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HomeMy WebLinkAbout04-6263 MICHAEL L. BANGS, ESQUIRE ID. #41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 HEMPT BROS., INC., ) Plaintiff ) ) vs. ) ) STANLEY MILLER, a/k/a RA YMOND ) STANLEY MILLER, ) Defendant ) ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004- b~~ G C.;l C-r<VLh'J JURY TRIAL DEMANDED 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 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 , HEMPT BROS.. lNC .1ST ANLEY MILLER f DISK 19 MICHAEL L. BANGS, ESQUIRE ID. #41263 429 SOUTH 18TH STREET CAMP HILL, P A 17011 (717) 730-7310 HEMPT BROS., INC., ) Plaintiff ) ) vs. ) ) STANLEY MILLER, a/k/a RA YMOND ) STANLEY MILLER, ) Defendant ) ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA W NO.2004- IoJ..W G o'tL l<V2-l JURY TRIAL DEMANDED COMPLAINT AND NOW comes the Plaintiff, HEMPT BROS., INC., by and through its counsel Michael L. Bangs, Esquire, and in support thereof files the following Complaint: 1. Plaintiff, HEMPT BROS., INC., is a Pennsylvania corporation with its principal place of business at 205 Creek Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant, STANLEY MILLER, aJk/a RAYMOND STANLEY MILLER, is an adult individual who resides at 930 Linden Lane, Dauphin, Dauphin County, Pennsylvania, 17018. 3. On or about May 11, 2004, Plaintiff and Defendant entered into a contract whereby Plaintiff agreed to provide certain work and material at Defendant's residence at 930 Linden Lane, Dauphin, Pennsylvania, for the price of$8,755.20 ("Contract 1 "). Attached hereto and marked as Exhibit A is a true and correct copy of Contract 1. 4. On or about July 28, 2004, Plaintiff and Defendant entered into a contract whereby Plaintiff agreed to provide additional work and material at Defendant's residence for the price of 1 1 HEMPT BROS. INC , ISTANLEY MlLLER I DISK 79 $6,100.00 ("Contract 2"). Attached hereto and marked as Exhibit B is a true and correct copy of Contract 2. 5. Plaintiff well and fully performed its obligations under Contract 1 and Contract 2 and all work was done in a good and workmanlike fashion. 6. Plaintiff requested Defendant to pay for the work and material supplied to Defendant under Contract 1 and Contract 2. 7. Defendant has failed or refused to make payment to Plaintiff under the terms of Contract 1 and/or Contract 2. COUNT I BREACH OF CONTRACT 8. Paragraphs 1 through 7 are incorporated herein by reference as if more fully set forth. 9. Under the terms of Contract 1 and Contract 2, Defendant has an obligation to pay Plaintiff within thirty (30) days of invoice. Attached hereto and marked as Exhibit C is a true and correct copy of the invoices C 1 and C2, invoices for both contracts. 10. Defendant has breached Contract 1 and Contract 2 with Plaintiff by his failure to pay the invoices within the terms of Contract 1 and Contract 2. 11. Under the terms of Contract 1 and Contract 2, Plaintiff is entitled to receive 1 % per month as a delinquency charge for all accounts due and owing after thirty (30) days and 10% for the cost of collection. 12. Plaintiff has been damaged in the amount of $20,574.70 which represents the outstanding balance due, plus delinquency calculated at 1 % per month up to November 17, 2004. 2 . HEMPTBROS., INC ./STANLEYMILLER/DISK 79 13. Plaintiff is entitled to collection charges in the amount of $2,057.47. 14. All of these damages are solely and directly related to the breach of Contract 1 and Contract 2 by Defendant as a result of his failure to pay for the work that was performed and the materials supplied under the terms of Contract 1 and Contract 2 to Defendant. WHEREFORE, Plaintiff demands judgment in the amount of $22,632.17, plus interest at the rate of 1 % per month for all invoices due over thirty (30) days to be calculated to the time of judgment, plus costs of suit. COUNT II UNJUST ENRICHMENT 15. Paragraphs 1 through 14 are incorporated herein by reference as ifmore fully set forth. 16. The work performed and the materials provided by Plaintiff to Defendant are just and reasonable and are the prices which the agents, servants and employees of Defendant and Defendant himself promised to pay Plaintiff for those materials and services. 17. Defendant has failed or refused to pay for the work performed and materials received by him despite repeated demands by Plaintiff. 18. Defendant has been unjustly enriched at Plaintiffs expense by his failure to pay for the work performed and materials received under Contract 1 and Contract 2 in the amount of $20,574.70, plus interest at the rate of 1 % per month, plus collection costs of 10% or $2,057.47, as a result of Defendant's acceptance of the work performed and materials delivered by Plaintiff for Defendant. 3 HEMPT BROS. INC.. 1ST ANLEY MILLER I DISK 79 WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $22,632.17, together with interest at the rate of 1 % per month for all invoices due over thirty (30) days to be calculated to the date of judgment in this case, plus costs of suit. Respectfully submitted, ftA,. /) u L /') M~C~~i1-ANGS (1. #.~3) Attorney for Plaintiff 429 South 18th Street, Camp Hill, P A 17011 (717) 730-7310 4 HEMPT BROS. INC. 1ST ANLEY MILLER I DISK 79 VERIFICATION GEORGE F. HEMPT, being duly sworn according to law, deposes and says that he is the President of Hempt Bros., Inc., a Pennsylvania corporation, and that as such officer, he is authorized to make this Verification on its behalf and that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief, and further understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. HEMPT BROS., INC. 5 EXHIBIT A ~ .}; \11111 HEMPT BROS., Inc. ."..." I j 205 CFiEEK ReAD, CAMP Hill, PA 17011 · FAX (717i 761-5019 STEElTON: 939-9586 CAMP Hill: 737,3411 lOCUST ,DOINT: 795.9000 --;if'S"~ :',,!.\l~'J ..' (\::''?:~:. - ".::_::)I~~~: :::;cn,:" - j~:r,: - ":':;c',,],! ,.;';VI('() '.ia,.~r,..}~' - ~:i,::'1?-t If': ::",_<:!".~,: '_ '''<,'/~r' - '-"',,:': TCL.~:'~D 436,S'" DATE: PRO.JECT: TO: May 11, 2004 Bituminous Paving - Clarks Valley Road Mr. Stan Miller 930 Linden Lane Dauphin, P A 17018 We are pleased to submit the following quotation for the above captioned project: Description; ID-2 \Vearing Placement of:t 1,824 S"{ to include; 1. Clean and prepare for paving 2. Tackcoat 3. Furnish and place 1" ID-2 wearing - L 4. AC-20 where needed TOTAL COST: 1,824 SY @ $4.80 SY = $8,755.20 ~ NOTE: Quote does not include any adjacent driveways. The above quotation and proposal constitutes a present offer to contract and may be accepted in writing only by haVing this form signed where indicated below by an authorized officer or agent of the purchaser and returned to the offices of Hempt Bros" Inc, no later than sixty \60\ days from the above date. Hempt Bros,. Inc.. makes no warranties, express or implied. including an implied warranty of merchantability or fitness for a particular purpose, unless expressly set forth herein. We will not be responsible for failure to make delivery when prevented by any causes or reasons be,!ond our control, including shortage of raw ll11aterials, The prices quoted-above are based on costs for labor and materials prevailing on the date shown above and arp- subject to change if ',here is an Increase In our labor or materials costs between the quotation date and date of delivery. prOVided that such increase sllall only, eflect actual labor and material cost changes as incurred by Hempt Bros.. Inc, Our terms are thirty \201 di;lYs net; after thirty 1,301 days from the date of any invoice, a delinquency charge In the amount of one Dercent 11%'1 per :llonth will be assessed on any 'item or IJalance remaining unpaid, plus ten percent 110%1 for cost of collection. !f at any time the fmanclal resoonslbllit': of clIstomer becomes Impaired or unsatisfactory, Hempt Bros.. Inc.. reserves the f1gnt to require payments In advance or satisfactory guarantee that 'llVoices will be promptly paid when due, In the event the tenure of a contract IS more than thirty (301 days, Hempt Bros.. Inc.. shalll)e paid monthly iw the tenth of each month follOWing the determination of the amount due. lit is understood that the prices quoted aoqve are based un our 0per;;t'ng open S110p,i ThiS oroposal and the Signed acceptance therp-on constitutes the entire agreement between the parties. and there ilre 110 covenAntS, ';onditlons. ~epresentatlons or agreements, or<)1 or written. other than those herein contained. nor is this proposal, if accepted. suoject to further JDprOVal 011he parties. We would appreciate your acceptance of the above offer and promise to pav Hempt Bros.. Inc for the performance of same bv 31gnlllg 'he .lcceptance below, returning one copy to us, and retaining a copy for your records, Sincerely. HEMPTZS., I~C. ~_ -~ ~~/ ~...~.~......"............."..... jAI~ Y7tl' t) '01 ~I '/ {/--. ( / ,~CCE?T ANCE ........................................ . :::::;::~'~fM;"",,"d'"e"'m'.A""m'm K~lr. , .' EXHIBIT B \, \ 205 C:=1E=:< ROAD, CAMP HilL.. PA li011 · FA)< f71ii iGl.5G13 Si"c:Oc.TON: 939.9556 CAMP HILL, 737.34; 1 LOCUST POI~.): 79:-3000 TOLjll'lC ":26.:'" 51; ~ ,,1 . ~ ') ~;; :, .1,.....r: ),.-;,,:;,. - ::F: - "'::..'~.: ;i. '''r: ...j':"";.; - ;;'f~r -,;/; =.: if .,.".~~~." - ~"J.30 =~. DATE: PRO.JEeT: TO: July 28,2004 Driveway Paving Mr. S tan Miller 930 Linden Lane Dauphin, P A 17018 We are pleased to submit the following quotation tor the above captioned project: Description: Construction of:t 852 SY to include: 1. Clean and prepare for paving 2. Furnish and place 1 W' ID-2 wearing surface TOTAL COST: $6,100.00 i"he above quotation and proposal constitutes a present offer to contract and may be accepted in writing only by having thiS form signed 'N11ere Indicated below bv an authoriz:ed officer or agent of the purchaser and returned to the offices of Hempt Bras,. Inc, no later than sixty (60) days irom the above aate. Hempt Bros.. Inc., makes no warranties, express or implied. including an implied warranty of merchantability or fitness for a particular ouroose, unless expressly set forth herein. We will not be responsible for failure to make delivery when prevented by any C;3uses or reasons beyond our control, Including shortage of raw h1aterials. The prices quoted above are based on costs for labor and materials prevailing on the date shawn above and are subject to change if there IS an Increase In our labor or materials costs between the quotation date and date of delivery, provided that SUCh Increase shall only reilect actuallaoor ana matenal cost changes as incurred lJY Hempt Bras" Inc. 'Jur terms are thirtY !30l clays net: Jtter thirty (30) days from the date of any inVOice, J delinquency cl1argB in the amount oi one Dercant (1 o~i IJer momh wI/I be assessed on anv item or balance remaining unpaid, piLlS ten percent (10%) for cost of collection. Ii at anv time the financial resoonSloliltv 'J! c~stomer becomes Impaired or unSatiSfaCtOry, Hempt 8ros.. Inc" reserves the right to require oayments in advance or satiSfactOry guarantee that 'nvolces wIlllle [Jromptly paid when due, In the event the tenure of a contract IS more than thirty (301 days, Hemp( Bros., Inc.. shalllJe paid monthly !;v the tenth of each month follOWing the determination of tl1e amount due. (It is understood that the prices quoted above are based on ,;ur ooerating 'lpen ShOP.1 -:-l1ls orooosal and the Signed acceptance thereon constitutes the entire agreement between t11e parties. and there are no covenants. conoltlons, representations Qr agreements, oral or Written, other than those herem contained, nor is tl,\IS proposal. If accepted, subject to further aoprovalLJI t:-,e ;lar"e5, 'Ne would Jopreclate '!our "cceptance C)f t11e <Jbove offer and promise to pay Hempt Bros.. Inc. for the performance oi 'iame '.)V 51gl1109 '!',e 'C~2';rance ~)e!ow. "erurnlng ')ne c:;:;y ,C I.1S, ,md ret,lIn1f1g " COpy for 'lour records, Sincerely, ;-!E:YIPT 3ROS.. INC. ../7 , ;;', ~<;::-::.~- Bv ., ...."...." .....,;-:, ..... ..,/..:" ,,,.....v.:......, ..... . ~~ ~^C:;~~~::~:::::;"':":O:'""'""co,,O''' ,"0 'h, ,,,m, "' ,,,m,,, '::.ATE (OG~ t 'l .~ ~j(y w f' ~ ) ~ ~ J C") ,- ~2 "'-) c::) o -I' --{ or f r~;:J -"jn ;) ,~) ~'1 (~, , ) ;.='.; C JrIl :;:;.j :.1..\ -< ~:? I' , ") 01-- -':) (..'~ r) 0:.' 8 MICHAEL L. BANGS, ESQUIRE LD. NO, 41263 429 SOUTH 18TH STREET CAMPHILL,PA 17011 (717) 730-7310 HEMPT BROS., INC. ) Plaintiff ) ) VS. ) ) STANLEY MILLER, a/k/a RAYMOND ) STANLEY MILLER ) Defendant ) ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004 --6263 CIVIL TERM CIVIL ACTION - LAW TO: STANLEY MILLER a/k/a RA YMOND STANLEY MILLER 930 Linden Lane Dauphin, PA 17018 DATE OF NOTICE: January 26, 2005 IMPORTANT NOTICE Required by Rule 237.1 (a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN 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 MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RlGHTS. YOU SHOULD TAKE THIS NOTICE TO A LA WYER 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 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 TELEPHONE: (717) 249-3166 ~VlkJ2)liL ?/JJ' MICHAEL 1. BAN V Attorney for P1aintif c~ S ~ ~:g .:;..J" ~. -~,,' ..- rV -' "". .;.":-) -n 9., ~\'\f\ ~r1~:r\ .....,'1' \~:,('~ll <)e':'1 /~~ \-'i\ LJ\ '::J'~ r:? :;.? -- cJ'\ - ~ -~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-06263 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HEMPT BROS INC VS MILLER STANLEY AKA RAYMOND STA R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MILLER STANLEY AKA RAYMOND STANLEY MILLER but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 10th , 2005 , this office was In receipt of the attached return from DAUPHIN '7 Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County './ So a~;::~~p/~:'::...~.'~;~~':::= " 4'~"'- ./"~'~/' ,.,...... ~/ V:~:"r? '~' -?" R. Thomas Kline Sheriff of Cumberland County 18.00 9.00 10.00 26.25 .00 63.25 01/10/2005 MICHAEL BANGS Sworn and subscribed to before me this ,p ;2'1~ day Off:JAAA-f117 I A.D. ~ov) ~Jur~ Q '~-,~J~ ~ 4 ?I Prothonotar~ ... In The Court of Common Pleas of Cumberland County, Pennsylvania Hempt Bras Inc VS. stanley Miller aka Raymond Stanley Miller No. 04-6263 civil Now, December 16, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ./"") LP'" . //'/' ~~~. ,- ~-:,,....;.,,-. ;r .k.......z;;::e';'#"~<f< ..1" _~~.4" r ~ Sheriff of Cum berland County, P A Affidavit of Service Now, 0' clock M. served the ,20_, at within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County,PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ $ . @Hit~ llf tqr ~4rr-iff William T. Tully Soli citor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania HEMPT BROS INC vs County of Dauphin MILLER STANLEY Sheriff's Return No. 7149-T - -2004 OTHER COUNTY NO. 04 6263 AND NOW:January 4, 2005 at 3:29PM served the within COMPLAINT upon MILLER STANLEY AKA MILLER RAYMOND STANLEY to DEFENDANT by personally handing 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 930 LINDEN LANE DAUPHIN, PA 17018-0000 Sworn and subscribed to So Answers, JK~ before me this 5TH day of JANUARY, 2005 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2006 Sheriff of Dauphin C~y, Pa. 1,// ,; / ,1 " C~''''{5:3~;t'{("l \,-__?r}'"12._ By j J i Deputy Sheriff Sheriff's Costs:$26.25 PD 12/20/2004 RCPT NO 202431 ~ KC ~. MICHAEL L. BANGS, ESQUIRE I.D. NO, 41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 HEMPT BROS., INC., Plaintiff ATTORNEY FOR PLAINTIFF vs. ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2004-6263 CIVIL TERM STANLEY MILLER alk!a RAYMOND STANLEY MILLER, Defendant CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff and against the Defendant for Defendant's failure to file a responsive pleading to Plaintiffs Complaint, in the amount of$22,632.17, plus interest at the rate of 1 % per month for all invoices due over thirty (30) days to be calculated to the time of judgment, plus costs of suit. I further hereby certify that notice has been given to the Defendant in accordance with Rule 237.1. Respectfully submitted,... {/~v>(i 7;/~ MICHAEL 1. BANGS,,'. Attorney for Plaintiff 429 South 18th Street Camp Hill, P A 170 II (717) 730-7310 Supreme Court ID #41263 Date: March 7, 2005 . . MICHAEL L. BANGS, ESQUIRE ID NO. 41263 429 SOUTH 18TH STREET CAMP HILL PA 17011 (717) 730-7310 A TTORNEY FOR PLAINTIFF r-::~I E ' ~. ...-. HEMPT BROS" INC. ) Plaintiff ) ) vs, ) ) STANLEY MILLER, alkJa RAYMOND ) STANLEY MILLER ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004 -6263 CIVIL TERM CIVIL ACTION - LAW TO: STANLEY MILLER alkla RA YMOND STANLEY MILLER 930 Linden Lane Dauphin, PA 17018 DATE OF NOTICE: January 26, 2005 IMPORTANT NOTICE Required by Rule 237.1 (a)(2) YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN 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 MA Y BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MA Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VE 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 q;f, lkaJlJl1ll /JUlf/= . ICHAEL L. BANGS Attorney for Plaintiff G -tg. ~~ i 0 - \> S ~ ~ ~ ?! 0, (! ~~ ,--.... r-' ~~~! ~;~;::~ eIl :;7:'". ~; I co .......) ~;'." r:-? CJ ;;- MICHAEL L. BANGS, ESQUIRE J.D. NO. 41263 429 SOUTH 18TH STREET CAMP HILL, P A 17011 (717) 730-7310 HEMPT BROS., INC., Plaintiff ATTORNEY FOR PLAINTIFF vs, ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-6263 CIVIL TERM STANLEY MILLER a!kIa RAYMOND STANLEY MILLER, Defendant CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE I hereby certify that the residences/addresses of the Plaintiff and Defendant are as follows: Hempt Bros., Inc. 205 Creek Road Camp Hill, PA 17011 Stanley Miller, a!kIa Raymond Stanley Miller 930 Linden Lane Dauphin, PA 17018 ) MICHAEL 1. BANG I Attorney for Plaintiff t/ r-,.'l ( ~! ":0;') ';;:;. is; ::rJ I c:J ~.? '-".I .jC- - MICHAEL L. BANGS, ESQUIRE LD. NO. 41263 429 SOUTH 18TH STREET CAMP HILL, P A 170 II (717) 730-7310 HEMPT BROS., INC. ) Plaintiff ) ) vs. ) ) STANLEY MILLER, a/k/a RAYMOND ) STANLEY MILLER, ) Defendant ) ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2004-6263 CIVIL TERM CIVIL AcnON - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the judgment entered in the above-referenced matter on March 8, 2005 SATISFIED. Respectfully submitted, /"'""1 / V/t1'1i~/cl l / f/ MICHAEL 1. BANGS/ Attorney for PlaintiffI/o" 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 Supreme Court lD #41263 Date: February 22, 2006 /)Jjl '-") :\1 \"J .C.) ',-..