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HomeMy WebLinkAbout06-1784 BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff GRAND VALLEY MANUF ACTURlNG CO. 220 South Washington Street, Titusville, PA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. () l-. In <{ CUrJ. .- Iv- CALABRESE & SONS, INe. 406 Brandy Lane, Mechanicsburg P A 17055 Defendant : CIVIL ACTION - LAW COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within (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 yonr defenses or objections to the claim 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cnrnberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 71666 BURTON NEIL & ASSOCIATES, P.C. Burton Neil, Esquire, Identification No. 11348 1060 Andrew Drive, Suite 170 WestChester,PA 19380 610-696-2120 Attorney for: Plaintiff GRAND VALLEY MANUF ACTURlNG CO 220 South Washington Street, Titusville, P A Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. Ii.', -- : NO. 0 (. - J 1 S 'I vVu / l~ CALABRESE & SONS, INC. 406 Brandy Lane, Mechanicsburg, P A 17055 Defendant : CNIL ACTION - LAW Complaint 1. The plaintiff is Grand Valley Manufacturing Co with place of business located at 220 South Washington Street, Titusville, Pennsylvania 2. The defendant is Calabrese & Sons, Inc. with place of business located at 406 Brandy Lane, Mechanicsbnrg, Cnrnberland County, Pennsylvania. 3. At the instance and request of the defendant, the plaintiff sold and delivered to defendant goods and merchandise at the times, of the kinds, in the quantities, for the prices and pursuant to the terms set forth in plaintiff's invoices to defendant, copies of which are attached hereto, made a part hereof and are marked Exhibit A. 4. The goods and merchandise which plaintiff sold to the defendant were of a good and merchantable quality and were those goods which the defendant had ordered from plaintiff. The defendant received and accepted all of the goods and merchandise sold to it by the plaintiff. S. The prices plaintiff charged defendant were fair and reasonable and were the prices defendant had agreed to pay plaintiff. 6. From time to time, plaintiff called defendant to discuss balance due plaintiff in the snrn of $12,000.00, which statements defendant received without protest. 7. Although demand was made by plaintiff upon defendant to pay the snrn of$12,000.00, the defendant failed and refused to pay all or any part thereof. 8. Plaintiff is entitled to interest at 6% per annum from 30 days after invoice date. Wherefore, plaintiff demands judgment against defendant in the snrn of $12,000.00 together with interest at 6% per annnrn from 30 days after invoice date and the costs of this action. BURTON N IL & ASSOCIATES, P.C. ( By: Burton Neil, squire Attorney for Plaintiff -GRAND VALLEY MANUFACTURING CO. Invoice INVOICE No.1 11444-02 PHONE (814) 827-2707 FAX (814) 827-4349 Date Customer P.O. No. Cust Part No. Drawing No. Customer Phone No. 9/16/2004 1204 Cylinder Assembly 506311 (717) 766-4771 GVM Part No. Freight Carrier Sales Representative Gl Acct 5431 5002.00 Sold to: Calabrese & Sons, Inc. TERMS: 1/2% 10 DAYS - NET 30 DAYS. Ship to: Calabrese & Sons, Inc. PO Box 1667 FINANCE CHARGE OF 1% PER MONTH. PO Box 1667 406 Brandy lane SIMPLE INTEREsr ON ALL PAST DUE 406 Brandy lane Mechanicsburg PA 17055 ACGOUNTS Mechanicsburg PA 17055 . Description & SIN Quantity Unit Price UM ltemAmt 4130 forging rough machined to dwg CS8726926 3 4.340.000 EA 13.020.00 GVM machine complete to dwg 506311 Rev N three parts released by Government inspector Frank Wiseniewski 9/16/04 SIN 432965-1. 432965-2,5 EXHIBIT A Grand Total 13,020.00 Remit to: 220 SOUTH WASHINGTON STREET TITUSVillE, PA 16354 GRAND - VALLEY . MANUFACTURING CO. Invoice INVOICE No.1 11444-01 PHONE (814) 827-2707 FAX (814) 827-4349 Remit to: 220 SOUTH WASHINGTON STREET TITUSVillE, PA 16354 Date Customer P.O. No. Cust Part No. Drawing No. Customer Phone No. 7/26/2004 1204 Cylinder Assembly 506311 (717) 766-4771 GVM Part No. Freight Carrier Sales Representative Gl Accl 5431 5002.00 Sold to: Calabrese & Sons, Inc. rERMS: 1/2% 10 DAYS. NET 30 DAYS. Ship to: Calabrese & Sons, Inc. PO Box 1667 FINANCE CHARGE OF 1% PER MONrH. PO Box 1667 406 Brandy lane SIMPLE INTERESr ON ALL PASr DUE 406 Brandy lane Mechanicsburg PA 17055 ACCOUNTS Mechanicsburg PA 17055 Description & SIN Quantity Unit Price UM ItemAmt 4130 forging rough machined to dwg CS8726926 2 4.340.000 EA 8,680.00 G VM machine complete to dwg 506311 Rev N two parts released by Government inspector Frank Wiseniewski 7/26/04 SIN 432965-3, & 432965-4 Grand Tolal 8,680.00 . . Verification F,eA-IIIK I-! ,,'" E j (Name of authorized representative) IS c. Fo (Title or Position) for Grand Valley the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best ofthe undersigned verifier's knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 3/}./o6 . c- /7~ ~ .[ ~~ : c>' C ,. o '( ....0 " G ... -C. +:, (- , ~ I'l LA. V" v (:l, (") ,.., c> f_"J " t....::; -n t-;;-' .-4 >',' -....1: --n I " F': -n fT' C?> T",,) ;---~ -' -::; ( r,\ .Co_ , ~') 0 :< -- ------ F,IFlLESIDA T AFILEIGenerallCurrentl1 1093.16.ans 1 \mas Created 9120/04006PM Revised: 4/28/06 3:28PM 11093.16 David A. Fitzsimons, Esquire MARTSON DEARDORFF WILLIAMS & OTTO J.D. No. 41722 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant GRAND VALLEY MANUFACTURING CO., Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-1784 CIVIL ACTION - LAW CALABRESE & SONS, INC., Defendant. JURY TRIAL DEMANDED DEFENDANT CALABRESE & SONS. INC.'S ANSWER TO PLAINTIFF'S COMPLAINT NOW comes the Defendant, Calabrese & Sons, Inc., by its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and avers the following in response to the Complaint of Plaintiff: 1. Admitted upon information and belief. 2. Admitted. 3.-6. Admitted. 7. Admitted in part and denied in part. While it is admitted that as ofthis pleading, the sum due of $12,000.00 has not been paid. Defendant has not "refused" to pay such, which is a legal conclusion; to the extent a response is required, Defendant intends to pay as soon as it has sufficient funds available to pay the invoice. 8. Admitted. WHEREFORE, Defendant requests that this Court enter an award in accordance with its obligation to pay $12,000.00 and 6 percent interest and costs to the Plaintiff as requested in Plaintiff s Complaint. MARTSON DEARDORFF WILLIAMS & OTTO ~~~~~ Date: April 28, 2006 David A. Fitzsimons, Esquire J.D. No. 41722 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Deardorff Williams & Otto, herebycertity that a copy ofthe foregoing Defendant Calabrese & Sons, Inc. 's Answer to Plaintiff s Complaint was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Burton Neil, Esquire BURTON NEIL & ASSOCIATES, P.c. 1060 Andrew Drive Suite 170 West Chester, PA 19380 MARTS ON DEARDORFF WILLIAMS & OTTO BY:'(\~LtL1X, c. jthC{[l~) Meliss~ A. Scholly J Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: April 28, 2006 b7Ji .-?' :.- ~', ,') C) --..~ (' c) BURTON NEIL & ASSOCIATES, P.C. BY: Yale D. Weinstein, Esquire, LD. No. 89678 1060 Andrew Drive, Suite 170, West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff GRAND VALLEY MANUFACTURlNG CO. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA VS. : NO. 06-1784 civil CALABRESE & SONS, INC. Defendant : CIVIL ACTION - LAW Praecipe for Judgment on Admissions To the Prothonotary: Pnrsuant to PA R.C.P. 1037(b), you are requested to enter judgment for the plaintiff GRAND VALLEY MANUFACTURING CO.and against the defendant CALABRESE & SONS, INC. on the admissions in its answer to the complaint, a copy of which is attached hereto as Exhibit A and, to assess damages as follows: Principal snrn: Interest from 10/16/04 to 5/16/06 @ 6%: TOTAL: $12,000.00 $ 1,140.00 $13,140.00 By: e Ill, Esquire ey for Plaintiff And now, this .:2t:S-~.^'- day of , 200' judgment is entered for the plaintiff GRAND VALLEY MANUFACTURING CO. and against the defendant CALABRESE & SONS, INC. per PA R.C.P. 1037 (b) and damages are assessed in a snrn certain against said defendant pnrsuant to the admissions in its answer to the complaint as follows; in the total principal sum of $12,000.00 along with interest in the amount of$1,140.00 for a total of$13,140.00. a~l By . In making this communication, we advise our firm is a debt collector. F\F'ILESIDATAFILE\Gtncn:aI\C\lITtlll.\IIQllJ.16._I'omll ~ ClYllloM. ~iJIlU 0:00PM R.evi>>N: 4r.8IOtI J.~BPM 1l04J.16 David A. Fitzsimons, Esquire MARTSON DEARDORFF WILLIAMS & OTTO J.D. No. 41722 10 East High Street Carlisle,PA 17013 (717) 243-3341 Attorneys for Defendant (") ...., = 0 c = " <~ ~ ..,.,.i'":""": > ~-n !:!}r'i " +.".~ .' ;;;0 mF OJ ~o '" "'em ~,oO --.:: . co C)(L, ~~~ " .=.?o"r, 0.'-0,' ~5;D "7'.. . :::!:: ~,' ......,- >c w 3m Z =-' -l C" :ii -< = -< GRAND VALLEY MANUF ACTUR1NG CO., Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-1784 CIVIL ACTION - LAW CALABRESE & SONS, INC., Defendant. JURY TRIAL DEMANDED DEFENDANT CALARRI?SE & SONS.INC.'S ANSWER TO PLAINTIFF'S COMPLAINT NOW comes the Defendant, Calabrese & Sons, Inc., by its attorneys, MARTSON DEARDORFFWII1.lAMS & OTTO, and avers the followinginresponse to the Complaint ofPlaintiff: I. Admitted upon information and belief. 2. Admitted. 3.-6. Admitted. 7. Admittedinpartanddeniedinpart. While it is admittedtbatasofthisplcading, the sum due of$12,OOO.OO has not been paid. Defendant has not "refused" to pay such, which is a legal conclusion; to the extent a response is required, Defendant intends to pay as soon as it has sufficient !\mds available to pay the invoice. 8. Admitted. EXHIBIT A .. WHEREFORE, Defendantrequests that this Court enter an award in accordance with its obligation 1 to pay $ 12.000.00 and 6 percent interest and costs to thePlaintiffas requested in Plaintitrs ComPlaint~ MARTSON DEARDORFF WILLIAMS & OTIO Date: Apri128, 2006 ~~~- David A. Fitzsimons, Esquire I.D. No. 41722 10 East High Street Carlisle,PA 17013 (717) 243-3341 Attorneys for Defendant , . CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copyofthe foregoing Defendant Calabrese & Sons, Inc. 's Answer to Plaintiffs Complaint was served this date by depositing same in the Post Office at Carlisle, P A, frrst class mail, postage prepaid, addressed as follows: Burton Neil, Esquire BURTON NEIL & ASSOCIATES, P.e. 1060 Andrew Drive Suite 170 West Chester, P A 19380 MARTSON DEARDORFF WILLIAMS & OTTO By:', \, l1Y\ C, Melissa A. Scholly Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: April 28, 2006 BURTON NEIL & ASSOCIATES, P.C. BY: Yale D. Weinstein, Esquire Identification No. 89678 1060 Andrew Drive, Suite 170 WestChester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff GRAND VALLEY MANUFACTURING CO. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1784 civil CALABRESE & SONS, INC. Defendant : CIVIL ACTION - LAW RULE OF CML PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on...J'1 . \p _ ~~ :) ;'Y)fo I By: Deputy If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. BURTON NEIL & ASSOCIATES, P.C. BY: Yale D. Weinstein, Esquire Identification No. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff GRAND VALLEY MANUFACTURING CO. 220 South Washington St, Titusville, PA Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1784 civil CALABRESE & SONS, INC. 406 Brandy Lane Mechanicsburg PA 17055 Defendant : CIVIL ACTION - LAW Certification of Address Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. BURTO NE & SOCIATES, P.C. (' By: Ill, Esquire for Plaintiff In making this communication, we advise that our firm is a debt collector. ,>~D~ v r. '"!J a- \\. 0 & ~ ~ ~ ~~:Sf ~'~ ~-1- ~~ () r::':.") -n c....... c~ ..-t (": ~~;n -.,- -:"1" f".' - 'C' c- -.. r',) (...."; c"t. cJ..I.. U' ,;; -< \I- l~ - I f ~ SHERIFF'S RETURN - REGULAR CASE NO: 2006-01784 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRAND VALLEY MANUFACTURING CO VS CALABRESE & SONS INC BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CALABRESE & SONS INC the DEFENDANT , at 0921:00 HOURS, on the 29th day of March , 2006 at 406 BRANDY LANE MECHANICSBURG, PA 17055 by handing to JOE CALABRESE, OWNER ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 8.80 .00 10.00 .00 36.8~~03/30/2006 '-1". BURTON NEIL r-~e:~<~ R. Thomas Kline Sworn and Subscribed to before By: ~, Deputy Sheriff me this /'1 €: ~ ~(,. day of A.D. Prothonotary ~' - PRAECIPE FOR WRIT OF EXECUTION (MONEY mDGMENT) Pa.R.C.P. ~ 3103 to 3149 GRAND V ALLEY MANUFACTURING CO. Plaintiff : IN THE COURT OF COMMON PLEAS VS. CALABRESE & SONS, INC. Defendant( s) INTEGRITY BANK Garnishee( s ) : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-1784 civil : CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. 3. against CALABRESE & SONS. INC. and against INTEGRITY BANK , Defendant(s) , Gamishee( s) 4. and index this writ ( a) against (b) against Defendant( s) Garnishee( s) as a lis pendens against the real property of the defendant( s) in the name of the Gamishee( s) as follows: (specifically describe property) Levy on all property of the defendant at: 406 Brandy Lane, Mechanicsburg P A 17055 Serve interrogatories on garnishee at: 3345 Market Street, Camp Hill, P A 17011 5. Amount Due Interest from 6/20/06 Total *Plus writ costs Dated: July 17, 2006 $13,140.00 $58.77 $13,198.77* ( Yale D. Weinstein, Esquire Attorney for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another coun as authorized by Rule 31 03(b), the county should be indicated. Under Rule 31 03( c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 31 04( a). When the writ issued to another county indexing is required as of course in that county. See Rule 31 04(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. - S "e. -+- ~ -- ~ - ~~ w..to... ~ 7t f4 ~ ~ l.> , r -. - w V, 0 'CrJ . v" ~ CI) 0- C) o 0' 0 ~ V'\ ~ :" -,~. ) Lv \) ~ Q \' \ ' ; R \ \ I \ ..--' r -- ~~ r:J -J ~ ~ - '. ..... - - -- ~?- - ...... ... ~ (:,' _t;::Jb ~ . - - ..., .' ...... - - -# tj ~ p- WRIT OF EXECUTION and/or ATTACHMENT " - COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1784 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GRAND VALLEY MANUFACTURING CO., Plaintiff (s) From CALABRESE & SONS, INC., 406 BRANDY LANE, MECHANICSBURG, P A 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY OF THE DEFENDANT AT: 406 BRANDY LANE, MECHANICSBURG, PA 17055 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of INTEGRITY BANK, SERVE INTERROGATORIES ON GARNISHEE AT: 3345 MARKET STREET, CAMP HILL, PA 17011 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $13,140.00 Interest FROM 6/20/06 - $58.77 Atty's Comm % Atty Paid $119.30 Plaintiff Paid Date: JULY 21, 2006 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name YALE D. WEINSTEIN, ESQillRE Address: BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SillTE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 89678 BURTON NEIL & ASSOCIATES, P.C. By Y:ale D. Weinstein, Esquire Identification No. 89678 , 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff GRAND V ALLEY MANUFACTURING CO. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-1784 civil CALABRESE & SONS, INC. Defendant : CNIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Mark the judgment Satisfied on payment of your costs only. By: The law firm of Burton Neil & Associates is a debt collector. 71666 1111111111I111111111111111111111111 111111111111111111111111111111I11111111111111111111111111111111111111111111111111111111111111111111111111 2 s. '"0 ftj IT\!.' ' ~;'~,_. 2' ..t::. %'~~ ~ g cr" (/) Cd N 0' ~ ....... ~ ~-n 1"\"\ r:: -0 rr~ .,)0 ~~~) (2- (~: .(:-rn 9 ~ \.f! o o,.D Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Gainishee Postage TOTAL 18.00 262.80 Advance Costs: 364.50 Sheriffs Costs: 364.50 $ 000.00 ~ ;J} ~ Sheriffs Costs: .50 1.00 13.20 40.00 20.00 Refunded to Atty on 09/12/06 9.00 $ 364.50 ../ q.:ll-()(., 9- So~~ ~ r~"~I'~ R. Thomas Kline, Sheriff CJCt-4J,'o. ~ By Claudia A. Brewbaker c. C' I - ~ :E I I :( d S l lnr 900l \/d ./\.1 ;'~ l !..) ,.; L ,'-~ ';1 i d .~: b v~ l i ._-; .::L:lIB3HS ]Hl .::lCl 3JI.:UO Cft-t5''i'-l9 / ~ n,lO$ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GRAND VALLEY MANUFACTURING CO., NO 06-1784 Civil CIVIL ACTION - LAW Plaintiff (s) From CALABRESE & SONS, INC., 406 BRANDY LANE, MECHANICSBURG, P A 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY OF THE DEFENDANT AT: 406 BRANDY LANE, MECHANICSBURG, P A 17055 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of INTEGRITY BANK, SERVE INTERROGATORIES ON GARNISHEE AT: 3345 MARKET STREET, CAMP HILL, PA 17011 GARNISHEE(S) as follows: and to notify the gamishee(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) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $13,140.00 Interest FROM 6/20/06 - $58.77 Atty's Comm % Atty Paid $119.30 Plaintiff Paid Date: JULY 21, 2006 L.L. $.50 (Seal) Due Prothy $1.00 Other Costs f~ Prothonotary By: Deputy REQUESTING PARTY: Name YALE D. WEINSTEIN, ESQUIRE Address: BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 89678