HomeMy WebLinkAbout01-04560Jrohnson, Duffie, Stewart & Weidner
By: Michael J. Cassidy
I.D. No. 82164
301 Market Street
Attorneys for Plaintiffs
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
COMPREHENSIVE TEST & BALANCE, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
C.K. MECHANICAL CONTRACTORS, INC.,
Defendant
NOTICE TO DEFEND
To the Defendant:
CIVIL ACTION -LAW
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 defense 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 ehtered against you by the court without further notice for any money claimed in the
complaint or for any ether 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
Telephone: (717) 249-3166
NO. QI --tlslt~
Johnson, Duffle, Stewart & Weidner
By: Michael J. Cassidy
I.D. No. 82164
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717)761-4540
Attorneys for Plaintiffs
COMPREHENSIVE TEST & BALANCE, INC., IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO.
v.
CIVIL ACTION -LAW
C.K. MECHANICAL CONTRACTORS, INC.,
Defendant
COMPLAl111T
AND NOW, this ~~*day of July 2001, comes the Plaintiff, COMPREHENSIVE TEST & BALANCE,
INC., by and through its undersigned attorneys, Johnson, Duffle, Stewart & Weidner, and files this
Complaint, and in support thereof avers as follows:
1. Plaintiff is Comprehensive Test & Balance, Inc., a business corporation organized and
existing under the laws of the Commonwealth of Pennsylvania, with its principal place of business located at
55 Park Drive, Dover, York County, Pennsylvania 17315.
2. Defendant is C.K. Mechanical Contractors, Inc., a corporation organized and existing under
the laws of the Commonwealth of Pennsylvania, with its principal place of business located at 2715 McCoy
Street, Williamsport, Lycoming County, Pennsylvania, 17701.
3. On or about September 24, 2000, Plaintiff submitted a bid proposal to Defendant to perform
testing, adjusting, and balancing of the heating ventilation and air conditioning system (HVAC system) for
the amount of $3,090.00, as part of a construction project at Our Lady of Lourdes Parish located at Salt
Road, Enola, Cumberland County, Pennsylvania, a copy of which bid proposal is attached hereto,
incorporated herein by reference, and marked as Exhibit "A."
4. By purchase order dated October 27, 2000, Defendant accepted Plaintiff's bid proposal to
perform the HVAC system testing, adjusting, and balancing for the amount of $3,090.00, a copy of which
purchase order is attached hereto, incorporated herein by reference, and marked as Exhibit "B."
5. The purchase order specifies net payment within thirty (30) days of completion of the work.
6. Plaintiff performed the HVAC system testing, adjusting, and balancing in a complete and
workmanlike manner.
7. By invoice dated November 20, 2000, Plaintiff billed Defendant for the contracted HVAC
testing, adjusting, and balancing in the amount of $2,781.00, which represented the contract amount of
$3,090.00 less ten percent (10%) retainage withheld, a copy of which invoice is attached hereto,
incorporated herein by reference, and marked as Exhibit "C."
8. Plaintiff has repeatedly demanded payment of the total contract amount of $3,090.00, but
Defendant has wholly neglected and refused to pay the same or any part thereof.
WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $3,090.00, with
interest from November 20, 2000, and costs.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
~° /~ c
By: ~`----' l~-~
Mich I .Cassidy
Attor I.D. No. 82164
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
~aaoas Attorneys for Plaintiff
9/ERIFICATION
I, TODD W. WALTER, President of COMPREHENSIVE TEST & BALANCE, INC., verify that the
statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I
understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904,
relating to unsworn falsification to authorities.
Date: 07 /901
Todd W. Walter, President
STr~Fr/T
Jun 07 O1 05:16p Todd Walter 717-932-D277 p•2
Comprehensive Test & Balance, ItdC. DATE :srza~oo
55 pork dr. Dover, Pa. 17315
7I7-938-8196 Phone
717-932-0277 FAX
B!D PROPOSAL
CONTRACTOR: CK MECH. OWNER : OUR LADY OF LOURDES
ATTN: KEN FAULKNER
JOB LOCATION : ENOLA PROJECT ; NEW EDUCATIONAL BLDG. FOR
OUR LADY OF LOURDES
BID RATE : HBG.
REFLECTED WORK COST
THE FOLLOWING PRICE WILL COVER TESTING ADJUSTING AND $3 090.00
BALANCING PORTION FOR ABOVE PROJECT. REPORT WORK DONE.
TOTAL COST $3,090.00
COMMENTS : CALL ME KEN.
Jun 07 O1 O5:16p Tadd Walter 717-932-0277 p•4
` ~OCY-2T-80 11:49 AM C. K. MECNQNICRLS 5T0 494 2389 P. 62
Al6CHANICAL CONTRACTORS INC.
BOX 3554
,s MccoY sTRSaT:
~LIAMSPORT, PA 17701
IN$ 717-494-2337
PA ~ 194016
cotaTSs
t~dor Na
5hlp To:
COMPR8H6NSIVE TEST &
BAI,ANCS, INC.
55 PARK DRIVE
DOV& pA 17315 '
De'te Needed Terms
10/27/2000 10/30/2000 NET 30 RAYS
OtlR LAAY OF LOiIRDES PARI6
SALT ROAD
ENOLA PA
w Shipped Req. Na w Dept for
ChiUCK RNAUFF OUR LADY OF LQURDES PARISH
B11Aty Pert Na 1 Descr~gdOn Price unit
I
.000 COMPTEST~~9 TBSTING, ADJUSTING & BALANCINO 3090.000 3090.00
n~lo~~d ~ z~8~ .c~
f~'ze•ao ,invc~~~ ic`
3090;0
0...
309D.Dti
r send us Copses Dt your brvaiCe.
b to be entered !n eccacyanca with Wices, delivery, and apeci/ications shown above.
us Ihxnediatety /t you are ixraWe to ship complete order by the date rpeo/Tied,
r.A4emt ,zxa,,.,wea
~ :, , .
,Jun, p7 01 05:16p Todd Walter
COMPREHENSIVE TEST &
BALANCE, INC.
55 PARK DRIVE
DOVER, PA 17315
717-938-8196
BILL TO
:K Ml;Gri
~CCOUNTSPAYABLE
715 MCCOY ST
VILLIAMSPORT, PA I7701
p.5
-Ot- //-1-~t•(7~
~INVOICE~
DATE INVOICE #
unonnoo ioa
MAIL TO
CK MECH
CHUCK KNAUFF
2715 MCCOY ST
WILLIAMSPORT, PA 17701
TERMS I PROJECT
2% l0 Net30 ~ 00-50 LADY OF LOURDES
DESCRIPTION
TESTING, ADJUSTING, AND BALANCING WORK COMPLETED TO DATE.
PRELIMINARY REPORT WORK COMPLETED,
LESS 10% RETAINAGE HELD
.~~' ~ -for C,hu.r,~ a •~`.';o I
~~-~- w/,~'~'1~`,~" <~ lea •D~~ ~r ~e%
~~~ ~-acne w~ 3~isoo -~o~ ~.~~ ~a~~h ~
ll ~tii~ Sig=i~S 0t'~~- ~
w-11 C~-
~~po~.2 ~~ ~~~~ 5~0 ~'~-g'f Z33~7
~.~:cl
C+~,i,~ bc~-c-k--
717-932-0277
P.O. N0.
144016
AMOUNT
3.090.110
•309.00
~~~ .
APPROVED BY I Total 52,781.00
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2001-04560 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COMPREHENSIVE TEST & BALANCE
VS
C K MECHANICAL CONTRACTORS INC
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
C K MECHANICAL CONTRACTORS INC
but was unable to locate Them
deputized the sheriff of LYCOMING
to wit:
in his bailiwick. He therefore
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On August 14th 2001 this office was in receipt of the
attached return from LYCOMING
Sheriff's Costs: So answe s:
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. homas Kline
Lycoming County 23.50 Sheriff of Cumberland County
.00
60.50
08/14/2001
JOHNSON DUFFIE STEWART
Sworn and subscribed to before me
this /L ~ day of (~ ,~,,,.N
2sv l _ A.D.
l' 71 OD rt.P ~
Prothonotaz`y 'P'
CASE NO: 2001-04560 T
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
~OEIN7.`Y'OR CUki&E~tI,AND
COMPREHENSIVE TEST & BALANCE
VS
C.K. MECHANICAL CONTRACTORS
DONALD L. COHICK JR. ,Sheriff or Deputy Sheriff of Lycoming
County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT was served upon
C.K. MECHANICAL the
DEFENDANT at 0002:27 Hour, on the 6th day of August 2001
at 2715 MCCOY ST
WILLIAMSPORT, PA 17701 by handing to
JIM SMITHGALL, SERVICE MGR.
a true and attested copy of COMPLAINT together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 9.00 (~
Service 9 . 00 ~ S~`["° . ~.
Affidavit 2.50 Char s ~r w~e i~
Surcharge .00 By ~/`
Mileage 3.00
23.50 08/07/2001 Deputy Sheriff
REFUND$51.50
Sworn and subscribed to before
me this ~' day of
A.D. ~cu1
Prothonotary & Clerk of Courts
Wimamsport, Lycoming County
My Commission Expires Jan. 2, 2004
M ~
In The Court of Common Pleas of CuYnberiand County, Pengasylvania
Canprehensive Test & Balance Inc.
VS.
C.K. Mechanical Contractors, Inc.
SERVE: C.K. Mechanical Contractors, IA6~ O1 4560 civil
Ivory July 31, 2001
I, SHERIFF OF CUMi3ERLAND COUNTY, PA, do
hereby deputize the Sheriff of Lycoming
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
~~..p
Sheriff of Cumberland County, PA
Af~ioissvit ®f Service
Now,
within
upon
at
by handing to _
a
and made known to
copy of the original
the contents thereof.
So answers,
Sheriff of
Sworn and subscribed before
me this day of , 20_
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
20, at o'clock M. served the
County, PA
.ter
Johnson, Duffie, Stewart & Weidner
By: Michael J. Cassidy
I.D. No. 82164
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717)761-4540
COMPREHENSIVE TEST & BALANCE, INC.
Plaintiff
v.
C.K. MECHANICAL CONTRACTORS, INC.,
Defendant
Attorneys for Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4560 Civil Term
CIVIL ACTION -LAW
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Enter judgment by default in favor of the Plaintiff, and against the Defendant, C.K. MECHANICAL
CONTRACTORS, INC., by reason of the failure of the Defendant to enter an appearance or to file an Answer within 20
days of the date of service of the Complaint endorsed with a Notice to Defend, and assess the Plaintiff's damages as
follows:
Amount claimed in Plaintiffs Complaint ...........................................................$3,090.00
Six percent (6%) interest from November 20, 2000 ......................................... 185.40
Tota I ...................................................................................................... $3, 275.40
It is hereby certified that written notice of intention to file this Praecipe was mailed to the Defendant, C.K.
MECHANICAL CONTRACTORS, INC., 2715 McCoy Street, P.O. Box 3554, Williamsport, PA 17701, on August 28,
2001; said notice being mailed after the default occurred and at least ten (10) days prior to the date of the filing of this
Praecipe. A true and correct copy of the aforesaid notice, together with receipt for mailing, are attached hereto as Exhibit
"A,° and made a part hereof.
Dated: / ~ ~/
:149757
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
gy:
Micha J Cassidy
Attorn .D. No. 82164
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for Plaintiff
`l
JUDGMENT
AND NOW, this ay of J~ 2001, judgment is entered in favor of Plaintiff,
Comprehensive Test and Balance, Inc.,. and against Defendant, C.K. Mechanical Contractors, Inc., as
directed above.
2,
Prothonotary
Johnson, Duffie, Stewart & Weidner
By: Michael J. Cassidy
I.D. No. 82164
301 Mazket Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717)761-4540
COMPREHENSIVE TEST & BALANCE, INC.,
v.
Plaintiff
C.K. MECHANICAL CONTRACTORS, INC.,
Defendant
To: C.K. Mechanical Contractors, Inc.
Date of Notice: August 28, 2001
IMPORTANT NOTICE
N0. o! - $S~o Civil Terry
CIVIL ACTION -LAW
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 TEN 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 THtS NOTICE TO A LAWYER AT ONCE. iF YOU DO NOT NAVE 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
Telephone: (717) 249-3166
149461
Attorneys for Plaintiffs
I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
Mich .Cassidy
Attorn LD. No. 82164
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for Plaintiffs
.;<~ ..
U.8. P08TAL ~ ~~- Q~..~iC.~ - ~.
IFICAT ,~ _ ;~~.POSiAGE
c Nts78'al Y= f O :~
~ sit ~;' .75
' ~~_~~ ~' IE~ YB NEiEN ~
I~~ 6738619
Qw pip of oAinry mail
C.K. MECJ-fgrJICgLCuI~TP,~1~TO2S. INC.
a~ 15 M ~ Q~~~I "~-T
P.O. (30x
W~~~IA~-ISPOPLT PA i~"Inl
MAY BE USED fOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE
FOR INSURANCE -PO3TMg3TER
PS FORM 3817 U S GPO 1 1-6 1
MAY 1973 ~ 3
CERTIFICATE OF SERVICE
AND NOW, this ~ day of September 2001, the undersigned does hereby certify that he did this
date serve a copy of the foregoing PRAECIPE upon the other parties of record by causing same to be
deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as
follows:
C.K. MECHANICAL CONTRACTORS, INC.
2715 McCoy Street
P.O. Box 3554
Williamsport, PA 17701
JOHNSON, DUFFIE, STEWART & WEIDNER
t
By:
Mic el J. Cassidy
Comprehensive Test & Balance Inc IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Writ No.
Term, 20
vs.
No. 04560 Civil Temr, 20 Ol
C K Mechanical Contractors Inc
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY OF SAID COURT: Please issue WRIT OF EXECUTION in the above matter,
(1) Duected to the Sheriff of Lycoming County, Pennsylvania;
(2) Against C.K MECHANICAL CONTRACTORS. INC
2715 McCoy Street. P O Box 3554. Williamsport. PA 17701 . " Defendant (s)-;
(3) and against NORTHERN STATE BANK
120 West 4a' Street. Williams. PA 17901 Gamishee (s) ;
(4) and index this writ
(a) against C.K. MECHANICAL CONTRACTORS. INC.
2715 McCoy Street. P.O. Box 3554. Williamsport. PA 17701 Defendant (s) and
(b) against NORTHERN STATE BANK
120 West 4`" Street. Williamsport. PA 17701 Gamishee (s),
as a lis pendens against the real property of the Defendant (s) in the name of the Gamishee (s) as follows: (Specifically
describe property)
Levy upon and sell all personal property of the Defendant, C.K. MECHANICAL CONTRACTORS, INC.,, including, but not
limited to, all tools, eguipment, furnishings, funds, accounts, and other personal property of C.K. MECHANICAL
CONTRACTORS, INC, located at 2715 McCoy Street, Williamsport, Pennsylvania 17701.
Attach all funds and accounts of the Defendant, C.K. MECHANICAL CONTRACTORS, INC, on deposit with NORTHERN
STATE BANK, 120 West 4`„ Street, Williamsport, Pennsylvania 17701, including, but not limited to, those funds held in
Northern State BankAccauntNo.031318596 0110003761.
(5) Amount Due $ 3.275.40
Interest From 09/12/01 $ 1.08
Costs $ 15.50 1
Date: 9 I ~ ~ ~ ~ ~....
Michael J. as idy, Esquire
Johnson, D ie, Stewart & Weidner
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone: (717) 761-4540
Attorney for Plaintiff
:749984.2
-.
' ~ WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 01-4560 CIVIL TERM
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF Lyccminp COUNTY:
To satisfy the debt, interest and costs due Cm7prehensive Test & Balance, Inc.
from C.K. Mechanical Construction, Inc., 2715 McCoy Street, P.O.BOX 3554, Williamsport,
PA 17701
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell LPw r~nn and > > all
ne onal p~gperty of the Defendant including but not limited to all tools eauit~nent
furnishings, funds, accounts and other personal property of C.K. Mechanical Contractors,
Inc., located at 2715 McCoy Street, Williamsport, PA 17701
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
Attach all funds and accounts of Defendant on deposit with Northern State-Bank, 120
West 4th Street, Williamsport, PA 17701 including but not limited to, those funds held in
Northern State Bank Account No. 031318596 0110003761
as follows:
and to noTrfy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof:
(3) If propertyoithedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepossessionofanyoneother.
than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is ehjoinedas above
stated.
AmouMDue $3,275.40 L.L, $.50
Interest from 9/12/01 - $1.08 Due Prothy
Atty's Comm
°fo
Atty Paid $133.00
Plaintiff Paid
Date: September 18, 2001
REQUESTING PARTY:
Name Michael J. Cassidy~sp.
o son, -T'f3e, Sty-~ &-Weimer
Address: ~ ~ go~0o
Lemoyne, PA 17043-0109
Attorney for: Plaintiff
Telephone: 717-761-4540
Supreme Court ID No. 82164
Ocher Costs
Curtis R. Long
Prothonotary, Civil Division
-,~.~ ,~~ , . 5--
Depury
Johnson, Duffie, Stewart & Weidner
By: Michael J. Cassidy
I.D. No. 82164
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
COMPREHENSIVE TEST & BALANCE, INC.,
Plaintiff
v.
C.K. MECHANICAL CONTRACTORS, INC.,
Defendant
Attorneys for Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4560 Civil Term
CIVIL ACTION -LAW
ORDER TO MARK JUDGMENT SATISFIED
TO THE PROTHONOTARY:
Please mark the judgment in the above-captioned matter satisfied of record.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By: ~. / ~.---e
Dated: ~~ ~~ ° ~ Miclla~ J. Cassidy
Atto ey I.D. No. 82164
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
:150753 Telephone (717) 761-4540
Attorneys for Plaintiff
I -,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMPREHENSIVE TEST & BALANCE, INC.,
Plaintiff
No. 01-4560
vs.
C.K. MECHANICAL CONTRACTORS, INC., CIVIL ACTION
Defendant
vs.
NORTHERN STATE BANK,
Garnishee
RESPONSE TO INTERROGATORIES IN ATTACHMENT
1. C.K. Mechanical Contractors, Inc. has two 12- deposit accounts at
Northern State Bank bearing number 110003753 with a current balance of $5,901.27
and account number 110003761 with a current balance of 55,351.66.
2. See answer to interrogatory number 1 above.
3. See answer to interrogatory number 1 above.
4. See answer to interrogatory number 1 above.
5. See answer to interrogatory number 1 above.
6. See answer to interrogatory number 1 above.
7. See answer to interrogatory number 1 above.
8. See answer to interrogatory number 1 above.
9. See answer to interrogatory number 1 above.
10. See answer to interrogatory number 1 above.
1 1. See answer to interrogatory number 1 above.
12. See answer to interrogatory number 1 above.
13. See answer to interrogatory number 1 above.
125 East Third Street
Williamsport, PA 17701
(5701 326-2443
F:\appsnew\wpc\Ot-0134 NOHTHEHN STATE BANK- C.K. MacM1anicel\Feapanae to GarniaM1ee Inbrcogetoriea.wptl
I.D. No. 30477
Attorney for Garnishee
VERIFICATION
The undersigned hereby certifies and says that he is an authorized to execute
this verification, that the undersigned has reviewed the contents of the attached
Response to /ntenogatoiies in Attachment ,and that the facts set forth therein are true and
correct to the best of the knowledge, information and belief of the undersigned.
The undersigned acknowledges that any false statements made herein would
be made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn
falsification to authorities.
r~` --.---r ~ ~ v
Michael Caffrey
NORTHERN STATE BANK
F:\appsnew\wpc\07-0134 NORTHERN STATE BANK - C.K. Mechanical\verification.wpd
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMPREHENSIVE TEST & BALANCE, INC.,
Plaintiff
vs.
No. 01-4560
C.K. MECHANICAL CONTRACTORS, INC., CIVIL ACTION
Defendant
vs.
NORTHERN STATE BANK,
Garnishee
CERTIFICATE OF SERVICE
WILLIAM P. CARLUCCI, hereby certifies and says that on this,? day of
December, 2001 he served a copy of the document upon which this Certificate of Service
is attached upon the following:
Michael J. Cassidy, Esquire
Johnson, Duffie, Stewart & Weidner
301 Market Street
P.O. Box 109
Lemoyne, PA 17043
Fred A. Holland, Esquire
Murphy, Butterfield & Holland, P. C.
442 William Street
Williamsport, PA 17701
by placing a copy of the same in the United States mail, first class delivery addressed as
set forth above.
ELION, WAYNE, GRIECO, CARLUCCI
SHIPMAN & IRWIN, P.C.
125 East Third Street
Williamsport, PA 17701
(570) 326-2443
William P. Carlucci, Esquire /jy
I.D. #30477 '/~
F:\appsnew\wpc\07-0134 NORTHERN STATE BANK - C.K. Mechanicallcert of service.wpd