The URL can be used to link to this page

Home My WebLink About00-05703 MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- 5703 ~ v, CARLISLE MOTEL AND CAMPGROUND, INC., Defendant CIVIL ACTION - LAW NOTICE 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 a 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, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, p, C, ~~ By: Solicitor for Plaintiff LAW OFFICES SNELBAKER. E3RENNEMAN & SPARE i LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ""'_"'"<o;To<..'.'.',;,!,'',,,"-'--'""'.''' MIDDLESEX TOWNSIllP MUNICIPAL AUTHORITY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. 00- CARLISLE MOTEL AND CAMPGROUND, INC., Defendant CIVIL ACTION - LAW COMPLAINT Middlesex Township Municipal Authority, by its Solicitor, Snelbaker, Brenneman & Spare, P. c., files this Complaint against Defendant Carlisle Motel and Campground, Inc. as follows: BACKGROUND 1. Plaintiff Middlesex Township Municipal Authority (the "Authority") is a duly authorized and existing municipal authority under the laws of the Commonwealth of Pennsylvania with a principal office and place of business located at 350 N. Middlesex Road, Carlisle, Middlesex Township, Cumberland County, Pennsylvania, 2, Defendant Carlisle Motel and Campground, Inc, is a Pennsylvania business corporation with a principal office and place of business located at 1075 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 3. Defendant is the owner of a parcel of real estate located at 1075 Harrisburg Pike, Carlisle, in the Township of Middlesex, also identified as tax parcel No. 21-19-1637-011 (hereinafter the "premises"), 4, Plaintiff provides municipal water, and sewer service in and to various locations throughout Middlesex Township, I 5, Defendant is provided at its premises, for its and/or the occupants of Defendant's premises use and benefit, municipal water and sewer service by the Authority. COUNT I 6, The averments of Paragraphs 1 through 5, inclusive, of this Complaint are incorporated by reference herein in their entirety, 7. At all times relevant hereto, specifically from November, 1999 through June, 2000, Plaintiff provided Defendant with water and sewer services at Defendant's premises, 8, The water and sewer services provided to Defendant by Plaintiff as described above were provided in accordance with the terms, conditions and requirements of applicable rules, rates and regulations as established by the Authority, 9, Defendant has consistently failed and refused to pay Plaintiff in full for charges assessed Defendant for water and sewer services provided Defendant at Defendant's premises for the period of December 9, 1999 through July 7,2000 despite repeated requests to do so, 10, Defendant has failed and refused to pay the total amount of $10,279.49 due and owing Plaintiff for water and sewer services provided the premises from December 9, 1999 through July 7, 2000, which sum includes applicable late charges or penalties assessed in accordance with rules, rates and regulations of the Authority. 11, The amounts billed by Plaintiff to Defendant for water and sewer services provided Defendant's premises were never objected to by Defendant as being inaccurate. 12. The amounts billed by Plaintiff to Defendant for water and sewer services provided LAW OFFICES SNELBAKE:R, BRENNEMAN & SPARE Defendant's premises were fair, reasonable and never objected to by Defendant. -2- --".",..'--"-,' 13, The amounts due and owing Plaintiff by Defendant as set forth in Paragraph 1 0, above, were billed to Defendant on a monthly basis, which bills contained a statement of current monthly charges due together with an indication of any previous balance due on Defendant's account for water and sewer services provided together with applicable penalties, A true and correct copy of Defendant's account statement with amounts claimed to be due as set forth in this Complaint, is attached hereto and incorporated by reference herein as "Exhibit A", 14, Defendant's failure timely to pay for water and sewer services provided Defendant's premises is a material breach of Defendant's express and/or implied obligation to pay for same in accordance with Plaintiffs applicable rates, rules and regulations, WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $10,279.49 together with interest and costs of this suit. COUNT II (In the alternative to Count I) 15, The averments of Paragraphs 1 through 14, inclusive, of this Complaint are incorporated by reference herein in their entirety, 16. The water and sewer services provided by Plaintiff to Defendant at Defendant's premises were not provided by Plaintiff to Defendant as a gratuity, 17, The charges for the water and sewer services as more fully set forth in Court I of this Complaint were fair, reasonable, customary and never objected to by Defendant. 18. Defendant wrongfully secured benefits from the use of the water and sewer services LAW OFFICES SNELE3AKER, BRENNEMAN & SPARE provided Defendant's premises that would be unconscionable for Defendant to retain. -3- LAW OpFICES SNELBAKER. BRENNEMAN & SpARE 19. Defendant has been unjustly enriched at the expense of Plaintiff in the amount of $10,279.49. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $10,279.49 together with interest and costs of this action.. SNELBAKER, BRENNEMAN & SPARE, p, C, ,Ja ~ - -? BY: Keith O. Brenneman, Esquire 44 W, Main Street Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Plaintiff Middlesex Township Municipal Authority Date: August 17,2000 -4- I LAW OFFICbS SNELBAKER, BRENNEMAN & SPARE VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section 4909 relating to unsworn falsification to authorities, I verify that I am authorized to execute this Verification on behalf of the Plaintiff in my capacity as Operations Manager. :t~~. Middlesex To perations Manager ship Municipal Authority Date: r )7/06 -,_.'" ~~ -~'" ~~ .~ ~~- ~k,MdIIlilJ1ll.1iV#' -:ox .:..,: -:~: ~ i. .g "if.. M' i.~~ ,g~ISt: - Zip: ... , ' ... :~?;'~~~!f~~~~~~~:~{~~~~%~~~~:~~f:~~~{':~~:~1tI~~~~~~;f~~t~~~;~~~~~~~~~~f:~~;~~~:~~~~~~~~~~~~~~%~::~~~~~;~~:I~~~~~~~~;i~~~t;{~~::~~:~~~?~~~~~~!~:~~~~~i~~~~~:~f~~~~~~ :::~::~~~~:x~~~~:t:::::gx<<q::: 08/08/2000 ~~tf.[l~~~f.~~f.~ .' Accounf-1n.fo.....h......,.... Date Ty Oa/03/00 SL 08/02/00 PE 07/07/00 BL 07/06/00 PE ,07/06/00 PY 06/16/00 PP 06/16/00 PY 06/05/00 BL 06/05/00 PE .. 05/12/00 PI' '05/12/00 PY 05/04/00 ElL 05/03/00 PE 04/04/00 BL 04/03/00 PE Transactions query Water Sewer 1,947.96 966.23 187.24 92.94 1,872.36 929.43 140.73 100.30 -2,500.00 0.00 -149.44 -74.54 -2,376.02 0.00 2,023.56 1,003.03 149.44 74.54 -366.92 -182.20 -2,450.88 0.00 1,494.36 745.43 179.68 89.26 .1,796.76 892.63 187.24 92.94 Press Current Acco~nt Master Record ~~~~ . Met e r & F i nanC"i'a'f""rn for acct: 00204 Total Open Bal 2,914.19 13,193.68 280.18 10,279.49 2,801.79 9,999.31 BILLING 2000/JUNE 241.03 7,197.52 -2,500.00 6,956.49 -223.98 9,456.49 -2,376.02 9,680.47 3,026.59 12,056.49 223.98 9,029.90 -549.12 8,805.92 -2,450.88 9,355.04 2,239.79 11,805.92 268.94 9,566.13 2,689.39 9,297.19 280.18 6,607.BO <F1:> to exit I Reference BILLING 2000/JULY P: <F9:> - Help ~.... . I oe/O:~~~~~t:.In 0 Tra:::::~:n:c::::: :::t~~;~~c~:~~~a'nc;a I~ ~ pate Ty Water Sewer Total Open Bal Reference ~ ~ g~~l!~gg ~[~~::~tn -::t~~ -fH~:~~ ti~~J~ BILLING 2000/F~a. f.f.i.!.;.: ~ 03/03/00 PE 119.20 59.82 '179.02 6,525.83 ~ jf.g~~gi~gg:~ : :B~:~i :~t~i: :ri:j~ ;;iig:i~ ::~~::: ::::;~:NUAR i . . 01/06/00 PE 172.12 85.58 257.70 2.834.69 . I 12/07/99 aL 1,721.16 855.83 2,576.99 2,576.99 BILLING 1999/'1 . 12/02/99 PY -1,569.96 -782.23 -2,352.19 0.00 f ~~~~~~:: ~~. ~ ;~:t:: . ~:~:~; ~:;~~:~: ~:;~~:~: BIL.LING 1999/10 10/14/99 PP -117.00 -78.22 -235.22 0.00 10/14/99 PY -2,637.52 -1,417.26 -4,254.7B 235.22 10/06/99 BL 1,267.56635.03 1,902.59 4,490.00 BILLING 1999/09 Pre~s <F1:> to exit jt St: - Ii p: P:- - -' ~_::~.~:'~.:,:, I <F9:> - Help _ ~~~~~~~~~~~~~~?~~~~~~;~~t~~~i:~:l~~~~}~~~;~~~1~~r~~~i~~~~~~~:~;i~~~~~~~}Z5~1~ji.~~~t~~:5~~1~~~~~~~~~:~zj~~~:~~i~~~~?*~~x~*t~i~~t~*~~~:~~~:~~~:~Z?*~~~ EXHIBIT A iIlW!lit\I'M-~k:"Ilti'tf"M.il1if~",~;lI;e"~;;,dJli -li- \~ ~ ~ C5 \), '-J ~" ilii!IIIIH ~ . 1 CA \\:! , , ~ " -"--. " - ~ - "-Ii o a ~ a -oF;:'; ~ (...:>. III ,.~-; V\ ~ zr~; dO) ~\ ~ ~ ~~i m IJ)> ;to> \ \ ~8 :x ~ \ s'-=;. co ~ - , 1',1 iI II ri [,I " !i i! ri r,1 l,! i , !,i [I I! :1 I, 11 !i 'I II II .I I' !I il 11 I 'I ~ o -n ":;-:;;;'-n "'r="-;: "-,~" ,n =:::jd ~~~~ ;i'~ '-' ---/ ~ -< .-" -- ~~ " ~'"= ~ ~~,,~ SHERIFF'S RETURN - REGULAR CASE NO: 2000-05703 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDDLESEX TOWNSHIP MUNICIPAL A VS CARLISLE MOTEL AND CAMPGROUND KENNETH E. GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CARLISLE MOTEL & CAMPGROUND INC the DEFENDANT , at 1322:00 HOURS, on the 25th day of Auqust , 2000 at 1075 HARRISBURG PIKE CARLISLE, PA 17013 by handing to RAY CASHILL, OWNER AND ADULT IN CHARGE 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 Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So Answers: r~~ R. Thomas Kline 08/28/2000 SNELBAKER BRENNEMAN & SPARE me Sworn and Subscribed to before By: this 7 ~ day of ~".~ d2 trlJi) A. D. Q~!J~.~ ~thonotary , , " .. MIDDLESEX TOWNSHIP MUNICIPAL : IN THE COURT OF COMMON PLEAS OF AUTHORITY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, : NO. 00-5703 CARLISLE MOTEL AND CAMPGROUND, INC" Defendant : CIVIL ACTION - LAW IMPORTANT NOTICE TO: Carlisle Motel and Campground, Inc., Defendant Date of Notice : February 22, 2001 IMPORTANT NOTICE YOU ARE IN DEF AUL T 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 TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MA Y 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: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Peunsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P. C, r1~~ LAW OFFICES SNELBAKER. BRENNEMAN & SPARE By: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Solicitor for Plaintiff " .. .. LAW OFFICES SNELBAKER, BRENNEMAN & SPARE CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Carlisle Motel and Campground, Inc. 1075 Harrisburg Pike Carlisle, P A 17013 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W, Main Street p, O. Box 318 Mechanicsburg, P A 17055 (717) 697-8528 Solicitor for Plaintiff Date: February 22, 2001 V~'L .' -'. " " ~'~-'-~' ';'ih:~~A*~~ - " c__ ~:~,,~". ;:",' ".", - : "^' '-~_L '.~, -," o f~:: ,~ ,~['i 63':' 2;,': ?i~>' '~ :;.-- -:j -< - '... ""- Q ::!:! "f C';J t'v C>j -^~'" - t\J j....< .~~i(~~ :';~ :::> .'-...; I". 't'~ '~ ~" ~ ~ if! ., I !1 II," , " I'.,., . , . ~' I , I I . . , MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO, 2000-5703 CARLISLE MOTEL AND CAMPGROUND, INC., Defendant CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT UPON DEF AUL T PURSUANT TO Pa.R.C.P. 1037(b) TO THE PROTHONOTARY: Please enter judgment against Defendant Carlisle Motel And Campground, Inc, and in favor of Plaintiff Middlesex Township Municipal Authority in the amount of $294.39 together with interest and costs of this action due to Defendant's failure to file within the required time a pleading to the Complaint in this action. A certified copy of the Complaint containing a notice to defend was served upon Defendant on August 25, 2000, I hereby certify that written notice of intention to file this Praecipe was mailed to the Defendant (the party against whom judgment is to be entered) for failure to plead to the Complaint and at least ten days prior to the date of the filing of this Praecipe. A copy of the written notice mailed to the Defendant on February 22, 2001 is attached hereto and incorporated by reference herein as "Exhibit A", SNELBAKER, BRENNEMAN & SPARE, p, C. Date: April 17, 2001 By:Jln~ Keith 0, Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Solicitor for Middlesex Township Municipal Authority u>W OFFICES SNELBAKER, B~ENNEMAN & SPARE , , LAW OFFICES $N ELBAKER. BRENNEMAN & SPARE " ~ . , CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Carlisle Motel and Campground, Inc. 1075 Harrisburg Pike Carlisle, PA 17013 KOn~~ Keith 0, Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street p, O. Box 318 Mechanicsburg, P A 17055 (717) 697-8528 Solicitor for Plaintiff Date: ~,4Aill1 ').O(), ~.~ . - ~,~'", '=, , , . , MIDDLESEX TOWNSHIP MUNICIPAL : IN THE COURT OF COMMON PLEAS OF AUTHORITY, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 00-5703 CARLISLE MOTEL AND CAMPGROUND, INC., Defendant r. ,~" ';:.-::- \,-- : CIVIL ACTION - LAW ----:'1 -r; ~- ,-",-' ~;:'- ,/'. -<- IMPORTANT NOTICE 7'_ ?:-='- /'~7 ;-; TO: Carlisle Motel and Campground, Inc., Defendant '"-.'. - Date of Notice: February 22, 2001 IMPORTANT NOTICE YOU ARE IN DEF AUL T 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 TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MA Y 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: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P. C. K'€~~ LAW OFFICES SNEL8AKER. BRENNEMAN & SPARE By: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg,PA 17055 (717) 697-8528 Solicitor for Plaintiff EXHIBIT A - ~ , , LAW OFFICES SNEL8AKE~, BRENNEMAN 8: SPARE J, .:.....;.-,. '0<, ~ , . CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Carlisle Motel and Campground, Inc. 1075 Harrisburg Pike Carlisle, PA 17013 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Plaintiff Date: February 22, 2001 ~, ' .H -,~,~ ~"1 , , ~1IiID~_'~b""..oI1ia;~j;I\lif-~tiL~~'-';'"'" '- ~,".,,~<:;. "",(;-::."~"",-"",,.,,-- e' _ -, U-- '~'-llIiliIIIi!i~ . . ~ C) c::; " 1V ~ ~ C' .,~ ~7.~ It.. ";'C s2ft '. 0 ::':) ;-:-:'C r - 0 Cr_!.;> -j ". < ...... ~ - ~ --c~ t .,';;-.""", b p! -7', ." ~ '::---'-," S~: (::,~~ f'...) '--~) 2~ ;::~.{ (If "'- ::<: ~.J - {fl -< ff ~~ ,......, ., "". ~ n, . . " . , i ;-1 Iii I il Ii 1 1 , , '" - ",~, 1 , .' MIDDLESEX TOWNSHIP MUNICIPAL : IN THE COURT OF COMMON PLEAS OF AUTHORITY, : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : NO. 2001-1191 CIVIL TERM CARLISLE MOTEL AND CAMPGROUND, INC., Defendant : CIVIL ACTION - LAW 0 CJ , c: :?"" ::;--;-.> v 6~ " ~? t~ ..'... cr; -....; / c:: ),:; (~-, - ;:; ,'-", ~-"." > ""OJ' 1":;' - ~~~ ...:-::. -J en _--.1 -~ .." TO: Carlisle Motel and Campground, Inc., Defendant Date of Notice: April 3, 2001 IMPORTANT NOTICE YOU ARE IN DEF AUL T 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 TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE 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: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, p, C. I/t(~~ LAW OFFICES SNELElAKER. BRENNEMAN & SPARE By: Keith O. Breuneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Solicitor for Plaintiff I '- '. LAW OFFICES SNELBAKER, BRENNEMAN & SPARE " --.-,' lill?-"""":"""" CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Carlisle Motel and Campground, Inc, 1075 Harrisburg Pike Carlisle, P A 17013 \~~~ Keith 0, Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, p, C, 44 W. Main Street P. 0, Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Plaintiff Date: April 3, 2001 I I LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ~"', MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-5703 CARLISLE MOTEL & CAMPGROUND, INC" Defendant TO THE PROTHONOTARY: CIVIL ACTION - LAW PRAECIPE Please mark the judgment entered in favor of Middlesex Township Municipal Authority and against Defendant Carlisle Motel & Campground, Inc. in the above-captioned matter satisfied upon your docket and indices, Date: June 20, 2001 SNELBAKER, BRENNEMAN & SPARE, P. C. Mht~ BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Solicitor for Defendant Middlesex Township Municipal Authority "~~ I ~ " ,,~~~-~~4':':~lUr'-Lf" '., "..,,_ ,,<, ~"~"_o_~ '. ,"'. '.~ ,'-,',~' ,r.., . ~_ ~, H <" _ ,~.., " '_, """""" ,--~ ,- . , >'d'"'-!.i=k'"L[ "~- ~,= (") C <- '"Or!; f11rn 2:-1" 2'-',' 655:" ~iE .E; Cf ~c' Pc 2:: :2 ~ -'. ~" ;,! 1",1, ,I II !I !,I 'I !I :1 '1 ~~ U .1 "I 11 II' I, II I " c::::~ Q " ::-. ~ -,', -.J~ "'I J ..' .'-, --f\_.' ~a ~TJ -< ,,~ :p c:- - '-