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HomeMy WebLinkAbout94-3422 Civil TOWNSHIP OF SILVER SPRING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : GREGG R. CARIGNAN, : Defendant : NO. 94-3422 CIVIL TERM IN RE: DEFENDANT'S PRELIMINARY OBJECTIONs; BEFORE SHEELY, p.j., BAYLEY and OLER, JJ. pRDER OF COURT AND NOW, this ~ day of September, 1994, upon careful consideration of the parties' briefs and oral arguments, the Defendant's preliminary objection in the nature of a demurrer to Counts I and III of the complaint is DENIED. The defendant,s motions to strike paragraphs 8, 9, 10, 16, 17, 22, 23 and 26 of the complaint are DENIED. The defendant's motions for more specific statements with regard to paragraphs 3, 6, 13, 20 and 26 are DENIED, and defendant,s motions for more specific statements with regard to paragraphs 4, 16 and 22 are GRANTED. Finally, the defendant,s motion to dismiss for lack of subject matter jurisdiction is DENIED. BY THE COURT, ~esley Oler,~r., j~z Richard C. Snelbaker, Esq. 44 West Main Street Mechanicsburg, PA 17055 Attorney for Plaintiff TOWNSHIP OF SILVER SPRING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : GREGG R. CARIGNAN, : Defendant : NO. 94-3422 CIVIL TERM IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS BEFORE SHEELY, P.J., BAYLEY and OLER, JJ. OPINION and ORDER OF COURT Oler, J. The present case was commenced by the filing of a complaint requesting equitable relief in the form of an injunction for allegedviolations Of Silver Spring Township ordinances. At issue in this case are the preliminary objections of the defendant addressed in the following opinion. STATEMENT OF FACTS The facts in the instant case may be summarized as follows: The plaintiff is the Township of Silver Spring located in Cumberland County, Pennsylvania.~ The defendant, Gregg R. Carignan, is in possession of property known as 6495 Carlisle Pike within a C-2 Highway Commercial District in the Township of Silver Spring.2 The plaintiff initiated this action by filing a complaint which alleges that, for several years, the defendant has violated ordinances of the Township of Silver Spring by collecting and storing "junk, trash, debris, scrap, unlicensed and unworkable motor vehicles and other materials on [his property]" in violation Complaint at paragraph 1. Complaint at paragraphs 2-3, 13. NO. 94-3422 CIVIL TERM of several township ordinances.3 Regarding the specific ordinances which have been violated, the plaintiff's complaint alleges that the defendant's conduct in collecting and storing various forms of debris constitutes a violation of Ordinance No. 4 of the Silver Spring Ordinances enacted on December 15, 1959; of Ordinance No. 26 of the Silver Spring Ordinances enacted on October 14, 1969; and of various sections of the Silver Spring Township Zoning Ordinance.4 With regard to Ordinance No. 4, the complaint alleges that the defendant is in violation of the ordinance because he has created, maintained and operated a junk yard; because he has failed to obtain a license as a "junk dealer"; and because he has failed to fence in his property in accordance with the provisions of the ordinance.5 Additionally, Count I of the complaint alleges that the defendant has disregarded the Township's notice of past ordinance violations.6 Finally, Count I of the complaint alleges that the defendant's operation of a junk yard, in violation of Ordinance No. 4, constitutes a nuisance and is a threat to the public health, safety, and welfare.7 Complaint at paragraph 4. Complaint at paragraphs 6, 20 and 22. Complaint at paragraphs 6-8. Complaint at paragraph 4. Complaint at paragraphs 9, 14. 2 NO. 94-3422 CIVIL TERM With regard to the violations of Ordinance No. 26, Count III of the complaint alleges that the defendant's conduct constitutes a violation of the ordinance's proscription on the storage of "wrecked or junked motor vehicles or parts thereof on private grounds within the Township.-8 Count III also alleges that the plaintiff has notified the defendant of his violation of the ordinance.9 Count II of the complaint alleges that the defendant has violated the Silver Spring Township Zoning Ordinance. Sections 302.1A.20, 809.1A.1 and 5 of the ordinance prohibit the use of property in a C-2 Highway Commercial District for "open storage of motor vehicles as an automobile graveyard, for outdoor storage of material not part of the normal residential use of the premises and as a junk yard.''~° Finally, Count II alleges that the plaintiff has notified the defendant of his violation of the zoning ordinance.~ Count IV of the complaint alleges that the defendant's conduct, referred to in paragraph 4 of the complaint, including storage of junk, trash, debris, scrap, and motor vehicles on his property, constitutes a public nuisance.~2 In support of this Complaint at paragraphs 20-21. Complaint at paragraph 22. Complaint at paragraph 14. Complaint at paragraph 16. Complaint at paragraphs 4 and 27. 3 NO. 94-3422 CIVIL TERM nuisance theory, the complaint alleges that the conditions upon the defendant's property constitute a "threat of danger to the health, safety and welfare of the public by creating and maintaining an environment in a basically residential neighborhood which provides for the breeding of insects, vermin, and other animal life inimical to human life, by creating and maintaining a condition attractive and dangerous to unsuspecting children, and generally creating and maintaining conditions incompatible with the conditions of the community and in violation of the public rules of order .... "~ The complaint also alleges that the pattern of defendant's prior violations of Silver Spring ordinances indicates that a "multitude of summary conviction proceedings" will be necessary to enforce the ordinances in the instant case.TM Finally, the complaint avers that the plaintiff has no adequate remedy at law and demands equitable relief in the form of an injunction.~s The defendant has responded to the complaint with various preliminary objections which may be summarized as follows: (1) demurrers to Counts I and III of the complaint; (2) motions to strike several paragraphs of the complaint; (3) motions for more specific statements; and (4) a motion to dismiss for lack of subject matter jurisdiction. Complaint at paragraph 26. Complaint at paragraphs 10, 17, and 23. Complaint at paragraphs 11, 18, 24 and 28. 4 NO. 94-3422 CIVIL TERM Initially, the defendant has demurred to Count I of the complaint alleging that the plaintiff has failed to state a cause of action arising under Ordinance No. 4, which prohibits a person from engaging in the business of a junk dealer without a license.~6 The defendant argues that the complaint is deficient because it fails to allege that the defendant is a junk dealer.~7 In addition to this claim, the defendant has filed an Amended Preliminary Objection in the form of a demurrer to Count III of the complaint. With regard to the sufficiency of Count III, the defendant alleges that the plaintiff~has failed to state a cause of action under ordinance No. 26 by merely alleging the storage of junked motor vehicles and other debris on the defendant's property.~8 The defendant asserts that the presence of such vehicles on a person's property does not, in itself, support a finding of nuisance in fact and that, absent allegations of nuisance in fact, the complaint in this regard should be dismissed.~9 In addition to these demurrers, the defendant has filed motions to strike various portions of the plaintiff's complaint. More specifically, the defendant seeks to strike paragraphs 8, 10, Preliminary Objections at paragraph 2. Preliminary Objections at paragraphs 3-4. Amended Preliminary Objections at paragraph 27. Amended Preliminary Objections at paragraphs 27-28. 5 NO. 94-3422 CIVIL TERM 16, 17, 22, 23 and 26 on the ground that these paragraphs are vague and do not describe the alleged behavior of the defendant with sufficient particularity, in violation of Pa. R.C.P. 1019(a).2° Additionally, the defendant contends that the allegations of paragraphs 10, 17 and 23, which include statements that the plaintiff will be required to institute a multitude of summary conviction proceedings in order to enforce its ordinances, "as indicated by Defendant's past history in dealing with violations of Plaintiff's ordinances," are irrelevant and should be stricken.2~ Finally the defendant claims that the allegations of paragraph 9 of the complaint, indicating that the defendant's conduct constitutes a public nuisance, and the allegations of paragraph 26, indicating that the defendant's conduct presents a danger to the health, safety, and welfare of the public, should be stricken because they are conclusory statements in violation of Pa. R.C.P. 1019(a).22 The defendant has also filed motions for more specific statements regarding various paragraphs of the complaint. Initially, the defendant asserts that paragraph 3 of the complaint, which alleges that the defendant is in possession of a certain parcel of land known as 6495 Carlisle Pike, is impermissibly vague, because the parcel named in the complaint is subdivided into two Preliminary Objections at paragraphs 7, 8, 11, 12 and 13. Preliminary Objections at paragraph 11. Preliminary Objections at paragraph 9. 6 NO. 94-3422 CIVIL TERM lots, only one of which contains an automobile salvage shop containing unlicensed and unworkable vehicles.23 The defendant claims that the lack of particularity with regard to the land named in paragraph 3 entitles him to a more specific pleading.24 Also in relation to the place of the alleged violation, the defendant has filed motions for more specific statements with regard to paragraphs 13 and 26. The defendant contends that paragraph 13 of the complaint, which alleges that the subject premises are in a C-2 Highway Commercial District, is inconsistent with paragraph 26, which alleges that the defendant has created an unsafe environment in a "basically residential neighborhood.-25 Additionally, the defendant claims that the phrase "basically residential neighborhood" is vague and "does not effectively describe the alleged place of violation."26 In addition to these claims related to the land involved in the instant case, the defendant has requested a more specific pleading with regard to paragraph 4 of the complaint, which alleges that "for several years" the defendant has stored trash and debris on his property.27 The defendant contends that the averments of Preliminary Objections at paragraphs 14-16. Preliminary Objections at paragraph 16. Preliminary Objections at paragraphs 22-23. Preliminary Objections at paragraph 23. 7 NO. 94-3422 CIVIL TERM paragraph 4 do not comply with Pa. R.C.P. 1019(f), because the paragraph does not state with sufficient particularity the time at which the alleged violations occurred.28 The defendant also objects to paragraphs 16 and 22 of the complaint, which allege that the plaintiff has notified the defendant of his violations of the Silver Spring Zoning Ordinance and of Ordinance No. 26. The defendant maintains that he is entitled to a more specific pleading with regard to paragraphs 16 and 22 because they do not "particularly describe the manner of notice as required by law.''29 Additionally, the defendant submits that he is entitled to a more specific pleading with regard to paragraphs 6, 13, and 20 of the complaint because these paragraphs, which allege that the defendant has violated several Silver Spring Ordinances, do not particularly describe the official acts or documents referred to in the complaint in violation of Pa. R.C.P. 1019(d).3° Finally, the defendant asserts that this case should be dismissed for lack of subject matter jurisdiction. In making this 27 Preliminary Objections at paragraph 17; Complaint at paragraph 4. Preliminary Objections at paragraph 8. Preliminary Objections at paragraphs 17, 19. Preliminary Objections at paragraphs 20-21. 8 NO. 94-3422 CIVIL TERM assertion, the defendant contends that the plaintiff "has failed to plead service of an enforcement notice as required by law" and that this Court lacks jurisdiction over an enforcement proceeding where no notice is given.3~ STATEMENT OF LAW Demurrers. In regard to the defendant's demurrer to Count I, we note that in analyzing a pleading for purposes of a demurrer, the trial court is required to consider as admitted all well- pleaded facts and any inferences which are reasonably deducible from those facts. A preliminary objection in the nature of a demurrer should be granted only in cases which are free from doubt and where the complaint clearly fails to state a cause of action. The Court should resolve any doubt as to whether the complaint presents a valid claim for relief in favor of overruling the demurrer. Britt v. Chestnut Hill College, 429 Pa. Super. 263, 632 A.2d 557 (1993). The defendant has also filed an Amended Preliminary Objection in the form of a demurrer to Count III of the complaint alleging the plaintiff's failure to state a cause of action under ordinance No. 26 by merely alleging the storage of junked motor vehicles and other debris on the defendant's property.~2 With regard to this ~ Preliminary Objections at paragraphs 24-25. 32 In the brief filed in opposition to the defendant's preliminary objections, the plaintiff asserts that this Court should not address the defendant's amended preliminary objections 9 NO. 94-3422 CIVIL TERM claim, we note that, where a party seeks to enjoin an alleged nuisance arising from the operation of an automobile junkyard in violation of a local zoning ordinance, the record before the court must establish that the conduct of the defendant has become a nuisance in fact. 2 Summary of Pennsylvania Jurisprudence ~21:51, at 230 (1991). The storing of abandoned automobiles has been held to constitute a nuisance in fact where accumulation of the junked vehicles creates a danger to the health of a municipality's citizens by creating a breeding area for rodents or where junked vehicles create an attractive nuisance for children. Commonwealth v. Sadecky, 41 Pa. Commw. 86, 89-90, 398 A.2d 1073, 1075 (1979). Motions to strike. Pa. R.C.P. 1028(a)(2), formerly 1017(a)(2), provides that a motion to strike off a pleading is proper where the pleading fails to conform to a rule of court or where the pleading contains impertinent matter.TM A motion to because they were filed without leave of court or consent of the opposing party. Although we do not encourage this method of amendment, we note that an amendment to a preliminary objection which is filed without leave of court or consent of the opposing party can be properly considered by a reviewing court where the amendment is filed before any action is taken on the original preliminary objection. Bowman v. Meadow Ridge, Inc., 419 Pa. Super. 511, 615 A.2d 755 (1992). Accordingly, we address the defendant's amended preliminary objection on its merits. 3~ With respect to preliminary objections seeking to strike impertinent matter, the Commonwealth Court has held that the authority of a court to strike impertinent matter should be sparingly exercised and only when a party can affirmatively show prejudice. Commonwealth, Dep't. of Envtl. Resources v. Hartford Accident and Indemnification Co., 40 Pa. Commw. 133, 138, 396 A.2d 885, 888 (1980). 10 NO. 94-3422 CIVIL TERM strike, however, is not a substitute for a motion for a more specific pleading. "[F]ailure to conform to a rule of court contemplated by a preliminary objection in the nature of a motion to strike is not the mere failure to plead sufficient facts .... " Huguet v. Foodsaves, Inc., 3 Pa. D. & C.3d 136, 138 (Chester Co. 1971). Additionally, a motion to strike must be overruled where it is substituted for a motion for a more specific pleading. McNally v. Eynoyer, 1 Pa. D. & C.4th 372, 375 (Lancaster Co. 1988); see also 2 Goodrich Amram 2d 1017(b):12, at 256 (1991). With regard to the defendant's motion to strike paragraph 26 as a conclusory allegation, we note that the Pennsylvania Rules of Civil Procedure do not expressly prohibit pleading conclusions of law. Such pleading is, however, impliedly prohibited by Rule 1019(a), which restricts pleadings to the material facts upon which a claim or defense is based. 2 Goodrich Amram 2d S1019(a):7, at 322 (1991). "A practical test of whether an averment is a conclusion of law is whether it could fit or describe two or more factual situations and whether it states the consequences of what happened instead of the fact of what happened." Id., at 322-23. A reviewing court is permitted wide discretion in determining whether an averment is a conclusion of law or an allegation of fact or whether a particular averment constitutes evidence rather than a material fact. "What would normally be a 'conclusion of law' 11 NO. 94-3422 CIVIL TERM may, in a particular pleading, be considered a material fact." Id., at 324. Motion for a more specific pleading. With regard to the defendant's motions for more specific statements, we note that Pa. R.C.P. 1019 provides that the material facts on which a cause of action or defense is based shall be stated in a concise and summary form. Pa. R.C.P. 1019(a). In this regard, where a preliminary objection challenges the sufficiency of a pleading, "[t]he question to be decided is ... whether [the] pleading ... informs an opponent with accuracy and completeness of the specific basis on which recovery is sought so that he or she may know without question upon what gounds to make his or her defense." 2 Goodrich Amram 2d S1017(b):21, at 265 (1991). In regard to the information sought upon a motion for a more specific pleading, it is well established that a motion seeking details which are more easily known by the adverse party will be denied. Under such circumstances, "it [becomes] obvious that the adverse party merely wants to determine how much his adversary 'knows' and could prove and is not requesting the specific pleading because he is in the dark about what the pleading party is claiming." Speck v. Finegold, 268 Pa. Super. 342, 352 n.10, 408 A.2d 496, 501 n.10 (1979), rev'd on other grounds, 497 Pa. 77, 439 A.2d 110 (1981). In addressing the defendant's motion for a more specific 12 NO. 94-3422 CIVIL TERM pleading with regard to the averments of time in paragraph 4, we note that Pa. R.C.P. 1019(f) requires averments of time and place to be specifically stated. Lack of subject matter jurisdiction. Finally, we address the law governing the defendant's motion to dismiss for lack of subject matter jurisdiction. Initially, we note that a preliminary objection averring lack of subject matter jurisdiction involves a determination of whether a court has jurisdiction over the subject matter of an action. 2 Goodrich Amram 2d S1017(b):7, at 249 (1991). "The test in such a situation is the competency of [the] court to determine controversies of the general class to which [the case] belongs. Id., at 249. With regard to the subject matter jurisdiction of this Court in zoning violation cases arising under the Pennsylvania Municipalities Planning Code (MPC), Section 617 of the MPC provides: In case any ... land is or is proposed to be · ..maintained ... in violation of any ordinance enacted under this act or prior enabling laws, the governing body; ... in addition to other remedies, may institute any appropriate action or proceeding to prevent · .. in or about such premises, any act, conduct, business or use constituting a violation.34 Additionally, in Board of Supervisors v. Matlack, 38 Pa. Commw. 34 Act of Dec. 21, 1988, P.L. 1329, S61, 53 P.S. §10617 (1994 Supp.). 13 NO. 94-3422 CIVIL TERM 523, 394 A.2d 639 (1978), the Court held that a common pleas court has jurisdiction to issue an injunction restraining a use of property which violates a township's zoning ordinance. Moreover, a township is not required to exhaust its statutory remedies to enjoin a defendant's alleged violation of its zoning ordinance. Bradley v. South Londonderry Twp., 64 Pa. Commw. 395, 440 A.2d 665 (1982). APPLICATION OF LAW TO FACTS Application of the points of law enumerated above to the facts of the instant case leads to a conclusion that the defendant's demurrer to Count I should not be granted. The defendant's preliminary objection in the form of a demurrer alleges that the plaintiff has failed to state a cause of action under Ordinance No. 4 because the complaint does not state that the defendant is a junk dealer. Examination of the complaint, however, reveals that the plaintiff has satisfied this requirement. Paragraph 7 avers that the defendant has failed to obtain a license as a junk dealer. We find this allegation sufficient to merit the denial of the defendant's motion for a demurrer. With regard to the defendant's demurrer to Count III, we find that the plaintiff has stated a cause of action under Ordinance No. 26. In making this determination we note the averments of paragraph 9 of the complaint, incorporated by reference in Count III, indicating that the defendant's operation of a junk yard 14 NO. 94-3422 CIVIL TERM constitutes a nuisance and is a threat to public health, safety and welfare. Additionally, we note that paragraph 26 alleges that the defendant's conduct as averred in paragraph 4 creates a threat of danger to the health and safety of the public by creating and maintaining an environment which provides for the breeding of insects and vermin and which creates an attractive nuisance. Reading the complaint as a whole, we are satisfied as to the averments of nuisance in fact required to maintain a cause of action. The defendant's demurrer to Count III is, therefore, denied. With regard to the defendant's motion to strike paragraphs 8, 10, 16, 17, 22, 23 and 26 on the ground that these paragraphs are vague and do not describe the alleged behavior of the defendant with sufficient particularity, we find that the defendant has substituted a motion to strike for a motion for a more specific pleading. Accordingly, we deny the defendant's motion to strike. With regard to the defendant's assertion that paragraphs 10, 17 and 23, should be stricken as irrelevant material, we find that the defendant has failed to show the prejudicial nature of the statments contained in those paragraphs and accordingly deny the motion to strike. Finally, we address the defendant's motion to strike the allegations of paragraph 9 and paragraph 26. Paragraph 9 alleges that the defendant's conduct constitutes a nuisance in fact and 15 NO. 94-3422 CIVIL TERM paragraph 26 supports this allegation by averring that the defendant's conduct is dangerous to the health, safety and welfare of the public because it creates a breeding ground for vermin and an attractive nuisance for children. In addressing the motion to strike these allegations, we reemphasize the law governing a nuisance which arises from the operation of an automobile junkyard in violation of a local zoning ordinance. Under this law, the record before the court must show that the defendant's conduct constitutes a nuisance in fact, and a nuisance in fact is established by showing that the defendant has endangered the public welfare by creating a breeding ground for vermin or by creating an attractive nuisance. We decline to strike these paragraphs as we find that they comport with the pleading requirements for nuisance in fact. We, therefore, deny the defendant's motion to strike paragraphs 9 and 26. We now address the defendant's motions for more specific statements. With regard to defendant's assertion that paragraph 3 of the complaint is impermissibly vague because it does not specify the section of the parcel which is being used as an automobile junkyard, we hold that paragraph 3 is sufficiently specific to permit the defendant to form a defense. In addition, we note that the information sough~ is easily known to the defendant and accordingly deny the motion for a more specific pleading with regard to paragraph 3. 16 NO. 94-3422 CIVIL TERM In examining paragraph 13 and paragraph 26 of the complaint, in light of the defendant's motion for a more specific pleading, we reach a similar conclusion. We find no inconsistency between paragraph 13, indicating that the subject premises are in a C-2 Highway Commercial District, and paragraph 26, which alleges that the defendant has created an unsafe environment in a "basically residential neighborhood." Furthermore, we hold that the phrase "basically residential neighborhood" is not so vague as to prevent the defendant from preparing a defense. As the premises in question are alleged to be the defendant's residence, he would appear to be aware of the nature of the surrounding neighborhood. Because the information sought by the defendant is more easily known to the defendant than to the plaintiff, we deny the defendant's motion for a more specific pleading. Applying the guidelines set forth in Pa. R.C.P. 1019(f) with respect to averments of time, we grant the defendant's motion for a more specific pleading regarding paragraph 4. This paragraph alleges that the defendant has violated the plaintiff's ordinances "for several years." We find that this allegation may be insufficient to permit the defendant to prepare a defense and instruct the defendant to specify with more particularity the time of the alleged violations. In examining the defendant's motion for more specific statements regarding the notice portions of paragraphs 16 and 22, 17 NO. 94-3422 CIVIL TERM we find that these paragraphs are deficient because they fail to particularly describe the manner of notice. Accordingly, we grant the defendant's motion for a more specific pleading and instruct the plaintiff to specify the manner of notice. In applying the relevant points of law to the defendant's motion for a more specific pleading with regard to paragraphs 6, 13 and 20, we find that additional specificity is not warranted. Defendant objects to these paragraphs because he contends that they do not describe the official acts or documents allegedly violated by the defendant. Our examination of the complaint reveals that each of the ordinances is identified by its official number or name and date of enactment. In addition, we note that defendant has appended copies of Ordinance No. 4 and Ordinance No. 26 to his brief in support of his preliminary objections. We are thus satisfied that the information in the pleading informs the defendant of the plaintiff's basis of recovery and permits the defendant to formulate a defense. The defendant's motion for a more specific pleading is therefore denied. Finally, we address the defendant's assertion that this court lacks subject matter jurisdiction over the case before us. As Pennsylvania case law indicates that a court of common pleas has jurisdiction to issue an injunction restraining the violation of a zoning ordinance, we find that this Court is competent to determine the issues arising from the instant case. Accordingly, we deny the 18 NO. 94-3422 CIVIL TERM defendant's motion to dismiss for lack of subject matter jurisdiction.3s For all of the aforementioned reasons, we enter the following order: ORDER OF COURT AND NOW, this ~ day of September, 1994, upon careful consideration of the parties' briefs and oral arguments, the Defendant's preliminary objection in the nature of a demurrer to Counts I and III of the complaint is denied. The defendant's motions to strike paragraphs 8, 9, 10, 16, 17, 22, 23 and 26 of the complaint are denied. The defendant's motions for more specific statements with regard to paragraphs 3, 6, 13, 20 and 26 are denied and that defendant's motions for more specific statements with regard to paragraphs 4, 16 and 22 are granted. Finally, the defendant's motion to dismiss for lack of subject matter jurisdiction is denied. BY THE COURT, J. Wesley Oler, J~., J. 3s Defendant asserts that this court lacks subject matter jurisdiction because the plaintiff has failed to allege that it has complied with the notice provisions of Pennsylvania Municipalities Planning Code S616.1. After examining the statute, however, we find that there is no requirement in law to give the specific notice required under section 616.1 of the MPC prior to initiating an action in equity. Subject matter jurisdiction is, therefore, properly vested in this court. 19 NO. 94-3422 CIVIL TERM Richard C. Snelbaker, Esq. 44 West Main Street Mechanicsburg, PA 17055 Attorney for Plaintiff Stephen K. Portko, Esq. 101 Office Center, Suite A 101 South Route 15 Dillsburg, PA 17019 Attorney for Defendant : rc 20 Stephen K. Portko, Esq. 101 Office Center, Suite A 101 South Route 15 Dillsburg, PA 17019 Attorney for Defendant