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Home My WebLink About04-6403MUTUAL BENEFIT INSURANCE COMPANY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. SAMUEL B. KING and RHODA S. KING, Each CIVIL DIVISION - LAW Individually and Trading As, S & R ROOFING Defendant(s) NOTICE TO DEFEND 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 filing in writing with the Court your defenses or objections to the claims set froth 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 MUTUAL BENEFIT INSURANCE COMPANY IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ?I-(- (2t U'L L SAMUEL B. KING and RHODA S. KING, Each CIVIL DIVISION - LAW Individually and Trading As, S & R ROOFING Defendant(s) COMPLAINT The Plaintiff, MUTUAL BENEFIT INSURANCE COMPANY, by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of NINE THOUSAND, TWO HUNDRED FIFTY-NINE DOLLARS AND FOURTEEN CENTS ($9,259.14), along with interest thereon from December 7, 2004 upon a cause of action of which the following is a statement: The Plaintiff, MUTUAL BENEFIT INSURANCE COMPANY, is a company organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 409 Penn Street, Huntingdon, Pennsylvania 16652. 2. The Defendants, SAMUEL B. KING and RHODA S. KING are adult individuals trading and doing business as S & R ROOFING with an office and place of business at 7210 McClays Mill Road, Newberg, Cumberland County, Pennsylvania 17240. Plaintiff, at Defendants' request, did provide Commercial General Liability Insurance for the benefit of Defendants for the period of April 5, 2001 through April 5, 2002; April 5, 2002 through April 5, 2003; and, April 5, 2003 through May 24, 2003. 4. The prices charged for said insurance coverages provided were just and reasonable, were the legal and market prices therefor, and were the prices which the Defendants promised and agreed to pay Plaintiff therefor. \USER\STACY\CCP COMPLAINTS\WORK\MUTUALINSCO30434.wpd:IODec04 Defendants defaulted on their obligation to pay the premiums when due. The balance due and owing by Defendants to Plaintiff for policy period April 5, 2001 through April 5, 2002 is the sum of Two Thousand, Three Hundred Seventy-Seven Dollars and Twenty Cents ($2,377.20), as appears by Plaintiff's Accounts Receivable document hereto attached, marked as Exhibit "A" and made a part hereof. 7. The balance due and owing by Defendants to Plaintiff for policy period April 5, 2002 through April 5, 2003 is the sum of Three Thousand, Eighty-Three Dollars and Zero Cents ($3,083.00), as appears by Plaintiff's Invoice hereto attached, marked as Exhibit "B" and made a part hereof. 8. The balance due and owing by Defendants to Plaintiff for policy period April 5, 2003 through May 24, 2003 is the sum of Two Thousand, Seven Hundred Ninety-Two Dollars and Zero Cents ($2,792.00), as appears by Plaintiff's Accounts Receivable document hereto attached, marked as Exhibit "C" and made a part hereof. 9. The balance due and owing by Defendants to Plaintiff is the sum of Eight Thousand, Two Hundred Fifty-Two Dollars and Twenty Cents ($8,252.20), as appears by Plaintiff's Statement of Account hereto attached, marked as Exhibit "D" and made a part hereof. 10. Due to Defendants default in payment of said amounts due and owing as aforesaid, interest has been added to said account in the total amount of Seven Hundred Fifty-Six Dollars and Ninety-Four Cents ($756.94) and fees in the amount of Two Hundred Fifty Dollars and Zero Cents ($250.00). :AUSER\STACY\CCP COMPLAINTS\WORK\MUTUALINSCO30434.wpd: I ODecO4 11. Plaintiff frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of NINE THOUSAND, TWO HUNDRED FIFTY-NINE DOLLARS AND FOURTEEN CENTS ($9,259.14), along with interest thereon from December 7, 2004 Respectfully submitted, KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak 407 North Front Street Post Office Box # 11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff \USER\STACY\CCP COMPLAINTS\WORK\MUTUALINSCO30434.wpd: I Mec04 4 Accounts Receivable 1/16/04 12:17:04 OTHER ACCOUNT==> C03912452 .00 Account AUD912452 Agent 140260, AVIS INSURANCE Name S & R ROOFING Status A Plan '0 Address 7210 MCCLAYS MILL RD NEWBURG PA 172400000 Eff Dte: 0/00/0000 00 Account balance .00 Exp Due Original Paid Current Tran S Ln# Policy # T Yr date $-amount date $-balance date S t 0.01 CF00912452 I 01 5/31/01 E 371.00 6/04/01 .00 5/01/01 1 C 002 P 371.00- .00 6/04/01 1 C 003 C200912452 I 02 1/17/03 E 5893.00 12/04/02 .00 6/25/02 1 C 004 P 1168.60- (10.00 R) .00 8/19/02 1 C 005 P 1178.60- .00 10/21/02 1 C 006 P 1168.60- (10.00 R) .00 12/04/02 1 C 007 CP00912452 I 03 8/18/03 E 3083.00 0/00/00 .00 7/21/03 C > $-amount Cf3-installments Cf5-alpha search to- ln# Src trans status Cf1-next account Cf2-previous display itinc. 3- b??cd inSwrtcl -?rx 5??.? a3 77a o? fm- WAIVE /tran ln# SF NSF RF DATE 1162004 Roll Help < NOTE PAD > bal can c e ? ?,vfe) c? acc ?i2t . Lwlvilt insurance Company t;0mmerctal Tunes roncy Home office copy • ?A member of Mutual Benefit Group Common Policy Declarations Transaction Date 7/18/2003 409 Penn Street, PO Box 577 Effective Date 4/05/2003 ® Huntingdon, Pennsylvania 16652-0577 Final Audit Direct Bill ,. 111d1C:d1.CS \AICLL19t--b N1dQCC Policy Number CP00912452 Previous Number CP00912452 Year Risk New 2000 i sulneli??ati`ltd;;' V .-.......amt rel @ %g ?s S & R ROOFING AVIS INSURANCE M0260 SAMUEL KING T-A INS ACQUISITIONS INC T/A 7210 MCCLAYS MILL RD 3399 JETSTAR DRIVE NEWBURG PA 17240 LITITZ PA 17543-7636 Phone 717-625-3770 From: 4 / 0 5 / 2 0 0 2 To: 4 / 0 5 / 2 0 0 3 12:011 am. standard time at your mailing address above. .? ROOFING/SIDING CONTRACTOR INDIVIDUAL In return for the payment of the premium, and subject to all terms of this policy, we agree with you to provide the insurance as stated in this policy. This policy consists of the following coverage parts for which a premium is indicated. This premium may be subject to adjustment. COMMERCIAL GENERAL LIAB. COVERAGE PART Audit premiums are due within 30 days of the audit billing date. ADDITIONAL 4 FULL-TERM PREMIUM See net premium change below 3,083.00 Any person who knowingly and with intent to injure or defraud any insurer files an application or claim containing any false, incomplete or misleading information shall upon conviction, be subject to imprisonment for up to seven years and payment of a fine of up to $15,000. NOTICE- THIS POLICY MAY PROVIDE COLLISION COVERAGE FOR RENTAL VEHICLES. REFER TO YOUR POLICY DECLARATIONS, REM TWO, COLLISION COVERAGE. AN "8" IN THE "COVERED AUTOS" COLUMN INDICATES THAT COVERAGE IS PROVIDED. REFER TO YOUR POLICY OR CONTACT YOUR AGENT FOR MORE DETAILS. Foims Applicable'to`A4l , , Yerage:f?arts IL00171198 IL01660199 IL02460900 IL09100181 LIAY2K1098 MBCD100294 PROY2K0499 OOOMBG0798 Countersigned By Authorized Representative Date 3-CD-100 (2/94) AR0600 01 Accounts Receivable 1/16/04 12:01:12 ` AUDIT ACCOUNT==> AUD912 452 .00 OTHER ACCOUNT==> C03912 452 ..00 Account C04912452 Agent 140260 AVIS INSURANCE Name S & R ROOFING Status C Plan U Address 7210 MCCLAYS MILL RD NEWBURG PA 172400000 Eff Dte: 0/00/000 0 00 Account balance .00 Exp Due Original Paid Current Tran S Ln# Policy # T Yr date $-amount date $-balance date S t 001 BA00912462 I 04 4/19/03 R 1880.00 0/00/00 .00 3/18/03 C 002 BA00912462 1 04 4/13/03 R 1880.00- 0/00/00 .00 3/20/03 C 003 CP00912452 1 04 5/24/03 R 13322.00 0/00/00 .00 4/23/03 C 004 CP00912452 I 04 5/30/03 E 995.00- 0/00/00 .00 5/01/03 C 005 CP00912452 I 04 5/31/03 E 145.00 0/00/00 .00 5/09/03 C 006 CP00912452 I 04 5/24/03 R 9847.00- 0/00/00 .00 9/23/03 C 007 CP00912452 I 04 10/22/03 E 167.00 0/00/00 .00 9/23/03 C to- fm- WAIVE tran $-amount ln# Src trans st atus ln# SF NSF RF DATE ---> 1162004 Cfl-next accoun t Cf3-installments Roll Cf2-previous di spl ay Cf5-alpha search Help < NOTE PAD > AR0600 01 Accounts Receivable 1/16/04 12:01:28 ' AUDIT ACCOUNT==> AUD912452 .00 OTHER ACCOUNT==> C03912452 ,.00 Account C04912452 Agent 140260 AVIS INSURANCE Name S & R ROOFING Status C Plan U Address 7210 MCCLAYS MILL RD NEWBURG PA 172400000 Eff Dte: 0/00/0000 00 Account balance .00 Exp Due Original Paid Current Tran S Ln# Policy # T Yr date $-amount date $-balance date S t 008 CP00912452 A 04 0/00/ 00 R 2792.00- 0/00/00 .00 9/29/03 C * End of detail to- fm- WAIVE tran $-amount ln# Src trans status ln# SF NSF RF DATE ---> 1162004 Cfl-next account Cf3-installments Roll Cf2-previous display Cf5-alpha search Help < NOTE PAD > T"l?c -iv.?o c?cccitns ?c1C? -iTc? 1 -Ifs L E. oIL, 94 245x2 5 & R Rooms Summary of a:mc uM due 7/30/2004 01-M Audit invoicW 612=2 5.8w.00 Payment 8/19102 0,168.6€3) Payment 10121/02 (1,178.60) Payment 12/4102 (1,16$.610) 2;377.20 02.03 Audit {nvolcm 7/29/03 3,083.00 3,083.00 03-04 policy term hiveOiCW 4/23103 13.322-00 Fndorsen3erst 51IM3 (995.00) Endomefns M WWO3 145.00 CancOation 3f2M 967.0D CanceRation 9123103 (9,847.00) 2,792.00 Torsi amount due 8,252.20 ®004/004 Dec 13 04 10:51a Kay Reynolds VERIFICATION 502-515-4276 p.7 i, ??a?a (ie S ??t?-e (? eMIUM Hud-c1- St ?j viS?Tr , (rtimc) (uric) of MUTUAL BENEFIT INSURANCE COMPANY, verify that the statements made in the aforegoing document ate true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unworn falsification to authorities. MUTUAL BENEFIT INSURANCE COMPANY By: ?liQt? ?Qx C? Title: 1 f Um ?? Dated: 1???31 C7 30434 F:IUSERISTACYICCF COMPLAINTS1WOltKUMUTUALINSCO30434.%vpd:tODccO4 91d ]d AuaoA i ddnmA WdTP:TO DH, or D3a '?Q `?, ? ?., ? ? .. v? ? ? r-., -? ?,..? ., ? _.... -? y ?::' ' ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MUTUAL BENEFIT INSURANCE COMPANY : No: 04-6403 Civil Term Plaintiff : Civil Action - Law VS. SAMUEL B. KING RHODA S. KING Each Individually and Trading As, S & R ROOFING Defendants AN WER 1. Admitted 2. Denied, Defendants reside and do business in Franklin County. 3. Denied, Defendant, Samuel B. King, may have requested Insurance however Rhoda S. King made no such request. 4. Denied, Defendants are without sufficient knowledge or information to form a belief as to the truth of the matter averred. 5. Denied, Defendant Samuel B. King cancelled his insurance with Plaintiff. 6. Denied, Defendants are without sufficient information or knowledge to form a belief as to the truth of the matter averred. Defendants believe and therefore state that a premium increase was added after an "audit". 7. Denied, Defendants are without sufficient information or knowledge to form i belief as to the truth of the matter averred. Defendants believe and therefore state that a premium increase was added after an "audit". 8. Denied, Defendant Samuel B. King the insurance policy with the Plaintiff prior to policy renewal in 2003 after being informed that the new premium was more then double the previous premiums. 9. Denied, Defendants do not owe any money to the Plaintiff. 10. Denied, Defendants are not aware of any contract signed by them that allows Plaintiff to charge interest or fees. 11. Denied, conversations had taken place between Defendant Samuel B. King and Plaintiff and demand for some amount of money was made. No demand for the amount claimed has ever been made on Rhoda S. King. Wherefore, Defendants pray the Complaint of Plaintiff be dismissed. Respectfully H. Anthony Adams Attorney for Defendant 49 West Orange Street Shippensburg, Pa. 17257 Supreme Court ID # 25502 VERIFICATION I verify that the statements made in this statement are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: <5' e. SAMUEL B. KING Date: /-H-Cr RHO A S. KING r ?? -fit iy r?% ???i ?.? i ? ?_,? `r: ? ? t???? i t ,..a .._. SHERIFF'S RETURN - OUT OF COUNTY . CASE NO: 2004-06403 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MUTUAL BENEFIT INSURANCE CO VS KING SAMUEL B ET AL 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: KING SAMUEL B but was unable to locate Him deputized the sheriff of FRANKLIN serve the within COMPLAINT & NOTICE in his bailiwick. He therefore County, Pennsylvania, to On February 4th , 2005 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Franklin Co 50.00 .00 87.00 02/04/2005 KNUPP KODAK IMBLUM So answers-- Thomas Kline ! R'. Sheriff of Cumberland County Sworn and subscribed to before me this day of a7i}L?? A.D. Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-06403 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MUTUAL BENEFIT INSURANCE CO VS KING SAMUEL B ET AL 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: but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On February 4th , 2005 this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: So answerz? Docketing 6.00 Out of County .00 Surcharge 10.00 R. Thomas Kline .00 Sheriff of Cumberland County 02/04/2005 KNUPP KODAK IMBLUM Sworn and subscribed to before me this day of A. D. Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-06403 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MUTUAL BENEFIT INSURANCE CO VS KING SAMUEL B ET AL 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: KING RHODA S but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On February 4th , 2005 this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: So answers Docketing 6.00 Out of County .00 Surcharge 10.00 R,: Thomas -e .00 Sheriff of C uTrb-er-!-dhd county 02/04/2005 KNUPP KODAK IMBLUM Sworn and subscribed to before me this day of A.D. Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-06403 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MUTUAL BENEFIT INSURANCE CO VS KING SAMUEL B ET AL 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 KING RHODA S TRADING AS but was unable to locate Her S&R ROOFING to wit: in his bailiwick. He therefore deputized the sheriff of FRANKLIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On February 4th , 2005 , this office was in receipt of t attached return from FRANKLIN Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 02/04/2005 KNUPP KODAK IMBLUM Sworn and subscribed to before me this day of A. D. .-? --? -" -° So answers, f R -Thomas 1 ine Sheriff of Cumberland County Prothonotary In The Court of Common Pleas of Cumberland Coon y, Pen sylva is Mutual Benefit Insurance Company vs. Samuel B. King et al SERVE: Samuel B. King Now December 28, 2004 hereby deputize the Sheriff of No. 04-6403 civil I, SHERIFF OF CUMBERLAND COUNTY, PA, do Franklin deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Affidavit of Service Now, 170 7ANU-4k Y , 20 tom, at ,'o0 o'clock A _ M. served the within 1... yl- upon Sa,vtu?l 6 King at 45- - 4ncaln Way C t 6 by handing to 1 ??Inuel 16 . 11cinef a Trge -t-Atrs&od Co p„ copy of the original Gm j2. C•v,) L xyV and made known to ??r?'l the contents thereof. So answers, ` PA ; Sheriff of < x"."eZ (it/ County, PA (1 COSTS Sworn and subscrib before me this '7 day of . 20 S SERVICE MILEAGE AFFIDAVIT Notarial weal ER:Ch-d. D. McCarty, Notary Public burg Boro, Fra nklin County ission EePire; ''n. ?y• ?t?P? In The Court of Common Pleas of Cumberland County, Pennsylvania Mutual Benefit Insurance Company v5. Samuel B. King et al SERVE: Samuel B. King trading as S&R Roofing No. 04-6403 civil Now, December 28, 2004 hereby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. t " Sheriff of Cumberland County, PA Affidavit of Service Now, eff 7 JANuAR't , 2005 , at .'ov o'clock A M. served the within _r Mp ,mot v. 44W upon .ti, „ p a , lL? nG at t by handing to Sct?n?,t? 1?i n9 a /-ue- g- A-tibes?Pd copy of the original Ce. r;,, *l L-ck./ and made known to A , ,/Yt So answers, C&." , y??/ .- ? V *;It??, r the contents thereof. 4L? Sheriff of ,alt ly County, PA COSTS Sworn and subscrib before me this day o 20 '.z SERVICE $ MILEAGE AFFIDAVIT Notarial deal Richard D. McCarty, Notary Public Chamber burg Boro, Fsanklu! County My Commission Eepire. ',n. 2v, 2007 In The Court of Common Pleas of Cumberland County, Pentisylvania Mutual Benefit Insurance Company vs. Samuel B. King et al SERVE: Rhoda S. King No. 04-6403 civil Now, December 28, 2004 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this `r ?_1 ` Sheriff of Cumberland County, PA Affidavit of Service Now, /0/ , 206;, S', at Z `o0 o'clock /V M. served the within &-X17- oX ecji1/°4 6-r <f/l- c-c>Sv- T upon at '7.1 A?7 by handing to if ** 6 Se A`/.tip;.. a G4- copy of the originale4ac-Ae,- ,-4t> .2 311C -- 7- and made known to X OA-W .5 A-,O? C Sworn and subscribe before me this day of , 20 'VS So answers, the contents thereof. S C nty, PA COSTS SERVICE NULEAGE _&FFIDAVIT Notarial peal [Richard D. McCarty, Notary Public hamber burg Boro, F,anklm County Commission E°,;•'rr: n. ?v, ''007 $ In The Court of Common Fleas of Cumberland County, Pennsylvania Mutual Benefit Insurance Company vs. Samuel B. King et al SERVE: Rhoda S. King trading as S&R Roofing No. 04-6403 civil Now, December 28, 2004 hereby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Franklin deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Affidavit of Service Now, r7X-11/ ZU ,20d s, ato'clock M. served the upon by handing to ,?'f0/ a Gl/l7' ci?r??' copy of the original?.?'v and made known to - 5???-- the contents thereof. ?V 10A c0 ? ' ` Sworn and subscribed before me this (n day of14-? , 20 ?S So answers, Sheriff of Coun , PA COSTS SERVICE $ MILEAGE AFFIDAVIT Notarial peal Q Richard D. McCarty, Notary Nblic D Chamber burg Boro, !-- nkl±r County ti?: Commission Epir? '?? ''pp? Curtis R. Long Prothonotary Q11.921ffite of the Protbonotarp Cumberianb Couutp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 04 -L,463 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6571