BRIEF IN SUPPORT OF DEFENDANTS' PRELIMINARY OBJECTIONS

PRELIMINARY OBJECTIONS TO COMPLAINT IN CIVIL ACTION

   ON JUNE 19, 2006 WE FILED PRELIMINARY OBJECTIONS.

THE BEGINNING OF THE LONGEST SUMMER

   I TALKED TO THE ROSTRAVER TWP ZONING OFFICER ABOUT ACCESS THROUGH THE UNOPENED ALLEY.  THEN I HAD A MEETING WITH THE ASPHALT CONTRACTOR  WHO SAID THE MOST THEY COULD HAVE MADE THE DRIVEWAY WIDER WOULD BE 2 INCHES BECAUSE OF THE STRAIGHTENING OF THE EDGES. HE ALSO SAID  IF ANYTHING THEY WENT AWAY FROM THE NEIGHBORS.  THEN HE ASKED, WHY DID THEY WAIT SO LONG?  I WAS HAPPY AFTER MEETING THE ASPHALT CONTRACTOR AND TOTALLY AGREED WITH WHAT HE SAID.  AFTER THE ASPHALT CONTRACTOR WAS DONE IN 2002, THE EDGE OF THE DRIVEWAY AWAY FROM THE NEIGHBORS, NOW HAD A 4 INCH BANK OF DIRT WHEREAS PREVIOUSLY THE GROUND TAPERED NICELY RIGHT TO THE EDGE OF THE DRIVEWAY.  I GOT THE EAVE ENCROACHMENT LAY-OUT FROM THE SURVEYOR AND TOOK THEM TO MY ATTORNEY.  I WAS ALSO GOING TO THE LIBRARY AND BORROWING MORE BOOKS.  "NOTE THAT ENCROACHMENTS ON A NEIGHBORS LAND OF 3 OR 4 INCHES ARE SERIOUS."   " A LAWYER WHO DOESN'T INVESTIGATE THE FACTS BEFORE FILLING WHAT TURNS OUT TO BE AN UNFOUNDED LAWSUIT MAY BE LIABLE.....THE PERSON WHO TOLD THE LAWYER TO FILE THE SUIT ALSO MAY BE LIABLE FOR.......   IMAGINE WHATS GOING THROUGH MY MIND.