HomeMy WebLinkAbout10-6923SHERIFF'S OFFICE OF CUMBERLAND
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Robert Allen Hinkle (et al.)
vs.
Bryce A. Myers (et al.)
SHERIFF'S RETURN OF SERVICE
11/02/2010 05:47 PM - William Cline, Corporal, who being duly sworn according to law, states that on November 2,
2010 at 1247 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Cindy Lee Myers, by making known unto Kevin Duffy, adult in charge at 37 Shepherd
Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at thsame time handing to
him personally the said true and correct copy of the same. SIC
CLINE, D
11/02/2010 05:47 PM - William Cline, Corporal, who being duly sworn according to law, states that on November 2,
2010 at 1247 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Bryce A. Myers, by making known unto Kevin Duffy, adult in charge at 37 Shepherd
Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to
him personally the said true and correct copy of the same.
A -
U NTY
Case Number
2010-6923
SHERIFF COST: $55.24
SO
CLINE, DEPUTY
November 04, 2010
RONNY
R ANDERSON, SHERIFF
.. r Ms -
;c Ceic-r;.5uit? ?h2r'f, T'2<:.csot: !?i?.
ROBERT A. HINKLE and
LUANN HINKLE,
Plaintiffs
V.
BRYCE A. MYERS and
CINDY L. MYERS,
Defendants
. tyF
: THE COURT OF COA
: CUMBERLAND COU:
NO. 2010 - 6923 CI`
CIVIL ACTION - LAI
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against
IN PLEAS OF
, PENNSYLVANIA
TERM
claims set forth in the
following pages, you must take action within twenty (20) days after this complaint, order and
notice are served, by entering a written appearance personally orb attorney and by 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 judgment may be entered
against you by the court without further notice for any money claim d 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 LAWY R AT ONCE. IF YOU
DO NOT HAVE -A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH FORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, HIS OFFICE MAY BE
ABLE TO PROIVDE YOU WITH INFORMATION ABOUT IGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A EDUCED FEE OR NO
FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
WE ARE A
BE
Americans with Disabilities
Act of 1990
The Court of Common Pleas of Cumberland County is required
Americans with Disabilities Act of 1990. For information about accessi
accommodations available to disabled individuals having business before
office. All arrangements must be made at least 72 hours prior to any hearing
You must attend the scheduled conference or hearing.
oy law to comply with the
ile facilities and reasonable
ie court; please contact our
or business before the court.
2
ROBERT A. HINKLE and
LUANN HINKLE,
Plaintiffs
V.
BRYCE A. MYERS and
CINDY L. MYERS,
Defendants
: THE COURT OF CO)
: CUMBERLAND COU
NO. 2010 - 6923 CI1
CIVIL ACTION - LAI
COMPLAINT
AND NOW9 this _ day of November, 2010, comes t
HINKLE and LUANN HINKLE, Husband and Wife, by and throug
McKnight, P.C. and make the following Complaint against the Defen
and CINDY L. MYERS, averring as follows:
1. Plaintiffs, Robert A. Hinkle and Luann Hinkle, are adu
Shepherd Road, Newville, Cumberland County, Pennsylvania 17241.
2. Defendant Cindy L. Myers is an adult individual now
Shepherd Road, Newville, Cumberland County, Pennsylvania 17241.
3. Defendant Bryce A. Myers is the son of Defendant Cir
adult individual now or formerly residing at 37 Shepherd Road, Nev
Pennsylvania 17241.
4. Defendant Cindy L. Myers formerly owned the real
Road, Newville, Pennsylvania (hereinafter the "Property"), with her
Myers.
5. In 2009, Defendant Cindy L. Myers and her former
divorce proceedings, had fallen behind in their mortgage obligati4
and were facing a foreclosure action by Washington Mutual Bank
Docket No. 2008 - 3342.
ON PLEAS OF
Y, PENNSYLVANIA
TERM
Plaintiffs, ROBERT A.
their attorneys, Irwin &
BRYCE A. MYERS
individuals residing at 29
formerly residing at 37
L. Myers, and is also an
Cumberland County,
located at 37 Shepherd
husband, Steven W.
were involved in
secured by the Property,
ed at Cumberland County
6. To assist the Defendants, Plaintiffs loaned sufficient)
satisfy the mortgage deficiency, stop the foreclosure action, make c
payments, and purchase Christmas gifts.
7. As part of the agreement with Defendants, Plaintiff;
retirement fund or account in the name of Plaintiff Luatin Hinkle,
savings account, and obtained a certified check payable to "Washingt
of $16,051.68. True and correct copies of the certified check dated T
payable to "Washington Mutual" in the amount of $16,051.68, as well
Plaintiff Robert A. Hinkle, are attached hereto and incorporated herein
8. At the time of payment of the mortgage deficiency by P
the parties would later sign documentation evidencing the loans at
terms.
funds for Defendants to
monthly mortgage
withdrew funds from a
ted said funds into a
Mutual" in the amount
-ch 30, 2009, and made
> bank receipt signed by
Exhibit "A."
iffs, it was agreed that
establishing repayment
9. At the time of payment of the mortgage deficiency by Plaintiffs, it was also
understood that that Defendant Cindy L. Myers would retain ownership of the Property after her
divorce thereby providing collateral for the repayment of the funds loaned by Plaintiffs.
10. As a direct and proximate result of the funds loaned y Plaintiffs, the mortgage
deficiency was satisfied and the foreclosure judgment docketed at C Berland County Docket
No. 2008-3342 was marked vacated. A true and correct copy of the Praecipe to Vacate
Judgment filed on April 14, 2009 at Cumberland County Docket No. 2008-3342 is attached
hereto and incorporated herein as Exhibit "B."
11. Defendant Cindy L. Myers was subsequently able t resolve and finalize her
divorce and transfer the Property into her name.
12. One day later, Defendant Cindy L. Myers transferred
of both Defendants and then obtained a new mortgage loan. A true
recorded Deed for the Property dated September 24, 2009, is attach
herein as Exhibit "C."
Property into the name
correct copy of the last
hereto and incorporated
2
13. Despite repeated requests for Defendants to sign d
repayment terms of the loaned funds and securing the interests of
Defendants have failed and refused to respond to Plaintiffs.
COUNT I - BREACH OF CONTRACT
14.
cuments establishing the
in the Property,
The averments of paragraphs one (1) through thirteen (13) of this Complaint are
made a part hereof and incorporated herein by reference.
15. Defendants have verbally acknowledged both the recei t of direct funds loaned to
them and the benefit of monies paid on their behalf by Plaintiffs.
16. Defendants have also verbally acknowledged that laintiffs would incur tax
liabilities and fees for the early withdrawal of retirement funds, and that Defendants would be
responsible for said tax and fee consequences.
17. Despite repeated requests by Plaintiffs, Defendants ave refused and failed to
either sign documents securing the interests of Plaintiffs in the Property, or to begin to repay to
Defendants the expenses incurred by Plaintiffs or the monies loaned b Plaintiffs on behalf of the
Defendants.
18. Defendants have breached their agreements with Plaintiffs by failing or refusing
to either sign documents securing the interests of Plaintiffs in the Property, or to begin to repay
the monies loaned by Plaintiffs.
19. In order to assist Defendants in retaining the Property and meeting their financial
obligations, Plaintiffs have loaned the following monies and incurred the following expenses:
Payment to Washington Mutual Bank $16,051.68
Income tax penalty for early withdrawal
from Plaintiffs' retirement fund 3,0 5.00
Payment toward Defs.' monthly mortgage 570.00
Cash For 2007 and 2008 Christmas gifts 3 0.00
Filing Fees 2.00
Sheriff's Service Fees 1 0.00
TOTAL $209198.68
3
20. Despite repeated demands, Defendants continue
documents securing the interests of Plaintiffs in the Property, or to
loaned by Plaintiffs
21. Plaintiffs are entitled to certain damages, including
expenses outlined above, as well as interest and any additional
litigation.
WHEREFORE, the Plaintiffs, Robert A. Hinkle and Luann
that this Honorable Court enter judgment against Defendants in the
One Hundred Ninety-Eight and 68/100 ($20,198.68) Dollars, plus
interest, and all other and further relief that this Honorable Court de
COUNT II - UNJUST ENRICHMENT
22. The averments of paragraphs one (1) through twenty-(
are made a part hereof and incorporated herein by reference.
refuse to either sign
;in to repay the monies
not limited to, those
associated with this
e, respectfully request
t of Twenty Thousand
additional costs, late fees,
fair and just
(21) of this Complaint
23. Both Defendants accepted and actively used monies loaned by Plaintiffs and
received the benefit of monies paid by Plaintiffs on behalf of the Defendants, by accepting cash
from Plaintiffs and by directing Plaintiffs how and where payments should be made on behalf of
the Defendants.
24. Plaintiffs conferred benefits on the Defendants by
money needed to satisfy mortgage and other financial obligations and
25. Defendants have received the benefits of the money lc
and profited thereby through the payment of mortgage and other
them to borrow the
organize their finances.
to them by Plaintiffs,
obligations.
4
26. It is and continues to be inequitable for Defendants to
from Plaintiffs and the benefit of the paid obligations while failing
Plaintiffs.
27. As a result of Defendants' failure to either sign doci
of Plaintiffs in the Property, or to begin to repay the monies loaned
incurred out-of-pocket expenses of at least $20,198.68, as well as at
benefit of the use of the funds loaned to Defendants or paid on their 1
WHEREFORE, the Plaintiffs, Robert A. Hinkle and Luann
that this Honorable Court enter judgment against Defendants in the
,etain the monies loaned
refusing to reimburse
nts securing the interests
Plaintiffs, Plaintiffs have
.ey fees, interest, and lost
respectfully request
of Twenty Thousand
One Hundred Ninety-Eight and 68/100 ($20,198.68) Dollars, plus anyl additional costs, late fees,
interest, and all other and further relief that this Honorable Court deems fair and just.
Respectfully
IRWIN & Mc KNIGHT, P.C.
By: '
Douglas . Mille , Esquire
Supreme Court ID # 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsyly a 17013
(717) 249-2353
Dated: November, 2010 Attorney for Plain iffs
5
VERIFICATION
The foregoing document is based upon information which
counsel and ourselves in the preparation of this action. We have read
document and they are true and correct to the best of our knowledge,
understand that false statements herein made are subject to the penal
4904, relating to unworn falsification to authorities.
ROBERT A.
LYYANN
been gathered by our
statements made in this
and belief. We
of 18 Pa.C.S.A. Section
Date: November 4, 2010
EXHIBIT "A"
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11'0000? 12 144110-1.1:0 1 100 704 21:0 1EDO I;
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Walnut Bott om
1166 Walnut Bottom Road
Carlisle P 17013
Inquiries a11: 717-249-4666
Acct XXXXX X946 HINKLE,LUANN
Eff: 03/30 09 Date: 03/30/09
Tlr: 1721 - Time: 11:42am
Withdrwl f rom REGULAR SAVINGS 00
Prev Bal: 17,073.41
Amount: 16,051.68
New Bal: 1,021.13
Seq: #224409
Check Disb ursed -16,051.68
WASHINGTO MUTUAL
Ref rumba 00 417147
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ID Sourc :
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SigCa d
? Known
Other
E-Statem nt Change! Starting March 1st
eStateme is will include a full calendar
month. Sign up today if you do not
receive eStatements!
LUANN H
EXHIBIT "B"
SHAPIRO & DeNARD , LLC
BY: ILANA ZION, ESQ J IRE
ATTORNEY I.D. NO: A Bar # 87137
3600 HORIZON DRIVE SUITE 150
KING OF PRUSSIA; PA 19406
TELEPHONE: (610)278- 6800
S & D FILE NO.08-03 008
JPMorgan Chase Bank,, National Association,
successor in interest to ashington Mutual
Bank fWa. Washington utual Bank, FA
PLAINTIFF
VS.
Steven Wayne Myers Oa Steven W. Myers
and Cindy Lee Myers a 4a Cindy L. Myers
. DEFENDANTS
TO THE PROTHOT
Kindly mark the Jud
without prejudice to
COURT OF COMMON PLEAS
CUMBERLAI?D COUNTY
NO: 2008-3342 CIVIL TERM
KY:
entered on July 22, 2008 in the above
iff.
SHAPIRO & DENARDO,
BY:
Ilana Zion,
action vacated
'F
I, ILANA ZION, ES,
correct copy of the m
following parties via
Steven Wayne Myers
111.6 Karen Drive
Carlisle, PA 17013
Cindy Lee Myers aka
37 Shepherd Road
Newville, PA 17241
CERTIFICATE OF SERVICE
RE, hereby certify
that
Praecipe to Vacate
class mail, postage prepaid:
Steven W. Myers
,dy L. Myers
I
at on I (served a true and
Mortgago oreclosure Judgment upon the
I
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SHAPIRO & DENAROO, LLC
BY:
ILANA ZIO;
Attorney for
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EXHIBIT "C"
`X\
This Deed
MADE THE 24`h day of September in the year of our Lord
(2009).
BETWEEN CINDY L. MYERS, married woman, of Cumberland
GRANTOR herein,
A
N
VI!?i01VUwd?V
PARCEL NO. 30-1$-1683-051
D
CINDY L. MYERS, married woman, and BRYCE A
Cumberland County, Pennsylvania, GRANTEES herein.
thousand and nine
, Pennsylvania,
, single man, of
WITNESSETH, that in consideration of ONE AND XX/I00 ($1'.00 Dollar, in hand paid,
the receipt whereof is, hereby acknowledged, the said grantor does hereby grant and
convey to the said grantees, as joint tenants with the right of survivorship.
ALL THAT CERTAIN tract or lot of land situate in Nort Newton Township,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and
described as follow, to wit:
BEGINNING at a point on the northern dedicated right-of-way li e of Carlisle Avenue
(T-403) at the dividing line of Lot #24 and Lot #23, said point also being located 113.28
feet east of the eastern extremity of an arc connecting the northern dedicated right-of-way
line of Carlisle Avenue (T-403) and the eastern dedicated right-of-way line of James
Drive;
THENCE by line of Lot #23 North 23 degrees 29 minutes 09 seconds West 100.00 feet
to a point on line of lot #22; thence by line of Lots #22 and #2 North 66 degrees 30
minutes 51 seconds East 112.03 feet to a point; thence by lands now or formerly of Greg
R. and Mary H. Shade South 24 degrees 45 minutes 00 seconds East 100.02 feet to a
point; thence by the northern dedicated right-of-way line of Ca lisle Avenue (T-403)
South 66 degrees 30 minutes 51 seconds West 114.23 feet to a point, the place of
BEGINNING.
CONTAINING 11,313 square feet.
BEING Lot #24 of the: Final Subdivision Plan of North Newton
RECORDED in Plan Book 66, Page 97, on August 9, 1993.
Phase I.
i-f it 9nnaa?Ja3 - Pang. 1 of 4
I do hereby certify that the precise residence and complete
the ti 'thin named grantee is 37 Shepherd Road, Ney? ??ra,?le, PA 1724;
office address of
Attorne for C`?11
Inct.# 9no933743 - Paae 2 of 4 1
BEING the same premises which Steven Wayne Myers and Cin,
and wife, by deed dated the 23rd day of September, 2009, and reco
Recorder of Deeds for Cumberland County to Instrument No.
granted and conveyed onto Cindy Lee Myers, GRANTOR herein.
The within conveyance is between parent and child and,
realty transfer tax.
IN WITNESS VNEREOF, said grantor has hereunto set
day and year first above written.
Signed, Sealed and Delivered
in the Presence of
c } A C-c-r
CINDY
Commonwealth of Pennsylvania)
) SS.
County of 'U,?n b,? t Q a )
On this, the J'I =f` day of ?4 fer r\&^ , 2009, be)
officer, personally appeared CINDY L. WERS, known to me
to be the person whose name is subscribed to the within instrur
that she executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and
Lee Myers, husband
ed in the office of the
exempt from
hand and seal the
(SEAL)
me, the undersigned
satisfactorily proven)
it, and acknowledged
seal.
-jjdTNH LL SEAL
RpR4N !. &USES1
Notary Public C011?1r
ANAU/aRODUN, coU
MV Con?mi01M.Expiros Apt 17, 2011
incr * 9nn4337d3 - Pana 3 of 4
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200933743
Recorded On 9/30/2009 At 2:24:43 PM
x Instrument Type - DEED
Invoice Number - 53359 User ID - AF
* Grantor - MYERS, CINDY L
* Grantee - MYERS, CINDY L
* Customer - GRIFFIE
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JUSTICE
RECORDING FEES - $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
BIG SPRING SCHOOL $0.00
DISTRICT"
NORTH NEWTON TOWNSHIP' $0.00
TOTAL, PAID $48.50
* Total Pages - 4
Certification Page
DO NOT DETACH
This pa a is now part
of this 1 dal document.
I Certify this to
in Cumberland
recorded
unty PA
ct% ctry?
-e 4
° RECORDER O D DS
- Information denoted by an
the verification process and
isk may change during
not be reflected on this Page.
01
111111111111111111111
M-+ i! 91)n4337a3 - Pane 4 of 4 1
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have
of the foregoing document upon the persons indicated below by
postage paid in Carlisle, Pennsylvania 17013, on the date set forth
BRYCE A. MYERS
CINDY L. MYERS
37 SHEPHERD ROAD
NEWVILLE, PA 17241
a true and correct copy
class United States mail,
Date: November 4, 2010 IRWIN & McKNXGHT, P.C.
Douglas Of. Mill,
Supreme Court I.
West Pomfret Pr(
60 West Pomfret
Carlisle, Pennsyl
(717) 249-2353
Esquire
No. 83776
bssional Building
17013-3222
ROBERT A. HINKLE and
LUANN HINKLE,
Plaintiffs
V.
BRYCE A. MYERS and
CINDY L. MYERS,
TO THE PROTHONOTARY:
C'? ry
C v
rn C
Z RI S
?
.
: THE COURT OF COMMON PLEF `
' rn
-0
I
: CUMBERLAND COUNTY, PENN VAN W,
,
NO. 2010 - 6923 CIVIL TERM ?
CIVIL ACTION - LAW N .
Please enter judgment by default in favor of the Plaintiffs, Robert A. Hinkle and Luann
Hinkle, and against the Defendants, Bryce A. Myers and Cindy L. Myers, for their failure to file an
Answer to the Complaint within the required time. The Complaint contains a notice to defend
within twenty (20) days from the ate of service thereof. The Defendants were served with a copy
of the Writ of Summons on No ember 2, 2010, and were mailed copies of the Complaint on
November 4, 2010.
Attached as Exhibit "A" is a copy of Plaintiffs' written Notice pursuant to Rule 237.1 of the
intention to file a praecipe for entry of default judgment, which I certify was mailed by regular mail
to the Defendants at their current dress on November 26, 2010, which date is at least ten (10) days
prior to the filing of this Praecipe.
Please assess damages in
complaint, together with any appli
amount of $20,198.68, being the amount demanded in the
costs and subsequent interest.
Respectively submitted,
Date: December 7, 2010
IRWIN & McKNIGHT, P.C.
By: v AAA JUJA
Douglas G filler, Esquire
Supreme Court I.D. No 83776
60 West Pomfret Street
Carlisle, PA 17013
717-249-2353
Attorney for Plaintiffs
???5 a/3Fl
t1
EXHIBIT "A"
ROBERT A. HINKLE and
LUANN HINKLE,
Plaintif
V.
BRYCE A. MYERS and
CINDY L. MYERS,
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010 - 6923 CIVIL TERM
CIVIL ACTION - LAW
To Defendants: BRYCE A. MYERS
CINDY 14. MYERS
37 Shep erd Road
Newville PA 17241
Date of Notice: N
YOU ARE IN DEF.
WRITTEN APPEARANCE
WRITING WITH THE C1
CLAIMS SET FORTH AGA
FROM THE DATE OF THIS
YOU' WITHOUT A HEARD
IMPORTANT RIGHTS.
YOU SHOULD TAKI
NOT HAVE A LAWYER,
BELOW. THIS OFFICE
HIRING A LAWYER.
IF YOU CANNOT A
ABLE TO PROVIDE YOU
OFFER LEGAL SERVICES
FEE.
26, 2010
IMPORTANT NOTICE
/*/I :.
1 ,41
a
ULT BECAUSE YOU HAVE FAILED TO ENTER A
PERSONALLY OR BY ATTORNEY AND FILE IN
URT YOUR DEFENSES OR OBJECTIONS TO THE
NST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
J AND YOU MAY LOSE YOUR PROPERTY OR OTHER
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO
:O TO OR TELEPHONE THE OFFICE SET FORTH
;AN PROVIDE YOU WITH INFORMATION ABOUT
RD TO HIRE A LAWYER, THIS OFFICE MAY BE
H INFORMATION ABOUT AGENCIES THAT MAY
ELIGIBLE PERSONS AT A REDUCED FEE OR NO
nberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
IRWIN & McKNIGHT, AjJLA
P.C..By:
Douglas GQMiller, Esquire
Supreme Court I.D. No. 83776
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Attorney for Plaintiffs
TE OF
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by first class United States mail,
postage paid in Carlisle,
17013, on the date set forth below:
BRYCE A. MYERS
CINDY L. MYERS
37 SHEPHERD ROAD
NEWVILLE, PA 17241
Date: December 7, 2010
IRWIN & McKNIGHT, P.C.
Dou"1g as G#Miller, Esquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353