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HomeMy WebLinkAbout95-05348 ()',i Ii!!:' I ,t' :1 i i. i i .;i, i ! d 'I ,,: ,\ HIl il q H,_I! I ii, j:! < I. . i! t 'I ': 'I ji!;)'I!. !!i j IJl'P'll.'l Ili:1 hlll.!l! I I Ii Hi 1 ,)II!; i Iii I h', \;!l\'>" I II II III ;11 I iiijl.:,Jj,',i tl!'I.I:! 'I IlllJl I (;llilly. \l('ll1\' '/11".-,111,\., ,M1I1 l,.,.i\HJ dul'l \'_,hl". :;i"(", ,,1 l,\ll,il ill ,,'i ~5IHH'i i"f nr l)pputy GI\l,I','i 'f f n f !:FY!'\ i dl 'I 'i) j.dllll! tqH )ll ii1. Hill !.l'Il' \iJt lilll'l Illl'.ill! fJ.l.lIJ Ul' . 1\1 !.l,I.-J.. Iji~'JI"i.'ni;i 11U\!1,::i~ '._111 tile IO'I;l\ ll'iY UI O\,':t:q'H',,- i! \ ' . I I ~ i 1_ \l I , 01'11' ; I 11.1 ','II :'U11. ,\illtl (1"IOI!1 F !!Dill' ';jlI[1 .\ I'. .\ L ., I. I'!,I,,! 1.,1,1\.' Ii' WI'." U(.JIJIJ': 1.11 jlllld' CO \,j\ld,'/,-, 1'1 11l\.:--j \.;\\ 1.1"1 II:< li,,'.;,d 111'1 1.0 t:d! 1j,;;IH 111['11'1 (, Ii'll ,q-Id ,\1 jill' i 1111' >\llll I-,tt.'-; \;q:l I,'UII',.' (If 1111 tIll' "\ q' f . ',);1' IlIIH' ili "'.c'i.'I.ltlll It,l' "I Lt'lltJUll tn 1,111' 1,1'-111 '1,\ "" .;' i I I ' " ",_,:.1" 1\( HI {' L I Illl ~ "', .', \/ I I I,' Ii 1 II d.t...., \ l;lll'l'll.\,II!f> '.[1 " 1 , " .:14~ j' 'it Chu- "I ',Ii '-t'j)-,U\" ..~~~~~ 111..liI i ,I ~ l},.j ~ l'~n r'~ 1'!F1 F "j'h, ,1[: 'j ":;,,J...'j ;,iJi I lliiL! I; I'd: 11j, III,' ;'j, ,I i ! ; t ~ R~ ., , " (ll~ q: )il~ 1.lJP,' BOROUGH OF MOUNT nOLLY SI'R1NGS. I' lnintif C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 5348 CIVIL 1995 !lARB CO.. CIVIL ACTION - LAW Defcndant RULE 1312~l, The Petiti~n for Appointment of Arbitrators shall be substantially in the following forml PETITION FOR APPOUtnlENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Keith O. !lrenneman , counsel for the plnintiff/~"1IdJA1 in the above 1. 2. action (or actions), respectfully represents that: Th. above-captioned action (or actions) is (are) at iasue. Th. claim of the plaintiff in the action is $13,411.08 Th. counterclaim of the defendant in the action is 0 .The following attorneys are interssted in thQ wi.. disqualified to sit as arbitrators: case(s) us couAsal or lire other- Keith O. Ilrenncman, Esquire. WHEREFORE. your petition.r pray. your Honorable Court to appoint three (3) arbitrator. to whom the ens. .ha11 be submitted. kt~d, Keith O. Ilrenneman Dntel December 11, 1995 AND NOW. ORDER OF COURT , 19~. in con.ideration of the Esq. ,liMn, '/Itw ./JAY! ".5-- Elq.. and ,Esq.. are appointed arbitrators in the above-caption.d action (or actions) as prayed for. B\e ~o~rt l \, ~/ /' P. J. . ,I .... ~ i N .. e 8$ :r. ~ ~ oCI: p::j r,o,j ~in I 8: - -~ ~ c.., ~ Ii) .n lJ.J 1:90.. ..... 0 u. In t3 " 0 a> -.,. FllJi' n:I"'~ .' , 1\,./. , '0,'. ,i "'''',1' , ~ 11 ~<i I;' ~ . . /" /- I ,.1 ,: ::: 15 Ct. . FiJi",.. L""V" ...I..JIi' II '.....,. '''\ ., \~. HI - s ~ ..... .... .... '"....~.. 2'~Qa ..,nu..... _::"0> a~. '.c-' c:,:i4ft:;; tju.;r'z _. Wi"''' ~:a:ml.M ..:r..... ...=> ",'" ~ :! .' ~I~ .1 II II! g I ,., Clo 0 u E t: 0 U '0 :; u 2 ~ :~ .c II o .. ~... .. 0 :S11 ce 'E ~ .ll U'M >-..~ , . '3 0 I . .. . II u " I . .c~ -. - ... 0 .. .' CUNNINGHAM & C,tiERNICOFF, P.C. , .' . . . BOROUGH OF MOUNT HOLLY SPRINGS, I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 95 - 5348 CIVIL TERM BARB CO., CIVIL ACTION - LAW Defendant ANSWER TO COMPLAINT AND NOW, comes Defendant, Barb Co., by and through ite coun..l, cunningham' Chernicoff, P.c., and fil.. it. Anewer to the Complaint filed by the Borough of Mount Holly spring8, and in support thereof, avers as follows: 1. Admitted. 2, Admitted. 3, Admitted 4, Admitted. . . 5. The Defendant is without knowledqe lufficient to form a belief as to the truth or veracity of the avermentl contained in paraqraph 5 of the plaintiff's Complaint and strict proof of the same, if relevant, is demanded at the till. of trial. 6. Admitted. 7. Admitted. COUNT I B. The answers contained in Paraqraphs 1 throuqh 7 are incorporated herein by reference as if more fully set forth. 9, Admitted. 10. The Defendant is without knowledqe sufficient to form a belief as to the truth or veracity of the averments contained in Paragraph 10 of the plaintiff's Complaint and striot proof of the same, if relevant, is demanded at the time of trial. 2 --~~,-!'''r-~..,..",,--~}.., , .' 11. The Defendant is without knowledge sufficient to form a belief as to the truth or veracity of the averment. contained in paragraph 11 of the plaintiff's complaint and strict proof of the same, if relevant, is demanded at the time of trial. 12. The Defendant is without knowledge sufficient to form a belief as to the truth or veracity of the averments contained in paragraph 12 of the plaintiff's complaint and strict proof of the same, if relevant, is demanded at th. till. of trial. 13. Denied. It is specifically denied that Defendant has consistently failed and refused to pay plaintiff in full for charges assessed Defendant for water, sewer and trash services provided to Defendant at Defendant's premises for the period of April 1, 1994 through June 30, 1995. By way of further response, payments have been sent, however, payment. were applied by the plaintiff to alleged arrearages, the payments for which had already been agl'eed upon per the term. of an Agreement reached between the plaintiff and the Defendant, and which the plaintiff has failed to attach as an appropriate exhibit to their complaint. The most recent 3 payment made by the Defendant to the plaintiff was in the amount of Four Thousand Ninety Five and 00/100 Dollare ($4,095.00) which was sent to Plaintiff's counsel on October 18, 1995. 14. Denied. It is denied that Defendant has failed and refused to pay the total amount of Thirteen Thousand Four Hundred Eleven and 08/100 Dollars ($13,411.08) allegedly due and owing Plaintiff for water, sewer and trash service provided to the premises from April 1, 1994 through June 30, 1995. By way of further response, Defendant has attempted to make payments to the Plaintiff for water, sewer and traeh services provided for the premlBes, however, plaintiff hae applied the payments made by the Defendant to alleged arrearages which had been the subject of an additional and separate Agreement reached between the Plaintiff and the Defendant which the Plaintiff failed to attach ae an appropriate exhibit to their Complaint. 15, Admitted. 16. Denied. It is denied that the amount billed by Plaintiff to the Defendant for water, sewer and trash services 4 provided Defendant's premises were fair and reasonable. By way of further response, the amounts billed by the Plaintiff to Defendant for water, sewer and trash services are usurious. 17. Admitted in part. It is admitted that Defendant bills tenant-.i of the mobile home units located on the premisss for water, sewer and trash services either directly for such services or by inclUding such service costs in the rent charge for its tenants. By way of further response, Defendant has only recently started to bill tenants of the mobile hOlDe units located on the premises for water, and Defendant began to bill the tenants of the mobile home units on March 23, 1993 for water. Defendant began to bill the tenants of the mobile ho.e units for sewer and trash services approximately one (1) year later. 18. Denied. It is denied that in spite of Defendant billing its tenante and receiving payment from its tenants for water, sewer and trash services, Defendant has refused and intentionally failed to remit to plaintiff or pay Plaintiff 5 , ~.r.', for .uch .ervices billed to Defendant. By way of furthel' response, Defendant has only recently lltarted to bill the tenants for water, sewer and trash services. 19. The avelments contained in Paragraph 19 of the Plaintiff's Complaint represent conclusions of law to which no response is required. In the event a response ill required, the averments of Paragraph 19 are denied. WHEREFORE, Defendant respectfully requellt. that thiB Honorable Court enter judgment in its favor and against the Plaintiff, and dismiss the Plaintiff's Complaint with prejudice and further award Defendant all such other relief a. iB proper and just. COUNT II (In the alternative to Count I) 20. The answers contained in Paragraphs 1 through 19 are incorporated herein by reference as if more fully set forth, 21. Admitted. 6 " 22. Admitted in part and denied in part. It is admitted that the charges for the water, sewer and trash service. a. more fully set forth in Count I of the Plaintiff's Complaint were not objected to by the Defendant. It is denied that the charges for the water, sewer and trash services a. .et forth in Count I of the Plaintiff's complaint are fair, customary and reasonable. 23. The averments contained in paragraph 23 of the plaintiff'. complaint represent conclusions of law to which no re.ponse is required. In the event a response i. required, the averments of Paragraph 23 are denied. 24. The averments contained in Paragraph 24 of the plaintiff's Complaint represent conclusions of law to which no re.ponse i. required. In the event a response i. required, the averments of paragraph 24 are denied. WHEREFORE, Defendant respectfully requests that this Honorable Court enter judgment in its favor and against the 7 . Plaintiff, and dismiss the Plaintiff's Complaint with prejudice and further award Defendant all such other relief aa i8 proper and just. Respectfully submitted, CUNNINGHAM' CHERNICOFF, P.C. Date I Novelllber 1995 B~tiIM'-"'.r..:J,'IA~ (J.:J......~, t+tu.-1 Paige Bacdonald-Matth.., Esquire I.D. 166266 2320 North Second Stre.t P.O. Box 60457 Harri.burg, PA 17106-0457 (717) 238-6570 (Attorney. for Defendant) 8 . , VIIR1I'IC&'1'IO. I, Georqe J. Adams, verify that the .tate.ent. .ade in the foreqoinq Answer to Complaint are true and correct to the best of .y knowledqe, information and belief. I understand that fal.e state.ents herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relatinq to unsworn falsification to authorities. Date I 11-/3.9'1' ~ CERTIFICATE OF SERVICE I, Paige Macdonald-Matthes, Esquire, do hereby certify that a true and correct copy of tho Answer to Complaint in the above-captioned matter was placed in the united States Mail, first class deliver, postage prepaid in Harrisburg, Pennsylvania on November /4, 1995, on the following: Keith O. Brenneman, Esquire Snelbaker , Brenneman 44 We.t Main Street Mechanicsburg, PA 17055 (Attorney. for Plaintiff) Respectfully submitted, CUNNINGHAM' CHERNICOFF, P.C. Date: November /1. 1995 ~ '"'\ By: '--^..O'~ J...'(,..,^..l'l"'~ -~l~ Paige Macdonald-Matthes, Esquire 1.0. '66266 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 (Attorneys for Defendant) 9 " LAW O,FlCI:_ 6NnnAKER II BneNNEMAN BOROUGH OF MOUNT HOLLY SPRINGS, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95- SJ'ifJ' CIVIL TERM v, BARB CO., CIVIL ACTION - LAW Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set fQrth 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 a 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. court Administrator One courthouse square carlisle, pennsylvania 17013-3387 (717) 240-6285 SNELBAKER & BRENNEMAN, P. c. By,i~ Attorneys for Plaintiff LAW a'Ple... 6NELDAKER II BRENNEMAN BOROUGH OF MOUNT HOLLY SPRINGS, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95- S 3~ CIVIL TERM CIVIL ACTION - LAW Plaintiff v. BARB CO., Defendant COMPLAINT The Borough of Mount Holly springs, by its solicitors, Snelbaker' Brenneman, P. C., files this complaint against Barb Co. as follows: 1. Plaintiff Borough of Mount Holly springs is a duly authorized and existing political sUbdivision with a place of business and office address at 200 Harman street, Mount Holly springs, cumberland county, Pennsylvania. 2. Defendant Barb Co. is a Pennsylvania business corporation maintaining an office or principal place of business at 3780 Trindle Road, suite 3, Camp Hill, Cumberland county, Pennsylvania. 3. Defendant is an owner of a parcel of real estate located at Mountain and Park streets in the Borough of Mount Holly springs, also identified by tax parcel No. 23-32-2338-038 (hereinafter "premises") which premises is utilized by Defendant as a mobile home park, containing approximatelY 25 mobile home units, whose owners lease, inter AliA, lot space from Defendant, 4. Defendant is provided at its premises, for its and/or its tenants' use and benefit municipal water, sewer and trash services by the Plaintiff and the Hount Holly springs Borough Authority. 5. Plaintiff is the duly authorized agent and/or lessee of the Hount Holly springs Borough Authority responsible for the management, maintenance and operation of the water and sewer systems servicing Defendant's premises and as such, is responsible for billing and collecting assessments and charges for water and sewer services provided Defendant. 6, Defendant filed a voluntary petition under Chapter 11 of the united states Bankruptcy Code in the united states Bankruptcy Court for the Middle District of Pennsylvania on December 8, 1992. 7. By Order of court dated september 1, 1995, the Bankruptcy Court terminated the automatic stay in the bankruptcy proceeding with respect to the Plaintiff, thereby permitting Plaintiff to exercise all remedies available to it against Defendant and its property. A true and correct copy of the aforementioned order of September 1, 1995 is attached hereto and incorporated by reference herein as "Exhibit A", -2- LAW DfflClS GNELDAKER ft BRENNEMAN COUNT I 8. The averments of Paragraphs 1 through 7, inclusive, of this complaint are incorporated by reference herein in their entirety. 9. At all times relevant hereto, specifically from April 1, 1994 through June 30, 1995, Plaintiff provided Defendant (and through Defendant, Defendant's tenants) with water and sewer services and trash removal services at Defendant's premises. 10. The water services provided Defendant by Plaintiff as described above were provided in accordance with the terms, conditions and requirements as set forth in Mount Holly Springs Borough Code of ordinances Chapter XXIV, as amended. 11. The sewer services provided Defendant by plaintiff as described above were provided in accordance with the terms, conditions and requirements as set forth in Mount Holly springs Borough code of Ordinances, Chapter XVIII, as amended. 12. The trash removal services provided Defendant by plaintiff as described above were provided in accordance with the terms, conditions and requirements as set forth in Mount Holly springs Borough Code of ordinances, Chapter IX, as amended. 13. Defendant has consistently failed and refused to pay plaintiff in full for charges assessed Defendant for water, sewer -3- LAW O"ICU SNELDAKEA a BRENNEMAN 'i";,~.,,,,\,-.,, ' ." and trash services provided to Defendant at Defendant's premises for the period of April 1, 1994 through June 30, 1995 despite repeated requests to do so by both account statements delivered to Plaintiff and communication by Plaintiff's counsel. 14. Defendant has failed and refused to pay the total amount of $13,411,08 due and owing Plaintiff for water, sewer and trash services provided the premises from April 1, 1994 through June 30, 1995. 15. The amounts billed by Plaintiff to Defendant for water, sewer and trash services provided Defendant's premises were never objected to by Defendant. 16. The amounts billed by Plaintiff to Defendant for water, sewer and trash services provided Defendant's premises were fair and reasonable. 17. Defendant bills tenants of the mobile home units located on the premises for water, sewer and trash services either directly for such services or by including such service costs in the rent charged its tenants. 18. In spite of Defendant billing its tenants and receiving payment from its tenants for water, sewer and trash services, Defendant has refused and intentionally failed to remit to Plaintiff and/or pay Plaintiff for such services billed to -4- Defendant. 19. Defendant's failure timely to pay for water, sewer and trash servicos provided Defendant's premises is a material breach of Defendant's express and/or implied obligation to pay for same in accordance with Plaintiff's then current rates and service charges. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $13,411.08, together with interest and costs of this action. COUNT II (In the alternative to Count Il 20. The averments of Paragraphs 1 through 19, inclusive, of this Complaint are incorporated by reference herein in their entirety. 21, The water, sewer and trash services provided by Plaintiff to Defendant at Defendant's premises were not provided by Plaintiff to Defendant as a gratuity. 22. The charges for the water, sewer and trash services as more fully set forth in Count I of this complaint were fair, customary, reasonable and never objected to by Defendant. LAW o'"cu SNELUAKER II BRENNEMAN 23. Defendant wrongly secured benefits from the use of the -5- LAW O,'ICU SNELDAKER a BRENNEMI\N water, sewer and trash services provided Defendant's premises that would be unconscionable for Defendant to retain. 24. Defendant has been unjustly enriched at the expense of the plaintiff in the amount of $13,411,08. WHEREFORE, plaintiff demands judgment against Defendant in the amount of $13,411,08, together with interest and costs of this action. The total claims of plaintiff in this action, exclusive of interest and costs, do not exceed the jurisdictional limits ~or mandatory arbitration in cumberland county, SNELBAKER , BRENNEMAN, P. c. By: Ke th a.Brenneman, Esqu re 44 West Main street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for plaintiff Borough of Mount Holly springs Date: October 5. 1995 -6- '. LAW O,.'ICU 6NELDAKER a BRENNEMAN VERIFICATIQli I verifY that the statements made in the foregoing complaint are true and correct. I verify that I am authorized on behalf of the plaintiff, Borough of Mount Holly springs, to execute this Verification for the plaintiff as the utility Billing clerk. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification to authorities. ~)1tt;;J ~ '~~A 1 Amy L. M ller, ut 1 ty Billing Clerk Date: 10 -!; - q s;- II,. , , ,.11'7.1 ) ) } ) ) ) \ 19 In Tha Court of CODmon Pl.as of or Cumberland County, ?enna~lvania CI r:- s- -) ''/ c;- ~o.L.l-t (.) lY ~,ic {(J" OAnt We do aolemnly swaar (or affirm) that we will support, obey and deiend the Coaetitution of the United Statea and reConstitution oi this waalth and that we will diacharsa the duti'~ of our oifice with fi AWAllD We, thl under.ilded arbitrators, having been duly appointed and sworn (or &fUmed), uke the follovinl avardl (Notal It damasa. for delay ara awarded, thay shall be eaparately Itatad.) Ipplicable. ) Arbitr~to (Insert ( e>; Date of aaariDsl (1/ - l -) /" r.-ij. OaU of Avard I ..J.t - 7- ) c' , -.. ' '" " 'Y'l,.-J/( ~ ~OTIC! OF ENTRY OF AWAllD Nov, the.l'k.lday of "'-J""L I~rd waa entarad upon the aockec partie. or their attorneys. . 19 :LL, at'La-, 11...:1.. the above and notice cherlof siven by mail to the _.J...cld"l'':'\.'" c ( ll."l/~" 1-. . ?rothonotary Arbitrator.' co~en8acion co be paid upon appeal I $ ;J "~'UV Byl (. I' . __.... j!itlfL.~..;"" )],. .'f,. i ' D8put~1 '"It.. ". A} J . (,...../e... tv ~tL. V'L<..fu...... .'~ -AUf W ..ML " . J,( S" n \0 F: ...., 0 '. ~:.; " iF/. ~ I, c i1j'TJ !f;'~ i : ". t,", I i~ ~ l-"j c: r',~ .:.;,,,., ::H y;; .. ID ,.~ ."ff .', .. . , ~:' ...,J ~ t f. ~ -f~~ , ~ \" ~' \ \J V ~ ... -.. LAW O"ICII SNELOAtCE:n, BRENNEMAN a SPARE BOROUGH OF MOUNT HOLLY SPRINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA plaintiff NO, 95-5348 CIVIL TERM v. BARB CO., CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARY: Please enter judgment against Defendant Barb Co. and in favor of plaintiff Borough of Mount Holly springs in the above action in the amount of $2,316.08 plus interest and costs of suit in accordance with the Arbitrators' Award entered June 2, 1997 in the above matter. SNELBAKER, BRENNEMAN , SPARE, P. C. By: re Date: July 14, 1997 . -. LAW O,,,CII BN!LBAKER. BftlNNEMAN a SPARE '_-:"3.0':._,''',,__-' t.-.. CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Paige MacDonald-Matthes, Esquire cunningham' Chernicoff, P. C. P. O. Box 60457 Harrisburg, PA 17106-0457 J4A~ Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN , SPARE, P. C, 44 West Main street P. o. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for plaintiff Borough of Mount Holly springs Date: July 14, 1997 "'l- .-- {:. l~.~ c . . i~ .:~ lU~' ~.. (.~; .' .". I'.' 1'- !-i- L)( , I fJ, ...1, lI:" . ::.~ i. t':j ~ " ." ~ ~ ~ >1 ~ \.., ~ s (~ . ~ ~ "I..c) ., ~ i "- \\ }:IJ ~ . Il\.- i ~~ C' ~ ,. LAW O"ICn BNELBAKER. B..INNIMAN a SPARE BOROUGH OF MOUNT HOLLY SPRINGS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 95-5348 CIVIL TERM BARB CO., CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARYt Please mark the judgment entered in favor of the Borough of Mount Holly springs against Defendant Barb Co. in the above action "satisfied" upon your docket and indices, SNELBAKER, BRENNEMAN , SPARE, P. C. , R~-MNC.. ~o~renneman, Esquire 44 West Main Street Hechanicsburg, PI. 17055 (717) 697-8528 Attorneys for Plaintiff Borough of Mount Holly Springs By: Date: 1'1 Ai-......... "" "_ _...., ~""" ;'i~'/'=O'" .... -. E; ~ l"; .. r.:, etP C\: l~)::..~ '- 3/" i:C i.,J:..,' ""',:::j r. :,;. I',. 01 "";n L. - )'.. -'H' ::>. '''":-,,, f: r.:" , Ir,] :.:c !:J~ i::; ,.... a 01 .~ ,- LAW O"ICII SNILIIAKEIt, eftlNNEMAN a SPAnE CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the toregoing Praecipe to be served upon the person and in the manner indicated below: Date: if N~"ClltIJt. "'" FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Robert E, Chernicoff, Esquire Cunningham' Chernicoff, P. C. P. 0, Box 60457 Harrisburg, PA 17106-0457 ~~ Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN , SPARE, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Borough of Mount Holly Springs ~ -' .,. C'; l:; 1-' (~ ?~3:~ lI~P I " :::: , .. " , li, u. -.,::! I") (.71 '(.1 " .' -' ;::~ . I... i.i:'" ~. liii} r~: CJ ,"'.lU, ;.: II. r- d 0 lJ' .~