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HomeMy WebLinkAbout01-06582 '0' , ,J, ..... ""--",,',;,,,--- "jillW~" EDWARD N. FLAIL, JR. ATTORNEY I. D. #10049 POST OFFICE BOX 507 130 WEST LANCASTER AVENUE WAYNE, PA 19087 (610) 964-1600 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. 2890 Hempland Road Lancaster, PA 17601 NO.01- (,,5"92- ~ : v. LETORT CONSTRUCTION, INC., also known as Cold Creek Roofing Company 50 Lisburn Road Carlisle, PA 17013 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 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 OBTAIN LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 '''I " ,J,C < , '-d'"L>ti~Iif..{,,,,, EDWARD N. FLAIL, JR. ATTORNEY I. D. #10049 POST OFFICE BOX 507 130 WEST LANCASTER AVENUE WAYNE, PA 19087 (610) 964-1600 ATl'ORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. 2890 Hempland Road Lancaster, PA 17601 NO.01- ("S'S.2.. v. LETORT CONSTRUCTION, INC., also known as Cold Creek Roofing Company 50 Lisburn Road Carlisle, PA 17013 COMPLAINT 1. Plaintiff with the name and address first above is a Pennsylvania corporation engaged in the business of building supply. 2. Defendant, with the name and address second is a Pennsylvania corporation, engaged in the business of general contractor. 3. On or about April 7, 1997, Defendant, DANNY V. SWEARINGEN, completed and executed a credit application, a true and correct copy of which is attached hereto as Exhibit "A" and incorporated by reference, under which Defendant established a credit in the name of LETORT CONSTRUCTION, INC., also known as Cold Creek Roofing Company. ~ "~ ~'" ~, 1 .'. ",'1 -," _ "". - ,,::,' , '~~ .,;".. '-<~"'~(r'~i,. 4. Thereafter, at the special oral request of Defendant acting through Danny V. Swearingen, and others of its shareholders, directors, officers, employees and agents, who were au~horized or allowed to act on Defendant's behalf, Plaintiff made and performed work and services and sold merchandise of the kind and quantity, on the dates, in the forms, and for the prices set forth in Plaintiff's books of original entry, true and correct copies of which are attached hereto as Exhibit "B" and incorporated by reference, which consist of invoices for various types of building materials and supplies sold by Plaintiff to Defendant. 5. Defendant received and accepted the aforesaid. 6. The prices set forth in Exhibit "B" are the fair and reasonable market prices existing at the time of the transactions and is that which Defendant agreed to pay. 7. All credits due Defendant for payments and returns or other deductions authorized by Plaintiff are set forth in Exhibit "B". 8. In addition to the amount set forth in Exhibit "B", Plaintiff claims interest at the rate of 1 1/2% a month, as set forth in Exhibits "A" and "B", which is $1,046.03 from December 31, 2000 through November 30, 2001. 9. In addition to the amount set forth in paragraph 7, Plaintiff claims attorney's fees, as set forth in Exhibits "A" and "B" at the rate of 15%, the amount Plaintiff pays its attorney for collection work which are $995.67, making the total of Plaintiff's claim $7,633.49, through November 30, 2001. 10. Despite demand of the sum due by Plaintiff and promises of payment by Defendant, Defendant has not made payment. WHEREFORE, Plaintiff demands judgment against Defendant, LETORT CONSTRUCTION, INC., also known as Cold Creek ;? ~~~ ~ ~ , , _ oJ ,,_ , ~~," ~ ,..,~ ' {" _ '<'--";J:~,i, Roofing Company, in the sum of $7,633.49 plus costs and interest from December 1, 2001. WARD N. FLAIL, JR. ATTORNEY FOR PLAINTIFF 'j' '~"'" - "'"'~" . """""~ , -" . ~ 1i\1,..l<i' - ~!hi&i.t('h"'H''l'IIiri--,,,,,iL,;- QUALITy'ROOFING SUPPLY CO., INC. f)vtJ~~. DC.J 2890 Hempland Road . Lancaster, PA 17601 717.293.8800 CREDIT APPLICATION AND CONTRACT (Please complete aI/lines) FIRM NAME: Letort Construction, Inc. and/or Cold Creek Roofinq Mailing Address: SO Li <;t'hllrn Rnan Business Address: Same I Carlisle. P~. 17013 Building is Owned ~ Rented 0 i Date Business Started Auq. 1993 CREDIT LIMIT DESIRED 150,000.00 OFFICE USE ONLY CREDIT LIMIT /t?c?vd APPROVED BY ~.::Y DATE APPROVED - ? - fi'" ? SALESPERSON . / to _-. Check One: Individual n ~ Corporation ~ Partnership 0 Phone No.: (717 ) ?SR-RO?l FAXNo.:(717 ) 25e-q375 Type of Business: []( Commercial ~ Residential ~ Remodeling Q{ Industrial 0 Wholesale Appllcanl Builds - Contract % How many homes built per year? PRINCIPALS OF FIRM: 1. Name: Dannv V. Swearinqen SS# 203-36-3847 Title: President Address: '50 T; ~b"X'l' Rn",rl Street r.::.rli91,::,. City SS# 181-42-7819 P"I 17013 State Zip Tille: Vice-President 2. Name: Betsy R.Swearingen Address: Street City State Zip 3. Name: SS# Title: Address: Street City State Zip TRADE REFERENCES: 1. Name: \.. lip,(" ""[>ply rn r T1'(," Accl. # 44RQOO PHONE NO.: (717 ) 741-4(;44 Address: ?fiOR K,::,..yt\7.:::!f nri"Po Street Vnrk P.::. City . 1740? State PHONE NO.: e17 Carlisle, Pa. State Zip 243-~:;939 2. Name: \ Castles Lumber Accl. # 1202 Street City 17013 Zip Y90-9814 Address: \ 3. Name: \ Address: 290 E. Pomfret St. Street Acct. # LET020 PHONE NO.: (717 Readinq. Pa. 19612 City State Zip Kohl Buildino Products POBox 14746 BANK REFERENCES: 'It' F 1. Name & Branch armers Trust Account Executive: Address: One West High Street, Carlisle, Pa. 17013 Checking Phone No.: ( 717) 243-n12 Type of Account: 2. Name & Branch Account No.: Address: Type of Account: SALES TAX EXEMPT fjxHml~ Account Executive: ~ ". ' Phone No.: ( Account No.: YES x NO -IF YES, PLEASE ATTACH CERTIFICATE COPY. PLEASE READ THE TERMS AND CONDITIONS LISTED ON BACK AND SIGN THE CREDIT APPLICATION ON BACK BPn290 Rev. 9/94 Please sign the back $;' '~Jr",",",J,' ~,~,~-t-ibii.~'~!~'r~i( ,,,,;:-,,,h-,,,,.~,iO;, ":.U'~'.""-,,;.i', .. "I!~li,:~M;OA[{~~h;iIi.~~",,;~~,~,"!1;;~r;"ll,,","~Aidt~m""#j,j{f4,-.<,""""J~rl:#J'l&~~t'W~ Hm. Ii_ 11_ TERMS AND CONDITIONS In addition to the terms and conditions set forth in any subsequently executed sales agreement or similar document, all purchases made fly Applicant shall be subject to the following terms and conditions: 1. Quality Roofing Supply Company, Inc. ("Quality Roofing") reserves complete discretion concerning aU extensions of credit and shall have the right at any time to refuse to extend credit to Applicant or change credit limit without notice. 2. No warranty is made by Quality Roofing relating to the quality of materials provided by it to Applicant. All materials are subject to a manufacturer's warranty and any claim relating to such materials shall lie exclusively against the manufacturer. Quality Roofing shall not, under any circumstances, be liable to Applicant or to any ather person for lost profits, additional expenses incurred in replacing defective materials, or any other special, incidental. indirect. consequential losses, delay damages, or damages of any kind whatsoever. NO WARRANTY OF MERCHANTABILITY OR WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, OR ANY OTHER WARRANTY, EXPRESS, STATUTORY OR IMPLIED SHALL APPLY TO ANY ~IATERIALS SOLD BY QUALITY ROOFING, i 3. Applicant acknowledges that shipping dates stated by Quality Roofing, are only estimates and do not represent a set time for performance. Time will not be of the essence unless Quality Roofing agrees in writing to that effect. i I 4. Applicant acknowledges and agrees that all purchases made by it shall be paid for in accordance with such payment terms as may from Ume to time be established by Ouality Roofing. Any invoice not paid in fuil within the terms stated on invoice wi:1l be SUbject to a finance charge of one and c:le-half percent (1-1/2%) per month. and balances under $25.00 will be subiect to a minimum finance charge of $.50 per month. 5. Applicant hereby grants to Quality Roofing a security interest in all materials sold by Quality Roofing to Applicant. on open book account or ;-:ursuant to written or oral contract, to secure the prompt and full payment of any and all amounts now or at any time hereafter owing by Applicant to \-':'J8Iity Roofing. So long as any balance remains owing from Applicant, Quality Roofing shall have all rights of an unpaid secured creditor under the P'.:'lnsylvania Uniform Commercial Code and all ather righ'ts and remedies available at law or in equity. fl. This Credit Application and any subsequent contract of sale between Quality Roofing and Applicant, shall be deemed to have been entered into at the home office of Ouality Roofing in Lancaster, Lancaster County, Pennsylvania. Applicant acknowledges and consents to the exercise of jurisdiction by the Courts of Common Pleas of the Commonwealth of Pennsylvania. Applicant further agrees that venue for any lawsuit brought by Applicant, its successors or assigns, against Quality Roofing for whatever reason. shall lie exclusively in the Court of Common Pleas of Lancaster County, Pennsylvania. 7. In the event that Applicant's account is referred to an attorney or collection agent lor collection, Applicant agrees that Quality Roofing Supply Company, Inc. shall be entitled to collect. in addition to principal and accrued finance charges, an attorney's fee 01 fifteen percent (15%) thereof and/or collection fees. 8. This Credit Application and any transactions pursuant thereto shall be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania. 9. Applicant agrees to provide Quality Roofing Supply Co., Inc. with written notice of any change in Applicant's name. address, ownership or form of business entity. 10. Applicant hereby authorizes Quality Roofing to contact any bank, credit or trade reference to verify the Applicant's credit standing and/or assets and hereby authorizes those parties to release all pertinent information to Quality Roofing. By signing below, each undersigned individual acknowledges that he or she has read the terms and conditions above and that he or she understands that those terms and conditions have legal consequences to the Applicant. AP~ t.n-O~~J'T.I ~we. By () / -~'o- Relc:atfunship to Applicant: (SEAL) By: (SEAL) Relationship to Applicant: GUARANTY In consideration of the credit which has been or which may in the future be extended to Applicant, and pursuant to the Terms and Conditions contained in the Credit Application and Agreement, each undersigned hereby personally guarantees the prompt and full payment of all amounts now or here~~er owing by Applicant to Qualitx Roofing. Each of the undersigned further agrees that the foregoing guaranty is continuing, absolute and unconditional and may be e~forced against any of the undersigned individually, Jointly or in any combination, without first proceeding against Applicant. Each of the underSigned waives any right to be released by reason of any extension of time or change in terms of payment and any other defense now or hereafter available, except the defense of payment., . By signing below, each u~~ersigned Individual acknowledges that he or she has read the Terms and Conditions above, that he or she understands that these Terms and CondItIons have legal consequences both to the Applicant and to the undersigned individually and that he or she agrees to be bound thereby. SIGNED: SIGNED: DATE: Do Not Write Below This Line-For Office Use Only D&B RATING CREDIT LIMIT TERMS Salesperson Credit Manager Manager ACCEPTED: QUALITY ROOFING SUPPLY CO. INC. By Tille .'- ,,~." .~ ,~'- ~ ^ ,~,~.. I ~~"." ~., ~~,=_ " ~ '~ ' ~--,~"..._~ '. ~ ~b... U~'-'- ,~ !L!.ii~---d:j$>JI~Ic'l1jil ("-,~w,,fu;jj~ ';.0/"0' ~QJ' - - - - .-= - -'. , "";- - - QUALITY Please direct billing inquiries to: Quality Rooting Supply Co., Inc. Corporate Office 2890 Hempland Road Lancaster, PA 17601 800-552-6060 www.quali.rfrcoiingsupply.com STATEMENT CENTERVlllE g~A~CH ClAlIT~ RCCFI~G SlPP P.C. eCx E2C836 I' c.er~rviJ1l> , J:'~ .llOO'552,60BO Llu4c&5Iet!. 9 - - 1>,1; C 4lO0.422,2040 Mechamcsburg, PA 800-896-1090 Reading, PA 800-641-2850 Lewes, DE 800-324-5792 New Castle, DE 800-544-3704 CCLt CREEK RCCFI~G A~t CR lETCRT CO~STRlCTICN I~C. 50 LIsnURN RUC CARLISLE. PA 11013 . ",:. . 'CODES ~~,.' A. DISCOUNT F - ANANCE S - SERVICE ALLOWED CHARGE CH-";:;Gf C.CRMEMO 'I-INVOICE W.WAiTE.OFF o -OR MEMO P - PAYMENT U. UNAPPuEO CASH ALL SALES ARE SUBJECT TO THE TERMS AND CONDITIONS OF SALE ON THE REVERSE SIDE ~rrr=i~~.I:=l~tiimi~~m '" 'AMoUNT"" ~ . MOUNmlECETVal". 'r'~BAtANCEt)UE ,. 1351H HCl lULe/lie; 1 3,4<JC.31 3,4C;C.3, 13 5513 HCl lC/2 el c;e; I 1.2el.gc 4.11E.21 1703 HCl 1/25/C( 1 2eC;.H S,CtS.C:: SOC557 7/31/CC S 144 . I C 5,212.1~ SC3C7C;5 C/31/CC S 14~.IC ~,3'3t:.2; SC3ICe<J <;nc/cc S 83.52 !; ,113". 7 ~ SOlI/:4 lC/::1/CC S 7/:.C2 5,51~.77 501250 1113CICC S U .C2 5,5C;1.7~ tC/o 1101 ~ j Dc9;t,C7"''''''' (j vrtH., 1't.fV (~ 'DEe. ~I, DO '"''"''14 'llla}Oj f '0 I /0 1'-1 GI (1-T~ So ?&.U') ~Clc.. i){,O I- , . -If ~3 ~,9~ IllINC IS NCh THRU ~C~lH EN[ - tErUCT DISCCL~l '''ICE-CNLY - PlEASF ~f."IT 'iT1.B wrn p6Hnr EXHIBI'lr"BU . "',~'b L,J.'''''' VERIFICATION "'"'. ~"" ' ',--',' ,,' ~,; .h~;~"Jl~r"." "\fi! DONALD HOLLINGWORTH, hereby verifies that he is corporate credit Manager for QUALITY ROOFING SUPPLY COMPANY, INC., and that he makes this Verification on its behalf, and that the facts set forth in the foregoing pleading are true and correct to the best of his knowledge, information and belief. This Verification is made subject to the penalties of 18 PA. C.S.A. S4904, relating to the falsification of unsworn statements to authorities. Date: ~~~/ LD HOLLI 1.~ ~ L '''"'',_'.' ~~ ,,~N, ~,"~~, < "~<'",,,y ,~__'" _ ~,"' .<, ,. ,""'", ,,_ ,E ~"'i;'b'r',J;!':'J!'~"';C";"iCb~-t0~j;K-JJ!H';"'''ii.~Mffi\lni\lllilll<ltl"~~~i!4Bi<ili.t;jl?~~~:.A ~~ ~ /0 (l;) ~ r- "-,- ....... -- ~ <:> -l::. -.... '",,"'," i'" ~ ~ ,-,'-' ()v 0' cJ'1 ","",,' D r- c:J1 ~I <::! 53-~ C9 ""- , 11..... () C s: vCJ rTirr-: Z'--q ~}~,~ r" c'= <; ,,' ):~ r-- -,;;-~ ,-.T i;:C) c: 7' :< - o o~ '1 2: o "c :"0 ~,:;f r~lf__~ "'':.)r:n --,t 1 ~::~:1 ~~; ~j2S (5 In :;:j :i:J -< -0 - "'~ S:-' ':.) - .""""'~." "~ll:,r"~' -........," -'>>~!i...\f'-'""' 1'1 'lliIiH;l<f",,,,"-,,-,;ro'"-41i'V,' SHERIFF'S RETURN - REGULAR CASE NO: 2001-06582 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND QUALITY ROOFING SUPPLY VS LETORT CONSTRUCTION INC A/K/A KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LETORT CONSTRUCTION INC A/K/A COLD CREEK ROOFING COMPANY the DEFENDANT , at 1620:00 HOURS, on the 30th day of November, 2001 at 50 LISBURN ROAD CARLISLE, PA 17013 by handing to BETSY SWEARINGEN, SEC a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Additional Comments LETORT CONSTRUCTION INC IS NO LONGER IN BUSINESS. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.25 .00 10.00 .00 31.25 r~r./<:~ R. Thomas Kline 12/03/2001 EDWARD FLAIL JR me this 13 "::. day of Sworn and Subscribed to before By: I DUt_L, .2tJo1 A.D. .- q,'4i1-'-"' (L h. _,"-., AO';;: Prothonotary , '77 ~ ~'"' '"" . EDWARD N. FLAIL, JR. Attorney I.D. No.: 10049 130 West Lancaster Avenue P.O. Box 507 Wayne, Pennsylvania 19087 (610) 964-1600 I',' "j. , < ,;,..-;.." "",,,",,,,~'~''';''~ "'i.',:':( ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. v. LETORT CONSTRUCTION, INC., a/k/a Cold Creek Roofing Co. NO. 01-6582 PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE OFFICE OF THE PROTHONOTARY: Enter judgment against in favor of Plaintiff and against Defendant, LETORT CONSTRUCTION, INC., a/k/a Cold Creek Roofing Company, under Pennsylvania Rule of Civil Procedure 1037 for failure to file an Answer to the Complaint, and assess damages as follows: Debt from Complaint Interest from 12/1/01-1/1/02 TOTAL DATE: Ja,) 1/ u.x>Ck . $7,633.49 38.16 $7,671. 65 I hereby enter Judgment and assess damages as above. OFFICE OF THE PROTHONOTARY ~~~ ,*. ~ , "' ,j-. _L~ --~ ~,;.,..-.' ,'---', '. {"~::i . EDWARD N. FLAIL, JR. Attorney I.D. No.: 10049 130 West Lancaster Avenue P.O. Box 507 Wayne, Pennsylvania 19087 (610) 964-1600 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. NO. 01-6582 v. LETORT CONSTRUCTION, INC., a/k/a Cold Creek Roofing Co. CERTIFICATION OF SERVICE I, EDWARD N. FLAIL, JR., Attorney for Plaintiff, do hereby certify that a copy of the Rule 237.1 notice was served upon Defendant, LETORT CONSTRUCTION, INC., also known as Cold Creek Roofing Company, via first class mail, postage pre-paid on December 21, 2001. A true and correct copy of notice is attached hereto and marked Exhibit "A". Date: "'-\' , . ~_...J -~ "1~: "t'l ~ ' ,,~ ,"J, "'",,< . . .. EDWARD N. FLAIL, JR. Attorney Number 10049 130 West Lancaster Avenue Post Office Box 507 wayne, Pennsylvania 19087 (610) 964-1600 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. NO. 01-6582 v. LETORT CONSTRUCTION, INC., also known as Cold Creek Roofing Company TO: LETORT CONSTRUCTION, INC., also known as Cold Creek Roofing Company 50 Lisburn Road Carlisle, PA 17013 ADDRESS CORRECTION REQUESTED DATE: December 21, 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 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, PA 17013 (717) 249-3166 EDWARD N. FLAIL, JR. Attorney for Plaintiff EXHIBIT flAW ...-_,-~" . .. ....................... I UJ III Cl ~ '<t ffl rn 0 . 0.. III rn ~,...", :j "'~ I X~.cr: w~ ~"'..... ~'" w~ ~ .~. ~.., ,,).,. m- ,,~<'- ,,~\. ~~ ~~ ~I! ~\~ lJ ~ ~ ~ ~~ ~ ~~~ 1 ~ ~ . ~~~~~ ~ ~~ >< c: ro 0, "' o -u . U01 Z c: H."; .... - 0 ZO C') O~ ..... E-l 0 H~ r- U<V'Cl..... p <V CO ~ l..l 0 E-lU~..; UJ 0< Z'ClC: 0..... l..l - U 0 ::> <V U.a..... E-l [J) [J) ~ CO,'';.,.; 0......."'..... E-l~ l..l """""'0 CO "'COl!)U ~'.' , j ~ . 9 ~ > -' "' "~'-' l:l',~,~'""'"!!!','-, "." '"~ ~ l . ~ _" ~J,'"""' "-c'-, ijr ~ - , ''; , 0 ''lilfi~~~,,,,,;, , EDWARD N. FLAIL, JR. Attorney I.D. No.: 10049 130 West Lancaster Avenue P.O. Box 507 Wayne, Pennsylvania 19087 (610) 964-1600 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. 2890 Hempland Road Lancaster, PA 17601 NO. 01-6582 v. LETORT CONSTRUCTION, INC., a/k/a Cold Creek Roofing Co. 50 Lisburn Road Carlisle, PA 17013 CERTIFICATION OF ADDRESSES I certify that the addresses of the within judgment creditor and judgment debtor are as listed above. / "', ~-".' -, "- "'c~;..;... ,1,,,, '''; -" - ~'- i4il ' ~~,""",,"'" , EDWARD N. FLAIL, JR. Attorney I.D. No.: 10049 130 West Lancaster Avenue P.O. Box 507 Wayne, Pennsylvania 19087 (610) 964-1600 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. NO. 01-6582 v. LE~ORT CONSTRUCTION, INC., a/k/a Cold Creek Roofing Co. TO: LETORT CONSTRUCTION, INC., also known as Cold Creek Roofing Company 50 Lisburn Road Carlisle, PA 17013 ADDRESS CORRECTION AND FORWARDING REQUESTED NOTICE Notice is hereby given that a judgment in the above-captioned matter has been entered against you on , 2002. OFFICE OF THE PROTHONOTARY If you have any questions concerning the above, please contact: EDWARD N. FLAIL, JR. Attorney for Plaintiff 130 W. Lancaster Ave. P. O. Box 507 Wayne, PA 19087 (610) 964-1600 ~~ ~~r,;;,"/ -~ili:niJ!l!tI<I--'~~'~'if~;,~;:o-;""'J"""\C." " ~. d~_ ~,~.~,'~,,", ", ~- "",I"~~~ ,~ ,~~"v,' ,'~A,,j;'_','~"'i'd "ih'~ib"''':''',';''!-l'''&;iiiofJfijfo>lM!It~~*,\l1~i$;~iS~~i!Ii-i'Yl1fi!!-~~- c~(.:).(g. ~lt ~ ;0 Q_ t & rJ ....... ~ ~ :\ ~ ~ Ii :5 .... 0:--. r ~ r ~~ ~ --<"t- (") CJ ~:~ C 1'''J :.~ '-- cpt1 ~p,o ~~~ :e:: -< r:: c., .'0 -- ,,> 0 "0- ~ ..--~- () ", )> ~? - c 1 ) Z ~ -., :::> -< (,.) SJ -< c, I~J 1M .. ","'-~-- ~~," BElli .~"~, , ~ L,l ,; , "0:.:''''',-- -"',(","", ';"~~;i; EDWARD N. FLAIL, JR. ATTORNEY NUMBER 10049 130 WEST LANCASTER AVENUE POST OFFICE BOX 507 WAYNE, PENNSYLVANIA 19087 (610) 964-1600 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION QUALITY ROOFING SUPPLY COMPANY, INC. . . NO. 01-6582 v. LETORT CONSTRUCTION, INC., a/k/a Cold Creek Roofing Co. ORDER TO SATISFY TO THE OFFICE OF THE PROTHONOTARY: Kindly mark the Judgment, "satisfied" as to Defendant, LETORT CONSTRUCTION, INC., a/k/a Cold Creek Roofing Co., upon payment of your costs only. 1\ I ,1 ~"! DWARD N. FLAIL, JR. Attorney for Plaintiff ~ ',: <0" , " , ' - ~~1ir1!~iWmimlri&,l~Jl&it,O'J:'ii;.Pli!~\';<!ii;1:,')-1i.i'~~:"'!1~.gk,'~,::"""Z4"'J''''8;M';MjlUltJ1.diif~.~~_Jl\ilklj~@~~~~~~~~~iliW~'[,1~,iiL- 0,' '""""<''''""N~'~ _" "', ,'",,_ '., .. <>", ,'~_ ~. _ ~V , (') c -o~~',: nlh'- ~Z:.Y :ZC.' ~':? -" ~9 JC:~~ ~- "~^,",- ~" C) r-"':' ~ 1111!!l!J:', C) ',I ",~ ., ,c, ~ ,~ "" '.. ? ~'--' ~