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Home My WebLink About02-4576CO.M.MONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Cumberland JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas ar] appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. NAVE OF APPELLANT Grant Elec. Constracti~./A. Grant ~ ^OO.ESS OF A"P~LLA,~T CITY 61 0 Alexander Sprin~ Rot ST^TE ZIPCODE ~ ~tp Sales, Inc. vsGr CV YEAR CV-0000280 no IS,G,~u~o~~./A. e signed ONLY when this ~otation is ren,,ir~ ,,~ D~ R.C.P.J.p. No. 10088. ~ ......... r ~. /f appellant was Claimant (see PA R.C.P.J.p. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case. No. 1001(6)) in action before district Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see PA R.C.P.J.p. No. 1001(?) in action Pefore District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAEClPE: To Prothonotary Enter rule upon Love's Auto Sales, Inc. Name of appellee(s) _, appellee(s), to file a complaint in this appeal (Common Pleas No.(~3~,~--~/OC~aL~U,,.[ ] within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attorney or agent RULE:To Love's Auto Sale~ Inc. Name of appellee(s) __, appellee(s) (2) (3) Date:~ You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this rule upon you by personal service or by certified or registered mail. If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECIPE. The date of service of this rule if service was by mail is the date of the mailing. __, Year ~-~ '~,~. ~/~ White - Prothonotary Copy Green - Court File Copy Yellow Appelant's Copy Pink - Appellee Copy Gold - D.J. Copy Proth.- 76 PROOF~OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FtLED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF AFFIDAVIT: I hereby swear or affirm that I served , upon the District Justice designated therein on E~a copy of the Notice of Appeal, Common Pleas No. (date of service) __ year [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name __, year____, [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. ]and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on _ , year ______ [] by personal s(~rvice [] by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF _ , YEAR S~nature of Affiant My commission expires on _ , year ____ COMMONWEALTH OF PENNSYLVANIA CO UNTY O F: CU~JB~p/ji, ND 09-2-01 PAO~'~" P- CORRRAI, ~' 1,.'COURTHouSE SQUARI~ :. CAliLII~L]R, PA NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE ~OVR, s AUTO SALBs, INC. ~ 1970 SPRING ED C,~RLISL~, PA 17013 L DEFENOANT: VS, (71'7) 240-6564 17013-0000 "'~e,~^o~,;ss '*~.,a,Z~amD=K SPRING ROAD GRANT ELEC CONTRACTING INC. /A. GRANT hCAP'LZSLR, PA 17013 610 ALEXANDI~R 8PR N~ ~nar, -- D0Cket No.: C~- 0000280-02 ] CAKLISLE, PA 1701~ ..... Date Filed: 6/12/02 THIS IS TO NOTIFY YOU THAT: Juctgment: · ' ~-'] Judgment was entered for: (Name)_ T.nv~,~ arvn ~a~'.~. .~q~. [] Judgment was entered against: (Name)~ in the amount of $ ~ 2. ~07. q8 on: (Date of Judgment) Defendants are jointly and severally liable. Damages will be assessed on: L-'~ This Case dismissed without prejudice. Amount ot Judgment Subject to [~i]Attachmenl/Act5of1996 $_. ~ [] Levy is stayed for_ days or [] generally stayed. (Date & Time) [Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Tolal $ 87.9_8 $ Post Judgment Credits $ Post Judgment Costs $__ -- [] Objection to levy has been file- -~- Certified Judgment Total ~Y========= o and nearing will be held. ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON FLEAS, CIVIL MUST INCLUDE A COPY OF THIS NOTICE OF. DIVISION. YOU SEP-17-2002 11:16 ?172432?99 98% P.~2 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA oou. o AFFIDAVIT: I hereby swear or affirm that I served a copy of the Notice o_f Appeal, Common Pleas No. ~'~' '~J~/A t ~' 4J I 'T~('t~, upon the District Justice designated therein on (date of service) (~. !~'~ , year 1~2~)__~, Dby &sonal se[vice ~by (certified)(registered)mail, sender's receip~tla}tached hereto~ and upon the appellee, (name ~_6'~-' _~ Al ~'~b .~ I~'~-'~ ~["'r~ . , on ~'~ ~x~'~ , year~:~{~, , [] by personal service.~by (certifie-'d)(registePred) mail, sender's receipt attach--~-~ her~eto. and further that I served the Rule toi File. a. Complaint accompanying the above Notice of Appeal upon the app. ellee(s) to whom the Rule was addressed on ~/~'~'~ ,year ~,1~ , [] by pemonal s~rvice~Y (certified)(registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AN,D SU..~C_RI,~._D BEFORE ME t~ of off, iai before ~m af~vit was ~ade ' ~ My commission expires on Member, :Penil~j,/Ivarr~a ~-~ Ct ~ COMMONWEALTH OF PENNSYLVANIA ~F' NOTICE OF AlS'PEAL FROM COURT OF COMMON PLEAS Cumberland JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL . :: - ~, - Notice is given that the appellant has tiled in the above Court of Common Pleas an appeal from the judgment render~dl:~y:ihe ' District Justice on the date and in the case mentioned below. NAME OF APPELLANT ~ MAG. DIST. NO. OR NAME OF D.J. paUla P_ C~rr,=~l £1q_7_0! Grant Elec. Constractin~ Inc./A. Gra~Jt ADD.ESS OF APPELLANT C,T¥ SIAl[ 7,~ CODE 10 AlexanDer sorln~ Road c~r]~]~ oa - -- ~,~ DATE OF JUDGMENT [ IN THE cASE OF (P~INTIFF) (DEFENDAND C~IM NO. C" '3 r' ~ ~ .... ~ ~ 81~URE OF APPEL~ O~ATTORNE~R ~T Grant CV YEAR _. vvvv.ov v,' m LT YEAR ' - m ,_ _ ~ ~ .... This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No. 1008B. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case. S~nature of Prothonotary or Deputy If appellant was Claimant (see PA R.C.P.J.P. No. 1001(6)) in action before district Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This seCtion of form to be used ONLY when appellant was DEFENDANT (see"PA R.C.P.J.P. No. 1001(7) in action before District Justice: IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAEClPE: To Prothonotary Enter rule upon Love ' s Auto Sales, Inc. , aPpellee(s), to file a complaint.in this appeal Name of appellee(s) (Common Pleas No. (~,,~~) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attorney or agent RULEF Ye Love's~ At~tofSales~, Inc.'. ~" -;. appellees) - Name of appellee(s) (1) (2) (3) Date: ~:~ , ~ White - Prothonotary Copy * , Green - Court File Copy "' ',~-', Yellow - APpelant's Copy Pink Appellee Copy Gold - D.J. Copy You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this ru[e upon you by personal service or by certified or registered mail. If you do not f. il~ ~:c0r~laint within'this!~, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECIPE. The date oi:s6r~iee of this ruie if service wa.s by mail is the date of the mailing. Signature of Protho~o ary oep y t ~ Proth. - 76 LOVE'S AUTO SALES, INC., Plaintiff GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COLTRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 02-4576 Civil Term LOVE'S AUTO SALES, INC., Plaintiff GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 4576 CIVIL ACTION - LAW NOTICE TO PLEAD You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 LOVE'S AUTO SALES, INC., Plaintiff GRANT ELECTRICAL CONTRACTING, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02 - 4576 CIVIL ACTION - LAW .. : .. COMPLAINT Plaintiff, Love's Auto Sales, Inc., by its attorneys, Broujos & Gilroy, P.C., sets forth the following: Plaintiff Love's Auto Sales, Inc. is a Pennsylvania Corporation with principal address located at 1970 Spring Road, Carlisle, Pennsylvania. Defendant Grant Electrical Contracting, Inc. is a Pennsylvania Corporation with principal address located at 610 Alexander Spring Road, Carlisle, Pennsylvania. At the request of Allen Grant who is an officer and shareholder of the Defendant, Plaintiff performed various automobile repair work on vehicles owned by the Defendant. Defendant had a running account with Plaintiff for payment on the various automobile repair work that Plaintiff performed on Defendant's vehicles. The current balance owing from Defendant to Plaintiff on Defendant's running account with Plaintiff is $2,432.17. 6 A copy of the various invoices issued by Plaintiff to Defendant in connection with the mentioned service work are attached hereto and marked Exhibit "A". WHEREFORE, Plaintiff requests judgment against Defendant in the amount of $2,432.17 plus costs to include filing fees Plaintiffs paid at the District Justice and any costs associated with the above captioned action. Respectfully submitted, Hubert X. Gilroy, E_s_q~ Attorney for Plainti~ Broujos & Gilroy.~/P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 Supreme Court ID No. 29943 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: LOVE'S AUTO SALES INC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Invoice Date Invoice # 12/26/2001 ! 297/216 Bill To GRANT ELECTRICAL CONTRACTING INC. 610 ALEXANDER SPRING ROAD CARLISLE PA 17013 Item Qty NPN 2 NPN I NPN 2 NPN I NPN 2 NPN 2 NPN 010 0101 LABOR LABOR LABOR LABOR LABOR LABOR LABOR Description BAI-IERY TERMIAL ENDS FA2002 BALL JOINT 2=4800 U-JOINTS USED TIRE WIPER BLADES GALLONS ANTI-FREEZE CHANGE OIL AND FILTER PA STATE INSPECTION Stic&~r Numb~r:A120963316 Old Mil~age:161090 N~w Mileage:17742g Brakes: Tires: LF: I I B LF:7 RF:I IB RE:7 LR:2R LR:6 RR:2R RR:9 PA. INSPECTION STICKER BALANCE 3 TIRES REPLACE BATI'ERY TERMIALS REMOVE AN REPLACE U-JOINTS MOUNT, BALANCE AND TIRE DISPOSAL (ONE TIRE) REPLACE LEFT BALL JOINT FLUSH ANTI-FREEZE ALIGNMENT (PUT CASTERS IN) 93 FORD TRUCK SERIAL#H2PHA01257 Sales Tax P.O. No. TRK#23 Net 30 Rate Amount 3.00 6.00T 35.00 14.00 30.00 10.00 7.00 20.00 20.00 ZOO 21.00 20.00 50.00 12.00 45.00 20.00 89.00 6.00% 35.00T 28.00T 30.00T 20.00T 14.00T 20.00T 20.00T 2.00T 21.00T 20.00T 50.00T 12.00T 45.00T 20.00T 89.00T 25.92 'We aPPreciate y°ur~'°mpt pnyme~i: EXHIBIT Total $457.92 LOVE'S AUTO SALES INC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Invoice Bill To GRANT ELECTRICAL CONTRACTING INC. 610 ALEXANDER SPRING ROAD CARLISLE PA 17013 Item Qty NPN 2 NPN NPN NPN NPN NPN NPN NPN NPN NPN NPN 010 0101 LABOR LABOR LABOR LABOR LABOR LABOR LABOR LABOR Description 18 INCH WIPER BLADES FK-I?9 TRAM KIT QTS TRANS FLUID BOITLES BRAKE FLUID HORN A657 AIR FILTER FUEL FILTER CANS BRAKE CLEAN 77311 RIGHT BRAKE HOSE LEFT BRAKE HOSE CARB CLEANER PA STATE INSPECTION Sticker Number. Al23086600 Old Mileage:l 13257 New Mileage: I 17967 Brakes: Tires: LF:6B LF:6 RF:6B RF:6 LR:5 LR:6 RR:5 RR:6 PA. INSPECTION STICKER CHANGE OIL AND FILTER CART N/C FOR OIL AND FILTER CART FLUSH COOLING SYTEM CHANGE TRANS FLUID CLEAN THRO I-ILE BODY AND INJECTOR ROTATE TIRES FIX HORN REPLACE FUEL FILTER REPLACE LEFT AND RIGHT BRAKE LINES VIN# I FTHF26H6LNB42385 90 FORD F250 5.8L Sales Tax Rate Amount ....... io.oo 2°.°°T 28.00 2.00 0.60 22.00 10.00 12.00 4.00 22.00 45.00 4.00 20.00 2.00 20.00 29.00 39.00 20.00 10.00 22.50 22.50 60.00 6.00% 28.00T 18.00T 3.00T 22.00T I 0.00T 12.00T 8.00T 22.00T 45.00T 4.00T 20.00T ZOOT 20.00T 29.00T 39.00T 20.00T 10.00T 22.50T 22.50T 60.00T 26.22 $463.22 LOVE'S AUTO SALES INC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Invoice Date Invoice # 1/22/2002 1413 Bill To GRANT ELECTRICAL CONTRACTING INC. 610 ALEXANDER SPRING ROAD CARLISLE PA 17013 Item NPN qPN ~ABOR We appreciate your prompt payment. Qty Description ............ ~ QTS OIL I REBUILT TRANSMISSION REMOVE AND REPLACE TRANSMISSION 89 FORD TRUCK 5.0L ;ales Tax Total Rate 1.25 825.00 225.00 Amount 2.50T 825.00T 225.00T 63.15 $1,115.65 LOVE'S AUTO SALES INC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Invoice Date I InVoice # 1/28/2002 j 1427 Bill To GRANT ELECTRICAL CONTRACTING INC. 610 ALEXANDER SPRING ROAD CARLISLE PA 17013 Item Qb/ NPN NPN NPN NPN NPN 010 0101 LABOR Description 194 BULB 18 INCH WIPER BLADES 3087 GREASE SEALS 5347 FRONT ROTORS INNER TIE ROD PA STATE INSPECTION Sticker Number:Al23086595 Old Mileage:97412 New Mileage:108003 Brakes: Tires: LF: LF:7 RF: RF:7 LR:SR LR:7 RR:SR RR:7 PA. INSPECTION STICKER REPLACE ROTOR AND LEFT INNER TIE ROD END VIN# i B7GL26X6MS318558 91 DODGE DAKOTA P.O. No. Terms Net 30 Sales Tax 1.00 10.00 5.00 55.00 75.00 20.00 Total Rate 6.00~A 2.~ 135.~ Amount I .OOl 20.00T I 0.00T I 10.00T 75.00T 20.00T 2.00T 135.00T 22.38 $395.38 m 0 I-- ITl Z 000 000 ZZ mo C<: O(DO~ 0 ]>o -i ~-~ ]> mc) c o .I> F- ]>Z O0 C ~-.-t Z .--4 rtl 77 Fq ]> "O~: ']{>0 p,) ~ '-'~' Z 0 4:~ 60 p]--I :-, o'~ (.,0 Z O600' 0 LOVE'S AUTO SALES INC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Invoice I/4/2002 [ 1377 Bill To GRANT ELECTRICAL CONTRACTING INC. 610 ALEXANDER SPRING ROAD CARLISLE PA 17013 Item NPN Qty Description 2 TAIL GATE CABLES 92 DODGE DAKOTA Sales Tax P.O. No. Rate 2i:50 6.00% Total Terms Net 30 Amount 43.00'] 2.58 $45.58 LOVE'S AUTO SALES INC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Invoice Date l-- Invoice # 1/3/2002 ~ 1316 Bill To GRANT ELECTRICAL CONTRACTING INC. 610 ALEXANDER SPRING ROAD CARLISLE PA 17013 Item Qb/ NPN I NPN LABOR Description ACTUATOR 14060 KEY SWITCH FIX KEY SWITCH 89 FORD TRUCK 5.0L Sales Tax P.O. No. Terms 'IRK/il0 Net 30 Rate 16.00 20.00 90.00 Amount 16.00T 20.00T 90.00T 6.00% 7.56 LOVE'S AUTO SALES INC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Invoice __.1 j _,310 I_nvoice # / Bill To [G~-~ ELECTRICAL COmR*C~ INC. t610 ALEXANDER SPRING ROAD CARLISLE PA 17013 P.O. No. TRK#11 Item NPN EABOR LABOR Please remit to above address. Qty Description Rate I DL7744 ALTERNATOR CHECK CHARGING SYSTEM/ALTERNATOR WILL NOT CHARGE REPLACE ALTERNATOR VIN#2FTEF14Y6HCA7305 I OLD MILEAGE: NEW MILEAGE: 62557 87 FORD FIS0 4.9 LIC~YHD8115 Sales Tax Total 6.00% 120.00 25.00 45.00 Terms Net 30 Amount 120.00T 25.00T 45.00T 11.40 $201.40 Z LOVE'S AUTO SALES [NC 1970 SPRING ROAD CARLISLE PA 17013 717-249-2255 FAX 717-249-2042 Bill To i GRANT ELECTRICAL CONTRACTING INC. i61o ALEXANDER SPRING ROAD iCARLISLE PA 17013 Date 12/13/2001 Ih olce Invoice # 1257 NPN , NPN NPN ; NPN ! NPN !NPN NPN ] qPN qPN Item LABOR LABOR LABOR BOR Thank you mr your ousi . Qty Description D539 OiL FILTER AND 5 QTS OIL lEAD LIGHT AND SWITCH KNOB :AN SWITCH WITCH HEATER PLUG 1025K6 SERP BELT J574 FRONT BRAKE PADS CA6366 AIR FILTER QTS TRANSMISSION FLUID 16-4514 FRONT CALIPERS YH 141798 ROTOR CHANGED OIL FILTER CART AND OIL REMOVED, REPLACED FRONT ROTOR, FRONT BRAKE PADS, CALIPERS, BELT AND AIR FILTER FIX TRANSMISSION LEAK LUBRICATION, FIX HEATER SWITCH, AND DASH NEEDS REAR TIRES!H!!H!!!!! NEW MILEAGE:208910 Sales Tax Total P.O. No. TRK#20 Rate 0.00 12.00 12.00 15.00 24.00 75.00 I 0.00 3.50 100.00 149.00 20.00 145.00 35.00 40.00 me~ms Net 30 Amount 12 00T I ZOOT 15.00T 24 00T 75.00T 10.00T 7.00T 200.00T 149.00T 20.00T 145.00T 35.00T 40.00T 44.64 $788.64 INRE: LOVES AUTO SALES, INC., Plaintiff V. GRANT ELECTRICAL CONTRACTING, INC., Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA 'NO. 02-4576 · CIVIL ACTION - LAW · JURY TRIAL DEMANDED ANSWER TO COMPLAINT AND NOW, comes Your Defendant, Grant Electrical Contracting, Inc., by and through its counsel, Cunningham & Chernicoff, P.C., and files its Answer to Complaint filed by Yale Electric Supply Co., Inc., and in support thereof answers as follows: 1. Admitted. 2. Admitted. 3. Denied. It specifically is denied that there existed an individual by the name of Allen Grant who is an officer and/or shareholder of the Defendant. By way of further pleading, if an individual by the name of Allen Grant requested work be performed by Plaintiffto various automobiles owned by the Defendant such individual had no authority, express or implied, to enter into binding contracts on Defendant's behalf. 4. Paragraph 4 state conclusions of law to which no response is required. By way of further pleading, Defendant is unable to determine with any accuracy how Plaintiff defines "running account" as set forth in Paragraph 4 of Plaintiff's Complaint. 5. Denied. It is specifically denied that amounts owing :from Defendant to Plaintiff are $2,432.17. By way of further pleading, Plaintiff failed to credit Defendant for monies paid by Defendant to Plaintiff in exchange for automotive repair work. By way of further pleading, Plaintiff billed Defendant for work that was not performed by Plaintiff'nor agreed upon by the parties to be performed. 6. It is admitted that various invoices are attached to Pl~fintiWs Complaint and marked as Exhibit "A". It is denied that those invoices represent accurate charges by Plaintiff to Defendant for reasons more fully set forth in this Answer. WHEREFORE, Defendant demands judgment in its favor and against Plaintiff together with costs, interests, reasonable attorneys fees, and any other re]lief this Court may deem appropriate. Date: Respectfully submiitted, CUNNINGHAM & CHERNICOFF, P.C. By: John M. Hyams, Esquire I.D. #87327 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 tlf/answers/Iove-gra 2 IN RE: LOVES AUTO SALES, INC., Pbtntiff V. OI~.~T ELECTRICAL CONT1LACTING, lINC., Defendant · IN THE COURT OF COMMON PLEAS · CUMBEP,.LAND COUNTY, PENNSYLVANIA · NO. 02-4576 : · CIVIL ACTION - LAW : : ·/UR¥ TRIAL DEM~d~DED : : : _v -.nn CATlO I, ALAN G. UNGEB, verify that the ststernem$ made in [he foregoing Answer to Complaint me true and correct to thc best of'my knowledge, information and beli~. I uncteratand ~hat ~ny false statements herein made ~re sUb, eot to the penakie~ o1[' ]g P~. C.S.A. §4904. relating to unsworn fal$ilicatiou to n~horities. D~te: December ~ 2002 INRE: LOVES AUTO SALES, INC., Plaintiff V. GRANT ELECTRICAL CONTRACTING, INC., Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA 'NO. 02-4576 · CIVIL ACTION - LAW · JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Stacy A. Sollenberger, a legal secretary for the law finn Cunningham & Chemicoff, P.C., hereby certify that on December ,~t~, 2002, a true and correct copy of the ANSWER TO COMPLAINT was served by first-class U.S. Mail, postage prepaid, to: Hubert X. Gilroy, Esquire Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 CUNNTNGHAM & CHERNICOFF, P.C. Stacy A. ~u~tllenber.ger d 2320 North Second Street Harrisburg, PA 17110 LOVE'S AUTO SALES, INC., Plaintiff V GRANT ELECTRICAL CONTRACTING, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02 - 4576 CIVIL ACTION - LAW RULE 1312.1. form: The Petition for Appointment of Arbitrators shall be substantially in the following PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Hubert X. Gilroy, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in this action is $ 2,432.17. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: Hubert X. Gilroy, Esquire Broujos & Giiroy, P.C. 4 North Hanover Street Carlisle, PA 17013 John M. Hyams, Esquire Cunningham & Chernicoff, P.C. 2320 North Second Street Harrisburg, PA 17106 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, ]Attorney * y~~'nt~uire ORDER OF COURT AND NOW, January ictig~s prayed ~or. ~ 2003 in consideration of the foregoing petition, Esq., ..~l.n.~, ./ ~?~ .a ~/.e.~/~ , Esq., and , Es~l., are aPp~int~d ~rbi-trat~rs ]n the above-captioned BY THE ' By: ~~J' LOVE'S AUTO SALES, INC., Plaintiff VS, GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4576 OATH We do solemnly swear (or affirm) that we support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ~~hairman =--~/~---- - Mark C. Duffie,~'trator AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: We award Plaintiff the sum of $2,432.17, plus interest and costs, Arbitrator, dissents. (insert name if applicable) Date of Hearing: 29 August 2003 Date of Award: 9 September 2003 Mark C. Duffle, Arbitpt~/r Arbitator's compensation to be Paid upon appeal: NOTICE OF ENTRY OF AWARD Now, this /ff day °fd'~'f~no(ice thereof ' 2003, at ..~: /~., 7~ .M., the above award was entered upon the docket an given by mail to the parties or their attorneys. Prothor~tary $290.00 1.37