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HomeMy WebLinkAbout13-6396 Supreme Co ennsylvania Cour Co`�mmo neas For Prothonotary Use Only: it per S t rr- rt e Docket No: S' County 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 bylaw or rules of court. r -- I Commencement of Action: Complaint © Writ of Summons Petition S• Transfer from Another Jurisdiction ® ®Declaration of Taking E: C ' Lead Plaintiffs Name: Lead Defendant's Name: T , Carlisle Cement Products Company Stoltzfus Landscape Contracting, LLC Dollar Amount Requested: x within arbitration limits I Are money damages requested? ® Yes ® No i (check one) ®outside arbitration limits O N Is this a Class Action Suit? © Yes 0 No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff /Appellant's Attorney: Melissa L. Kelso, Esquire © Check here if you have no attorney (are a Self- Represented [Pro Se] 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 h'P a of claim, check the one that you consider most important. " TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS © Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card ® Board of Assessment © Motor Vehicle x] Debt Collection: Other ® Board of Elections ® Nuisance Dept. of Transportation Premises Liability Statutory Appeal: Other S' ® Product Liability (does not include � Employment Dispute: E mass tort) ® Slander/Libel/ Defamation Discrimination C' ® Other: Employment Dispute: Other ®Zoning Board T. ® Other: I ' © Other: O MASS TORT © Asbestos N © Tobacco © Toxic Tort - DES ® Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS Q Toxic Waste ® Other: ®Ejectment � Common Law /Statutory Arbitration B ® Eminent Domain/Condemnation 0 Declaratory Judgment O Ground Rent Mandamus Landlord/Tenant Dispute Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY g g t Quo Warranto ® Mort a e Foreclosure: Commercial D Dental ©J Partition 0 Replevin ® Legal ® Quiet Title - -i Other: ® Medical ® Other: ® Other Professional: Updated 1/112011 t t E 0 F ICL. 2 ` 1 00T 30 A1 4 1 11: 34 Salzmann Hughes, P.C. E UM B[ R" L A N D CO Samuel E. Wiser, Jr., Esquire PENNSY 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 IN THE COURT OF COMMON PLEAS OF CARLISLE CEMENT PRODUCTS, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff q / STOLTZFUS LANDSCAPE CONTRACTING, LLC, and CIVIL ACTION JONATHAN STOLTZFUS Defendants 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 103.751 a . a 1 �- dq 7s3q IN THE COURT OF COMMON PLEAS OF CARLISLE CEMENT PRODUCTS, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. STOLTZFUS LANDSCAPE CONTRACTING, LLC, and CIVIL ACTION JONATHAN STOLTZFUS Defendants 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, Cumberland County, Pennsylvania. 2. Defendant Stoltzfus Landscape Contracting, LLC ( "Defendant Stoltzfus Landscape "), is a limited liability company with its registered office located at 220 Keystone Drive, Middletown, Dauphin County, Pennsylvania. 3. Defendant Jonathan Stoltzfus ( "Defendant Stoltzfus ") is the principal owner and manager of Stolzfus Landscape Contracting, LLC. 4. Plaintiff operates a business which supplies cement and masonry related products ( "Products ") to retailers, contractors, and consumers. 5. Defendant Stoltzfus Landscape is an entity involved in contracting that purchases cement and masonry related products to incorporate into work that Defendants complete for its customers. 2 r 6. In November 2006, Defendants requested that Plaintiff extend credit to Defendant Stoltzfus Landscape to accommodate Defendant Stoltzfus Landscape's purchase of Plaintiff's products. 7. Defendants completed an application for the extension of credit by Plaintiff. A true and correct copy of the Credit Application is attached hereto as Exhibit "A." 8. Upon the execution of the Credit Application, Defendants agreed to the conditions related to Plaintiff's extension of credit to Defendant Stoltzfus Landscape. 9. Plaintiff granted Defendants' request for credit, thereby creating a contract between the parties ( "Agreement One "), and established a credit account for Defendant Stoltzfus Landscape, identified as Account Number 214 ( "Credit Account #214 "). 10. From approximately December 2006 to June 2012, Defendant Stoltzfus Landscape requested that Plaintiff supply it with products, the cost of which was billed to Defendant Stoltzfus Landscape's Credit Account #214. 11. In February 2011, Defendants requested a second, separate credit account from Plaintiff for supplies that Defendants sought for the Pennsylvania Garden Expo. 12. Plaintiff granted Defendants' request without requiring a new credit application, thereby creating another contract between the parties ( "Agreement Two ") and established a second credit account for both Defendants, identified as Account Number 383 ( "Credit Account 4383 "). 13. Whereas Credit Account #214 was issued solely to Defendant Stoltzfus Landscape, Credit Account #383 was issued jointly to Defendant Stoltzfus Landscape (the business entity) and Defendant Jonathan Stoltzfus personally. 14. By executing the first Credit Application and orally agreeing to open a second credit account as well, Defendants agreed to abide by the terms included in the Application, which included 3 the agreement to pay a finance charge of the lesser of 1.5% 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 Agreements. 15. The products were delivered in the quantities and for the prices set forth on invoices provided to the Defendants. A true and correct copy of the latest invoice for Credit Account #214 is attached hereto and incorporated herein as Exhibit `B;" a true and correct copy of the latest invoice for Credit Account #383 is attached hereto and incorporated herein as Exhibit "C." 16. These invoices were provided to Defendants upon delivery of products and a summary of the charges were included in a billing statement. 17. Defendants received and continue to receive monthly billing statements reflecting the invoiced amounts. 18. The prices that Plaintiff charged Defendants for its products are fair, reasonable market prices and they are the prices that Defendants agreed to pay. 19. The balance due and owing for invoices dated March 4, 2011 through September 25, 2012 on Defendant Stoltzfus Landscape's Credit Account #214 is Twenty Seven Thousand, One Hundred Five Dollars and Thirty Cents ($27,105.30). See Exhibit `B." 20. The balance due and owing for invoices dated February 18, 2011 through September 25, 2013, on Defendants Stoltzfus Landscape's and Jonathan Stoltzfus' Credit Account #383 is Seventeen Thousand, Three Hundred Dollars and Six Cents ($17,300.06). See Exhibit "C." 21. Although demand has been made, Defendants have failed to make payment of the amount due and owing for each account. 4 Count I — Breach of Contract Against Defendant Stoltzfus Landscape 22. Plaintiff incorporates the averments of the preceding paragraphs as if set forth at length. 23. Plaintiff and Defendant Stoltzfus Landscape entered into two contracts, Agreement One and Agreement Two, pursuant to which Plaintiff would provide Defendant Stoltzfus Landscape with products at Defendant's request, charge the purchase price of these products to Defendant Stoltzfus Landscape's line of credit and Defendant Stoltzfus Landscape would pay Plaintiff the purchase price of these products. 24. Plaintiff provided Defendant Stoltzfus Landscape with the products requested. 25. Defendant Stoltzfus Landscape has failed to compensate Plaintiff for all products that Defendant Stoltzfus Landscape received and retained under both Agreements. 26. Defendant Stoltzfus Landscape's failure to make full payment to Plaintiff breaches the parties' Agreements. 27. Defendant Stoltzfus Landscape's breach of the parties' Agreements has damaged Plaintiff. 28. Specifically, the combined balance due for both accounts is Forty Four Thousand, Four Hundred Five Dollars and Thirty Six Cents ($44,405.36), of which Defendant Stoltzfus Landscape is individually liable for Twenty Seven Thousand, One Hundred Five Dollars and Thirty Cents ($27,105.30), and jointly and severally liable with Defendant Jonathan Stoltzfus for the remaining balance of Seventeen Thousand, Three Hundred Dollars and Six Cents ($17,300.06). 29. Defendant Stoltzfus Landscape's breach of the parties Agreements entitles Plaintiff to compensation for its reasonable attorneys' fees and collection costs associated with this action. 30. An award of attorneys' fees of fifteen percent (15 %) of the amount due and owing to Plaintiff by Defendant Stoltzfus Landscape on the combined delinquent accounts in the amount of 5 Six Thousand, Six Hundred Sixty Dollars and Eighty Cents ($6,660.80) is an amount which reflects reasonable attorney fees related to the costs of collection of the delinquent amounts. 31. Defendant Stoltzfus Landscape's breach of the parties' Agreement therefore entitles Plaintiff to a total of Fifty One Thousand, Sixty Six Dollars and Sixteen Cents ($51,066.16), plus costs of this action. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant Stoltzfus Landscape in the amount of Fifty One Thousand, Sixty Six Dollars and Sixteen Cents ($51,066.16), plus costs of this action, along with all other fees and costs deemed just. Count II — Breach of Contract Against Defendant Jonathan Stoltzfus 32. Plaintiff incorporates the averments of the preceding paragraphs as if set forth at length. 33. Plaintiff and Defendant Jonathan Stoltzfus entered into a contract pursuant to which Plaintiff would provide Defendant Jonathan Stoltzfus with products at Defendant's request, charge the purchase price of these products to Defendant Jonathan Stoltzfus' line of credit and Defendant Jonathan Stoltzfus would pay Plaintiff the purchase price of these products. 34. The parties agreed that Defendant Jonathan Soltzfus's Agreement would follow the same terms as Defendant Stoltzfus Landscape's Agreement with Plaintiff. 35. Plaintiff provided Defendant Jonathan Stoltzfus with the products requested. 36. Defendant Jonathan Stoltzfus has failed to compensate Plaintiff for all products that Defendant Jonathan Stoltzfus received and retained under Agreement Two. 37. Defendant Jonathan Stoltzfus' failure to make full payment to Plaintiff breaches the parties' Agreement. 38. Defendant Jonathan Stoltzfus' breach of the parties' Agreement has damaged Plaintiff. 6 39. Specifically, the balance due for Credit Account #383 is Seventeen. Thousand, Three Hundred Dollars and Six Cents ($17,300.06), which Defendant Jonathan Stoltzfus is jointly and severally liable for with Defendant Stoltzfus Landscape. 40. Defendant Jonathan Stoltzfus' breach of the parties Agreement entitles Plaintiff to compensation for its reasonable attorneys' fees and collection costs associated with this action. 41. Fifteen Percent (15 %) of the amount due and owing to Plaintiff by Defendant Jonathan Stoltzfus on the delinquent account in the amount of Two Thousand, Five Hundred Ninety -Five Dollars ($2,595) is an amount which reflects reasonable attorney fees related to the costs of collection of the delinquent amounts. 42. Defendant Jonathan Stoltzfus' breach of the parties' Agreement therefore entitles Plaintiff to a total of Nineteen Thousand, Eight Hundred Ninety -Five Dollars and Six Cents ($19,895.06), plus costs of this action. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant Jonathan Stoltzfus in the amount of Nineteen Thousand, Eight Hundred Ninety -Five Dollars and Six Cents ($19,895.06), plus costs of this action, along with all other fees and costs deemed just. Count III = Unjust Enrichment Against Defendant Stoltzfus Landscape 43. Plaintiff incorporates the averments of the preceding paragraphs as if set forth at length. 44. Plaintiff provided Defendant Stoltzfus Landscape with products at Defendant Stoltzfus Landscape's request. 45. Defendant Stoltzfus Landscape received, accepted and retained these products and the benefit of these products. 7 46. Defendant Stoltzfus Landscape failed to compensate Plaintiff for the benefit of these products, at the expense of Plaintiff. 47. Permitting Defendant to retain the benefit of these products without compensating Plaintiff unjustly enriches Defendant Stoltzfus Landscape to the detriment of Plaintiff. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant Stoltzfus Landscape in the amount of Fifty One Thousand, Sixty Six Dollars and Sixteen Cents ($51,066.16), plus costs of this action, along with all other fees and costs deemed just. Count III — Uniust Enrichment Against Defendant Stoltzfus Landscape 48. Plaintiff incorporates the averments of the preceding paragraphs as if set forth at length. 49. Plaintiff provided Defendant Jonathan Stoltzfus with products at Defendant Jonathan Stoltzfus' request. 50. Defendant Jonathan Stoltzfus received, accepted and retained these products and the benefit of these products. 51. Defendant Jonathan Stoltzfus failed to compensate Plaintiff for the benefit of these products, at the expense Plaintiff. 52. Permitting Defendant Jonathan Stoltzfus to retain the benefit of these products without compensating Plaintiff unjustly enriches Defendant Jonathan Stoltzfus to the detriment of Plaintiff. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant Jonathan Stoltzfus in the amount of Nineteen Thousand, Eight Hundred Ninety -Five Dollars and Six Cents ($19,895.06), plus costs of this action, along with all other fees and costs deemed just. 8 Respectfully submitted, SALZMANN HUGHES, P.C. Date: y' aS(' 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 9 VERIFICATION I 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 unsworn falsification to authorities. Carlisle Cement Products Company Date: $ J6hA M. umberger, III sident 10 NOV - 18 -2008 0345 PM P. 09/10 CA RLI SLE CEMENT PRODUCTS CO., INC. CARLISLE PA MAILING ADDRgA.S OFFICE /PLANT P.O. BOX 617 610 E. NORTH ST. RETAIL OFFICE (717) 243 -5323 MANUFACTURING �~ (717) 243 -4225 (� FAX 1. (7 17) 243 -6604 CREDIT APPLICATION Company Name _✓ ' " /' / '' 1' �°.- < - c r.. Address r -oo� 17111 Primary Phone � - d (Mobile Fax 7, 7 Contact Name Tax Status TAXABLE EXEMPT exemption certificate required) Tax ID # ..�' PO Required ,-___ YES NO Type of Business SOLE PROPRIETOR PARTNERSHIP CORP. Nature of Business t ,..�.rG•�zlc Name of Owner /President ,�-•, K.�K /„� `/��� /" Years in Business Desired Line of Credit Bank Name /Contact- A ,cam /! l✓ /� /"�n��r.T•� Phone # /Fax Account # EX BIT b . D NOV -18 -2008 0346 PM P. 10 /10 CARLISLE CEMENT KOPUCTS CO.. tNC. CARLIS3LE PA MAILINO ADDI ESA OFFIC"LAN P.O. BOX 617 610 E. NORTH ST. RETAIL OFFICE (717) 243 -5323 MANUFACTURING (717) 243 -1225 FAX (717) 243 -6604 1 Com an /Genteel � �' �- � � Address / Phone /Fax -2.z ,x- /.�.• . /'.� -r 1i� 7 Account # -�- (2) Company /Contact Address/Phone/Fax c. /7,, 7 J� 2,7-- JS 'J �,,X Account # (3) Company /Contact g Address /Phone /Fax Account # The undersigned affirmb that the information provided is complete, trua.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 terms Itemized on each involos. The COMPANY understands that if on account is established, the credit line Is subject to periodic review. Shipments may be held if the account is delinquentor exceeds the established fide of credit The CO MPANY agrees to pay a finance charge of the lesser of 1.5% per month (10% annual) or the maximum permitted by law for any unpaid balances beyond its terms. The COMPANY agrees to pay a Returned Chock Fee of $26.00 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 a nd attorney's fees. Resolution for any dispute related to the account shall be the exclusive Jurisdiction of the courts in Cumberland County Pennsylvania. It is agreed that any rights under this agreamant are nontransferable and that written notice is to be provided to CARLISLE CEMENT PRODUCTS 80 days befora the transfer or sale of any substantial part of the COMPANY'S Mtsiness. AUUW rixed Signatu Print Name I Title Date Ale% c .� t >,, Carlisle Cement Products, In Account Statement PO BOX 617 Carlisle, PA 17013 -0617 Account Number: 0000214 717- 243 -5323 Due Date: Net 30 Balance: $27,105.30 STOLTZFUS LANDSCAPE CONTRACTING, LLC Minimum Payment: $0.00 STOLTZFUS LANDSCAPE CONTRACTING, LLC /ON HO Amount Enclosed: JONATHAN STOLTZFUS/PO REQUIRED 220 KEYSTONE DRIVE MIDDLETOWN , PA 17057 l IIIiII IIIIi N!I! Illll 11111 1111 II Please detach and enclose fop portion with payment. I IIIlillllll -- -------------------------------------------------------------------------------------------- - - - -.. A c c o u n t Sum m a ry NO md Account Number: 0000214 Closing Date: 9/25/2012 Name: STOLTZFUS LANDSCAPE CO Due Date: Net 30 STOLTZFUS LANDSCAPE CO JONATHAN STOLTZFUS /PO 220 KEYSTONE DRIVE MIDDLETOWN , PA 17057 Previous Balance: $27,105.30 New Charges: $0.00 Credits / Payments: $0.00 '-- -_ - -__ A, V New Balance: $27,105.30 y{ $0.00 . $0.00 $0.00 $0.00 l $27,1 Y 05.30 $ A c c o u n t Activity C aTM. � �1' ;cliff No account activity during this period * ** LE31T Account Number: 0000214 Page 1 of 1 Carlisle Cement Products, In Account Statement PO BOX 617 Carlisle, PA 17013 -0617 Account Number: 0000383 717- 243 -5323 Due Date: Net 30 Balance: $17,300.06 Minimum Payment: $0.00 JONATHAN STOLTZFUS - SHOW ACCT JONATHAN STOLTZFUS - SHOW ACCT /ON HOLD Amount Enclosed: STOLTZFUS LANDSCAPE CONTRACTING, LLC 220 KEYSTONE DRIVE MIDDLETOWN , PA 17057 I IIIIII VIII VIII VIII VIII III() VIII III) IIII Please detach and enclose top portion with payment. ----------------------------------------------------------------------------------------------------- A c c o u n t Sum m a ry Account Number: 0000383 Closing Date: 9/25/2012 Name: JONATHAN STOLTZFUS - SH Due Date: Net 30 JONATHAN STOLTZFUS - SH STOLTZFUS LANDSCAPE CO 220 KEYSTONE DRIVE MIDDLETOWN , PA 17057 Previous Balance: $17,043.37 New Charges: $256.69 Credits / Payments: $0.00 ------------- - - - - -- ------------------- ------------------- --------------- - - -- New Balance: $17,300.06 $509.57 1 $0.00 1 $241.21 1 $245.55 $16,303.73 $17,300.06 A c c o u n t A c tiv ity 9/25/2012 Finance Charge — Finance Charge #76906 $256.69 EXHIBIT C Account Number: 0000383 Page 1 of 1 SHERIFF'S OFFICE OF CUMBERLAND COUNT( i R Ronny RAnderson I HE '9, i l" � Sheriff 113 F OV 18 PAM 2: 22 Jody S Smith r Chief Deputy CUMBERLAND COUNTY Richard W Stewart PENNSYLVANIA Solicitor `"wE S"ERErw Carlisle Cement Products Company Case Number vs. Stoltzfus Landscape Contracting, LLC (et al.) 2013-6396 SHERIFF'S RETURN OF SERVICE 10/31/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Stoltzfus Landscape Contracting, LLC, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Affidavit according to law. 10/31/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jonathan Stoltzfus, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Affidavit according to law. 11/07/2013 The requested Complaint& Notice served by the Sheriff of Dauphin County upon Jonathan Stolzfus, who accepted for Stoltzfus Landscape Contracting, LLC, at 222 Noth Paxtang Avenue, Harrisburg, PA 17111. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 11/14/2013 10:54 AM -The requested Complaint&Notice served by the Sheriff of Dauphin County upon Jonathan Stoltzfus, personally, at 222 North Paxtang Avenue, Harrisburg, PA 17111. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.46 SO ANSWERS, November 14, 2013 RONIV y R ANDERSON, SHERIFF (^!Ccult'i``,ulfe She!Ifi,TflicO50ft 111'- Of Ale �&hvrf-f Shelle Ruhl Jack Duignan Real Esta a 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, INC. VS STOLTZFUS LANDSCAPING County of Dauphin CONTRACTING, LLC Sheriff s Return No. 2013-T-2901 OTHER COUNTY NO. 2013-6396 And now: NOVEMBER 7, 2013 at 10:54:00 AM served the within NOTICE& COMPLAINT upon STOLTZFUS LANDSCAPING CONTRACTING, LLC by personally handing to JONATHAN STOLTZFUS * 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 222 NORTH PAXTANG AVENUE HARRISBURG PA 17111 DEFENDANT IS NOT LOCATED AT ADDRESS 220 KEYSTONE DRIVE, MIDDLETOWN, PA 17057. GOOD ADDRESS FOR DEFENDANT IS 222 NORTH PAXTANG AVENUE, HARRISBURG, PA 17111. * OWNER Sworn and subscribed to So Answers, before me this 8TH day of November, 2013 Q ��� Y of Dan C Pa. .. B 41 .' COMMONWEALTH OF PENNSYLVANIA De p Sheriff NOTARIAL SEAL De ty: J STRAINING Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 11/1/2013 My Commission Expires August 17,2014 cpWitt, of the Shelley Ruhl Jack Duignan Real Esta e 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, INC. VS County of Dauphin STOLTZFUS LANDSCAPING CONTRACTING, LLC Sheriff s Return No. 2013-T-2901 OTHER COUNTY NO. 2013-6396 And now: NOVEMBER 7, 2013 at 10:54:00 AM served the within NOTICE & COMPLAINT upon JONATHAN STOLTZFUS by personally handing to JONATHAN STOLTZFUS 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 222 NORTH PAXTANG AVENUE HARRISBURG PA 17111 DEFENDANT DOES NOT RESIDE AT ADDRESS 220 KEYSTONE DRIVE, MIDDLETOWN, PA 17057. GOOD ADDRESS FOR DEFENDANT IS 222 NORTH PAXTANG AVENUE, HARRISBURG, PA 17111. Sworn and subscribed to So Answers, ! before me this 8TH day of November, 2013 ,,,� f�� Sher' of Daup in Co ty, Pa. - J�`( .. By COMMONWEALTH OF PENNSYLVANIA De Sheriff NOTARIAL SEAL De ty: J STRAINING Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $66.5 11/1/2013 My Commission Expires August 17,2014