HomeMy WebLinkAbout07-6080`I
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
1047 Old Bernville Road
Reading, Pennsylvania 19605
Plaintiff,
vs. Civil No: 67- bow 01y;F&I
BINGAMAN-LAZAR BUILDING COMPANY, LLC
Serve: Alfred Lazar
455 Saint Johns Drive :
Camp Hill, Pennsylvania 17011
and
ALFRED LAZAR
455 Saint Johns Drive
Camp Hill, Pennsylvania 17011
and
LAWRENCE BINGAMAN
455 Saint Johns Drive
Camp Hill, Pennsylvania 17011
Defendants.
NOTICE TO DEFEND AND CLAIM RIGHTS
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 GET LEGAL HELP.
Court Administrator, Cumberland County
1 Courthouse Square
Carlisle, PA 17013
717-240-6200
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
1047 Old Bernville Road
Reading, Pennsylvania 19605
Plaintiff,
VS. Civil No: 0 7' 60-1114
BINGAMAN-LAZAR BUILDING COMPANY, LLC
Serve: Alfred Lazar
455 Saint Johns Drive
Camp Hill, Pennsylvania 17011
and
ALFRED LAZAR
455 Saint Johns Drive
Camp Hill, Pennsylvania 17011
and
LAWRENCE BINGAMAN
455 Saint Johns Drive
Camp Hill, Pennsylvania 17011
Defendants.
COMPLAINT
Plaintiff, Kohl Roofing & Siding Co. t/a Kohl Building Products Inc., by and through its
Silverman & Associates, Chtd., and Gary S. Silverman, Esq. hereby brings this action
inst Defendants and states as follows:
Parties
1. Plaintiff Kohl Roofing & Siding Co. t/a Kohl Building Products Inc. ("Kohl") is,
was at all times relevant hereto, a Pennsylvania corporation with its principal office at 1047
Old Bernville Road, Reading, PA 19605.
4
2. Defendant Bingaman-Lazar Building Company, LLC ("BLBC") is and was at all
times relevant hereto a Pennsylvania limited liability company.
3. Defendant Alfred Lazar ("Lazar") is and was at all times relevant hereto a
Pennsylvania resident.
4. Defendant Lawrence Bingaman ("Bingaman") is and was at all times relevant
a Pennsylvania resident.
Factual Background
5. On or about January 29, 2007, BLBC executed a Business Credit Application
Agreement") with Kohl wherein BLBC agreed to pay for materials provided by Kohl. A copy
Iof the agreement with personal guaranty is attached hereto as Exhibit A and incorporated herein
reference.
6. Prior to the sale of materials by Kohl to BLBC, Lazar and Bingaman each
a personal guaranty ("Guaranty") wherein they agreed to be held personally liable for
account of BLBC in the event of default by BLBC under the Agreement. A copy of the
are included as part of the Agreement and attached hereto as Exhibit A and
herein by reference.
7. Pursuant to the terms of the Agreement, Defendants agreed to pay interest in the
of eighteen (18%) percent per annum on the unpaid balance of any account twenty-five
1(25) days past due.
8. Pursuant to the terms of the Agreement, Defendants agreed to pay thirty-three and
third percent (33 1/3%) of the principal amount due for attorney's fees plus costs.
COUNTI
(Breach of Contract against Bingaman-Lazar Building Company, LLC:)
9. Kohl incorporate paragraphs 1 through 8 in this Count I as if fully stated herein.
5
10. At the request of BLBC, Kohl in January of 2007 provided building products
(hereinafter "supplies") to BLBC on open account and sent invoices demanding payment. BLBC
has failed to pay the principal amount totaling four thousand nine hundred seventy and 63/100
dollars ($4,970.63). A true and accurate copy of the Invoices and Statements are attached hereto
as Exhibit B and incorporated herein by reference.
11. Despite due demand for payment and full performance by Kohl, BLBC has failed
pay Kohl pursuant to the Agreement and is in breach thereof.
12. As a result of the failure of BLBC to pay the sums due, Kohl has sustained
in the following amounts:
(a) principal in the amount of $4,970.63;
(b) accumulated interest through September 6, 2007 in the amount of $2.45;
(c) interest from September 6, 2007 until the date of judgment in the amount of 1.5%
per month (18% per annum);
(d) attorney's fees in the amount of $1,656.88 (33 1/3% of the principal balance due);
and
(e) costs of this action.
WHEREFORE, Plaintiffs, Kohl Roofing & Siding Co. t/a Kohl Building Products Inc.
Is judgment against Defendant Bingaman-Lazar Building Company, LLC as follows:
(a) principal in the amount of $4,970.63;
(b) accumulated interest through September 6, 2007 in the amount of $2.45;
(c) interest from September 6, 2007 until the date of judgment in the amount of 1.5%
per month (18% per annum);
(d) attorney's fees in the amount of $1,656.88 (33 1/3% of the principal balance due);
and
6
(e) costs of this action.
Count II
(Breach of Personal Guaranty by Mr. Lazar and Mr. Bingaman)
13. Kohl incorporates paragraphs 1 through 12 in this Count II as if fully stated
herein.
14. At the request of BLBC, Kohl in January 2007 provided building materials
(hereinafter "supplies") to BLBC on open account and sent invoices demanding payment. BLBC
failed to pay. A true and accurate copy of the Invoices and Statements has been previously
hereto as Exhibit B and incorporated herein by reference.
15. Despite due demand for payment and full performance by Kohl and the default by
BLBC, Personal Guarantors Bingaman and Lazar have failed to pay Kohl pursuant to the
and are in breach thereof.
16. As a result of the breach of the Personal Guaranties by Lazar and Bingaman, Kohl
sustained damages in a sum equal to the outstanding balance which is due from BLBC as
flows:
(a) principal in the amount of $4,970.63;
(b) accumulated interest through September 6, 2007 in the amount of $2.45;
(c) interest from September 6, 2007 until the date of judgment in the amount of 1.5%
per month (18% per annum);
(d) attorney's fees in the amount of $1,656.88 (33 1/3% of the principal balance due);
and
(e) costs of this action.
WHEREFORE, Plaintiffs, Kohl Roofing & Siding Co. t/a Kohl Building Products Inc.
s judgment against the Defendants Lawrence Bingaman and Alfred Lazar as follows:
7
(a) principal in the amount of $4,970.63;
(b) accumulated interest through September 6, 2007 in the amount of $2.45;
(c) interest from September 6, 2007 until the date of judgment in the amount of 1.5%
per month (18% per annum);
(d) attorney's fees in the amount of $1,656.88 (33 1/3% of the principal balance due);
and
(e) costs of this action.
bmitted,
SILVE NIAN c A5
._S?IATES, CHID.
Gary\&?Mlverman #44089
11200 Rockville Pike
Suite 300
N. Bethesda, MD 20852
(301) 468-4990
Attorney for Plaintiff
8
VERIFICATION
GARY S. SILVERMAN, ESQUIRE, hereby states that he is the attorney for the
Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true
and correct to the best of his knowledge, information and belief.
The undersigned understands that the statements herein are made subject to the penalties
of 18 Pa.C.S.A. Section 4904 relating to unsworn falsific$fT'on tNauthorities.
Silverman #44089
11200 Rockville Pike
Suite 300
N. Bethesda, MD 20852
(301) 468-4990
Attorney for Plaintiff
9
-=KOHL
BUILDING ODUIL S
« 60 9"M 0?
CORPORATE & READING BRANCH OFFICES:
1047 Old Bernville Road, Reading, PA 19605-9311
610-926-8800 610-916-0582 (FAX)
BUSINESS CRE"IT APP
Instructions: EXHIBIT
L Complete all sections (missing information
2. Sign appropriate sections on FRONT and B
3. Provide financial statement
Date 61vARa/ - Z, 2,?-1eA 7
Credit Line Requested $ 4000
Legal Name of Business: A&GAM" - (,421412 184JaD406 COQ L.LG DBA: SAME
Address: 4855 SAtnsr .6014 > S CQ City: CAMP HILL. State: zip:
Business Phone: (717) f75- 13&7 Fax #: (717) M-231,7 Cell#: (717) 3rfQ'4DP?0 Business Established: Zooo
Fed. Tax I.D. #: SIP11 7D Corporation Sole Prop Partners ' Are owners also involved in any other business? _ Yes No
Tax Status: I Taxable _ Non-taxable (If tax-exempt, certificate must be provided.)
,'Have you ever had an account with Kohl Building Products? -Yes -No Name of previous business:
Name of contact: AL iArw LA rAg Purchase Order Required? _ Yes X No
Principals.
Full Name Home Address & Phone # Position Social Security #
1') 44wi2t.act 13 r4 r.Am& P D 44o- 3o$ - PA (MO -0 A951 fi*4 A: -- 110A
2.) ALAU-0 01f LA ZAe %Or- St?rot &fa S Dew CAMP KILL RA - q's ZM -ow,txR/ 1911.
Supplier References:
Name Phone # Fax# Acct #
> 1-fa Hooku 0f-Pot 717- 651- 94,94 el?s}I
2.) f kOHL AtaLn4sc pRaL)uf is 17 - 7 go W O L5
3.) R-F FAG" 717-7&I-o.( zD CASK
4.)
Bank (Checking) Name/Branch
Signature authorizing the bank to release
acct#: t;1c; d/1
Fax:
Phone: (117) -%,5
Has the business or any of the principals listed above filed for bankruptcy? (explai
GUARANTY
In order to induce KOHL BUILDING PRODUCTS (hereafter referred to as KBP), to extend credit to the person or business named above applying for credit, I/WE hereby PERSONALLY
GUARANTY to KBP, prompt payment for all materials purchased from KBP, whether or not the amount of said purchase exceeds the credit limit requested in the credit application. UWE
also PERSONALLY GUARANTY payment of 1 1/2% per month interest on the unpaid balance of any account past due, plus 33 1/3% attorney's fees and court costs. Additionally, YWE
acknowledge that the terms and conditions contained in the business credit application shall be incorporated herein by reference and be made a part of this GUARANTY.
This is a continuing GUARANTY and shall remain in full force and effect until revoked by Guarantor in writing and sent via certified mail/return receipt requested to KBP. Such
revocation shall be effective only as to claims that arise out of transactions entered into after the receipt of said notice. This GUARANTY shall remain binding upon the heirs, estate
representatives, successors and assigns of Guarantor(s). The undersigned hereby waive their homestead exemption as well as all requirements or rights with regard to notice, demand,
presentment or protest and hereby appoint any employee of KBP or attorney to appear in any court or competent jurisdiction for the purpose of confessing judgment on all amounts due
pursuant to the terms of this GUARANTY.
The undersigned, recognizing that his or her individual credit history may be a factor in the evaluation of accepting this GUARANTY, hereby consent to and authorizes KBP to obtain
and use (from time to time and on an "as needed" basis) any and all information related to the credit evaluation process, including but not limited to, the undersigned's consumer credit report.
IMPORTANT NOTICE: THIS CONTAINS A CONFESSION OF JUDGEMENT PROVISION, WHICH CONSTITUTES A WAIVER OF
IMPORTANT RIGHTS YOU MAY HAVE AS A DEBTOR AND ALLOWS THE CREDITOR TO OBTAIN A JUDGEMENT AGAINST YOU
WITHOUT FURTHER NOTICE. ??r
X Signature ur.A.v Print Name: LJ44--o ewe A4 j,4cft y SS #/1?' -W-Q&Jy Date
X
X Signature Print Name: Aa*-tof (K SS # 1'Qp'-? ? 6 Date _ :t: Sienature o.:.,. u-...e. .... ..
5NTitlcs
Signature
No Titles
Print Name:
Date
SS #
Date
TERMS AND CONDITIONS OF SALE E
I . Kohl Building Products' terms and Condit of sale, as well Sall aspects of this application L (incl
; the personal guaranty), have been reviewed for, and
are in compliance with all State and Federa. is. Additionally, all decisions with regard to the exta„ion of credit to any corporation, sole proprietorship,
individual or personal guarantor shall be made in accordance with applicable State and Federal laws, including but not limited to, the Equal Credit Opportunity
Act. The Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants: on the basis of race, color, religion, national origin,
sex, marital status, or age; or because all or part of the applicant's income is derived from any public assistance program, or because the applicant has in good
faith exercised any right under the Consumer Credit Protection Act.
2. These terms and conditions of sale shall control (and supercede all other agreements between the parties) as to all sales made by KOHL BUILDING
PRODUCTS (hereafter referred to as KBP), including all direct shipment sales (whether or not materials are billed to Purchaser's job accounts). Additionally,
Purchaser agrees that they shall be responsible for payment of all materials even where said purchase exceeds the credit limit requested. Terms of sale are net
30 days unless otherwise noted on invoice. Accounts that exceed 60 days past terms may be placed on credit hold until the account is paid current.
3. All orders are based on market price at time of shipment. All prices for direct or drop ship items are FOB shipping point unless otherwise specified in writing
by an agent of KBP. Prices for all other items are FOB point of delivery. The prices quoted are subject to Federal, State, or Local taxes.
4. All orders placed for special order materials (i.e. those materials not kept in stock) are final and may require deposit at time of order, with payment in full
required prior to delivery. Once a special order is-placed and confirmed in writing by KBP, purchaser agrees to accept said materials and make payment in full.
Returns for non-stock or special order materials are subject to the manufacturer's return policy.
5. All materials delivered must be examined and inspected by the purchaser upon receipt. Any claim of shortage or damage must be made at time of delivery.
Where Purchaser cannot examine and inspect material upon receipt, any and all claims must be made within 3 days of delivery or Purchaser accepts materials
.as is".
6. Defective material may be returned for credit or replacement. Returns must be accompanied with the original invoice. Returns must be made within 30 days
of invoice date. Resaleable stock items may be returned and credit will be given when material is received and inspected. Returned materials are subject to a 15%
handling fee. Additional restocking charges imposed by the manufacturer will be charged to the Purchaser. Obsolete and/or discontinued materials are not
returnable.
7. Purchaser agrees that their sole remedy for any default arising out of the sale of materials shall be the return of said materials purchased for a full refund, and
that no suit for default will be brought against, or include KBP where consequential or incidental damages, attorney's fees or costs are sought.
8. On orders placed where the delivery date is delayed due to a manufacturer's shipping, or any other error, Purchaser agrees to hold KBP harmless for the delay
and agrees to make payment in full for materials. Purchaser further agrees that KBP shall not be responsible for, and KBP shall be held harmless, for any product
defect, manufacturer's shipping defect, or any injury to person(s) due to said defects. y
9. KBP makes NO WARRANTIES express or implied, including without limitation, WARRANTIES AS TO MERCHANTABILITY, OR AS TO FITNESS FOR
A PARTICULAR USE OR PURPOSE, and shall not be liable for any loss or damage arising from the use of such materials. ALL MATERIALS ARE DELIVERED
"AS IS" AND "WITH ALL FAULTS". Any contradictory statement made by an employee of KBP, shall have no effect.
10. On all matters referred by KBP for collection, Purchaser agrees to pay 33 1/3% of the principal amount due for collection fees, plus all costs of collection.
All invoices are due net 30 days from date of invoice or statement. Any unpaid past due balance shall be charged 1 1/2% per month interest (18% annum).
Accounts that exceed 60 days past terms may be placed on credit hold until the account is paid current.
11. Purchaser agrees that all material sold on account constitute a continuing contract, and no specific individual sale, invoice, or purchase item shall
considered separate for the purpose of mechanics liens, payment bonds, or for any other purpose. Title to all material shall remain KBP until paid for in full.
be
12. Purchaser represents and warrants that the information provided herein is true and complete. Further, Purchaser authorizes KBP to make all inquiries it
deems necessary to verify the information provided above, including Dun & Bradstreet reports and credit report information. Further, the undersigned who is
either the principal of the credit applicant or other interested party, (recognizing that his or her individual credit may be a factor in the evaluation of the credit
history of the applicant), hereby consents to and authorizes KBP to obtain and use (from time to time and on an "as, needed" basis) any and all information
related to the credit evaluation process, including but not limited to, the undersigned's consumer credit r eport.
13. Purchaser waives his/her/its homestead exemption as well as all requirements or rights with regard to notice, demand, presentment or protest and hereby
appoints any employee of KBP or any attorney for the purpose of confessing judgment in any court of competent jurisdiction in favor of KBP for all amounts
due under the provisions of these terms and conditions of sale. IMPORTANT NOTICE: THIS INSTRUMENT CONTAINS A CONFESSION OF JUDGEMENT PROVISION, WHICH CONSTITUTES A WAIVER OF
IMPORTANT RIGHTS YOU MAY HAVE AS A DEBTOR AND ALLOWS THE CREDITOR TO OBTAIN A JUDGEMENT AGAINST YOU WITHOUT
FURTHER NOTICE.
Purchaser acknowledges that he/she has read and AGREES TO ALL OF THE ABOVE TERMS AND CONDITIONS OF SALE.
X tiunr,.4? ??
t R" Ow?R - p &tW t,
Signature Name (Print)
)( Title
s^ L/?LA2 OlAAM - PAQ.I'xiet
Signature Name (Print)
Title
Signature Name (Print)
Title
Signature Name (Print)
Title
OKOHL
BUILDING P110oucls
REMIT TO:
PO BOX 5108
PHILADELPHI.
S T A T E M E N T
BINGAM & LAZAR BUILD CO
455 SAINT JOHNS DRIVE
CAMP HILL PA 17011-1330
*S SHIP TO:
E3 ACCOUNT #
k, PA 19175-0843
BIN025
STATEMENT DATE
HIBrr
08-13-07
COPY #
1
ACCOUNT# PHONE # DIVISION PAGE
BIN025 717/975-2367 03 1
INVOICE CUSTOMER INVOICE GROSS DISCOUNT DISCOUNT NET
DATE PO NUMBER AMOUNT DATE AMOUNT PAYMENT AMOUNT
12/14/06 SINGER 355203 77.95- 67.37 10.58-
02/01/07 KEHLER 56579 26,351.53 19,646.68 6,704.85
02/19/07 KEHLR 59988 208.28 208.28
HECKS RE EIVED SINCE: 07 -13-07
000000242 08-08-07 2000.00
f
A SERVICE CHARGE OF 1-1/2 % PER MONT H (18% PER YEAR ON ALL AST DUE AMOU NTS
CURRENT 30 DAYS 60 DAYS 90 DAYS OVER 90 TOTAL DUE
6,902.55 6,902.55
TKO M L KOHL BUI NG PRODUCTS REMIT TO:
BUILDIHGPRODUCIS 860 WESLE. DRIVE PO BOX 510843
MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843
INVOICE
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILDING CO
H SITE DELIVERY
455 SAINT JOHNS DRIVE I 1003 GREG'S ROAD
CAMP HILL PA 17011-1330 P HARRISBURG PA 17011-1330
MISC: DKKJ
INVOICE NO.
356579
INVOICE DATE
02-01-07
CUSTOMER/WHITE
ACCOUNT # SHIP DATE SHIP VIA PAGE
BIN025 01-31-07 DELIVERY 1
REFERENCE FREIGHT TERM MESSAGE
CALL AL 379-9080
OUTSIDE` SALESMAN I NSIDE SALESMAN PURCHASE ORDER
YOUR LOCAL BRANCH MANAGER MAUREEN LIVESAY KEHLER
QUANTITY
ORDERED SHIPPED
UOM
DESCRIPTION
QUANTITY
UOM
PRICE
DISCOUNT
EXT
CANDLELIGHT CABINETRY
DOOR STYLE: CANTERBURY FO
FINISH: BURNISHED NUTMEG ACCENT CHERRY
PO#: 308049 ACKNOWLEDGEMENT: 75138
ALL ITEMS NON STOCK / NOT RETURNABLE
ALL PLYWOOD CONSTRUCTION
1 1 EACH NC00018522 UB3312.90 1 EACH 1566.200 1566.20
TALL UTILITY CABINET 33 X 12 X 90 BUTT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018523 SK3612-RW33 1 EACH 54.050 54.05
SHELF KIT 33 X-12
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018524 U1812.90L-MW1'6- 1 EACH 1530.280 1530.28
TALL UTILITY CABINET 18 X 12 X,30' LEFT
?ruva?L?Livnl tt-uvt?tcl?ux]C rV tSUx1v,L?ti. '.P1t1:1"?'Ir;Cz
1 1 EACH NC00018525 SK1812-RW16-- 1 EACH 37.380 37.38
SHELF KIT 16 X 12
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018526 U1512.90R-NFEL- 1 EACH 1428.290 1428.29
TALL UTLITY CABINET 15 X 12 X 90 RIGHT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018527 SK1812-RW15 1 EACH 3<7.380 37.38
SHELF KIT 15 X 12
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018528 UB2712.90-MW26 1 EACH 1668.200 1668.20
TALL UTILTIY CABINET 27 X 12 X 90 BUTT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
TOTAL: a = im .....
TKO H L KOHL BUI NG PRODUCTS REMIT TO:
BUILDING PRODUCTS 860 WESLL, DRIVE PO BOX 510843
MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843
INVOICE
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILDING CO
H SITE DELIVERY
455 SAINT JOHNS DRIVE I 1003 GREG'S ROAD
CAMP HILL PA 17011-1330 P HARRISBURG PA 17011-1330
MISC: DKKJ
INVOICE NO.
356579
INVOICE DATE
02-01-07
ACCOUNT# SHIP DATE SHIP VIA PAGE
BIN025 01-31-07 DELIVERY 2
REFERENCE FREIGHT TERM MESSAGE
CALL AL 379-9080
OUTSIDE SALESMAN I NSIDE' SALESMAN PURCHASE ORDER
YOUR LOCAL BRANCH MANAGER MAUREEN LIVESAY KEHLER
QUANTITY
ORDERED SHIPPED UOM DESCRIPTION QUA NTITY UOM PRICE DISCOUNT EXT
1 1 EACH N000018529 SK3012 1 EACH 54.A50 54.05
SHELF KIT 26 X 12
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018530 TEP152490L-TFFEL 1-EACH 253.850 253.85
TALL END PANEL 15 X 24 X 90 LEFT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018531 TEP152490R-TFER- 1 EACH 618.630 618.63
TALL END PANEL 15 X 24 X 90 RIGHT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018532 W0936L-FFER. 1 EACH 700.550 700.55
WALL CABINET 9 X 36 LEFT
CANDLELIGHT CANTERBURY FQ BURNISH NU'T'MEG
1 1 EACH N000018533 WB3018 1 EACH 413.870 413.87
WALL CABINET 30.X 18 BUTT DOORS
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018534 W2136R--FFEL 1 EACH 551.520 551.52
WALL CABINET 21 X 36 RIGHT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018535 WD2436L-FI-MULL3 1 EACH 843.060 843.06
DIANGLE WALL CABINET 24 X 36 LEFT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018536 W1836L-MW16-00L 1 EACH 731-.410 731.41
WALL CABINET 18 X 36 LEFT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018537 ARV54-72 1 EACH 519.690 519.69
ARCH RAISED VALANCE 55 X 12.5 OGEE EDGE
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
TOTAL: CSB.V Ir= .....
i
F. =KOHL KOHL BU' NG PRODUCTS REMIT TO:
BUILDING PRODUCTS 860 WESLL, DRIVE PO BOX 510843
MECHANICSBURG, PA 17055 PHILADELPHIA. PA 19175-0843
INVOICE
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILDING CO
H SITE DELIVERY
455 SAINT JOHNS DRIVE I 1003 GREG'S ROAD
CAMP HILL PA 17011-1330 P HARRISBURG PA 17011-1330
MISC: DKKJ
INVOICE NO.
356579
INVOICE DATE
02-01-07
ACCOUNT # SHIP DATE SHIP VIA PAGE
BIN025 01-31-07 DELIVERY 3
REFERENCE FREIGHT TERM MESSAGE
CALL AL 379-9080
OUTSIDE SAL€SMAN INSIDE SALESMAN PURCHASE ORDER
YOUR LOCAL BRANCH MANAGER MAUREEN LIVESAY KEHLER
QUANTliY UDM DESCRIPTION QUANTITY UOM PRICE DISCOUNT EXT
ORDERED SMtFPED
1 1 EACH N000018538 WB3336-OOR P EACH 882.850 882.85
WALL CABINET 33 X 36 BUTT DOORS
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018539 WB3618.24 1 EACH 532.070 532.07
24 DEEP WALL CABINET 36 X 18 BUTT DOORS
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
4 4 EACH N000018540 LAC13 4 EACH 417.500 1670.00
LARGE ACANTHUS CORBEL
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH NC00018541 DCBP96-BARHT 1 EACH 1083.730 1083.73
DESIGNER CUSTOME "BASF_ PANEL 96:4 PANEL
CANDLELIGHT CANTERBURY FO BURNISH NU'T'MEG
1 1 EACH N000018542 DCBP24-BARHT P EACH 282.260 282.26
DESIGNER CUSTOMS BASE PANEL 1 PANEL. -
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1: 1 EACH N000018543 BB3,6.02--2W-ROT 1 EACH 994.250 994.25
TWO DRAWER BASE CABINET 36 BUTT DOORS
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018544 B2DD36-MD18 1 EACH 958.550 958.55
TWO DEEP DRAWER BASE CABIET 36
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018545 BB27-MD18-TOER PEACH 1067.720 1067.72
BASE CABINET 27 BUTT DOORS
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018546 B09L-W/DRAWER 1`EACH 651.880 651.88
BASE CABINET 9 LEFT W/DRAWER
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
TOTAL: CCNI'IlNUED ..
KO N L KOHL BUI NG PRODUCTS REMIT TO
BUILDIHGPRODUCTS 860 WESLL. DRIVE PO BOX 510843
MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-0843
INVOICE
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILDING CO
H SITE DELIVERY
455 SAINT JOHNS DRIVE I 1003 GREG'S ROAD
CAMP HILL PA 17011-1330 P HARRISBURG PA 17011-1330
MISC: DKKJ
INVOICE NO.
356579
INVOICE DATE
02-01-07
CUSTOMER WHITE
F ACCOUNT # SHIP DATE SHIP VIA PAGE
C
BIN025
01-31-07
DELIVERY
4
REFERENCE FREIGHT TERM MESSAGE
CALL AL 379-9080
OUTSIDE SALES MAN INSIDE SALESMAN PURCHASE ORDER
YOUR LOCAL BRANCH MANAGER MAUREEN LIVESAY KEHLER
QUANTITY M
UO DESCRIPTION QUANTITY UOM PRICE DISCOUNT EXT
ORDERED SHIPPED
1 1 EACH N000018547 B09R-TD 1 EACH 387.160 387.16
BASE CABINET 9 RIGHT
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018548 BD15.04 1 EACH 649.520 649.52
FOUR DRAWER BASE CABINET 15
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
l 1 EACH NC00018549 SBB36-UT P EACH 653.850 653.85
SINK BASE CABINET 36 BUTT W/UTILITY TRAY
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018550 BWD18 - 1 EACH 859.090 859.09
DOUBLE WASTBASKET BASE CABINE`£ 18.
CANDLELIGHT CANTERBURY FO 'BURNISH L?IM1 G
1 1 EACH N000018551 BERD36L-SS " ?1 EACH 985.480 985.48
ANGLE BASE EASY REACH 36 LEFTSUPEIR_'.SUSA
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
"5 5 EACH NC00018552 MTK-08 5 EACH 27.350 136.75
MATCHING TOE KICK
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
3' 3 EACH N000018553 LBM-08 3i`EACH 58.320 174.96
LIGHT BAR MOLDING
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
4 4 EACH N000018554 RFP-10 4 EACH 196.620 786.48
REVERSIBLE FRIEZE PLATE
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
6 6 EACH N000018555 DC-08 6 EACH 117.670 706.02
DECORATIVE CROWN
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
TOTAL: cuqi2llm ..
==KOHL
BUILDING PRODUCTS
KOHL BUI NG PRODUCTS REMIT TO:
860 WESLL. DRIVE PO BOX 510843
MECHANICSBURG, PA 17055 PHILADELPHIA. PA 19175-0843
INVOICE
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILDING CO
H SITE DELIVERY
455 SAINT JOHNS DRIVE I 1003 GREG'S ROAD
CAMP HILL PA 17011-1330 P HARRISBURG PA 17011-1330
MISC: DKKJ
INVOICE NO.
356579
INVOICE DATE
02-01-07
CUSTOMER/WHITE
ACCOUNT # SHIP DATE SHIP VIA PAGE
BIN025 01-31-07 DELIVERY 5
REFERENCE FREIGHT TERM MESSAGE
CALL AL 3 79-9080
OUTSIDE SALESMAN INSIDE SALESMAN PURCHASE ORDER'
YOUR LOCAL BRANCH MANAGER MAUREEN LIVESAY KEHLER
QUANTITY UOM DESCRIPTION QUANTITY UOM PRICE DISCOUNT EXT
ORDERED' SHIPPED
1 1 EACH N000018556 BF03 1 EACH 27.350 27.35
BASE FILLER 3"
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018557 WF0336 1 EACH 34.060 34.06
WALL FILLER 3 X 36
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
6 6 EACH N000018558 6; EACH N/C
SHELVES
1 1 EACH NC00018559 1 EACH N/C
CARE KIT BURNISHED
2` 2 EACH NC000185GO RI 117 2 EACH 105.250 210.50
ROPE MOLDING .INSERT
CANDLELIGHT CANTERBURY FO BURNISH 2fUTMEG
1 1 EACH N000018561 TF0390 1 EACH 66.060; 66.06
TALL FILLER 3 X' 90 ;
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018562 OCM-08 1 EACH 23.740 23.74
OUTSICE CORNER MOLDING
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
1 1 EACH N000018563 SM-08 1 EACH 22.190 22.19
SMALL SCRIBE MOLDING
CANDLELIGHT CANTERBURY FO BURNISH NUTMEG
N FRONT ST,R ON ROBERTS VALLEY RD(1ST R
AFTER ROCKVILLE BRIDGE)TOP OF RV RD BEAR
RIGHT,GREG'S ROAD ON LEFT,TO 1003 ON
RIGHT.
TOTAL: CV I.....
=KOHL
BUILDING PRODUCTS
KOHL BUI NG PRODUCTS REMIT TO:
860 WESLL. DRIVE PO BOX 510843
MECHANICSBURG, PA 17055 PHILADELPHIA. PA 19175-0843
INVOICE
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILDING CO
H SITE DELIVERY
455 SAINT JOHNS DRIVE I 1003 GREG'S ROAD
CAMP HILL PA 17011-1330 P HARRISBURG PA 17011-1330
MISC: DKKJ
INVOICE NO.
356579
INVOICE DATE
02-01-07
CUSTOMER/WHITE
ACCOUNT # SHIP DATE ' 'SHIP VIA PAGE
BIN025 01-31-07 DELIVERY 6
REFERENCE FREIGHT TERM _ MESSAGE
CALL AL 379-9080
OUTSIDE SALESMAN I NSIDE SALESMAN' PURCHASE ORDER
YOUR LOCAL BRANCH MANAGER MAUREEN LIVESAY KEHLER
QUANTITY
ORDERED SNIFFED
"" -
UOM
DESCRIPTION
QUANTITY
UOM
PRICE
DISCOUNT
EXT
1 1 FUEL 1 5.000 5.00
L5°s Handling Charge On All Returns
- > FUEL SURCHARGE ON ALL DELIVERIES AS OF 5-3-04 <
PA'? TERMS* C.O.D. DUE DATE, APR1t t5, 2007
TOTAL: $ 10,000.00
=KOHL
BUILDING PRODUCTS
KOHL BU? NG PRODUCTS REMIT TO:
860 WESLL, DRIVE PO BOX 510843
MECHANICSBURG, PA 17055 PHILADELPHIA, PA 19175-084
INVOICE
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILD CO *S
H
455 SAINT JOHNS DRIVE I 455 SAINT JOHNS DRIVE
CAMP HILL PA 17011-1330 P CAMP HILL PA 17011-1330
INVOICE NO. I
359988
INVOICE DATE
02-19-07
CUSTOMER WHITE
ACCOUNT # SHIP DATE SHIP VIA PAGE
BIN025 02-16-07 PRIORITY PU 1
REFERENCE FREIGHT TERM MESSAGE
717-975-2367
OUTSIDE SALESMAN I NSIDE SALESMAN PURC14ASE ORDER
YOUR LOCAL BRANCH MANAGER MAUREEN LIVESAY KEHLR
QUANTITY
RDE 0 RED SHtPPEO UOM DESCRIPTION QUANTITY UOM PRICE DISCOUNT EXT
5
1
l,H1VLL?Lli1ri-1 l:?it31NC:1KY -
FINISH: BURNISHED NUTMEG ACCENT CHERRY
PO#: 308511 ACKNOWLEDGEMENT: 76834
ALL ITEMS NON STOCK / NOT RETURNABLE
5 EACH N000020280 WF0642 5 EACH
WALL FILLER 6 X 42
CANDLELIGHT BURNISHED NUTMEG ACCENT CHER
1 EACH NC00020281 FS1296 P EACH 175.200
FURNITURE SHELF 12 X 96
CANDLELIGHT BURNISHED NUTMEG ACCENT CHER
1 EACH N000020282 STAIN 1 EACH 21.290
QUART OF BURNISHED STAIN
SUB-TOTAL
696 PA SALES TAX 25-1891170
L5% Handling Charge On All Returns
FUEL SURCHARGE ON ALL DELIVERIES AS OF 5-3-04 <--
PAY TERMS: 1% 30 DAYS, NET 31 DAYS DUE DATE: APRIL 22, 2007
YOU MAY DEDUCT $1.96 IF PAID ON OR BEFORE MARCH 21. 2007
N/C
175.20
21.29
196.49
11.79
TOTAL: $ 208.28
- KOHL BU' NG PRODUCTS REMIT TO:
860 WESLL, DRI VE PO BOX 510843
KOHL MECHANICSBURG, PA 17055 PHILADELPHIA. PA 19175-0843
BUILDING PRODUCTS CREDIT MEMO
BINGAM & LAZAR BUILD CO *S S BINGAM & LAZAR BUILD CO *S
H
455 SAINT JOHNS DRIVE I 455 SAINT JOHNS DRIVE
CAMP HILL PA 1 7011-1330 P CAMP HILL PA 17011-1330
CREDIT MEMO NO.
355203
CREDIT MEMO DATE
12-14-06
ACCOUNT # SHIP DATE IRAN' SALE TYPE PAGE
BIN025 12-11-06 355203 05 1
REFERENCE MESSAGE
347600 717-975-2367 CASH ACCT
OUTSIDE SALESMAN I NSIDE SALESMAN PURCHASE ORDER
YOUR LOCAL BRANCH MANAGER DENNIS KISSINGER SINGER
QUANTITY
I
UOM
ORIG.
INV #
I
DESCRIPTION
_
TOTAL UNITS
UOM
PRICE
EXTENDED
2- EA 347600 MA14RT176
14X22 ROUND-TOP LOUVER; LIGHT MAPLE
SUB-TOTAL
616 PA SALES TAX 25-1891170
TOTAL 2-EA 36.770 73.54-
73.54-
4.41-
77.95
TOTAL: $ 77.95-
n N
h
#k o
o _ ? ` a n'r?
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-06080 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KOHL ROOFING & SIDING CO ETC
VS
BINGAMAN-LAZAR BUILDING CO
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
BINGAMAN-LAZAR BUILDING COMPANY LLC the
DEFENDANT
at 1842:00 HOURS, on the 5th day of November , 2007
at 455 SAINT JOHNS DRIVE
CAMP HILL, PA 17011 by handing to
ALFRED LAZAR, OWNER
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
Postage
Surcharge
'alf3? CO
Sworn and Subscibed to
before me this day
of
18.00
14.40
.75
10.00
So Answers:
P
R. Thomas Kline
11/06/2007
SILVERMAN & ASSOCIATES
By:
A. D.
t,7 5Ud r i
1.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-06080 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KOHL ROOFING & SIDING CO ETC
VS
BINGAMAN-LAZAR BUILDING CO
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
LAZAR ALFRED the
DEFENDANT at 1842:00 HOURS, on the 5th day of November , 2007
at 455 SAINT JORN.q T)RTUR
CAMP HILL, PA 17011 by handing to
ALFRED LAZAR
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
p?
Sworn and Subscibed to
before me this
of
So Answers:
6.00
.00
.00
10.00
R. Thomas Kline
11/06/2007
SILVERMAN - ' SSOCT- ---
By:
day
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-06080 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KOHL ROOFING & SIDING CO ETC
VS
BINGAMAN-LAZAR BUILDING CO
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
BINGAMAN LAWRENCE the
DEFENDANT at 1842:00 HOURS, on the 5th day of November , 2007
at 455 SAINT JOHNS DRIVE
CAMP HILL, PA 17011 by handing to
ALFRED LAZAR
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 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
la'?_ (off 16.00
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
11/06/2007
SILVERMAN & ASSOCIATES
By:
A. D.
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
1047 Old Bernville Road
Reading, Pennsylvania 19605
Plaintiff,
vs.
Civil No: 2007-6080
BINGAMAN-LAZAR BUILDING COMPANY, LLC :
and
ALFRED LAZAR
and
LAWRENCE BINGAMAN
Defendants.
Notice of Praeciae to Enter Judgment by Default
To: Bingaman-Lazar Building Company, LLC
Date of Notice: February 6th, 2008
IMPORTANT NOTICE
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 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:
Court Administrator, Cumberland County
1 Courthouse Square
Carlisle, PA 17013
717-240-6200
Respectfully submitted,
SILVERMAN & ASSOCIATES, CHTD.
Ua .'Silverman #44089
1120 Rockville Pike, Suite 300
North Bethesda, Maryland 20852
(301) 468-4990
Attorney for Plaintiff
CERTIFICATE OF SERVICE
hiw)
I HEREBY CERTIFY that on this _ day ot4a
2008, a copy of the Notice
of Praecipe to Enter Judgment by Default to the Prothonotary of the Court was sent via first class
mail to:
Bingman-Lazar Building Company, LLC
455 Saint John's Drive
Camp Hill, PA 17011
ATY . Silverman #44089
N
o
C7
ct
G coc?+-
-n
°TS i ?' 1 f't1
C^i. ? ? ?j'Tl
f
,ie
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
1047 Old Bernville Road
Reading, Pennsylvania 19605
Plaintiff,
vs.
BINGAMAN-LAZAR BUILDING COMPANY, LLC :
and
ALFRED LAZAR
and
LAWRENCE BINGAMAN
Defendants.
Civil No: 2007-6080
Notice of Praecine to Enter Judgment by Default
To: Alfred Lazar
Date of Notice: February 6th, 2008
IMPORTANT NOTICE
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 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:
Court Administrator, Cumberland County
1 Courthouse Square
Carlisle, PA 17013
717-240-6200
r,
<.
Respectfully submitted,
SILVERMAN & ASSOCIATES, CHID.
Gar
.?Strman #44089
11200 Rockville Pike, Suite 300
North Bethesda, Maryland 20852
(301) 468-4990
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this p 1. day o bN
of Praecipe to Enter Judgment by Default to theme-Prothonotary of the Court a copy of the Notice
mail to: was sent via first class
Alfred Lazar
455 Saint John's Drive
Camp Hill, PA 17011
. Silverman 4#44089
?: co
I I
h
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
1047 Old Bernville Road
Reading, Pennsylvania 19605
Plaintiff,
I vs.
BINGAMAN-LAZAR BUILDING COMPANY, LLC
and
ALFRED LAZAR
and
LAWRENCE BINGAMAN
Defendants.
Civil No: 2007-6080
Notice of Praecipe to Enter Judgment by Default
To: Lawrence Bingaman
Date of Notice: February 6th, 2008
IMPORTANT NOTICE
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 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:
Court Administrator, Cumberland County
1 Courthouse Square
Carlisle, PA 17013
717-240-6200
Respectfully submitted,
SILVERMAN & ASSOCIATES, CHTD.
Gary rman #44089
11200 4kville Pike, Suite 300
North Bethesda, Maryland 20852
(301) 468-4990
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this ft?Nwaj
of Praecipe to Enter Judgment by Default to the day o? 2008, a copy of the Notice
mail to: Prothonotary of the Court was sent via first class
Lawrence Bingaman
455 Saint John's Drive
Camp Hill, PA 17011
verman #44089
31
• i i+
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
1047 Old Bernville Road
Reading, Pennsylvania 19605 :
Plaintiff,
VS.
Civil No: 2007-6080
BINGAMAN-LAZAR BUILDING COMPANY, VLC
and
ALFRED LAZAR
and
LAWRENCE BINGAMAN
Defendants.
Praecipe to Enter Judgment by Default
To: Prothonotary of the Court
Please note that plaintiff requests judgment by default, pursuant to Pa. R.C.P. 237. 1, on
the defendant, Bingman-Lazar Building Company, LLC, upon the expiration from 10 days of the
dais of notice herein.
The Plaintiff requests that the judgment by default be entered for the sums due per the
complaint originally filed in this case, minus payments made since the case filing date, as
follows:
(a) principal in the amount of $3,198.60;
(b) accumulated interest through January 29. 2008 in the amount of $83.60;
(c) interest from January 29, 2008 through the date of judgment at the contractual rate
of 1.5% per month;
(d) attorney's fees in the amount of $1,656.88; and
(b) costs of this action.
WHEREFORE, the Plaintiff requests that the judgment by default be entered in the
amounts as set forth above, totaling $4,939.08, per the original complaint filed minus payments
made by the Defendant since the date of filing.
Respectfully submitted,
SILN'EIf& ASSOCIATES, CHTD.
Crary k. zf iverman
11200 ockville Pike
Suite 300
N. Bethesda, Maryland 20852
(301) 468-4990
Counsel for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day of , 2008, a copy of the
Praecipe to the Prothonotary of the Court was sent via first class mail to
Bingman-Lazar Building Company, LLC
455 Saint John's Drive
Camp Hill, PA 17011
0 00
r :
oh o ? ?,
o
Plaintiff
IN THE COURT OF COMMON PLEAS
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - &1q'kSiNnt NO.
To Defendant(s)
You are hereby notified that on
the following (Order) (Decree)
(Judgment) has been entered against you in the above captioned case.
DATE: I b &A
Prothonotary
I hereby certify that the name and address of the proper person(s) to receive this notice is:
A Defendido/a
Defendidos/as
Por este medio se le esta notificando que el
de del . el/la siguiente (Orden) (Decreto)
(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FE CHA:
Prothonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el
certificado de residencia:
Abogado del Demandante
DCBA - 400 - Rule 236 (a) (2) - 8 / 1 / 99 Proth. - 78
?. S
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC. :
1047 Old Bernville Road
Reading, Pennsylvania 19605
Plaintiff,
VS. ;
BINGAMAN-LAZAR BUILDING COMPANY, LLC
and
ALFRED LAZAR
and
LAWRENCE BINGAMAN
Defendants.
Civil No: 2007-6080
Praecine to Enter Judgment by Default
To: Prothonotary of the Court
Please note that plaintiff requests judgment by default, pursuant to Pa. R.C.P. 237.1, on
the defendant, Lawrence Bingaman, upon the expiration from 10 days of the date of notice
herein.
The Plaintiff requests that the judgment by default be entered for the sums due per the
complaint originally filed in this case, minus payments made since the case filing date, as
follows:
(i) principal in the amount of $3,198.60;
0) accumulated interest through January 29, 2008 in the amount of $83.60;
(k) interest from January 29, 2008 through the date of judgment at the contractual rate
of 1.5% per month;
(1) attorney's fees in the amount of $1,656.88; and
(b) costs of this action.
WHEREFORE, the Plaintiff requests that the judgment by default be entered in the
Iamounts as set forth above, totaling $4,939.08, per the original complaint filed minus payments
by the Defendant since the date of filing.
Respectfully submitted,
SILV RMA & CIATES, I
HTD
Counsel for Plaintiff
Gary rman
11200 ckville Pike
Suite 300
N. Bethesda, Maryland 20852
(301) 468-4990
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this c` \% day of 2008, a copy of the
Praecipe to the Prothonotary of the Court was sent via first class mail to:
Lawrence Bingaman
455 Saint John's Drive
Camp Bill, PA 17011
- L- . ilverman
.sue -? F
? _
?"
m :"?
?•
7y
Q (3
.?'.,.a a
?iZ ??
c ? v , ,{,+
? a ,.
?.:.; .?
wx -6
?
Plaintiff
IN THE COURT OF COMMON PLEAS
CaYt COUNTY, PENNSYLVANIA
Vs.
w CIVIL ACTION -
Defendant NO.
To , Defendant(s)
You are hereby notified that on
the following (Order) (Decree)
(Judgment) has been entered against you in the above cap Toned case.
DATE:
Prothonotary
I hereby certify that the name and address of the proper person(s) to receive this notice is:
t? Defendido/a
Defendidos/as
Por este medio se le esta notificando que el
dle del el/la siguiente (Order-) (Decreto)
(Fallo) ha sido anotado en contra suya en el caso mencionado en e1 epigrafe.
FECHA:
Prothonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el
certificado de residencia:
Abogado del Demandante
DCBA - 400 - Rule 236 (a) (2) - 8 / 1 / 99 Proth. - 78
4
•r
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
1047 Old Bernville Road
Reading, Pennsylvania 19605
Plaintiff, ;
VS. Civil No: 2007-6080
BINGAMAN-LAZAR BUILDING COMPANY, LLC
and
ALFRED LAZAR
and
LAWRENCE BINGAMAN
Defendants.
Praecive to Enter Judgment by Default
To: Prothonotary of the Court
Please note that plaintiff requests judgment by default, pursuant to Pa. R.C.P. 237.1, on
the defendant, Alfred Lazar, upon the expiration from 10 days of the date of notice herein.
The Plaintiff requests that the judgment by default be entered for the sums due per the
complaint originally filed in this case, minus payments made since the case filing date, as
follows:
(e) principal in the amount of $3,198.60;
(f) accumulated interest through January 29, 2008 in the amount of $83.60;
(g) interest from January 29, 2008 through the date of judgment at the contractual rate
of 1.5% per month;
(h) attorney's fees in the amount of $1,656.88; and
(b) costs of this action.
WHEREFORE, the Plaintiff requests that the judgment by default be entered in the
I amounts as set forth above, totaling $4,939.08, per the original complaint filed minus payments
I made by the Defendant since the date of filing.
Respectfully submitted,
SIL
IATES, CHTD.
112001ockville Pike
Suite 300
N. Bethesda, Maryland 20852
(301) 468-4990
Counsel for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this d l'4 day of , 2008, a copy of the
Praecipe to the Prothonotary of the Court was sent via first class mail to:
Alfred Lazar
455 Saint John's Drive
Camp Hill, PA 17011
S. Silverman
-97
p
V
J
4v
?
=!
?` lr
???? 1 ?,;? Q1UQ?J
Plaintiff
IN THE COURT OF COMMON PLEAS
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION
Defendant NO. ?J
To ???'? , Defendant(s)
You are hereby notified that on
the following (Order) (Decree)
(Judgment) has been entered against you in the above caiptioned case.
DATE: / o
]l hereby certify that the name and, address of the proper person(s) to receive this notice is:
A
Defendido/a
Defendidos/as
Por este medio se le esta notificando que el
ale del . el/la siguiente (Orden) (Decreto)
(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Prothonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el
certificado de residencia:
Abogado del Demandante
DCBA - 400 - Rule 236 (a) (2) - 8 / 1 / 99 Proth. - 78
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
KOHL ROOFING & SIDING CO. t/a KOHL
BUILDING PRODUCTS INC.
Plaintiff,
VS. Civil No: 2007-06080
BINGAMAN-LAZAR BUILDING COMPANY,
LLC
and
ALFRED LAZAR
and
LAWRENCE BINGAMAN
Defendants.
PRAECIPE TO SATISFY
To The Prothonotary:
Please mark the judgment in the above-captioned case as satisfied on July 11, 2008.
Respectfull Submitted,
SILVE ASSOCIATES, CHTD.
GARY4-51LVERMAN
11200 Rockville Pike
Suite 300
N. Bethesda, MD 20852
301-468-4990
CERTIFICATE OF SERVICE
I hereby certify that on this
mailed postage prepaid to:
Bingaman-Lazar Building Co., LLC
Alfred J. Lazar
445 Saint Johns Drive
Camp Hill, PA 17011
and
Lawrence A. Bingaman
PO Box 38
Gratz, PA 17030
day of July 2008 a copy of the foregoing praecipe was
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