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Home My WebLink About01-1191MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, Plaintiff CARLISLE MOTEL AND CAMPGROUND, 1NC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 20oi- CIVIL ACTION - LAW NOTICE 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 a 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P. C. Solicitor for Plaintiff LAW OP'FiC[S SNELBAKER, BRENNEMAN ~ SPARE MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, Plaintiff CARLISLE MOTEL AND CAMPGROUND, INC. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- d/q/ ~_.~o CIVIL ACTION - LAW LAW OFFICES SNELBAKER, BReNNEMAN & SPARE COMPLAINT Middlesex Township Municipal Authority, by its Solicitor, Snelbaker, Brenneman & Spare, P. C., files this Complaint against Defendant Carlisle Motel and Campground, Inc. as follows: BACKGROUND 1. Plaintiff Middlesex Township Municipal Authority (the "Authority") is a duly authorized and existing municipal authority under the laws of the Commonwealth of Pennsylvania with a principal office and place of business located at 350 N. Middlesex Road, Carlisle, Middlesex Township, Cumberland County, Pennsylvania. 2. Defendant Carlisle Motel and Campground, Inc. is a Pennsylvania business corporation with a principal office and place of business located at 1075 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 3. Defendant is the owner of a parcel of mai estate located at 1075 Harrisburg Pike, Carlisle, in the Township of Middlesex, also identified as tax parcel No. 21 - 19-1637-011 (hereinafter the "premises"). 4. Plaintiff provides municipal water and sewer service in and to various locations throughout Middlesex Township. 5. Defendant is provided at its premises, for its and/or the occupants of Defendant's premises use and benefit, municipal water and sewer service by the Authority. LAW OFFICES SNELBAKER. BRENNEMAN & SPARe COUNT I 6. The averments of Paragraphs 1 through 5, inclusive, of this Complaint are incorporated by reference herein in their entirety. 7. At all times relevant hereto, specifically from July 2000 through January 2001, Plaintiff provided Defendant with water and sewer services at Defendant's premises. 8. The water and sewer services provided to Defendant by Plaintiff as described above were provided in accordance with the terms, conditions and requirements of applicable rules, rates and regulations as established by the Authority. 9. Defendant has consistently failed and refused to pay Plaintiff in full for charges assessed Defendant for water and sewer services provided Defendant at Defendant's premises for the period of July 2000 through January 2001 despite repeated requests to do so. 10. Defendant has failed and refused to pay the total amount of $21,923.52 due and owing Plaintiff for water and sewer services provided the premises from July 2000 through January 200 I, which sum includes applicable late charges or penalties assessed in accordance with rules, rates and regulations of the Authority. 11. The amounts billed by Plaintiffto Defendant for water and sewer services provided Defendant's premises were never objected to by Defendant as being inaccurate. 12. The amounts billed by Plaintiffto Defendant for water and sewer services provided Defendant's premises were fair, reasonable and never objected to by Defendant. 13. The amounts due and owing Plaintiffby Defendant as set forth in Paragraph 10, above, were billed to Defendant on a monthly basis, which bills contained a statement of current monthly charges due together with an indication of any previous balance due on Defendant's account for water and sewer services provided together with applicable penalties. A true and correct copy of Defendant's account statement with amounts claimed to be due as set forth in this Complaint, is attached hereto and incorporated by reference herein as "Exhibit A". 14. Defendant's failure timely to pay for water and sewer services provided Defendant's premises is a material breach of Defendant's express and/or implied obligation to pay for same in accordance with Plaintiffs applicable rates, rules and regulations. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $21,923.52 together with interest and costs of this suit. LAW OFFICES SNELBAKER, BRENNEMAN & SPARE COUNT II (In the alternative to Count I) 15. The averments of Paragraphs 1 through 14, inclusive, of this Complaint are incorporated by reference herein in their entirety. 16. The water and sewer services provided by Plaintiffto Defendant at Defendant's premises were not provided by Plaintiff to Defendant as a gratuity. 17. The charges for the water and sewer services as more fully set forth in Court I of this Complaint were fair, reasonable, customary and never objected to by Defendant. 18. Defendant wrongfully secured benefits from the use of the water and sewer services provided Defendant's premises that would be unconscionable for Defendant to retain. 19. Defendant has been unjustly enriched at the expense of Plaintiff in the amount of $21,923.52. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $21,923.52 together with interest and costs of this action. SNELBAKER, BRENNEMAN & SPARE, P. C. Date: March 1, 2001 Keith O. Breuneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (7 l 7) 697-8528 Solicitor for Plaintiff Middlesex Township Municipal Authority LAW OFFICES SNELBAKER, BRENNEMAN & SPARE -4- Date Water Sewer Total 02/06/01 BL 2,325.96 1,150.23 3,476.t9 02/05/01PE 141.88 70.86 212.74 01/05/01 aL 1,418.76 708.63 2,127.39 ol/05/01PE 179.68 89.26 Z68.94 !2/06/00 BL 1,796.76 892.63 2,689.39 12/05/00 PE 194.80 96.0Z E91.42 12/04/00 PP -367.79 -204.26 -572.07 12/04/00 PY -2,927.93 0.00 -2,927.93 11/03/00 GL 1,947,96 966.23 2,914.19 11/03/00 PE 194.80 95.6Z 291,42 10/06/00 BE t,947.96 966.23 2,914.19 10/05/00 PE Open Be1 Reference 22,217.9t 8[LLZNG 2001/JANUAF 18,741.72 16,528.98 BILLING 2000/DEC. 16,401,59 16,132.65 BILLING 2000/NOV, 13,443.26 13,151.84 13,723.91 16,651.84 BILLING 2000/OCTOBE 13,737.05 13,446023 61LL~NG 2000/SEPT. ;:';;~';-'~'-~;~-'~;;-'-;~;'~;"*'.:::~ Current Account Master Record .."" ' '' ..... :' 02/20/2001 .... ~: ........... ;;.~:;:~;:.' ..... i::~;[ ACcount Info ~ Meter & F~nanci~l Info iici Trans&ction$ query for ~cct; 00204 :.'.'5 ~:~: 172.99 107.66 280,~$ 10~532,04 }~( 09/12/00 PP -622.77 -289.86 -812.63 10,251.39 i!!i:l 09/12/00 PY -5,672.47 0.00 -5,672.47 11,064.02 ::!:::lj.!~!~ 09/07/00 PE 194.80 Press 96.62 <F1>291'42to exit 16,736.49 ":~:f St: PA Z~13: 17013__ P: -__-__ ~.102,20/2001 Current Account ~ster Record ~' ' ':"" .... ~ .' ..... . ' Account' ~:~:~Inf~ I I Meter & F~ne~l'~'n~'~ ...... Transactions query for acc,: 00204 Ty Water Sawer Total Open Be1 Reference 08/03/00 BL 2,174.76 1,076.63 3~251,39 16,&45.07 BILLING 2000/AUGUST 08/03/00 BL 1,g~7.96 966.23 2,914,19 13,193.68 ~ZLLZNG 2000/JULY 08/02/00 PE 1~7.24 92.94 280.18 10~279..49 07/06/00 PE 140.73 100.30 241.03 7,197.52 07/08/00 P¥ -2,500.00 0.00 -2,500.00 6,956,49 06/16/00 PP -149.44 -74.$4 -223.98 9,456.49 06/16/00 PY -2,376.02 0.00 -2,376.02 9,660.47 06/08/00 BL 2,023.56 1,003.05 3,026.$9 12,056.49 BILLING 2000/MAY 06/05/00 PE 149.44 74.§4 223.98 9,029.90 05712/00 PP -366.92 -182.20 -549.12 8,805.92 05/12/00 PY -2~450.88 0.00 -2,450.88 9,355.04 05/04/00 BL 1,494.36 745.43 2,~39.79 11,805.92 BILLING 2000/APRIL 05/03/00 PE 179.68 89.25 208.94 9,506.13 04/04/00 8L 1,796.76 892.63 2,689.39 9,297.19 BILLLING MARCH/2000 Press <Fl> to exit St: PA Zip: 17013 P: . .- -__ <F9> - Help "EXHIBIT A" VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4909 relating to unswom falsification to authorities. I verify that I am authorized to execute this Verification on behalf of the Plaintiff in my capacity as Operations Manager. ' l{ory :[yrorrison,/Operations Manager ~ Middlesex ToF~nship Municipal Authority Date: Iqarch 1, 2001 LAW OFFICES & SPARE SHERIFFIS RETURN CASE NO: 2001-01191 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDDLESEX TOWNSHIP MUNICIPAL VS CARLISLE MOTEL AND CAMPGROUND REGULAR RICHARD SMITH , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE CARLISLE MOTEL AND CAMPGROUND INC DEPENDANT , at 0014:07 HOURS, at 1075 HARRISBURG PIKE CARLISLE, PA 17013 RAYMOND CASHILL (OWNER) a true and attested copy of on the 5th day of March Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 2001 by handing to COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 3 Affidavit Surcharge 10 31 O0 i 0 00 00 O0 10 Sworn and Subscribed to before me this /~ ~ day of So Answers: R. Thomas Kline 03/06/2001 SNELBAKER, By: B~ARE iff MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, Plaintiff CARLISLE MOTEL AND CAMPGROUND, INC., Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-1191 CIVIL TERM : CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT UPON DEFAULT PURSUANT TO Pa.R.C.P. 1037(b) TO THE PROTHONOTARY: Please enter judgment against Defendant Carlisle Motel And Campground, Inc. and in favor of Plaintiff Middlesex Township Municipal Authority in the amount of $21,923.52 together with interest and costs of this action due to Defendant's failure to file within the required time a pleading to the Complaint in this action. A certified copy of the Complaint containing a notice to defend was served upon Defendant on March 5, 2001. I hereby certify that written notice of intention to file this Praecipe was mailed to the Defendant (the party against whom judgment is to be entered) for failure to plead to the Complaint and at least ten days prior to the date of the filing of this Praecipe. A copy of the written notice mailed to the Defendant on April 3, 2001 is attached hereto and incorporated by reference herein as "Exhibit A". SNELBAKER, BRENNEMAN & SPARE, P. C. LAW OFFICES SNELBAKER, BRENNEMAN & SPAre Date: April 17, 2001 BY: I~[~/~ ~ Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Middlesex Township Municipal Authority CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Carlisle Motel and Campground, Inc. 1075 Harrisburg Pike Carlisle, PA 17013 Date: Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Plaintiff LAW OFFICES SNELBAKER, BRENNEMAN & SPAre MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, Plaintiff CARLISLE MOTEL AND CAMPGROUND, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-1191 CIVIL TERM : CIVIL ACTION - LAW TO: Carlisle Motel and Campground, Inc., Defendant Date of Notice: April 3, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 LAW OFFICES SNELBAKER, BRENNEMAN & SPARE SNELBAKER, BRENNEMAN & SPARE, P. C. Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Plaintiff EXHIBIT A CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Carlisle Motel and Campground, Inc. 1075 Harrisburg Pike Carlisle, PA 17013 Date: April 3, 2001 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPA~, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Plaintiff SNELBAKER, BRENNEMAN SPARE IN THE COUI~ OF ~ P~AS OF ~ (~(XIN'PY, PI~i~3/LVANIA MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY, Plaintiff V. CARLISLE MOTEL AND CAMPGROUND, Defendant TO THEPROTHONOTARY OF THESAID COURT: CIVIL D13IISION : File No. 2001-1191 : Amount Due $21,923.52 : Interest 6% per annum from 4/17/01 : Atty's Comm N/A ($109.61/mo.) INC.; Costs The undersigned hereby certifies that the below does not arise out of a retail installr~nt sale, contract, or account based on a confession of judgnent, 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. PRAECIPE FOR F~ECUTION Issue writ of execution in the above matter to the Sheriff of County, for debt, interest and costs upon the following described property of the defendant(s) PRA~CIPE FOR ATTAC~[~T EX~CUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attacbraent 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) Any and all bank accounts, checking accounts, savings accounts, fund accounts and any other accounts title in the name o~ Carligle Motol And Campground, Inc., i~cluding, but not lJm~te~ ~o, Fnrm~r Keystone Financial Account No.0001307738, at M&T Bank, Garnishee, One West High Street, Ca~lisle, PA ]7013 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exh/bit. DATE: May, 14, 2001 Signature: //~F,~-~ Print Name: Address: K~b O Rr~nn~maD, Esql]ir~ 44 W. Main Street Mechanicsburq PA 17055 Attorney for: Plaint{ ff Telephone: 717-697-8528 Supreme Court ID No.: 47077 Notes: If real property, supply six copies of description including iraprovements and an original and copy of affidavit of ownership PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. SHERIFF'S RETURN - CASE NO: 2001-01191 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GARNISHEE MIDDLESEX TOWNSHIP MUNICIPAL VS CARLISLE MOTEL AND CAMPGROUND And now BRIAN BARRICK Cumberland County, Pennsylvania, to law, at 0014:01 Hours, on the , Sheriff or Deputy Sheriff of who being duly sworn according 17th day of May , 2001, attached as herein commanded all goods, chattels, moneys of the within named DEFENDANT CARLISLE MOTEL AND CAMPGROUND INC hands, possession, or control M & T BANK 1 WEST HIGH STREET rights, debts, of the within named Garnishee credits, and , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TAMMY SEIBERT (CUSTOMER SERVICE) personally 3 true and attested copies of the within COMPLAINT & NOTICE and made the contents thereof known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So answers. R. Thomas Kline ~:~.:~ Sheriff of~umberla 05/18/2001By t D~uepu t~SheL i f ~~ Sworn and subscribed to before me SHERIFF'S RETURN CASE NO: 2001-01191 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND - GARNISHEE MIDDLESEX TOWNSHIP MUNICIPAL VS CARLISLE MOTEL AND CAMPGROUND And now BRIAN BARRICK Cumberland County of Pennsylvania, to law, at 0014:01 Hours, on the 17th day of May , as herein commanded all goods, chattels, rights, debts, moneys of the within named ADD'L DEFENDANT, M & T BANK hands, possession, or control of the within named Garnishee 1 WEST HIGH ST ,Sheriff or Deputy Sheriff of who being duly sworn according 2001, attached credits, and , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TAMMY SEIBERT (CUSTOMER SVC) personally three copies of interogatories together with 3 true the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this R3~W day J_z~ A.D. ! notary R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo By Deputy Sheriff and attested copies of the within WRIT OF EXECUTION/INTERRO and made SHERIFF'S RETURN CASE NO: 2001-01191 P COMMONWEALTH OF PENNSLYVANIA COLrNTY OF CUMBERLAND - GARNISHEE Amended MIDDLESEX TOWNSHIP MUNICIPAL VS CARLISLE MOTEL AND CAMPGROUND And now DOUG DONSEN Cumberland County of to law, at 0013:00 Hours, on the as herein commanded all goods, chattels, moneys of the within named DEFENDANT CARLISLE MOTEL AND CAMPGROUND INC hands, possession, or control of M & T BANK 1 WEST HIGH ST 4th day of June , __ rights, debts, ,Sheriff or Deputy Sheriff of Pennsylvania, who being duly sworn according 2001, attached credits, and the within named Garnishee , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TAMMY SEIBERT (CUSTOMER SERVICE) personally three copies of interogatories together with 3 true and attested copies of the within COMPLAINT & NOTICE and made the contents there of known to Her Sheriff's Costs: Docketing Service .00 Affidavit .00 Surcharge .00 .00 Sworn and subscribed to before 2~ ~ day of ~:- ~ this P~o~honot ary R. Thomas Kline Sheriff of Cumberland County 00/00/0000 MIDDLESEX TOWNSHIP iMUNICIPAL : AUTHORITY, : Plaintiff : CARLISLE MOTEL AND CAMPGROUND, INC., Defendant and M & T BANK, also known as Manufacturers And Traders Trust Company, Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-1191 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO THEPROTHONOTARY: Please mark the judgment entered in favor of Middlesex Township Municipal Authority and against M & T Bank, also known as Manufacturers and Traders Trust Company, Garnishee emered on July 9, 2001 satisfied upon your docket and indices. SNELBAKER, BRENNEMAN & SPARE, P. C. Date: August 1,2001 BY: ~/"~/~ ' Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Solicitor for Middlesex Township Municipal Authority CERTIFICATE OF SERVICE I, KEITH O. BKENNEMAN, ESQUIRE, hereby certify that I have on the below dar, e, caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL~ POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Christine Alianello Legal Department M & T Bank P. O. Box 708 Altoona, PA 16603 Carlisle Motel & Campground, Inc. 1075 Harrisburg Pike Carlisle, PA 17013 M&T Bank One West High Street Carlisle, PA 17013 LAW OFFICES SNELBAKER, BRENNEMAN & SPARE Date: August 1,2001 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P.O. Box318 Mechanicsburg, PA 17055 (717) 697-8528 Solicitors for Plaintiff Middlesex Township Municipal Authority R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage i. 49 Advertising ~ Law Library .50 Prothonotary ~.. 00 Mileage 6.35 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 76.34 Advance Costs: 150.00 Sheriff's Costs: 76.34 73.66 Refunded to Atty on 7/1/02 Sworn and Subscribed to before me this io~ day of~.~ 2002 A'D' pr~n~ta~y~ )'l~"~t' ',~ So Answers; (~ ~ · mas Kline, Sheri~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland TO satisfy the debt, interest and costs due from Carlisle Motel and Campground, Inc. NO. _01-1191 CIVIL ~ TE~ CIVIL ACTION - LAW COUNTY: Middlesex Township Municipal At]thority PLAINTIFF(S) 1075 Harrisburq Pike, Carlisle, Pa. 17013 (1) You are directed fo levy upon the property of the defendant(s) and to sell DEFENDANT(S) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ M & T Bank, Garnishee One West Hiqh Street, Carlisle, Pa. 17013 .~ Pnllc~q' Any and ~11 hank ec'r'n~n~-~, ¢'hc, c'king ~c'r'nllnfq, ~.wving~ ~cCC~l~n~-s, find accounts and any other accounts title in the name of Carlisle Motel ~,'~'~: and Campground, Inc., including but not limited to former Keystone Financial Account No. 0001307738 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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) II property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify him/he rthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $21,973.52 L.L. ~1% Der ar~zum from nterest 4/17/01( $109.61 Mo, ) Due Prothy Atty's Comm % N/A Other Costs Atty Paid 103,60 SN. 5N 1.00 Plaintiff Paid Date: May 14, 2001 REQUESTING PARTY: NameKe~h O. Brenneman. Esq. Address: 44 W~t lv/.-~n ~-r~=~=~ Mechanicsburq, Pa. 17055 Attorney for: Plaintiff Telephone: (717) 697-8528 Supreme Court ID No. 47077 by: Curtis R. Lona Prothonotary, Civil Division Deputy