Loading...
HomeMy WebLinkAbout01-1639MCCORKEL CONSTRUCTION SERVICES, INC., Plaintiff BLESSINGS QUALITY PAINTING, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 01- //.,df CIVIL TERM :COLLECTION 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 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 of 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, PA 17013 (717) 249-3166 MCCORKEL CONSTRUCTION SERVICES, INC., Plaintiff vi. BLESSINGS QUALITY PAINTING, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 01- ,//~ ~ CIVIL TERM :COLLECTION COMPLAINT 1. Plaintiff, McCorkel Construction Services, Inc., formerly McCorkel Homes and Remodeling, has a principal place of business .at 1405 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, Blessings Quality Painting, has a principal place of business at 5 Limekiln Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. On or about July 12, 2000, the Defendant provided to the Plaintiff an invoice detailing work to be performed and the cost for that work at Chainsaw Road. (Exhibit 1 ) 4. On or about July 2000, the Plaintiff provided the Defendant with $2,920.00 as partial payment for the verbal contract. 5. On or about August 2000, the Plaintiff provided the Defendant with an additional payment of $2,000.00 for a total paid amount of $4,920.00. 6. The total contract price amount for services was $6,690.00. 7. The paint contracted for was flat paint or stain. 8. The Defendant was advised in a timely manner that there was a deadline for the painting to be completed and that violation ol= the deadline would result in financial penalties to the Plaintiff. 9. As the deadline approached, the Defendant was advised that completion of the job was required; the Defendant absented himself from the Chainsaw Road job site. 10. The Defendant failed to complete the (x)ntracted painting for the Chainsaw Road property. 11. The Defendant refused to perform in a timely manner and thereby the Plaintiff faced potential penalty costs at $1,000.00 per day for delay. 12. As a result the Plaintiff substituted men from Plaintiff's construction crew to paint and sand until the Plaintiff could employ a professional painter to complete the work that Defendant refused to complete. 13. Plaintiff's substitute employees were pulled from their routine duties to paint and sand; therefore, Plaintiff lost $2,446.50 worth of construction work due to the substitution of employees. 14. Plaintiff employed a professional pai~ter, Ronald Smith, to complete the Defendant's work at an additional cost of $2,868.00. 15. The Defendant's failure to report to the property and complete the work contracted for in a timely manner breached the contract. 16. As a result of the Defendant's breach of contract, the Plaintiff incurred $5,314.50 increased cost to complete the same job, as Defendant contracted to complete. WHEREFORE, for all the above reasons, the Plaintiff, McCorkel Construction Services, Inc., requests judgment in their favor in the amount of $5,314.50 plus interest and cost of suit. Date Respectfully Submitted TURO LAIN OFFICES 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff d~ UO O~:bO~ Joe ~cCor~el ['/17) ~3-38~ p.d CALL (7t7) lS~,'lt74 BleMdag's ~ NAJIE: VERIFICATION I, Ron Turo, Esquire, attorney for the Plaintiff herein, have sufficient knowledge of the facts contained in this Complaint and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, based upon information received from the Plaintiff. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. A verification executed by the Plaintiflf will be filed of record as soon as it becomes available. Ron Turo, Esquire MCCORKEL CONSTRUCTION SERVICES, INC. Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COLrNTY, PENNSYLVANIA : NO. 01-1639 : CIVIL TERM BLESSINGS QUALITY PAINTING: Defendants : COLLECTION ANSWER AND COUNTERCLAIM 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. By way of further answer, the terms of the verbal contract were confirmed in writing and are consistent with the terms set forth in the invoice dated July 12, 2000 identified as exhibit 1 of Plaintiff's Complaint. 5. Admitted in part. It is admitted that on August 29, 2000 the Plaintiff provided the Defendant with an additional payment of $2,000.00 for services rendered pursuant to the terms set forth in Plaintiff's Exhibit 1. By way of further answer, the pmies agreed to a modification of the original terms of their agreement whereby three coats of paint and stain were to be applied instead of two coats, which had been originally agreed. The additional cost for the third coat was $850.00. This agreement was memorialized by the invoice dated August 29, 2000 a copy of which is attached hereto and incorporated herein and designated as Defendant's Exhibit 1. 6. Admitted. 7. Admitted. 8. Denied. It is specifically denied that the Defendant was advised in a timely manner that there was a deadline for the painting to be completed. By way of further answer, the Defendant was only advised of any deadline only one to two weeks before the home was to be completed pursuant to an alleged contract between Plaintiff and the homeowner. 9. Denied. By way of further answer, Defendant had advised the Plaintiff that it was impossible for him to complete his painting work until the house was properly trimmed. The trimming process began on July 10, 2000 and was not finished until the last week in August, a period when the Defendant painted rooms as the trim work was finished in each room. The Defendant also informed the Plaintiff and his other employees of the absolute need to have work completed in the home prior to brushing interior polyurethane as that process requires a completely dust free environment to be performed properly. At no time did the Plaintiff provide the Defendant with such an environment in which to complete his work. 10. Admitted in part, denied in part. It is admitted that the Defendant failed to complete the contracted painting for the Chain Saw Road property. By way of further answer, Defendant was advised on Thursday morning September 7, 2000 by Susan McC, orkel, that he was forbidden from returning to the job site and that he would be arrested if he repotted to the job site. At no time did the Defendant refuse to perform his work pursuant to the terms of the agreement. 11. Denied. It is denied that the Defendant refused to per['orm his work in a timely manner. By way of further answer, Plaintiff and his employees took approximately six to eight weeks to trim out the house, a process that normally takes one to two weeks. Plaintiff would have been in a position to satisfy any deadline that he imposed upon himself or was imposed upon him by a separate contract if the Plaintiff and his employees had completed their work in a timely fashion. 12. After reasonable investigation, the Defendant is without knowledge or information to form a belief as to the truth of the averment and it is therefore denied. 13. After reasonable investigation, the Defendant is without knowledge or information to form a belief as to the troth of the averment and it is therefore denied. 14. After reasonable investigation, the Defendant is without knowledge or information to form a belief as to the truth of the averment and it is therefore denied. 15. Denied. It is denied that the Defendant breached the contract. By way of further answer, any failure that the Defendant had to report to the property to complete his work was due to the specific instructions he received from the Plaintiff by Mrs. Susan McCorkel who advised him that he was forbidden from appearing on the job site and would be arrested if he reported to it. 16. After reasonable investigation, the Defendant is wit~tout knowledge or information to form a belief as to the troth of the averment and it is therefore denied. WHEREFORE, for the reasons said forth above, the Defendant requests that the Plaintiff's Complaint be dismissed. COUNTERCLAIM 17. The Defendant incorporates by reference the averment set forth in Paragraphs 1 through 16 of his Response to New Matter as if fully set forth herein at length. 18. Pursuant to the terms set forth in the Defendant's invoices dated July 12, 2000 (Plaintiff's Exhibit 1) and August 29, 2000 (Defendant's Exhibit 1) the Plaintiff was to pay to the Defendant an amount of $6,690.00 for materials and painting services rendered. 19. The Plaintiff made two installment payments toward satisfying this amount. These installment payments totaled $4,920.00. 20. The Plaintiff still owes the Defendant an amount of $1,770.00. 21. The Plaintiff's unilateral action of banning the Defendant from the job site was the only reason that the job could not be completed. WHEREFORE, for the reasons set forth above, the Defendant requests a judgement from this Honorable Court in the amount of $1.770.00, plus interest ~md costs of suit. Respectfully submitted, Jam, J. Kay)r, Ka3il and l}~own,~ P.C. 4 E Liberty Ave. Cm le, P~ 17013 (71'7) 243-7922 Residential Commercial Spray Palndng Roof Painting CALL (717) 258-1274 Blessing's Quality Painting 5 LIMEKILN ROAD * CARLISLE, PA 171)13 INVOICE To: CCOCI&,<, I-/oo-,~~ ~ DATE )ANT S EXHIBIT #1 VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my cotmsel arid not my own. I have read the statements made in this document ,'md to the extent that it is based upon information which I have ~.iven to my counsel, it is true and correct to the best of my kno~vledge, information and belief. To the extent that the conteuts of the statements are that of counseI, I have relied upon counsel in malting this Verification. I tmderstand that false statements hereiu are made subject to the penalties of 18 PA. C.S. § 4904, relating to unsworn falsification to authorities. CERTIFICATE OF SERVICE I hereby certify that a tree copy of the foregoing ANSVO'~R AND COUNTERCLAIM was served on Plaintiffs Counsel by First-class mail, postage prepaid, by forwarding a true and correct copy unto: Ron Turo, Esquire 32 South Bedford Street Carlisle, PA 17013 Date f// 4 East L Lib~ ~aye squire {~venue ' Loft Carlisle, PA 17013 (717) 243--7922 McCORKEL CONSTRUCTION SERVICES, INC., Plaintiff BLESSiNGS QUALITY PAiNTING, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-1639 JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant, Blessings Quality Painting, in the above matter. Defendant hereby demands a twelve jurorjury trial in the above captioned action. Dated: July.~YS, 2001 MARTSON ARDORFF WILLIAMS & OTTO By George B. Faller, Jr., Esquir~ I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Blessings Quality Painting CERTIFICATE OF SERVICE I, Melinda A. Hall, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ron Turo, Esquire TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO MelindatX. Hall Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 25, 2001 I1 VICCORKEL CONSTRUCTION SERVICES, INC., Plaintiff BLESSINGS QUALITY PAINTING, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 01-'1639 CIVIL TERM :COLLEC:TION PLAINTIFF'S ANSWER TO 'COUNTERCLAIM 17. No answer required. 18. Admitted. By way of further answer the Plaintiff was to pay this amount if the service was actually rendered in a timely and workman like manner. 19. Admitted. 20. Denied. By way of further answer the Plaintiff re-alleges his allegations that the Defendant, in fact, having not completed the job owes him the entire amount paid to him of $4,920.00 plus additional costs and damages. 21. Denied. Plaintiff re-alleges the contents of his original Complaint wherein he outlines the Defendant's actions which caused the E)efendant to fail to complete the contract in work in a timely manner pursuant to the contract between the parties. WHERFORE, for all the reasons set forth above, Plaintiff requests judgment in it's favor and respectfully requests this Honorable Court to dismiss the Defendant's Counterclaim. Respectfully Submitted TURO LAW OFFICES on Turo, Esquire 28 South Pitt Street Carliisle, PA 17013 (717) 245-9688 Attorney for Plaintiff CERTIFICATE OF SERVlCF I hereby certify that I served a true and cc, rrect copy of the Plaintiff's Answer to Defendant's Counterclaim upon James J. Kayer=, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the ~_~ day of ///~/~---~ ;~"~ , 2001, from Carlisle, Pennsylvania, addressed as follows: - / James J. Kayer, Esquire Kayer & Brown 4 Liberty Avenue Carlisle, PA 170,13 TURO LA~~ 'Rot Turo"~Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff MCCORKEL CONSTRUCTION SERVICES, 1NC. Plaintiff BLESSINGS QUALITY PAINTING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1639 CIVIL : CIVIL ACTION- LAW NOTICE OF HEARING TO: James M. Robinson, Esquire Turo Law Offices 28 S. Pitt Street Carlisle, PA 17013 George B. Failer, Jr., Esquire Martson, Deardorff, Williams & Otto, P. C. Ten E. High Street Carlisle, PA 17013 NOTICE IS HEREBY GIVEN that the undersigned Arbitrators appointed by the Court in the above-captioned matter will meet for the purpose of their appointment on Thursday, October 4, 2001, beginning at 1:00 o'clock p.m. in the Second Floor Hearing Room in the old Courthouse in Carlisle, Pennsylvania, at which time and place you may appear and be heard, together with and counsel, if you so desire. Date: August 15, 2001 Keith O. Brenneman, Esquire, Chairman Shaun Mumford, Esquire Douglas Lovelace, Jr., Esquire LAW OFFICES SNELBAKER. BRENNEMAN & SPARE CC: Court Administrator, Cumberland County MCCORKEL CONSTRUCTION SERVICES, INC., Plaintiff VS. BLESSINGS QUALITY PAINTING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-1639 CIVIL CIVIL ACTION- LAW IN RE: NONJURY TRIAl, ORDER AND NOW, this 3°'' day of May, 2001, pretrial conference in the above captioned matter is set for Monday, July 30, 2001, at 9:00 a.m. in Chambers of the undersigned. BY THE COURT, Ron Turo, Esquire For the Plaintiff James J. Kayer, Esquire For the Defendant Court Administrator :rlm SHess', J1 PRAEClPE FOR LISTING CASE FOR TRIAl (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( ) for JURY trial at the next term of civil court. ( × ) for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) McCorkel Construction Services, Inc. (Plaintiff) VS. (check one) (X) Assumpsit ( ) Trespass ( ) Trespass (Motor Vehicle) ( ) (other) Blessings Quality Painting (Defendant) VS. The trial list will be called on and Trials commence On Pretrials will be held on (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) Date: No. 01 -1 639 Civil Term x 2001 Indicatetheattorneywho willt~ caseforthepartywhofilestl3ispraecipe: Ron Turor Esquire Indicatetrialcounselforotherpartiesifknown: James J. Kayer, Esquire This case ~s ready for trial. Print Name: Ron Tur._o.~__E~.cLu±re Attorney for: Plaintiff SHERIFF'S RETURN - CASE NO: 2001-01639 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCCORKEL CONSTRUCTION SERVICES VS BLESSINGS QUALITY PAINTING REGULAR DAWN L. KELL Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BLESSINGS QUALITY PAINTINGthe DEFENDANT at 0020:10 HOURS, on the 23rd day of March at 5 LIMEKILN ROAD 2001 CARLISLE, PA 17013 by handing to JAMES BLESSING (OWNER) a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 10.00 .00 31.10 Sworn and Subscribed to before me this ~ ~ - day of ~ ~2~ ! A.D. P~o[hoHotary So Answers: R. Thomas Kline 03/26/2001 RON TURO Deputy Sheriff In The Court of Co.on Pleas of ClWWherland County, Pennsylvania No.___., 19 OATH We do sol---~ly swear (or affirm) :hat we will support, obey and defend :he Constitution of :he United States and the Constitution of :his Comznon- wealth and :ha: we will discharge the duties of our office with fidelity. Chairman AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make :he following award: (Note: If dm.-$es for delay are awarded, :hey shall be separately stated.) epplicable.) Date of Hearing:. Date of Award: · Arbitrator, dissents. (Insert name if Chairman NOTICE OF ENTRY OF AWARD Now, the day of , 19 , at , .It., :he above award was encered upon the docket and no:ice :hereof given b~--mail to :he par:les or their attorneys. Arbitrators' com~.ensa:ion to be paid upon appeal: $ By: Pro:honotaz7 MCCORKEL CONSTRUCTION SERVICES, INC. Plaintiff BLESSINGS QUALITY PAINTING, Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA · NO. 01-1639 CIVIL TERM · COLLECTION PETITION FOR APPOINTMENT OF ARBITRATORfi TO THE HONORABLE, THE JUDGES OF SAID COURT: I, James M. Robinson, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. 2. The above-captioned action is (or actions are) at issue. The claim of the Plaintiff in the action is $5,314.50. The counterclaim of the Defendant in the action is $1,770.00· The following attomeys are interested in the case as counsel or are otherwise disqualif~:i to sit as arbitrators: George B· Failer, Jr., Esquire William F. Martson, Esquire John B. Fowler, III, Esquire Daniel K. Deardorff, Esquire Thomas J. Williams, Esquire Ivo V. Otto, III, Esquire Edward L Schorpp, Esquire Carl C. Risch, Esquire Ron Turo, Esquire Robert J. Muldedg, Esquire Galen R. Waltz, Esquire James M. Robinson, Esquire Carol L. Cingranelli, Esquire Gerald J. Foulke, Esquire James J· Kayer, Esquire Mark A. Denlinger, Esquire WHEREFORE, YOUR Petitioner prays this Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, J ,a~es M. Robir~on, Esquire / MCCORKEL CONSTRUCTION SERVICES, INC. Plaintiff vi. BLESSINGS QUALITY PAINTING, Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1639 CIVIL TERM : COLLECTION ORDER OF COURT AND NOW, this ~/~,~ day of ~f~_//f , 2001, in consideration of the andf°reg°ing~4~/.~, .Petiti°n' .~ z~ ~-~'~-~ , ~-~/~ ~Es(:l., ~' ~/z,~_~_.~ar~itmtors" "~ ~' Esq, Esq., are appointed in the aboVe-captioned · action as prayed for. BY THE COURT, OATH In The Court of Common Pleas of C,~herland County, Pennsylvania ~o. ~(- I~ 3 ~ 19 We do sol---~[y swear (or affirm) that we will support, obey and defend the Constl~ution of the United States and the Cons~itu~ion of ~his Common- wealth and that we will discharge the duties of our-office with fidelity. We, the undersized arbitrators, having been duly appointed and swdrn (or affirmed), make :he following award: (Note: If d~m~ges for delay are awarded, they shall be separately stated.) , applicable.) Date of Hearing: Date of Award: . Arbitrator, dissents. (Insert name if NOTICE OF ENTRY OF AWARD award was entered upon :he docke: and notice ~b.~eof given b~-mail :o :he parties or =Seir a~to~e7s. Arbitrators' compemsation to be paid upon appeal: $ 09~_ ~ d)6~- z/~,- 7,,,°07 MCCORKEL CONSTRUCTION, SERVICES, INC., Plaintiff BLESSING'S QUALITY PAINTING, Defendant IN THE ,COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1639 CIVIL TERM COLLECTION PRAECIPE FOR ENTRY OF JUDGMENT TO: Prothonotary Cumbedand Coun~ Cou~house One Cou~house Square Cadisle, PA 17103-3387 Please enter judgment in favor of Plaintiff, McCorkel Construction Services, Inc. and against Defendant, BLESSING'S QUALITY PAINTING in the amount of $3,48t.16 pursuant to the award granted by the Board of Arbitrators dated October 4, 2001, as evidenced by the attached copy of the Notice of Entry of Award attached hereto and incorporated herein as Exhibit a. Principal $ 3,261.35 b. Interest $ 219,81 Total Amount: $ 3,481.16 Plus additional interest at $ .54 per diem for every day after November 6, 2001. Respectfully Submitted TURO LAW' OFFICES Date ~Ses M. Robi~on, Esquire outh Pitt E~treet Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff OATH In The Court of Common Pleas of C,~mherland County, Pennsylvania No. 1 37 !9 We do sol--~ly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Common- wealth amd that we will discharge the duties of our-office with fidelity. We, the undersigmed arbitrators, having been duly appointed and sworn (or affirmed), make :he following award: : .., ~ : (Note: If d~=ges for delay are awarded, ~hay shall be separately stated. ) applicable.) Date of Rearing: Date of Award: . Arbitrator, dissents. (Insert name if NOTICE OF ENTRY OF AWARD award was entered upon the docket and no:ice :hereof gi--~en b~mait to the parties or their attorneys. Arbitrators' compe~sation =o be paid upon appeal: Deputy R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, DUE TO BANKRUPTCY., NO ACTION TAKEN IN SlX MONTHS. Sheriff's Costs: Docketing $ 18.00 Poundage 1.25 Advertising Law Library .50 Prothonotary 1.00 Mileage 3.45 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee Advance Costs: $ 150.00 Sheriff's Costs: 64.20 Refunded to Atty on 64.20 85.80 3/21/03 Swom and Subscribed to before me this/eft' dayof~~L~ 2003 A.D. ~ a.~ Pr6th'onotary So Answers; R. Thomas Kline, Sheriff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO01-1639 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MCCORKEL CONSTRUCTION SERVICES INC Plaintiff (s) From BLESSING'S QUALITY PAINTING5 LIMEKILN ROAD CARLISLE PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY. (2) Y°u are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upun an subject to attachment is found in the possessiun of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount DueS3261.35 Interest Atty's Comm % Att3' Paid $118.10 Plaintiff Paid Date: MAY 24, 2002 REQUESTING PARTY: Name JAMES M ROBINSON ESQ Address: 28 SOUTH PITT STREET CARLISLE PA 17013 Attorney for: PLAINTIFF Telephone: 7172459688 Supreme Court ID No. L.L.$.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division ~-/ I