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Home My WebLink About13-6202 Supreme Co .ennsylvania Cou 06 o 4 leas For Prothonotary Use Only: it ver, t Docket No: CUf t r County l [ /3 o �- `d The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: i Complaint Writ of Summons El Petition S ® Transfer from Another Jurisdiction ® Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: C Carlisle Cement Products Company Chris Archibald T Dollar Amount Requested: Mwithin arbitration limits I Are money damages requested? X Yes No (check one) ®outside arbitration limits O N Is this a Class Action Suit? Yes [S No Is this an MDJAppeal? ® Yes [@ No � A Name of Plaintiff /Appellant's Attorney: Melissa I, Kelso, Esquire I'. Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your - PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important.. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card 13 Board of Assessment Motor Vehicle 0 Debt Collection: Other ® Board of Elections ® Nuisance Credit /Purchase account Dept. of Transportation [3 Premises Liability Statutory Appeal: Other S Product Liability (does not include mass tort) l� Employment Dispute: i t •E . Discrimination s ® Slander/Libel/ Defamation - 1c 0 Other: ® Employment Dispute: Other ® Zoning Board E3 Other: "I ® Other: MASS TORT Asbestos N , [3 Tobacco ® Toxic Tort - DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: ® Ejectment ® Common Law /Statutory Arbitration 13 Eminent Domain /Condemnation ® Declaratory Judgment ® Ground Rent Mandamus ® Landlord/Tenant Dispute Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Commercial ® Quo Wan•anto ® Denta( ® Replevin ® Partition ® Legal ® Quiet Title [3 Other: ® Medical [3 Other: ® Other Professional: Updated 1/1/2011 P t _ THE' i� 10N0 `�j i f } Yy�; 1 i�'�t 2013 OCT 21 PM 2: 4 2 Salzmann Hughes, P.C. Samuel E. Wiser, Jr., Esquire CIVIBERLAND COUJ TY Attorney I.D. No. 203665 P E N S Y LVA N j A Melissa L. Kelso, Esquire Attorney I.D. No. 306793 79 St. Paul Drive Chambersburg, PA 17201 Telephone: 717- 263 -2121 Fax 717 - 261 -9998 IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products Company, Inc. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. Chris Archibald, individually and CIVIL ACTION d/b /a Chris Archibald Landscape Design Defendant 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 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 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 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249 -3166 S a�j isl J IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products Company, Inc. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. Chris Archibald, individually and CIVIL ACTION d/b /a Chris Archibald Landscape Design Defendant COMPLAINT AND NOW, comes Plaintiff, Carlisle Cement Products Company, Inc., by and through its counsel, SALZMANN HUGHES, P.C., who avers as follows: 1. Plaintiff, Carlisle Cement Products Company, Incorporated ( "Plaintiff'), is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its registered office at 510 East North Street, Carlisle, Pennsylvania. 2. Defendant, Chris Archibald is an adult individual that currently resides at 102 Steeplechase Lane, Harrisburg, PA 17112. 3. Defendant, Chris Archibald does business under the fictitious name Chris Archibald Landscape Design, which is a sole proprietorship located at 5999 Union Deposit Road, Harrisburg, Pennsylvania 17111. 4. Plaintiff operates a business that supplies cement and masonry related products ( "Products ") to retailers, contractors, and consumers. 5. On or about August 8, 2011, Defendant Archibald, on behalf of both himself and Defendant Chris Archibald Landscape Design requested that Plaintiff extend credit to them in the amount of a $10,000.00 line of credit in order to permit them to purchase Plaintiff's products for use in Defendant Chris Archibald Landscape Design's business. A true and correct copy of the Credit Application is attached hereto as Exhibit "A." 6. By executing the Credit Application, Defendants agreed to abide by the terms included in the Application, which included the agreement to pay a finance charge of the lesser of 12% per month and the agreement to compensate Plaintiff for reasonable attorneys' fees and collection costs if necessitated by Defendants' breach of the terms of the line of credit. 7. Plaintiff accepted and granted Defendants' request for credit and established a credit account for Defendant ( "Account #419 "), thereby entering into a contract ( "Agreement "). 8. Pursuant to the parties' Agreement, Plaintiff would supply Defendants with products, Plaintiff would bill the cost of these products to Defendants' credit account, and Defendants would pay Plaintiff for the purchase price of these items. 9. From approximately August 2011 to approximately August 2012, Plaintiff supplied Defendants with the supplies requested by Defendants and billed Defendants' credit account for the cost of these items. A true and correct copy of the Sales Receipts for these purchases is attached hereto as Exhibit `B." 10. Plaintiff has requested payment from Defendants for these purchases on numerous occasions. 11. Despite these requests, Defendants have failed to compensate Plaintiff for these purchases to date. 12. To date, Defendants have failed to compensate Plaintiff for $24,045.44 worth of supplies. Count I — Breach of Contract 13. Plaintiff incorporates the averments of the preceding paragraphs as if set forth at length. 14. Plaintiff and Defendants entered into an enforceable Agreement pursuant to which Plaintiff extended Defendants a line of credit and provided Defendants with various products, as outlined in the Sales Receipts, in exchange for which Defendants were to compensate Plaintiff for the sales price. See Exhibits "A" and "B." 15. Defendants have failed to compensate Plaintiff for all products requested by Defendants and provided to them by Plaintiff. 16. Defendants' failure to fully compensate Plaintiff breaches the Agreement between the parties. 17. Defendants' breach of the Agreement has caused damage to Plaintiff in the amount of $24,045.44, plus costs and interest. 18. Defendants' breach of the Agreement entitles Plaintiff to compensation by Defendants for Plaintiffs reasonable attorneys' fees and collection costs associated with its collection of Defendants' delinquent account pursuant to the express terms of the agreement. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment in its favor and against Defendants in the amount of $24,045.44, plus costs, interest, and any other award deemed just. Count II — Uniust Enrichment 19. Plaintiff incorporates the averments of the preceding paragraphs as if set forth at length. 20. Plaintiff provided Defendants with products at Defendants' request. 21. Defendants received, accepted and retained these products and the benefit of these products. 22. Defendants failed to compensate Plaintiff for the benefit of these products, at the expense Plaintiff. 23. Permitting Defendants to retain the benefit of these products without compensating Plaintiff unjustly enriches Defendants to the detriment of Plaintiff. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter judgment in its favor and against Defendants in the amount of $24,045.44, plus costs, interest and any other award deemed just. Respectfully submitted, SALZMANN HUGHES, P.C. Date: `V �g ` By: Samuel E. Wiser, Jr., Esquire Attorney ID# 203665 Melissa L. Kelso, Esquire Attorney I.D. No. 306793 79 St. Paul Drive Chambersburg, PA 17201 (717) 263 -2121 Counsel for Plaintiff '05/1372013 08:52 FAX Carlisle Cement Qj0006/0007 CARLISLE CEMENT PRODUCTS CO., INC. CARLISLE PA .AG ADDRESS OFFICEIPLANT �. BOX 617 510 E. NORTH ST. RETAIL OFFICE (717) 243 -5323 MANUFACTURING (717) 243 -1225 FAX (717) 243 -6604 CREDIT APPLICATION Company Name .4i "if��j' ,� Z14WZ Address Primary Phone t �f:' '%'�'I = Mobile 1 FaX Contact Name Tax Status TAXABLE EXEMPT (Signed exemption certificate required) T 10 # PO Required OYES NO Type of.Business SOLE PROPRIETOR,.-; PARTNERSHIP CORP. Nature of Business Name of Owner /President Years in Business _. Desired Line Of Credit L � Bank Name /Contact ��7/ ?0 - : e` ��c i 8 , Phone #/Fax # 71 - Account # EXHIBIT A, ` 05/13%2013 08:53 FAX Carlisle Cement 0007 /0007 CARLISLE CEMENT PRODUCTS CO., INC. CARLISLE PA MAILING ADDRESS OFFICEIPLANT P.O. BOX 817 510 E. NORTH ST. RETAIL OFFICE (71 T) 243.5323 MANUFACTURING (717) 243-1225 FAX (717) 243-6604 (1) Company /Contact Address /Phone /Fax Account # (2) CompanylContact Address /Phone /Fax Account# (3) Company /Contact Address /Phone /Fax Account # The undersigned affirms that the information provided is complete, true.and correct_ The undersigned is authorized to obtain credit on behalf of the COMPANY and grants authorization to CARLISLE CEMENT PRODUCTS to investigate the references provided. It is agreed that the COMPANY will make payment promptly according to the terns itemized on each invoice. The COMPANY understands that If an account is established, the credit line is subject to periodic review. Shipments maybe held if the account Is delinquent or exceeds the established line of credit The COMPANY agrees to pay a finance charge of the lesser of 12% per month or the maximum permitted bylaw for any unpaid balances beyond its terms. The COMPANY agrees to pay a Returned Check Fee of $25.00 for any check that is not honored by its bank. In the event CARLISLE CEMENT PRODUCTS finds it necessary to place the account for collection, the COMPANY agrees to pay all collection costs and attorney's fees. Resolution for any dispute related to the account shall be the exclusive jurisdiction of the courts In Cumbertand County Pennsylvania. It is agreed that any rights under this agreement are nontransferable and that written notice is to be provided to CARLISLE CEMENT PRODUCTS 30 days before the transfer or sale of any substantial part of the COMPANY'S business. Authorized Signature Print Name t Title ' Date Carlisle Cement Products, In Account Statement PO BOX 617 Carlisle, PA 17013 -0617 Account Number: 0000419 . , 717- 243 -5323 Due Date: Net 30 Balance: $18,513.81 Minimum Payment: $0.00 ARCHIBALD, CHRIS ARCHIBALD, CHRIS LANDSCAPE DESIGN Amount Enclosed: 5999 UNION DEPOSIT ROAD HARRISBURG, PA 17111 IIIIIIIVIIIIIIIIVIIIVIIIVIIIIIIIII III IIII Please detach and enclose top portion with payment. ----------------------------------------------------------------------------------------------------- A c c o u n t Sum m a ry Account Number: 0000419 Closing Date: 9/25/2012 Name: ARCHIBALD, CHRIS Due Date: Net 30 ARCHIBALD, CHRIS LANDSC 5999 UNION DEPOSIT ROAD HARRISBURG, PA 17111 Previous Balance: $18,243.80 New Charges: $270.01 Credits / Payments: $0.00 New Balance: $18,513.81 $852.06 1 $0.00 1 $160.62 1 $7,110.06 $10,391.07 $18,513.81 A c c o u n t A c tiv ity 9/25/2012 Finance Charge -- Finance Charge #76888 $2 EXHIBIT a Account Number: 0000419 Page 1 of 1 V.ERIFICATION T verify that all the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief and that any false statements made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: By: G ohri M. Rumber , , Presf t 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Sheriff RAnderson i. .' f" �' O wo)r, ikkrw( Jody S Smith 2 1 3 NQV 15 P11 2: 33 Chief Deputy r Richard W Stewart UMBE LAft'D COUNTY Solicitor mr ° = = ' ¢ PENNSYLVANIA Carlisle Cement Products Company Case Number vs. Chris Archibald(et al.) 2013-6202 SHERIFF'S RETURN OF SERVICE 10/23/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Chris Archibald, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint&Notice according to law. 10/23/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Chris Archibald Landscape Design, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint& Notice according to law. 11/06/2013 08:28 AM-The requested Complaint&Notice served by the Sheriff of Dauphin County upon Chris Archibald, personally, at Arroga's Grille House, 4301 Linglestown Road, Harrisburg, PA 17112. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 11/06/2013 08:28 PM-The requested Complaint& Notice served by the Sheriff of Dauphin County upon Chris Archibald,who accepted for Chris Archibald Landscape Design, at Arroga's Grille House, 4301 Linglestown Road, Harrisburg, PA 17112. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.46 SO ANSWERS, November 08, 2013 RON � R ANDERSON, SHERIFF (0)CountySuite Sheriff,Tcleosoft,Inc. o 13t1t Shelley Ruhl Jack Duignan Chief Deputy Real Estate Deputy Matthew L. Owens Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff CARLISLE CEMENT PRODUCTS Commonwealth of Pennsylvania COMPANY, INC. VS County of Dauphin CHRIS ARCHIBALD Sheriff s Return No. 2013-T-2920 OTHER COUNTY NO. 2013-6202 And now:NOVEMBER 6, 2013 at 8:28:00 AM served the within NOTICE & COMPLAINT upon CHRIS ARCHIBALD LANDSCAPE DESIGN by personally handing to CHRIS ARCHIBALD * 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at MEETING PLACE: AROOGA'S GRILLE HOUSE, 4301 LINGLESTOWN ROAD HARRISBURG PA 17112 * OWNER Sworn and subscribed to So Answers,! before me this 7TH day of November, 2013 p i ' Sheriff of D uphin C.�c�t�ty a. Y COMMONWEALTH OF PENNSYLVANIA uty S eriff NOTARIAL SEAL Deputy: W CONWAY Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 11/5/2013 M Commission Expires Au gust 17,2014 - th. ` - Shelleyy Ruhl •,,_.,�, Jack Duignan Real Estale Deputy '• Chief Deputy Matthew L. Owens ® Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania CARLISLE CEMENT PRODUCTS COMPANY, INC. VS County of Dauphin CHRIS ARCHIBALD Sheriff s Return No. 2413-T-2920 OTHER COUNTY NO. 2013-6202 And now:NOVEMBER 6, 2013 at 8:28:00 AM served the within NOTICE& COMPLAINT upon CHRIS ARCHIBALD by personally handing to CHRIS ARCHIBALD 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at MEETING PLACE: AROOGA'S GRILLE HOUSE, 4301 LINGLESTOWN ROAD HARRISBURG PA 17112 Sworn and subscribed to So Answers, ! before me this 7TH day of November, 2013 Sheriff of D hin Co By COMMONWEALTH OF PENNSYLVANIA De ty Sheriff NOTARIAL SEAL Deputy: W CONWAY Karen M,Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 11/5/2013 M Commission Expires August 17,2014 Salzmann Hughes,P.C. Samuel E.Wiser,Jr.,Esquire Attorney I.D.No. 203665 Melissa L.Kelso,Esquire Attorney I.D.No.306793 79 St.Paul Drive Chambersburg,PA 17201 Telephone:717-263-2121 Fax 717-261-9998 : IN THE COURT OF COMMON PLEAS OF Carlisle Cement Products Company, Inc. : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff vs. : No. 13-6202 2 r -t7 C Chris Archibald, individually and : CIVIL ACTION �, 'Ti- d/b/a Chris Archibald Landscape Design "''z" II si Defendant • c co ti N.) :t TO: Chris Archibald and Chris Archibald Landscape Design 102 Steeplechase Lane 5999 Union Deposit Road Harrisburg, PA 17112 Harrisburg, PA 17112 DATE OF NOTICE: November 27, 2013 IMPORTANT NOTICE 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 (10) 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 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1800-990-9108 717-249-3166 Respectfully submitted, SALZMANN : HUGHES,, P .C. Date: fl� d�� j By:,/Samuel E. Wiser, Jr., Esquire Attorney I.D. No. 203665 Melissa L. Kelso, Esquire Attorney I.D. No. 306793 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on the l/ day of November 2013, I served a true and correct copy of the foregoing document via United States mail, first class mail, postage prepaid, and addressed as follows: Chris Archibald 102 Steeplechase Lane Harrisburg, PA 17112 Chris Archibald Landscape Design 5999 Union Deposit Road Harrisburg, PA 17112 Salzmann Hughes, P.C. By: / Melissa L. Kelso, Esquire Salzmann Hughes, P.C. Samuel E. Wiser, Jr., Esquire Attorney 1.D. No, 203665 Melissa L. Kelso, Esquire Attorney I.D. No. 306793 79 St. Paul Drive Chambersburg, PA 17201 Telephone: 717-263-2121 Fax 717-261-9998 - -.C L, Pkai NON° 1,614 JUL 3 1 Pt j: CUNBERL A ND COLIN T Y PENNSYLVANIA Carlisle Cement Products Company, Inc. Plaintiff vs. Chris Archibald, individually and d/b/a Chris Archibald Landscape Design Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : No. 2013-6202 : CIVIL ACTION PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Kindly enter judgment by default against the above named Defendant Christ Archibald, individually and doing business as Chris Archibald Landscape Design in the amount of Twenty Four Thousand, Forty -Five Dollars and Forty -Four Cents ($24,045.44) plus interests and costs for Defendant's failure to timely respond to Plaintiff's Complaint with the required time period . Attached as Exhibit "A" is a copy of Plaintiff's written Notice in accordance with Rule 237.1, which I certify was mailed by regular mail to Defendant Chris Archibald individually and doing business as Archibald Landscape Design on November 27, 2013, which is at least 10 days prior to the filing of this Praecipe Date: By: Respectfully submitted, SALZMANN HUGHES, P.C. Samuel E. Wiser, Jr., Esquire Attorney ID# 203665 Melissa L. Kelso, Esquire Attorney I.D. No. 306793 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff OW U ftLi "Pet 1)ce 11/14:-/ei AND NOW, �J U 3 2014,'ud ! � gmen t is entered in favor of Plaintiff and against Defendant Christ Archibald, individually and doing business as Chris Archibald Landscape Design in the amount of Twenty Four Thousand, Forty -Five Dollars and Forty -Four Cents ($24,045.44) plus interests and costs. Prothonota 'Salzmann Hughes. P.C. Samuel E. Wiser, Jr., Esquire Attorney I.D. No. 203665 Melissa L. Kelso, Esquire Attorney W. No. 306793 79 St. Paul Drive Chambersburg, PA 17201 Telephone: 717-263-2121 Fax 717-261-9998 Carlisle Cement Products Company, Inc. Plaintiff vs. Chris Archibald, individually and d/b/a Chris Archibald Landscape Design Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA (-3 : No. 13-6202 : CIVIL ACTION - CD w_ TO: Chris Archibald 102 Steeplechase Lane Harrisburg, PA 17112 and DATE OF NOTICE: November 27, 2013 Chris Archibald Landscape Design 5999 Union Deposit Road Harrisburg, PA 17112 IMPORTANT NOTICE 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 (10) 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 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1800-990-9108 717-249-3166 PLAINTIFF'S EXHIBIT Respectfully submitted, SALZMANN HUGHES, P.C. z By: (f Samuel E. Wiser, Jr., Esquire Attorney I.D. No. 203665 Melissa L. Kelso, Esquire Attorney I.D. No. 306793 79 St. Paul Drive Chambersburg, PA 17201 (717) 263-2121 Counsel for Plaintiff CERTIFICATE OF SERVICE I hereby certify that on the day of November 2013, I served a true and correct copy of the foregoing document via United States mail, first class mail, postage prepaid, and addressed as follows: Chris Archibald 102 Steeplechase Lane Harrisburg, PA 17112 Chris Archibald Landscape Design 5999 Union Deposit Road Harrisburg, PA 17112 Salzmann Hughes, P.C. Melissa L. Kelso, Esquire CERTIFICATE OF SERVICE (-)el• I hereby certify that on the at 1 day of July 2014, I served a true and correct copy of the foregoing document via United States mail, first class mail, postage prepaid, and addressed as follows: Chris Archibald 102 Steeplechase Lane Harrisburg, PA 17112 Chris Archibald Landscape Design 5999 Union Deposit Road Harrisburg, PA 17112 By: Salzmann Hughes, P.C. elissa L. Kelso, Esquire