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HomeMy WebLinkAbout2012-7259 SECHRIST : IN THE COURT OF COMMON PLEAS OF CONSTRUCTION, INC., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : : CIVIL ACTION – LAW v. : : ROBERT J. HARPSTER, : Trial Ct. No. 2012-07259 Defendant : Superior Ct. No. 1393 MDA 2017 OPINION PURSUANT TO PA.R.A.P. 1925 Peck, J., January 18, 2018 – In this civil case involving a breach of contract in the construction of a residence, Plaintiff, a Pennsylvania corporation engaged in the business of contracting, sued Defendant for Defendant’s alleged failure to timely pay Plaintiff amounts specified in the construction contract and for Defendant’s alleged interference with the Plaintiff’s timely 1 completion of its duties under the contract. The Defendant counter-sued the Plaintiff for unsatisfactory workmanship in the construction of his residence, which formed the basis 2 of the Defendant’s breach of contract counter-claim against the Plaintiff. A jury trial was held on March 27-30, 2017, after which the jury found in favor of Plaintiff on Plaintiff’s 3 claim and Defendant’s counter-claim and awarded the Plaintiff $102,568.96 in damages. 4 Accordingly, this Court entered an Order in favor of the Plaintiff on March 30, 2017. Following a post-judgment motion by the Plaintiff to mold the jury verdict to include statutory interest, this Court entered an Order molding the verdict to include pre- judgment interest at the statutory rate of 6% per annum for a total of $129,579.72 on 5 August 21, 2017. On August 29, 2017, this Court denied Defendant’s Motion for Post- 1 See generally Pl.’s Compl., November 30, 2012. 2 See generally Def.’s Answer with New Matter and Counterclaim to Pl.’s Compl., January 8, 2013. 3 In Re: Verdict/Request to Mold Verdict/Withdraw Claim for Unfair Trade Practices, Order of Court, March 30, 2017 (Peck, J.). 4 Id. 5 Order of Court, August 21, 2017 (Peck, J.). 67 Trial Relief. The Defendant filed a Notice of Appeal on September 5, 2017. Pursuant to Pa.R.A.P. 1925(b), Defendant filed the following statement of errors complained of on 8 appeal: 1) Lack of breach of contract jury instructions regarding both testimony and evidence presented during the trial: (a) 19.150 Burden of Proof – Oral Modification of a Written Contract an nom (No Oral Modification) Clause; (b) 19.170 Condition Precedent; (Restatement (Second) of Contracts §224), (c) 19.210 Anticipatory Breach/Repudiation of Contract; and (d) 20.10 Creation of an Express Warranty. 2) The breach of contract jury instructions were not sufficiently clear and definitive in setting forth the Plaintiff or Defendant’s possible actions: (a) 19.110 Material and Immaterial Breaches; and (b) 5.10 Clear and Convincing Evidence. 3) The Court’s verdict slip did not require the jury to vote as to whether there was a material and immaterial breach of the contract through considering the five prong test derived from the Restatement (Second) of Contracts §241 to be conducted when evaluating evidence to determine if a breach of contract had actually occurred, as well as those subsequent actions of the non-breaching party who erroneously treats an immaterial breach as a material breach and treats the contract has \[sic\] ended. 4) The breach of contract jury instructions were not sufficiently clear and definitive in setting forth Plaintiff of Defendant’s possible damages: (a) 17.270 Damages – Fraudulent Misrepresentation or Nondisclosure; (b) 19.250 Damages; and (c) 19.260 Mitigation of damages. 5) Lack of jury instructions regarding the unauthorized use and substitution of nonstandard products for specified Trademark products integral to the construction contract and related specifications presented during the trial: (a) 16.00 Harm to Persons 6 In Re: Motion for Post-Trial Relief of Def., Robert J. Harpster, Order of Court, August 29, 2017 (Peck, J.). 7 Def.’s Notice of Appeal (September 5, 2017). 8 We also note that Defendant filed a Supplemental 1925(b) statement on October 24, 2017. This Court, pursuant to an Order dated December 1, 2017, denied consideration of Defendant’s supplemental 1925(b) statement. We subsequently denied Defendant’s request for reconsideration of our December 1, 2017 Order on January 12, 2018. Therefore, the arguments raised in Defendant’s supplemental 1925(b) statement will not be addressed here. See Supplemental Defendant 1925(b) Concise Statement of Errors and Other Matters, October 24, 2017; Order of Court, December 1, 2017 (Peck, J.); Order of Court, January 12, 2018 (Peck, J.). 2 Resulting From Reliance on Seller’s Misrepresentation of a Material Fact-Restatement (Second) of Torts §402B; and (b) 19.130 Modification. 6) Lack of jury instructions regarding Unfair Trade Practices and Consumer Protection Laws that were integral to the Defendant’s counterclaim were not referenced in jury instructions as was the Plaintiff’s unfair enrichment claim. 7) Lack of depositions and interrogatories related jury instructions regarding both testimony and evidence presented during the trial: (a) 3.10 Evidentiary Admissions-Answers to Interrogatories; (b) 3.20 Admissions of Fact (pleadings, responses to requests for admissions, interrogatories, stipulations of facts), and (c) 3.00 Deposition Testimony and Videotaped Testimony. 8) The Court’s molding of the jury verdict to include pre- judgment interest which was not supported by an amount determinable nor to be determined from the terms and conditions of the contract. 9) The Court undermined the Defendant’s direct testimony as a “lay person” when it directed Defendant’s attorney to prohibit the Defendant’s usage of the word “mold” on March 29, 2010 \[sic\] when referencing any stains on the wall. The Plaintiff attorney pleads with the Court on March 29, 2017 (TR Pg 6) “if this would have \[sic\] been brought to our attention…some sort of environmental inspection or hazard inspection to \[sic\] be done…” (See attachment (Exhibit A) Pictures of foundation walls with stains, dehumidifier logs, and CDC information on mold were forwarded February 16, 2017 and February 21, 2017). The Court warns the Defendant’s attorney of a possible Discovery violation when no warning was appropriate. 10) Plaintiff representative’s subpoenas for witnesses who testified, as well as documents (Fairview Township Building Permit st File and Members 1 FCU mortgage file) which were never provided to the Defendant pursuant to the rules of Discovery were permitted by the Court. Plaintiff attorney admits on the record that document subpoenas were issued and not disclosed to Defendant. 11) Plaintiff Attorney misconduct regarding Discovery violations, as well as, false and misleading statements to the jury and Court. 12) The Court’s list of Plaintiff exhibits provided to the jury included a description of a Defendant email referenced as a “Termination Email” which was highly pre-Judicial \[sic\]. The title of the Defendant’s email was “NOTIFICATION – BREACH OF 3 CONTRACT & PROHIBITED ACCESS TO PROPERTY UNTIL FURTHER NOTICE.” 13) Plaintiff expert witness testimony relied upon a moisture gage which he admitted lacked the capability to determine the amount of water that was either possibly passing through the exterior foundation block wall face or the amount of water that was possibly accumulating inside the foundation block wall. In addition, despite the fact that a dehumidifier was continually cycling at a 55% humidity rate during his inspection on March 15, 2017 in the presence of the Plaintiff and Defendant attorneys, Plaintiff, Defendant, and Defendant’s brother, he testified that he found humidity levels of less than 19% throughout the Defendant’s basement. The testimony did not satisfy the Frye standard for admissibility of scientific, technical, and or other specialized knowledge with respect to his “evaporation theory” and associated recommendation. 14) Plaintiff witness Derick Trout testifies as an expert relative to water infiltration, condensation, and weather related issues to thwart the required expert disclosure and discovery process. 15) The Court allowed the testimony of Plaintiff’s witness, Steven Gertz, who admitted on several occasions during direct testimony that he didn’t have his reading glasses and couldn’t read several documents that were entered into evidence. 16) Juror communicating privately with the Court who is confused about ongoing testimony and questions the fairness of our court system including verdicts of some publicized cases of which these topics were not disclosed to the Defendant in their entirety by the Court for further consideration. 17) Juror(s) no. MAR-27-321 (Bar Scan No. 17) and the Caucasian male juror with black rim glasses sitting next to him were permitted to periodically sleep throughout the trial during the 9 testimony of the Plaintiff, Defendant and other witnesses. Based upon the above alleged errors, the Defendant prays for the Court’s 10 judgments to be vacated and a new trial to be granted. Pursuant to Pa.R.A.P. 1925(a), this opinion is written in support of this Court’s judgments. 9 Def.’s Concise Statement of Errors and Other Matters Pursuant to PA Rule 1925(b) Regarding the Final Order Entered in the Docket on Sep. 1, 2017 and Aug. 30, 2017 Non-Final Order (October 2, 2017). 10 Id. 4 FINDINGS OF FACT The Plaintiff’s evidence in support of its claim for breach of contract against Defendant was as follows: The Plaintiff and Defendant entered into a contract for the construction of 11 Defendant’s home on February 3, 2012. The contract included specifications for the home to guide how the project was to be completed, and a “draw schedule” to specify 12 when and how much the Plaintiff would be paid for its performance. It also contained language which provided that in the event of a breach, the non-breaching party could collect 10% of the remaining balance of the contract from the breaching party as 13 liquidated damages. The Defendant paid the first three draws to the Plaintiff, but 14 withheld payment of the fourth and final draws. 15 Eric Sechrist, the owner of Sechrist Construction, Inc., testified that Defendant 16 did not follow his advice. Defendant insisted on interviewing all of Plaintiff’s 17 subcontractors before they could start work. Defendant made several changes once the 18 work started. Defendant did work himself and hired his own subcontractors instead of 19 using Plaintiff’s subcontractors on several occasions, which delayed construction. Defendant was present at the work site most days, told Plaintiff and Plaintiff’s 11 See Transcript of Proceedings, 61, March 27, 2017 (hereinafter “N.T. at ___”). 12 See Pl.’s Exhibit 2, “Agreement” dated February 3, 2012 (March 28, 2017); see also Pl.’s Exhibit 10, “Disbursement Schedule” (March 28, 2017). 13 See Pl.’s Exhibit 2, “Agreement” dated February 3, 2012, 2-3 (March 28, 2017). 14 N.T. at 92, 110; see also Transcript of Proceedings, 186-87, March 28, 2017 (hereinafter “N.T. Vol. II at ___”). 15 We refer to Mr. Sechrist and Sechrist Construction, Inc. interchangeably as “Plaintiff” throughout this opinion. 16 Plaintiff advised Defendant before the project began that he should change the grade of the home by filling the excavation hole and impacting the fill to improve future drainage of the home; Defendant declined to make these changes. N.T. at 60-61. On cross-examination, Defendant denied ever having this conversation with Plaintiff. Transcript of Proceedings, 78, March 29, 2017 (hereinafter “N.T. Vol. III at ___”). Plaintiff also advised Defendant to use soil to backfill around the garage and front of the house to improve drainage, but Defendant wanted to use stone and executed a change order to that effect. N.T. at 74-75. 17 N.T. at 62-63, 84-85, 110. 18 See Pl.’s Compl., Exhibit B – Change Orders, November 30, 2012. 19 N.T. at 85-87, 92-94. 5 20 subcontractors how to do their jobs, and made them redo work they had already 21 finished. Defendant often insisted on more or different work and changes that caused 22 unnecessary delay. Plaintiff always accommodated Defendant’s requests, often paying 23 for changes himself. Defendant’s interference kept Plaintiff from completing the project 24 by the deadline. Plaintiff received an email from Defendant terminating him from the job on 25 November 9, 2012. The email stated that Plaintiff was forbidden from doing any more 26 work on the property until further notice. Plaintiff was instructed to remove everything, 27 including his tools, from the property. As a result, Plaintiff was prevented from further 28 performance under the contract. Even though Defendant never released the final two 29 draws, Plaintiff paid all of his subcontractors in full for their work. The manager from Defendant’s lending bank testified that before the bank would approve any draws on a construction loan, certain specific portions of the work had to be done on the project and the bank’s appraiser would have to do an inspection and 30 authorize release of the funds. The bank’s appraiser testified that the draw schedule attached to the parties’ agreement was a boilerplate schedule prepared by the bank, and that the work necessary to release each draw could vary from builder to builder 20 N.T. at 68-71, 78, 81-83. 21 Defendant made Plaintiff dig up rocks and clean them. N.T. at 77. Defendant made the roofer redistribute unplaced shingles to different areas of the roof. N.T. at 80. 22 Defendant changed the type of mortar to be used in the basement after the mortar had been delivered to the job site. N.T. at 66. Defendant would only allow specific pieces of lumber to be used. N.T. at 79. Plaintiff shut down the project for 1-2 days while awaiting delivery of new trusses because Defendant would not accept the ones that were delivered. N.T. at 83. Defendant wanted different kitchen cabinets than the ones Plaintiff would provide, at a cost of about twice the allowance under the construction loan. N.T. at 89. Plaintiff, the waterproofing subcontractor, and the excavator returned to the jobsite several times to do additional work when Defendant wanted to raise the grade of the house. N.T. at 100-01. 23 N.T. at 131, 141. 24 N.T. at 122-23, 127. 25 N.T. at 94-95. 26 N.T. at 95; see also Pl.’s Exhibit 6, Termination Email dated 11/09/12, March 27, 2017. 27 N.T. at 118-19. 28 N.T. at 97. 29 N.T. at 97-98. 30 N.T. Vol. II at 16-17. 6 31 depending on how they organized the build timeline. The actual release of funds under each draw was based upon the appraiser’s judgment of whether an adequate amount of progress had been made since the last draw, and not on exactly what was written in the 32 draw schedule. It is common practice to approve a draw even if every single item has 33 not been completed at that point. The appraiser personally inspected the property prior to the release of each draw, and on October 21, 2012, found that the progress on the 34 construction was adequate to release the fourth draw to Plaintiff. The Fairview 35 township building inspector also testified that he inspected the house at various times 36 during construction and everything was up to code. Defendant contacted the lender in 37 order to stop payment to Plaintiff on the fourth draw. The fourth and fifth draws were 38 paid directly to Defendant. Darrick Trout, Plaintiff’s waterproofing technician, testified that he took extra care and time to apply the waterproofing membrane to the walls and gaged his work as he went to ensure that every area of the membrane was done correctly and was the proper 3940 thickness. He applied the waterproofing according to the manufacturer’s warranty, and a water test showed that there was no water infiltration into the basement through the 41 membrane. Upon questioning regarding sagging in the membrane, Mr. Trout testified that sagging in the material once sprayed is typical where there is extra thickness, and is 42 not a concern as to the quality of the waterproofing material or its application. Gary Albright, another of Plaintiff’s subcontractors who assisted with waterproofing the 31 N.T. Vol. II at 56-61. 32 Id. 33 N.T. Vol. II at 60-61. 34 N.T. Vol. II at 18, 66-67. 35 The subject property at issue here is located in Fairview Township. 36 N.T. Vol. II at 149, 154-55, 157-59. 37 N.T. Vol. II at 22. 38 N.T. Vol. II at 29. 39 N.T. Vol. II at 78, 100. 40 N.T. Vol. II at 83-84. 41 N.T. Vol. II at 100. 42 N.T. Vol. II at 93-94. Bubbling of the material is also not a concern as long as the minimum thickness of the material has been met in those areas. N.T. at 100. 7 43 foundation and basement, witnessed a water test that was performed by Tremco. No water was infiltrating into the basement during that test, except where the technician specifically placed a hose against a non-waterproofed block to show Defendant how the 44 waterproofing worked. Plaintiff personally observed another waterproofing test on the 45 basement, and no water infiltration was observed at that time. Any water infiltration or drainage problems on the property that might have occurred after Plaintiff stopped work 46 was the fault of Defendant. Plaintiff’s engineering expert also investigated whether there was water infiltration in Defendant’s basement in February of 2013 and again in 47 March 2017. He used two types of moisture readers to measure the moisture wherever 48 he saw efflorescence. The moisture levels on the walls’ surfaces were within or below 4950 the normal range. There was no water infiltration. Any moisture the Defendant experienced could be remedied by applying a coat of special paint to the walls before 51 finishing the basement. 52 The Ivany block manufacturer testified that Defendant was provided with the specifications for the generic Ivany block at the beginning of the project and did not 53 object to its use. He also stated that the primary difference between generic and 54 trademarked Ivany block is compression strength. Tests done on the two blocks also 43 N.T. 145-46. Tremco is the manufacturer of the waterproofing membrane that was used on Defendant’s home. N.T. at 144. 44 N.T. at 147-49. 45 N.T. at 98-99. 46 After Plaintiff ceased working on the property, Defendant hired his own subcontractors to fill the garage and driveway area with materials other than those initially recommended by Plaintiff. The manner in which those contractors completed the final grading of the home only served to exacerbate any drainage issues. N.T. at 135-38. 47 N.T. Vol. III at 143. 48 N.T. Vol. III at 144, 151-52. 49 N.T. Vol. III at 144, 148. 50 N.T. Vol. III at 150-51, 157-58. 51 N.T. Vol. III at 145-46. 52 Ivany block is the type of block that was used in the subject property’s basement. 53 N.T. Vol. II at 112. 54 N.T. Vol. II at 113-14. The trademarked Ivany block had a compression strength of 3,000 PSI and the generic block used for the project had 2,200 PSI. The witness stated that PSI was not relevant to the performance of the block except in high-rise construction. N.T. Vol. II at 114. 8 reveal that the generic block that was actually used was superior in quality to the 55 trademarked block with respect to water absorption. 56 Defendant’s landscaper is a former personal friend of Defendant. He did excavation work on the property before Plaintiff was hired and built drain spouts, 57 finished the retainer wall, and put in the lawn after Plaintiff was no longer on the job. 58 Defendant did not pay him for all of the work that he did. Robert Ott was a painter that was originally a subcontractor for Plaintiff, but became Defendant’s subcontractor for 59 this project as a favor to Defendant because he knew him personally and to save 60 Defendant money. He was fired by Defendant after finishing almost all of his painting 6162 work, and was not paid the final one-third of what he was owed by Defendant. The Defendant’s evidence in support of his counter-claim for breach of contract against Plaintiff was as follows: Defendant testified that Plaintiff breached the contract by not providing the 63 trademark Ivany block specified in the contract, not completing the construction of the 64 home, and performing a myriad of things inadequately under the contract. There were problems in the construction that Defendant uncovered on his own and brought to others’ 65 attention to be corrected. There were other problems that Defendant had to correct by 55 The generic block has a capacity to absorb 11.6 pounds of water per cubic foot and the trademarked block has an 11.9 lb. capacity. N.T. Vol. II at 115-16. Although negligibly different in this case, a lower absorption rate is generally better to prevent moisture intrusion. N.T. Vol. III at 124-25. 56 N.T. Vol. II at 119-20, 125. 57 N.T. Vol. II at 121-22. 58 N.T. Vol. II at 123-25, 130. 59 N.T. Vol. II at 166. 60 N.T. Vol. II at 163-64. 61 The Defendant complained about the paint job and fired the witness before giving him the chance to correct the perceived problem. N.T. Vol. II at 165. 62 N.T. Vol. II at 164-65. 63 Defendant chose the trademarked Ivany block because of a brochure that Plaintiff had provided to him, and getting that exact block was an important part of the contract. N.T. Vol. II at 188-190. 64 N.T. Vol. II at 192, 196-97; N.T. Vol. III at 16-17, 56-59, 61-62, 64. 65 The water line had to be moved. N.T. Vol. II at 194. The sewer lines in the basement were hazardously placed. N.T. Vol. II at 194. Two roof trusses were cracked. N.T. Vol. II at 195-96; N.T. Vol. III at 25-26. Rough plumbing had to be moved. N.T. Vol. III at 78-79. 9 66 himself. Defendant has to constantly run a dehumidifier in the basement and cannot use 67 the basement. Time and completion of construction has not remediated the water 68 infiltration issue in the basement. Water containment on the outside of the property also 69 continues to be an issue. 70 At the time the “termination” email was sent to Plaintiff, Defendant was still 71 interested in maintaining a contractual relationship with Plaintiff. Defendant did not release the fourth and final draws to Plaintiff because portions of the work that were to be 72 completed before the fourth draw could be paid were not done, and Defendant did not want to give Plaintiff any more money until the water infiltration issue in the basement 73 was resolved. Defendant’s expert engineer testified that in November of 2014 and again in March 2015 he personally investigated whether there was water infiltration in 74 Defendant’s basement. He determined that there was and continues to be moisture in the basement caused by voids in the waterproofing membrane, and not as the result of 75 condensation. He also stated that the final grading of a house is an integral factor in 66 Defendant squeegeed water that was pooling on the sub-floors. N.T. Vol. II at 198-99. He purchased tarps to prevent the sub-floors from becoming dirty. N.T. Vol. III at 63, 81-82. Defendant hired a subcontractor to backfill so he could have a driveway and porch due to originally incorrect grading. N.T. Vol. II at 201; N.T. Vol. III at 69-70. He built a retaining wall. N.T. Vol. III at 19. 67 N.T. Vol. II at 203-204. Defendant also stated he observed mold growth in the basement. N.T. Vol. II at 198-99. 68 N.T. Vol. III at 29-30, 44-45, 50. 69 N.T. Vol. III at 47-49. 70 See Pl.’s Exhibit 6, Termination Email dated 11/09/12, March 27, 2017. 71 N.T. at 117; N.T. Vol. III at 50-51. 72 The final electrical work, installation of kitchen appliances, and retaining walls were not completed. N.T. Vol. II at 51-52. According to the draw schedule, these items were to be finished before the fourth draw was authorized. N.T. Vol. II at 37-38. Defendant understood that the manufacturer had to be paid before the kitchen cabinets and tops would be installed. N.T. Vol. II at 191-92. Plaintiff testified that it is typical to pay for installation of the kitchen after it is completed, to make sure the materials are satisfactory. N.T. at 135. 73 N.T. Vol. III at 82-86. 74 N.T. Vol. III at 112-115. 75 N.T. Vol. III at 115, 117-18. 10 ensuring that water will drain away from the home effectively and maintaining the 76 effectiveness of a waterproofing membrane. DISCUSSION We begin by addressing the standards of review applicable to Defendant’s claims. Here Defendant claims many errors of various types, but broadly challenges the sufficiency of the evidence to sustain the jury’s verdict and complains of several of the Court’s decisions throughout the trial regarding evidentiary and procedural matters. Each of the Defendant’s claimed errors are meritless. Admission of evidence is within the sound discretion of the trial court and rulings on the admissibility of evidence will not be overturned on appeal absent an abuse of discretion. Smalls v. Pittsburgh-Corning Corp., 843 A.2d 410, 413 (Pa. Super. 2004). An abuse of discretion is “more than just an error in judgment” and only occurs when the judgment exercised was “manifestly unreasonable, or the result of partiality, prejudice, bias or ill-will.” Commonwealth v. Smith, 673 A.2d 893, 895 (Pa. 1996). Furthermore, we have discretion in deciding the content and phrasing of jury instructions, so long as the concepts are clear and accurate when presented to the jury. Commonwealth v. Stokes, 615 A.2d 704, 708 (Pa. 1992). We also have discretion to overlook procedural defects 77 and forgive harmless errors in order to expedite the judicial process. When a jury has heard a case and delivered a verdict, a new trial will not be granted unless the jury’s verdict is so contrary to the evidence as to shock one’s sense of justice and a new trial is a necessary remedy. Lanning v. West, 803 A.2d 753, 765 (Pa. Super. 2002). “A new trial will not be granted on the ground that the verdict is against the weight of the evidence where the evidence is conflicting and the fact finder could have 76 N.T. Vol. III at 125. The final grading of the home was performed by Defendant. Id. 77 See Pa.R.C.P. No. 126 (“The \[civil procedure\] rules shall be liberally construed to secure the just, speedy and inexpensive determination of every action or proceeding to which they are applicable. The court at every stage of any such action or proceeding may disregard any error or defect of procedure which does not affect the substantial rights of the parties.”); See also Rubenstein v. Southeastern Pennsylvania Transp. Authority, 668 A.2d 283, 286 (Pa. Cmwlth. 1995) (“\[Pa.R.C.P. No. 126\] functions to grant the trial court latitude to overlook any procedural defect that does not prejudice the rights of a party.”). 11 decided in favor of either party.” Id. Our decision to uphold the jury’s verdict may only be reversed if we “acted capriciously, abused \[our\] discretion, or committed an error of law that controlled the outcome of the case….If there is any support in the record for the Court's decision to deny a new trial, that decision must be affirmed.” Price v. Chevrolet Motor Div. of General Motors Corp., 765 A.2d 800, 807 (Pa. Super. 2000) (internal citations omitted). Here there was sufficient evidence to support the jury’s verdict finding that Defendant breached the contract with Plaintiff, and that damages in the amount awarded to Plaintiff were appropriate. There was no abuse of discretion or any harmful error on the part of this Court that would warrant any relief that Defendant has requested. This Court’s decisions to enter the verdict as found by the jury and deny Defendant’s request for a new trial should be affirmed. We now turn to address each of Defendant’s errors. a. Jury Instructions and Verdict Slip Defendant’s errors numbered one through seven allege various deficiencies in, absences of, or other issues with the jury instructions and verdict slip. As a threshold matter, in order to properly preserve an issue upon appeal concerning the form or content of jury instructions or a verdict slip, the complaining party must timely object. Commonwealth v. Gonzalez, 112 A.3d 1232, 1240 (Pa. Super. 2015); Commonwealth v. DuPont, 730 A.2d 970, 984-85 (Pa. Super. 1999). A defendant must make a specific and timely objection at trial to a particular jury instruction, or waiver will result. See Pa.R.A.P. Rule 302 (b); Commonwealth v. Charleston, 16 A.3d 505, 527 (Pa. Super. 2011). Furthermore, as attorneys for each party act as the representatives of their clients, any acts performed and statements made by the attorney within the scope of his or her employment and authority are binding upon the client. Walck v. Dept. of Transportation, Bureau of Driver Licensing, 625 A.2d 1276 (Pa. Cmwlth. 1993). Any stipulation or lack of objection made by the party’s attorney during the course of the proceeding is imputed to his or her client, along with any resulting waiver of the client’s rights. 12 Here, we provided each party ample opportunity to submit its own proposed jury 78 instructions. Each party, in fact, did submit its own jury instructions. Thereafter, we took each side’s suggestions and incorporated them where appropriate into our own instructions. No instructions regarding Plaintiff’s unfair Enrichment claim or Defendant’s 79 Unfair Trade Practices claim were necessary, as neither claim went to the jury. Instructions regarding the clear and convincing standard of proof were not required, as the only claim before the jury (e.g. breach of contract) required each party to respectively 80 prove his claim by a preponderance of the evidence. Neither party raised an objection to any of the jury instructions in their final form, either before or after the jury was 81 charged. We specifically considered whether the final instructions were complete, clear, and thorough in order to give the jury all the information it needed to properly deliberate and reach a verdict before charging the jury. Upon review of the transcript, there is no evidence to support the Defendant’s argument that the jury instructions were deficient. Even if there was any deficiency, Defendant has waived this argument by not objecting to the instructions at the time of trial. 82 Similarly, this Court did not find any deficiency in the content of the verdict slip. Even if a deficiency existed, the Defendant has waived any objection to the verdict slip 83 by not raising the issue at trial. 78 N.T. at 5-7. 79 Following a motion by Defendant to dismiss Plaintiff’s unjust enrichment claim and after a discussion with both counsel on the matter, that claim was dismissed by Order of Court. N.T. Vol. III at 139-40. Defendant voluntarily withdrew his claim for Unfair Trade Practices. N.T. Vol. IV at 67. 80 See Snyder v. Gravell, 666 A.2d 341, 343 (Pa. Super. 1995). 81 N.T. at 35; N.T. Vol. II at 210; see also Transcript of Proceedings, 2, 53, March 30, 2017 (hereinafter “N.T. Vol. IV at ___”). 82 Specifically, Defendant’s claim that the verdict slip was deficient in that it did not include a section for the jurors to vote on whether there had been a material breach of the contract is without merit because this Court specifically instructed the jury on the elements of breach of contract, including material breach, as well as defined “material breach” for the jury. See N.T. Vol. IV at 40, 44-45. 83 Defendant’s counsel specifically did not raise an objection to the exclusion of a materiality provision in the verdict slip when given the opportunity by the Court to do so, and both parties agree that the materiality question did not need to be included on the verdict slip. N.T. Vol. III at 129, 173. 13 b. Molding the Verdict to Include Statutory Pre-Judgment Interest The Court’s molding of the jury verdict to include 6% prejudgment interest was appropriate. “In contract cases, statutory prejudgment interest is awardable as of right.” Pittsburgh Const. Co. v. Griffith, 834 A.2d 572, 590 (Pa. Super. 2003) (internal citations omitted). “In claims that arise out of a contractual right, interest has been allowed at the 84 legal rate from the date that payment was wrongfully withheld, where the damages are liquidated and certain, and the interest is readily ascertainable through computation.” Id. “\[E\]ven where the terms of a contract do not expressly provide for the payment of interest, a nonbreaching party has a legal right to recover interest, as damages, on a definite sum owed under the contract.” Cresci Const. Services, Inc. v. Martin, 64 A.3d 254, 262 (Pa. Super. 2013) (internal citations omitted). “The disputed amount must be either specified in the contract or ascertained from the terms of the contract such that at the time of breach, the breaching party can proffer a tender.” Id. at 265. Here the parties had a contract which provided that certain amounts were to be paid by Defendant in exchange for performance by Plaintiff over several different time 85 periods for the construction of Defendant’s home. The contract also included reciprocal provisions that in the event of a breach, liquidated damages in the amount of ten per cent (10%) of the remaining balance of the contract would be paid by the breaching party to 86 the non-breaching party. These amounts were certain and determined by the parties at 87 the time of contracting, and were clearly expressed by the terms of the contract. Furthermore, at trial, the parties stipulated that $102,568.96 was the correct amount of 88 damages for purposes of the Plaintiff’s claim, not including statutory interest. Prejudgment interest is therefore readily ascertainable through computation and is appropriate in this case. 84 See 41 P.S. §202 (the “legal rate of interest” shall be construed to refer to the rate of interest of 6% per annum). 85 See Pl.’s Exhibit 2, “Agreement” dated February 3, 2012 (March 28, 2017); see also Pl.’s Exhibit 10, “Disbursement Schedule” (March 28, 2017). 86 See Pl.’s Exhibit 2, “Agreement” dated February 3, 2012, 2-3 (March 28, 2017). 87 See Pl.’s Exhibit 2, “Agreement” dated February 3, 2012 (March 28, 2017); Pl.’s Exhibit 10, “Disbursement Schedule” (March 28, 2017); N.T. Vol. II at 168. 88 N.T. Vol. II at 168-73. 14 c. Defendant’s Testimony Regarding Mold in the Basement The Defendant’s claim that his lay testimony regarding mold was undermined by the Court is without merit. It is axiomatic that an attorney represents his or her client’s best interests, and that all duly admitted attorneys in good standing are presumed to be competent. See Commonwealth v. Pierce, 527 A.2d 973 (Pa. 1987). Although clients have the ultimate authority to determine the objectives of representation, lawyers have 89 latitude to determine the means to achieve those objectives, including trial strategy. Here, there was a discussion on the record between the Court and both attorneys 90 about the issue of mold. It was agreed that neither party’s expert witness would testify as to the presence or absence of mold because there had been no formal testing done 91 regarding this fact. There was ultimately no expert testimony regarding mold. After Plaintiff complained that lay testimony regarding mold would be improper, Defendant’s counsel specifically offered to instruct his client not to testify further about mold so as to 92 accommodate Plaintiff’s objection. In this case, Defendant’s attorney stipulated not to discuss the presence or absence of mold (or what Defendant believed caused the mold) in the Defendant’s basement in front of the jury, and instructed his client to proceed accordingly. Defendant acquiesced to this request, and did not press the matter during the trial. There is no indication in the record that Defendant disagreed with his attorney’s strategy or that the Defendant’s then- counsel was not acting in the best interests of his client. Indeed, Defendant’s counsel was adept and presented as a skilled trial lawyer. Furthermore, the jury was able to view all of the photographs of the alleged damage about which Defendant complained as the testimony progressed and during deliberations. The jury was free to interpret what caused the alleged damage to Defendant’s basement based on common sense and regardless of 89 See 42 Pa.C.S.A. Rules of Prof. Conduct, Rule 1.2(a); See also 42 Pa.C.S.A. Rules of Prof. Conduct, Rule 1.4, cmt. 2 (a lawyer must reasonably consult with the client about the means used to accomplish his objectives, either before or within a reasonable time after acting on his behalf. In some circumstances, including at trial, the lawyer may need to act without first consulting the client.) 90 N.T. Vol. III at 6-12. 91 N.T. Vol. III at 7-8. 92 N.T. Vol. III at 12. 15 courtroom semantics. In addition, the Defendant actually did, at one point, say that he believed there was mold in his basement; this statement was not corrected by either 93 party’s attorney or the Court. The jury therefore heard this testimony and was free to consider it and give it whatever weight they thought it deserved. The Defendant’s claim that the Court gave an inappropriate warning to Defendant regarding a possible discovery violation is likewise without merit. The Court gave no such warning to Defendant, nor did the Court instruct Defendant not to use the word “mold” in his testimony. Even if Defendant interpreted the Court’s conversation with the attorneys as such a warning, it would not have been inappropriate given that both parties’ counsel agreed that such evidence should not be admitted at trial. Generally, the facts known and opinions to be given by a party’s expert at trial are discovered before trial begins during the discovery process. If discovery of the expert witness has been completed, the expert is not permitted to testify beyond the scope of that discovery or testify in a way that is inconsistent with his or her expert report. See Pa.R.C.P. No. 4003.5(a) and (c); Chanthavong v. Tran, 682 A.2d 334 (Pa. Super. 1996). The purpose for such a rule is to provide the adversary with the opportunity to prepare a meaningful response to the proposed testimony, and prevent unfair surprise at trial. Daddona v. Thind, 891 A.2d 786, 805 (Pa. Cmwlth. 2006). Here, the Plaintiff objected to the Defendant’s lay testimony concerning mold because the alleged mold in Defendant’s basement was not brought to the attention of Plaintiff in time to prepare a sufficient 94 rebuttal by Plaintiff’s expert witness. Even though Defendant was not testifying as an expert regarding mold, the fact that determining the presence and/or type of mold requires specific testing by an expert led the Plaintiff to object to lay testimony that 95 would essentially operate as expert testimony for the jury. Because Defendant did not 93 N.T. Vol. II at 199, 204. It should also be noted that the Court in this case was sensitive to whether a limiting instruction regarding Defendant’s testimony regarding mold would be given, as it may have called into question his credibility. Ultimately it was decided that a limiting instruction would not be given with regard to the Defendant’s testimony concerning a “black chalky substance,” a “dark spot,” or “mold” in his basement so as not to draw undue attention to the testimony. N.T. Vol. III at 31-40. 94 N.T. Vol. III at 6-7. 95 N.T. Vol. III at 9. 16 provide Plaintiff with any such expert report that mold was present and Plaintiff would have been unable to counter the allegations given there was insufficient time for an independent examination of the basement by Plaintiff’s own expert, any warning given by the Court to the Defendant in this case regarding testimony about mold would have been proper. d. Plaintiff Misconduct Defendant’s Statement of Errors complain generally of Plaintiff counsel’s “misconduct regarding discovery violations” and “false and misleading statements.” Without further specification from Defendant of the alleged egregious conduct, it is difficult for this Court to address the same. However, following review of the record, there is no evidence to suggest that Plaintiff’s attorney engaged in misconduct during the course of the trial. There were no discovery violations by Plaintiff that resulted in any prejudice to the Defendant in this case. Upon further review, it is not apparent in the record that Plaintiff made any deliberately false or misleading statements to the jury or to the Court. Defendant presents only bald assertions that Plaintiff and/or Plaintiff’s counsel was guilty of misconduct during the trial, and does not specifically cite to any particular part of the record or any specific conduct done by either of them to bolster his accusations. It is a cornerstone of the practice of law that each attorney must zealously advocate for his or her own client within the legal and ethical bounds of the law, and that the attorney will highlight the facts and inferences most favorable to his or her own 96 client. Simply because Plaintiff’s attorney highlighted different facts and inferences than Defendant over the course of the trial does not make that alternative position an erroneous or misleading one. With regards to a potential discovery violation, that issue was dealt with by the parties’ attorneys and the Court on the record and out of the hearing 96 See 42 Pa.C.S.A. Rules of Prof. Conduct, Rule 1.3, cmt. 1 (“A lawyer should pursue a matter on behalf of a client despite opposition, obstruction or personal inconvenience to the lawyer, and take whatever lawful and ethical measures are required to vindicate a client’s cause or endeavor. A lawyer must also act with commitment and dedication to the interests of the client and with zeal in advocacy upon the client’s behalf.”). 17 97 of the jury, and did not affect the course of the proceedings. Defendant’s suggested eleventh error of malfeasance on the part of Plaintiff is therefore unsubstantiated and unconvincing. Similarly, Defendant’s tenth error regarding the nondisclosure of certain witnesses and documents to the Defendant before trial is without merit. There were no witnesses presented to the jury of whom Defendant was unaware or to whom Defendant objected during the trial. Even if Plaintiff made an error by not providing Defendant with copies of the subpoenas of certain witnesses prior to trial, Defendant knew of the witnesses’ identities and prepared cross-examinations of the witnesses in order to develop their 98 testimony in full. Although the Defendant claims that the Fairview Township Building st Permit File and the Members 1 FCU mortgage file were erroneously presented during testimony, a review of the record reveals this claim to be inaccurate. The record shows that the parties stipulated both prior to trial and during trial that certain documents in the st Members 1 FCU mortgage file containing Defendant’s personal information were 99 impertinent to the litigation and would be excluded. In addition, the updated inspection st reports produced by the Members 1 FCU witness were only provided to the Plaintiff at 100 the time of trial, and they were immediately copied to the Defendant for review. As to 97st The Defendant complained that the Members 1 FCU witness had brought with her to the trial documents from Defendant’s mortgage file containing personal information about Defendant and his financial relationship with the bank that the parties had previously agreed would not be included in the testimony. The parties agreed after discussion with the Court that the contents of those documents would not be testified to, the Plaintiff would not look at them, they would not be entered into evidence, and the witness would take them back to the bank with her. The Court did not find that a discovery violation had occurred, and no objection was raised by Defendant to the testimony of the witness other than that regarding Defendant’s personal information which was already ruled on by the Court via previous stipulation of the parties. N.T. Vol. II at 4-8. 98 All witnesses who testified for Plaintiff were included in Plaintiff’s Pretrial Statement and Supplemental Pretrial Statement prior to trial. See Pl.’s Pre-Trial Memorandum, March 9, 2017; Pl.’s Supplemental Pre-Trial Memorandum, March 24, 2017. 99 N.T. Vol. II at 4-8; See also Stipulation of Parties to Resolve Def.’s Motion for Protective Order and to Resolve Pl.’s Motion to Overrule Objections to Subpoena, March 28, 2016; In re: Stipulation of Parties to Resolve Def.’s Motion for Protective Order and to Resolve Pl.’s Motion to Overrule Objections to Subpoena, Order of Court, April 7, 2016 (Peck, J.). 100 The Defendant was given the complete file one day before the records would be presented to the jury, thus giving the Defendant an adequate opportunity to prepare for cross-examination of the witness regarding those particular documents. N.T. at 7-8. 18 the entrance of the Fairview Township building Permit File, Defendant did not object to any of its contents nor to the witness’s testimony regarding such at trial, so any claim he 101 may have had regarding the propriety of this exhibit was waived. The Defendant also complains in his twelfth numbered error that the list of exhibits provided to the jury referenced a Defendant email as a “Termination Email” and that such reference was prejudicial to the Defendant because that was not the true title of the email. Even if labelling the document “Termination Letter” was error, it was harmless and did not prejudice the Defendant. As mentioned supra, the Court may disregard errors 102 that do not affect the substantial rights of the parties. In the case of an allegedly mislabeled trial exhibit, this Court finds no precedent for granting the relief the 103 Defendant requests. The general rule thus applies, and Defendant may only succeed on a showing that he was prejudiced by the allegedly mislabeled document. The jury is entitled to use common sense, as well as their common-sense understanding of words and connotations, in interpreting the evidence. There is nothing in the record to suggest that the jury was confused or misled by the title of the document on the exhibit list as opposed to the title and content of the document itself, nor is there anything of record to indicate Defendant was prejudiced by the same. Here, the jury heard a number of witnesses testify as to the nature, substance, and import of the particular document. Plaintiff testified that the document was “an email from Mr. 101 N.T. Vol. II at 152-161; It is also noted that the Defendant had the opportunity to cross-examine the witness regarding the documents in the file, and chose not to do so. N.T. Vol. II at 161. 102 See Pa.R.C.P. No. 126. 103 Independent research by this Court did not yield any reported precedential decisions authorizing a new trial based upon mislabeled trial exhibits, and Defendant did not provide any legal support for his position asking for such in his Statement of Errors. In United States v. Banks, the Court refused to grant a Defendant’s motion for a new trial or mistrial based upon exhibits which were shown to the jury bearing solely a government exhibit label, when the parties had previously stipulated to the exhibits being labeled as “joint” exhibits. United States v. Banks, 2006 WL 8424793 (W.D. Pa. 2006). Defendant contended that such mislabeling prejudiced the jury against him. Id. The Court found that as Defendant did not explain how he was prejudiced by the incorrect labels and the jury heard evidence pertaining to the documents themselves, there was no prejudice and a new trial was not granted. Id. Although not binding on this Court, we find that the facts as stated in Banks are sufficiently analogous to our facts and the reasoning of that Court is sound. We therefore conclude that here, the reference to the November 9, 2012 letter as “Termination Letter” was not prejudicial to the Defendant and therefore does not warrant relief under the circumstances. 19 Harpster terminating \[him\] from the job” and that the email contained the words “you are 104 to be terminated from the project.” Plaintiff further testified that receipt of the document had the effect of causing him to stop all work on Defendant’s home, seek 105 counsel, and cease communications with the Defendant. Defendant testified that the document was a notice to the Plaintiff of a breach of contract and that the document 106 further indicated Defendant’s desire to work with Plaintiff. The jury was able to examine the document itself during their deliberations, and had the opportunity to view it together with their recollections of the testimony pertaining to it. That the jury ultimately found the Plaintiff more credible than Defendant and found that Defendant prevented Plaintiff from completing its work and failed to pay Plaintiff for work completed, does not rest on an exhibit label. Defendant’s fourteenth numbered error that Plaintiff used its lay witness, Derick Trout, as an expert during the trial in order to subvert the expert discovery and disclosure process for experts is also baseless. The Pennsylvania rules of evidence require that any witness who is not testifying as an expert must have personal knowledge about the matter to which he or she is testifying. See Pa.R.E. Rule 602. While expert witnesses may give their opinion regarding matters beyond their personal knowledge, lay witnesses are permitted to give their opinions only if the testimony is “rationally based on the witness’s perception; helpful to clearly understanding the witness’s testimony or to determining a fact in issue; and not based on scientific, technical, or other specialized knowledge.” Pa.R.E. Rule 701. Here, the Plaintiff did not seek to have Mr. Trout qualified as an expert during trial. Defendant did not lodge any objection seeking a ruling that his testimony be considered an unqualified expert opinion or lay opinion. Mr. Trout spoke from personal knowledge and experience as a waterproofing contractor and as the person who 104 N.T. at 94-95. 105 N.T. at 118-22, 133. 106 N.T. Vol. II at 192. 20 107 specifically did the waterproofing on the Defendant’s home. Although the witness did have specialized knowledge by virtue of his experience, some of which he shared with the jury in order to explain his own workmanship and observations of the Defendants home, it does not appear from the transcript that he answered any hypothetical questions regarding the state of Defendant’s home or based his opinions on facts that were not 108 within his personal knowledge. Furthermore, the jury was given instructions regarding 109 expert testimony and lay testimony and how to weigh the credibility of each. The jury also was instructed that they could choose either to believe or disregard opinion evidence 110 given by lay witnesses. The jury was free to disregard any of Mr. Trout’s testimony that it believed was not credible, and was free to give his testimony whatever weight they believed it deserved. Considering the above, there were no prerequisite expert testimony procedures for the Plaintiff to follow in order to present that witness’s testimony to the jury. e. Plaintiff’s Rebuttal Expert’s Testimony / Frye Standard This Court followed all necessary steps to ensure that the jury only heard admissible and relevant testimony from the Plaintiff’s expert. Pennsylvania law requires that expert evidence must meet the Frye standard, which states that “\[a\]dmissibility of the evidence depends upon the general acceptance of its validity by those scientists active in the field to which the evidence belongs.” Commonwealth v. Topa, 369 A.2d 1277, 1281 (Pa. 1977) (emphasis in original). The Frye test is satisfied when the “methodology that underlies the evidence has general acceptance in the relevant scientific community.” Grady v. Frito-Lay, Inc., 839 A.2d 1038, 1043-44 (Pa. 2003). The Court does not decide whether propositions or theories offered by the expert are true or false, but rather acts as gatekeeper to decide whether the science being offered by the expert is “sufficiently reliable, solid, trustworthy,” and “good enough to serve as the basis for the jury's findings of fact” or if it is “dressed up to look good enough, but basically so untrustworthy that no 107 N.T. Vol. III at 77-91. 108 Id. 109 N.T. Vol. IV at 31-33, 35-37. 110 N.T. Vol. IV at 37. 21 finding of fact can properly be based on it.” Blum by Blum v. Merrell Dow Pharmaceuticals, Inc., 705 A.2d 1314, 1322 (Pa. Super. 1997). Challenges to a Court’s rulings on admissibility under Frye are subject to an abuse-of-discretion standard. Grady, 839 A.2d at 1046. Importantly, we note that the Defendant did not follow necessary procedures which would have preserved his claim based on Frye for appeal. Complaints of error may not be raised for the first time on appeal; they must be raised first in the trial court where the judge can correct the errors as they are made. See Pa.R.A.P. 302(a); Commonwealth v. Clair, 326 A.2d 272, 274 (1974). “One must object to errors, improprieties or irregularities at the earliest possible stage of the criminal or civil adjudicatory process to afford the jurist hearing the case the first occasion to remedy the wrong and possibly avoid an unnecessary appeal to complain of the matter.” Commonwealth v. Strunk, 953 A.2d 577, 580 (Pa. Super. 2008) (quoting Commonwealth v. English, 667 A.2d 1123, 1126 (Pa. Super. 1995). When a Defendant raises an evidentiary challenge to the admissibility of expert testimony based on standards of scientific reliability under Frye, he must seek to preclude the evidence prior to appeal or waiver will result. See Commonwealth v. Einhorn, 911 A.2d 960, 975 (Pa. Super. 2006) (finding waiver where appellant failed to file a motion in limine and did not request a Frye hearing). If a Frye hearing has not been requested, objection to the underlying methodology used by the 111 expert witness is waived. Here Defendant did not make any motion either to request a Frye hearing or to exclude the expert’s evidence on the basis of inadequacy under Frye before or during the proceedings. In addition, Defendant did not raise any objection to the admissibility of the Plaintiff’s expert’s methodologies at trial, but rather cross-examined the expert on the 112 basis of his testimony. Regardless of Defendant’s lack of objection at the time of trial to the testimony, Defendant had adequate opportunity to, and in fact did, call into 111 Commonwealth v. Walker, 2017 WL 2992978 (Pa. Super. 2017); See also Commonwealth v. Latham, 2014 WL 10979805, at *2-3 (Pa. Super. 2014). 112 Id. 22 113 question the expert’s methods and tools of measurement on cross examination. On the other hand, Plaintiff followed all procedures necessary for his expert to give testimony, including the necessary discovery procedures, providing the expert’s report to Defendant prior to trial, and certification of the expert through testimony regarding his qualifications 114 at trial. 115 Lastly, the jury was given instructions on how to evaluate an expert’s testimony. The jury was free to believe all or part of either party’s expert witness, and was free to reconcile each expert’s testimony so as to give one expert more weight and/or credibility than the other. The Plaintiff’s Expert’s testimony was therefore properly received at trial. f. Plaintiff’s Witness’s Testimony without Reading Glasses According to the Pennsylvania Rules of Evidence, evidence is admissible when it is competent and relevant. See Pa.R.E. Rule 402; Conroy v. Rosenwald, 940 A.2d 409 (Pa. Super 2007). Evidence is relevant if it tends to prove or disprove a material fact. Id. The Court is the gatekeeper that decides which evidence is relevant and thus admissible, and which is not relevant and thus is inadmissible and should not be considered by the jury. In contrast, issues of credibility of a witness are always for the finder of fact – in this case, the jury – to decide. “Credibility determinations are within the sole province of the jury.” Martin v. Evans, 711 A.2d 458, 463 (Pa. 1998). “A jury is entitled to believe all, part, or none of the evidence presented \[and\] can believe any part of a witness’ testimony that they choose, and may disregard any portion of the testimony that they disbelieve.” Randt v. Abex Corp., 671 A.2d 228 (Pa. Super. 1996). Whether a witness is able to identify and testify about a document allegedly prepared by him bears on that witness’s credibility and on what weight the jury should give that evidence, not necessarily the relevancy of the evidence. Defendant complains that Plaintiff’s witness Steven Gertz’s testimony should not have been admitted, apparently on the basis that Mr. Gertz could not see several 113 N.T. Vol. III at 151-52, 155, 162. 114 N.T. Vol. III at 141-43. 115 N.T. Vol. IV at 35-37. 23 documents at trial without his reading glasses. Mr. Gertz was the real estate appraiser for 116 Defendant’s lending bank and made five inspections of the subject property. He offered testimony regarding his role as the inspector of the property, and testified to the 117 content of inspection reports regarding the property that he had prepared at the time. While Defendant argues the lack of glasses should therefore preclude Mr. Gertz’s testimony in total, it appears what Defendant is actually taking issue with is the witness’s credibility. Here, the jury was instructed regarding the general credibility of witnesses, including factors to consider in determining credibility, in the opening jury 118 instructions. During questioning, the witness indicated that the documents to which he was testifying were difficult to read because he did not have his reading glasses with 119 him. However, the witness also indicated that this fact would not hinder his ability to 120 read and testify to the contents of the documents. The Defendant had the opportunity to cross-examine the witness on his ability to see and testify to the documents in front of him immediately after he testified, and chose not to do so. At the close of the trial, the jury was given a standard jury instruction regarding 121 credibility, which expanded upon the initial instruction. The jury was told that a witness’s ability to see and remember the things that he or she was testifying about 122 should be factors in determining whether or not they believe the testimony. Furthermore, the jury also received the documents themselves to view in their deliberations, and had the chance to compare the witness’s testimony about the documents to the actual documents and take any discrepancies between the two into 123 account when evaluating the witness’s credibility. The jury was free to give the witness’s testimony whatever credibility and weight that they believed it deserved. Mr. Gertz’s testimony was properly admitted. 116 N.T. Vol. II at 54. 117 N.T. Vol. II at 55-71. 118 N.T. at 23, 25-27. 119 N.T. Vol. II at 56. 120 Id. 121 See Pa. SSJI (Civ), § 4.20 (2013); N.T. Vol. IV at 31-33. 122 N.T. Vol. IV at 32. 123 N.T. Vol. IV at 59, 61. 24 g. The Court’s in camera Communication with a Juror A review of the transcript gives no credence to Defendant’s allegation of error that any part of this Court’s in camera interview with a juror was inappropriate. “\[O\]nly those ex parte communications between a court and jury which are likely to prejudice a party” will require a new trial. Commonwealth v. Bradley, 459 A.2d 733, 734 (Pa. 1983). “The reason for prohibiting a trial judge from communicating with a jury ex parte is to prevent the court from unduly influencing the jury and to afford counsel an opportunity to become aware and to seek to correct any error which might occur. Where there is no showing either that the court's action may have influenced the jury or that its directions were erroneous, then the reason for the rule dissolves.” Id. at 739. During the trial, one of the jurors indicated through the Court’s bailiff to the Court that he was having some trouble understanding what was going on and expressed that he 124 wanted to be able to ask questions. After this Court consulted with the parties’ attorneys, Plaintiff’s attorney requested that the Court do an in camera interview of the juror to ensure that he was able to understand English and perform his duties 125 adequately. Both parties agreed that the Court would interview the juror on the record 126 to establish the nature of his questions and to determine whether he was fit to serve. During the in camera interview the Court re-instructed the juror to listen to the testimony and reminded him that he would be deciding the facts and applying the facts to the law 127 given by the judge, and that he could not ask questions during the trial. Although the juror indicated he disagreed with the way “the system” was set up, he maintained that he could be fair and impartial, and that he would be objective and discharge his duties as a 128 juror faithfully despite his personal feelings. He also confirmed that he could understand English and that he understood “ninety-nine percent” of what was going on in 124 N.T. Vol. II at 131. 125 N.T. Vol. II at 132. 126 N.T. Vol. II at 133-35. 127 N.T. Vol. II at 139-40. 128 N.T. Vol. II at 136-42. 25 129 the trial. The Court relayed the substance of its conversation with the juror to the parties’ attorneys, and thereafter neither party asked to see the transcript of the 130 conversation nor objected to the service of the juror. h. Sleeping Juror As stated supra, issues that are not raised at the time of trial are waived on appeal. In the case of sleeping jurors, the complaining party must demonstrate that he suffered actual prejudice caused by the sleeping juror. Commonwealth v. Lawson, 762 A.2d 753 (Pa. Super 2000), appeal denied, 781 A.2d 141 (Pa. 2001). “The mere appearance of a juror or fact finder dozing may not be taken as a clear indication that an individual is asleep, and is missing relevant testimony. Moreover, even if a juror nods off, it must be demonstrated that he actually missed portions of the testimony, and the complaining party must demonstrate that he suffered actual prejudice.” In re DeFacto Condemnation and taking of lands of WBF Associates, L.P., 972 A.2d 576, 589 (Pa. Cmwlth. 2009) (internal quotations and citations omitted). Claims involving a sleeping juror are waived if the complaining party does not take affirmative steps to both bring the issue to the trial judge’s attention and request a specific remedy from the Court at the time the claim arises. Commonwealth v. Strunk, 953 A.2d at 577, 581 (Pa. Super. 2008). Here, this Court provided the jurors with specific instructions to pay close 131 attention to the parties and the evidence. We also specifically warned the jury that 132 sleeping during the testimony would not be tolerated. This Court does not recall any juror being asleep during this particular trial; furthermore, there is no reflection in the transcript that we reprimanded any juror for sleeping during the trial. There is also no indication in the transcript that either party raised an objection regarding a sleeping juror at any time during the proceedings. Even if there was a sleeping juror present during this trial, Defendant did not raise the issue with the Court at the time of the juror’s alleged conduct, and Defendant has further failed to specify which parts of the testimony was 129 N.T. Vol. II at 136, 138. 130 N.T. Vol. II at 142. 131 See N.T. at 21-22, 32-33. 132 N.T. at 21-22. 26 missed by the juror(s) and has failed to establish that he has suffered any prejudice as a result. Because Defendant has not met his burden to show that he was prejudiced in the result even if his allegations of a sleeping juror were true, Defendant’s seventeenth claim for error is waived and should be dismissed. CONCLUSION Based on the foregoing discussion, we respectfully request that our Orders dated March 30, 2017, August 21, 2017, and August 29, 2017 be affirmed in all respects. BY THE COURT, ___________________________ Christylee L. Peck, J. Veronica Boyer, Esq. Mette, Evans & Woodside 3401 North Front Street Harrisburg, PA 17110-0950 Attorney for Plaintiff Robert J. Harpster 758 Maple Shade Drive. Lewisberry, PA 17339 Defendant, Pro se 27