UilSU llt vanity 2 Un. fl. 1. 95 .1.90
LAUNDHY HOOH 5 ' X 7 ' X 0'
.Suitl and lh1 llll t:eillllfJ J~ Hq. (t. .GO 2\.00
m'PICI': AIII:A 1',' :< 1 ~ I ;::__~I_~
. c le:li'~ri-;l'l. . ... ._-,-'
11111 !;'1.II. , ;'h .1(.,1111
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^"lplllt 11, IIJ!J:J
QlIfVf!'.!1:'!:
D^llEMt:NT S'r^lIlWAY Il' X )' X II' WITII
31' X 3 I' X II ' I,MW It!'! --- -.--,---..
. Romove and rUpl'1GU IJ lUll down CAr-put
on steps and 1",,,1111') 9 III ydn.
.Scrapo rubbor tJllt:kin'J trolll f1lt~IJ!J
snd landing 2 hrn.
FI\MILY ROOM 23' x Ill' X II' 1'I.lI:;
6' x 12' x U' -..---
.Install 6" coilinq iUIIUlilt1uII laid 011
grid
.Clean grid
.Install coilLng tL11I Ln grLd oyntum
.Ramovo and roplnco Cill'put
124' x 10' nnd 121 x fit ~
.Scrape rubbor bockill'J Crom f looru
STORIIGE nOOM 12' )( U' X II'
. Ins te 11 61l(;'ij11Tr"j-iiinliIii'llllll
.Cloan grid
.Inetell coiling lilu Ln grid nynlwn
. "omovo and rupl.lt:U fJ lUll down 10
carpol
.Scrapo rubbur hnekll1tJ from fluor
$ IO/,!i I'J.'/ J
_ .~ rl.~J-!_~I
111, .!"/1."10
1,112"1.1"1
J :. )-,-l~ILlj7
UMIEMENT 'WrH 6' x 4' X 61'
. Install 6IrmJl1Tii;J-riliiUTiltloll
.Cloen grid
.Install coLlin') 1.11"
.Cloan lilu fluul.'
GEtn:IIA'. 1 TEfW
.toaoctricall"nnpHt:lion illHI rUI',,!.rll
.Continunl COl1tulltll 1II11l111J1II,llloll
.CartmJlI ur duha-ln
.lIml11n'J lUIII diulHHllll 01 dohrin
.l)urmitn, 11\1I1"I1:t1111\ IllId III'Ill'l' V I II lOll
.fhl10ll '{'ilK UII I1hltor101 J Ih,101.(10)
. ."lnn 1 ': IIfUlllllq
Uubt.otOll
1U" {)vtllllll,ld
lU'f,1'11I111
TII'l'^I,
406 (HJ. ft.
406 0". Ct.
4116 DCJ.ft.
36 ydo.
406 DCJ. ft.
96 nq.ft.
96 nq. Ct.
96 n".ft.
2/3 ydo.
96 nq. ft.
24 1I'1.Ct.
H 0'1. Ct.
24 Ill]. ft.
24 "'1. ft.
I lot
20 hrn.
10 hrn.
I lot
I lot
16 lint.
:;III'lIli I' t I,d i1r,
^LI:,~; JI. !;U;I,I';::,
/, ,,!,! 1;'/'
UtU'l'
PRlet:
19.00
21.00
.U5
.20
1.00
19.00
.40
.85
.20
1.00
19.00
.40
.85
.20
I. 00
.12
(entimatcdl
21.00
21.00
450.00
525.00
21.00
lilt:.
'/ /1'
l',"/ .
, , /
MIITERIAL
~
177.27
42.00
413.10
97.20
486.00
684.00
194.40
81. 60
19.20
96.00
202.73
3U.40
20.40
4.80
24.00
2.011
300.00
420.00
210.00
450.00
525.00
366.06
336.00
17,519.73
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ALEX R. SZELES, INC,
IlUllOEI15. APPflAISEns. HOME IMrnOVEMENTS
61 10llne.sle, St,olll- 00. ....SOA
Harrlsbulg, ra, "111
17171501.0230
Subsidiary
PRO-CLEAN
(PROFESSIONAL CLEANING SEAVICFI
ES1'H1/\TE
@
2001 Oom Road
WyOmlssina. PI. 19010
12151313.31eQ
October 16. 1992
Page 1
TO: DDNI\LD CHUDll
GAD DUSINESS SERVICES, INC,
PO DOX 734
C/lMP HILL P/\ 17011
RE: /\DDITIONI\L WORK REQUIRED
ZONI\ LANDIS
116 LI\NCI\STER DLVD.
MECHI\NICSDURG PA 17055
SECOND FLOOR HALL 26' X 3' X 8'
.Paint walls and ceiling
STI\IRWI\Y 12' X 3' x B'
.paint walls and ceiling
.paint skirtboards
QUI\NTITY
542 sq,ft.
252 sq. f t.
24 lin. ft.
1 hr.
264 sq.ft.
FOYER 12' X 41' X 8'
.Spot seal walls
. Paint walls
FOYER - KITCHEN . POWDER ROml
.Additional for removal and replacement
of 5/811 sub flooring inntead of
1" lauan undcrlaymcnt 258 sq.ft.
POI~DER ROOM . SECOND FLOOR OI\'I'H
.Remove and reset (2) vanities -
Disconnect ~'nd reconlll.~ct sink
plumbinq due to sub f loor repl<lt:I~l1H!nt 2 ea.
MISCELLI\NEOUS
.Hental of dehumidifit~r!; .:lnd (all fl!';
per altilcl\l!d il\voiC:t'~i
'l'(J'I'td,:; {'uIITHIIII:!1 IHI 1'111;1: ,J,..
It PiIY:;
~(Q)fPW
UNI1'
PRICE H/\TERII\L LI\DOR
"i"J'~'~ ',','.
.40 216,80
.40 100.80
2.00 48.00
21.00 21.00
.40 105.60
.25
64.50
4~.()1l
90,00
11190.11
J.536.uf
Plalnlilf's Exhibit
l'afrU I.
I.nntllll I.ltltll 1.1011,11)
OCllllll!l' 1(1, 1992
Gulllol.l $ 2,536.81
10' OVtlrhuod 253.60
2,790.49
10\ Profit. 279.05
'J'O'I'^I, $ 3,069.54
Sullmi I.tl!d by,
ALEX n. SZELES, INC.
J. Miltoo Talcff
JMT/mru
'~J', ',' "
/
-'
ALEX SZELES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
V. :
I
ZONA LANDIS, I NO. 94-6849 CIVIL TERM
Defendant :
: CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, FEBRUARY 7, 1996, the court having been
informed that the parties have reached a settlement, the Board of
Arbitrators previously appointed is hereby vacated. The Chairman
shall be paid the Bum of $50.00.
By the Court,
"- (,-; \::=
H rold E. Sheel
Edmund G. Myers, Esquire - Coj"{j ,-,.....:L.(. :1./""/9".
Chairman..J ,7f1
Court Administrator
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