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HomeMy WebLinkAbout08-6183Carlisle Cement Products, Inc., VS. Plaintiff Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. b8 (x183 aivi l Term CIVIL ACTION 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 IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products, Inc., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. O F- 13 C -7Z- Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction Defendants CIVIL ACTION 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. Defendants are Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction, with an address of 150 Pine Knob Road, Newville, Pennsylvania, (hereinafter referred to as "Defendants"). 3. Plaintiff operates a business which supplies cement and masonry related products to retailers, contractors, and consumers. 4. Defendants requested that Plaintiff extend credit to Defendants to accommodate the Defendants' purchase for Plaintiff's products. 5. Plaintiff granted Defendants' request for credit and established a credit account for Defendants. 6. From approximately May 2006 to approximately March 2007, Defendants requested that Plaintiff supply the Defendants with products, the cost of which was billed to Defendants' credit account. 7. The products were delivered in the quantities and for the prices set forth on invoices provided to the Defendants. (A copy of an invoice provided to the Defendants is attached hereto and incorporated herein as Exhibit "A") 8. Said invoices were provided to Defendants upon delivery of products and a summary of the charges were included in a billing statement. 9. Defendants receive and continue to receive monthly billing statements reflecting the invoiced amounts. (A copy of one of Defendants monthly billing statement reflecting the overdue balance is attached hereto as Exhibit "B" and incorporated herein by reference.) 10. The prices that Plaintiff charged Defendants for its products are fair, reasonable market prices and they are the prices which Defendants agreed to pay. 11. The balance due and owing on the account of the Defendants as reflected in Exhibit "B" is the sum of Nine Thousand One Hundred Twenty-five Dollars and Thirty-three Cents ($9,125.33). 12. Although demand has been made, Defendants have failed to make payment of the amount due and owing. 14. Defendants have 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 Defendants in the amount of Nine Thousand One Hundred Twenty-five Dollars and Thirty-three Cents ($9,125.33) plus interest, attorney fees as allowed by law and costs of this action which amount is within the limits of the amount required for submission to arbitration pursuant to local court rules. Respectfully submitted, SALZMANN HUGHES, P.C. Date: BY: ive y, squire Attorney ID# 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff VERIFICATION I verify that all the statements 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 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: D Z?y By: Its: r/n5 icro Carlisle Cement Products, Inc. PO Box 617 Carlisle, PA 17013-0617 717-243-5323 Bill To: COUNTRY LANE CONSTRUCTION MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 717-776-4321 Reference: Comment: CHURCH Item Lookup Code Description TH0350007 SIKAFLEX ALUMINUM GRAY Invoice Transaction #: 40286 Account #: 327 Page: 3 of 3 Date: 3/1/2007 Time: 8:13:25 AM Cashier: DON Register #: 2 COUNTRY LANE CONSTRUCTION MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 717-776-4321 Quantity Price Extended 2 $4.25 $8.50 Thank you for shopping Carlisle Cement Products, Inc. Please come again! Ship To: Sub Total $8.50 Sales Tax $0.51 Total $9.01 Store Account $9.01 Change Due $0.00 • Carlisle Cement Products, In Account Statement PO Box 617 Carlisle, PA 17013-0617 Account Number: 327 717-243-5323 Due Date: Net 30 Balance: $9,125.33 Minimum Payment: $0.00 COUNTRY LANE CONSTRUCTION/ON HOLD Amount Enclosed: MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 Please detach and enclose top portion with payment. - -- - - ------------------------------------------------------- ---------- ---- ----------- - --- 11111 ------ --- -- ----------------------- ---- 11111111111 IN IN ---- - - Account Summary Summary. I n fbrmMorl- Account Number: 327 Closing Date: 5/25/2008 Name: Due Date: Net 30 COUNTRY LANE CONSTRUC MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 Previous Balance: New Charges: Credits / Payments: New Balance: - =? $380.36 1 $127.31 _ - I --.31$125.4 --' 61$119.--_67?_ _ ?--- Account Activi Gate _ 5/22/2008 Return -- Tram 5/25/2008 Finance Charg $9,006.77 $128.56 $10.00 ------------------- ------------------- $9,125.33 - - ce e- $9.125.33 es Credits coon #63056 $10.00 -- Finance Charge #37972 $128.56 - Account Number: 327 Page 1 of 1 I IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products, Inc., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. CIVIL ACTION Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction Defendants 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 : IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products, Inc., : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff VS. : No. Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction Defendants : CIVIL ACTION 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. Defendants are Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction, with an address of 150 Pine Knob Road, Newville, Pennsylvania, (hereinafter referred to as "Defendants"). 3. Plaintiff operates a business which supplies cement and masonry related products to retailers, contractors, and consumers. 4. Defendants requested that Plaintiff extend credit to Defendants to accommodate the Defendants' purchase for Plaintiff's products. 5. Plaintiff granted Defendants' request for credit and established a credit account for Defendants. 6. From approximately May 2006 to approximately March 2007, Defendants requested that Plaintiff supply the Defendants with products, the cost of which was billed to Defendants' credit account. 7. The products were delivered in the quantities and for the prices set forth on invoices provided to the Defendants. (A copy of an invoice provided to the Defendants is attached hereto and incorporated herein as Exhibit "A") 8. Said invoices were provided to Defendants upon delivery of products and a summary of the charges were included in a billing statement. 9. Defendants receive and continue to receive monthly billing statements reflecting the invoiced amounts. (A copy of one of Defendants monthly billing statement reflecting the overdue balance is attached hereto as Exhibit "B" and incorporated herein by reference.) 10. The prices that Plaintiff charged Defendants for its products are fair, reasonable market prices and they are the prices which Defendants agreed to pay. 11. The balance due and owing on the account of the Defendants as reflected in Exhibit "B" is the sum of Nine Thousand One Hundred Twenty-five Dollars and Thirty-three Cents ($9,125.33). 12. Although demand has been made, Defendants have failed to make payment of the amount due and owing. 14. Defendants have 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 Defendants in the amount of Nine Thousand One Hundred Twenty-five Dollars and Thirty-three Cents ($9,125.33) plus interest, attorney fees as allowed by law and costs of this action which amount is within the limits of the amount required for submission to arbitration pursuant to local court rules. Respectfully submitted, Date: f SALZMANN HUGHES, P.C. By: ive y, squire Attorney ID# 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff VERIFICATION I verify that all the statements 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 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: D Z?) By: i Its: • • 05 J Carlisle Cement Products, Inc. PO Box 617 Carlisle, PA 17013-0617 717-243-5323 Bill To: COUNTRY LANE CONSTRUCTION MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 717-776-4321 Reference: Comment: CHURCH Item LW ',` TH0350007 SIKAFLEX ALUMINUM GRAY Ship To: Invoice Transaction #: 40286 Account #: 327 Page: 3 of 3 Date: 3/1/2007 Time: 8:13:25 AM Cashier: DON Register M 2 COUNTRY LANE CONSTRUCTION MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 717-776-4321 PO Extended 2 $4.25 $8.50 Thank you for shopping Sub Total $8.50 Carlisle Cement Products, Inc. Sales Tax $0.51 Please come again! Total $9.01 Store Account $9.01 Change Due $0.00 I #_1 w Carlisle Cement Products, In PO Box 617 Carlisle, PA 17013-0617 717-243-5323 COUNTRY LANE CONSTRUCTION/ON HOLD MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 Please detach and enclose top portion with payment. --_ ----- -- __---------------------------------------------- Account Summary Account Statemer Account Number: 3 Due Date: Net Balance: $9,125. Minimum Payment: $0. Amount Enclosed: Account Number. 327 Closing Date: 5/25/20 Name: Due Date: Net COUNTRY LANE CONSTRUC MARTIN LICHTENBERGER 150 PINE KNOB ROAD NEWVILLE, PA 17241 Previous Balance: $9006. New Charges: Credits / Payments: New Balance: Account Activi $128. $10. $9,125. 1 5/22/2008 Return -- Transaction #63056 4 tl$10. 5/25/2008 Finance Charge -- Finance Charge #37972 $128.56 - Account Number: 327 Page 1 o K? ? 0? -- D VI ? C,.. N "te rrn 4 SHERIFF'S RETURN - REGULAR A, CASE NO: 2008-06183 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CARLISLE CEMENT PRODUCTS INC VS LICHTENBERGER MARTIN ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LICHTENBERGER MARTIN the DEFENDANT , at 1907:00 HOURS, on the 24th day of October , 2008 at 150 PINE KNOR RnAn NEWVILLE, PA 17241 by handing to MARTIN LICHTENBERGER 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 18.00 Service 16.00 Postage .59 Surcharge 10.00 "11040" L .59 4 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 10/29/2008 SALZMANN HUGHES By. Deputy S riff A. D. SHERIFF'S RETURN - REGULAR i' CASE NO: 2008-06183 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CARLISLE CEMENT PRODUCTS INC VS LICHTENBERGER MARTIN ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE the LICHTENBERGER SANDRA was served upon DEFENDANT at 1206:00 HOURS, on the 28th day of October , 2008 at 150 PINE KNOB ROAn NEWVILLE, PA 17241 SANDRA LICHTENBERGER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge )I/03/08 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/29/2008 SALZMANN HUGHES By. Deputy Sheriff of A. D. Carlisle Cement Products, Inc., Plaintiff vs. Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction Defendants DATE OF NOTICE: / TO: Martin Lichtenberger 150 Pine Knob Road Newville, PA 17241-8645 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 2008-6183 : CIVIL ACTION and Sandra Lichtenberger 150 Pine Knob Road Newville, PA 17241 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. Date: 3 Bl ---?? Y Attorney ID# 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff i CERTIFICATE OF SERVICE AND NOW, thisday of December, 2008, I, hereby certify that I served the Notice of Praecipe for Entry of Default Judgment this day by depositing the same in the United States mail, postage prepaid, in Chambersburg, Pennsylvania, addressed to: Martin Lichtenberger 150 Pine Knob Road Newville, PA 17241-8645 Sandra Lichtenberger 150 Pine Knob Road Newville, PA 17241-8645 Salzmann Hughes, P.C. U'r,Lt 0 ??"C) Melissa K. Dively, Esquire r-; r.l., ^°r? ` , ,. i I Carlisle Cement Products, Inc., VS. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2008-6183 CIVIL ACTION Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction Defendants PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Please enter judgment by default against the above named Defendants Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction in the amount of Nine Thousand, One Hundred, Twenty Five Dollars and Thirty Three Cents ($9,125.33) plus interests and costs. Respectfully submitted, SALZMANN HUGHES, P.C. Date: J -ZD? By: Meliss K. iv quire Attorney 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff CERTIFICATE OF SERVICE AND NOW, this ;& day of February 2009, I, hereby certify that I served the Notice of Praecipe for Entry of Default Judgment this day by depositing the same in the United States mail, postage prepaid, in Chambersburg, Pennsylvania, addressed to: Martin Lichtenberger 150 Pine Knob Road Newville, PA 17241-8645 Sandra Lichtenberger 150 Pine Knob Road Newville, PA 17241-8645 Salzmann Hughes, P.C. OKI- F; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION CARLISLE CEMENT PRODUCTS, INC. Plaintiff V. MARTIN LICHTENBERGER and SANDRA LICHTENBERGER, Individually and as husband and wife d/b/a Country Lane Construction Defendants _ Confessed Judgment X Other File No. 2008-6183 Amount Due $9,125.33 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 Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s): AU and all personal Dronerty located at 150 Pine Knob Road Newville PA 17241-8645 PRAECIPE FOR ATTACHMENT EXECUTION . Issue writ of attachment to the Sheriff of Cumberland 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, Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction. Date SALZMANN HUGHES, P.C. Me i . D' , squire A # 36780 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff 209 ,,I - F j 1= 4 t • co P o A"Y +W.sq AP-00 of qS` • so ?' Woo al.' O " a.00 Due Cc • so LL a?97ta "i+cf- 4 N6")W( WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6183 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CARLISLE CEMENT PRODUCTS, INC., Plaintiff (s) From MARTIN LICHTENBERGER and SANDRA LICHTENBERGER, individually and as husband and wife d/b/a COUNTRY LANE CONSTRUCTION, 150 Pine Knob Road, Newvill, Pa 17241-8645 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all personal property located at 150 Pine Knob Road, Newville, PA 17241-8645. (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 $9,125.33 Interest Atty's Comm % Atty Paid $179.59 Plaintiff Paid Date: 6/01/09 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs -. 4?*4 s R. Long o By: REQUESTING PARTY: Name MELISSA K. DIVELY, ESQUIRE Address: SALZMANN HUGHES, PC 79 ST. PAUL DRIVE CHAMBERSBURG, PA 17201 Attorney for: PLAINTIFF Telephone: 717-263-2121 Supreme Court ID No. 36780 Deputy ?'' e'a-. } 1 C Sheriffs Office of Cumberland County R Thomas Kline "CE TrHL Sheriff OF t i ,` `? 'TIDY Ronny R Anderson t. Chief Deputy :. 2909 SEP 15 A,l ?? 1 l Jody S Smith a L, l.' I.Y Cum Civil Process Sergeant or ,F T"` " " r Edward L Schorpp Solicitor Carlisle Cement Products Inc vs. Case Number Lichtenberger Sandra d/b/a Country Lane Construction 2008-6183 SHERIFF'S RETURN OF SERVICE 06/17/2009 06:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2009 at 1800 hours, he served a true copy of the within writ of execution, upon the defendants, to wit: Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction, by making known unto David Lichtenberger, adult son and adult in charge, at 150 Pine Knot Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendants on 06-18-09. 06/17/2009 06:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2009 at 1800 hours, he served a true copy of the within writ of execution, upon the defendants, to wit: Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction, by making known unto David Lichtenberger, adult son and adult in charge, at 150 Pine Knot Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendants on 06-18-09. 06/17/2009 06:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2009 at 1800 hours, he served a true copy of the within writ of execution, upon the defendants, to wit: Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction, by making known unto David Lichtenberger, adult son and adult in charge, at 150 Pine Knot Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendants on 06-18-09. 06/17/2009 06:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2009 at 1800 hours, he served a true copy of the within writ of execution, upon the defendants, to wit: Martin Lichtenberger and Sandra Lichtenberger, individually and as husband and wife d/b/a Country Lane Construction, by making known unto David Lichtenberger, adult son and adult in charge, at 150 Pine Knot Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendants on 06-18-09. 08/03/2009 12:27 PM - Sale bill posted on 08-03-09 at 1225 hours by Deputy Noah Cline. Sale date set for Thursday 08-20-09 at 1500 hours. Copy of sale bill mailed to Attorney Dively. 08/03/2009 12:27 PM - Sale bill posted on 08-03-09 at 1225 hours by Deputy Noah Cline. Sale date set for Thursday 08-20-09 at 1500 hours. Copy of sale bill mailed to Attorney Dively. 08/03/2009 Sale bill posted on 08-03-09 at 1225 hours by Deputy Noah Cline. Sale date set for Thursday, 08-20-09 at 1500 hours. Copy of sale bill mailed to Attorney Dively. 08/03/2009 12:27 PM - Sale bill posted on 08-03-09 at 1225 hours by Deputy Noah Cline. Sale date set for Thursday 08-20-09 at 1500 hours. Copy of sale bill mailed to Attorney Dively. 08/14/2009 R. Thomas Kline Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED. Defendant filed for bankruptcy. SHERIFF COST: $140.18 September 14, 2009 9/n/O i ,?- B ? x/935 / 3bC.a? SO ANSWERS, Ir R THOMAS KLINE, SHERIFF