HomeMy WebLinkAbout09-3139Fred August Nehr, Esquire
fnehrng,gibleylaw.com
Identification No.: 91676
GIBLEY AND McWILLIAMS, P.C.
524 N. Providence Road
Media, PA 19063-0807
(610) 627-9500
Attorney for Claimant, Bradco Supply
Corporation
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BRADCO SUPPLY CORPORATION,
1646 West Chester Pike, Suite 9
West Chester, PA 19382
Claimant,
V.
SUTLIFF ENTERPRISES, INC.,
P.O. Box 1307, 13`h & Paxton Streets
Harrisburg, PA 17105
Owners or Reputed Owners
and
NICHOLAS EVANOFF COMPANY,
997 Peiffers Lane
Harrisburg, PA 17109
Contractor.
Civil Action No. :
04 - 313? IYX- 16T6"
MECHANICS' LIEN CLAIM
AND NOW, comes Claimant Bradco Supply Corporation by and through counsel, Gibley
and McWilliams, P.C., and hereby files the following Mechanics' Lien Claim as a subcontractor
and material supplier, pursuant to the Mechanics' Lien Law of 1963, 49 P. S. § 1101 et seq., as
periodically amended, against the premises herein described, any and all buildings erected
thereupon and the curtilage appurtenant thereto, for the price and value of the materials
furnished, herinafter described, in the amount of $17,912.85 together with interest due it as a
sub-contractor and material supplier under the herein described, as follows:
Claimant, Bradco Supply Corporation, is a corporation organized and existing
under the laws of New Jersey with a Certificate of Authority to conduct business in the
Commonwealth of Pennsylvania and a place of business located at 1646 West Chester Pike,
Suite 9, West Chester, Pennsylvania, 19382.
2. Claimant Bradco Supply Corporation files this Mechanics' lien claim as a
Subcontractor.
The property subject to lien is any and all buildings erected and the curtilage
appurtenant thereto located at 6462 Carlisle Pike, Mechanicsburg, Cumberland County,
Pennsylvania, 17050.
4. The owner or reputed owner of the property subject to the lien is Sutliff
Enterprises, Incorporated, having a registered office address of P.O. Box 1307, 13`t' & Paxton
Streets, Harrisburg, Pennsylvania, 17105, and a place of business located at 6462 Carlisle Pike,
Mechainicsburg, Cumberland County, Pennsylvania, 17050. (See Exhibit "A" for records of the
Tax Database and Pennsylvania Department of State Corporation Records).
5. The Contractor is identified as Nicholas Evanoff Company with a registered office
address of 997 Peiffers Lane, Harrisburg, Pennsylvania, 17109.
6. The materials were furnished by Claimant pursuant to an order placed by
Contractor to supply materials for a construction project at the above described property.
7. The general nature and character of the labor and material furnished by Bradco
Supply Corporation was in connection with the construction project and consisted of related
construction materials as more fully described in the Claimant's invoices. (See true and correct
copies of the relevant invoices describing the material supplied by Claimant to said premises
attached hereto and marked collectively as Exhibit `B").
On November 12, 2008 through November 20, 2008, Claimant, pursuant to the
order of Contractor, agreed to furnish construction materials as more fully described in the
Claimant's invoices, at the premisies described above. (See Exhibit "B")
9. The materials supplied were utilized in the above described premises and were
free from defect.
10. The date upon which Bradco Supply Corporation completed the work for which
this claim is made was November 20, 2008.
11. The amount due claimed to be due to Bradco Supply Corporation for the aforesaid
delivery of construction materials supplied is $17,912.85 plus interest.
12. Formal Notice of Intention to File a Mechanics' Lien Claim was served on Sutliff
Enterprises, Inc. by certified mail, return receipt requested on April 15, 2009. (See true and
correct copies of said Formal Notice and certified mail return receipts attached hereto as Exhibit
44U
13. This lien is claimed against the premises described above as any and all buildings
erected and the curtilage appurtenant thereto located at 6462 Carlisle Pike, Mechanicsburg,
Cumberland County, Pennsylvania, 17050.
GIl
By:
Date: v? ?oU
Corporation
Attorney for Claimant, Bradco Supply
VERIFICATION
I, George Maybroda, hereby verify that I am authorized on behalf of Claimant, Bradco
Supply Corporation, in the above-captioned matter, that I am authorized to make this
Verification on its behalf and that the facts set forth in the foregoing document are true and
correct to the best of my knowledge, information and belief.
The statements contained herein are made pursuant to the penalties of 18 Pa.C.S. §4904
relating to unsworn falsification to authorities
Date: S_/)j Ll 1'w
(Evanoff- 6462 Carlisle Pike)
-? A
Business Entity
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Filing History
Date: 5/14/2009 (Select the link above to
view the Business
Entity's Filing History)
Business Name History
Name Name Type
SUTLIFF ENTERPRISES, INC. Current Name
Business Corporation - Domestic - Information
Entity Number:
Status:
Entity Creation Date:
State of Business.:
Registered Office Address:
Mailing Address:
349742
Active
5/1/1946
PA
13TH & PAXTON STS
HARRISBURG PA 0 -0
No Address
Officers
Name: JACK L BENNER
Title: President
Address: PO BOX 1307 13TH PAXTO
HARRISBURG PA 17105-22
Name: JACK L BENNER
Title: Secretary
Address: PO BOX 1307 13TH PAXTO
HARRISBURG PA 17105-22
Name: JACK L BENNER
Title: Treasurer
Address: PO BOX 1307 13TH PAXTO
HARRISBURG PA 17105-22
Name: JACK L BENNER
Title: Vice President
https://www.corporations.state.pa.us/corp/soskb/Corp.asp?331713 5/14/2009
TaxDB Result Details
Page 1 of 1
Detailed Results for Parcel 38-18-1328-084. in the 2004 Tax Assessment Database
DistrictNo 38
Parcel ID 38-18-1328-084.
MapSuffix
HouseNo 6462
Direction
Street CARLISLE PIKE
Ownerl SUTLIFF ENTERPRISES
C/O INCORPORATION
PropType C
PropDesc
LivArea
CurLandVal 498000
CurImpVal 1002000
CurTotVal 1500000
CurPrefVal
Acreage 2.49
CIGrnStat
TaxEx 1
SaleAmt 550000
SaleMo 03
SaleDa 29
SaleCe 19
SaleYr 89
DeedBkPage 0033W-00125
YearBlt 1996
HF File Date
HF Approval_Status
http://taxdb.ccpa.net/details.asp?id=38-18-1328-084.&dbselect=l 4/15/2009
?X?ib?t ?3
INVOICE
Bradco Supply Corporation
UPC VENDOR INVOICE DATE
*** D U P L I C A T E **A 000000 11/20/08
CUST.#: 605240 SALES REP P.O. NO.
SHIP TO #: 1 195 11607
SHIP To: NICHOLAS EVANOFF COMPANY
sutliff cadillac
6462 carlisle pike
MECHANICSBURG. PA 17015
BILL To: NICHOLAS EVANOFF COMPANY*
997 PEIFFERS LANE
HARRISBURG, PA 17109
LINE PRODUCT QUANTITY
NO. AND DESCRIPTION ORDERED
2* pf6101frls 1
FST 060 10'X100' EPDM FIRE RTD LOW SLOPE
3* PF61050FRLS 1
FST 060 10'X50' EPDM FIR RTD LOW SLOPE
5* fsttiq 25.60
FST TAP ISO 1/2 "0" .50.2.5
ORDER NO.
11556669-00
PAGE X
1
REMIT TO: Bradco Supply - Harrisburg
451 JPL Wick Drive
Harrisburg, PA 17111
PHONE 717-564.4453
FAX 717.564-1952
INSTRUCTION S
SHIP POINT SHIP VIA SHIPPED TERMS
Bradco Supply - Harrisburg Bradco Truck 11/20/08 1%10thNetEOM
QUANTITY QTY.
B.O. SHIPPED QTY. UNIT UNIT
UIM PRICE AMOUNT
INETI
0 1 RL 0.505 SF 505.00
0 1 RL 0.505 SF 252.50
0 25.60 SO 69.75 SO 1785.60
3 Lines Total Qty Shipped Total 27.60
See Reverse Side for Terms and Conditions Cash Discount
Last Page
Total 2543.10
DELIVERY CHG 35.00
Taxes 154.69
Invoice Total 2732.79
25.44 If Paid By 12110108
3
INVOICE
Bradco Supply Corporation
UPC VENDOR INVOICE DATE
*** DUPLICATE *** 000000 11/12/08
CUST.B: 605240 SALES REP P.O. NO
SHIP TO A: 1 195 11595
SHIP To: NICHOLAS EVANOFF COMPANY
Sutliff cadillac
6462 carlisle pike
MECHANICSBURG, PA 17015
BILL TO: NICHOLAS EVANOFF COMPANY*
997 PEIFFERS LANE
HARRISBURG, PA 17109
LINE
NO. PRODUCT
AND DESCRIPTION QUANTITY
ORDERED
2* fsttiq 16
FST TAP ISO 1/2 "Q" .50-2.5
3* xff700 4
FST 7" AP FAST 500 W56RAC4209
6* pf6101frls 9
FST 060 10'X100' EPDM FIRE RTD LOW SLOPE
12* W56RAC1620 2
FST QUICKSEAM 18" SA FLASHING
13* fsti20 111.68
FST ISO 4X8 BF 2.0"
ORDER NO.
11436576-00
PAGE #
1
REMIT TO: Bradco Supply - Harrisburg
451 JPL Wick Drive
Harrisburg, PA 17111
PHONE 717-564-4453
FAX 717-564-1952
INSTRUCTION S
SHI P POINT SHIP VIA SHIPPED TERMS
Bradco Supply - Harrisburg Bradco Truck 11/12/08 1910thNetEOM
OUANTITY
5.0. QTY.
SHIPPED QTY. UNIT
U/M PRICE UNIT AMOUNT
(NET)
10.56 5.44 SQ 67.40 SQ 366.66
0 4 BX 127.55 BX 510.20
0 9 RL 0.482 SF 4342.50
0 2 RL 180.15 RL 360.30
4.16 107.52 SQ 68.30 SQ 7343.62
5 Lines Total Qty Shipped Total 127.96
See Reverse Side for Terms and Conditions
Last Page
Total 12923.28
DELIVERY CHG 35.00
Taxes 777.50
Invoice Total 13735.78
Cash Discount 129.24 If Paid By 12/10/08
1
INVOICE
Bradco Supply Corporation
UPC VENDOR INVOICE DATE ORDER NO,
*** D U P L I C A T E *** 000000 11/17/08 11436576-01
CUST.a: 605240 SALES REP P.O. NO. PAGE A
SHIP TO 9: 1 195 11595 1
SHIP To: NICHOLAS EVANOFF COMPANY
sutliff cadillac
6462 carlisle pike REMIT TO: Bradco Supply Harrisburg
MECHANICSBURG, PA 17015 451 JPL Wick Drive
Harrisburg, PA 17111
PHONE 717-564-4453
BILLTD: NICHOLAS EVANOFF COMPANY* FAX 717-564-1952
997 PEIFFERS LANE
HARRISBURG, PA 17109 INSTRUCTIONS
SHIP POINT SHIP VIA SHIPPED TERMS
Bradco Supply - Harrisburg Bradco Truck 11/17/08 1X10thNetEOM
LINE PRODUCT QUANTITY QUANTITY QTY. QTY. UNIT UNIT AMOUNT
NO. AND DESCRIPTION ORDERED B.O. SHIPPED U/M PRICE [NET)
2* fsttiq 10.56 0 10.56 SO 67.40 SQ 711.74
FST TAP ISO 112 V .50.2.5
13* fsti20 4.16 0 4.16 SQ 68.30 SQ 284.13
FST ISO 4X8 BF 2.0"
14* fsttiq 5.44 0 5.44 SQ 67.40 SO 366.66
FST TAP ISO 1/2 "Q° .50-2.5
3 Lines Total Qty Shipped Total 20.16 Total 1362.53
Taxes 81.75
Invoice Total 1444.28
See Reverse Side for Terms and Conditions Cash Discount 13.63 If Paid By 12/10/08
Last Page 2
Law Offices
Gibley, and McWil lams
A Professional Corporation
524 North Providence Road
Tarragon Office Center
8111 Church Road, Suite 105 Media, PA 19063
(610) 627-9500
Cherry Gill, NJ 08002 (610) 627-2400 (fax)
(856) 773-0331
(856) 873-9283 (fax)
VIA CERTIFIED MAIL
RETURNRECEIPT REOUESTED
Jack L. Benner
Sutliff Enterprises, Inc.
6462 Carlisle Pike
Mechanicsburg, PA 17050
April 15, 2009
Jack L. Benner
Fred August Nehr, Esquire
fnehr@gihleylaw.com
Sutliff Enterprises, Inc.
P.O. Box 1307, 13`' & Paxton Streets
Harrisburg, PA 17105
RE: Subcontractor's Formal Notice of Intent to File Mechanic's Lien Claim
Dear Sir and Madam:
Please be advised that my client, Wickes Lumber/Bradco Supply Corp., is a construction and
building materials supplier having contracted with Nicholas Evanoff Company to furnish and deliver
building and construction materials to your property and/or construction project located at 6462 Carlisle
Pike, Mechanicsburg, Pennsylvania on November 12, 2008 through November 20, 2008.
My client is currently owed the sum of $17,912.85 for the construction supplies and building
materials delivered to the above property on November 12, 2008 through November 20, 2008. This
letter shall constitute formal notice to you of my client's intention to file a mechanic's lien claim against
the property listed above for the materials that were supplied and delivered to the above address.
Very truly yours,
FAN/me
cc: Nicholas Evanoff Company
997 Peiffers Lane
Harrisburg, PA 17109
GIBLEY M ILLIAMS, P.C.
By:
Fred August Nehr, Esquire
Attorney for Claimant
Wickes Lumber/Bradco Supply Corp.
¦ complete items 1, 2, and 3. Aiso complete
item 4 if Restricted Delivery Is desired.
• Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
j6-C -
?t
G . Agent
? Addre;
R by (Ff Name) C ate of Deil
Is delivery address d / es
flferent from kem 1? ? Yes
If YES, enter delivery address below: ? No
r C r 3o ?7 3. Service Typ=Fee)
2 {,` Certified l f 0 ? RegisterjW
. Re
scted Deli
( ? Insured very? (Extra 2. Article Numt(er ? Yes
(77ansferfmm'senice1abel) 7008 3230 0001 2863
5222
PS Form 3811, February 2004 Domestic Retum Receipt
_ 102595-02-M-1540;
FILFCr-:
F TI rfiARY
2Ol C9 VA 18 Fri1 2,' 5 5
eke i s& z40.
Sheriffs Office of Cumberland County
Sheriff R Tho as Kline „tp c` cuu?ucrt? 0 Edward L Schorpp
Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFFICE CF 'm£ >,?-ERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/19/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and
inquiry for the within named defendant, to wit: Sutliff Enterprises, Inc., but was unable to locate them in
his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Mechanics'
Lien Claim according to law.
05/19/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and
inquiry for the within named defendant, to wit: Nicholas Evanoff Company, but was unable to locate them
in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Mechanics'
Lien Claim according to law.
05/22/2009 12:38 PM - Dauphin County Return: And now May 22, 2009 at 1238 hours I, Jack Lotwick, Sheriff of
Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within
Mechanics Lien Claim, upon the within named defendant, to wit: Sutliff Enterprises Inc. by making known
unto Ken Long, adult in charge at 997 Peiffers Lane Harrisburg, Pennsylvania 17109 its contents and at
the same time handing to him personally the said true and correct copy of the same.
05/26/2009 11:05 AM - Dauphin County Return: And now May 26, 2009 at 1105 hours I, Jack Lotwick, Sheriff of
Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within
Mechanics Lien Claim, upon the within named defendant, to wit: Sutliff Enterprises Inc. by making known
unto Jack Benner, President at 13th and Paxton Streets Harrisburg, Pennsylvania 17105 its contents and
at the same time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $53.00
May 28, 2009
2009-3139
Bradco Supply Corporation
VS
Nicholas Evanoff Company
r?
?. J
^.7
t?
l t?
a-?
(Ptlitt of the ?Slt"*rfrf
Mary Jane Snder
Real Estate Depu
William T. Tully
Solicitor
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
BRADCO SUPPLY CORPORATION
VS
NICHOLAS EVANOFF COMPANY
Sheriff s Return
No. 2009-T-1388
OTHER COUNTY NO. 093139
And now: MAY 26, 2009 at 11:05:00 AM served the within MECHANICS LIEN CLAIM upon
SUTLIFF ENTERPRISES INC. by personally handing to JACK BENNER, PRESIDENT 1 true
attested copy of the original MECHANICS LIEN CLAIM and making known to him/her the contents
thereof at 13TH AND PAXTON STREETS HBG PA 17105
ALSO SERVED WAS NOTICE OF CLAIM
Sworn and subscribed to
before me this 26TH day of May, 2009
117?
NOTARIAL SEAL
ARY JANE SNYDER, Notary Publi
Highspire, Dauphin County
IM, Commission Expires
Set 1, 2010
So Answers,
Sheriff of G D hin?pount?, ?
?e? ??
Ey
Deputy Sheriff
Deputy: R HOPKINS
Sheriffs Costs: $66.5 5/21/2009
(Mlitt Of thr- SIterief
Mary Jane Snyder
Real Estate Depu
William T. Tully
Solicitor
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
BRADCO SUPPLY CORPORATION
VS
NICHOLAS EVANOFF COMPANY
Sheriff s Return
No. 2009-T-1388
OTHER COUNTY NO. 093139
And now: MAY 22, 2009 at 12:38:00 PM served the within MECHANICS LIEN CLAIM upon
NICHOLAS EVANOFF COMPANY by personally handing to KEN LONG 1 true attested copy of the
original MECHANICS LIEN CLAIM and making known to him/her the contents thereof at 997
PEIFFERS LANE HBG PA 17109
ESTIMATOR
Sworn and subscribed to So Answers,
before me this 26TH day of May, 2009
NOTARIAL SEAL
ARY JANE SNYDER, Notary Publi
Highspire, Dauphin County
M Commission Expires Set 1 2010
Sheriff of
By
Deputy: W CONWAY
Sheriffs Costs: $66.5 5/21/2009
A 176,
FINAL PROTECTION IN THE COURT OF COMMON PLEAS OF
FROM ABUSE ORDER CUMBERLAND COUNTY, PENNSYLVANIA
Extended Order Q Amended Order NO. 2009-3221
1. PLAINTIFF
Stephanie Miller Coulson 10/5/1964
First Middle Last Suffix Plaintiff DOB
Name(s) of All protected persons, including minor child/ren and DOB.
Laura Elizabeth Coulson 2119/1992
V.
DEFENDANT
Daniel Kamuela In
First Middle Last Suffix
Defendant's Address: Address Unknown
CAUTION:
E]Weapon Involved
El Weapon Present on the Property
0 Weapon Ordered Relinquished
DEFENDANT IDEN TIFIERS
DOB 1/26/1992 HEIGHT 51ft.8
SEX Male WEIGHT 170
RACE Unknown EYES Brown
HAIR Brown
SSN
DRIVERS
LICENSE #
EXP DATE STATE PA
The Court Hereby Finds: That it has jurisdiction over the parties and subject matter, and the Defendant will be provided with reasonable
notice and opportunity to be heard.
The Court Hereby Orders:
® Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found.
0 Except as provided in paragraph 3 of this order, Defendant shall not contact Plaintiff, or any other person protected under this
order, by telephone or by any other means, including through third persons.
® Additional findings of this order are set forth below. D em b c,- 31i Zo / o
Order Effective Date May 29, 2009 Order Expiration Date M 2012
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF
UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.A. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND
CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. A VIOLATION OF THIS ORDER MAY RESULT IN THE REVOCATION OF THE
SAFEKEEPING PERMIT, WHICH WILL REQUIRE THE IMMEDIATE RELINQUISHMENT OF YOUR FIREARMS, OTHER WEAPONS AND AMMUNITION TO THE
SHERIFF. PLAINTIFF'S CONSENT TO CONTACT BY DEFENDANT SHALL NOT INVALIDATE THIS ORDER WHICH CAN ONLY BE MODIFIED BY FURTHER
ORDER OF COURT. 23 Pa.C.S.A. § 6108(g).
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH
OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261-2262. IF YOU POSSESS A
FIREARM OR ANY AMMUNITION WHILE THIS ORDER IS IN EFFECT, YOU MAY BE CHARGED WITH A FEDERAL OFFENSE EVEN IF THIS PENNSYLVANIA
ORDER DOES NOT EXPRESSLY PROHIBIT YOU FROM POSSESSING FIREARMS OR AMMUNITION. 18 U.S.C. §922(g)(8).
Plaintiff or Protected Person(s) is/are:
[ ] spouse or former spouse of Defendant
[ ] parent of a child with Defendant
[X] current or former sexual or intimate partner with Defendant
[ ] child of Plaintiff
[ ] child of Defendant
[ ] family member related by blood (consanguinity) to Defendant
[ ] family member related by marriage or affinity to Defendant
[ ] sibling (person who shares parenthood) of Defendant
Defendant was served in accordance with Pa. R.C.P. 1930.4 and provided notice of the time, date and
location of the hearing scheduled in this matter.
Appearances by Parties and/or Counsel:
. Plaintiff appeared personally and is represented by: Jessica C. D. Holst, Esquire
. Defendant appeared personally and is unrepresented.
AND NOW, this 29th Day of May, 2009 the court having jurisdiction over the parties and the subject-
matter, it is ORDERED, ADJUDGED and DECREED as follows:
This order is entered by agreement without an admission. Without regard as to how the order was
entered, this is a final order of court subject to full enforcement pursuant to the Protection From
Abuse Act.
Plaintiffs request for a final protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten or attempt to use physical force that would
reasonably be expected to cause bodily injury to Plaintiff or any other protected person in any place
where they might be found.
2. Defendant is prohibited from having ANY CONTACT with Plaintiff either directly or indirectly, or
any other person protected under this order, at any location, including but not limited to any contact at
Plaintiffs or other protected party's school, business, or place of employment. Defendant is
specifically ordered to stay away from the following locations for the duration of this order.
Bible Baptist
201 W. Main St.
Shiremanstown, PA 17011
Dairy Queen
221 Penrose Pl.
Carlisle, PA 17013
3. The following additional relief is granted as authorized by §6108 of the Act:
Defendant is prohibited from stalking, as defined in 18 Pa.C.S.A. § 2709. 1, or harassing, as defined in
18 Pa.C.S.A. § 2709, the following family and household members of Plaintiff:
Name Relationship Address
Stephanie Coulson Mother
Andrea Coulson Sister
- The Defendant shall not damage, destroy, or dispose of in any manner, any property owned
jointly by the parties, or solely by the Plaintiff.
4. A certified copy of this Order shall be provided to the police department where Plaintiff resides and
any other agency specified hereafter:
Carlisle PD
Carlisle Barracks PSP
5. THIS ORDER SUPERSEDES ANY PRIOR PROTECTION FROM ABUSE ORDER OBTAINED
BY THE SAME PLAINTIFF AGAINST THE SAME DEFENDANT.
i eavr r 3! 7-010
6. All provisions of this order shall expire in 3-years on May 29, .
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A
FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23
PA.C.S.A. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION
AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. A
VIOLATION OF THIS ORDER MAY RESULT IN THE REVOCATION OF THE
SAFEKEEPING PERMIT, WHICH WILL REQUIRE THE IMMEDIATE
RELINQUISHMENT OF YOUR FIREARMS, OTHER WEAPONS AND
AMMUNITION TO THE SHERIFF. PLAINTIFF'S CONSENT TO CONTACT BY
DEFENDANT SHALL NOT INVALIDATE THIS ORDER WHICH CAN ONLY BE
MODIFIED BY FURTHER ORDER OF COURT. 23 Pa.C.S.A. § 6108(g).
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT
OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE
COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST
WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND
INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO
FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261-
2262. IF YOU POSSESS A FIREARM OR ANY AMMUNITION WHILE THIS
ORDER IS IN EFFECT, YOU MAY BE CHARGED WITH A FEDERAL OFFENSE
EVEN IF THIS PENNSYLVANIA ORDER DOES NOT EXPRESSLY PROHIBIT
YOU FROM POSSESSING FIREARMS OR AMMUNITION. 18 U.S.C. §922(g)(8).
NOTICE TO SHERIFF, POLICE AND LAW ENFORCEMENT OFFICIALS
The police and sheriff who have jurisdiction over Plaintiffs residence OR any location
where a violation of this order occurs OR where Defendant may be located, shall
enforce this order. The court shall have jurisdiction over any indirect criminal contempt
proceeding, either in the county where the violation occurred or where this protective
order was entered. An arrest for violation of paragraphs 1 through 2 of this order may be
without warrant, based solely on probable cause, whether or not the violation is
committed in the presence of the police or any sheriff. 23 Pa.C.S.A. §6113.
Subsequent to an arrest, and without the necessity of a warrant, the police officer or
sheriff shall seize all firearms, other weapons and ammunition in Defendant's possession
that were used or threatened to be used during the violation of the protection order or
during prior incidents of abuse and any other firearms in Defendant's possession.
The Sheriff of Cumberland County shall maintain possession of the firearms, other
weapons or ammunition until further order of this court.
When Defendant is placed under arrest for violation of this order, Defendant shall be
taken to the appropriate authority or authorities before whom Defendant is to be
arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and
signed by the police officer, sheriff OR Plaintiff. Plaintiffs presence and signature are
not required to file the complaint.
If sufficient grounds for violation of this order are alleged, Defendant shall be arraigned,
bond set, if appropriate and both parties given notice of the date of the hearing.
S ;?9 p>'
Date
Entered pursuant to the consent of Plaintiff and Defendant:
'?)V 6UJ4.14 5-2147 0 9 L"A Z --q NAy &?4'
Step anie M. Coulson Date i7 r V% A; 5 Date
Plaintiff
BY THE
Edward E. Guido, Judge
Laura E. Coulson
Daniel K. Ing
Plaintif. Defendant
essica C. D. Holst Date
Attorney for Plaintiff
MidPenn Legal Services
401 East Louther Street
Carlisle PA 17013
Distribution to:
MidPenn Legal Services, Attorney for Plaintiff -nn S?9?f
David Allen Henson, Pro Se Defendant
'-r-mav
4zax-ed and Mailed to PSP - s`a9?of
j;? i ? ?? ? - a ??,?
`,;J'.',
.,
Lebo, Regina
From: ra-jnetoperations@state.pa.us
Sent: Friday, May 29, 2009 11:26 AM
To: Lebo, Regina
Subject: PFAD Document Confirmation No.20093221 against ING, DANIEL
PFAD Document Confirmation No.20093221 against ING, DANIEL filed by COULSON, STEPHANIE
RECORD ACCEPTED BY CLEAN: 2009-05-29 11:25:21Z
s
Fred August Nehr, Esquire
fnehr ,,g'blolaw.com
Identification No.: 91676
GIBLEY AND McWILLIAMS, P.C.
524 N. Providence Road
Media, PA 19063-0807
(610) 627-9500
Attorney for Claimant, Bradco Supply
Corporation
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BRADCO SUPPLY CORPORATION
1646 West Chester Pike, Suite 9
West Chester, PA 19382
Claimant, :Civil Action No.: 09-3139 MLD Term
V.
SUTLIFF ENTERPRISES, INC.,
6462 Carlisle Pike
Mechanicsburg, PA 17050
Owner or Reputed. Owner,
and
NICHOLAS EVANOFF COMPANY,
997 Peiffers Lane
Harrisburg, PA 17109
Contractor.
AFFIDAVIT OF SERVICE
Commonwealth of Pennsylvania
SS
County of Delaware
I, Fred August Nehr, Esquire, counsel for Claimant Bradco Supply Corporation, hereby
being duly sworn, depose and state as follows:
1. I am the attorney for Bradco Supply Corporation, claimant in the above-captioned
proceedings, and submit this Affidavit pursuant to 49 P.S. § 1502(a)(2).
2. At 12:32 P.M. on May 22, 2009, Dauphin County Sheriffs Deputy served upon
Nicholas Evanoff Company notice of filing a mechanic's lien filed herein bearing the court term and
number and date of filing of the said claim, by personally handing the said mechanic's lien claim to
Ken Long at the place of business for Nicholas Evanoff Company located at 997 Peiffers Lane,
Harrisburg, PA 17109. A copy of the Sheriff's Return of Service is attached hereto.
3. At 11:05 A.M. on May 26, 2009, Dauphin County Sheriff s Deputy served upon
Sutliff Enterprises Inc. notice of filing a mechanic's lien filed herein bearing the court term and
number and date of filing of the said claim, by personally handling the said notice to Jack Benner
at Sutliff Enterprises Inc.'s place of business located at 13' and Paxton Streets, Harrisburg, PA
17105. A copy of the Sheriff's Return of Service is attached hereto.
GIBLEY MC %-wAMSI, P.C.
By:
Fr 4d A gust , Esquire
Date: June 1, 2009
Sworn to and subscribed
before me this I' day
of June, 2009.
N
v NOTARIAL SEAL
JENNIFER A ATWELL
NOtory Public
M "A
* )WMH, DELAWARE COUNTY
MY Cornndaion Expfrea Apr 10, 2011
the ?***rfff
MaryJane Sn??77der
ut
t
D
R E
t
ep
y
e
s
a
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania BRADCO SUPPLY CORPORATION
VS
County of Dauphin NICHOLAS EVANOFF COMPANY
Sheriffs Return
No. 2009-T-1388
OTHER COUNTY NO. 093139
And now: MAY 26, 2009 at 11:05:00 AM served the within MECHANICS LIEN CLAIM upon
SUTLIFF ENTERPRISES INC. by personally handing to JACK BENNER, PRESIDENT 1 true
attested copy of the original MECHANICS LIEN CLAIM and making known to him/her the contents
thereof at 13TH AND PAXTON STREETS HBG PA 17105
ALSO SERVED WAS NOTICE OF CLAIM
Sworn and subscribed to
before me this 26TH day of May, 2009
A!?
NOTARIAL SEAL
t JANE SNYDER, Notary Publi
ighspire, Dauphin County
mmission Expires Sept 1 2010
So Answers,
Sheriff of D u hin CJ?Wtg, ?
By
Deputy Sheriff
Deputy: R HOPKINS
Sheriffs Costs: $66.5 5/21/2009
R states Spnlyder
M E
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
BRADCO SUPPLY CORPORATION
VS
NICHOLAS EVANOFF COMPANY
Sheriffs Return
No. 2009-T-1388
OTHER COUNTY NO. 093139
And now: MAY 22, 2009 at 12:38:00 PM served the within MECHANICS LIEN CLAIM upon
NICHOLAS EVANOFF COMPANY by personally handing to KEN LONG 1 true attested copy of the
original MECHANICS LIEN CLAIM and making known to him/her the contents thereof at 997
PEIFFERS LANE HBG PA 17109
ESTIMATOR
Sworn and subscribed to
before me this 26TH day of May, 2009
Ao?
NOTARIAL SEAL
F JANE SN'I'DER, Notary Publi
ighspire, Dauphin County
mmission Expires LcZ 1 2010
So Answers,
y eAeo(-
Deputy: W CONWAY
Sheriffs Costs: $66.5 5/21/2009
Fll1 + _tr Y
2Q9 JUN -3
r.:
Fred August Nehr, Esquire
fnehr@p,ibleylaw.com
Identification No.: 91676
GIBLEY AND MCWILLIAMS, P.C.
524 N. Providence Road
Media, PA 19063-0807
(610) 627-9500
Attorney for Claimant, Bradco Supply
Corporation
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BRADCO SUPPLY CORPORATION
1646 West Chester Pike, Suite 9
West Chester, PA 19382
Claimant, :Civil Action No.: 09-3139 MLD Term
V.
SUTLIFF ENTERPRISES, INC.,
6462 Carlisle Pike
Mechanicsburg, PA 17050
Owner or Reputed Owner,
and
NICHOLAS EVANOFF COMPANY,
997 Peiffers Lane
Harrisburg, PA 17109
Contractor.
AFFIDAVIT OF SERVICE
Commonwealth of Pennsylvania
SS
County of Delaware
I, Fred August Nehr, Esquire, counsel for Claimant Bradco Supply Corporation, hereby
being duly sworn, depose and state as follows:
1. I am the attorney for Bradco Supply Corporation, claimant in the above-captioned
proceedings, and submit this Affidavit pursuant to 49 P.S. § 1502(a)(2).
2. At 12:29 P.M. on June 4, 2009, Dauphin County Sheriff's Deputy served upon
Nicholas Evanoff Company notice of filing a mechanic's lien filed herein bearing the court term and
number and date of filing of the said claim, by personally handing the said notice of filing a
mechanic's lien claim to Nicholas Evanoff at the place of business for Nicholas Evanoff Company
located at 997 Peiffers Lane, Harrisburg, PA 17109. A copy of the Sheriff's Return of Service is
attached hereto.
GIBLEY AND MCWILLIAMS, P.C.
By:
Date: June 9, 2009
Sworn to and subscribed
before me this 9"' day
of June, 2009.
N Public
NOTARIAL SEAL
JENNIFER A ATWELL
Notary Public
Tmmlly DIA BOROUGH. DELAWARE COUNTY
Commission Expires Apr 18, 2011
Jun. 9. 2009 12:28PM DAUPHIN COUNTY SHERIFF No.4722 P. 1
'if the ?$4erftf
Mary J a Wer Charles E. Sheafter
William T. Tully Mitt XRinehart
Solicitor
Dauphin County
Hamsbur& Pennsylvania 17101
ph: (717) 780.6590 fait: (717) 255-2869
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania BRADCO SUPPLY CORPORATION
VS
County of Dauphin NICHOLAS EVANOFF COMPANY
Sheriffs Return
No. 2009-T-1558
OTHER COUNTY NO.093139MCD
And now: JUNE 4, 2009 at 12:29:00 PM served the within NOTICE upon NICHOLAS EVANOFF
COMPANY by personally handing to NICHOLAS EVANOFF, OWNER 1 true attested copy of the
original NOTICE and making known to him/her the contents thereof at 997 PEIFFERS LANE HBO
PA 17109
SERVED NOTICE OF MECHANICS LEIN
Sworn and subscribed to
before me this 9TH day of June, 2009
lwt4w?
NOTARIAL SEAL
Y JANE SNYDEI? Notary Publi
Highspire. Dauphin County
ML Comrnissioo ire5 Se 1.2010
So Answers,
nsp
of Dauphin County, Pa.
By
Deputy Sheriff
Deputy: T WONG
Sheriffs Costs: $47.25 6/4/2009
OF THE RPCi TH'40TARY
2009 JUN 12 Pik 3: 4 0
VV?Y ii -/i !?1 T