HomeMy WebLinkAbout08-2719q
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
. No. D'S - 61119
: CIVIL ACTION
0;?.
Defendant : JURY TRIAL DEMANDED
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the
Carlisle Cement Products, Inc.,
vs.
Bryan Rhinesmeith d/b/a
Rhinesmith Masonry,
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.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
No. OP- .2 7l 9 Gcvc l ??,..
Bryan Rhinesmeith d/b/a CIVIL ACTION
Rhinesmith Masonry,
Defendant 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 Bryan Rhinesmith d/b/a, Rhinesmith Masonry located at 1940 Landvarter
Road, Hummelstown, 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 July 2005 to approximately November 2005, 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 an invoice provided to the Defendant is attached hereto and
incorporated herein as Exhibit "A")
8. Said 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 "B"
is the sum of Nine Thousand, Six Hundred Thirty Five Dollars and Thirty Eight Cents ($9,635.38).
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 Nine Thousand, Six Hundred Thirty Five Dollars and Thirty-Eight Cents ($9,635.38) plus interest,
attorney fees as allowed by law and costs of this action.
Respectfully submitted,
SALZMANN HUGHES, P.C.
Date: ` Z
:Me}issra_K. Div squire
Attorney ID 0
79 St. Pa 've
Cham urg, PA 17201
(717) 263-2121
Counsel for Plaintiff
VERIFICATION
I verify that all the staWments made in the foregoing Complaint are true and correct to the best
of my knowledge, information and belief and that any false statements made are subject to the
penalties of 19 Pa.C.S. Section 4904 relating to unworn falsification to authorities
Date; Z 0 Y gy.
Its:
U- -14 (e wt r--( Ov-a t'u S
EXHIBIT
A
Carlisle Cement Products, Inc.
PO Box 617
Carlisle, PA 17013-0617
717-243-5323
Bill To: RHINESMITH MASONRY
BRYAN RHINESMITH
1940 LANDVARTER ROAD
HUMMELSTOWN, PA 17036
(717)805-4357
Transaction
Account #:
Page:
Date:
Time:
Cashier:
Register #:
'Sales Receipt
16386
1248
1 of 1
11/10/2005
1:41:02 PM
DON
4
Ship To: RHINESMITH MASONRY
BRYAN RHINESMITH
1940 LANDVARTER ROAD
HUMMELSTOWN, PA 17036
(717)805-4357
Rep Item Lookup Code Description
CCP000108 PALLET CCP RETURNED
Thank you for shopping
Carlisle Cement Products, Inc.
Please come again!
Quantity Price Extended
-20 $10.50 ($210.00)
Sub Total ($210.00)
Sales Tax $0.00
Total ($210.00)
Change Store Account $210.00
Previous Balance $7,930.61
New Balance $7,720.61
EXHIBIT
B
Carlisle Cement Products, In
PO Box 617
Carlisle, PA 17013-0617
717-243-5323
RHINESMITH MASONRY
BRYAN RHINESMITH
1940 LANDVARTER ROAD
HUMMELSTOWN, PA 17036
Account Statement
Account Number: 1248
Due Date: Net 30
Balance: $9,635.38
Minimum Payment: $0.00
Amount Enclosed:
1111111 II
i II Ilii
fll
fl III
I III
I
Please detach and enclose top portion with payment.
Account Summary
Summa Inry Information
Account Number: 1248 Closing Date:
Name: Due Date:
RHINESMITH MASONRY
BRYAN RHINESMITH
1940 LANDVARTER ROAD
3/25/2007
Net 30
HUMMELSTOWN, PA 17036 Previous Balance: $9,508.71
New Charges: $126.67
Credits / Payments: $0.00
New Balance:
$9,635.38
Current 1 - 30 Da s 31 60 Da s -
$401.23 -$129.98 $132 39?--?1$126_D31?--?0$8,845.,7 1 B-$9,6 35.38e
Account Activity s
Date Account Activity,
3/25/2007 Finance Charge -- Finance Charge #25239
$126.67
Account Number: 1248 Page 1 of 1
-60L
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-02719 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CARLISLE CEMENT PRODUCTS INC
VS
RHINESMITH BRYAN D/B/A RHINESM
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:
RHINESMITH BRYAN D/B/A RHINESMITH MASONRY
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On May 7th , 2008 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answers
Docketing 18.00 -%
Out of County 9.00
Surcharge 10.00 R. Thomas Kline
Dep Dauphin County 37.25 Sheriff of Cumberland County
Postage 1.55
7 5 . 8 0
05/07/2008
SALZMANN HUGHES
Sworn and subscribe to before me
this day of
A. D.
• ` i
In The Court of Common Pleas of Cumberland County, Pennsylvania
Carlisle Cement Products Inc
vs.
Bryan Rhinesmith d/b/a No. 08-2719 civil
Rhinesmith Masonry
Now, April 29 , 2008 , I. SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now, , 20 , at o'clock M. served the
within
upon
at
by handing to
a copy of the original
and made known to
Sworn and subscribed before
me this day of , 20
So answers,
the contents thereof.
Sheriff of
COSTS
SERVICE
MILEAGE _
AFFIDAVIT
County, PA
(pilitt of the'sherw
Mar Jane er
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
CARLISLE CEMENT PRODUCTS, INC.
VS
BRYAN RHINESMITH DB/A
RHINESMITH MASONRY
Sheriff s Return
No. 2008-T-0936
OTHER COUNTY NO. 08-2719
And now: MAY 5, 2008- at 9:22:00 AM served the within COMPLAINT upon BRYAN
RHINESMITH DB/A RHINESMITH MASONRY by personally handing to BRYAN RHINESMITH
DB/A RHINESMITH MASONRY 1 true attested copy of the original COMPLAINT and making
known to him/her the contents thereof at 1940 LADVARTER ROAD HUMMELSTOWN PA 17036
Sworn and subscribed to
before me this 5TH day of May, 2008
A7?
NOTARIAL SEAL
RY JANE SNYDER, Notary Publi
Hiire, Dauphin County
M Commission Expires Sept I 2010
So Answers,
Sheriff of Dauphin County, Pa.
By
Deputy Sheriff
Deputy: KIMBERLY BARTO
Sheriffs Costs: $37.25 5/1/2008
Carlisle Cement Products, Inc.,
VS.
Plaintiff
Bryan Rhinesmeith d/b/a
Rhinesmith Masonry,
Defendant
DATE OF NOTICE: -4// /0 2
TO: Bryan Rhinesmith
D/b/a Rhinesmith Masonry
1940 Ladvarter Road
Hummelstown, PA 17036
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 2008 -93W oZ?IQ
: CIVIL ACTION
JURY TRIAL DEMANDED
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
FOR FAILURE TO PLEAD
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.
Pennsylvania Laywer Referral Service
100 South Street
Harrisburg, PA 17108-1086
(800) 692-7375
Respectfully submitted,
SALZMANN HUGHES, P.C.
By
?.
Dively, Esquire
Attorney ID# 36780
79 St. Paul Drive
Chambersburg, PA 17201
(717) 263-2121
Counsel for Plaintiff
CERTIFICATE OF SERVICE
?99k
I hereby certify that on the -V-- day of August 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:
Bryan Rhinesmith
D/b/a Rhinesmith Masonry
1940 Ladvarter Road
Hummelstown, PA 17036
By
Salzmann Hughes, P.C.
?; .?
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c
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Carlisle Cement Products, Inc.,
VS.
Bryan Rhinesmeith d/b/a
Rhinesmith Masonry,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
01,719
No. 2008
: CIVIL ACTION
: JURY TRIAL DEMANDED
PRAECIPE TO ENTER JUDGMENT BY DEFAULT
TO THE PROTHONOTARY:
Please enter judgment by default against the above named Defendant Bryan Rhinesmith,
d/b/a Rhinesmith Masonry in the amount of Nine Thousand, Six Hundred Thirty Five Dollars and
Thirty Eight Cents ($9,635.38) plus interests and costs.
Date:
Respectfully submitted,
SALZMANN HUGHES, P.C.
By:
Melissa K. Dively, Esquire
Attorney ID# 36780
79 St. Paul Drive
Chambersburg, PA 17201
(717) 263-2121
Counsel for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that on thef"day of August 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:
Bryan Rhinesmith
D/b/a Rhinesmith Masonry
1940 Ladvarter Road
Hummelstown, PA 17036
Salzmann Hughes, P.C.
By:
elissa K. squire
Carlisle Cement Products, Inc.,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
VS.
Bryan Rhinesmeith d/b/a
Rhinesmith Masonry,
Defendant
DATE OF NOTICE:
TO: Bryan Rhinesmith
D/b/a Rhinesmith Masonry
1940 Ladvarter Road
Hummelstown, PA 17036
: No. 2008 936
: CIVIL ACTION
';
C J
JURY TRIAL DEMANDED ??--
ra
NOTICE OF PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
FOR FAILURE TO PLEAD
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.
Pennsylvania Laywer Referral Service
100 South Street
Harrisburg, PA 17108-1086
(800) 692-7375
Respectfully submitted,
SALZMANN HUGHES, P.C.
By -4
_A4efissI K. Dively, Esquire
Attorney ID# 36780
79 St. Paul Drive
Chambersburg, PA 17201
(717) 263-2121
Counsel for Plaintiff
O
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
CARLISLE CEMENT PRODUCTS, INC. _ Confessed Judgment
Plaintiff X Other
V. File No. 08-2719
Amount Due $9,635.38
BRYAN RHINESMITH, d/b/a Interest $
RHINESMITH MASONARY Atty's Comm $
Defendants 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 Dauphin County, for debt,
interest and costs, upon the following described property of the defendant(s):
AM and all personal property located at 1940 Ladvarter Road, Hummelstown, PA, Dauphin
County, Pennsylvania, 17036.
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Dauphin 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, Bryan Rhinesmith, d/b/a Rhinesmith Masonry.
Date c( /--),D JQP
SAL N U- HES, P.C.
ively, Esquire
Attorney ID# 36780
79 St. Paul Drive
Chambersburg, PA 17201
(717) 263-2121
Counsel for Plaintiff
C
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CARLISLE CEMENT PRODUCTS, INC. No: 2008-2719
Plaintiff
V.
CIVIL ACTION
BRYAN RHINESMITH, d/b/a
RHINESMITH MASONARY
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
"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CARLISLE CEMENT PRODUCTS, INC.
Plaintiff
V.
BRYAN RHINESMITH, d/b/a
RHINESMITH MASONARY
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:
[ J 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
[ 1 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: [ J in cash; [ J 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
No: 2008-2719
CIVIL ACTION
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 DAUPHIN COUNTY.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-2719 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF DAUPHIN COUNTY:
To satisfy the debt, interest and costs due Carlisle Cement Products, Inc. Plaintiff (s)
From Bryan Rhinesmith d/b/a Rhinesmith Masonary
(1) You are directed to levy upon the property of the defendant (s)and to sell Any and all personal
property located at 1940 Ladvarter Road, Hummelstown, PA, Dauphin County, Pennsylvania
17036.
(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 $9,635.38 L.L.$.50
Interest
Atty's Comm % Due Prothy $2.00
Atty Paid $194.80 Other Costs
Plaintiff Paid
Date: September 24, 2008
#s/ ILA le. .,&°!_
Curtis R. Long, Prothonotary,r
(Seal) By:
eputy
REQUESTING PARTY:
Name Melissa K. Dively, Esq.
Address: 79 St. Paul Drive
Chambersburg, PA 17201
Attorney for: Plaintiff
Telephone: (717) 263-2121
Supreme Court ID No. 36780
Carlisle Cement Products, Inc.,
vs.
Bryan Rhinesmeith d/b/a
Rhinesmith Masonry,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 2008 -=All (q
Plaintiff
Defendant
CIVIL ACTION
: JURY TRIAL DEMANDED
PRAECIPE TO REISSUE WRIT OF EXECUTION
TO THE PROTHONOTARY:
? cr 1
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C)
AND NOW, comes the Plaintiff, Carlisle Cement Products, Inc., by and through its counsel,
Melissa K. Dively, Esquire, of Salzmann Hughes, P.C., who praecipes the Prothonotary of
Cumberland County as follows:
1. A Praecipe for Writ of Execution was filed in the above referenced matter on September
4, in the Office of the Prothonotary of Cumberland County, Pennsylvania at the above docket
number.
2. The Writ of Execution was forwarded to the Dauphin County Sheriff for execution on or
about October 14, 2008 and docketed to 2008-CV-13409 by the Dauphin County
Prothonotary.
3. The parties attempted to negotiate a settlement but were unable to do so before the Writ of
Execution expired.
4. Pursuant to Pennsylvania Rules of Civil Procedure, Rule 3106 (d), a writ shall not be
served nor shall a levy or attachment be made thereunder after the expiration of mnV
A
days from the date of issuance or reissuance. $10-00 P'A A7W
P4d38t'Z
WHEREFORE, the Plaintiff, Carlisle Cement Products, Inc. respectfully requests the
Prothonotary to reissue the Writ in the above captioned action.
Respectfully submitted,
Date: 1-7 to _ By:
c.:
SALZMANN HUGHES, P.C.
Attorney ID# 36780
79 St. Paul Drive
Chambersburg, PA 17201
(717) 263-2121
Counsel for Plaintiff
REISSUED
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-2719 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF DAUPHIN COUNTY:
To satisfy the debt, interest and costs due Carlisle Cement Products, Inc. Plaintiff (s)
From Bryan Rhinesmith d/b/a Rhinesmith Masonary
(1) You are directed to levy upon the property of the defendant (s)and to sell Any and all personal
property located at 1940 Ladvarter Road, Hummelstown, PA, Dauphin County, Pennsylvania
17036.
(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 $9,63538
Interest
L.L.S.50
Atty's Comm %
A.tty Paid $194.80
Plaintiff Paid
Date; September 24, 2008
(Seal)
REQUESTING PARTY:
Name Melissa K. Dively, Esq.
Address: 79 St. Paul Drive
Chambersburg, PA 17201
-Attorney for: Plaintiff
Due Prothy $2.00
Other Costs
4111 4"
ct,t? "e. 0"
Gnu isis R. Long, Prothonotary
By:
6eputy
Telephone: (717) 263-2121
Supreme Court ID No. 36780
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Personal Property
FACE SHEET
File # Case Number Document Type
2008 -CV -13409 -NT WRIT OF
EXECUTION &
ATTACHMENTS
Bankruptcy Case Number
Received From: County
Date Received: 3/16/2010 Date Expires: 6/9/2010
PEOPLE ASSOCIATED WITH THE CASE
Primary Defendant(s)
Name: BRYAN RHINESMITH DOB:
Current Physical Address: 1940 LADVARTER ROAD HUMMELSTOWN, PA 17036
Defendant(s)
Name:
Address:
D/B/A RHINESMITH MASONARY DOB:
1940 LADVARTER ROAD HUMMELSTOWN, PA 17036
Primary Plaintiff(s)
Name: CARLISLE CEMENT PRODUCTS, INC. DOB:
Attorney: MELISSA K DIVELY
Attorney Phone: 717-263-2121
Attorney Address: 455 PHOENIX DRIVE SUITE A CHAMBERSBURG, PA 17201
PERSONAL PROPERTY INFORMATION
Monies Levied:
Date of Levy:
District Justice:
COMMENTS
AND NOW 3/17/2010
SENT LEVY OUT WITH DEPUTIES
Date of Sale:
AND NOW 3/23/2010
DEP GM COMPLETED LEVY
SENT COMPLETED LEVY SHEET TO ATTY
WRIT IN LEVY FILE
9/6/2011 RETURNED WRIT ABANDONMENT OF LEVY
SENT REFUND TO ATTY AND RETURNED WRIT
Cash Accounting
Amount
Date Added
Category
ID
$200.00
3/17/2010
Deposit Agency
356133
($20.00)
9/6/2011
State Fee
408843
($67.00)
9/6/2011
Sheriff Costs
408844
($1.34)
9/6/2011
Poundage
408845
($111.66)
9/6/2011
Refund to Atty/Pltf
408846
Total Number of Rows: 5
Balance Due: $0.00
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Qfice of the Sheriff
BRYAN RHINESMITH
D/B/A RHINESMITH MASONARY
1940 LADVARTER ROAD
HUMMELSTOWN, PA 17036
Dear MELISSA K. DIVELY, ESQ.
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
J.R. Lotwick
Sheriff
March 24, 2010
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
RE: WRIT OF EXECUTION NO. 2008 -CV -
13409
The above Writ of Execution was served on March 23, 2010, at which time a levy was made.
After 20 days from the above date and upon your request in writing, the property will be posted for sale.
If this writ is not returned SATISFIED, STAYED in this office, or a sale scheduled (at your request)
within 6 months from the date of service, this writ will be returned ABANDONED.
The Sheriffs cost as of today are $
THIS IS NOT A BILL
Siinncerreely,
J.R. Lotwick
Sheriff of Dauphin County
Carlisle Cement Products, Inc.,
vs.
Bryan Rhinesmith d/b/a
Rhinesmith Masonry,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: No. 2008 —2719
: CIVIL ACTION
: JURY TRIAL DEMANDED
PRAECIPE TO SATISFY JUDGMENT AND DISCONTINUE CASE
Please mark the above -captioned matter settled, satisfied and discontinued against Defendant
Bryan Rhinesmith d/b/a Rhinesmith Masonry in the above referenced matter.
B
Respectfully submitted,
rr
cr,
SALZMANN HUGHES, P.C.
C r
Wise squire
Attorney ID# 20 65
79 St. Paul Drive
Chambersburg, PA 17201
(717) 263-2121
Counsel for Plaintiff
crt
CERTIFICATE OF SERVICE
I hereby certify that on the day of April 2014, I served a true and correct copy of the
foregoing document via United States mail, first class mail, postage prepaid, and addressed as
follows:
Bryan Rhinesmith
D/b/a Rhinesmith Masonry
1940 Landvarter Road
Hummelstown, PA 17036
By:
Salzmann Hughes, P.C.