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COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
NOTICE OF APPEAL
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. /YI_ 70'.,..... /J ' /J
cv ~::!. I~J~
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and in the case mentioned below.
OJY
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ATE ZIP CODE
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ClAIM NO.
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If appellant was CL 'ANT I see Pa, R.C'p,J.P, No,
1001 (6) in action before District Justice, he MUST
FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
CV 1\1 C V -0DOO I <g S" - 00
LT19
This block will be signed ONLY when this notation is required under Po. R,C.P.J.P. No.
10088.
This Noti~ of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS ta, the judgment for possession in this case.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of fomJ to be used ONLY when appellant was DEFENDANT (see Pa, R.C.P.J.P, No.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee),
PRAECIPE: To Prothonotary
Enter rule upon ~ \ e .J-
1001 (7) in action before DistIict Justice,
(Common Pleas No.
&:J - 703,<
;/fI(l.(l(t r t.-JJ.!I"'lL
- Name 0' appeIlee(5)
6/J
, oppellee(s), to file a complaint in this appeal
RULE: To b",\.e.
J- >>~YVI' ~ 1 wLk
Name of awe11f'e(5J
ry of judgment of non pro~
attorney or agent
,appellee(s).
(1) You are notified that a rule is hereby entered upon you ta file a complaint in this appeal within twenty (20) days afler the dale of
service of this rule upon you by personal service or by certified or registered moiL
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU,
(3) The date of service of this rule if service was by mail is the date of moiling.
Date:
t9d. I,;} ,~
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at or Ooputy
AOPC312.-&4
COURT FILE TO BE FILED WITH PROTHONOTARY
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PROOF OF SERVICE OF NOTICE OF: APPEAL AND RULE TO FILE COMPLAINT
COMMONWEALTH OF PENNSYlVANIA
(This prool 01 service MUST BE FILED WITHiN TEN (101 DA YS AFTER filing the notice 01 appeal. Check applicable boxes)
COUNTY OF ; s.
AFI=IDA VIT: I hereby swear or affirm that I served
a copy 01 the Notice of AppeaL Common Pleas No, , upon the District Justice designated therein on
(date of service) '" [J by personal service D by (certified) (registered) mail, sender's
reGeipt attached hereto, and upon the appellee, (na,ne) , on
, 19__,_ D by personal service [J by (certified) (registered) mail, sender's receipt attached hereto,
o and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on _ , 19~ D by personal service 0 by (certified) (registered)
mail, sender's receipt attached hereto,
SWORN (AFFiRMED) AND SUBSCRIBED BEFORE ME
THIS
DAY OF
__,19_
Sig'1ature of official before whom affidavit was made
Titf.g of official
My commission expires on
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09-3-03
NOTICE OF JUOGMENTITRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
mALE & HARRIET WHITE 'I
580 N. MIDDLETOWN RD.
CARLISLE, PA 17013
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Disl, No,:
OJ Name" Hon,
SUSAN K. DAY
/\do"" 229 MILL STREET, BOX 167
MT. HOLLY SPRINGS, PA
""pho", (717) 486 -7672
17065
DEFENDANT: NAME and ADDRESS
'BEST AUTO SALES
1445 HOLLY PIKE
CARLISLE, PA 17013
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Docket No,: CV- 0000185 - 00
Date Filed: 8/01/00
VS.
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BEST AUTO SALES
1445 HOLLY PIKE
CARLISLE, PA 17013
THIS IS TO NOTIFY YOU THAT:
Judgment: DEFAUl.'!' JUTJ~MmI1'I' PLTF
[iJ Judgment was entered for: (Name) TIU,F." HlIlllHF.T WHTTF.
[iJ Judgment was entered against: (Name) RF.9T J\Tl'I'O 9J\T,1'.9
in the amount ot $
3,1"3 04 on:
(Date of Judgment)
9/15/00
. .
o Defendants are jointly and severally liable,
o Damages will be assessed on:
(Date & Time)
O Amount of Judgment Subject to
AttachmenVAct 5 of 1996 $
Amount of Judgment $ 3.096.04
Judgment Costs $ 67.00
Interest on Judgment $ .0,0
Attorney Fees $ .0'0
Total $ 3 ,163.,04
Post Judgment Credits $
Post Judgment Costs $
------------
------------
Certified Judgment-TOtal $
o This case dismissed without prejudice.
o
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Levy is stayed for
days or 0 generally stayed,
Objection to levy has been filed and hearing will be held;
Dale: >'"".-",- .. .., .'~ . 'Pla.ce; -.--.- ...~- .c:c- ""0 ~'-'." - "-.,.- ~ -' . ..
Time:
MUST INCLUDE A COpy OF
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ANY PARTY HAS THE RIGHT TO EAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROT NOT YtCLERK OF THE.'COUR-T\OF COMMON PLEAS, CIVIL DIVISION. YOU
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HIS NOT' E OF JUDG " I ,R, ,t ,j,' RIPT F,ORM WITHYOUR NOTICE OF APPEAl.
!;, , ' " '.', . DistrIct Justice
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e' roc edings containing the judgment
My commission exPt first Monday of January,
AOPC 315-99
, District Justice
i~~rtif~' t~a~t~~ is "
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SEAL
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
,
(This proof 01 service MUST BE FILED WITHIN TEN (10) DA YS AFTER filing the notice of appeai, Check applicable boxes)
,
AFFIDA~IT:
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I hereby swear or affirm that I served
lP a copy 01 the Notice 01 Appeal, Common'Pleas No, 00- 703.s ,upon the District Justice designated therein on
i ((jate 01 service) d c T~ (J...../7.'!2~O ' , , fi<J by personal service 0 by (Gertifi~)(registered) mail, sender's
receipt altachedhereto, arid upon the appellee, (name) 'D.4/v t /..jAA.Atn- bJ#/, r... , on
!: oc.T'lto.- '/ BJ', Jt:I!l.O CI 0 by personal service pi! by (certilied) (registered) mail, sender's receipt attached hereto,
~ and further thall served the Rule To FileaCpmplaint accompanying the above Notice of Appeal upon the appellee(s) to whom
" the Rule was addressed on' IlCT"~ I A ,~O by personal service llll by (certified) (registered)
maii, sender's receipt attached hereto, U' /
SWORN (A1F, IRM,E, 0) AN, D," SUBSCRI~E~ BEFORE ~E , .-~ f~~ _',
THIS ilf':IDAYOF OCT ~~ x: "// r/;, ( )
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Return Receipt Fee
I:(] (Endorsement Required)
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COf!o\MO,NYfE"LJHOF PEN~sYLlIAN'A
COURJO~COf!o\MON PtEAS
~ROM
DISTlUCT JUS'I'Ici1. JUPGMENr
COMMON PLEAS No. .,m'7o~ c~,(.JiI,
NOTICE OF APPEAL
Notice is given thf'lff,e appellant has' filed in the above Court of Common Pleas an appeal from the judgrT1ent ,l'i;ridered by the Dist(id Justice on the
date and in the c~ mentioned below. '
. 'JUDICI..L DISTRICT
~ OF APPELltNT ,
"e,s::L t?" \"
ADDIESS OF APPELLANT .' ' I
,I IJd,,-' Ilfe"'I'I,'
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DATE OF NT
c~, I 'S 'GO
,ClAIM NO.
MAG. D-'St t~O,'0R;~, ME OF ,o.J. " ' '.
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SIGNATURE OF APPELlANT ~ HIS AT~NEY Oil: !GeNT
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This block will be~gned QNlY when this notation is required under.J'a.' R.cP.JP;Nci If aPPellant 'was CL 'ANT (seef'a.R.G.P,JP; No. ,,'
10088. ' ,',' "
This Natice of Appeal,whenreceived by the ,District Justice, will operate as a 1001(6) in<Jqtionb,e,foreDist{i9tJustice, he MUST
S1UPERSEDEAS to the judgment for posses~on in this cose. ' FILE A COMPLAINT within twenty (21J;:) dar:>after
filinghis,NQTlCE of APPEAL.
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INTJiE CASE,OF (Plaintiff),
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Signature of Prothonotary or Deputy
PRAECIPE TO ENUR RULl': TO FILl': COMPLAINt AND RULE TO FILE
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(ThIs section ,of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in afJtkJR: [4efQre:f)ls!rictJustice,
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IF NOT USED, detach from copy of notiCe of appeal t(lbe served upon appellee),
PRAECIPE: To Prothonotary I
En~ rule upon'-~\ e + //'')(!(t'IZ''-' ,-",;-/ 11',~
Name of appeltee(s)
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(Common Pleas No. t.::t'J" '/('3.< (.M'v(
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, appelle~). t<t~~ a ~~pjaint in this appeal
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RULE: To!:::> o,J\?
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Name o( appeI/f3e{sJ
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) within twenty (20) days after servic~ af ru'1 or suJ~< r}':of luddi1lel)fof non pros.
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, l \. SignatiJre of appellant hi; attorneY or agent
'-'",' ",r\:, ,appellee(s).
(1 t You are notified It1at a rul" is hereby entered upon )'ou '" ,file a complaint?" this appeal within twenty (20) daysafler ,the do"', of
servic",;of-~is rule upon, you by persClnpI service or by certiiied or registered mail .
"":':,":;~:,:;::s..<-"~,,,,,,/\/' , I
(2) If you ~ti!i~fi:If(/~P!arni.J.tithin this time, a JU,DGMENT OF, NON plios Will 8E ENTERED AGAINsT YOU,
':V' ''''''''f -';-":i~~;..r-,- <':,""i'
(3) T~~9f:';vi!;~,qfthiS rule~,t"rce was by mail is the da'" qf moiling.
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NJPC 312-84
COURT FILE
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Dale White,
Harriet White
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
Best Auto Sales,
Defendant
No, 00-7035 CIVIL TERM
IN ASSUMPSIT
NOTICE TO DEFEND AND CLAIM OF RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in
the following pages, you must take prompt action. You are warned that if you fail to do
so, the case may proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available
in the Office of the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE; 240-6195
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM,
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
TELEPHONE; 717-249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990, For information about accessible
facilities and reasonable accomodations available to disabled individuals having
business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing,
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Dale White,
Harriet White
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUM:nERLAND COUNTY, PENNSYL VANIA
v.
CIVil.. ACTION - LAW
Best Auto Sales,
Defendant
No, 00-7035 CIVIL TERM
IN ASSUMPSIT
COMPLAINT
1.
AND NOW comes Dale White and Harriet White, Plaintiffs, by and through Frey and
Tiley, attorneys for Plaintifs, and makes the following statement
Plaintiffs are Dale White and Harriet White, husband and wife, adult individuals,
residing in the Township of North Middleton, Cumberland County, Pennsylvania,
having their mailing address at 580 North Middleton Road, Carlisle, Pennsylvania
17013,
8,
Defendant is Best Auto Sales, having its office and principal place of business in
South Middleton Township, Cumberland County, Pennsylvania, and having a
mailing address of1445 Holly Pike, Carlisle, Pennsylvania 17013.
Plaintiffs are the owners of a 1995 Dodge van,
On or about June 16,2000, Plaintiffs delivered their van to Defendant for repairs in
the form of replacement of the radiator. Defendant performed the work replacing the
radiator. Attached hereto and incorporated herein by reference as Exhibit "A" is a
true and correct copy of the invoice prepared by Defendant indicating completion of
the work.
After paying for the work performed, Plaintiffs took possession of the van.
On subsequently driving the van, the automobile stopped functioning properly and
was unable to be operated because oftransmission problems.
The transmission problems were the result of Defendant failing to properly install the
radiator, resulting in transmission fluid leaking from the van, damaging the
transmission and making the van inoperable,
The damages to Plaintiffs' van was the direct and proximate result of Defendant's
,
failure to perform the replacement of the radiator in a workmanlike fashion.
2,
3,
4,
5.
6.
7.
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As a result of Defendant's failure to perform the radiator replacement in a
workmanlike manner, Plaintiffs incurred costs to repair of $2,856.70. Attached
hereto and incorporated herein by reference as Exhibit "B" is a true and correct copy
of the invoice itemizing expenses paid for the repair of the van, It is to be noted that
the cost of installing an external cooler and the sales tax associated with that
installation as itemized on Exhibit "B" is not included in Plaintiffs' claim for
damages as it is not believed to be related to the damages caused by Defendant.
As a result of Defendant's failure to perform the radiator replacement in a
workmanlike manner, Plaintiffs incurred costs to tow their van to a repair garage in
the amount of $120.00.
As a result of Defendant's failure to perform the radiator replacement in a
workmanlike manner, Plaintiffs incurred costs of car rental while their van was being
repaired of $119.34
Plaintiffs' damages as a proximate result of Defendant's failure to perform its work
in a workmanlike manner totals $4,096,04, as follows;
9,
10.
11.
Repair costs
Towing costs
Car Rental costs
Total
$2,856.70
120.00
119.34
$4.096 04
WHEREFORE, Plaintiffs respectfully request judgment in their favor and against the
Defendant in the amount of $4,096.04, plus costs' and interest from the date of judgment.
Respectfully Submitted;
Robert G. Frey, Esquire
Supreme Court Number 46397
5 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5838
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I verify that the statements made in this Affidavit are true and correct to the best of my personal
knowledge, information, and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C. s. ~4904 relating to unsworn falsification to authorities.
Date: June i3 ,2001
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Dale White,
Harriet White
Plaintiffs
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 00-7035 CIVIL TERM
IN ASSUMPSIT
Best Auto Sales,
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint of Plaintiff in the above-captioned matter.
Respectfully Submitted:
Robert G. Frey, Esquire
Supreme Court Number 4639
5 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5838
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-07035 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WHITE HAROLD ET AL
VS
BEST AUTO SALES
DOUGLAS DONSEN
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
~. says, the within COMPLAINT & NOTICE, REINS was served upon
BEST AUTO SALES the
DEFENDANT , at 0855:00 HOURS, on the 29th day of November, 2001
at 1445 HOLLY PIKE
CARLISLE, PA 17013
by handing to
MIKE TAYLOR, MECHANIC
a true and attested copy of COMPLAINT & NOTICE, REINS together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
3.25
.00
10.00
.00
31.25
.rfJ?n;.,~~
R. Thomas Kline
Sworn and Subscribed to before
11/30/2001
FREY & TILEY
By:QtCJ
4W'--
eputy Sheriff
me this p!!:: day of
J.fJuPw.Ju, diJO I A. D.
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thonotary I -r]
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Dale White,
Harriet White
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 00-7035 CIVIL TERM
IN ASSUMPSIT
v.
Best Auto Sales,
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
TO: Cumberland County Prothonotary
Please enter judgment in favor of Plaintiff and against Defendant in the amount of $4,096.04
with interest thereon at the rate of 6% per annum from January 17, 2002, plus costs, for failure of
Defendant to plead within twenty days from the date of service of the Complaint on November 29,
2001. It is certified that Notice of Intention to Enter Default Judgment has been given in
accordance with Rule 237.1 of the Pennsylvania Rules of Civil Procedure, a copy of said Notice
being attached hereto.
DATED: January 17,2002
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Robert G. Frey
Attorney for Plaintiff
5 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-5838
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Dale White,
Harriet White
Plaintiffs
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 00-7035 CIVIL TERM
IN ASSUMPSIT
Best Auto Sales,
Defendant
TO:
DATE OF NOTICE:
Best Auto Sales
December 20, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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
IMPORT ANT 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, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200
Sfj
Carlisle, Pennsylvania 17013
(717) 243-5838
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Attorney for Plaintiffs
5 South Hanover Street
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