A long-time client of our firm, Red Apple Orchards ("RAO"), a Pennsylvania limited liability company located in Brodheadsville, Pennsylvania, needs our help with a property dispute. As the name of the business suggests, RAO is in the business of growing and selling red, delicious apples. It also sells apple cider to its customers in the fall and gives tours of the orchard to visitors. The apple trees on the 150-acre property are very old and big and impressive. Tourists from all over the region come to RAO to view its magnificent apple trees and sample its products.

The owner and operator of RAO is Jack McCoy. His family started the business during the Great Depression.

Green Acres, LLC, also a Pennsylvania limited liability company, neighbors RAO's property on one side. Green Acres is also a family run business, owned and managed by Chuck Hatfield, whose family started farming in the 1920's, growing corn and other vegetables. Although they are neighbors, the Hatfield and McCoy families don't much like each other. Hatfield would constantly complain to the zoning officer of the Borough about the tourist traffic in and out of RAO's orchard.

RAO has at least twenty (20) old and massive apple trees that grow along the property line between its orchard and the Green Acres farm. These trees are rooted on RAO's property; however, they are so large that their colossal tree limbs extend over to Green Acres property. More than five (5) of the trees have limbs that overhang Hatfield's two (2) barns that are on the Green Acres side of the property line.

Over the past year, Chuck Hatfield has been "harassing" our client, according Jack McCoy, to trim the tree limbs back that overhang the Green Acres barns. Hatfield believes these limbs will come down with the next good snowstorm and damage the roofs of those structures. McCoy, however, argues that the tree limbs are sound and that they are not currently damaging Green Acres' property. McCoy also believes that if these magnificent trees were trimmedor worse yet, cut downhis business would suffer. Specifically, his yield of apples and apple cider would diminish, and the beauty of his orchard would be marred.

Jack McCoy has come to us because he continues to receive verbal warnings from Hatfield if those trees are not tended to. Hatfield even threatened to contact his attorney if RAO did not remedy the situation. After a lull of some two (2) months in the feud, McCoy saw employees of Green Acres cutting the limbs of his trees back to the property line.

RAO and its owner/manager want to sue Green Acres and the Hatfield family for the damage done to its property and business. Jack McCoyever the cautious businessman--also wants to know if he had some duty to care for these trees since they weren't damaging any Green Acres property.

Please research whether our client has a case against his neighbor under Pennsylvania law and, if so, identify those cause or causes of action. Also research any duty of care our client may have owed to his neighbor under the facts presented. Please draft a legal office memorandum to me and a letter to the client outlining your findings.