HomeMy WebLinkAbout96-00193
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ALEX R, SZELES, INC"
Plaintiff
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IN 'I'IIE COURT OF COMMON
PI,EAS OF CUMBf;RI.AND COUNTY.
PENNUYLVANIA
vs,
CIVIL ACTION - LAW
HEINEMAN & RUMBERGER. a
partnership comprised of
DOUGLAS R. HEINEMAN and
RODNEY L, RUMBERGER,
DefendantG
NO.
CIVIL TERM
COMPI.A TNT
AND NOW comes tht! ll!love-named Plaintiff. by its attorney, Samuel L.
Andes, and makes the following Complaint agains the above-named
Defendants:
1. The Plaintiff is Alex R, Szeles, Inc" a Pennsylvania
corporation with offices at 5110 Lllncaster street, Harrisburg, Dauphin
County, Pennsylvania,
2. The Defendant is Heineman & Rumberger, a partnership comprised
Ilof Douglas R, Heineman and Rodney L, Rumberger, The partnership owns
real estate at and maintains offices at 163 North Hanover Street in
Carlisle, Cumberland County, Pennsylvania,
3. Plaintiff is a general contractor engaged in, among other
things, fire and other casualty repair and restoration,
4, Following a fire at the property owned by the Defendants at 163
North Hanover Street in Carlisle, Pennsylvania, Plaintiff and Defendants
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!entered into an oral agreement by which Plaintiff agreed to complete
extensive repair, reconstruction, and restoration work at the property
owned by the Defendants at 163 North Hllnover Street, for which the
Defendants agreed to pay to Plaintiff the total slim of $:153.751.17, The
parties reached that oral agreement in March of 1995,
5, Oubsequently. in June of 1995. the parties reached a second oral
agreement by which Plaintiff agreed to complete additional repair.
reconstruction and restoration work on the Defendants' property at 163
North Hanover Street in Carlisle and the Defendants agreed to pay
Plaintiff for that additional work the additional sum of $9.961.39,
6. Plaintiff well and truly performed all of its obligations undp.r
the oral contract with the Defendants and completed the repair.
reconstruction and restoration work on Defendants' property on :16 June
1995,
7, Defendant has paid to Plaintiff a total of $:147.471,17 for the
services provided by Plaintiff pursuant to the oral contract between the
parties. leaving a balance due Plaintiff of $16.241,39,
8. Despite repeated requests and demands from Plaintiff, Defendants
ilhave failed to pay the balance of $16,:141,39 and. thereby, has injured
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Plaintiff in that amount,
WHBIBPOIB. Plaintiff demands jUdgment against Defendant in the
amount of $16.241,39. plus interest from and after :16 June 1995, plus
costs of suit,
&~-- ~C&
1 L, Andes
Attorney for Plaintiff
Supreme Court ID 17:1:15
525 North 12th street
Lemoyne, PA 17043
(717) '161-5361
SHERIFF'S I/ETUIlN- HEGULAR
GASE NO: !996-Ql~I~J P
COMMONWEAL1'Il OF PENNSYLVANIA:
COUNTY OF GUMDEI/l.AND
ALEX R S2ELE? I!{C
VS.
HEINEMAN & RUMBERGER
KRISTIN D, MERT::: , Sh~riff or Deputy Sheriff of
GUM BERLAND County, Pennsylvania, who being duly sworn according
to law, sayl', the wlthin UJJ1P_L.AI.NJ____ woo "lI:'rvL'd
upon HEINEMAN & RUMBERGER A PARTNERSHIP the
defendant, at _En! :00 HOURS, un th" 17th day of January
1 9il6 a t -----1J;...;J...Ji91ITlJ II A II 0 V E R S T R _I'; E T
CARLISLE. PA !7~J...;J_
County. PennsylvClnia. by handing to
, CUMBERLAND
JQ~li~~lEIlIEMAlI. SECRETARY ANp
ADULT IN CIIARGE
a true and atto:>sted copy of the COMPLllIlIT _____.__.__.._____
togetheor wi th !i~Ltlt;;~_____
and at the sameo tlme directing IIpr att,'Otion to the' conbmts thL'reof,
Sheriff's Gostsl
Docketing
Seorvicp.
Affidavit
SurclulI"ge
18,01'1
2.80
,00
2.00
So ~{(~~~<.~
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R. Thom,is-rnTile;-Sher 1 rr----
$'22:-lIIOSAMUEL ANDES
Ql1l18/1996
by II' AI, /1 ,) l,~~
----iliw.~-~rL~.L . rr
L~pU y ~ 1.
Sworn and subscribed to b,,!ore me
this I ",. day of .:t..J'(",.~________
19--"'''___ A, [1,
___~, 1 'IL"J!'--llll~"(~' 1L1k!i.:..______,___
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