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Home My WebLink About05-6336IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION successor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., I-T No. O5 -X331, (2c?LL ? Plaintiff, xv, vs. COMPLAINT IN CONFESSION OF JUDGMENT RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN FILE NO. C0061185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION successor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Civil Action No. Plaintiff, VS. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants. COMPLAINT IN CONFESSION OF JUDGMENT 1. Plaintiff is a corporation having its principal place of business at 201 Corey Avenue, Braddock, Allegheny County, Pennsylvania 15104. 2. Defendant Russ Rineer Contracting, Inc. f/d/b/a Russel A Rineer, a sole proprietorship (hereinafter "Defendant Russ Rineer Contracting"), is a corporation having its place of business at 104 S. 17th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Defendant Russel A. Rineer, Jr. is an adult individual engaged in business at 104 S. 17th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 4. On or about May 22, 1998, Defendant Russel A. Rineer, Jr. entered into a Guaranty and Suretyship Agreement, and Defendant Russ Rineer Contracting completed an Application for December Of, 2005 Page 2 Credit, true and correct copies of which are attached hereto as Exhibit "A" and Exhibit "B", respectively (both hereinafter collectively referred to as the Note). 5. Plaintiff sold goods on credit to Defendants, Russ Rineer Contracting and Russel A. Rineer, Jr., in the principal amount of Nine Thousand Six Hundred Twenty-four dollars and Seventy-six cents ($9,624.76) as is evidenced by that certain Statement of Account and Invoices, true and correct copies of which are collectively attached hereto as Exhibit "C". 6. An Event of Default has occurred within the meaning of the Note as the result of, inter alia, the Defendants' failure to have made payments to Plaintiff as they became due. All notice requirements have been fulfilled. The Note has been accelerated. 7. The Note has not been assigned. 8. Plaintiff is the holder of the Note. 9. Judgment has not been entered on the Note against the Defendants in this or any other jurisdiction. 10. The amount due from the Defendants, jointly and severally, to Plaintiff for which Judgment is authorized, as of November 25, 2005, is $12,355.79 computed as follows: Unpaid Principal Balance $ 9,624.76 Interest to 11/25/05 $ 259.87 Attomeys' Fees at 25% $ 2,471.16 TOTAL $12,355.79 11. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. December 01 2005 Page 3 12. The underlying transaction, as evidenced in part by Exhibit "A" and Exhibit "B", is a commercial transaction. WHEREFORE, Plaintiff demands Judgment be entered in its favor and against the Defendants, Russ Rineer Contracting and Russel A. Rineer, Jr., jointly and severally, in the amount of $12,355.79 plus costs and interest at the contractual rate from and after November 25, 2005 as provided in Exhibit "B". Dated: ceM , 2005 BERNSTEIN LAW FIRM, P.C. By. X WW4 Christopher M. Boback, Esquire Attorney for Plaintiff PA I.D. #91730 Suite 2200 Gulf Tower Pittsburgh, PA 15219 December 01, 2005 Page 4 Pursuant to the authority contained in the warrant of attorney, a copy of which is attached to the Complaint filed in this action, I hereby appear for the Defendants and confess judgment in favor of the Plaintiff and against the Defendants, jointly and severally, as follows: Unpaid Principal Balance $ 9,624.76 Interest to 11/25/05 $ 259.87 Attorneys' Fees at 25% $ 2,471.16 TOTAL $12,355.79 plus costs and interest (at the contractual rate of .5%) from and after November 25, 2005. i Al rn`fl Attorney for Defendant Pro hac vice December 01, 2005 Page 5 CERTIFICATE OF ADDRESS I hereby certify that the precise address of Plaintiff is: 201 Corey Avenue Braddock, PA 15104 I further certify that the last known address of the Defendants is: 104 S. 171n Street Camp Hill, PA 17011 I further certify that the underlying transaction, as evidenced in part by Exhibit "B" attached hereto, is a commercial transaction. Dated: 2005 ?? December 01, 2005 Page 6 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are/ e n active members of the Armed Forces of the United States or any other military or non-military service covered by the Servicemembers Civil Relief Act, as amended, December, 2003 ("SCRA"). The undersigned further states that if said party is engaged in military or non-military service, as defined within the SCRA, the undersigned is without receipt of or knowledge of an Application for Relief as required by the SCRA. The undersigned fixrther states that the information is true and correct to the best of the undersigned's knowledge and belief and upon infonnation received from others. 44/V December 01, 2005 Page 7 AFFIDAVIT OF NON-CONSUMER CREDIT TRANSACTION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities, that the judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. December 01, 2005 Page 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION successor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Civil Action No. Plaintiff, VS. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants. NOTICE PURSUANT TO 42 PA.C.S.A. 42737.1 STRIKING OFF OR OPENING JUDGMENT; PLEADINGS; PROCEDURE (a)(1) Relief from a judgment by confession shall be sought by petition. Except as provided in subparagraph (2), all grounds for relief whether to strike off the judgment or to open it must be asserted in a single petition. The petition maybe filed in the county in which the judgment was originally entered, in any county to which the judgment has been transferred or in any other county in which the sheriff has received a writ of execution directed to the sheriff to enforce the judgment. (2) The ground that the waiver of the due process rights of notice and hearing was not voluntary, intelligent and knowing shall be raised only (i) in support of a further request for a stay of execution where the court has not stayed execution despite the timely filing of a petition for relief from the judgment and the presentation of prima facie evidence of a defense; and (ii) as provided by Rule 2958.3 or Rule 2973.3. December 01, 2005 Page 9 (3) If written notice is served upon the petitioner pursuant to Rule 2956.1(c)(2) or Rule 2973.1(c), the petition shall be filed within thirty days after such service. Unless the defendant can demonstrate that there were compelling reasons for the delay, a petition not timely filed shall be denied. (b) If the petition states prima facie grounds for relief the court shall issue a rule to show cause and may grant a stay of proceedings. After being served with a copy of the petition the plaintiff shall file an answer on or before the return day of the rule. The return day of the rule shall be fixed by the court by local rule or special order. (c) A party waives all defenses and objections which are not included in the petition or answer. (d) The petition and the rule to show cause and the answer shall be served as provided in Rule 440. (e) The court shall dispose of the rule on petition and answer, and on any testimony, depositions, admissions and other evidence. The court for cause shown may stay proceedings on the petition insofar as it seeks to open the judgment pending disposition of the application to strike off the judgment. If evidence is produced which in a jury trial would require the issues to be submitted to the jury the court shall open the judgment. (0 The lien of the judgment or of any levy or attachment shall be preserved while the proceedings to strike off or open the judgment are pending. (g) If you, have been incorrectly identified as debtor, you are entitled to costs and reasonable attorneys' fees as determined by the court. JACK BROWN WHOLESALE OF HARRISBURG . DIVISION OF JACK BROWN WHOLESALE SUPPLY INC. ?2969 N. 7TH STREET • HARRISBURG, PA 17110 VA I 717/234-8500 • 800/228-6687 1 1? ¦ am" •••nw• Y MNM MWI A APPLICATION FOR CREDIT AND WHOLESALE PRMLEGES CONFIDENTIAL / C 1S 4Q ?JI;£? ?/? Ll I I /? TI40E Typeof Business This is s FsrinDati WW& /:,4 m n7 L . r 3+ 7 Di / Propdstomhip A0D•"` Pwmmhip arr. STATE a aP Corpomilon Sy,? ?.?0 ea•+Ew nrona Social Sscurlty Number 191 of Propd%0 Partner) PRINCIPALS - OWNERS Banic Account. No. Addmss Account Carthd in Name at TRADE SUPPLIERS RVERENCM Bank J W UQ kill jfNCj S i7` Account No. d .) S/ -2X-9 Adana, r2 -a n ,4^jn 06vows gl,? o Aceount Carded ,.J - In Name of jL&s A. --?> CREDIT INFORMATION: ',.lts's,name If sole proprla altip or partnenhip Do you own your own hww? ? You ? No Mwtpgsd by /U1?T I UnJS Qr ?x Fertsnl LD. No. (If Corporatlorrts Our Estimated Mord* RBW*wrants Are $ Our personal andla &Wnmp Rmux W Statement Is Attached ? (Fl mmiel Stetemrrre re for Jack Otero Wholwsle Supply, bm CONFIDENTIAL use only). OTHER INFORMATION YOU WEN TO FURNISH US: THE ABOVE INFORMATION IS FURNISHED FOR THE PURPOSE OF RECEIVING CREDIT FROM JACK 8ROWN WHOLESALE FOR THE DURCHASE OF MERCHANDISE ON OPEN ACCOUNT. YWE 00 HEREBY CEITRFY THAT THE STATEMENTS HEREIN SET FORTH ARE TRUE AND comg .r.. VWE HEREBY AUTHORIZE JACK BROWN WHOLESALE TO WHOM THIS APPLICATION IS MADE, ANY CREDIT BUREAU OR OTHER INVEFnGATNE AGENCY EMPLOYED BY SUCH PERSON. TO WVES MTE THE REFERENCES HEREIN LISTED OR STATEMENTS OR OTHER DATA OBTAINED FROM ME OR FROM ANY OTHER PERSON PERTAINING TO MY CREDIT AND FINANCIAL RESPONSIBILITY. AND. FURTHER. THE BUYER DOES HEREBY EMPOWER ANY ATTORNEY OR ANY COURT OF RECORD WITHIN THE UNITED STATES OF AMERICA TO APPEAR FOR A AND WITHOUT COMPLAINT FILED, CONFESS JUDGEMENT AGAINST IT AND IN FAVOR OF JACK BROWN WHOLESALE SUPPLY, INC. OR ANY SUCCESSORS ORASSIGN& AS OF ANY TERM, FOR THE UNPAID BALANCE OF ANY CREDIT EXTENDED TO THE BUYER ASA RESULT OF THE APPLICATION, TOGETHER WITH ANY UNPAID 1NTERESr THERON. ANY COSTS OF THE SUIT AND ATTORNEYS FEES OF 25% OF THE TOTAL INDESTEONESS,THE BUYER HEREBY WANES AND RELEASES ALL ERRORS IN SAID PROCEEDING,, WANES STAY OF EXECUTION. THE RIGHT OF INOUISRION OF THE PAYMENT, AGREES TO CONDEMNATION DF ANY PROPERTY LEVIED UPON BY VIRTUE OF ANY SUCH EXECUTION, AND WANES ALL EXEMPTION OF LEVY AND SALE OF ANY PROPERTY THAT NOW IS OR HEREAFTER MAY HE EXEMPTED BY LAW, Name of Business Date vS : 2 2 ?I GUARANTY AND SURETYSHIP AGREEMENT ,,I bg (p 1 In eonsids `ration forthe extension of credit for the purchase of goods to r i5 £? hereinafter referred to as "Buyer', by Jack Brown Wholesale Supply, Inc., hereinafter referred to as "Seller", hereinafter referred to as "Guarantors," jointly and severally agree that (1) In the event that the Buyer does not repay the Seller in accordance with the terms of any agreement between Buyer and Seller for the extension of credit for the purchase of goods In the normal course of business, the Guarantors, upon demand by Seller, shall promptly pay for the goods; (Z In the event of the failure of the Guarantors to perform in accordance with the foregoing paragraph, then the entire debt of the Debtor to the Seiler shall Immediately become dua, and the Guarantors hereby authorize the Prothonotary or any At- tomey of any Court of Record within the United States or elsewhereto appear for them and to confess judgment against the Guarantors In favor of the Sailer for any sum then due the Seller along with the court costs and attorney fees of Twenty-Five percent (25%t (3) This Agreement is a.dontinuing Guaranty and shall remain in effect until the receipt of written notice by registered mail, return receipt requested to the Sailer from the Guarantors evidencing their intention to terminate this Agreement; such ter. mination does not discharge any previous liability Incurred by the Guarantors under this Agreement; (4) This Agreement shall not be terminated or its obligations hereunder discharged by reason of any modification in the terms of any agreement between the Buyer and the Seiler, (5) This Agreement shall not be terminated or Its obligations hereunder discharged by any proprietary or structural change In the composition of the Buyer; (6) The Guarantors recognize the commercial nature of all transactions between the Buyer and Seller, M The Guarantors warrant that their Income is in excess of Ten Thousand and 001100 Dollars ($10.000); (8) The Sellers waiver of any breach of this Agreement by the Buyer shall not be deemed to be a Waiver of any other breach by the. Buyer, Recognizing that this is a contract of Suretyship and Guaranty, and with the intention to be legally bound, the Guarantors hereby execute this Agreement on the--AL?6,day c- 171 A (4 te?. - e7 Y rrmS. AeRy?mfl¢?°R? , 8?i b lCis° T±.. McClure-Johnston Company STATEMENT P.O. Box 200312 Pittsburgh, PA 15251-0312 , Phone: 412-351-4300 Fax. 412-351-1480 ry E-Mail: info@mcclurejohnston.com ?. = 10/19105 Website: www.mcclurejohnston.com 1 RUSSEL A. RINEER, JR. DBA RUSS RINKER CONTRACTING, INC. 104 S 17TH Sr CAMP HILL, PA 17011.5531 CA7E '' l?rvhzr~ /1A7P . , ? AdfoY/1?];i i"YAM72k7E 1'Ytki7?14fLaUN7 1P i ArIANGG PaymerK 05/09/05 386596 06/08/05 1065.01 - 1065.01 05/12/05 388133 06/11105 62.33 62.33 05/12/05 388134 06/11105 79.55 79,55 05116105 388930 - 06115/05 721.22 721,22 05116105 388937 0611905 62.13 62.13 05/16/05 388938 06115105 2178.62 2178.62 05/18/05 390426 06/17/05 252.11 252.11 05131105 394730 0650105 2013.28 2013.28 06/02/05 395771 07/02/05 81.30 81.30 06/02/05 395772 07/02105 1838.69 1838.69 06/30/05 406144 07/30105 722.72 - 722.72 07106/05 408207 0810905 57.19 57.19 07/12/05 410443 08/10/05 .20.51 20.51 67112/05 410553 08111/05 17.52 17.52 07113105 411061 08/12105 40.94 40,94 07/13105 411100 08/10105 -107.14 -107.14 07/18/05 412573 08/17/05 261.63 261.63 .08/19/05 425508 09/10/05 •63.43 63.43 08/30/05 RC1164 09109/05 118.49 08/30/05 93.49 PY 25.00 8751/05 SC3018 07/31/05 64.39 64.39 08/31/05 SC3109 08/31/05 133.28 133.28 0950/05 SC3193 09/30/05 138.93 138.93 .00 138.93 94985 9390. 98 9624.76 McClure-Johnston Company Pasto 201 Corey Avenue CREDIT Braddock, PA 15104-1321 - 412-351-4300 Fax: 412-351-1480 '? - .425508 E-Mail: info@mcclurejohnston.com 08/19/05 Website: www.mcclurejohnston.com RMSEL A. RINSER, JR. DBA ORIG INV RUSS RINEER CONTRACTING, INC. 388938 104 S 17TH ST , CAMP HILL, PA 17011-5531 e RLW H68 67 RGA 25498,2636 CALL C41007 08/1 9/05 PA VFT20DS VINYL FINISH TRIM-DESERT SAND -10 -10 0 EA 4.64 EA -46.40 VJ051DS ALCOA 5/8 J-CHANNEL DESERT SAN -2 -2 0 EA 4.16 EA -8,32 D AWOP6DS ALCOA VINYL OSC 101-DESERT SAN - -1 -1 0 EA 15.67 EA -15.67 D MS RESTOCKING CHARGE 1 1 0 EA 10.55 EA 10.55 -70.39 - 10. 55 - - 3.5 9 .00 -63.43 H68671 CALL 216715 107/06/05 IPA 1 I 1 RGV1824D5 ALCOA 18X24 RECT GABLE VENT-DE 2 2 0 EA 38.35 EA 76.70 BERT SAND RECTGVDS ALCOA 14X20 RECT GABLE VENT-DE 1 1 0 EA 34.16 EA 16 SERT SAND OG37AW ALCOA S" GUTTER 37'-WHITE 2 2 0 EA 67.98 EA 1 5.96 " .1 t".6 •rr "It nrrrw W r•rrrra Iltf Ir Ar •"iln rry.rr rv. a'W OrYrwde Ylrlr ?rrr n...,t..w.y terra r.rr?w erus r.ryey,. 246.82 .001 .001 14.811 .001 261 • 0 w J ! ! a-;orOM Y pz Ht to M min ow 1 IWO A pt H p gi 0.4 ?. its x i 3a ? .j ?? zt 1 Y r Y McClure-Johnston Company Past 0 201 Corey Avenue CREDIT Braddock, PA 15104-1321 n 412-351-4300 Fax: 412-351-1480 411100 E-Mail: info@mcclurejohnston.com 07/13/05 Website: www.mcclurejohnston.com' 1 man .. R' / RUSSEL. A. RINEER, JR. DBA ORIG INV 39 4730, - RUSS RINEER CONTRACTING, INC . 406144, 395 772 104 S 17TH ST , - CAMP HILL,. PA 17011-5531 RLW H6 867 RGA 25444 CALL C40258 07/ 13/ 05 PA 2 RT2PC ALCOA 2X3 DOWNSPOUT 10'-PEBBLE -3 -3 0 EA 11.80 EA -35.40 STONE CLAY VJ051PC ALCOA 5/8 J-CHANNEL PEBBLE CLA -4 -4 0 EA 4.16 EA -16.64 Y VJ121PC +ALCOA 1-1/4 J-CHANNEL PEBBLE -2 -2 0 EA 4.25 EA -8.50 CLAY PTS12VPC PRO-TECH T4 VENTED-PEBBLESTONE -1 -1 0 EA 10.98 EA - -10.98 CLAY PTS12NPC PRO-TECH T4 SOLID-PEBBLESTONE -1 -1 0 EA 10.79 EA -10.79 CLAY OG175PC ALCOA 5" OUTSIDE MITER-PEBBLE -4 -4 0 EA 3.87 EA -15.48 CLAY RTA2PC ALCOA 2X3 DOWNSPOUT CLIP-PEBBL -7 -7 0 EA .47 EA -3.29 ESTONE CLAY IM o: 101.08 . 00 - 6.0 6 .00 - -107.14 McClure-Johnston Company 7901 ALLENTOWN BLVD INVOICE HARRISBURG PA 17112 800-228-6687. FAX 717-671-1400 0 0 >r REMIT PAYMENT TO: P.O. BOX 200312 • PITTSBURGH, PA 15251-0312 411061 E-Mail: info@mcclurejohnston.com W 13/05 Webafte: www,mcclur ejohnston.com RUSSEL A. RINSER, JR. PEA RUSSEL A. RINSER, JR. DBA RUSS RINEER CONTRACTING, INC. RUSS RINSER CONTRACTING, INC. 104 S 17TH ST 104 S 17TH ST CAMP HILL-, PA 17011-5531 CAMP HILL, PA 17011-5531 RLW H68 67 CALL 219426 07/13/ 05 PA 1 1 RTA7PC ALCOA 2X3 A ELBOW-PEBBLESTONE 1 1 .0 EA 2.80 EA 2.80 CLAY QUADPC OSI QUAD #301-PEBBLE CLAY(52) 2 2 0 EA 4.94 EA 9.88 QUADDS OSI QUAD #425-DESERT SAND(22) - 2 2 0 EA 4.94 EA 9.88 PIISHAKE ELK 30YR PRESTIQUE-SHAKEWOOD 1 1 0 BN 48.17 SO 11 06 , iw+.ti.e w,w m r aHw.. r w r rrs. an k ?.p ,.NNNY wW ?rw•rr Wq. rrarrwr.rwr? abti b oe r ,?/ W ol+vlr ? as W ?r• a 1s W ! '"•?*++? 38.62 .00 .00 - 23 .00 90.94 = n ? 9G D N' 0-t OrOy vnn ttn m n r TAX V ? Fl M ?i t7 2` ??y$ &C` N UJ ??g4cC fn tp D l % 3 i i ~2 SY ? 'nom A a l 4:0 9 n RLWI H68671STAYTON CALL 218595 1 07/11/05 IPA I.v31 ft d4 . W a.wY r Wprr1??s.(w{ 1 A• w M+?w.+?aww ra wi..mrrr W W. .rr b er r wrr w? .u a m? r.ws w is.r w r}w w ua prof 99 .00 16,531 001 .00 Y 1 k <g 13.00 3.53 1 17.52 R w T TNT m n m ?. Z 0_1 OrCKO ?p 3?ul in X03 EP U) m = r N ;_? r gym?';?I? 4 _;a p i ci Z 03 0 fn t11 ti to w ? a ? ? ' ?T? ? i?1 o?SR 0-4 :r ?3 = s [] a a ? z N 6 b r 6 3 v .- rt D ? N ? m f?11 ? r Z r 9 r 3 McClure-Johnston Company Pasto 201 Corey Avenue CREDIT Braddock, PA 15104-1321 n 412-351-4300 Fax: 412-351-1480 , - 410443 E-Mail: info@mcclurejohnston.com Website: www.mcclurejohnston.com 07/12/05 1 A. RINEER, JR. DBA ORIG INV 394730 NEER CONTRACTING, INC. - 10;4S 7TH ST ® LL, PA ; 17011-5531 RLWH6 7RGA 23891 86 CALL C40233 07/ 12/ 05 PA x OG165PC ALCOA 5" INSIDE MITER-PEBBLE C -5 -5 0 EA 3 .87 EA -19.35 LAY -19.35 . 00 - 1.1 6 - ,00 -20.51 ?Dyy?9yymT?Tm?a(?x?, • R t _9o 0 a- • • O-1 oro(a 7-X M •} ) 6 C C + 9FNN I N N N m H F+ M jp 'q D = m m ;i ? i-4nz t c y ° n z? s o z ? S tR O-I ?-S ? gg fFNNN? ) N N D FIJI -lz3) S m m m? ° iN -i(13z 0m J 1 M J D+ a? ? A z J G1 m ? 3 z n 9g?? ? McClure?Johnston Company 7901 ALLENTOW N BLVD INVOICE HARRISBURG PA 17112 m 800-228-6687 FAX 717-671-1400 REMIT PAYMENT TO: P.O. BOX 200312 ' PITTSBURGH, PA 15251-0312 4 6 0 E-Mail: info@mcclurejohnston.com W /05 0 6 /3 Web site: www.mcclurejohnston.com RUSSEL A. RINSER, JR. DEA RUSSEL A. RINSER, JR. DBA RUSS RINSER CONTRACTING, INC.' RUSS RINSER CONTRACTING, I NC. 104 S 17TH ST 104 S 17TH ST CAMP HILL, PA 17011-5531 - CAMP HILL, PA 17011-5531 RLW H6 867 ...... N CALL - 214878 06/ 29/05 PA 1 1 PTSI2NPC PRO-TECH T4 SOLID-PEBBLESTONE 13 13 0 EA 10.79 EA 14 .27 CLAY PTS12VPC PRO-TECH T4 VENTED-PEBBLESTONE 3 3 0 EA 10.98 EA 2.94 CLAY T924PC TRIM COIL 24X50-PEBBLE CLAY 3 3 0 RL 62.02 RL 186.06 OG26PC ALCOA 5" GUTTER 26'-PEBSLESTON 1 1 0 EA 50.29 EA 50.29 E CLAY OGi55PC ALCOA 5" END CAP PEEnESTONE(2 10 30 0 EA 2.00 EA 20.00 SL-25R/CT) ••, RTA7PC ALCOA 2X3 A ELBOW-PEBBLESTONE 15 15 0 EA 2.80 EA 42.OD CLAY RTB7PC ALCOA 2X3 B ELBOW-PEBBLESTQNE 2 2 0 EA 2.80 EA 5.60 CLAY BR1PC ALCOA POP RIVETS-PEBBLE CLAY 2 2 0 EA 3.53 EA 7.06 OG175PC ALCOA 5" OUTSIDE MITER-PEBBLE 6 6 0 EA 3.87 EA 23.22 CLAY A51S1 5" ALUM SCREW-ON HIDDEN HANGER 100 100 0 EA .96 EA 96.00 QUADPC OSI QUAD #301-PEBBLE CLAY(52) 4 4 0 EA 4.94 EA 19.76 TS24DS TRIM COIL 24X50-DESERT SAND 1 1 0 RL 58.61 RL 58.61 -1/i{ Lrrls M bl k !r•1 r w• r YJ.s, lua It, •?iy 1 M pke • eYi M? •Ja Ml,n btl Yw 1? ?Ie,1,t 11 61 •!",111•"va Y,r,•1 evP ? s rs d •1 • • ?? •.we•??••?.+.. 681.81 .00 00 40.9 1 .00 722.72 m c D (r.rA }rt' 0 Dr N . ? f. xF?- t o .:• 1 S is Y1. R'. u : n m 0 A n O-I OrOw ? m ;D &cc CO U3 C N r D gg JZD 3n 2 m? Ef) z iin z m 9. d ? 99 3 D m? r -i s d ? aa D 3.'1 n y ?p a o-i a-= M. _ °rNND ? N M3 zrm I s NZ3) l l ° m f ? 2 p z N -lnz m z a.3 e M Z ? ?J 3 D y j .. 9?1 ? McClure-Johnston Company 7901 ALLENTOWN BLVD INVOICE HARRISBURG PA 17112 800-228-6687 FAX 717-671-1400 , REMIT PAYMENT TO: P.O. BOX 200312 ' PITTSBURGH, PA 15251-0312 395772 E-Mail: info@mcclurejohnston.com 06/02/05 Website: www.mcclurejohnston.com 2 RUSSEL A. RINSER, JR. DBA - RUSS RINSER CONTRACTING, INC. ' 104 S 17TH ST , p: CAMP HILL, PA 17011-5531 RLW B68 67 RUSS CALL 198268 05/1 2/05 PA 1 1 ; 1 A wl _ SRD6IPC +STRUCTURE D6-PEBBLE CLAY 10 10 0 'SO 120.74 SO 1207.40 SROP12PC ++STRUCTURE OSC-PEBBLE CLAY 2 2 0 EA 38.96 EA 77.92 VJ121PC +ALCOA 1-1/4 J-CHANNEL PEBBLE l.OD 1.00 .00 CT 169.89 CT 169.89 CLAY TS24W TRIM COIL 24X50-WHITE/WHITE 5 5 0 RL 55.88 RL 27 .40 I-I/I>s ?uM e.Yy OIY k Yv?Mm YI ? N kYV. (Ila M •vvp M vo. vUJ?tvYVY, WYO. iaW. WOw WA kw ks Y1p0Y vImYMYOV kwsl eoP NY Of [YOw dOhY Ynvat WYw,Y U><?a+a.r• 1734.61 .00 .00 104.0 8 .00 1838.69 _--------- ! ! ! ! 74 prom ?i In g`3 r 02. cg r?? Z ? r N ?? t'1? 16 VAC to 0 s3 N, 1 'PC 4 Q y P 03 •• Qti to V McClure-Johnston Company 7901 ALLENTOWN BLVD INVOICE HARRISBURG PA 17112 . 800-228-6687 FAX 717-671-1400 , , ry REMIT PAYMENT TO: P.O. BOX 200312 • PITTSBURGH, PA 15251-0312 395771 E-Mail: info@mcclurejohnston.com W 2/05 Website: www.mcclurejohnston.com ' RUSSEL A. RINSER, JR. DBA RUSS RINEER CONTRACTING, INC. 104 S 17TH ST , CAMP HILL, PA 17011-5531 RLW H6 867 CALL 204740 06/ 01/05 PA 1 1 ?. R 1 RGV1824PC ALCOA 18%24 RECT GABLE VENT-PS 2 2 .0 EA 38.35 EA 76.70 BBLESTONE was Y-.b: n.•wir I w•Ya, ai o..s.w®.nn ?.A?y . 11 giammig AY p¢•? •daa, W Wn mtlw. WMCeeh Yn b•tlON- •tl•d M1V •m r,+.rwp riYr,m•N.r •+rr ! 1 ! ! Y"•u"•?sa ^+•?+a•Y• 76.70 .00 00 0 - .00 81.30 f ? a., oroN ; w «. to * N Nor .&: ?, yr ??iz F, m N r. y pig r I t„f ? A gip & w I SC3 2K 0 i ? s McClure-Johnston Company 7901 ALLENTOWN BLVD INVOICE HARRISBURG PA 17112 800-228-6687 FAX 717-671-1400. ,r REMIT PAYMENT TO: P.O. BOX 200312' PITTSBURGH, PA 15251-0312 394730 E-Mail: info@mcclurejohnston.com 05/31/05 Websits: www.mcclurejohnston.com 1 RUSSBL A. RINEER, JR. DBA RUBS RINEER CONTRACTING, INC . 104 S 17TH ST , CAMP HILL,. PA 17011-5531 RLW H6 867 CALL 204259 05/ 31/ 05 PA 1 1 VJ051PC ALCOA 5/8 J-CHANNEL PEBBLE CLA 40 40 0 EA 4.16 EA 166.40 Y RT2PC ALCOA 2X3 DOWNSPOUT 101-PEBBLE 20 20 0 EA 11.80 EA 236.00 STONE CLAY PTS12NPC PRO-TECH T4 SOLID-PEBBLESTONE 16 16 0 EA 10.14 EA 162.24 CLAY PTS12VPC PRO-TECH T4 VENTED-PEBBLESTONE 5 5 0 EA 10.33 EA - 51.65 CLAY TS24PC TRIM COIL 24X50-PEBBLE CLAY 5 5 0 PL 55.88 RL 279.40 OG33APC ALCOA 5" GUTTER 33'-PEBBLESTON 5 5 0 EA 63.83 EA 319.15 E CLAY OG37APC ALCOA 5" GUTTER 37'-PEBBLESTON 3 3 0 EA 71.56 EA 214.68 E CLAY OGI6APC ALCOA 5" GUTTER 161-PEBBLESTON 2 2 0 EA 30.95 EA 6 .90 E CLAY 3 OG26PC ALCOA 5" GUTTER 261-PEBBLESTON 1 1 , 0 EA 50 29 EA 29 504 E CLAY ... . . d RTA7PC ALCOA 2X3 A ELBOW-PE13BLESTONE. 28 28 0 EA 2.80 EA 78.40 CLAY RTB7PC ALCOA 2X3 B ELBOW-PEBBLESTONE 5 5 0 EA 2.80 EA 14.00 CLAY OG155PC ALCOA 5" END CAP PEBBLESTONE(2 28 28 0 EA 2.00 EA 56.00 5L-25R/CT) OG165PC ALCOA 5" INSIDE MITER-PEBBLE C 8 8 0 EA 3.87 EA 30.96 LAY OG175PC ALCOA 5" OUTSIDE MITER-PEBBLE 8 8 0 EA 3.87 EA- 30.96 CLAY A51S1 5" ALUM SCREW-ON HIDDEN HANGER 100 100 0 EA .96 EA 96.00 ROT2X3 ALCOA 2"X3" RAVE TUBE 10 10 0 EA 1.24 EA 12.40 RTA2PC ALCOA 2X3 DOWNSPOUT CLIP-PEBBL 40 40 0 EA .47 EA 18.80 ESTONE CLAY BR1PC ALCOA POP RIVETS-PEBBLE CLAY 2 2 0- EA 3.53 EA 7.06 QUADPC OSI QUAD #301-PEBBLE CLAY(52) 2 2 0 EA 4.94 EA 9.88 N14PC 1-1/4" SS TRIM NAIL 1/4#-PEBBL 1 1 0 EA 3.15 EA 3.15 ESTONE CLAY I.IniIrWr Wr/NUb Wger• W Ybbm (Ilf IrAW W M W ? 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N 'rF'"-' I "Df . - AN ? o D rrr 3) 2 . C C11 31 <D ! .<.. m m z \ n n e n tr-,# ?: a zdocaor?oa0w aoo DDa µr arrr.krr O'wW WW NNr $ $ or 0-i crow ~ C C ? N N towm mr r Z IM xy qp M ?'M(%i ? -cn inz i € zz m i Q "s H if ? n t.. 6g ?!Y z? c c,a F 01 -xwill! ° III M .1 3 83 ? 'VP gill 0 9y?? y? ? 3 Spa J .- v 3 McClure-Johnston Company 7901 ALLENTOWN BLVD INVOICE HARRISBURG PA 17112 , 800-228-6687 FAX 717-671-1400 . n, 390426 REMIT PAYMENT TO: P.O. BOX 200312 ` PITTSBURGH, PA 15251-0312 E-Mail: info@mcclurejohnston.com 05/18/05 Website: www.mcclurejohnston.com 1 RUSSEL A. RINSER, JR. DBA RUSSEL A.RINEER,, JR. DBA RUSS RINSER CONTRACTING, INC. RUSS RINEER CONTRACTING, INC. 104 S 17TH ST -104 S 17TH ST CAMP HILL, PA 17011-5531 CAMP HILL, PA 17611-5531 RLW H6 867 CALL 199791 05/1 7/05 PA 1 1 I= N. M m TS24B TRIM COIL 24X50-MUSKET BROWN 1 1 0 RL 20.00 RL 20.00 ABOVE MAT. DAMAGED PSSIONW PRO-SELECT DS SOLID-WHITE 1 1 0 EA 9.01 EA 9.tttt1 OG26W ALCOA 5" GUTTER 261-WHITE 1 1 0 EA 50..29 EA 50:9 RTA7W ALCOA 2X3 A ELBOW-WHITE 10 10 0 EA 2.80 EA 28 00 00155W ALCOA 5" END CAP WHITE(25L-25R 10 10 0 EA 2.00 EA 20.00 /CT) A51S1 5" ALUM SCREW-ON HIDDEN HANGER 100 100 0 EA .96 EA 96.00 BR1W ALCOA POP RIVETS-WHITE 1 1 0 EA 3.54 EA 3.54 RTA2W ALCOA 2X3 DOWNSPOUT CLIP-WHITE 20 20 0 RA .55 EA 11.00 ,.ins L.io„,rr.X? r?Na a rr s• „Yrr.ll,F ti AMY ,J M?+ W d r,Y? -W a, mb. Nd OrY,w Yr rq.1 Y ^ n,s,leryr?rrrr..p.,,rrmr rw.rrur asgnrus su.,ary. 237.8 4 .00 '.00 14.27 - .0 0 252.11 O? CrON maer ffmm - Z `?{ G) m r- ?oram'??$-rxz raj -a $'no m iii E m ch D@ C C X 4- 03 U) in m fOr rr. {flit., ???i l: _ H Y r rs p 3 3!r +r+ attar{! Tii r t t Stiff, tS s iii of #5- a t; r -I rn aiy 9 El m m 1., 31 -4 Hal z n m ! 9` ?` v-i n z 6s am AMP 1 z 7 Y n L ; O ca z w , y , 1f- rr.Vr ?_ SS K r r n D ? 1yT? {[ r 1i N(r?. u n v CO") D .. tyy WIEi1 { ) O 3 O r z {]? DM D r n e g' i LA z 00 ??jcpp t A a o Yd v O S; 0-1 o-2t/y, g Cm !? a _ _ e9E zfl '' 88p ? ? ff ?o c m -4 3 3 Fl fn LO ma o $ y s , -miQ rmM M4 vcn U) D z Inz _nr a NYmrro ,1 3) p r: r m :0 o 2: X -1 U) m m _ xT t31 fi r m z m s 4 r ?I -I M ac • M r ;u & ? y3m __4 rn m k m µ -ni X 89 z N . ! r w D ?9 ? i 37 r J • V, O941 w0 z AH, JRLWI H6867 CALL AWOP6DS ALCOA VINYL OSC 101-DESERT SAN D VFT20DS VINYL FINISH TRIM-DESERT SAND GVD50DS BARKWOOD DUTCHLAP DLS-DESERT S AND ABOVE ITEM IS NON-RETURNABLE VJ051DS ALCOA 5/8 J-CHANNEL DESERT SAN D 195747 05/05/05 IPA I 1 I 1 10 10 0 EA 15 15 0 EA 20 20 0 SQ 40 40 0 EA L.. I.In119nW akr}r11 kekrp wYl pb?Y4lo nlf 11s A?.p .?Pk..W.b.?w??51b?wYY. V?.OxY Mr. y'a. .wr bo ? r rr e* w ? r..r .r. ?..r w.yw• us..'uya... 2055.30 00 123.32 15.67 EA 156.70 4.64 EA 69.60 83.13 SO 1662.60 4.16 EA 166.40 I 001 2178.621 N Qfj ?(?i7ya1 A~ ? TeLi? ? r x ?t Zi x t4? 1 y Lw xS:? r x(tfl \ a' C 1< ? ? 1 4 r ? _ a i ' i, n a 3 F ? vro?n C3 z Z ? r 8i ? 42 LA ??IQ V F.a V 4r =1 w r a pL r d ti F•9 ? s i?S r T -- O-I OrON pgspm 29 *1 ?zg Fn ° ? W ? ? , m _ .+ yM ?i yqM •??. -VJ RID ?M?.1 ? 2 m M`3 z n m m -1nZ yyc $?"? • ? f ? z _ - I ? ,'0 tltltl q VIC 3F :0 m°Dm a r m? e r. w e M vI D • ? m C) mgt is 4:0 s ? 0 i • • • a r it 9 "` 3 Own RLW H68 67 SUSQUAHANNA DELIVER 198136 05/1 2/05 PA - 1 1 5048 ATLAS R-90ARD 1/2" 4' X 8' 60 60 0 EA 11.34 EA 680.40 ? ? VF" •?YY??Y?"?iv. M!? WYYw W MM?? abYrI?YIW?isPM?NIwY?Y?rsnr?l a"w •'?•'++n 680.40 .00 .00 40.82 .00 721.22 T / 0-4 vrcm 2pD9maD9?%2 ? r.17. ?,. . m y ; m N m y 7 i o r. -i C] $2 ? S??$ • a -4 Off c ? $z ;?; ? ? M a B s F J ?' \ 3 '1. y s ? # # # OrOw P D . U) U) mm. - N.,_ IJl En H 's tf, d'P>i --iflZ z m S ? g t pQ o m ]?'` yr. } Nm aw r ?I F6ti :: t sh't'. x D n, iq ' VI k a Z H s ? 4 f rp M11 reY?tl rtll IrYr rMw 111\ Ir Amy 4 Yvr M6r riW. rdarr.v.µr? 58.8DI .001 .001 3.531 .00 62.331 ZyyyyOrS??>9yxz =94m=$Dp ?p 111 N ? T ?? a : n m o $a a 0 A • 3 r t(? 6E '1. t ?? j :,.,. 71 ' 11? ,t 0-4 CrOcn l7-:nm n S CC ' :1 4-1 (n N r rJZ b in r-1m, na mm It ttj mm -iclz 1.e D - v z m nti [JI ty . W G7 0 ? g ~ 3) z ? a Q(V O? V-SNa?6a ? 1 ,?po? ? McClure-Johnston Company 7901 ALLENTOWN BLVD INVOICE HARRISBURG PA 17112 800-228-6687 FAX 717-671-1400 REMIT PAYMENT TO: P.O. BOX 200312 • PITTSBURGH, PA 15251-0312 386596 E-Mail: info@mcclurejohnston.com 0 05/09/05 Website: www.mcclurejohnston.com 1 RUSSEL A. RINSER, JR. DBA RUSSEL A. RINSER, JR. DBA RUSS-RINSER CONTRACTING, INC. RUSS RINSER CONTRACTING, INC. 104 S 17TH ST 104 3 17TH ST CAMP HILL, PA 17011-5531 CAMP HILL, PA 17011-5531 RLW H6 867 CALL 196552 05/ 09/05 PA 1 TS24BM - TRIM COIL 24X50-BIRCH/MAPLE 1 0 0 RL 58.61 RL .00 PTS12NW PRO-TECH T4 SOLID-WHITE 2 2 0 CT 143.65 CT 287. 30 NIA 1-1/2" SMOOTH ALUM SIDING NAIL 10 10 0 EA 5.48 EA LLLL 5 0 1# TS24PC TRIM COIL 24X50-PEBBLE CLAY 1 1 0 RL 58.61 RL 5 61 VJW ••ALCOA 5/8 J-CHANNEL WHITE 1 1 0 CT 139.32 CT 139.32 PSS1oNW PRO-SELECT D5 SOLID-WHITE 2 2 0 CT 8.44 EA 337.60 TS24A TRIM COIL 24X50-ALMORD 1 1 0 RL 58.61 RL 58.61 ABOVE ITEM IS NON-RETURNABLE TS24DS TRIM COIL 24X50-DESERT SAND 1 1 0 RL - 58.61 RL 58.61 QUADA OSI QUAD #429-ALMOND(53) 2 2 0 EA 4.94 EA 9.88 ,.Nf Y,?•rlu?.lu k OUp ail prY YYm (IM N.wp MI P?•.1,•esY4 ?YYa W. MhsOaW Y• 4tli?• aG•tl ?pda Y,r?I,wytMM1?av ?IM•?,er - "••??*•?+ 1004.73 .00 .00 60-.2 8 - 00 1065.01 m § g ? s P t i i v. NZ N D S ..3 ?. n) 1tR r 3 T` O Q ice" O-I P3 [A 4 Lq ca 0 6 3).P Ox I r- rvcdm .. MX w °. m(nERO m ty r wEd 4 n.zm M P,G) a j 3) m<zz m r o-i Oran M;D r N 3 N v wm Er) x Mr H 1+ H ? r.Iz3 r-4m x m g ) g ny 9.? gad MM i Y D -QZ zz m F s D ED D pa 3?? ? 0 4 i (q M W G7 G 3 ) ? Z M 0 O-f T-=III x 1D,8 ;C0 -C?O V U) (n pill Mr 2 fj) m x L r- -4 Z D m m C3 ? . ? U) ° D- i0 m _ D gyp ? n ?r SZ - y ? , ? Y ? 1 :JI H A Z D vy ? y° z $$ ? • 388133 ?6 ? ?S WIN ONfUbs 06+1} , 4Z 33 lOfS 81 388930 OGIL 2 LL3itp3, 388937 uz 721.22 79.33 ? 588938 f(611w f117 721.22 ? 5901/26 dJ17/05 ZI?8 i2 . 0,13: X211 2171.02 .39V7' O?IlOt2MS 20YS 28 252.11 395772 0 30 1 21813.28 {x781888; YQ614} 07 838 f9 81.38 M72 1838 69' ' #rQ 43 JF1 Om oauo6 >mm STI9 w 881 K - 72L72 5 .19 ?' , 4llpBj; ISgAtIdtlS 49i121ps ' 7.0 k 83113 011106 GB/10>Qi 47; 90 17.Sx ' 412579, 2579, 08/t7?@S 107:11 18.11 ?' 84`?Of8 0/131/03 Ut a =107.14 4%3! 26L6.3 6#.39-_ •r ; e t i 9 ? I ? t "," T:.20yy,yr,+.?51!H14fA-??7-0IRTB ?'»fi?70J # McClure-Johnston Company STATEMENT P.O. Box 200312 Pittsburgh, PA 15251-0312 . Phone: 412-351-4300 Fax: 412-351-1480 E-Mail: info@mcclurejohnston.com 09/30/05 Website: www.m6clurejohnston.com BRIM RUSSEL A. RRgEER, JR. D BA RUSS RINE ER CONTRAC TING, INC. YOUR ACCOUNT IS ON HOLD. 104 S 37171EI ST PLEASE BRI NG YOUR CAMP HIL L, PA 17011-553 1 av L d s s F '. P a ... 3 c N R R" a+ a tY cs Y y¢ ???i 3 ca o r FXiRI't?A14EV/MY }- iR !% x •s..;$ .n.o , = o 05109105 386596 06/08/05 1065.01 1065.01 05/12105 388133 06111105 62.33 62.33 05/12/05 388134 06111105 79.55 79.55 05/16/05 388930 06115105 721.22 721.22 05/16105 388937 06/15/05 62.13 62.13 05116105 388938 06/15/05 2178.62 2178.62 05/18105 390426 06/17/05 252.11 252.11 05/31105 -394730 06/30/05 2013.28 2013.28 06/02/05 395771 07/02105 81.30 81.30 06/02/05 395772 07/02/05 1838.69 1838.69 06/30105 406144 07/30/05 722.72 722.72 07/06/05 408207 08105105 57.19 57.19 07/12105 410443 08110105 -20.51 -20.51 07/12/05 410553 08111105 17.52 17.52 07/13/05 411061 08/12105 40.94 40.94 07113/05 411100 08110105 .107.14 -107.14 07/18/05 412573 08/17/05 261.63 261.63 08/19105 425508 09110105 .63.43 .63.43 06/30/05 RC1164 09/09/05 118.49 08/30/05 93.49 PY 25.00 07/31/05 SC3018 07/31/05 64.39 64.39 08/31/05 SC3109 00/31/05 133.28 133.28 09/30/05 SC3193 09/30/05 138.93 138.93 YOUR ACCO UNT IS SERIO USLY PAST DUE ! IF THERE IS A PRO BLEM OR IF PA YMENT ARRANGEME NTS ARE NEEDED PLEASE CAL L DAVE MINKIC KS AT 1.800-3906976 0 OTHERWISE A PAFfWNT TO BRIN G YOUR ACCO UNT CURREN T WOULD BE AP PRECIATED. YOUR ACCOUNT IS O N CREDIT HOLD AN D A PAYMENT M UST BE RECEI VED BY 10/10/0 5 TO PREVENrFURT HER COLLECTI ON ACTIONS. 138.93 94.85 749.63 9141. - 351 1 9624.76 McClure-Johnston.Company STATEMENT P.O. Box 200312 Pittsburgh, PA 15251-0312 - Phone: 412-351-4300 Fax: 412-351-.1480. TM E-Mail: info@mcclurejohnston.com 09/31105 Website: www.mcclurejohnston.com 1 RUSSEL A. RINGER, 3R. DBA YOUR ACCOUNT IS ON HOLD. BUSS>IUNRERCONTRACTING,INC. PLEASE BRING YOUR 104 10 s 17TH ST ACCOUNT TO A CURRENT STATUS CA CAMP ?,L, PA 17011-5531 a If,4i'€e INlrOlC?' `DUE1?Af£ AM131/I{T, PKM'asid7E ,'-.PYM7?iIktbUlv7". ` `7H, 9AI.4/VEF Mirk; '" 05109(05 386596 06108105 1065.01 1065.01 05/12!05 388133 06111105 62.33 62.33 05/12165 386134 06111/05 79.55 79.55 05/16105 388930 06/15/05 721.22 721.22 05116105 388937 06115105 62.13 62.13 05116/05 388938 06115105 2178.62 2178.62 o5/1M0S 390426 06117/05 252.11 252.11 05/31/05 394730 000105 2013.28 2013.28 06/02/05 395771 0702/05 81.30 81.30 06102/05 395772 07/0'2105 1838.69 1838.69 06/30/05 406144 07130105 722.72 - 722.72 07AWOS 408207 09105105 57.19 57.19 07/12/05 410443 08110105 .20.51 -20.51 07/12/05 410553 08111/05 17.52 17.52 67113/05 411061 08/12/05 40.94 40.94 07/13/05 411100 08/10/05 .107.14 -107.14 07118/05 412573 08/17/05 261.63 261.63 08/19/05 425508 09110105 63.43 43.43 06/30/05 RC1164 09109105 118.49 08130/05 93.49 PY 25.00 07/31/05 SC3018 07131105 64.39 64.39 89/31105 SC3109 001/05 133.28 133.28 YOUR ACCO UNT IS SERIO USLY PASTDUE I IF THERE IS A PRO BLEM PLEASE CALL DAVE MiNMC KS A I-SW232-001 9 M. 246. W E HAVE PREVIO USLY REMQiDED Y OU OF YOUR AC COUNT CONDITION AND A PAYMENT MUST BE REC EIVED RAMED LKIELY TO PREVENT FURTHER COL LECTION ACTIONS. 94.85 249.63 2707.10 6434 .7.5 9485.83 VERIFICATION The undersigned does hereby verify under penalty of perjury, that he is Credit Manager of McClure-Johnston Company, Plaintiff herein, that he is duly authorized to make this Verification and that the facts set forth in the foregoing COMPLAINT IN CONFESSION OF JUDGMENT are true and correct to the best of his knowledge, information and belief. David P. Mi cks, Sr. ? ? ?,. ?'t -, a l s?. ? ? ?- ? .? `'`' ?' ? ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., No. 05-6336 Plaintiff, VS. PRAECIPE FOR WRIT OF EXECUTION ON A COMPLAINT IN CONFESSION OF JUDGMENT RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants, FILED ON BEHALF OF: Plaintiff COMMERCE BANK, Garnishee. COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 DEBORAH R. ERBSTEIN, ESQUIRE PA ID #86470 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN FILE NO. C0061185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JO14NSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, No. 05-6336 vs. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. PRAECIPE FOR WRIT OF EXECUTION ON A COMPLAINT IN CONFESSION OF JUDGMENT To the Prothonotary: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against Defendant: Russ Rineer Contracting, Inc. f/d/b/a Russel A. Rineer 104 S. 17th Street Camp Hill, PA 17011 3. against Garnishee: 4. JUDGMENT Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 Interest from 11/26/05 to 3/14/06 Poundage SUBTOTAL: Costs (to be added by Prothonotary): TOTAL Date: o Russel A. Rineer, Jr. 104 S. 17th Street Camp Hill, PA 17011 $12,355.79 $ 219.32 $ 251.50 $12,826.61 BERNSTEIN LAW FIRRMj, P.C. By' - Christopher M. Boback, Esquire Attorney for Plaintiff f c ' 0 c 0 a C C ? ? F YI ' r. .S T March 17, 2006 Page 2 Certification I certify that (a) This praecipe is based upon a judgment entered by confession, and (b) Notice has been served pursuant to Rule 2958.1 at least thirty days prior to the filing of this praecipe as evidenced by a return of service filed of record. Christopher M. Boback, Esquire Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 Etc. IN THE COURT OF COMMON PLEAS OF McCLURE-JOHNS ------ MPApIY_______ CUMBERLAND COUNTY, PENNSYLVANIA successor in merger with JACK BROWN WHOLESALE SUPPLY INC. Writ No. _________ 05-6..33_(_______ Term, 19______ ------------------------------------------- No._______________...._______________ Term, 19______ vs. 1-2-,-355-.-79 Amount due ---- ___§ ---- _ _ ____ RUSS_RIXFER_CONTRACTING_INP-._ Interest from --- 11726 - 3-14-06__ -- -------- formerly doing business as RU SEL A. RINEER a sole proprietorship `ind Att'y'sCom.______--------------- _____________ ------------------------------------ RUSSEL A.. RINEER, SR. as Costs----------- ---- 3-_----_---------------- personal guarantor To the Prothonotaryof said Court: ISSUE WRITOF EXECUTION IN THE AIl0VF. %fA,ITER, (1) Directed to the Sheriff of - __ C04MLANIl_____ County, Penna.; (2)against KUSS RINEER_ CONTRACT ING_INC._formerly__doing.bu_s_iness-a_s_____-__ RUSSEL A. RINEER a sole proprietorship and RUSSEL A. RINEER, JR. as persona-1--guarnat-ar ----------------------------------------- -__----___. D renriant (3) and against COMM RCE_BA1uK_ _________________-.______________------ (4) nishee 's' and index this RUSS RINEER CONTRACTIN writ (a) against rt_____..________G, INC,__f_ormerly_doingbusn_e_s_s__as RUSSEL A. RINEER a sole proprietorship and RUSSEL A. RINEER, JR. as personal guarantor-r _ __. -- -- Defendant j,) and (b) against ___ COMMERCE _____________ BANK _____.__________ _.. ___________..__ ___ - - _------- ___-______.____ G.tmahce (s), as a Es pendens against the real property of the defendant s) in the name of the Ga; nidnr a? follutc, _ (SpetiG eallc describe Property) (5) Exemption has (not) been waived. Dated ________________________ Artom ep fur llrin tiff f, I- -- - -- NOTE Under paragraph (I) when the writ is directed to the sheriff of another county the county should be indicated as au thonnN b?' R111, 3103(b- . Under Rule 3303(e) a writ issued on a transferred ju dgement may be directed only to the =her if of the county In which issued. Paragraph (3) above should be completed only if a named garnishee Is to be in,ludud in the writ Paragraph (4) (a) should be completed only if index ing of the execution in the tour y of ; a is Feared as authorized by Rule 3104(a). When the writ isucs to another county Ind xing is rcq urcd .?? ,f <;;. .. in that pounty by the prothonotary. See Rule 3104(b)- _ Paragraph (4) (b) should be completed only if real property in the name of a garnishee is attached and index- ing as a his penderns is dewed. See Rule 3104(c). 2 a' y i CL ' , ism rt row {o Fl- C , v rt N• ? ? rt m m m ? n i ul b C O , N i O In O .Or 1 Cif ? m ro+a io H ; C *C ro ?J ro? w c-. < o? H r O n O w ? M n ? r H 'r• PI m P. 7t m O 0 C r?r• cn ? m ? C m i i 0 ola Z O b i m hi m n , r• ?i m,m ryp ti'mm 0 ° w ?z N 7?m p r•? ?rro,xc? O 'C H` i tl; n Cl 1 7a M a? ra o z m. n 11? n oo? r mi C , c~ti O ?z aH n°z n a G m m 0 -4 z I r /, 1 ? Cx l.J r•. r^ T C+% r 11 .?. ;> v -? A I 0 O i ? W , W n' 7 i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 05-6336 Civil COUNTY OF CUMBERLAND) CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MCCLURE-JOHNSTON COMPANY, SUCCESOR-IN MERGER WITH JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff (s) From RUSS RINEER CONTRACTING, INC. FORMERLY DOING BUSINESS AS RUSSEL A. RINEER, A SOLE PROPRIETORSHIP, AND RUSSELL A. RINEER, JR. AS PERSONAL GUARANTOR, 104 S. 17'u STREET, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY AGAINST PROPERTY AT 104 S.17'" STREET, CAMP HILL, PA 17011. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 1130 CARLISLE ROAD, CAMP HILL, PA 17011 -SERVE INTERROGATORIES GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $12,355.79 L.L. $.50 Interest FROM 11/26/05 TO 3/14/06 - $219.32 Arty'sComm % Due Prothy $1.00 Any Paid $37.50 Other Costs POUNDAGE - $251.50 Plaintiff Paid Date: APRIL 4, 2006 CURTIS R. LONG Prothonota (Seal) Bv: L- Deputy REQUESTING PARTY: Name CHRISTOPHER M. BOBACK, ESQUI RE Address: BERNSTEIN LAW FIRM, P.C. SUITE 2200 GULF TOWER PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-456-8114 Supreme Court ID No. 91730 March.] 7, 2006 Page 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, vs. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, 104S.17 1h Street Camp Hill, PA 17011 Defendants, COMMERCE BANK, Civil Action No. 05-6336 Garnishee. Suggested Reference No. TO: Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 46 caer-s IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the Writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. March 17, 2006 Page 3 D. If any Defendant above named is an individual, and if Social Security funds are directly deposited into an account of the Defendant, the levy and attachment shall not include any funds that may be traced to Social Security direct deposits. E. In your answers to these Interrogatories in Attachment, please state whether the account includes Social Security direct deposits or that you have identified the funds in the account as being from sources other than Social Security direct deposits. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Q4 rf ? OR rJ-r k/-Y1-c? (a-?? n?-r S31e o o aaB o w ?Yw r? (3 a ??.uc q n F Elmo s4 Ar [ a.? SSrLJLO. 2. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. S i s- i o Q?f r o.?l 4- 3. 3. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. SLR I? N5v?4 R '?-d C?LJ4S6-ivN L. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. March 17, 2006 Page 4 5. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? sq- 1?n?s??2tzTo QU?STI0"j 6. If the answer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? I) b 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 9. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? Q4?4NO Vt Tbl PdJ2 ?4QJS TS ItilTO "riot- A-606,% (L ?( ?Rfn1C?D }1-CCAC?NT ?Iv T4}? ©R-y?tNP`SZ? ?jJQS? V?FL.io(Z ?C? SE?JiC? ??-V? t7r l.v H-i CNt '1.t?`c..2`? p,..r ?t}g, Qc ?`cCSI c)? d F Crm w?4/Zc C qq (T?rHI)U.. 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. March 17, 2006 Page 5 11. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? N0 12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. BERNSTEIN LAW FIRM, P.C. Y: vv ,I I Christopher M. Boback, Esquire Attorney for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO. C0061185 March. 17, 2006 Page 6 VERIFICATION The undersigned does hereby verify under penalty of perjury, that he/she is the legal representative of ( n-kl r 4 n (i dZ,&,,,, C , Garnishee herein, that he/she is duly authorized to make this Verification and that the facts set forth in the foregoing INTERROGATORIES are true and correct to the best of his/her knowledge, information and belief qI, --//0to rn.No, tvu,3 spaa,n- r' i"> T r.- Illy -?fT -ri ii (V ) i N -.C U OZ .£ d I I ddtl 9U01 u'd'J.li=lt?'1 flft'3` ?336d(iJ JJ183HS Pi A 331330 IN THE COURT OF COMMON PLEAS OF CUMBERLAND MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, vs. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. CIVIL No. 05-6336 fn /`this U3 e/ INTERROGAT( FILED ON BE] Plaintiff COUNSEL OF THIS PARTY: NICHOLAS D. PA ID #38527 DEBORAH R. PAID #86470 CHRISTOPHE] PA ID #91730 Bernstein Law F Firm #718 Suite 2200 Gulf Pittsburgh, PA 1 412-456-8114 BERNSTEINF , PENNSYLVANIA fO )RIES IN ATTACHMENT OF: OF :RAWEC, ESQUIRE RBSTEIN, ESQUIRE M. BOBACK, ESQUIRE P.C. 9 NO. 00061185 March' 17, 2006 Page 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, VS. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, 104 S. 17`h Street Camp Hill, PA 17011 Defendants, COMMERCE BANK, Garnishee. TO: Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 Civil Suggested Reference A. You are required to file answers to the following interrc days after service upon you. Failure to do so may result in Judgment B. Herein, the word "defendant" means any one or more the Writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all subject to attachment which is then in the hands of the garnishee, it the defendant which comes into the Garnishee's possession thereafte against the Garnishee. For example, the resultant liability of a Ga measured by the balance in the debtor's account, either at the time of time of Judgment against the Garnishee, but rather by the amount during the intervening period. , PENNSYLVANIA No. 05-6336 within twenty (20) you. defendants against whom property of the Defendant Jso attaches all property of until Judgment is entered nishee-Bank would not be >ervice of the Writ or at the deposited and withdrawn MarcYi7, 2006 Page 3 D. If any Defendant above named is an individual, and directly deposited into an account of the Defendant, the levy and any funds that may be traced to Social Security direct deposits. Social Security funds are achment shall not include E. In your answers to these Interrogatories in Attachme t, please state whether the account includes Social Security direct deposits or that you have identified the funds in the account as being from sources other than Social Security direct depo its. 1. At the time you were served or at any subsequent time di money or were you liable to him on any negotiable or other writte that you owed him any money or were liable to him for any reason? DVF-f-,UoftfL'rF "O ACL_OOC"T- 53tpooaago -IDtD•3q p-, z- Sf2u?0. P? C>1;:' (V\kq I , as 96-SIo 00 W RS M rsOY I k)70 pC_( 00Ur S3LPOOda%O (y OF 40g, ,L/q. i. l6,1 If the answer to Interrogatory 1 is in the affirmative, state' money you owe or owed to defendant, and, if such money is in the location thereof; the terms, face amount and amount you owe or oN such negotiable or other written instruments and the present location the amount or amounts that defendant claims or claimed that you o nature and amount of each of such liabilities. 5 I- Pkfj5")-' Z 'To a,3 L5-Tr00_,1_. 3. At the time you were served or at any subsequent time custody or control of yourself and one or more other persons any solely or in part by the defendant. 54? Ass e_ ,a 0..ccs?o?'? . 4. If the answer to Interrogatory 3 is in the affirmative, value, and present location of each of such properties. you owe the defendant any instrument, or did he claim ff A [3w't-P,ucz o(:-- ®te PsOf-Vo6,T OP J n)(o TF f t?-00k A ,QsuMLXf he following: the amount of form of a fund, the present td to defendant on each of )f each of such instruments; ve or owed to him; and the there in your possession, -.rty of any nature owned the nature, fair market Mard l7, 2006 Page 4 5. At the time you were served or at any subsequent time d property of any nature owned solely or part by the defendant or claimed any interest? NS??2'D QJ£.STc)U,1- 6. If the answer to Interrogatory 5 is in the affirmative, value, and present location of each of said properties. 7. At the time you were served or at any subsequent time property in which the defendant had an interest? k) D 8. If the answer to Interrogatory 7 is in the affirmative, value, and present location of each of such properties. 9. At any time before or after you were served, did the defc property to you or to any person or place pursuant to your directio was the consideration thereof? p?F?N?C#AY M Rot_ DzPoS,TS A CCO.Df')T 1 N '?1??, D 20 rJ d?tL.? (?l?J ?S `C P21b2 pF W,.A.Cµ w?2`? tic THE 17 2??re+J CAF 10. If the answer to Interrogatory 9 is in the affirmative, value, and present location of each of such properties. you hold legal title to any which defendant held or the nature, fair market you hold as fiduciary any the nature, fair market ant transfer or deliver any or consent and if so what ?. a-?F?ctiN?fp o ?L/L.J ,CCc fnn?trf.12 cT.?.w?.t2e£ \?vReJil?. the nature, fair market March`17, 1006 Page 5 11. At any time after you were served did you pay, tra property to the defendant or to any person or place pursuant discharge any claim of the defendant against you? Q17 12. If the answer to Interrogatory 11 is in the affirmative, de fair market value and present location of each of such payments and BERNSTEIN LAW ;r, or deliver any money or his direction or otherwise the amount or nature, P.C. By, v v • • I I Christopher M. Boback, Attorney for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE N( Esquire C0061185 MavcA 17, 1006 Page 6 VERIFICATION The undersigned does hereby verify under penalty of pet representative of rom ME KLs ('j, az M(4 , that he/she is the legal herein, that he/she is duly authorized to make this Verification and that the facts Iset forth in the foregoing INTERROGATORIES are true and correct to the best of his/her belief. M•ob? information and j/3r, a r C? o T P \ ?4 Y CO £ d ? ? aatl gooti OZ ' ?-?a?atr? ??f3 ??? X30 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., No. 05-6336 Plaintiff, Vs. PRAECIPE FOR JUDGMENT AS TO GARNISHEE COMMERCE BANK RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants, FILED ON BEHALF OF: Plaintiff COMMERCE BANK, Garnishee. COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 DEBORAH R. ERBSTEIN, ESQUIRE PA ID #86470 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN FILE NO. 00061185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, CIVIL DIVISION VS. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. Civil Action No. 05-6336 PRAECIPE FOR JUDGMENT AGAINST GARNISHEE COMMERCE BANK TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, Commerce Bank, in the amount of $2,449.66, which is less than the amount Defendants owe to Plaintiff and which amount Garnishee has admitted owing to the Defendants, in answers to Interrogatories. Defendant is not a natural person and may not claim the $300.00 statutory exemption. Defendant is a natural person and has has not previously claimed the $300.00 statutory exemption. BERNSTEIN LAW FIRM, P.C. By: &Omee Christopher M. Boback, Esquire Attorney for Plaintiff I hereby certify that the address of the Plaintiff is: c/o Bernstein Law Firm, P.C., Suite 2200 Gulf Tower, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 1130 Carlisle Road, Camp Hill, PA 17011 cjh003139VO01 MAY-31-2096 0158 COMMERCE WIRE-ACH 7177956128 P.02 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION sueoesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., No. 05-6336 Plaintiff, VS. INTERROGATORIES IN ATTACHMENT RUSS RINSER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: PA ID #91730 NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 DEBORAH R. ERBSTEIN, ESQUIRE PA 11) #86470 CHRISTOPHER M. BOBACK, ESQUIRE Bemstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN t77 \ MY-M-2006 0158 COMMERCE WIRE-ACH 7177956128 P.03 March' 17, 2006 Page 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, sucemr-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, VS. RUSS RiNEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor 104 S. 17'i' Street Camp Hill, PA 17011 Defendants, COMMERCE BANK, Garnishee. TO: Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 Civil Action No. 05-6336 Suggested Reference No. IMPORTANT NOTICES TO OaRtvr HEE! A. You are required to file answers to the following interrogatories within twenty (20) days atter service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the Writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant sttbjeet to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession Shy, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. MRY-31-2006 01:58 tDMhERCE WIRE-HCH 7177956128 P.04 March' 17, 2006 Page 3 D. If any Defendant above named is an individual, and if Social Security funds are directly deposited into an account of the Defendant, the levy and attachment shall not include any funds that may be traced to Social Security direct deposits. E. In your answers to these Interrogatories in Attachment, please state whether the account includes Social Security direct deposits or that you have identified the funds in the account as being from sources other than Social Security direct deposits. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? ()£ F¢AI0AM•Yr Awzl ALt.?d 53(0002'no w+ rsH A Qr9t NCB 4 - IOLo•94 Per `l m r, Sta.UtD. Nb eA M Oki I , 6)0MU A 0VP6S,T oK ?9656-ov t,,WAr.i mmOt oKno Att.wor 53C,008840 (oIu'N(o T*F- PALOWr AJBAu1 pF 01, 449 • tole •2. If the answer to interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the atnow or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. ,5eg• P*j,5ws%. "fo doLsmot-)J- 3. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. e- _')4,j PsNS..?QL IIJ 0,0 G3c[a? ?• 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. MAY-31-2006 0159 COMMERCE WIRE-ACH 7177956128 P.05 March 17, 2006 Page 4 5. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? SSA ?NScJL(? ?? ?LSt?pN 6. Jf the answer to Interrogatory 5• is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? K) fl 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 9. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? DeFu1 WO M?7. ?Pos?rs IX)TO TNC Ac3ovQ, tLpFEL4.PCCp Ac.coocar iN TH"L Oap Naa.? cooic'Sf PrLLbX i'o yu.aq ?. N?? OF VaMM?N w4.Rt (" THt 0,24 t- 'r'" OP ?4M«LllK {J A1J1? 10. If the answer to interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. MAY-31-2006 01059 COMMERCE WIRE-PCH 7177956128 P.06 March 17, 2006 Page 5 11. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any parson or place pursuant to his direction or otherwise discharge any claim of the defendant against you? Q d 12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. BERNSTEIN LAW FIRM, P.C. By: vr- • .,r - ---% Christopher M. Boback, Esquire Attorncy for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15214 (412) 456-8100 BERNSTEIN FILE No. C0061185 MAY-31-2805 0159 COMMERCE WIRE-ACH 7177956128 P.07 March 1l 2006 Page 6 YMFIC_,ATI N The undersigned does hereby verify under penalty of perjury, that he/she is the legal representative ofri5m ML f U- w 114AfA i f. 10(} , Garnishee herein, that he/she is duty authorized to make this Verification and that the facts set forth in the foregoing IN1MOGATORIES are true and correct to the best of his/her knowledge, information and belief. rjT__ C rr-? h 1 ? rO G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, CIVIL DIVISION No. 05-6336 Vs. RUSS RINEER CONTRACTING, INC formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO GARNISHEE COMMERCE BANK ONLY Garnishee. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 DEBORAH R. ERBSTEIN, ESQUIRE PA ID #86470 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN FILE NO. C0061185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Civil Action No. 05-6336 Plaintiff, VS. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO GARNISHEE COMMERCE BANK ONLY TO THE PROTHONOTARY: At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment as to Garnishee Commerce Bank only. BERNSTEIN LAW FIRM, P.C. Christopher M. Boback, Esquire Attorney for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO: 00061185 Sworn to and subscribed before me this Ala 0 day o 2 NotlWy Public Notary Seal Linda Boyle, Notary Public ?'ii? 6,RjWurgh, Allegheny County My mm ssion Expires October 28, 2007 Member. Pennsylvania Association of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Civil Action No. OS-6336 Plaintiff, Vs. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. CERTIFICATE OF SERVICE I, Christopher M. Boback, Esquire, hereby certify that a true and correct copy of the foregoing Praecipe for Satisfaction of Judgment as to Garnishee Commerce MBank Only was served on the following parties by regular U. S. Mail, postage prepaid, this ?rday o, 2006, addressed as follows: Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 Russ Rineer Contracting, Inc. f/d/b/a Russel A. Rineer 104 S. 17`h Street Camp Hill, PA 17011 Russel A. Rineer, Jr. 104 S. 17`h Street Camp Hill, PA 17011 60/w- cjh0032GOV001 O O' r-_ „? ? O t T? to ? ? ;- ? ? , ?. ?. b? ? ?? .-C - _, _. 7 tJ ll d... .. SHERIFF'S RETURN - GARNISHEE -CASE NO: 2005-06336 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MCCLURE-JOHNSTON COMPANY ET AL VS RINEER RUSS CONTRACTING INC And now JESSICA HERMANSEN Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:25 Hours, on the 13th day of April , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT RINEER RUSS CONTRACTING INC F/D/B/A RUSSELL A RINEER hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to AMY THOMAS (CSR personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 nn true and made So answers: R. Thomas K11 , Sheriff of Cumberland County uu jy A? J. ,4'14 05/19/2006 By V -- D uty Sheriff SHERIFF'S RETURN - GARNISHEE -f-'ASE NO: 2005-06336 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MCCLURE-JOHNSTON COMPANY ET AL VS RINEER RUSS CONTRACTING INC And now JESSICA HERMANSEN ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:25 Hours, on the 13th day of April , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT RINEER RUSSEL A JR hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to AMY THOMAS (CSR) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 in the true and made So answers: ?!!!!Ihhomas Kli.n. Sheriff of Cumberland County uu L?y,, Sl?yloi, 05/19/2006 By De ty Sheriff e ?v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., No. 05-6336 Plaintiff, VS. PRAECIPE TO REISSUE WRIT OF EXECUTION ON A COMPLAINT IN CONFESSION OF JUDGMENT RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, FILED ON BEHALF OF: Plaintiff COMMERCE BANK, Garnishee. COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 DEBORAH R. ERBSTEIN, ESQUIRE PA ID #86470 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN FILE NO. 00061185 r -% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, No. 05-6336 VS. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. PRAECIPE TO REISSUE WRIT OF EXECUTION ON A COMPLAINT IN CONFESSION OF JUDGMENT To the Prothonotary: Kindly reissue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County for a garnishment only 2. against Defendant: Russ Rineer Contracting, Inc. f/d/b/a Russel A. Rineer 104 S. 17th Street Camp Hill, PA 17011 3. against Garnishee: 4. JUDGMENT Minus Payments Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 Interest from 11/26/05 to 10/17/06 on $4,906.13 Poundage SUBTOTAL: Costs (to be added by Prothonotary): TOTAL Date: 0ci?kGr (-7/ )RQ6 Russel A. Rineer, Jr. 104 S. 17th Street Camp Hill, PA 17011 $12,355.79 - 1/900,.13 $ 7,449.66 $ 262.48 $ 103.37 $ 5,271.98 BERNST LAW FIRM, P C. By: Christopher M. Boback, Esquire Attorney for Plaintiff Jctober-17, 2006 Page 2 Certification I certify that (a) This praecipe is based upon a judgment entered by confession, and (b) Notice has been served pursuant to Rule 2958.1 at least thirty days prior to the filing of this praecipe as evidenced by a return of service filed of record. 4 11;11 M?4e Christopher M. Boback, Esquire Attorney for Plaintiff n `a ? ?' ?? ? ? `? ? -rz p ... _ s .?????; ? ? = i _ .? F ?.,; _, , ? ? ?ry. WRIT OF EXECUTION and/or ATTACHMENT REISSUED COMMONWEALTH OF PENNSYLVANIA) NO 05-6336 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MCCLURE-JOHNSTON COMPANY, SUCCESOR-IN MERGER WITH JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff (s) From RUSS RINEER CONTRACTING, INC. FORMERLY DOING BUSINESS AS RUSSEL A. RINEER, A SOLE PROPRIETORSHIP, AND RUSSELL A. RINEER, JR. AS PERSONAL GUARANTOR, 104 S. 17TH STREET, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY AGAINST PROPERTY AT 104 S. 17TH STREET, CAMP HILL, PA 17011. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 1130 CARLISLE ROAD, CAMP HILL, PA 17011 - SERVE INTERROGATORIES GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4355:49 $4,906.13 L.L. $.50 Interest FROM 11/26/05TO-144M6 $219.32 10/17/06 on $4,906.13 -- $262.48 Atty's Comm % Due Prothy $1.00 Atty Paid $37.50 Other Costs 410UNDAGE 925t-50-- $103.37 Plaintiff Paid Date: APRIL 4, 2006 CURTIS R. LONG Prothonotar (Seal) B Deputy REQUESTING PARTY: Name CHRISTOPHER M. BOBACK, ESQUIRE Address: BERNSTEIN LAW FIRM, P.C. SUITE 2200 GULF TOWER PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-456-8114 Supreme Court ID No. 91730 f`J ? c a -tp C Y?? w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., No. 05-6336 Plaintiff, vs. AtiswerS Y?G INTERROGATORIES IN ATTACHMENT RUSS RINSER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 DEBORAH R. ERBSTEIN, ESQUIRE PA ID #86470 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN FILE NO. 00061185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, Vs. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, 104 S. 17th Street Camp Hill, PA 17011 Civil Action No. 05-6336 Defendants, COMMERCE BANK, Garnishee. Suggested Reference No. TO: Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the Writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. cjh003594V001 je D. If any Defendant above named is an individual, and if Social Security funds are directly deposited into an account of the Defendant, the levy and attachment shall not include any funds that may be traced to Social Security direct deposits. E. In your answers to these Interrogatories in Attachment, please state whether the account includes Social Security direct deposits or that you have identified the funds in the account as being from sources other than Social Security direct deposits. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Defendant had account 536002280 with a balance of $-42.00 at time served. 2. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. 3. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. See answer to question 1. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. cjh003594VO01 5. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? See answer to question 1. 6. If the answer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 9. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? Defendant made deposits into the above referenced account in the ordinary course prior to service, none of which were at the direction of Cam}erce Bank. 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. cjh003594VO01 11. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? No 12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. BERNSTEIN LAW FIRM, P.C. By: d?" - Christopher M. Boback, Esquire Attorney for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO. C0061185 cjh003594V001 r+ VERIFICATION The undersigned does hereby verify under penalty of perjury, that he/she is the legal representative of Ct?MMCLQG`z (5Bjib, k' (k , Garnishee herein, that he/she is duly authorized to make this Verification and that the facts set forth in the foregoing INTERROGATORIES are true and correct to the best of his/her knowledge, information and belief. + 71C(9 cjh003594V001 } *.ya .11 f A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MCCLURE-JOHNSTON COMPANY, CIVIL DIVISION succesor-in merger with JACK BROWN WHOLESALE',iUPPLY, INC., Plaintiff, No. 05-6336 Vs. PRAECIPE TO SETTLE, DISCONTINUE AND END AS TO GARNISHEE COMMERCE BANK ONLY RUSS RINSER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 DEBORAH R. ERBSTEIN, ESQUIRE - PA ID #86470 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8114 BERNSTEIN FILE NO. C0061185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE ,SUPPLY, INC., Plaintiff, vs. Civil Action No. 05-6336 RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. PRAECIPE TO SETTLE, DISCONTINUE AND END AS TO COMMERCE BANK ONLY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly settle, discontinue and end the above-captioned matter upon the records of the Court and mark the costs paid as to Garnishee Commerce Bank only. Sworn to and subscribed before me this a-- W day of 2006 Notary Seal Linda Boyle, Notary Public City of Pittsburgh, Allegheny County Myjg=?ion Expires October 29, 2007 Member. Pennsylvania Association of Notaries BERNSTEIN LAW FIRM, P.C. By: a**K Christopher M. Boback, Esquire Attorney for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO: 00061185 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, VS. RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants, COMMERCE BANK, Garnishee. Civil Action No. 05-6336 CERTIFICATE OF SERVICE I, Christopher M. Boback, Esquire, hereby certify that a true and correct copy of the foregoing Praecipe to Se':tle, Discontinue and End as to Garnishee Commerce Bank Only was served on the following parties by regular U. S. Mail, postage prepaid, this cP "day of/?O,141 64- 2006, addressed as follows: Commerce Bank 1130 Carlisle Road Camp Hill, PA 17011 Russ Rineer Contracting, Inc. f/d/b/a Russel A. Rineer 104S. 17th Street Camp Hill, PA 17011 Russel A. Rineer, Jr. 104 S. 17th Street Camp Hill, PA 17011 Cp l cjh003968VO01 M ?.a r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, No. 05-6336 vs. PRAECIPE FOR SATISFACTION RUSS RINSER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINEER, JR. as Personal Guarantor, Defendants. FILED ON BEHALF OF Plaintiff(s) COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA ID #38527 CHRISTOPHER M. BOBACK, ESQUIRE PA ID #91730 SHAWN P. MCCLURE, ESQUIRE PA ID #205951 Bernstein Law Firm, P.C. Firm #718 Suite 2200 Gulf Tower Pittsburgh, PA 15219 412-456-8100 BERNSTEIN FILE NO. C0061185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, vs. Civil Action No. 05-6336 RUSS RINSER CONTRACTING, INC. formerly doing business as RUSSEL A. RINEER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants. PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subscribed before me this O(A BERNSTEIN LAW FIRM, P.C. By: A orneys for Plaintiff Suite 2200 Gulf Tower Pittsburgh, PA 15219 (412) 456-8100 BERNSTEIN FILE NO: C0061185 day of n u? , 2007 N ry Public 90WOONWE LTH OF P WSYLVA vw NotmW Seal Linda Boyle, hbkwy PL"C CRY Of P*3Wx K A?aowV Cm* My Cwn*sim E*kw Od A 2M I Mon*r, ltmnsylvanW As"WO M oI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MCCLURE-JOHNSTON COMPANY, succesor-in merger with JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff, VS. Civil Action No. 05-6336 RUSS RINEER CONTRACTING, INC. formerly doing business as RUSSEL A. RINSER, a sole proprietorship, and RUSSEL A. RINSER, JR. as Personal Guarantor, Defendants. CERTIFICATE OF SERVICE I, Nicholas D. Krawec, Esquire, hereby certify that a true and correct copy of the foregoing Praecipe for Satisfaction was served on the Defendants by regular U. S. Mail, postage prepaid, this #1 day of ?, 2007, addressed as follows: RUSS RINEER CONTRACTING, INC. f/d/b/a RUSSEL A. RINEER 104 S. 17th Street, Camp Hill Cumberland County, Pennsylvania 17011 RUSSEL A. RINEER, JR. 104 S. 17th Street, Camp Hill Cumberland County, Pennsylvania 17011 ,, WRIT OF EXECUTION and/or ATTACHMENT REISSLIM COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6336 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MCCLURE-JOHNSTON COMPANY, SUCCESOR-IN MERGER WITH JACK BROWN WHOLESALE SUPPLY, INC., Plaintiff (s) From RUSS RINEER CONTRACTING, INC. FORMERLY DOING BUSINESS AS. RUSSEL A. RINEER, A SOLE PROPRIETORSHIP, AND RUSSELL A. RINEER, JR. AS PERSONAL GUARANTOR, 104 S. 17TH STREET, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY AGAINST PROPERTY AT 104 S. 17TH STREET, CAMP HILL, PA 17011. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 1130 CARLISLE ROAD, CAMP HILL, PA 17011 - SERVE INTERROGATORIES GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3559 - $4,906.13 L.L. $.50 Interest FROM 11/26/05 TO 10/17/06 an $4,906.13 -- $262.48 Atty's Comm % Due Prothy $1.00 Atty Paid $37.50 Other Costs -$991.50~ $103.37 Plaintiff Paid Date: APRIL 4, 2006 CURTIS R. LONG Prothono (Seal) By: Deputy REQUESTING PARTY: Name CHRISTOPHER M. BOBACK, ESQUIRE Address: BERNSTEIN LAW FIRM, P.C. SUITE 2200 GULF TOWER PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-456-8114 Supreme Court ID No. 91730 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Advance Costs: 300.00 Sheriff's Costs 267.14 Docketing 36.00 32.86 Poundage 5.24 Advertising Law Library .50 Prothonotary 1.00 Mileage 26.40 Misc. Surcharge 100.00 Levy 80.00 Post Pone Sale Certified Mail Postage Garnishee 18.00 TOTAL 267.14 ? Refunded to Atty on 10/24/07 ijlt7Jv7 ?1-y?- So Answers, R. Thomas Kline, S riff By C ?& 0z :1 d II NY 'f? `?1i?llU::i t1N'ri i1?38W110 JJ183HS 3H1 30 3013.30