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1L.o.03.35'97 /ht.1J J~
STIPULATION AGAINST MECHANICS LIENS
WHEREAS, Ray E THRUSH and Jean l THRUSH, his wife, entered into a contract
with Beaver Concrete, 2685 Edenville Road, Chambersburg, Pennsylvania, to construct a
pit to be located at 170 Smithdale Road, Shippensburg, in Southampton Township,
Cumberland County, Pennsylvania.
NOW, THEREFORE, it is hereby stipulated and agreed by and between the said
parties, as a part of the said contract and for the consideration therein set forth, that neither
the undersigned contractor, any sub-contractor or material man, nor any other person
furnislning labor or materials to the said contractor under this contract shall file a lien,
commonly called a mechanics' lien, for work done for construction of the said pit.
This Stipulation is made and intended to be filed with the County Prothonotary
within ten (10) days after date in accordance with the requirements of Act of Assembly of
Pennsylvania, in such case provided.
IN WITNESS WHEREOF, the said parties hereto have set their hands and seals the
2L day of J Ul Y, 2003.
WITNESS:
BEAVER CONCRETE
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By: tU tK~
AlA... "" /C ,.,,0v4 Contractor
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HRUSH, Owner
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L THRUSH, Owner
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
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On this 215+ day of July, 2003, before me, the undersigned officer, personally
appeared , of Beaver Concrete, Contractor, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument,
and acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
FOREST N N~TAR'Al SEAl
SHIPPENSBURG B/ERS, NOTARY PUBLIC
MY COMMISSION :,~g~S' COOEUNTY OF FRANKLIN
. c CEMBER 17. 2005
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Notary Public
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF . &1,^~ . ~ .".
On this'l..,,1lr day of July, 2003, before me, the undersigned officer, personally
appeared Ray E THRUSH and Jean L THRUSH, his wife, Owner, known to me (or
satisfactorily proven) to be the persons whose names are subscribed to the within
instrument, and acknowledged that they executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
NOTARIAL SEAL
FOREST N.MYERS. NOTARY PUBLIC
SHIPPENSBURG BOROUGH, COUNTY OF FRANKLIN
MY ,COMMISSION EXPIRES DECEMBER 17. 2005
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Notary Public
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vs.
) IN THE COURT OF COMMOM PLEAS OF
) CUMBERLAND COUNTY,
) PENNSYLVANIA
)
) CIVIL ACTION - FAMILY DIVISION
)
) NO.: 03-3567
)
PAMELA S. KREBS,
Plaintiff
JOHN R. KREBS,
Defendant
PETITION TO MODIFY ORDER OF CUSTODY
AND NOW, comes the above-named Plaintiff, Pamela S. Krebs, by and through her
!tttomey, JoAnne Murphy, Esquire of Gingrich, Smith, Klingensmith & Dolan and respectfully
pies this Petition to Modify Custody as follows:
I. Your Petitioner, Pamela S. Krebs (hereinafter "Mother"), is the above-named
Flaintiff and Mother of the subject minor children, David W. Krebs, born August 3, 1999 and
,
I
~eah S. Krebs, born July 19, 2001. Your Petitioner is an adult individual currently residing at
i
11650 Airport Drive, Mechanicsburg, PA 17055
2. The Respondent is Jolm R. Krebs (hereinafter "Father"), is the above-named
~laintiff and Father of the subject minor children, David W. Krebs, born August 3, 1999 and
I
~eah S. Krebs, born July 19, 2001 whose last know address was 908 Spring Circle,
i
!Mechanicsburg, P A 17055.
3. On June 23, 2004, the parties appeared with their respective counsel before
I
,
IConciliator Dawn S. Sunday, Esquire pursuant to Mother's Petition for Custody of the subject
iminor children. Pursuant to the agreement reached at the conference, an Order of Court dated
iJuly 9, 2004 was entered ordering shared legal and shared physical custody of the parties' minor
I
jchildren. Attached hereto is a copy of the Order and respectfully marked as exhibit "A."
4. Petitioner believes and therefore avers that she recently purchased a home in the
Cumberland Valley School District as it was her understanding that the parties agreed that the
children should attend the Cumberland Valley School.
5. Respondent is now indicating that he will be buying a residence in the Mechanicsburg
Area School District.
6. Petitioner believes that since the parties' oldest child will be school age and the parties
i
}viII no longer be residing in the same district it will be difficult to continue the shared custodial
i
rangement
,
,
7. Additionally, Petitioner believes and therefore avers that the current arrangement has
pot been in the children's best interest due to emotional difficulties that have arisen.
i
8. Petitioner believes and therefore avers that it would be in the best interest for her to
,
i
,
~ave primary custody and Father to have a regular schedule of partial physical custody.
i
I WHEREFORE, Petitioner is requesting the current Custody Order be modified to grant
~etitioner primary physical custody.
Respectfully submitted,
GINGRICH, SMITH, KLINGENSMITH & DOLAN
.CL~-
J e Murphy, Esquire
:l\tt rney for Plaintiff /' I
I
2 S. Market St., P. O. Box 267 i.../
lizabethtown, PA 17022
Attorney I.D. #80838
VERIFICATION
I verify that the statements made in this Petition to Modify Order of Custody are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Date:
5;!3k5
L:/#~
Pamela S. Krebs
vs.
) IN THE COURT OF COMMOM PLEAS OF
)
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) CIVIL ACTION - F AMIL Y DIVISION
)
) NO.: 03-3538
)
PAMELA S. KREBS,
Plaintiff
JOHN R KREBS,
Defendant
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a copy of Petition to ModifY Order of Custody
ppon the person(s) and in the manner indicated below, which service satisfies the requirement of
Pa. RC.P. 440:
Service by facsimile and first class mail addressed to:
Lori K. Serratelli, Esquire
(Attorney for Defendant)
Suite 20 I
2080 Linglestown Road
Harrisburg,PA 17110-9670
GINGRICH, SMITH, KLINGENSMITH & DOLAN
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Jo Murphy, Esquire
ftto~y for Plaintiff
(P. Q/Box 267
..Elifabethtown, P A 17022
(717) 367-1370
Attorney LD. #80838
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