HomeMy WebLinkAbout95-03738
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5. Pefendanta, by and through their agent Nile Bmyaer,
oontraoted with Plaintiff for Plaintiff to lnatall a aandmound to
Petllndanta' pl'operty lounted nt 4 n Houth Low iaberry Road,
Lewisberry, York County, Pennsylvnnla.
6. Set instnllatlon wns to bo puraunnt to Permit No.
L42194. Defendnnts have II copy of anld Permit, thus it ia not
attaohed to this complaint liB an Exhibit,
1. When Defendants' ngent, Nile Smyser, initially
approaohed Plaintiff with regard to Plnintiff installing a
aandmound, Plaintiff could not provide Defendants' agent with an
exact quote because numerous treos noeded to be removed f.rom the
property before the installation of the sand mound could begin.
8. After said trees were removed by Defendants, Plaintiff
verbally quoted Defendants' agent a f.ee of. $14,000.00 to
$14,500,00 plus the extras needed for the sandmound system.
9. Plaintiff installed the sandmound to Defendants'
property located at 411 South Lewisberry Road, Lewisberry, York
County, Pennaylvania pursuant to Permit No. L42194.
10. Plaintiff installed said sandmound pursuant to aaid
Permit No. L42194 and according to industry standards.
11. At no time has Defendant advised Plaintiff of any
diaaatiefaction with the installation by Plaintiff of Defendants'
aandmound.
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1~. Plnlntirr hns providod Dotendnnts with un invoioe for
prore~~lonul servicell rendered. ^ copy of snld invoioe is
attaohod this Compl,lllnt /HI I,;xhlhlt "A", IInd by rerorenoe is
Inoorporutod horoin nnd mndo II pnrt horeor.
13. Despite demand by Pllllntlft, Defendllnts hnve refusod to
pay said invoice,
WHEREPORE, Plaintiff respoctfully requost jUdgment in favor
of Plaintiff. and against Defendants In the amount of sixteen
Thousand Two Hundred Eighty-Pour Bnd 30/100 ($16,284.30) Dollars,
plus intorest at the legal rate of interest, plus cost of suit.
CO UN'!' I I
In the alternative, Plaintiff pleads the fOllowing oause ot
aotion I
14. Paragraphs 1 though 13 above are inoorporated herein by
referenoe as if fully set forth herein..
15. The charges and fees charged by Plaintiff for the
professional sand mound installation services provided to
Defendants are just and reasonable and are comparable to oharges
and fees charged by other professional sand mound installere of
eimilar quality and reputation for similar work and servioee.
16. Petendante, Kenneth R. Caffrey, Jr. and Vicky s.
Caffrey, accepted, and beneHted from, the professional sand
1''MIIWI1UAI1IIH(~lIIh'INI''''
mound installation servloes provided for by Plaintiff as
disoussed in Count r above.
17. Defendants knew that Plaintiff had been hired to
perform the s~nrl mound Installation servioes more fully desoribe
in Count I above and tuok no Btepa to prevent Plaintiff from
oompleting said sand mound lnBtallntion.
18. Despite Plaintiff/s proper completion of the work
oontraoted for, and repented demands by Plaintiff for payment/
Plaintiff has not been paid for the installation of the sand
mound as invoiced. A copy of the Plaintiff/s invoioe to
Defendants iB attached hereto as Exhibit "A" and by reference
incorporated herein and made a part hereOf.
19. The total amount due Plaintiff by Defendants for the
professional sand mound installation services rendered is Sixteen
Thousand Two Hundred Eighty-Four and 38/100 ($16,284.38) Dollars,
plus interest at the legal rate of interest.
20. Defendants, as OWners of the premises known as 417
South Lewisberry Road, Lewisberry, York County, Pennsylvania,
benefitted from the prof3ssional sand mound installation Bervices
provide and rendered by Plaintiff.
WHEREFORE, Plaintiff demands judgment in his favor and
against Defendants, jointly and severally, in the sum of Sixteen
Thousand Two Hundred Eighty-Four and 38/100 ($16/284.38) Dollars,
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