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HomeMy WebLinkAbout07-0463IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA KOHL ROOFING & SIDING CO. t/a KOHL BUILDING PRODUCTS INC. 1047 Old Bernville Road Reading, Pennsylvania 19605 Plaintiff, vs. MARTIN E. LICHTENBERGER t/a COUNTRY LANE CONSTRUCTION 150 Pine Knob Road Newville, Pennsylvania 17241 Defendant. Civil No: Q'`j - '~(~,3 ~ ' ~~~~1 ~~~-,, NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, Cumberland County Courthouse Square Carlisle, PA 17013 717-240-6200 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA KOHL ROOFING & SIDING CO. t/a KOHL BUILDING PRODUCTS INC. 1047 Old Bernville Road Reading, Pennsylvania 19605 Plaintiff, vs. MARTIN E. LICHTENBERGER t/a COUNTRY LANE CONSTRUCTION 150 Pine Knob Road Newville, Pennsylvania 17241 Defendant. PRAECIPE To The Prothonotary: Please accept for filing the enclosed: X Complaint ^ Complaint for Confessed Judgment and Civil No: ~ ~' - t1G 3 ~~ ~~^ X Prepare summons(es) and forward to the Sheriff for service. ^ Mail a notice of entry of judgment to the Defendant in the enclosed self- addressed, stamped envelope. I have enclosed a check in the amount of $55.50 to cover the costs of filing and $125.00 for service via the Sheriff. Please return afile-stamped copy of the Complaint to me in the enclosed self addressed stamped envelope. Thank you for your assistance. 2 Submitted, SIL~E~R,D~~& ASSOCIATES, CHTD. SILVERMAN #44089 11 0 Rockville Pike Suite 300 N. Bethesda, MD 20852 301-468-4990 P IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA KOHL ROOFING & SIDING CO. t/a KOHL BUILDING PRODUCTS INC. 1047 Old Bernville Road Reading, Pennsylvania 19605 Plaintiff, vs. MARTIN E. LICHTENBERGER t/a COUNTRY LANE CONSTRUCTION 150 Pine Knob Road Newville, Pennsylvania 17241 Civil No: O'~ - ~.{(„?~ l~ ~~`r ` v~ "-" L Defendant. COMPLAINT Plaintiff, Kohl Roofing & Siding Co. t/a Kohl Building Products Inc., by and through its attorneys, Silverman & Associates, Chtd., and Gary S. Silverman, Esq. hereby brings this action against Defendants and states as follows: Parties 1. Plaintiff Kohl Roofing & Siding Co. t/a Kohl Building Products Inc. ("Kohl") is, and was at all times relevant hereto, a Pennsylvania corporation with its principal office at 1047 Old Bernville Road, Reading, PA 19605. 2. Defendant Martin E. Lichtenberger t/a Country Lane Construction is and was at all times relevant hereto a Pennsylvania resident with a last address of 150 Pine Knob Road, Newville, Pennsylvania 17241. 4 Factual Background 3. On or about October 6, 2003, Lichtenberger executed a Business Credit Application ("Agreement") with Kohl as Country Lane Construction wherein Lichtenberger agreed to pay for materials provided by Kohl. A copy of the agreement is attached hereto as Exhibit A and incorporated herein by reference. 4. Pursuant to the terms of the Agreement, Defendants agreed to pay interest in the amount of eighteen (18%) percent per annum on the unpaid balance of any account twenty-five (25) days past due. 5. Pursuant to the terms of the Agreement, Defendants agreed to pay thirty-three and one third percent (33 1/3%) of the principal amount due for attorney's fees plus costs. COUNTI (Breach of Contract against Martin E Lichtenberger) 6. Kohl incorporate paragraphs 1 through 5 in this Count I as if fully stated herein. 7. At the request of Lichtenberger, Kohl from about April 2006 through June 2006 provided building products (hereinafter "supplies") to Country Lane Construction on open account and sent invoices demanding payment. Lichtenberger has failed to pay the principal amount totaling three thousand five hundred forty two and 48/100 dollars ($3,542.48). A true and accurate copy of the Invoices and Statements are attached hereto as Exhibit B and incorporated herein by reference. 8. Despite due demand for payment and full performance by Kohl, Lichtenberger has failed to pay Kohl pursuant to the Agreement and is in breach thereof. 9. As a result of the failure of Lichtenberger to pay the sums due, Kohl has sustained damages in the following amounts: (a) principal in the amount of $3,542.48; (b) accumulated interest through January 9, 2007 in the amount of $207.30; 5 (c) interest from January 9, 2007 until the date of judgment in the amount of 1.5% 'i per month (18% per annum); (d) attorney's fees in the amount of $1,177.49 (33 1/3% of the principal balance due); and (e) costs of this action. WHEREFORE, Plaintiffs, Kohl Roofing & Siding Co. t/a Kohl Building Products Inc. demands judgment against Defendant Martin E. Lichtenberger t/a Country Lane Construction as follows: (a) principal in the amount of $3,542.48; (b) accumulated interest through January 9, 2007 in the amount of $207.30; (c) interest from January 9, 2007 until the date of judgment in the amount of 1.5% per month (18% per annum); (d) attorney's fees in the amount of $1,177.49 (33 1/3% of the principal balance due); and (e) costs of this action. Respectfully submitted, SILVERpOIAN 83 ASSO~~bTES. CHTD. G S. erman #44089 11200 ockville Pike Suite 300 N. Bethesda, MD 20852 (301) 468-4990 Attorney for Plaintiff 6 VERIFICATION GARY S. SILVERMAN, ESQUIRE, hereby states that he is the attorney for the Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. G . Si verman #44089 11200 Rockville Pike Suite 300 N. Bethesda, MD 20852 (301) 468-4990 Attorney for Plaintiff 7 7ct Cl7 03.10:32a Sandy -._~. _~ ~ -=--= ~'~ i BUILDING DUGS r erer SO ~.ey..ey rnstructions: BUSINESS CREDIT APPLICATION ]. Complrte alt sections (missive information will delay processing). 2. Sion approp;iatc >ectiosu on FRONT and BALI( of ~~• Date of application: /l'i » (~ - ~ 3 3. Provide financial statement /l Credit Limit Requested ~ St.)Gip 00 Legal Name of Business: (~ p /1 yV ~~ L ~ ~ ~n rr~oy~~ ~~ K e b ~ ~ )~ •-~---~ DBA: Address: _~~_ r Ne JC •// City: ~ 1 Business Phone: (7~7) 7?~• y3,, Fax M: 617) 77G- State: ~ ZiP._~7~y~ Y~/q Fed. Tax 1.U. #: Corporation Sole Prop Partnership Havr you ever had an account with Ko1t1 Building Products? _ y~ ~ No Name of previous business: Nature of Business: ~ARp~,~Ry ~ /yj,9So,.. ~t.,i Parent Company Name {it an ~ Date Started: ~ - 9~f YY Name do Address of Bonding Co.; T~t Status: ~C Taxable _Non-taxable (If tax-exempt, certifcate must be providcdJ Are owners also involved in any other business?_,,~/Yes X No If yes Name(s) of Business(es): Who should we eonttsct regarding purchasing?; /~//~R~i~[r ~~~Z+C~ t~ 1 Principals: Full Name Purchase Order Required? ._ _ 1. 3 1 Hotrtc Address & Phone # Supplier References: Natnr 3 Have any of the principals Phone it ~,~- avs- '7. -.- -s..~., 776-4119 p.l DRPORATE &,:READIT\'G BRANCH OFFICES: 047,OId Berrtvilk Road.Readln8, PA 14601-93fi 610-926-8800 610-926=0806 (FAX) Fax - .ice-u. X Yes _ No Social Security is Aect # htLorder to in[lerce KOHL BUI3.DING PRODUCTS GUARANTY ~IA1~A+m ro KBP, prompt payment RK a!1 tnatc[ials paurebucd from TCBP, u~h['z or not the nmatnt oCoan~d ~ or bus[nese apPlymg for credit above. I/WE h also PERSONALLY GUA.RA.*t'fY . purchase exceeds the acdit limit aob3' PERSONALLY Payment of 1 1I1 ti per month interest on the unpaid balance of any t,atwot ?S days ast due, riD4t'~0d in the weds application. L'WE UWE ackrtowledge that the terms and oondhions tatttained in fhe business credit P plus 33 t/3!. sumrtey's fees and court eostg, Additionally, appliption shall be incarportaed herein by rcfatxcc and be made a part of Ihis GUARANTY. 11tia is a canGnuiag GUARANTY sad shall remain in full force and effect mail rctroked by Guarmttor by notice in writing by anified mtsiUrcttsm secs t revocation shall be eRopive only as tti claims [bat aria out of transactions entered inb aRa the rexei t of said notice. rcprcsrnfatives, successors and asri P P r'equtsted ro KBP. Stall[ t;ns of Guarantors}. The tmdasi ned h 71ds GUARANTY shall remain binding upon. the heirs, cxase pmsrnnnrnt or protest and h a B oreby waive their homestead rcetttption as well as all tequitgneats or ri creby ppomts any emPloYM of KBP or attotnty to appear in any coact or competent jurisdiction far the tT~ with regard to notice, deaand, ptttsuatu to the terms of this GUARANTY, putpoee of eonfeuing judgement on alt amounts due The undersigned, rccogs,izing that his or ha individual eratit history may be a factor in ffie ev~uation of accepting thin GUARANTY, hereby consents to and anthorius KBp to obtain and use (from time !o lime and on an "as needed' basis) arty and all information rcLued [o the credit evaluation process, including but not limited b, the mdertigtted's wasttma credit report. i\TI'ORTA~T NOTICE• TI37S CONTAINS A CONFESSION OF Ji:1DGEA'[ENT PRO~tSIOHI, WHICH CONSTITUTES A WAIVER OF I.'NPORTANT RIGHTS YOU MAY HAVE AS A DEBTOR AND ALLOWS THE CREDITOR TO OBTAIi\ A JU17GEiKENT AGAPiST YOL' WITHOUT FURTIIER NOTICE. Signature No Titles Print Namc: SS k Signature Datc__~__ No 7'i[ks --- --- Print Natno: SS # Signature Date~_ `-- ------- No Tides Print Name: -" SS # Signature _ _ Datc __ No Titles _ Print Name: SS k Due Q~P~t65lAlASiEtCS~CItE0.AP (20010.}) 4 Position ---- ---._ ........,,. vau,cruptcyr (explain) /Yo - Have any of the principals or business had a judgement entered against them? {exptain)_~e ~O~t 07 03 10:34a Sandi 776-4119 p,l 1. These terms of sale, as well as all aspects of this applieatron (i ludin ~1~ITIONS OF SALE State and Federal laws. Additionally, all decisions with regard to the extension of credit to e arartty), have been reviewed for, and. are in compliance with all guarantor shall be made in accordance Ktith applicable State and Federal laws, including but ~imidrto~the tie Crcdil Opportunity Act prohibits cred'ettxs from discriminatin ProPrietorshtP, individual or personal tKtat Credit Opportunity Act. The Equal g against credit applicants: on basis of race, color, religion, nations( origin, sex, marital status, age; because all tx part of the applicant's income is derived from any public assistance program, or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. 2. These terms and eondititets of sale t~ PRODUCTS (hereafter referred to as KBP), Intl ding all direct s~hic all other agrcetnents between the parties) as to all sales made by KOHL BUILDING Additionally, Purchaser egrets that they shall be responsible for payment ofa0 matcrialshcvcnrwhere staidurchaselex to Purchaser's various job accounts. of sale arc I°h IOth & 25th. P eeeds the credit limit requested. Terms 3. All orders arc based on quotation. Purchaser will. be billed at the prices quoted. All otherwise specified in writing by an agent. of KBP. ~Pritxs for a!1 other items are FOB pot of del veryt ~Thc price guar d ~ subject to additional Federal, State, or Local taxes. PP S Point unless 4. All orders placed for special order materials. (i. e: thosrmateriats not kept in stock) are first and may require deposit at time of order, with full required prior to dNivery. Once a.specisl order Is plaeed.and confirmed in writing by KBP, purchaser . in full. Returns for non-stock or special order materials are .subject to the. manutauurer's return policy. Payment in agrees to accept said materials and make payment 5. All materials delivered must be exattined.and inspected. deliycry. Where Purchaser cannot. examine : bxahr. P~aser upon receipt. Any claim of shortage or damage must be made u timt of after the time and insPea material upon receipt,. any and all claims must br made within 3 days of delivery, Any claims trade period shall be honored at the sole discretion of KBP. 6. Defcuive material may be returned for credit or rcplacemcnt. Returns must be accompanied with the original invoice or invoice number of purchase. -defective stock items may be returned and credit gill be given when material is received and inspeucd, Non-defective stuck materials returned are s jeer to a 1S°h handling fee. Additionally, restocking charges imposed by the manufacturer will be charged to the Purchaser. 7. Purchaser agrees that their sole remedy available for arty default arising out of the sale of mazerials shat! be the rearm of said materials purchased for a full refund, and that no suit for default will be brou tht against, or include KBP where caescqucntiat or incidcntat dturmgcs, attorney's fees or costa arc soveht. 8: On orders placed where the delivery date is detaytd due to a manufacturer's shipping, or any other error, Purchaser agrees to hold KBP delay and agrees to.maCe pavmcnt in fall for material. Purchaser further agrees that KBP shat( not be responsible for, and shalt hold KBP harmless, for any product defect, manufacturer's shi rn defect, or any injury to harmless for any DP g person(s) due to said defects. 9. KBP makes NO WARRANTIES express or implied, including without limitation, W ARRANTIFS AS TO MERCHANTABILITY, OR AS TO FITNESS FOR A PARTICULAR USE OR PURPOSE, and snap not be liable for any loss or damage arising from the use of such materials. ALL MATERIALS ARF DELIVERED "AS [S" AND ^WiTN ALL FAULTS'. Arty contradictory statement made by an employee of KBI', shall have no effect. ! 0. On all matters referred by KBP to their attorneys for colleuion, Purchaser agrees to pay 33 1B% of the principal amount due for attome s f costs. AO invoices arc due net 30 days from date of invoice or statement, and any unpaid balance 25 days past due from invoice or statement date shall be charged 11/2% per month interest (18'% annum). ~ mss' plus 1 ] .Purchaser agrees that all material sold on account constitute a continuing contract, and no considered separate .for the purpose of mechanics liens, payment bonds, or for an other u specific individual sate, invoice, or purchase item shall be fu1L, Y p rposc. Title to elf material shall remain KBP until paid for in l2. Purchaser represents and warrants that the information provided herein is true and complete Further purchaser authorizes KBP to make all in uirie deems accessary to verify the information provided above, including Dun & Bradstreet reports and credit report information, and as such the undersigned ivho is either the principal of the credit applicant or other interested party, (recognizing that his or her individual credit may be s factor in the evaluation of the credit history of the applicant), hereby consents to and authorizes KBP to obtain and use (from time to time and on an "as needed" basis) any and all information related to the credit evaluation process, including but not limited to, the undcisigned's consumer credit report. 13. Purchaser waives hislher/its homestead exemption as wdf as all requirements or rights with regard to noticx, dornand, appQQruts any employee of KBP or any attorney for the purpose ofnpnfessing judgement in any court of competent jurtsdiclr~nninnfavtx of [{gp oa alhelreby amounts due under the provisions of these terms and conditions of sate. IMPORTANT NOTICE: THIS INSTRUMENT CONTAINS A CONFESSION OF JUDGEMENT PROVISION. WHICH CONSTITUT A WAIVER OF IMPORTANTR[GHTS YOU MAY HAVERS A DEBTORAND ALLOWSTHE CREDITOR TO OBTAINA JUDGEMENT AGAINST YOU WITHOUT FURTHERNOTICE. Purchaser acknowledges that he/she has read and AGREES TO ALL OF THE ABOVE T)r1tMS AND CONDITIONS OF SALE. Signature -C~! ~(y.~.iQ -"-'~_L=1!~ . ~N~i~~ /t, ~~2< I~ fin. Tirle Si6mahrre "t -~iC Name 'nt) k S ~' __ Title Signature • Name (hint) ~( TiOc ^0~.~ Signah~rc Narnc (Print) eurw~liG.Pllo~ TiNc "'_" =--- =~ =KOHL BUILDING PRODUCTS COUNTRY LANE CONSTRUCTION 150 PINE KNOB RD NEWVILLE PA 17241-8645 REMIT T0: PO BOX 510843 PHILADELPHIA, PA 19175-0843 STATEMENT SHIP Tf ACCOUNT A` { COU531 STATEMENT DATE 08-30-06 COPY A' 1 Accoun+rx PHONE # DIVISION PacE COU531 717/776-4321 -zz 1 INVOICE __ ___ CUSTfJMER >INVOICE GROSS DISCOUNT DISCOUNT NET DATE PO NUMBER AMOUNT DATE AMOUNT- PAYMENT AMOUNT 04/05/06 K JONES 27958 1,286.76 480.59 806.17 04/10/06 K JONES 28350 93.92 93.92 04/14/06 HUMES 28898 1,526.56 1,526.56 04/14/06 HUMES 28949 97.37 97.37 04/18/06 HUMES 29193 84.52 84.52 04/18/06 K JONES 29198 18.03 18.03 04/19/06 HUMES 29312 17.12 17.12 04/20/0.6 HUMMES 29513 60.77 60.77 06/02/06 KELLY 34214 844.14 844.14 06/14/06 K JONES 35518 16.12- 16.12 - ~ ~ ~- s CURRENT 30 DAYS 60 DAYS 90 DAYS OVER 90 TOTAL DUE 844.14 16.12- 2,704.46 3,532.48 ~~ =~=KOHL KOHL Bl 'ING PRODUCTS REMIT T0: BUILDING PRODUCTS 860 WES~~V DRIVE PO BOX 510843 MECHANICSBURG. PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: DCS INVOICE NO. 327958 INVOICE DATE 04-05-06 ACCOUNT ~ SHIP .DATE SHfP VIA PAGE COU531 04-04-06 EMERGENCY PU 1 REFERENCE ER€1(~#HT TERM MESSAGE 717/776-4321 OUTSIpE S;4 ~ESMAM `INSIRE'SALE&MAN PURCHASE ORDER JON KAUTZ DENNY SALERNO K JONES QuAN3'iTY UC~IIA DE$CEtIPT10N QUANTITY Ut3M PRICE DISCOUNT EXT ORDERED ' SHIPPED 7b' 16 SQ MBD45DS 16 'SQ 63.'00 3008.00 MEADOWBROOK DBL 4-1/2" D-LAP DESERT SAND 6 6 PCS AWOP06DS 6 PCS 15_.570 99.42 3/4 ALCOA GRAINED OS POST; DES. SAND.. 2 2 PCS MVIP06DS 2 PCS 8.950 17.90 3/4 INSIDE CRNR; DESERT SAND 20; 20 PCS' MVJ051DS - 20 PCS 4.430 88.64 5/8 J CHANNEL - 1" FACE; DESERT SAID SUB-TOTAL ~~~~~ 1213.92 4r r , 6~ PA SALES 'AX ~~~ . 72.84 _ , ,.zy,w - -. .,~ >; 15~ Handling Charge On All Returns PAY TERMS:. 1% 10TH &_25TH DUE DATE: MAY 10, 2006 YOU MAY .DEDUCT 512':14 IF PAID ON OR BEFORE APRIL 25, 2006 TOTAL: $ 1, 286.76 ~~~ KQNL KOHL Bt WING PRODUCTS REMIT T0: BUILDING PADDUCTS 860 WES~~~' DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: DCS - INVOICE NO. 328350 'INVOICE DATE 04-10-06 > ACCOUNT'# SHIP DATE SHIP NIA PAGE COU531 04-07-06 EMERGENCY PU 1 REFERENCE FREIGHT'1`1=f~M MIrSSAGE 717/776-4321 OUTSIDE SA[.IrSMAN ___ INSIDE'. SALESMAN ' PURCHASE`ORDER JON KAUTZ DENNY SALERNO K JONES nuANTtrY UOM DESCpiPTFON QUANTITY UOM PRICE DFSCOUNT EXT ORDERED SHlPPEQ 20 20 PCS MVJ051DS 20'PCS 4.430;' 86..60 5/8 J CHANNEL - 1" FACE; DESERT SAND SUB-TOTAL 88.6a- 6l; PA SALES TAX 5.32 ~~~, ~ ~ ~ ~ ~ ~ ~. ,~ . ~~1~ ~: i~ - ~y 15% Handling Charge On All Returns PAY TERMS: 1X 10TH & 25TH DUE DATE: MAY 10, 2006 i i YOU MAY DEDUCT 5.89 IF PAID ON OR BEFORE APRIL 25, 2006 TOTAL: $ 93.92 -~KONL KOHL Bl 'ING PRODUCTS REMIT T0: BUILDINGPADDUCTS 860 WES~~V DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: DCS INVOICE NO. 328898 INVOICE DATE 04-14-06 ACCOUNT'# SHIP DATE SHIP VIA PAGE COU531 04-13-06 EMERGENCY PU i REFERENCE FREIGHT TERM MESSAGE 717/776-4321 OUTSIDE SALESMAN INSIDE ISALfrSIf~IA~V ''PURCWASE'ORDER JON KAUTZ DENNY SALERNO HUMES QUANTITY ~~ ©ESCRIPTION QUANTITY U4M PRICE DISCOUNT EXT ORDERED SHIPPED 14 14 SQ MBD45CA 14 SQ 63.00 882.00 MEADOWBROOK DBL 4-1/2" D-LAP; CAMEO' 4 4 PCS AWOP06CA 4'' PCS 16.57 66.28 3/4 ALCOA GRAINED OS POST; CAMEO 2` 2 PCS MVIP06CA 2 PCS 8.950 17.90' 3/4 INSIDE CRNR; CAMEO 20 20 PCS MVJ051CA ' 20 PCS 4.43'0 88.60 5/8 J CHANNEL - 1" FACE; CAMEO.'. 1'3 13 PCS 13 MVS250 n PCS 3.55b 46.15 ~ MASTIC VI ~.'I`ER STRTF ~~ ~r F '~ ~' ~ ..,~~ ~ . 5 ~. . 6 6 PC PTSI2VCA _ ~-.~ PC 9.390 56.34 PRO-TECH+ TPA, 4 VENTED M#;TTE; C"AI~O~~=~ ~' 8 8 PC PTSI2NCA ~ -_~~ :- ;_~ PC 9 _3''9.0 75'.12 PRO-TECH+ TFL 4 " ..SOLID M?~TTE ; Q~~'. ,_.; Z 2 RL TS24CA ~. 2 RL 72.'020 144.04 ALCOA 24" TRIM COIL; CAMEO 12 2 PCS VFROSCA 2 PCS 6.180 12.36 5/8 F CHANNEL; CAMEO 2 2 PCS OG155AL 2 PCS 1.930 3.86 ALCOA END CAPS; ALMOND 1L/1R 50 50 LB GN125 50 LB .950 47.50 1-1/4" GALV ROOFING NAILS SUB-TOTAL 1440.15 TOTAL: ~~NCJID..... ~_~_ -KO ~ ` KOHL Bl ING PRODUCTS REMIT T0: BUILDING PAODUCiS 860 WES~~Y DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHIIADEIPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: DCS INVOICE NO. 328898 INVOICE DATE 04-14-06 ACCOUNT # SHIP DATE. SHIP YIA PAGE COU531 04-13-06 EMERGENCY PU 2 REFERENCE fRE1GHT ~`ERM MESSAGE` 717/776-4321 OUTSIpE SA LESMAN iNS1DE:SALESMAN PURCHASE ORDER' JON KAUTZ DENNY SALERNO HUMES ___ Ql3ANTiTY' ORbERED SkiiRpQQ UOM t)€SCRIPTtON QUANTITY UflM ' pRtCE ' UiSCOUNT' EX7 6~ PA SALES TAX 86.41 ~_ ~~~'': ~ ,. ~.. F,~~ >,. F~f 3? .x w 15~ Handling Charge On All Returns FAY TERMS: 1X 10TH a 25TH DUE DATE: MAY 10. 2006 YOU MAY DEDUCT 514,40 IF PAID ON OR BEFORE APRIL 25, 2006 TOTAL: $ 1, 526.56 ~_~ KOHL KOHL Bl ING PRODUCTS REMIT T0: BUILDING PADDUCTS 860 WESLcY DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: DCS -INVOICE NO. 328949 INVOICE`DATE 04-14-06 ACCOUNT # SMIP QATE SMIP'V1A PAGE COU531 04-13-06 EMERGENCY PU 1 REFERENCE FCi~IGFiT TERM rtAESSA(3E 717/776-4321 OUTSIC'i~ SALESMAN INS1F1~ SAL~SNIAN PURCHASE ORDER JON KAUTZ DENNY SALERNO HUMES QF3ANTITY ORDERED &HiPPEP UQIIA DESCRIPTLOIV QUANTITY U4M PRLCE DtSCbUN7 EXT 1 1 EA MAMOUNT021 1 EA 6.'610. . 6.61 MOUNT MASTER; #21 IVORY / CAMEO Also matches: Sandstone Beige 1 1 EA MAVENT021 1 EA 10.9$'Q 10.98 EXHAUST VENT; #21 IVORY / CAMEO Also matches: Sandstone Beige i 1 BOX SSTNCH 1' BOX 2.'250 2.25 STAINLESS STEEL TRIM NAIL; CHAMPAIGNE ALSO MATCHES: WOLV SAND 1/4# BOX u~ ~..~~. ~ 1 1 RL T524CA ~. '~:; iY ~~w 'w'.~r~,,,RU ALCOA 2'4''~I~~COIIJ; CAMItO ~ ~~~ y 72.020 72.02 .~iV.. ri SUB-TOTAL 91.86 6~ PA SALES TAX 5.51 15~ Handling Charge ', On All Returns PA'f TERMS: 1X 10TH & 25TH DUE DATE: MAY 10, 2006 Y0~ MAY DEDUCT 5:92 IF PAID ON OR BEFORE APRIL 25, 2006 TOTAL: $ 97.37 ~~ T=KOHL KOHL Bl ING PRODUCTS REMIT T0: BUILDING PRODUCTS 860 WES~~Y DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: BRC INVOICE NO. '~ 329193 iNV01CE DATE I 04-18-06 I ACCOUNT # SHIP [SATE SHIP VIA PAGE COU531 04-17-06 EMERGENCY PU 1 REFEf~iVCE FR~IGH' TERM MESSAGE P 717/776-4321 OUT$1t~E SA LESMAN INSIE~E>S14)k:ESMAN PURCHASE QRDER JON KAUTZ FUTURE INS REP HUMES __ _.. nuANriTY UOM DESCRIPTION QUANTITY UDM PRICE DiSC0UN7 EXT ORDERED SHIPPED 18 18 PCS' MVJ051CA 18;PCS 4.430 79.74 5/8 J CHANNEL - 1" FACE; CAMEO SUB-TOTAL 79.74 6~ PA SALES TAX 4.78 <_ ~ Y~ r ~ S ,? 4 .5: 15?s Handling Charge On All Returns PAY TERMSi 1X 10TH & 25TH DUE DATE: MAY 25. 2006 YOU MAY DEDUCT 5.80 IF PAID ON OR BEFORE MAY 10. 2006 TOTAL: $ 84.52 =~ = KO N L KOHL Bl ING PRODUCTS REMIT T0: BUILDINGPAODUCiS 860 WES~~~( DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: BRC INVOICE NO. 329198 FNVOfCE' DATE 04-18-06 CUSTOMER/WHITE ACCOUNT. ~ '' SMIP DATE ''' SHIP VIA PAGE COU531 04-17-06 EMERGENCY PU 1 REFERENCE fREIGH't TERM MESSAGE 717/776-4321 OUTSIDE''SAC~SMAN tNSfDE:<SA[,hSMAN PURCHASE ORDER JON KAUTZ FUTURE INS REP K JONES nuaNTITY ORDERED SH#~FEp t/0M t)ESCfiIPTtUN QUANTITY tJOM PgtCi DISCOUNT EXT 3 3 PCS; MBD45DS .27 S4 63'.00 17.01 MEADOWBROOK DBL 4-1/2" D-LAP DESERT `;SAND SUB-TOTAL 17.01 6~ PA SALES TAX 1.02-. A *~~~. ,f: . 1`ry ~:; E 4: '' 15~ Handling Charge'' On All Returns i PAY TERMS: 1X 10TH &.25TH DUE DATE: MAY 25, 2006 .YOU hfAY DEDUCT 5.17 IF PAID ON OR BEFORE MAY 10, 2006 TOTAL: $ 18.03 ~~ ~~ KO N ~ KOHL Bl ING PRODUCTS REMIT T0: BUILDINGPADDUCTS 860 WES~~V DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: DCS INVOICE N'O. 329312 INVOICE DATE 04-19-06 ACCOUNT ~ _.._ ' SWIp''DATE ' Sf~tIP VlA PAGE COU531 04-18-06 EMERGENCY PU 1 REFERENCE 'FREIGHT TERM ' MESSAGE' 717/776-4321 OUTSIDl SAt ~ESMAN I NSIDE'SAGESMAN PURCHASE`ORDER JON KAUTZ PETE EMBORSKY HUMES QUANTITY ORDERED` $NiPFELI UQM DESCRIPTION QUANtITY UflM PRICE OISCOUN7 EXT ''i 1 PC PLYJWH 1 PC 16.150 16.15 PLY-J WHITE / 12' 6" SUB-TOTAL 16.15 6~ PA SALES TAX .97 ~ ~ S 3 F .Y _.. - 15~ Handling Charge' On All Returns PAY TERMS, 1~ 10TH & 25TH DUE DATE: MAY 25. 2006 YOU h}AY 6EDUCT 5.16 IF PAID ON OR BEFORE MAY 10. 2006 TOTAL: $ 17.12 s_ =_T =KOHL KOHL Bl ING PRODUCTS REMIT T0: BUILDING PRODUCTS 860 WES~~~' DRIVE PO BOX 510843 MECHANICSBURG. PA 17.055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 17241-8645 MISC: DKKJ JNUOICE NO. 329513 INVQICE DATE. 04-20-06 CUSTOMER WHITE ACCOUNT'' '' SHIP DATI~ SHIP VlA PAGE COU531 04-19-06 EMERGENCY PU 1 REFEftI_NCE ~CiE1GHT TI=Fi11A M1_SSAG.E 717/776-4321 OUTS10E-SAt,f*SMAN 'tNSIFJE`SAI,ESMAN' `Pt3RCHASE'ORD1=R JON KAUTZ DENNIS KISSINGER HUMMES nu,anrnrY ORDERED $HIP~D UOM DESCRIPTWN QUANTITY UOM PRICE E)1SCOUN7 EXT 10 10 PCS MBD45CA _91'SQ 63.00' 57.33 MEADOWBROOK DBL 4-1/2" D-LAP; CAME' SUB-TOTAL 57.33 6$ PA SALES TAX 3.44 tip, - - '~ ~~~ ` 7 - a ~ .r_ , p ._ ,~ s:<_ ;, 15~ Handling Charge On All Returns PAY TERMS: 1X 10TH & 25TH DUE DATE: MAY 25. 2006 YOU MAY DEDUCT f.57, IF PAID ON OR BEFORE MAY 10, 2006 TOTAL: $ 60.77 ~~ ~=KO N L KOHL Bl ING PRODUCTS REMIT T0: BU~LD~Nri pR~OU~$ 860 WES~~~' DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 INVOICE COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H To jobsite two story addition 150 PINE KNOB RD I 439 S YORK STREET NEWVILLE PA 17241-8645 P MECHANICSBURG PA MISC: JDS ~' IN1/UICE NO. ~ 334214 INVOICE DATE 06-02-06 CUSTOMER WHITE ACCQUNT # SHIP DATE 'SHIP V1A PAGE COU531 06-01-06 DELIVERY 1 'REF'ERENCE FREIGHT 'CfRM' MESSAGE 717/776-4321 QUTSIDE SALESMAN INS11)E 9ALESNIAN PURCHASE ORDER JON KAUTZ FUTURE INS REP KELLY nunNTiTV ORDERED $HtPPED UGHVI bI:BCRIPTION G:UANTITY U(3M PRICE DISCOUNT EXT 13 13 S¢ TIMB30BWW 13 'S4 55.770 725.01 GAF TIMBERLINE 30; WEATH. WOOD - BALTIMR BALTIMORE PRODUCT PAPER WRAPPER - STANDARD SIZE'' 1 1 BDL' SOV25WEG '.33 SQ 44.850 14.80` GAF SOVEREIGN 25YR; WEATHERED GREY 1 1 RL COBRANG 1 RL 46.550 46.55 GAF COBRA ROLL VENT . FOR NAIL Gi7N; 20' 1 1 FUEL l 10.000 10.00 FUEL SURCHARGE _ L= ~'r SUB-TOTAL 796.36 6 ~ PA SALES "!`AX ~ ' ~ " 4 7 . 7 8 =~-~ < c ;--~ 15~ Handling Charge On All Returns PAY TERMS: 1~ 10TH & 25TH DUE DATE: JULY 10. 2006 1'OU MAY DEDUCT 57:96. IF PAID ON OR BEFORE JUNE 25, 2006 TOTAL: $ 844.14 ~~~ KOHL BC ING PRODUCTS REMIT T0: ~'"KO N L 860 WES~~f DRIVE PO BOX 510843 MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843 BUILDING PADDUCis CREDIT M EM 0 COUNTRY LANE CONSTRUCTION S COUNTRY LANE CONSTRUCTION H 150 PINE KNOB RD I 150 PINE KNOB RD NEWVILLE PA 17241-8645 P NEWVILLE PA 1724.1-8645 CREDIT MEMO NO. 335518 G'REDIT MEMO 'DATE 06-14-06 ACCOUNT ~ SWIP DATE TRAN '" `` SALE: TYPE PAGE COU531 06-12-06 335518 05 1 REFERENCE ''M~SAGE 327958 717/776-4321 ._ OUTSIDE'SAI.ESI1+<AN [NSIEjE SAL~SAAAN PURCHASIr ORptFi JON KAUTZ K JONES QUANTITY UOM ORIG. INi/ # - bESCRiPT10N TOTAL UNITS UOM PRICE EXTENDED 2- PCS 327.958. MVIP06DS 2-PCS 8.950 17.90 3/4 INSIDE CRNR; DESERT SAND' 1-- EACH >' RESTOCK - 1-EACH 2.690 - 2.69 RESTOCKING CHARGE SUB-TOTAL 15.21 6~ PA SALES TAX .91 TOTAL 16.12 mss: l», ~ x` .. x9 1~~'/. `'?+. TOTAL: $ 16.12- , .~ -.. P ~ ~ .,o ~- ~- :; ~ ~ ~: -~ N ,. ~~ c_ fir, a` I V ~, ~O ~~ ~a 1 -~ -~ ~ ;~ :.. ;;~ DEBT AFFIDAVIT STATE OF Pennsylvania ) To wit: COUNTY OF Cumberland ) d7 - ~{~3 e;~.c7~ Personally appeared before me Jodi L Eberly, who being first duly sworn, says she is the Office Manager of Kohl Roofing and Siding Company d/b/a Kohl Building Products, that to the best of her knowledge and belief, Martin E. Lichtenberger is justly indebted for the amount of $3,532.48, plus interest and attorney's fees, and cost that the annexed account which is made a part hereof, is a true and correct statement of said indebtedness, no part of which has been paid, and against which there are no lawful offsets or counterclaims; that the defendant's last known address is 150 Pine Knob Road, Newville Pennsylvania 17241; and, further that the affiant is of information and belief that the debtor is not in the active military service of the United States. Jo L E erly SUBSCRIBED and SWORN TO before me this /~ ~- day of 2007. ~~ Notary Public My Commission Expires: Notarial Seal Caryl A. Hessler, Notary Public Spring Twp., Bertcs County My Commission Expres May 12, 2007 Member, Pennsylvania Association Of Notaries rv C1 ~•:~ ~... ~ 4„ , _T.~ - ~~ _ __ ~ _;~ ~ t E~ =r. -n w.... - ,7 r: ~ t-7 =i , :'.3 Cft .~ •-~ Sim son Renee ~ - ~~O`'~ From: ra-jnetoperations@state.pa.us Sent: Wednesday, January 24, 2007 9:15 AM To: Simpson, Renee Subject: PFAD Document Confirmation No.060463 against FUGITT, THOMAS 1~A~D Document Confirmation No. 060463 against ~'zIGI2*1; 2~CO~tAS fifzd 6y ~1A12,7I9V; CA9V~D2' ~~CO~~ACCL~~ B`YCL~EA9V 2007-01-24 09:14:222 SHERIFF'S RETURN - REGULAR CASE NO: 2007-00463 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KOHL ROOFING & SIDING CO VS LICHTENBERGER MARTIN E T/A COU TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LICHTENBERGER MARTIN E T/A COUNTRY LANE CONSTRUCTION the DEFENDANT at 1943:00 HOURS, on the 6th day of February 2007 at 150 PINE KNOB ROAD NEWVILLE, PA 17241 TRT T7TTTT L, T T('~V TL~TTD LSD /"~L~D by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.08 Postage .39 Surcharge 10.00 .00 .T-4 2 . 4 7 ~~i~fe 7 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 02/07/2007 SILVERMAN & ASSOCIATES -~_. By. r De uty Sherif ,' A.D. fi IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA KOHL ROOFING & SIDING CO. t/a KOHL BUILDING PRODUCTS INC. 1047 Old Bernville Road Reading, Pennsylvania 19605 Plaintiff, ~vs. Civil No: 07-463 MARTIN E. LICHTENBERGER t/a COUNTRY LANE CONSTRUCTION 150 Pine Knob Road Newville, Pennsylvania 17241 Defendant. Notice of Praecipe to Enter Judgment by Default To: Martin E. Lichtenberger t/a Country Lane Construction Date of Notice: 1 3 , 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN IO DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Court Administrator, Cumberland County 1 Courthouse Square Carlisle, PA 17013 717-240-6200 Respectfully submitted, SILVERMAN~ ASSOCIATES, CHTD. Gary Sil erg #44089 11200 ville Pike, Suite 300 North Bethesda, Maryland 20852 (30I) 468-4990 Attorney for Plaintiff CERTIFIC2ATE OF SERVICE I HEREBY CERTIFY that on this J~~day of , 2007, a copy of the foregoing otice of Praecipe to enter 3udgment by Default was sent postage prepaid via first class mail to ;fendant's last known address at: Ylartin E. Lichtenberger 154 Pine Knobb Road l~ewville, PA 17241 DEBT AFFIDAVIT STATE OF PENNSYLVANIA ) To wit: COUNTY OF CUMBERLAND ) Personally appeared before me J. Thomas Kearse, who being first duly sworn, says he is the President of Kohl Roofing and Siding Company d/b/a Kohl Building Products, that to the best of his knowledge and belief, Martin Lichtenberger t/a Country Lane Construction is justly indebted for the amount of $3,532.4$, plus interest and attorney's fees, and cost that the annexed account which is made a part hereof, is a true and correct statement of said indebtedness, no part of which has been paid, and against which there are no lawful offsets or counterclaims; that the defendant's last known address is 150 Pine Knob Road, Newville Pennsylvania 17241; and, further that the affiant is of information and belief that the debtor is not in the active military service of the United States. J~ ,~'~iorttas Kearse/ j l SUBSCRIBED and SWORN TO before me this ~ day of ~ 2007. ~. Notary Public My Commission Expires: Notarial Seal Caryl A. Hessler, Notary Public Spring Twp., Becks County My Commission Expires May 12,2007 Member, Pennsylvania Association Of Notaries -- AFFIDAVIT IN COMPLIANCE WITH SOLDIERS AND SAILORS CIVIL RELIEF ACT OF 1940, AS AMENDED STATE OF PENNYSYLVANIA ) To wit: COUNTY OF CUMBERLAND ) Personally appeared before me J. Thomas Kearse, who being first duly sworn, says he is the President of Kohl Roofing and Siding Company d/b/a Kohl Building Products, and makes this affidavit pursuant to the provisions Section 200 of the Soldiers and Sailors Relief Act of 1940; that he has caused a careful investigation to be made to ascertain whether or not Martin E. Lichtenberger is in the military service of the Army of United States, the United States Navy, Marine Corps, the Coast Guard, the Air Force or an officer of the Public Health Service detailed by proper authority for duty either with the Army or the Navy; and that as a result of said investigation affiant does hereby state that the Defendant is not in any of the above-named branches of the military service and further that the Defendant has not received notice of induction or notice to report for military service. Subscribed and sworn to before me this ~ day of t~ 2007. Notary Pub c My Commission Expires: Notarial Seal CaM ~• Hessler, Notary Public Spring Twp., Becks County My Commission Expires May 12, 2007 Member, Pennsylvania Association Cf Notaries -rt ~ C b -' ~ ~~ ~, r` . ~ n ~ x . ~ ~ -c~ ~s--~ ~ .-- --~ c;~ ~ ~ ``, ~- , ~ ~ ~ ~- s. IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA OHL ROOFING & SIDING CO. t/a KOHL UILDING PRODUCTS INC. : 1047 Old Bernville Road : eading, Pennsylvania 19605 : Plaintiff, vs. Civil No: 07-463 ARTIN E. LICHTENBERGER t/a COUNTRY LANE CONSTRUCTION 150 Pine Knob Road ewville, Pennsylvania 17241 Defendant. Praecipe to Enter Judgment by Default ~To: Prothonotary of the Court Please note that plaintiff requests judgment by default, pursuant to Pa. R.C.P. 237.1, on defendant, Martin E. Lichtenberger t/a Country Lane Construction, upon the expiration from 10 days of the date of notice herein. The Plaintiff requests that the judgment by default be entered for the sums due per the int originally filed in this case less payments made to date as follows: (a) principal in the amount of $3,542.48; (b) accumulated interest through March 20, 2007 in the amount of $329.25; (c) interest from March 20, 2007 until the date of judgment in the amount of 1.5% per month (18% per annum); (d) attorney's fees in the amount of $1,177.49 (33 1/3% of the principal balance due at the filing of the complaint); and (e) costs of this action. ~ ~ WHEREFORE, the Plaintiff requests that the judgment by default be entered in the amounts as set forth above, totaling $5,049.22, per the original complaint filed. Respectfully SILVERM~hvSOCLAtTES, CHTD. Gary SGerman 11200 Rockville Pike Suite 300 N. Bethesda, Maryland 20852 (301) 468-4990 Counsel for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this ~~day of 1 , 2007, a copy of the Praecipe to the Prothonotary of the Court was sent via first cl ss mail to: Martin E. Lichtenberger 150 Pine Knobb Road Newville, PA 17241 _~., ~ -~ ~ ° ~ ~ w ~ 1 '~ -~....~ r C Q ~ ~~ -~ ~ ,~, ~ T. ~ir ~ ..~~ -~ <1t `- ' 'T7 ^ ~ C'3 ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c -n KOHL ROOFING & SIDING CO. t/a : Civil Action — Law c.-, -; ., KOHL BUILDING PRODUCTS, INC., "'h'" Plaintiff =sa -:s VS. : No. 07-463 (-;E-- -.::;', C" r MARTIN E. LICHTENBERGER, • '� ; t/a COUNTRY LANE CONSTRUCTION, : -71" Defendant : PRAECIPE TO STRIKE JUDGMENT TO THE PROTHONOTARY: Please strike the judgment entered in the above captioned matter in accordance with the attached Order Avoiding Judgment entered August 8, 2011 by the United States Bankruptcy Court for the Middle District of Pennsylv Date: October A , 2014 WILLIAM C. CRAMER ATTORNEY AT LAW CHAMBERSBURG, PA 17201 (717) 264-3711 William C. Cramer Attorney for Defendant 14 North Main Street, Ste. 414 Chambersburg, PA 17201 (717) 264-3711 0.)„,0 40.apie (pg 3 c 32,57q IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Martin E. Lichtenberger and Sandra K. Lichtenberger, Debtors Martin E. Lichtenberger and Sandra K. Lichtenberger, his wife, Movants vs. Kohl Roofing & Siding Co. t/a Kohl Building Products, Inc., Respondent : Case No. 1:09-bk-06269-MDF : Chapter 13 : Motion to Avoid Lien : Docket Entry No: 69 ORDER AVOIDING JUDGMENT The within Debtor having filed a Motion to Avoid a judgment lien docketed to No. 07-463 in the Court of Common Pleas of Cumberland County, Pennsylvania, and after notice and an opportunity for a hearing thereupon as provided by law; IT IS HEREBY ORDERED AND DECREED that the said judgment held by Kohl Roofing & Siding Co. t/a Kohl Building Products, Inc., as Plaintiff, and docketed against Debtor Martin E. Lichtengerger, to No. 07-463, as filed in the Court of Common Pleas of Cumberland County, Pennsylvania, shall be and the same is hereby stricken and the Prothonotary/Clerk of the Court of Common Pleas of Cumberland County, Pennsylvania shall mark the docket record to show that said judgment is stricken and void. Debtor shall pay the filing fees or costs imposed by the Prothonotary/Clerk of the Court of Common Pleas of Cumberland County, Pennsylvania, if any, for striking said judgment from the Court records. Dated: August 8, 2011 By. the Court 43-.A4141.e.A._ Chief Bankruptcy Judge (JK) Case 1:09-bk-06269-MDF Doc 86 Filed 08/08/11 Entered 08/08/11 11:08:49 Desc Main Document Page 1 of 1