HomeMy WebLinkAbout96-00099
proposal for electrical and plumbing work. By way of further
answer, Defendant Keith R. Grove requested, and Plaintiff agreed,
to provide all-inclusive proposals in writing because Defendants
needed such proposals in writing for their bank which funded the
construction,
It is denied that it was agreed the estimate would be
revised at a later time. To the contrary, no such agreement was
reached, and Plaintiff specifically advised Defendant Keith R.
Grove that even through some minor items were not specifically
noted in the proposal for electrical work, the all-inclusive
figure given for his services - $3,454.00 - was his quote for the
electrical work, Finally, it is admitted that a copy of
Plaintiff's plumbing estimate is attached as part of Exhibit A to
Plaintiff's Complaint, It is denied that a correct copy of the
electrical estimate given Defendants is attached as part of
Exhibit A to Plaintiff's Complaint,
5. Denied, Paragraph 5 of Plaintiff's Complaint contains
an unwarranted conclusion of law to which no response is required
pursuant to Pa.R.c.p, 1029(d); therefore, same is deemed to be
denied, To the extent a response is necessary, there was no
LAW O"'ICEO
SNELB41<ER
a
BRENNEMAN
agreement between the parties that Plaintiff would charge or
Defendants would pay on a time and material basis or that any
agreement reached between the parties would be subject to
-2-
LAW O',ICU
SNELBAKER
lit
BRENNEMAN
....-.....<' ~:
Plaintiff's impending surgery schedule. To the contrary, the
"essence" of the agreement between the parties was that Plaintiff
was to complete electrical and plumbing rough-ins in accordance
with his proposals, in a reasonably workmanlike manner, which
Plaintiff failed to do, By way of further answer, neither
Defendant knew or was advised at the time Plaintiff's proposals
were accepted that Plaintiff was scheduled for surgery,
6. Admitted,
7, Denied, It is denied that Plaintiff began his work in
the home the last week of July, To the contrary, Plaintiff
commenced his work before mid-July. It is further denied that
Plaintiff was given 3 to 4 days to complete both the electrical
and plumbing rough-ins and that it would take him 10 days to
complete the work himself, It is also denied to the extent it is
expressed or implied, that Defendants placed Plaintiff under any
time constraints and that because of such constraints Plaintiff
was required to hire additional laborers to assist him. To the
contrary, had Plaintiff made a reasonable effort to perform his
contractual obligations in a reasonably workmanlike manner,
Plaintiff could have completed his work without being under any
time constraints which were self-imposed by his actions and/or
inactivity,
8, Admitted in part; denied in part. Although it is
-3-
admitted that Plaintiff did work in the house after surgery,
after reasonably investigation, the Defendants are without
sufficient information to form a belief as to the truth of the
allegation that Plaintiff completed work on the home September
19, 1995; therefore same is deemed denied and proof thereof
demanded, It is averred however that by September 19, 1995
Plaintiff had not completed his work,
LAw O".CU
SNELBAICER
III
SftENNEMAN
9. Denied, It is denied, to the extent it is implied, that
the list identified as Exhibit B and attached to Plaintiff's
Complaint sets forth both the work completed by Plaintiff and
materials furnished. It is further denied, to the extent it is
implied, that all the work indicated on Exhibit B was completed
or that all specific items thereon were in working order.
Finally, it is denied, to the extent it is implied, that Exhibit
B represents a correct list of labor and materials for which
payment is due Plaintiff, To the contrary, the attached listing
contains items not agreed to by Defendants, items not within the
scope of the plumbing and electrical proposals, items which were
not completed, items not in working order as well as items
intentionally and maliciously damaged by Plaintiff for pUrposes
of interfering with Defendants' efforts to receive an occupancy
permit, move into their home and receive the final draw from the
bank.
10, Admitted, with the qualification that the payments were
-4-
COUNTERCLAIM
Keith R. Grove and Mary Beth Grove v. Norman Elam
29. The averments of Paragraphs 1 through 28, inclusive,
above, are incorporated by reference herein in their entirety.
30. On or about May 20, 1995 Plaintiff Norman Elam
presented Defendants with a quote for rough-in of plumbing for
the home intended to be built by Defendants, A true and correct
copy of the quote is attached hereto and incorporated by
reference herein as "Exhibit 1".
31. On or after May 20, 1995, Defendants, through Defendant
Keith R. Grove, accepted the quote presented by Plaintiff.
32. During the course of Plaintiff's work under the
plumbing quote accepted by Defendants, Plaintiff and Defendants
reached certain agreements concerning additional plumbing work by
Plaintiff to be performed (hereinafter "change orders").
LAw O'''CE:.
SNELBAkER
1II
BRENNEMAN
33. During the course of Plaintiff's work, Plaintiff and
Defendants agreed to change orders respecting plumbing work to be
performed by Plaintiff in the basement powder room, the laundry
tub rough-in, the hook-up of exterior water service from the curb
box and the washer pan in the laundry of the second floor. These
additional items agreed to by the parties totalled $619.60,
34, On or after May 19, 1995 Plaintiff presented Defendants
-8-
LAW O"ICE8
SNELBAKER
III
BRENNEMAN
the amount of $450.00, plus interest and costs of this action.
COUNT II.
45. The averments of Paragraphs 1 through 44, inclusive,
above, are incorporated by reference herein.
46. Plaintiff, in the course of performing services for
Defendants in accordance with the electrical rough-in quote and
change orders failed properly to complete and/or install the
following items, among others:
a. wire the door chimes;
b. place and connect the post light;
c. wire water heater at proper location;
d, connect two exterior lights;
e, provide and wire spot light outlet;
f. provide, check for or place nailers for exterior
lights;
g. repair, replace or reinstall broken and crooked switch
plates;
h, provide an access hole for kitchen wiring;
i. install glass in light in foyer;
j . install lights and fans; and
k. install cook top,
47. plaintiff's failure to properly install and/or complete
the above items constitutes a material breach of the electric
rough-in contract between the parties,
48. As a direct, proximate and factual result of
Plaintiff's breaches aforesaid, Defendants have been damaged in
the amount of $2,453.63, representing the costs necessary to
modify the rough-in work done by Plaintiff, complete
-11-
installation, repair the deficiencies made reference to above and
conduct a complete service review and inspection.
WHEREFORE, Defendants demand judgment against Plaintiff in
the amount of $2,453.63, plus interest and costs of this action,
COUNT II r.
49, The averments of Paragraphs 1 through 48, inclusive,
above, are incorporated by reference herein.
50. Plaintiff impliedly warranted to Defendants that he
would use reasonable and ordinary care and skill in the
application of his professional knowledge to accomplish the work
pertaining to Defendants' home,
51, Plaintiff impliedly warranted to Defendants that he had
ordinary skill and ability in his business and profession and
would exercise same in the performance of his work pertaining to
Defendants' home,
52, Plaintiff impliedly warranted to Defendants that the
work Plaintiff did at Defendants' home would be done in a
reasonably workmanlike manner.
LAw O'"cu
SNELB~KER
a
BRENNEMAN
53. Plaintiff failed to perform his work in Defendants'
home in a reasonably workmanlike manner free from the various
defects and deficiencies made reference to in Count I and Count
-12-
11IB GROVE'S HOME, LOT 63, 11iE OAKS, BO~G SPRINGs, PA
. .
QUOTE FOR ELECTRICAL ROUGH.IN WITH RECEPTACLES AND
SWlTCHES.
I. 200 A!IP SERVICE S 450.00
2. 100 OUl'LBTS @ SI5.oo - 1500.00
~10 3.WAY O~S . @ 14.00 ___. ..,m-M::-'"
16 CANDLE OUTLETS. _. @ 15.00. - -- 240.00
.5 PAN Otm.ETS @ 11.00 - - 90.00
6.6 PHONE OUTLETS @ 10.00 - 60.00
7.6 TV.oUTLETS @ 12.00. - 72.00
1.1 SPOTlJTEOUTLET --@ 17.00 - 17.00'
9. 3 SMOKE DETBCTOR OU1l.ETS @ 12.00 . 36.00
10.IBXHAUSTPANVENTED~m@ 20.00 -20.00
11.2 EXHAUST FANIU~ u:,~... 25.00 50.00
12. I poST lJTE CIRCUIT . @ 21.00 21.00
13.1 WASBEROUTLET @ 25.00 . 25.00
14. I DRYER OUTLET (I 60.00 50.00
15. I MICROWAVE OUTLET . @. 25.00 - 25.00
fil)1 DISHWASHER OUTLET @ 25.00 - 25.00
'rf. I DISPOSAL OUTLET . 2100. - 25.00
II. I GAS WATBlUIEA'I'BIl OU11.BT . . 15.00 . - 15.00
19. 4 OPI allCUlTS . . . 35.00 - 140.00
20. 1 All. CQNDmONER CIllCUlT - . 60.00 - 60.00
21. 5 UCJ!.lJS ums . 45.00 - - 225.00
22. I BASEMENT POllrRr ."'l UTES.... 13.00 - 104.00
23. DOOR aDNE WIRING ..--.- . 15.00"'- .--. -- .15.00 -
TOTAL
.
~~J_
S '
NOTE; nns DOES NOT INCLUDE LIGHI1NG FIXTlJRES EXCEPT RECESS
UTES INIClTCHEN.
~cP
mANK yOU.... NO
9 S. ACORN DR.
BOn.ING SPRINGS, PA
251.1211
MAY 19 1995
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EXHIBIT 2
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NORMAN ELAN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-99 CIVIL TERM
vs.
KEITH R. GROVE and
MARY BETH GROVE,
Defendants
ANSWER TO NEW MATTER
12. Paragraph 12 contains an averment of a legal conclusion
to which no response is required pursuant to Pa. R.C.P. l029(d).
13. Denied. The plumbing and electrical work which was
performed by Plaintiff was performed in a workmanlike manner.
To the contrary, the electrical and plumbing both passed the
rough inspection, and the plumbing passed the final inspection.
Plaintiff was not given the opportunity to complete the
electrical work prior to the final electrical inspection.
14. Denied. Plaintiff at no time refused to complete work
on Defendants' house, to the contrary, Plaintiff while willing
to work, was not given the opportunity to complete the work.
15. Denied. To the contrary, Plaintiff completed the
plumbing work in accordance with his agreement with Defendants.
The central-vac system was roughed-in. At that point Defendants
gave written instruction to Plaintiff not to install the
system. The electrical work was completed in accordance with
J.nwOlnrt'H his agreement with Defendants, except for several minor details.
Duncun & Ottn, P.C.
Lnw Omr..
Dunrnn & alto, P.t:,
'.
16. Denied. Plaintiff did not damage work done in
Detendant's home. By way of further answer, paragraph 16 lacks
the specificity required for Plaintiff to formulate an answer.
17. Admitted only to the extent that Plaintiff removed
circuit breakers from the house and later returned the
breakers. It is denied that Plaintiff removed any other
materials from the job.
18. After reasonable investigation Plaintiff is without
knowledge or information sufficient to form a belief as to the
truth ot the averment contained in Paragraph 18.
19. Denied. Plaintiff informed Defendant of his surgery as
soon as the surgery was scheduled. All of the other
sub-contractors on the job were aware of the surgery as well as
both Defendants.
20. Denied. Plaintiff did not sign Defendant Keith R.
Grove's name to a request for electric inspection form. To the
best of Plaintiff's knowledge, no signature is required on such
a request for inspection.
21. Denied. Plaintiff did not sign Defendant Keith R.
Grove's name to a request for electric inspection form. To the
best of Plaintiff's knowledge, no signature is required on such
~ request for inspection.
-..A..}
'.
22. Denied. plaintiff did not do those things averred in
paragraphs 20 and 21, to the contrary, since Defendants paid for
the inspections, Plaintiff could not have had control.
23. Denied. It is admitted that on one occasion Defendant
gave a post-dated check to Plaintiff, however Plaintiff
requested payment, not a post-dated check. On the second
occasion Plaintiff requested payment before he would call the
inspector. Plaintiff said that he wanted paid, even if he had
to accept a post-dated check.
24. Denied that Plaintiff was aware of Defendants' practice
or that he was aware of when draws were to take place.
25. Admitted to the extent that the agreement between
Plaintiff and Defendants was not for time and materials but
rather priced by item, for example, 1 outlet was priced at
$15.00, 100 outlets would cost $1,500.00, etc.
26. It is denied that Plaintiff materially breached his
contractual obligations to Defendants, to the contrary,
Plaintiff substantially performed all work which was agreed upon
between the parties in a good and workmanlike manner. Any
failure to complete work was a result of the failure of
Defendants to give Plaintiff an opportunity to complete those
items.
27. Denied. The final amount due for the rough-in tor the
J,llW Ol1kl.'.
DUllCllll & OUll, ),,1:, central-vac is contained in Exhibit "B" of Plaintiff's Complaint
which contains the list of materials and labor expended by
Plaintiff in his work on Defendants' house.
28. It is admitted that Plaintiff only completed the
rouqh-in on the central vac system pursuant to Defendants'
written instruction to him not to complete installation.
ANSWER TO DEFENDANTS' COUNTERCLAIM
29. The answers to the averments of Paraqraphs 12 throuqh
28, incluSive, are incorporated by reference herein in their
entirety.
30. Admitted.
31. Admitted that Defendant Keith R. Grove accepted the
plumbinq quote presented by Plaintiff.
32. Admitted.
33. Admitted.
34. It is admitted that Plaintiff presented Defendants with
a quote for the rouqh-in of electric for the home, includinq
receptacles and switches. Plaintiff qualifies his answer in
that the quote was based on his past experience in determininq
the nUmber of receptacles and switches as well as the
instructions qiven to him by Defendants. At the time, Plaintiff
was not qiven detailed electrical specifications for the house
plan, therefore the quote was only an estimate of the actual
Lnwom.,.,.
Dunonn & Otto, 1',1:, number of switches and receptacles which would be needed.
35. Admitted.
36. It is admitted that during the course of Plaintiff's
work Defendants requested changes and additional work and that
these changes verbal.
37. It is admitted that Defendants requested the addition
of a large exhaust fan and four recess lights. Denied that only
two basement lights were installed, to the contrary Plaintiff
installed ten additional basement lights at Defendants'
request. Additionally, at the time Plaintiff quoted his price
to Defendants they had not decided on the type of stove they
wanted, therefore the stove was added later as well as
additional receptacles and additional lights in closets.
$346.00 was the cost of the exhaust fan and the recess lights.
38. Denied. Plaintiff did not intentionally and
maliciously damage material in Defendants' house. Plaintiff
admits taking circuit breakers from the home and later returning
them to the proper location without causing any damage to the
house.
COUNT I
39. The answers to the averments of Paragraphs 12 through
38, inclusive, are incorporated by reference herein.
Lnw omc,'.
Duncnn & Ol~l, P.C, was installed properly in a good and workmanlike manner.
40. Denied. Defendants failed to specify which of three
exterior hose bibs was installed improperly and how it was
improperly installed. All hose bibs were installed by a Master
Plumber in a good and workmanlike manner. The hot water heater
41. Denied. After reasonable investigation the Plaintiff
is without knowledge of information sufficient to form a belief
Law Office.
Duncan & Otto. P,C,
as to the truth of Defendants' statement.
42. Denied. The hot water heater was placed in a location
which was approved by both Defendants, furthermore, it wasplaced
in the only location available whi~h would meet code
specifications, excluding placement in the office or recreation
room which Defendants declined to do.
43. Denied. Paragraph 43 of Defendants' Counterclaim
contains an unwarranted conclusion of law to which no response
is required. The exterior hose bib and hot water heater were
properly installed.
44. Denied. The exterior hose bib and hot water heater
were properly installed in locations which were approved by
Defendants and in locations which were necessary to meet code
standards.
WHEREFORE, Plaintiff requests this court to dismiss
Defendants' Counterclaim with prejudice and enter judqment in
hi. favor on Plaintiff's claim together with costs of this
action.
COUNT II.
45. The answers to the averments of Paragraphs 12 through
44, inclusive, are incorporated by reference herein.
46. Denied. with regard to the items set forth by
Defendants in Paragraph 46, Plaintiff replies as follows:
a.
Plaintiff wired the door chimes, he did not
install the push button on the chimes because
Defendants failed to give him the opportunity
to do so.
b, Defendants failed to dig the ditch and set the
light post which was their responsibility,
therefore Plaintiff was unable to connect the
post light since he was not given the
opportunity.
c. The hot water heater was wired in the proper
location, conforming to code specifications
and with Defendants' approval.
d. The house was not finished sufficiently to
hang the exterior lights until January, 1996,
further, Plaintiff never agreed to hang the
outside lights.
e. Defendants failed to give Plaintiff a location
or instructions regarding the spot light
outlet.
f. It is not the electrician's job to place nailers
for exterior lights, rather it is the job of the
framer or vinyl workmen. Plaintiff never agreed
to undertake this task.
Law omce.
Dunenn & Ol~). P,C.
g. The switch plates were installed correctly and
were not cracked. Plaintiff was never given
the opportunity to straighten any switch plates
which may have been crooked.
h. It is not the electrician's job to cut access
holes for wiring. Plaintiff never agreed to
undertake this task.
i. The installation of the glass in the light in the
foyer was not contained in Plaintiff's quote.
Plaintiff expended at least two hours on the
installation of the light without charge to
Defendants. The glass was left off at the
request of Defendant Mary Beth Grove.
j. The lights and fans were installed properly
without charge to Defendants.
k. It is not the electrician's job to install the
cooktop, rather the installation should be
completed by the finish carpenter or cabinet
installer. Plaintiff never agreed to undertake
this task.
47. Denied. Paragraph 47 of Defendants' Counterclaim
contains an unwarranted conclusion of law to which no response
Lnw omc..
Duncnn & Ottll. P,C, allow him to complete that work.
is required. Plaintiff property installed all items which were
on his original quote and completed the electrical rough-in of
the house.
48. Denied. The electrical rough-in passed inspection
without requiring any modifications. Any work which Plaintiff
failed to complete was the result of Defendants' failure to
WHEREFORE, Plaintiff requests this court to dismiss
Defendants' Counterclaim with prejudice and enter judqment in
Low Offic..
Dunmn & attn. P,C,
his favor on Plaintiff's claim together with costs of this
action.
COUNT III
49. The answers to the averments of Paragraphs 12 through
48, inclusive, are incorporated by reference herein.
50. Admitted.
51. Admitted.
52. Admitted.
53. Denied. The work performed by Plaintiff was done in a
reasonably workmanlike manner. All work passed township
inspections and conformed to state electrical code
specifications.
54. Denied. Paragraph 54 of Defendants' Counterclaim
contains an unwarrantsd conclusion of law to which no response
is required. By way of further denial, Plaintiff performed his
work at Defendants' residence in a reasonably workmanlike manner
and substantially completed all items listed on his quote
excepted for those items which he was unable to complete because
of Defendants' actions.
VERIFICATION
I verify that the statements made in the foregoing Answers
to New Matter and Counterclaim are true and correct. I
understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unsworn falsification
to authorities.
~ C~"'l-
Norman Elam
Dated: :;"/1 ~ f 1~
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NORMAN ELAN
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
; NO. 9&1- q q CIVIL Tel,,"
vs.
KEITH R. GROVE and
MARY BETH GROVE
Defendants
.
.
COMPLAINT
AND NOW comes the Plaintiff, Norman Elam, by his
attorneys, Duncan & otto, P.C. and makes the following
Complaint:
1. The Plaintiff is Norman Elam, a sui juris adult
individual whose address is 25 North Acorn Drive, Boiling
springs, CUmberand County, Pennsylvania 17007.
2. The Defendants are Keith R. Grove and Mary Beth Grove,
husband and wife, sui juris adult individuals whose address is
24 North Pin Oak Drive, Boiling Springs, Cumberland County,
Pennsylvania 17007.
3. In May of 1995 Defendant Keith R. Grove came to the
home of Plaintiff Norman Elam to request Plaintiff to perform
the electrical and plumbing work on a house Defendants were
going to build on Lot 63, The Oaks.
4. Defendant Keith R. Grove requested that Plaintiff
immediately prepare an estimate of the cost for his services for
purposes of sUbmitting same to the bank to obtain financing. It
wwomc.. was agreed that the estimate would be revised at a later time.
Duncan & Otto. p,c,
Lnwome..
Dunenn & Ollo. P,C,
A copy of the estimate is attached hereto, incorporated by
reference and marked Exhibit "A".
5. The essence of the agreement between Plaintiff and
Defendants was that Plaintiff would charge Defendants materials
at his cost plus labor for the rough-in, subject to certain time
constraints imposed by plaintiff's impending surgery which was
scheduled for July 31, 1995.
6. On or about June 1, 1995, a stipulation against liens
was filed listing RaG Land Planning and Management as General
Contractor.
7. Plaintiff began his work on the house the last week of
July. He was given three (3) to four (4) days to complete the
eleotrical and plumbing rough-in. To oomplete the work himself
would have required ten (10) days. Beoause of the time
oonstraints, plaintiff was required to hire additional laborers
to assist him.
8. After his surgery, plaintiff resumed work on the house.
The last day of work on the house was September 19, 1995.
9. A list of the materials and labor totalling $9,052.50 is
attached hereto, incorporated by reference and marked Exhibit
liB".
10. Defendants paid Plaintiff $3,256.50 on August 6, 1995
and $3,038.20 on September 11, 1995.
11. After request for payment, Defendants have refused to
pay the remaining balance of $2,757.80.
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DETACH AND RETURN UPPER PORTION WITH YOUR REMITTANCE $
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...... FORM 3809
L U1l10INUS"
YOUR CHECK IS YOUR RECEIPT
EXHIBIT
I
Pt
THE GROVE'S HOME, LOT 63, THE OAKS, BOILING SPRINGS. PA
QUOTE FOR ELECTRICAL ROUGH-IN WITH RECEPTACLES AND
SWITCHES, '1, '1j
"
1. 200 AMP SERVICE----------- ------------------------------- ------$ 450,00
2.100 OUTLETS -----------------------------@$15,OO ----- -------1500,00
3,10 3-WAY OUTLETS ---------------------@ 14,00 ----- -------- 140,00
4, 16 CANDLE OUTLETS ----- ----------@ 15,00 ----- -------- 240,00
5.5 FAN OUTLETS ------------------------@ 18,00 ----- ----- 90,00
6, 6 PHONE OUTLETS ---------------------@ 10,00 -------- ----- 60,00
7, 6 TV OUTLETS -------------------------@ 12,00 -------- ------ 72,00
8, 1 SPOT LITE OUTLET -------- - ----@ 17,00 -------- -------- 17,00
9,3 SMOKE DETECTOR OUTLETS -------@ 12,00 --------- ----.---- 36,00
10, I EXHAUST FAN VENTED 1/2 BATH @ 20,00 _ ----- -------- - 20,00 -0 ~
11.2 EXHAUST FAN/LIGHT VENTED ---@ ~ ~_____________ 58,88 -17 - ""-
12, I POST LITE CIRCUIT ------------ @ 28,00 ---_________ 28,00 I / ( '"
13, I WASHER OUTLET ----------- @ 25,00 --------- 25,00
14, 1 DRYER OUTLET ------------- @ 60,00 ------__ 50,00
15, I MICROWAVE OUTLET ---------@ 25,00 ------------25,00
16 1 DISHWASHER OUTLET ---------@ 25,00 --- ----------- 25,00
17,1 DISPOSAL OUTLET ---------- @ 25.00 - ----------- 25,00
18, I GAS WATER HEATER OUTLET - @ 15,00 ----------------- 15,00
19,4 GFI CIRCUITS ------------- @ 35,00 --- ----------- 140,00
20, I AIR CONDITIONER CIRCUIT ---- @ 60,00 -- ------------- 60,00
21. 5 RECESS LITES ----_.-------------- @ 45,00 ---- ---------- --- 225,00
22,8 BASEMENT PORCELIN LITES --@ 13,00 _a. ------------- 104,00
23, DOOR CHINE WIRING ----.-------- @ 15,00 15,00
,~ &i{1CJ~-C
, TOTAL $------'lItP
loC>.,
NOTE; THIS DOES NOT INCLUDE LIGHTING FIXTURES EXCE~ _ l/
LITES IN KITCHEN, ') >'7
THANK yOU.... NORM ELAM
9 S, ACORN DR
BOILING SPRINGS, PA
258.1288
MAY 19 1995
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STATEMENT
200 AMP Elec. Service
Outlets/Switch Boxes 132 @ 15.00 each
3 Way Switches 16 @ 14.00 each
Fan Boxes 7 @ 18.00 each
phone outlets 6 @ 10.00 each
TV Outlets 4 @ 12.00 each
Smoke Detectors 3 @ 12.00 each
Sm. Exhaust Fans 2 @ 20.00 each
Lrg. Exhaust Fans 2 @ 70.00 each
Post line Circuit
Washer Outlet
Dryer Outlet
Microwave Outlet
Disposal Outlet
Gas Water Heater Outlet
GFI Circuit Outlets 5 @ 35.00 each
Air Conditioner Outlet
Recess Lites 11 @ 45.00 each
Basement Lites Outlets 11 @ 13.00 each
Door Bell Circuit
Garage Lites/Storage Area 4 @ 13.00 each
Closet Lites 4 @ 13.00
Bedroom/Bath/Dining Room Lites 13 @ 13.00
Outside Lites 8 @ 13.00
Attic Lites 2 @ 13.00 each
Four Way Switches 2 @ 18.00
Electric Oven Wiring
Cook Top Wiring
GFI for Whirlpool
Outlet in Snack Bar
Furnace Circuit
Approx 30' 1/2 gas line for fireplace & fittings
Basement 1/2 bath rough-in
Rough-in for central Vac 4 outlets & 1 Partial
Rough-in plumbing for Laundry Tub
Ice Make value & tee
Water line to house from curb box
Washer Pan & Switch plumbing
TOTAL EXPENSES FOR ELECTRIC AND EXTRAS
OUOTE FOR PLUMBING
TOTAL DUE
8-6-95 Payment on Account
9-11-95 Payment on Account
TOTAL OUTSTANDING BALANCE DUE
EXHIBIT
I
'l3
$ 450.00
1,995.00
224.00
126.00
60.00
48.00
36.00
40.00
140.00
28.00
25.00
60.00
25.00
25.00
15.00
175.00
60.00
495.00
143.00
15.00
52.00
52.00
169.00
104.00
26.00
36.00
140.00
140.00
75.00
25.00
25.00
125.00
350.00
350.00
79.50
25.00
140.00
54.00
S6.152.50
2.900.00
S9.052.50
S3.256.50
S3.038.20
S2.757.80
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1D !h. Court of Co..oa .1... .,
v.
KEITH R. GROVE und
MARY BETII GROVE
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CUIb.rlaad Couut7, 'Inaa,I.lai.
NORMAN ELMI
110, 96-9~ CIVIl.
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OATH
VI do 101e.a17 avlar (or Iffi~) that v. viii lupport, oblY lad dlflad
till Coutitution of tbl Vaitld Statll ad the Cout1t11tioa of tbb Comon-
wealth aad that VI vill dilchlr.. the dutl'l of our offlc. vlth fid.lity.
(;corge B. Fuller. Jr., Esquire - Chuirman
KathlelJn Kcntlng, Esquire
Wayne Pccllt, Esquire
AllARD
VI, thl UDdlralrald arbitrator., blvlDB bleD duly IppoiDtld aDd 1V0ra
(or 'afUnaed) , uti the followiD. avard:
(Notl: If d...... for de11Y Irl IVlrded, they lhall be
Ilplrltll, Itltld.)
appU.cable.)
. Arbitrator, di..eat.. (Insert Dime if
Dati of aear:iJla:
Dati of Avard:
George B. Fuller, .Jr.. Esquire - Chulrman
Kathleen Keating, Esquire
Wayne Pecht, Esquire
NOTICE OF ENTRY OF AWARD
NllIl, the day of
.vard va. eDtered UpOD the docket
parti.. or their attoraey..
,19 ,at , .M., the above
aDd Dotice ~eoi given bY-mail to the
Arbitrators' compensatioD to be
paid UpOD appeal:
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ProthoDotary
By:
Deput)'
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la IlIe Cou" ol C_ PI_ 01
ClIIIIllmud CoIIDIY, P~"'Ui&
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VI.
Nil,
96-99
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CIviL
19______
Keith R. Grove and
----------..---....--------------------------
------...---...---.-.-.-..----------------------
Mary Beth Grove.
---...--------.-----------......-----...------
lJefendants
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TO THE PROTHONOTARY.
.- .-.. --------..----------.--------------. --- ...--------------. .... -... -"'-- ---------..---- -------
Please mark this case settled. discontinued.
.--.....--------.--------.------.----------------..--------.--------------------.-..--..-....-..
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---..--------------... ----..---..----..--.----.-. ..........-.......-... .......-....--.-.
To
Lawrence Welker
--------------.-..-----------------...----
Pralhorunary
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/' Susan J. Ott{J ~ ~ ~ AuIlnwy lor Plain,iff.
Duncan & Otto
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PR.'ICIPE
F"~ed ___________________________ 19______
_______________________.__________. .'Ity.
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