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HomeMy WebLinkAbout09-0733 Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [7171 541-5225 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Plaintiff v. ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 RCP&P LLC 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA No. 09 - '733 _,?v? Terw+ YOU HAVE BEEN SUED IN COURT. ]F 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 AN 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 THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOC ION 32 SOUTH BEDFORD STRE CARLISLE, PA 17013` 1-800-990-9108 Z 717-249-3166 Date: February 10, 2009 By: Larry L.;Mill #28122 Attor for 1aintiff 1423 ate Road Duncannon PA 17020 717,957.2828 4 Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 . Plaintiff v. ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 RCP&P LLC 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O q- 7-33 Ct,?-,,! ' _ COMPLAINT 1. Plaintiff, Mid-Atlantic Materials, Inc. ("Mid- Atlantic"), a Maryland business corporation, is a supplier of building materials with a principal address of 6813 Quad Avenue, Baltimore, Maryland 21237. 2. Defendant, Altieri Enterprises, Inc. ("Altieri"), is is a Maryland business corporation with its business address at 9017 Red Branch Road, Suite 201, Columbia, Maryland 21045. 3. Defendant, RCP&P LLC ("RCP&P"), was a Maryland limited liability company whose registration was forfeited for failure to file property returns. RCP&P maintains a mailing address of 9017 Red Branch Road, Suite 201, Columbia, Maryland 21045. 4. Mid-Atlantic supplied materials to projects that Altieri was developing in Pennsylvania. 5. The projects that Mid-Atlantic supplied included Foxwood Estates, Mechanicsburg; Susquehanna Ridings, Etters; Manor at Westport, Mechanicsburg; Brook Meadow, Mechanicsburg; and, Rolling Hills Estates, Etters. 6. Mid-Atlantic was not paid for its materials that were used to improve Defendants' properties in Pennsylvania. 7. On July 21, 2008, Mid-Atlantic obtained a judgment against Altieri Homes and Darren B. Altieri of $300,015 in the Circuit Court for Baltimore County. 8. On December 31, 2008, the Maryland judgment was recorded in Cumberland County, Pennsylvania. See Exhibit "A" hereto. 9. Altieri Homes was the developer for The Manor at Westport and other Pennsylvania developments noted above. See, e.g., Exhibit "B" hereto. 10. It is believed and therefore averred that equitable title is held in the name of Altieri for the Pennsylvania projects. 11. Altieri Enterprises, Inc. and Altieri Homes are one and the same and have always been operated as a single business entity and use the same address at 9017 Red Branch Road, Suite 201, Columbia, MD 21045. 12. For the purpose of committing fraud on creditors, it is believed and therefore averred that legal title to The Manor at Westport may be held in the name of RCP&P, LLC. See Exhibit "C" hereto. 13. The address of RCP&P LLC is likewise 9017 Red Branch Road, Suite 201, Columbia Maryland 21045. Id. 14. It is believed and therefore averred that neither Altieri Enterprises, Inc. nor Altieri Homes are corporations in good standing in Maryland. See Exhibit "D" hereto. 15. It is believed and therefore averred that RCP&P is not a valid Maryland business and that it is not properly registered in Maryland. 16. It is believed and therefore averred that the Pennsylvania registered office of RCP&P is in fact Michael Brill & Associates and not RCP&P. 17. When Altieri applied for credit with Mid-Atlantic, it never disclosed its affiliations with Altieri Homes and RCP&P. See Exhibit "E" hereto. 18. When one lien was paid, Defendants' title agent sought a release of mechanic's liens in favor of "Altieri Enterprises, Inc." and not Altieri Homes or RCP&P. See Exhibit "F" hereto. 19. Mid-Atlantic avers that its judgment against Altieri Homes should be entered against Altieri Enterprises, Inc. and RCP&P, LLC. 20. Mid-Atlantic avers that at all times relevant hereto Altieri, Altieri Homes, and RCP&P were operated as a single business entity and that required corporate formalities were not followed. 21. Altieri, Altieri Homes, and RCP&P are legally one and the same. 22. Defendants' use of RCP&P was fraudulently intended to permit them to escape liability for the debts of Altieri and Altieri Homes. 23. RCP&P is being used to unlawfully syphon any net profits from the project or projects which are trust funds that should be delivered to the suppliers of labor and materials who improved the properties. 24. Altieri, Altieri Homes, and RCP&P were held out to the public as a single operating entity. 25. Altieri, Altieri Homes, and RCP&P had a common identity of officers, management, and ownership. 26. Altieri, Altieri Homes, and RCP&P intended to commit a fraud on the creditors by utilizing different names related to the projects. 27. Altieri and RCP&P acted with wilful intent to defraud the creditors of Altieri Homes. 28. Altieri and RCP&P should be required to satisfy and discharge the debts and liabilities of Altieri Homes. 29. Under Pennsylvania law, Altieri and RCP&P are liable to mid-Atlantic for the judgment against Atlantic Homes. WHEREFORE, Plaintiff prays for and demands judgment in its favor and against Defendants in the amount/qf $300,015.00, plus interest. DATE: February 10, 2009 By: v v LA *Y L. MILL R At orr*y I.D. #28122 VERIFICATION I, LARRY L. MILLER, hereby state that I am counsel for the Plaintiff in the within action and that the facts set forth in the foregoing Complaint are and correct to the best of my knowledge. The information set forth in this lien claim was provided by Charles E. Gibson, President of Mid-Atlantic Materials, Inc. Mr. Gibson's verification could not be obtained within the time allowed for filing this document. I understand that the statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Date: February 10, 2009 (Rule of Civil Procedure No. 236) MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue , Baltimore, MD 21237 Plaintiff , V. ALTIERI HOMES 9017 Red Branch Road, Ste 201 Columbia, MD 21045 DARREN B. ALTIERI 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA 6s - 0'? tt`? Notice is given that a judgment in the above-captioned matter has been entered against you on b F-C 2008. By: If you have any questions concerning the above, please contact: Larry L. Miller, Esquire 1423 State Road, Duncannon, PA 17020 717.957.2828 EXHIBIT A Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [7171 541-5225 = viz +^? , i t. j _ Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Plaintiff V. ALTIERI HOMES 9017 Red Branch Road, Ste 201 Columbia, MD 21045 DARREN B. ALTIERI 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA PRAECIPE TO FILE AND INDEX FOREIGN JUDGMENT TO: THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa. Cons. Stat. § 4306, kindly file and index the attached certified copy of the judgment entered in favor of Plaintiff, Mid Atlantic Materials, Inc., and against Defendants, Altieri Homes and Darren B. Altieri, in the total sum of $300,015.00 in the Circuit Court for Howard County, Maryland, in an action captioned Mid Atlantic Materials, Inc. v. Altieri Homes and Darren B. Altieri, Docket No. 13-C-08-73638 that was entered as a final judgment on July 21, 2008 by the Clerk of the Circuit Court. A true and correct certified copy of the judgment is attached hereto as Exhibit "A." Date: December 29, 2008 By: L 'rry ,L. ' ller C sel fo Plaintiff STATE OF MARYLAND, HOWARD COUNTY, TO WIT: I HEREBY CERTIFY that the aforegoing is a true photocopy of the original taken from the records of the Circuit Court for Howard County as recorded in Case Number: 13-C-08-73638 IN TESTIMONY WHEREOF, I hereto set my hand and affix the seal of the Circuit Court for Howard County this 11th Day of December, 2008. 71 Margar t D. Rappaport .??. °iV?19vLA?,??? Clerk of the Circuit Court for Howard County I, Diane 0. Leasure Judge of the Circuit Court for Howard County, in the Fifth Judicial District of the State of Maryland, do hereby certify that Margaret D. Rappaport who has given the preceding certificate, was Clerk of the said Circuit Court for Howard County at the time of so doing, and that his/her attestation is in due form, and his/her signature thereto is genuine. Q,.,- 6. Diane O. Leasure Judge of the Fifth Judicial Circuit STATE OF MARYLAND, HOWARD COUNTY, Sct. I, Margaret D. Rappaport, Clerk of the Circuit Court for Howard County, do hereby certify that the Honorable Diane 0. Leasure Judge of the Circuit Court for Howard County, who has certified and signed the above attestation, was at the time of so doing, Judge of the said Court, duly commissioned and qualified; and that to all acts done by him/her in that capacity, full faith and credit are due and ought to be given; and that his/her signature thereto is genuine. IN TESTIMONY WHEREOF, I hereunto subscribe my hand and affix the seal of the Circuit Court for Howard County, on this 11th Day of December, 2008, A.D. Margar t D. Rappaport Clerk of the Circuit Court for Howard County EXHIBIT A a CIRCUIT COURT FOR BALTIMORE COUNTY Suzanne Mensh Clerk of the Circuit Court County Courts Building 401 Bosley Avenue P.O. Box 6754 Towson, MD 21285-6754 (410)-887-2601, TTY for Deaf: (800)-735-2258 Maryland Toll Free Number (800) 938-5802 N 0 T I C E O F R E C O R D E D J U D G M E N T Case Number: 03-C-08 RJ Originating Court : 1300873638 C I V I L Mid Atlantic Materials Inc vs Altieri Enterprises Inc, et al I HEREBY CERTIFY that the following Judgment has been recorded in this Court in the above entitled case: Judgment Against: Altieri Homes 9017 Red Branch Road Columbia, MD 21045 Judgment in Favor of: Mid Atlantic Materials Inc Judgment Ordered On: 07/21/08 Judgment Entry Date: 07/21/08 Other Fee: $.00 Amount of Judgment: $250,000.00 Service Fee: $.00 PreJudgment Interest: $.00 witness Fee: $.00 Appearance Fee: $.00 Attorney Fee: $50,000.00 Filing Fee: $15.00 Total Judgment: $300,015.00 Plus court costs. IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of this Court. n'. 46 C7 I Clerk of the Circuit Court, per Issued: 07/21/08 ?o • CIRCUIT COURT FOR BALTIMORE COUNTY Suzanne Mensh Clerk of the Circuit Court County Courts Building 401 Bosley Avenue P.O. Box 6754 Towson, MD 21285-6754 (410)-887-2601, TTY for Deaf: (800)-735-2258 Maryland Toll Free Number (800) 938-5802 NOT I C E O F RECORDED JUDGMENT Case Number: 03-C-08 RJ Originating Court : 1300873638 C I V I L Mid Atlantic Materials Inc vs Altieri Enterprises Inc, et Al eal I HEREBY CERTIFY that the following Judgment has been recorded in this Court in the above entitled case: Judgment Against: Altieri, Darren B 9017 Red Branch Road Suite 201 Columbia, MD 21045 Judgment in Favor of: Judgment Ordered On: Judgment Entry Date: Amount of Judgment: Prejudgment Interest: Appearance Fee: Filing Fee: Mid Atlantic Materials 07/21/08 07/21/08 $250,000.00 $.00 $.00 $15.00 Plus court costs. Inc Other Fee: Service Fee: Witness Fee: Attorney Fee: Total Judgment: $.00 $.00 $.00 $50,000.00 $300,015.00 IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of this Court. ?,IT Cry Suzanne' Mensh •rceo• Clerk of the Circuit Court, per 5A, Issued: 07/21/08 s _ W a- Y.' _ p O ICO'- Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: (717) 541-5225 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. IN THE COURT OF COMMON PLEAS 6813 Quad Avenue CUMBERLAND COUNTY,PENNSYLVANIA Baltimore, MD 21237 . Plaintiff V. . ALTIERI HOMES . 9017 Red Branch Road, Ste 201 Columbia, MD 21045 . DARREN B. ALTIERI 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants VERIFICATION OF VALIDITY OF FOREIGN JUDGMENT I, Larry L. Miller, Esquire, being duly sworn according to law, depose and state that I am the attorney for the Plaintiff, Mid Atlantic Materials, Inc., and I am authorized to make this Verification on its behalf; and that, to the best of my knowledge, information, and belief: 1. The names of the judgment debtors are Altieri Homes and Darren B. Altieri. 2. The last known post office addresses of the judgment debtors is 9017 Red Branch Road, Suite 201, Columbia, MD 21045. 3. The name of the judgment creditor is Mid Atlantic Materials Inc. 4. The post office address of the judgment creditor is 6813 Quad Avenue, Baltimore, MD 21237. 5. The judgment in favor of Plaintiff, Mid Atlantic Materials Inc., and against Defendants, Altieri Homes and Darren B. Altieri, was entered in the total sum of $300,015.00 in the Circuit. Court for Howard County, Maryland, is valid, enforceable, and unsatisfied as of this date. I, LARRY L. MILLER, have read the foregoing and the factual statements contained therein are true and correct to the best of my knowledge, information and belief. I am authorized to make this Verification on behalf of my client, Mid Atlantic Materials Inc. The facts set forth in the pleading are based upon my review of the documents and information furnished by Mr. Charles E. Gibson, President of Mid Atlantic Materials Inc. This Verification is made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penaltJies. 1 I DATE: December 29, 2008 By: LARIP,Y L. ILLER L Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 Attorney for Plaintiff- MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Plaintiff V. ALTIERI HOMES 9017 Red Branch Road, Ste 201 Columbia, MD 21045 DARREN B. ALTIERI 9017 Red Branch Road," Ste 201 Columbia, MD 21045 Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA PRAECIPE Pursuant to Pennsylvania Rule of Civil Procedure 3002, enter judgment against the Defendants, Altieri Homes and Darren B. Altieri, in the amount of $300,015.00 in accordance with the certified copies of the Judgment Under Act of Congress in Case No. 13-C-08-73638 of the Circuit Court for Howard County, Maryland contemporaneously being filed, and index skid judgment against the Defendants. Date: December 29, 2008 By: Lar y L. Mil e Manor at Westport-Altieri Homes - Communities Net Page 1 of 1 r„ Manor at Westport-Altieri Homes Manor Drive Mechanicsburg, PA 17055 Click to show Phone# f a P. Photo Tour >>> Visit ° To view photos individually, click on any thun ® =rn id a F- (- enlarged view (may not be available for all pt here. 6®r, *m_. Overview Beautiful community offering open floor plans and stylish interiors, 4 bedrooms, 2.5 bath, convenient to Harrisburg. i'li?C(.' Visit Retlr( ?i?? 1?Gi: .nip +.__ ' ??_ c=`?, :CC Driva: ;r ;! 5erVed. Pn WERE6 BY. J; PI:i r.i -,ade Hawaii. A, kc3!"'_idti, "-a! s . lortana, wanla, Rhod, "-li nia, EXHIBIT B http://www.communitiesnet.comlcommunity/17727-manor-at-westportaltieri-homes/ 2/8/2009 Close Print http://www.altierihomes.comldisplay_image.php?image=./photos/communities/38 comm_plan_photo.jp... 6/19/2008 Page 1 of 3 AutoTrackXP Real Property Ownership and Deed Transfers Real Property Ownership Owner Name: Ownership Information RCP & P LLC i Coroorate Owner: YES Ownership Right: COMPANY - CORPORATION jSitus Address: WOODS WAY MECHANICSBURG PA 17055 ;Mailing Address: COLUMBIA MD 21045 Phone Number: Parcel Number: 10025608413 ICounty: CUMBERLAND i S81e3 Information Seller Name: OWNER RECORD Sales Date: Recording Date: 0012003 jSale Amount ;(Most Recent Sale Price): Sales Deed GRANT DEED Sale Transaction RESALE Category Type: Type: Page Number: 002188 Book Number: 000259 ;Multi Parcel Sale: MULTUDETAIL PARCEL SALE Loan Amount: Residential Model NO 'Indicator: 'PROPERTY IS RECORDED IN THE STATE OF PENNSYLVANIA, CUM BERLAND COUNTY PUBLIC RECORDS IN BOOK 000259 PAGE 002188. Assessor Information `Assessment Year: Assessed Land $63,000 Assessed Value: Improvements: +Total Assessed $63,000 ':Value: Market ?Market Land Value: $63,000 Improvements: ;Total Market Value: $63,000 !Calculated Land $63,000 Value: Calculated Total $63,000 Tax Amount: $346 Value: 'Tax Year: 2008 I Exemption: MISCELLANEOUS HOMEOWNERS EXEMPTION Property Characteristics 'Year Built: ( Property Type: VACANT 'Land Use: VACANT LAND (NEC) Lot Size: 11,761 SQFT Lot Size (Acres): 0.2700 Number of Buildings: 1 1 Number of Bedrooms: Legal Description ' Lot: 40 Municipality: LOWER ALLEN TOWNSHIP EXHIBIT C Census Tract: 0116.01 `Leoal Description: LOT 40 PB 89 PG 143 https:llatxp.choicepoint.comlatINatpropdeeds/d NatPropl)eeds.asp?PrintVersion=PROPDEEDSDetail... 2/5/2009 Page Real Property Deed Transfers Deed Transfers (1 of 2) Parcel Number: 10025608413 ;County: CUMBERLAND !Multi Parcel Sale: MULTI/DETAIL PARCEL SALE Transaction Type: RESALE ;Mortgage Deed Type: Document Type: GRANT DEED Document Year: 2003 i Vesting: COMPANY OR CORPORATION Seller Name(s): OWNER RECORD j Primary Buyer: RCP & P LLC Primary Ownership COMPANY - CORPORATION 'Primary Recording Date: 00/2003 Buyer Address: 9017 RED BRANCH RD 201 COLUMBIA MD 21045.2112 Sale Date: Resale/New RESALE Construction: Sale Price: Cash CASH Property Type: MISCELLANEOUS Sale/Mortgage: !Mailing Carrier C033 j Code: !Postal Code: PA iOWNER RECORD transferred ownership of this property through a grant deed to RCP & P LLC. Information on this deed transfer was !recorded in the state of PENNSYLVANINs deed transfer records in book 259 page 2188 on 0012003. i Deed Trans fers (2 of 2) Parcel Number: 10025608413 County: CUMBERLAND Multi Parcel Sale: MULTI/DETAIL PARCEL SALE !Transaction Type: RESALE Mortgage Deed ;Type: Document Type: GRANT DEED Document Year: 2003 ;Vesting: COMPANY OR CORPORATION I Seller Name(s): OWNER RECORD Primary Buyer: RCP & P LLC Primary Ownership COMPANY - CORPORATION ;Right: Recording Date: 00/2003 Buyer Address: 9017 RED BRANCH RD 201 COLUMBIA MD 21045-2112 (Sale Date: Resale/New RESALE Construction: Sale Price: Cash CASH I Property Type: VACANT Sale/Mortgage: r Land Use: VACANT LAND !Mailing Carrier C033 Code: Postal Code: PA (OWNER RECORD transferred ownership of this property through a grant deed to RCP & P LLC. Information on this deed transfer was !recorded in the state of PENNSYLVANIA's deed transfer records in book 259 page 2188 on 0012003. Source Information iReal Property Ownership is from the county assessor office and is updated annually. Deed Transfers are from the county recorder ;office and may be more current than the assessor data. To determine current ownership, review the transactions and dates in both ;sections of the Detail. IN anv fields are blank- this indicates the source did not SuoDIV that Information for this property. https:llatxp.choicepoint.com/atINatpropdeedsld_NatPropDeeds. asp?PrintVersion=PROPDEEDSDetail... 2/5/2009 Entity Deta;J. Page 1 of 1 Maryland Department of Assessments and Taxation 4 Taxpayer Services Division 301 West Preston Street W Baltimore, MD 21201 (2007 vw5.1) Main Menu. I security interest. Filings Business Entity Information (Charter/ Personal Property) New_S..earch I Rate_Stabil zation_Notices I Get.-Forms I Certificate of Status I SDAT_Home Taxpayer Services Division Entity Name: ALTIERI ENTERPRISES, INC. Dept ID #: D03245214 I General information Amendments Personal Property Certificate of Status Princi.pal._Office. 9744 CYPRESSMEDE (Current).; DRIVE ELLICOTT- CITY, MD 21043 Resident..A_g pt NO ACTIVE AGENT (Current): FOUND Status: INCORPORATED Good Standing: No Business Code: Ordinary Business - Stock .Date.. of Formation.-or 07/01/1991 R.e....gistratio.n State-of MD Formation; Stock./ Nonstoc..k. Stock Close/Not Close: Not Close j Link Definition General Information General information about this entity Amendments Original and subsequent documents filed Personal Property Personal Property Return Filing Information and Property Assessments Certificate of Status Get a Certificate of Good Standing for this entity EXHIBIT D http://sdatcert3.resiusa.orgfUCC-CharterlDisplayEntityb.aspx?EntityID=DO3245214&EntityName=A... 2/5/2009 Entity Detail Page 1 of 1 Maryland Department of Assessments and Taxation Taxpayer Services Division 301 West Preston Street W Baltimore, MD 21201 (2007 vw5.1) Main Menu Security Interest ._F ling.s_(U") Business Entity Information (Charter/ Personal Property) New Search Rate Stabl.ization._Notices Get Forms Certificate of_5tatus SDAT_Home Taxpayer Services Division Entity Name: ALTIERI HOMES, INC. Dept ID #: D06593685 General Information Amendments Personal Property Certificate of Status I Principal Office STE 201 (Current-J: 9017 RED BRANCH RD COLUMBIA, MD 21045 Resident. Agent NO ACTIVE AGENT (Current): FOUND Status: FORFEITED Good Standing: No Business Code: Ordinary Business - Stock Date__of Formaton.__or 12/31/2001 Registration: State _of MD Formation: Stock/Nonstock: Stock Close/.Not Close: Not Close k to Link Definition General Information General information about this entity Amendments Original and subsequent documents filed Personal Property Personal Property Return Filing Information and Property Assessments Certificate of Status Get a Certificate of Good Standing for this entity http://sdatcert3. resiusa. org/UCC-CharterlDisplayEntity_b. aspx?EntityID=DO6593685&EntityName=A... 2/5/2009 Entity De'aTIT Page 1 of 1 Maryland Department of Assessments and Taxation Taxpayer Services Division 301 West Preston Street W Baltimore, MD 21201 (2007 vw5.1) Main Menu security Interest-Filings . (.UCC) I Business Entity Information (Charter/ Personal Property) New Search Rate_Stabilizatton_Notices Get Forms (Certificate_of Status SDAT_Home Taxpayer Services Division Entity Name: ALTIERI HOMES, INC. Dept ID #: D06593685 General Information Amendments Personal Property Certificate of Status NOTICE. Al30UT_IMAGE AVAILABILITY.AND ACCURACY Page 1 of 1 Description R.E...S I Q.-NAT.. I..O.. N_. OF RESIDENT AGENT D E. PT.,_ACTI.O N ..-. FO_RFE.I..TURIE Date__ Filed Time Film 12/05/2008 0A8:46- 10/03/2008 PM 16- Folio Paq-es View Order Document Copies 0002 ' THE ENTITY WAS FORFEITED FOR FAILURE TO FILE PROPERTY RETURN FOR 2007. ARTICLES OF 08:58- n, P^PP 70n; 12/31/2001 AM 800327 0865 0004 to Link Definition General Information General information about this entity Amendments Original and subsequent documents filed Personal Property Personal Property Return Filing Information and Property Assessments Certificate of Status Get a Certificate of Good Standing for this entity http://sdatcert3.resiusa.org/UCC-CharterlDisplayEntity b.aspx?EntityID=DO6593685&EntityName=A... 2/5/2009 MID-ATLANTIC MATERIALS, INC. .6813 Quad Avenue 1141 j 11420 Old Baltimore Pike Baltimore, Maryland 21237 ax Beltsvill® cuyl .od.- 20705 Phone 410-284-2800 410-284-6790 ' ` _%&RjarAaf.0*7 636 CREDIT Name of Firm (Full Legal Name) 6 APPLICATION Address C101 r7 R,,d Telephone No. 41q- 715- r-f 6 City ?..O(Un,bIQ State _zip r?I0"s Fax No. 7L40-5gnc7 Nature of Business ?JU0C?Eh' Date Established- _ Iqq 1 Check One: ? PartnePship ® Corporation ? Sole Proprietorship Federal ID# Amount of Credit Required $ 010, 0w Have you ever filed bankruptcy ? Yes S No Are Purchase Orders Required? 9Yes ? No Is Applicant Tax Exempt? ? Yes 9No (If Yes Attach Tax Exempt Certificate) PRINCIPAL OFFICERS/OWNERS OR ALL PARTNERS Name Age 3_0 Soc. Sec. # -a 17 Home Address .2912 Surnmie ., k 11 D-1VG H -- '41 L ome Phone t 4,a- oa l q Name Grit lA 6. IS • /41-}t? 0 Age -??? Soc. Sec # d 1 r1- gh - 1009 Title . _ Home Address ?1 ?y9 I la _<XA rhnn? M E{; (I ) ?., yr 44 L4 Home Phone Q-1,1 1 10 - Name T(Z1r1 ?1 T K D. /`? 1Tie1^• 122,Ir1C.l Q2 A ( 3 r Titl ge. _ Soc. Sec. # I L4 a l 3 gt Home Address .2904 5(41n ne r. W 11 -Drive. H ome Phone 41b- 44a- IAas CREDIT REFERENCES r R ool I c.s Bank(4 Business Checking „ Account Number- 10I 6&rT4L :03 Branch 1= I 1 Cef!• Ci-1?i Mailing Address O 80X S3h F11?ee.1,1 C1i4v /ba1041PhoneNo. L -? -,o - _ C ?dy Cossemiio? SUPPLY FIRMS Name Phone Address 40 t l Qftil Bra ? Q r1 • . • ? CO (,,t,,"bip Mb .21.245 ? . Fax _ 4110- rIIS -rj3HL Name s 0 C. M i Re Phone q10 - 549 - 34,66 Address 093 } -' - -e /y(T? a07$4 Fax Name L C err. W i Ihel4cj Phone 'A"00-64110-1521 Address -1490 tiew T e_.Snol / ?V ' ?r e1Pr?r (t /qb Fax "r _ EXHIBIT t-• T ERMS: 2% 10th Prox; Net 25th The undersigned hereby makes application for credit from MID-ATLANTIC MATERIALS, INC. (MMI). The undersigned agrees to pay invoices in accordance with the payment terms indicated above and further agrees to pay costs of collection, including a twentyfive percent (25%) attorneys fee, and interest at the rate of eighteen percent (18%) per annum on all amounts past due. The undersigned further agrees that written notice shall be given to MMI of any invoice or statement errors within fifteen (15) days of the date thereon, and that all merchandise delivered will be checked when received and that any claims for shortages and/or damaged material will be reported in writing to MMI within 48 hours of receipt of the claim will not be allowed. The fact that this application contains a request for an estimate of monthly credit required shall not be deemed a limitation of liability by the undersigned or any guarantor. If the applicant is a corporation, the person signing the application on behalf of the applicant warrants that he is authorized to do so. If the applicant is not a corporation at the time of this application, and subsequently incorporates his business, with or without the knowledge of MMI, the applicant agrees to be jointly and severally liable to MMI for any indebtedness incurred by or transferred to such corporation. I/We authorize MMI to make whatever credit inquiries that it deems necessary with respect to the applicant and its principals in co i with this credit application or in the course of review or collection of any credit extended in reliance on t appl' at n. Signature 7kyxa 6.-A Wen PftS06-n{- Date 94199 Agent Signature Title Authorized Agent Title Date PERSONAL GUARANTEE For the purpose of inducing MID-ATLANTIC MATERIALS, INC. (MMI) to extend credit for the sale of building supplies and materials to , or any person or entity related to said company receiving materials, directly or indirectly, from MMI (herein collectively referred to as the "Firm°) and in further consideration of the delivery of certain materials to the Firm, and for other good and valuable consideration, the receipt of which is hereby acknowledged, the undersigned do hereby guarantee absolutely, irrevocably and unconditionally, without limitation as to time, payment per invoice of all sums due to MMI for such sales to the Firm or any related entity in accordance with the terms and conditions contained herein. The person or persons signing this Guarantee recognize and agree that they are jointly and severally liable with the Firm for any indebtedness owed by the Firm or any related entity. Each of the undersigned agrees that this Guarantee is being signed in his or her individual capacity and not in his or her representative capacity as an officer or director of a company. Thus any reference to a position with the Firm or with any company is merely for identification purposes only and in no way limits the individual liability of any of the undersigned. The undersigned further agree to pay costs of collection, including a twentyfive percent (25%) attorneys fee, and interest at the rate of eighteen percent (18%) per annum on all accounts past due. The undersigned waive notice of non-payment of the account by the Firm and further agree that this is a continuing and absolute guarantee. The undersigned waive acceptance of this guarantee, notice of the sale and delivery of materials, notice of the amount of the indebtedness, and notice of default or any extensions of time for payment. This is a contract under seal. Guarantor-Owner or Co-Owner of Assets Print Guarantor-Owner or Co-Owner of Assets Guarantor's Spouse Print Guarantor's Spouse Print Print DO NOT USE CORPORATE SEALS OR TITLES RELEASE OF MECHANICS' LIENS KNOW ALL MEN BY THESE PRESENTS, That we, the undersigned Mid-Atlantic Materials Inc., for value received, have remised, released and waived, and by these presents do, for ourselves and heirs, executors and administrators, remise, release and waive, to and in favor of Altieri Enterprises, Inc., his heirs and assigns, our right under Act of Assembly, entitled "Mechanics Lien Law of 1963, effective January I, 1964," to file or enter on record any Mechanics Lien or Liens against all that certain parcel of ground with the improvements thereon erected, situate in Cumberland County and known as Lot 35, Manor at Wesport, Mechanicsburg, PA 17055 , for any and all work done upon and materials furnished for the erection of a dwelling, or other buildings on said lot or lots, by us in the erection, building and completion thereof, or that may hereafter be done or furnished on the same. We further stipulate that we have been fully paid for any and all work performed and/or materials furnished to date. IN WITNESS WHEREOF, we have hereunto set our hands and seals, the day of the date written opposite our respective signatures. DATE IN PRESENCE OF SIGNATURE (SEAL) For Lumber Material (SEAL) For Stone Work & Material (SEAL) For Mason Work (SEAL) For Carptr Work & Material (SEAL) For Carpenter Work (SEAL) For Hardware & Glass (SEAL) For Plastering & Material (SEAL) For Painting & Glazing Material (SEAL) For Brick Work & Material (SEAL) For Brick Work (SEAL) For Tinning & Material (SEAL) For Fire Work & Material EXHIBIT r COMMONWEALTH OF PENNSYLVANIA : COUNTY OF BE IT REMEMBERED, that on this day of , before me, the subscriber, a Notary Pubic of the Commonwealth of Pennsylvania, personally appeared for , who being duly sworn according to law, doth depose and say that the foregoing is a full and complete Release or Waiver of Liens, and has been signed by all persons who have done work or furnished material in and about the erection and construction of the building mentioned at the head of the foregoing Release, except [NO EXCEPTION] and that all persons who have done work or furnished material in and about the erection and construction of the said building have been paid in full, in cash or by check presently payable, except [NO EXCEPTION] that the said building has been entirely finished and completed; that the cost thereof did not exceed $165,101.78; and that he makes this affidavit for the purpose of inducing Advantage Title Company to issue its policy on the described premises. SWORN AND SUBSCRIBED before me this day of Notary Public Commission Expires: ALL that certain tract or parcel of land situate in the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point on the southern right-of-way line of Manor Drive, said point being a common corner with Lot 36 of the Final Subdivision Plan of the Manor at Westport; of which this is a part; THENCE, along Lot 36, South 07 degrees, 01 minutes, 07 seconds West, for a distance of 137.40 feet to a point, said point being along the property line of Lot 40 of the aforementioned subdivision plan, of which this is a part; thence, along Lot 40 and Lot 41 of the aforementioned subdivision plan, of which this is a part, North 82 degrees, 58 minutes, 53 seconds West, for a distance of 80.00 feet to a point, said point being a common corner with Lot 34 of the aforementioned subdivision plan, of which this is a part; thence, along Lot 34 North 07 degrees, 01 minutes, 07 seconds East, for distance of 140.00 feet to a point, said point being on the southern right-of-way line of Manor Drive; thence, along said southern right-of-way line, South 82 degrees, 58 minutes, 53 seconds East, for a distance of 38.94 feet to a point; thence, along the same, along an arc of a curve, curving to the right, having a radius of 325.00 feet, an arc length of 41.17 feet, the chord of which being South 79 degrees, 21 minutes, 10 seconds East, for a distance of 41.14 feet to a point, the POINT OF BEGINNING. CONTAINING 11,164 square feet of land. BEING Lot 35 of the Final Subdivision Plan for The Manor at Westport as recorded in Cumberland County Records. The improvements thereon being known as 4576 Manor Drive, Mechanicsburg, PA. 17055. Cr) 7 cY:J r Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Plaintiff V. ALTIERI ENTERPRISES, INC. 9017 Red Branch Road, Ste 201 Columbia, MD 21045 RCP&P LLC 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-733 Civil Term PRAECIPE FOR LIS PENDENS TO: THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Please index the above-captioned action as a lis pendens against the real property owned by Defendants located at Lot 40, Manor Drive, Manor at Westport, Mechanicsburg, Cumberland County, Pennsylvania. I hereby certify that this action affects le to f: or other interests in the above-described pro erty. DATE: February 27, 2009 By: LAR Y LLER Attorney I.D. #28122 VERIFICATION I, LARRY L. MILLER, hereby state that I am counsel for the Plaintiff in the within action and that the facts set forth in the foregoing Lis Pendens are and correct to the best of my knowledge. The information set forth herein was provided by Charles E. Gibson, President of Mid-Atlantic Materials, Inc. Mr. Gibson's verification could not be obtained within the time allowed for filing this document. I understand that the statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. / Date: February 27, 2009 IIAR RY J. MILLER t t°?3 ..... ``; i _? =? -r',. `_.._ ,? } -:. -. t ;'k lr 1 1 ..{„' Larry L. iller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon PA 17020 Telephone [717] 541-5225 MID-AT TIC MATERIALS, INC. 6813 Qua Avenue Baltimore, MD 21237 Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-733 Civil Term ALTIERI ENTERPRISES, INC. 9017 Re Branch Road, Ste 201 Columbia, MD 21045 RCP&P L LC 9017 Re Branch Road, Ste 201 Columbia, MD 21045 Defendants PROOF OF SERVICE Inc., Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. I, Larry L. Miller, counsel for Mid-Atlantic Materials, ing duly sworn according to law, depose and say that on 16, 2009, I served a true copy of the Complaint on the out-of-s ate Defendants, by sending them simultaneously by regular and certified mail, return receipt requested to: ALTIERI ENTERPRI ES, INC., 9017 Red Branch Road, Ste 201, Columbia, MD 21045 an RCP&P LLC, 9017 Red Branch Road, Ste 201, Columbia, MD 21045. rue and correct copies of the February 16, 2009 service letters with the originally signed certified return receipt cards are collectively attached hereto as Exhibit "A." I certify that the foregoing statements made by me are true. I lam aware that if any of the foregoing statements made by me are wil4ully false, Date: May 20, 2009 I am subject to punishment. BY: La ry Miller MILLER LAW OFFICES, P.C. • Pennsylvania Office New Jersey Office - Suite 108, 50 Chestnut Rk1Qe Rd. 1423 State Road Duncannon, PA 17020 Montvale, NJ 07645 717 957 2828 RE. #3641 EMAIL IlmmillerlawCearthllnk.net Fax 7179574843 2/16/09 #3641 7184 3875 4490 0000 5771 February 16, 2009 ST Authorized Agent for Altieri Enterprises, Inc. 9017 Re Branch Road, Suite 201 Columbi. MD 21045 Re: Mid-Atlantic Materials v Altieri Enterprises, et al. Docket: 09-733 Civil Term Our File #3641 Dear SirYMadam: filed in I enclose and serve upon you a true and correct copy of the Complaint above-referenced matter. Sincerely, Larry L. Miller Enclo s LARRY L. MILLER, ESQUIRE MILLER LAW OFFICES, P.C. 1423 STATE ROAD DUNCANNON, PA 17020 12/16/08 #3641 A_ Sig/Iture: (?Addressee or ?Agent) i gg 5 ag V8 ` I w Ln LL U 00 ? e. KetWv1etl_ y VI : (please print cleaqy) C-b Deli wL= a 8! z N D. Addressee's Address (avnre,entF, Addessusweysendeg 0 UzM ! v O W K W w - Seconds Addrasa /Suite /Apt. /Floor (Pleeae Pi rit Clierlyj O WO w (L r LL + -•-•-- Delivery Address - ------------•----------.----------•----------•----•-- . ........................ Clty .................. .•-.--• State ---•-------ZIP a 4 Code 4. Restricted Delivery? & Service Type (Extra Fee) Ej Yes CERTIFIED f 2 Article Number 7184 3875 4490 0000 5771 Hill 1111111 111MI111111 III III 3875 4490 BODO 577.1 1. Article Addressed To: AUTHORIZED AGENT FOR ALTIERI ENTERPRISES, INC. 9017 RED BRANCH ROAD SUITE 201 COLUMBIA MD 21045 EXHIBIT A MILLER LAW OFFICES, P.C. Pennsylvania Office New Jersey Office - 1423 State Roads Suite 108, 50 Chestnut Ridge Rd. Ouncannon. PA 17020 1 ? 'I Montvale, NJ 07645 717 957 2828 RE #3641 EMAIL limmillerlawCearthlink.net Fax 7179574843 2/16/09 #3641 1 7184 3875 4490 0000 5764 February 16, 2009 ST Authorized 9017 Red F Columbia, Dear Sir/M a O¢ W= Q Z N o enclose and serve upon you a true and correct copy of the Complaint filed in the a ove-referenced matter. Sincerely, Larry L. Miller Enclosures nt for RCP&P LLC ch Road, Suite 201 21045 Mid-Atlantic Materials v. Altieri Enterprises, et al. Docket: 09-733 Civil Term Our File #3641 i LARRY L. MILLER, ESQUIRE MILLER LAW OFFICES, P.C. 1423 STATE ROAD DUNCANNON, PA 17020 j 2/16/08 #3641 A- SigNuree(?Addressee or ?AgenT) By: n ? >> e g U °-' WA ./ppj O S J C'1 O ^ UJI 0?CA LL C. Date of Delivery C11 °r, a k 0- ~ O. Addressee's Address ftNDManneFmmadd?susedbys ,.j0 4. Restricted Delivery? S. Service Type f (Extra Fee) E] Yes CERTIFIED I c. rvucie NUMDer 7184 3875 4490 0000 5764 AIIflIIIIIIIIl1111nVIMNN 7184 3875 441 0000 5764 1. Article Addressed To: AUTHORIZED AGENT FOR RCP&P LLC 9017 RED BRANCH ROAD SUITE 201 COLUMBIA MD 21045 - 2 9 No g c .............................. ...--•----•---••---.... W 9s 19 ¢Z! Delivery Address p fA $a?i?.?Q Z Q8i v W aUrn?c w w city •---•----- -------• ---•---••--- - ry State ZIP + 4 Code CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the for going this day of May 2009 by placing the same in the Un'ted States Mail, first class mail, postage prepaid, address d as follows: ALTIERI ENTERPRISES, INC. 9017 Re Branch Road, Ste 201 Columbi , MD 21045 RCP&P L C 9017 Re Branch Road, Ste 201 Columbi , MD 21045 By : c?caC U'V'_ FILED-C!- -1' IF OF IM" F ARY 2009 MAY 21 Ali 11: 214 CUC? 4 Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: (717) 541-5225 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. Plaintiff V. ALTIERI ENTERPRISES, INC. RCP&P LLC Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-733 Civil Term PRAECIPE TO ENTER JUDGMENT Please enter judgment for $315,500.71 in favor of the above-named Plaintiff, Mid-Atlantic Materials, Inc., and against the Defendants, Altieri Enterprises, Inc. and RCP&P LLC, for failing to file an answer in the above action within twenty days of the date of service of the Complaint. Plaintiff is entitled to the judgment on the principal debt of $315,500.71, plus interest at six percent per annum pursuant to 42 Pa.C.S. §8101 of $15,485.71 (see interest worksheet attached hereto) for a total due of $315,500.71. The above named Defendants were served with notice of intent to enter default judgment on May 20, 2009, pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. The notice was mailed to the Defendants more than ten days ago and it is attached hereto as Exhibit "A". 4 .4 Principal Debt Interest Total Date: June 1, 2009 $300,015.00 $ 15,485.71 $315,500 71 By: 'L. MILLER Attorney .D. No. 28122 Lawyers Diary and ManualTm Page 1 of 1 Post Judgment Interest Calculator Amount of Judgment: $300,015.00 Judgment Date 7/21/2008 Collection Date 5/30/2009 Computation Method: Simple Interest Annual Interest Rate: 6.000% Total Amount: $315,500.71 Total Interest: $15,485.71 Date Printed: 5/30/2009 Start Date End Onto Daps RAUO t Der meet Were* TOW 1 07/2112008 05/30/2009 6.000% $15,485.71 $315,500.71 01996-2002, Skinder-Strauss Associates and licensed to larry miller, miller law offices 4MILLER LAW OFFICES, P.C. Pennsylvania Office New Jersey Office - 1423 State Road Suite 108, 50 Chestnut Ridge Rd. Duncannon, PA 17020 Montvale, NJ 07645 717 957 2828 EMAIL Ilmmiliedaw@earthlink.net Fax 717 957 4843 May 20, 2009 ALTIERI ENTERPRISES, INC. RCP&P LLC 9017 Red Branch Road, Ste 201 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Columbia, MD 21045 Re: Mid-Atlantic v. Altieri et al Case No. 09-733 Civil Term Our File #3641 Dear Sirs/Madam: In accordance with Rule 237.1 of the Pennsylvania Rules of Civil Procedure, I am enclosing a Notice of Intent to Enter Default Judgment against Defendants. Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717] 541-5225 MID-ATLANTIC MATERIALS, INC. Plaintiff V. ALTIERI ENTERPRISES, INC. RCP&P LLC Defendants TO: ALTIERI ENTERPRISES, INC. AND RCP&P LLC 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. IN'THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-733 Civil Term IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE PURSUANT TO RULE 1026 OF THE PENNSYLVANIA RULES OF CIVIL PROCEDURE. 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, 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 1.800.990.9108 or 717:249.3166 DATE: May 20, 2009 By. R L. MILLER `? Attorney I.D. #28122 n,gr ?, t 4t4.co P® A'CT'/ o r?651 I?e1?i?. ?1?s1.?1 (Rule of Civil Procedure No. 236) MID-ATLANTIC MATERIALS, INC. Plaintiff V. ALTIERI ENTERPRISES, INC. RCP&P LLC Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-733 Civil Term Notice is given that a judgment in the above-captioned matter has been entered against you on dim And , 2009. By: If you have any questions concerning the above, please contact: Larry L. Miller, Esquire 1423 State Road, Duncannon, PA 17020 717.957.2828