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Home My WebLink About08-2718 Carlisle Cement Products, Inc., VS. Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. - a718 CIVIL ACTION 0, ivil - -(exm : JURY TRIAL DEMANDED NOTICE TO DEFEND 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. Pennsylvania Lawyer Referral Service 100 South Street Harrisburg, PA 17108-0186 (800) 692-7375 Carlisle Cement Products, Inc., VS. Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. df- .2717 CIVIL ACTION JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Carlisle Cement Products, Inc., by and through its counsel, Melissa K. Dively, Esquire of the law firm of SALZMANN HUGHES, P.C., and respectfully represents as follows in support of this Complaint: 1. Plaintiff is Carlisle Cement Products, Inc., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its registered office at 510 East North Street, Carlisle, Pennsylvania (hereinafter referred to as "Plaintiff'). 2. Defendant is Daniel Ward d/b/a, Ward Masonry Contracting & the Chimney Doctors, Inc., located at 1565 New Valley Road, Marysville, Pennsylvania, (hereinafter referred to as "Defendant") 3. Plaintiff operates a business which supplies cement and masonry related products to retailers, contractors, and consumers. 4. Defendant requested that Plaintiff extend credit to Defendant to accommodate the Defendant's purchase for Plaintiff's products. 5. Plaintiff granted Defendant's request for credit and established a credit account for Defendant. 6. From approximately October 2005 to approximately March 2007, Defendant requested that Plaintiff supply the Defendant with products, the cost of which was billed to Defendant's credit account. 7. The products were delivered in the quantities and for the prices set forth on invoices provided to the Defendant. (A copy of sales invoice provided to the Defendant is attached hereto and incorporated herein as Exhibit "A") 8. Invoices were provided to Defendant upon delivery of products and a summary of the charges were included in a billing statement. 9. Defendant received and continues to receive monthly billing statements reflecting the invoiced amounts. (A copy of one of Defendant's monthly billing statement reflecting the overdue balance is attached hereto as Exhibit "B" and incorporated herein by reference.) 10. The prices that Plaintiff charged Defendant for its products are fair, reasonable market prices and they are the prices which Defendant agreed to pay. 11. The balance due and owing on the account of the Defendant as reflected in Exhibit "C" is the sum of Eight Thousand Two Hundred Seventy Six Dollars and Eighty Six Cents ($8,276.86). 12. Although demand has been made, Defendant has failed to make payment of the amount due and owing. 14. Defendant has at no time disputed the amount due or made a claim to Plaintiff that the products that the Plaintiff provided were in any way unacceptable. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant in the amount of Eight Thousand, Two Hundred Seventy Six Dollars and Eighty-Six Cents ($8,276.86) plus interest, attorney fees as allowed by law and costs of this action. Date: Respectfully submitted, SALZMANN HUGHES, P.C. By. e ' y, Esquire Attorney ID# 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff VERIFICATION I verify that all the statements merle in the foregoing Complaint are true and connect to the best of my lmowledge, information and belief and that any false statements made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Hate: 2 o By: Its: ?o??? Or r? (i ?I v?1 r EXHIBIT A Carlisle Cement Products, Inc. PO Box 617 Carlisle, PA 17013-0617 717-243-5323 Bill To: WARD MASONRY CONTRACTOR, DAN WARD 1550 VALLEY ROAD MARYSVILLE, PA 17053 (717)957-2598 Reference: Comment: COOPER Transaction #: Account #: Page: Date: Time: Cashier: Register M Sales Receipt 12508 1572 1 of 1 9/12/2005 8:58:52 AM DON 4 Ship To: WARD MASONRY CONTRACTOR, DAN WARD 1550 VALLEY ROAD MARYSVILLE, PA 17053 (717)957-2598 Rep Item Lookup Code Description Quantity Price Extended YOR420019 LINTELS 4" 4X8X56 LINTEL 11 $10.00 $110.00 CCP000093 12 STD 12X8X16 216 $1.04 $224.64 CCP000072 12 45 DEGREE CNR 12 $3.08 $36.96 CCP000057 08 STD 8X8X16 230 $0.79 $181.70 CCP000029 08 45` CNR 8X8X16 4 $2.57 $10.28 CCP000017 04X6X16 SOL 4X6X16 50 $0.64 $32.00 LEH220025 PORTLAND TYPE 1-11 LEHIGH 6 $7.45 $44.70 GRA160001 LIME 3 $6.00 $18.00 Thank you for shopping Sub Total $658.28 Carlisle Cement Products, Inc. Sales Tax $39.50 Please come again! CCP Fuel Surcharge $9.87 Total $707.65 Store Account $707.65 Previous Balance $5,829.69 New Balance $6,537.34 Change Due $0.00 EXHIBIT B C'/ .' arlisle Cement Products, In ) Box 617 Aisle, PA 17013-0617 17-243-5323 V,'ARD MASONRY CONTRACTOR, DAN WARD/ON HOL 1:- 50 VALLEY ROAD ^IRYSVILLE, PA 17053 Pleas, Ac f-- Accol,; Ne _Ac Date -3l2r Account Statement Account Number: 1572 Due Date: Net 30 Balance: $8,276.86 Minimum Payment: $0.00 Amount Enclosed: 1111111 (IIII 11111 Iilll IIII IIII onclo<- lop portion with payment. --- --------------- _- i. _ ,-n m a ry at;or, 1572 Closing Date: 3/25/2007 Due Date: Net 30 WARD MASONRY CONTRAC 1550 VALLEY ROAD MARYSVILLE, PA 17053 _ 1 -:Ju.uays 31 - du ua. $111.65 T $113.72 Previous Balance: New Charges: Credits / Payments: ------------------- ------------------- New Balance: $8,168.0° $108.81 $0.0C ------------------- ------------------- $8,276.8E ys Balance Due 34- - --- - - ___$8,276.86 - -- Activity Charges - - --Credits -urge -- Finance Charge #25202 $108.81 Acc- : 1 ` - 2 Page 1 of 1 °P° 0) O o Oo 'D $b J p ^- r a -TI `L - ir Ti ? N -C t1 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-02718 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CARLISLE CEMENT PRODUCTS INC VS WARD DANIEL M D/B/A WARD MASON 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 to wit: WARD DANIEL M DBA WARD MASONRY CONTRACTING & CHIMNEY DOCTORS but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On May 14th , 2008 this office was in receipt of the attached return from PERRY / Sheriff's Costs: So erg'- Docketing 18.00 Out of County 9.00 f Surcharge 10.00 T omas Kline Dep Perry County 100.00 "`She iff of Cumberland County Postage 1.56 13 8 . 5 6 ?/?/? .? 05/14/2008 SALZMANN HUGHES Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Carlisle Cment Products Inc vs. Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors Inc No. 08-2718 civil April 29, 2008 Now, , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.. ,//?• Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, May 9, .20 0 6 , at 7 :15 o'clock P M. served the within Notice & Complaint upon Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc. at 1196 VAlley Rd. Marysville, Pa. 17053 ( Rye (Twp) by handing to Daniel M. Ward, Def. &Owner a True & Attested and made known to Him Sworn and subscribed before me this ' t-/ day of 20 MARGARET FLICKINGER. Notary pubis Bloomfield Boro. P" County ?Y Commission EY fires Feb.18,=2 the contents thereof. So answers, Aaron D. Richards Deputy Sheriff of Perry County, PA copy of the original Notice&Complaint COSTS SERVICE _ MILEAGE _ AFFIDAVIT Carlisle Cement Products, Inc., VS. Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc, Plaintiff Defendant TO: Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc. 1196 Valley Road Marysville, PA 17053 DATE OF NOTICE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 08-2718 : CIVIL ACTION : JURY TRIAL DEMANDED IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALITY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS OT 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PFIRSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Laywer Referral Service 100 South Street Harrisburg, PA 17108-1086 (800) 692-7375 Respectfully submitted, SALZMANN HUGHES, P.C. ?vely, Esquire ID# 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on the '?* day of July 2008, I served a true and correct copy of the foregoing document via United States mail, first class mail, postage prepaid, and addressed as follows: Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc. 1196 Valley Road Marysville, PA 17053 ?w N q l? ?T5 W_ Carlisle Cement Products, Inc., Plaintiff vs. Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-2718 : CIVIL ACTION JURY TRIAL DEMANDED PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Please enter judgment by default against the above named Defendant Daniel M. Ward, d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc. in the amount of Eight Thousand, Two Hundred Seventy Six Dollars and Eighty-Six Cents ($8,276.86) plus interests and costs. Date: ?? F Respectfully submitted, SALZMANN HUGHES, P.C. 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff r IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products, Inc., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 08-2718 Daniel M. Ward d/b/a : CIVIL ACTION Ward Masonry Contracting & The Chimney Doctors, Inc, Defendant JURY TRIAL DEMANDED AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA : COUNTY OF FRANKLIN § § I, Melissa K. Dively, Esquire, of the law offices of Salzmann Hughes, P.C., 79 St. Paul Drive, Chambersburg, Pennsylvania, do hereby swear and affirm that on July 9, 2008 I did mail a copy of the attached Notice by United States Mail, postage prepaid to Daniel M. Ward d/b/a Ward Masonry Contracting & the Chimney Doctors, Inc. 1196 Valley Road, Marysville, PA 17053 Salzmann Hughes, P.C. Sworn to and subscribed to before me, this 6"*1 day of 2008. u Pu By: Mel' Dive , Esqu' COMMONWEALTH OF PENNSYLVANIA Notarial Seal Emily C. Myers, Notary Public Chambersb n Boro, FrarMn Courtly My Comrnissiort E)ires Der. 19, 2011 Member, Pennsylvania Association of Notaries 4j t -- Carlisle Cement Products, Inc., VS. Plaintiff Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc, Defendant TO: Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc. 1196 Valley Road Marysville, PA 17053 DATE OF NOTICE: o> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-2718 CIVIL ACTION JURY TRIAL DEMANDFtbe 2 , 6, 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 OT 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. I Pennsylvania Laywer Referral Service 100 South Street Harrisburg, PA 17108-1086 (800) 692-7375 Respectfully submitted, SALZMANN HUGHES, P.C. Melissa ively, Esquire Att y ID# 36780 9 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on the C, day of July 2008, I served a true and correct copy of the foregoing document via United States mail, first class mail, postage prepaid, and addressed as follows: Danie' M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc. 1196 Valley Road Marysville, PA 17053 -ff+- oho T? :.. O T1 <i co < J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION CARLISLE CEMENT PRODUCTS, INC. Plaintiff _ Confessed Judgment X Other V. DANIEL M. WARD d/b/a WARD MASONRY CONTRACTING & THE CHIMNEY DOCTORS, INC. Defendants File No. 08-2718 Amount Due $8,276.86 Interest Atty's Comm $ Costs $ TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Perry County, for debt, interest and costs, upon the following described property of the defendant(s): Any and all personal property located at 1196 Valley Road, Marysville, Perry County, Pennsylvania 17053. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Perry County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) N/A and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). X Index this writ against the defendants, Daniel M. Ward, d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc.. Date SALZMANN HUGHES, P.C. d eliss a y, Esquire Attorney ID# 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff 1 o$ x Y ilk, ``'?., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CARLISLE CEMENT PRODUCTS, INC., Plaintiff VS. No. 08-2718 DANIEL M. WARD DB/A WARD MASONRY CONTRACTING & THE CHIMNEY DOCTORS, INC, Defendant WRIT OF EXECUTION - NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken. Such property is said to be . exempt. There is a debtor's exemption of $300.00. There are other exemptions, which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following: (a) Fill out the claim form and demand a prompt hearing. (b) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to the court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. This and any future communication from our debt collection firm are attempts to collect a debt and information obtained will be used for that purpose. 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 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 Y . . ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CARLISLE CEMENT PRODUCTS, INC., Plaintiff VS. No. 08-2718 DANIEL M. WARD DB/A WARD MASONRY CONTRACTING & THE CHIMNEY DOCTORS, INC, Defendant MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW (1) $300.00 statutory exemption (2) Bibles, school books, sewing machines, uniforms and equipment (3) Most wages and unemployment compensation (4) Social Security benefits (5) Certain retirement funds and accounts (6) Certain veteran and armed forces benefits (7) Certain insurance proceeds (8) Such other exemptions as may be provided by law CLAIM FOR EXEMPTION TO THE SHERIFF: 1. The above-named defendant claims exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon: (a) I desire that my $300.00 statutory exemption be: [ ] I. Set aside in kind (specify property to be set aside in kind): [ ] II. Paid in cash following the sale of the property levied upon; or [ ] III. I claim the following exemption (specify property and basis of exemption): (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) My $300.00 statutory exemption: [ ] in cash; [ ] in kind (specify property): (b) Social Security benefits on deposit in the amount of. $ (c) Other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at: Address Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: Defendant: THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-2718 Civil CIVIL ACTION - LAW TO THE SHERIFF OF PER2y COUNTY: To satisfy the debt, interest and costs due CARLISLE CEMENT PRODUCTS, INC., Plaintiff (s) From DANIEL M. WARD d/b/a WARD MASONRY CONTRACTING & THE CHIMNEY DOCTORS, INC., 11% Valley Road, Marysville, PA 17053 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all property located at 1196 Valley Road, Marysville, PA 17053. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $8,276.86 Interest Atty's Comm % Atty Paid $257.56 Plaintiff Paid Date: 9/03/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs iv.Li.- P . R. Long, Prothonotan By: Deputy REQUESTING PARTY: Name MELISSA K. DIVELY, ESQUIRE Address: SALZMANN HUGHES, P.C. 79 ST. PAUL DRIVE CHAMBERSBURG, PA 17201 Attorney for: PLAINTIFF Telephone: 717-263-2121 Supreme Court ID No. 36780 M % IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products, Inc., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. 08-2718 Daniel M. Ward d/b/a CIVIL ACTION Ward Masonry Contracting & The Chimney Doctors, Inc, Defendant JURY TRIAL DEMANDED PRAECIPE TO SATISFY JUDGMENT Please mark the above-captioned matter settled, satisfied and discontinued against Defendant Daniel M. Ward d/b/a Ward Masonry & the Chimney Doctors, Inc. in the above referenced matter. Respectfully submitted, SALZMANN HUGHES, P.C. F Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff It - %b CERTIFICATE OF SERVICE I hereby certify that on the &=-- day of October 2008, I served a true and correct copy of the foregoing document via United States mail, first class mail, postage prepaid, and addressed as follows: Daniel M. Ward d/b/a Ward Masonry Contracting & The Chimney Doctors, Inc. 1196 Valley Road Marysville, PA 17053 Salzmann Hughes, P.C. By. Melissa v y, Esquire dd? o0 O hY, r- C () 4M 1. 3 t