HomeMy WebLinkAbout06-5291
il
,BEST ROOFING TECHNOLOGY, INC.,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2006- S-J-rl U c 1)
CIVIL ACTION-LAW
IJERRY M. TROLINGER, VI UNG LEE,
IPYONG SUN LEE, VILLAGECRAFT
ICONTRACT FURNISHINGS, L.P,
i and VILLAGE CRAFT FACTORY
I
iDIRECT, INC.,
MECHANICS' LIEN
Defendants.
BEST ROOFING TECHNOLOGY, INC.'S
MECHANICS LIEN AGAINST JERRY M. TROLINGER, UI UNG LEE,
PYONG SUN LEE, VILLAGE CRAFT CONTRACT FURNISHINGS, L.P.,
AND VILLAGECRAFf FACTORY DIRECT INC.
1. The Claimant is Best Roofing Technology, Inc. ("Best Roofing") with an address
of 1462 Trind1e Road, Carlisle, Cumberland County, Pennsylvania 17013.
2. Pursuant to 49 P.S. 91201(5), Best Roofing files its mechanics' lien claim as a
subcontractor in this case.
3. The owners of the property subject to this mechanics' lien claim are Vi Vng Lee
and Pyong Sun Lee with an address of 501 Park Hills Drive, Mechanicsburg, Cumberland
County, Pennsylvania, 17055, Jerry Trolinger, VillageCraft Factory Direct, Inc. and VillageCraft
Contract Furnishings, L.P.
4. Jerry Trolinger is an adult individual with a residence address of 2551 Spring
Road, Carlisle, Cumberland County, Pennsylvania 17013.
5. VillageCraft Factory Direct, Inc. is a Pennsylvania corporation with a registered
office at 2551 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013.
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6. VillageCraft Contract Furnishings, L.P. is a Pennsylvania limited partnership with
a registered address of 1446 Holly Pike, Carlisle, Cumberland County, Pennsylvania 17013.
VillageCraft Contract Furnishings, L.P. is the record owner of the following fictitious name:
VillageCraft Quality Furnishings.
7. Best Roofing entered into an agreement with Rick Garman to install a new single
ply membrane roof on a building located at 1446 Holly Pike, Carlisle, Cumberland County,
Pennsylvania 17013.
8. Best Roofing completed installation of the roof system on May 30,2006.
9. Formal notice of intention to file this mechanics' lien claim was provided July 20,
2006.
10. The work performed by Best Roofing consisted of the removal of an existing built
up roof, replacement of rotted or deteriorated deck boards, installation of polyisocyanurate
insulation to the deck, installation of a reinforced membrane, flashing and accessories. Further
description of the labor and materials provided are attached hereto as Exhibit "A" and Exhibit
"B" and are incorporated by reference.
11. The amount due Best Roofing is $29,973.00.
,I
12. The property subject to this lien is described as follows:
ALL that certain tract of land situate in South Middleton
Township, Cumberland County, Pennsylvania, bounded and
described as Lot 3a according to Final Subdivision Plan for Leo's
Dairy, prepared by Douglas S. Brehm, P.L.S., of Statler-Brehm
Associates, Inc., dated April 20, 1994 and recorded in Cumberland
County Plan Book 68, Page 83.
BEING a portion of the premises which Allen Dairy Farms, Inc., by deed dated
May 26, 1983 and recorded in the Office ofthe Recorder of Deeds in and for
Cumberland County in Deed Book "E", Volume 30, Page 954, granted and
conveyed unto Leonard S. Leo, Grantor herein.
UNDER AND SUBJECT to a non-exclusive 60 foot wide access easement
serving said Lot 2A and the remaining lands of Grantor herein as set forth on the
Plan aforesaid.
ALSO known and numbered as 1446 Holly Pike, Carlisle, Cumberland County,
Pennsylvania.
13. Upon information and belief, Ui Ung Lee and Pyong Sun Lee executed a written
acknowledgment of the work prior to commencement of the work.
Respectfully submitted,
O'BIDEN, B~C:t71
David A. Baric, Esquire
J.D. # 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff
dab.dir/corporate/best/Jee/mechanicslien.clm
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Best Roofing Technology, Inc. r-5id/03 uy
ESTIMATE WORK SHEET-ADHERED
Job Name:
Location:
Date:
Quantity Description Unit Price Total Cost
6000 sq. ft. .045 reinforced EPDM 0.40 2,400.00
o sg. Ft. .045 NR 0.27 0.00
o sq. ft. .060NR 0.42 0.00
o sq. ft. .060R 0.53 0.00
o sq. ft. .45r Sure Weld TPO= 0.44 0.00
o sq. ft. 60 Sure Weld TPO.98 0.56 0.00
o sq. ft. Fleeceback 100 0.55 0.00
o sq. ft. Fleeceback 115 0.65 0.00
o sq. ft. Plywood 4' x 4'_ 4'x8' 1" 0.42 0.00
5250 sq. ft. Polyiso 4' x 4'_ 4'x8'_ 2" 0.77 4,042.50
o sq. ft. Polyiso 4'x4'_ G board 0.40 0.00
o sq. ft. Tapered 4'x4'_ X board 0.33 0.00
o sq. ft. Tapered 4"x4" Y board 0.66 0.00
-
o sq. ft. Tapered 4' x 4'_ Q Board 13.44 0.00
o sq ft Ins. Supplier Bradco 1/8" or 1/4" Quote 0.00
o sq. ft. Polyiso 4' x 4'_ 4'x8' 1 1/2 inch 0.28 0.00
o sq. ft. Fiberboard 4'x8' 1/2 inch 0.15 0.00
o sets Fast 100 15 gal 600.00 0.00
sets Fast 100 Box Set 180 sq. ft. 210.00 0.00
o gal Bonding Adhesive 13.51 0.00
1 gal EP.95 25.30 25.30
2 gal HP-250 16.85 33.70
o gal Weathered Membrane Cleaner 10.28 0.00
o each 6" Pourable Sealer Pocket 17.23 0.00
o each 8" Pourable Sealer Pocket Psen 19.38 0.00
o roll 18" Kleen Cured Flashing 105.00 0.00
o roll 24" Kleen Cured Flashing 100 155.55 0.00
o roll ~2" Non Reinforced Flashing 117.30 0.00
o roll 6" Non Rienforced flashing Uncured 53.00 0.00
2 rolls 6" Pressure Sensitive flashing 119.00 238.00
1 roll 6" RUSS PS 89.68 89.68
o roll 9: RUSS PS 134.51 0.00
Octn Lapsealant 105.00 0.00
o pcs PS InIOut Comers 4.87 0.00
1 ctn WCOM 35.00 35.00
o pcs Sm. Pipe Boots PS 13.17 0.00
o pcs Lg Pipe Boots PS 21.12 0.00
1 ctn 3" Insulation Plates 68.85 68.85
1 ctn 2" Seam Plates 59.50 59.50
o etn Locking Seam Plates Polymer 105.40 0.00
Oetn 8" hp 500 178.00 0.00
2 4" HP 1000 170.00 340.00
o ctn 5" SureFast 250 42.71 0.00
6" ASAP . 250 57.38
Octn 10" Preassem. Seam 126.99 0.00
o ctn 1 1/4" HP Fasteners 35.00 0.00
o gal Pourable Sealer 31.81 0.00
etn 2 1/4" HP fasteners 54.40 0.00
6 roll 3" SecurTape 44.20 265.20
o roll 6" secure tape 62.05 0.00
EXHIBIT IIAII
:
o
o lin ft
220 lin ft
o lin ft
o lin ft
o lin ft
o lin ft
o lin ft
o lin ft
lin ft
pcs
lin ft
each
o lin ft
o man days
15 man days
o man days
o man days
o man days
o man days
o man days
o man days
5 man days
o man days
o man days
o man days
o man days
0.00
Drip Edge I (2.5" face) Color
Drip Edge II ( 4" face)
SecurEdge ~ Coping Sys tem Kynar Steel 8"
SecurEdge ~ Coping System Kynar Alum. .050 10'
SecurEdge Gravel Stop HighStop I
SecurEdge Gravel Stop HighStop II
SecurEdge Gravel Stop ShortStop I
SecurEdge Gravel Stop ShortStop II
Secure EDGE 2000
Secure EDGE 2000 Comers
Extension
Comers
0.40
3.35
6.50
8.50
4.20
4.72
4.40
5.35
5.99
29.97
3.48
15.04
5" Box Gutter
shop fab .040 sheets 2.25
15% Increase Acc.
LABOR
Install new roof
Tear off existing roof
Install T. Bar
Fab new 5" box gutter
Install new gutter
Install new gravel stop &drip edge
Install new pressure treated lumber for coping
Flash curbs
Flash walls
Flash pipes and PS Pockets
Rework two (2) drains
Misc. work Coat Metal roof
travel
Sub Total
Tax
Total Materials
170.00
170.00
170.00
170.00
170.00
170.00
170.00
170.00
170.00
170.00
170.00
170.00
170.00
Sub Total
Mark.up
Total Labor
SUBCONTRACT
20 Total Man Days
4 crew days
5 crew size
o days Crane
3 each Dumpster
o per day Rentals
o sf Firestone Warranty
o sf Warrenty
o man hours p Travel 1 Hrs. per man
4 days FUEL
o per day Lodging
o crew per da: Meals
36282
24,577 .59
0.6774045
425.00
450.00
1200.00
0.07
0.06
25.00
60.00
3 85.00
5 20.00
Total subcontract
Total Materials
Total Labor
Total Subcontract
Sub total
Overhead
Profit
0.00
737.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.00
8,424.73
1.06
8,930.21
0.00
2,550.00
0.00
0.00
0.00
0.00
0.00
0.00
850.00
0.00
0.00
0.00
0.00
3,400.00
1.65
5,610.00
0.00
1,350.00
0.00
0.00
750.00
0.00
240.00
0.00
0.00
2,340.00
8,930.21
5,610.00
2,340.00
16,880.21
1.12
18,905.84
1.30
Total Contract Price
.'
24,577.59
SEP-11-2006 08:48 From:8EST ROOFING
Best Roofing Technology, Inc.
1462 Trindle Road
Carlisle, PA 17013
7172588951
To: 7172495755
inVOice l'iUIIIU~1
P.4/4
I:> II
Telephone:
Fax:
800.935-7663
717-258-8951
Sold To:
Rick Garman
2506 Walnut Bottom Road
Carlisle, PA 17013
Old Leo's Dairy
1446 Holly Pike
Carlisle. PA 17013
Customer 10
R1CKGARM
Customer PO
_ I Village Craft
Job Location
Invoice Date
J 5119/06
. p'
E
Item Quanity Descrivtion Umt rIce xtensfon
HOURS 76.5 To replace damaged woOd 55.00 4,207.
- , Plywood/Nails/Mise 3625.50 3.625.
.'
Please note our new remittance address
50
50
. ,
Subtotal
7,833.00
PleaS9 femit to
Best Roofing Tcchnofogy, Inc.
1462 Trindle Road
Carl/sic, PA 17013
Total $7,833.00
Exhibit "B"
VERlFICA nON
I verify that the statements made in the foregoing Best Roofing Technology, Inc.' s
Mechanics Lien Against Jerry M. Trolinger, Ui Ung Lee, Pyong Sun Lee, Villagecraft Contract
Furnishings, L.P. and Villagecraft Factory Direct, Inc. are true and correct to the best of my
knowledge, information and belief. This verification is signed by David A. Baric, Esquire,
Attorney for Plaintiff and is based upon the statements provided by Plaintiff, as well as
documents reviewed by the undersigned as attorney for Plaintiff. This verification will be
substituted and ratified by a verification signed by the Plaintiff who is presently unavailable to
sign said verification. I undersigned that false statements herein are made subject to penalties of
David A. Baric, Esquire
Dated:
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
BEST ROOFING TECHNOLOGY, INC.,
Plaintiff,
NO. 2006-5291-MCD
v.
CIVIL ACTION - LAW
JERRY M. TROLINGER; UI UNG LEE;
PYONG SUN LEE; VILLAGECRAFf
CONTRACT FURNISHINGS, L.P.; and
VILLAGECRAFT FACTORY DIRECT,
INC.,
MECHANICS' LIEN
Defendants.
PRAECIPE FOR ENTRY OF APPEARANCE
TO: Prothonotary, Cumberland County Court of Common Pleas
Kindly enter the appearance of the undersigned in this action as counsel of record
for Defendants JERRY M. TROLINGER, VILLAGECRAFf CONTRACT FURNISH-
INGS, L.P., and VILLAGECRAFf FACTORY DIRECT, INC.
Dated this -i- day of October, 2006.
PALLO LUC;CH7SI LAW OFFICES, LLC
.1 l ~t2 (I (I k~JL,\1
Faith M. Lucchesi
No. 86323
1368 South Atherton Street
State College, PA 16801
Phone: 814.237.1951
Fax: 814.689.1759
Faith(@2LawDogs.com
..
~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
BEST ROOFING TECHNOLOGY, INC.,
Plaintiff,
NO. 2006-5291-MCD
v.
CIVIL ACTION - LAW
JERRY M. TROLINGER; UI UNG LEE;
PYONG SUN LEE; VILLAGECRAFf
CONTRACT FURNISHINGS, L.P.; and
VILLAGECRAFT FACTORY DIRECT,
INC.,
MECHANICS' LIEN
Defendants.
CERTTIFICATE OF SERVICE
I certify that a copy of the foregoing PRAECIPE FOR ENTRY OF
APPEARANCE has been served by prepaid, first class U.S. Mail, upon the Plaintiff in
the manner indicated, this 4#'-- day of October, 2006, to:
David A, Baric, Esq.
O'Brien, Baric & Scherer
19 West South Street
Carlisle, P A 17013
P ~ LUCCHESI LAW OFFICES, LLC
tilt L~(!({ ~
Faith M. Lucchesi
ID No. 86323
1368 South Atherton Street
State College, PA 16801
Phone: 814.237.1951
Fax: 814.689.1759
Faith@2LawDogs.com
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
BEST ROOFING TECHNOLOGY, INC.,
Plaintiff,
NO. 2006-5291-MCD
v.
CIVIL ACTION - LAW
JERRY M. TROLINGER; UI UNG LEE;
PYONG SUN LEE; VILLAGECRAFT
CONTRACT FURNISHINGS, L.P.; and
VILLAGECRAFf FACTORY DIRECT, INC.,
MECHANICS' LIEN
Defendants.
PRELIMINARY OBJECTIONS TO PLAINTIFF'S MECHANICS' LIEN
AGAINST .JERRY M. TROLINGER. UI UNG LEE. PYONG SUN LEE.
VILLAGECRAFT CONTRACT FURNISHINGS. L.P.. AND
VILLAGECRAFf FACTORY DIRECT INC.
Pursuant to Pa. R.c.P. No. 1028, Defendants Jerry M. Trolinger, VillageCraft Contract
Furnishings, L.P., and VillageCraft Factory Direct, Inc., preliminarily object to the Plaintiff's
Mechanics' Lien as follows:
1. This lien has been filed as a result of work purportedly performed on leasehold
premIses.
A. The Lien Has Been Filed Against Persons or Entities Who Are Not Proper Parties.
2. Named and served as Defendants on the Lien are persons or entities who (a) are
neither owners nor leaseholders of the property; and (b) were not parties to the contract for
improvements to the leased premises out of which this claim arose.
WHEREFORE, it is respectfully requested that Plaintiff s Mechanics' Lien be dismissed
as to all improper defendants, and that all fees incurred for the filing thereof be charged against
Plaintiff.
Dated this ~ day of October, 2006.
PALLO LUCCHESI LAW OFFICES, LLC
j~l
.fLl+'A'
Faith M. Lucchesi
Attorney for Defendants Jerry M. Trolinger,
Village Craft Contract Furnishings, L.P.,
and VillageCraft Factory Direct, Inc.
ID No. 86323
1368 South Atherton Street
State College, PA 16801
Phone: 814.237.1951
Fax: 814.689.1759
F aithCW2LawDogs.com
2
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
BEST ROOFING TECHNOLOGY, INC.,
Plaintiff,
NO. 2006-5291-MCD
v.
CIVIL ACTION - LAW
JERRY M. TROLINGER; UI UNG LEE;
PYONG SUN LEE; VILLAGECRAFr
CONTRACT FURNISHINGS, L.P.; and
VILLAGECRAFT FACTORY DIRECT, INC.,
MECHANICS' LIEN
Defendants.
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing PRELIMINARY OBJECTIONS TO PLAINTIFF'S
MECHANICS' LIEN AGAINST JERRY M. TROLINGER, UI UNG LEE, PYONG SUN LEE,
VILLAGECRAFr CONTRACT FURNISHINGS, L.P., AND VILLAGECRAFr FACTORY
DIRECT, INC., has been served upon the Plaintiff by placing the same in the United States
j~
Postal Service, postage paid, first-class mail, properly addressed, this ~ day of October,
2006, to:
David A, Baric, Esq.
O'Brien, Baric & Scherer
19 West South Street
Carlisle, P A 17013
3
PALLO LUCCHESI LA W OFFICES, LLC
< ItSfi ~((f ~ ~~,
Faith M. Lucchesi
Attorney for Defendants Jerry M. Trolinger, et al.
ID No. 86323
1368 South Atherton Street
State College, P A 16801
Phone: 814.237.1951
Fax: 814.689.1759
Faith(ci:2Law Dogs.com
4
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
BEST ROOFING TECHNOLOGY, INC.,
Plaintiff,
NO. 2006-5291-MCD
v.
CIVIL ACTION - LAW
JERRY M. TROLINGER; UI UNG LEE;
PYONG SUN LEE; VILLAGECRAFf
CONTRACT FURNISHINGS, L.P.; and
VILLAGECRAFf FACTORY DIRECT, INC.,
MECHANICS' LIEN
Defendants.
NOTICE TO PLEAD
TO: BEST ROOFING TECHNOLOGY, INC.
You are hereby notified that you must file a written response to the enclosed Preliminary
Objections within twenty (20) days from service hereof or a judgment may be entered against
you.
Dated this ~ day of October, 2006.
PALLO LUCCHESI LAW OFFICES, LLC
I
)t;aA (Qua (UJ4 '
Faith M. Lucchesi
Attorney for Defendants Jerry M. Trolinger, et al.
ID No. 86323
1368 South Atherton Street
State College, P A 16801
Phone: 814.237.1951
Fax: 814.689.1759
FaithCW2Law Dogs.com
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BEST ROOFING TECHNOLOGY, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2006- 5291
CNIL ACTION-LAW
JERRY M. TROLINGER, UI UNG LEE,
PYONG SUN LEE, VILLAGECRAFT
CONTRACT FURNISHINGS, L.P,
VILLAGE CRAFT FACTORY
DIRECT, INe., VILLAGECRAFT
QUALITY FURNISHINGS and
VILLAGE CRAFT CONTRACT
FURNISHINGS, INC.,
MECHANICS' LIEN
Defendants.
REPLY TO PRELIMINARY OBJECTIONS
NOW, comes Plaintiff, Best Roofing Technology, Inc. ("Best Roofing"), by and through
its attorneys, O'BRIEN, BARIC & SCHERER, and files the within Reply to Preliminary
Objections as follows:
1. Denied. To the contrary, work was performed on property known as 1446 Holly
Pike, Carlisle, Cumberland County, Pennsylvania. Plaintiff has averred that all ofthe Defendants
are owners of this property.
2. After reasonable investigation, Best Roofing is without information sufficient to
form a belief as to the truth of these averments and they are, therefore, denied. To the contrary,
the Defendants are either owners, leaseholders and/or parties to the contract for improvements to
the property.
-
WHEREFORE, Plaintiff requests the Preliminary Objections be overruled and
Defendants pay the costs and fees of Plaintiff.
Respectfully submitted,
~~;&
David A. Baric, Esquire
I.D. # 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff,
Best Roofing Technology, Inc.
dab.dir/corporatelbestroofingllee/preliminaryobjection.rep
.....
VERIFICATION
I verify that the statements made in the foregoing Reply To Preliminary Objections are true
and correct to the best of my knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. c.s. 9 4904, relating to unsworn falsification to
authorities.
~&
David A. Baric, Esquire
DATED:
/d/~/~6
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-...
CERTIFICATE OF SERVICE
I hereby certify that on October <lD , 2006, I, David A. Baric, Esquire of O'Brien, Baric
& Scherer, did serve a copy ofthe Reply To Preliminary Objections, by first class U.S. mail, postage
prepaid, to the parties listed below, as follows:
Faith M. Lucchesi, Esquire
Pallo Lucchesi Law Offices, LLC
1368 South Atherton Street
State College, Pennsylvania 16801
Ui Ung Lee
Pyong Sun Lee
501 Park Hills Drive
Mec~mnC:?iKa 17055
David A. Baric, Esquire
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EST ROOFING TECHNOLOGY, INC.,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
O~ -5a.q I
NO~6()- 2~~1 MLD
CIVIL ACTION-LAW
RRY M. TROLINGER, UI UNG LEE,
YONG SUN LEE, VILLAGECRAFT
ONTRACT FURNISHINGS, L.P,
ILLAGECRAFT FACTORY
IRECT, INC.,
Defendants.
PRAECIPE TO REINSTATE
TO THE PROTHONOTARY:
Please reinstate Best Roofing Technology, Inc's Mechanics Lien Against Jerry M.
Trolinger, Ui Ung Lee, Pyong Sun Lee, VillageCraft Contract Furnishings, L.P. and VillageCraft
Factory Direct, Inc. filed on September 11, 2006.
Respectfully submitted,
Date: October 26, 2006
David A. Baric, Esquire
J.D. # 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
1r.
CERTIFICATE OF SERVICE
I hereby certify that on October 26, 2006, I, David A. Baric, Esquire of O'Brien, Baric &
Scherer, did serve a copy of the Praecipe To Reinstate, by first class u.S. mail, postage prepaid, to
the party listed below, as follows:
Faith M. Lucchesi, Esquire
Pallo Lucchesi Law Offices, LLC
1368 South Atherton Street
smreCOllege,~~ /4
David A. Baric, Esquire
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SHERIFF'S RETURN - REGULAR
4
CASE NO: 2006-05291 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BEST ROOFING TECHNOLOGY INC
...
VS
TROLINGER TERRY M ET AL
TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
LEE UI UNG
the
OWNER
, at 1143:00 HOURS, on the 7th day of November, 2006
at 31 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055
by handing to
UI UNG LEE
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
So Answers:
18.00
8.80
.39
10.00
.00
37.19/
~ 1I/IIe/Oc.,
r~~
R. Thomas Kline
11/08/2006
OBRIEN BARIC
Sworn and Subscibed to By:
before me this day
of A.D.
SHERIFF'S RETURN - REGULAR
· ".A
CASE NO: 2006-05291 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BEST ROOFING TECHNOLOGY INC
VS
TROLINGER TERRY M ET AL
TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
LEE PYONG SUN
the
OWNER
, at 1143:00 HOURS, on the 7th day of November, 2006
at 31 OLD WILLOW MILL ROAD
MECHANICSBURG, PA 17055
by handing to
UI UNG LEE
ADULT IN CHARGE
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00/'
~ /lIntel,
~~~~
R. Thomas Kline
11/08/2006
OBRIEN BARIC SCHERER
-----
Sworn and Subscibed to By:
before me this day
of A.D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-05291 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BEST ROOFING TECHNOLOGY INC
VS
TROLINGER TERRY M ET AL
R. Thomas Kline
ISheriff or Deputy Sheriffl who being
duly sworn according to law1 saysl that he made a diligent search and
inquiry for the within named OWNER
LEE UI UNG
but was
unable to locate Him in his bailiwick. He therefore returns the
MECHANICS LIEN CLAIM
I NOT FOUND I as to
the within named OWNER
I LEE UI UNG
501 PARK HILLS DR
MECHANICSBURG, PA 17055
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
Sworn and
18.00
8.80
5.00
10.00
.39_/
42.19./
III 0-..1 01., C}-
Subscribed to before
County
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
Postage
OBRIEN BARIC SCHERER
09/27/2006
me this
day of
A.D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-05291 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BEST ROOFING TECHNOLOGY INC
VS
TROLINGER TERRY M ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named OWNER
LEE PYONG SUN
but was
unable to locate Her in his bailiwick. He therefore returns the
MECHANICS LIEN CLAIM
, NOT FOUND , as to
the within named OWNER
, LEE PYONG SUN
501 PARK HILLS DR
MECHANICSBURG, PA 17055
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
6.00
.00
5.00
10.00
.00
21. 00 V-
nl 0(.\ 01. +
Subscribed to before
County
OBRIEN BARIC SCHERER
09/27/2006
Sworn and
me this
day of
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-05291 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BEST ROOFING TECHNOLOGY INC
VS
TROLINGER TERRY M ET AL
WILLIAM CLINE
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
TROLINGER JERRY M
the
OWNER
, at 1924:00 HOURS, on the 25th day of September, 2006
at 170 YORK ROAD
CARLISLE, PA 17013
by handing to
JERRY TROLINGER
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
~
6.00
8.80
.00
10.00
.00
24.80 / 09/27/2006
l'/o~(olt OBRIEN BARIC
to By:
.~~~
R. Thomas Kline
SCHERER
day
~V~f
Deputy erlf
Sworn and Subscibed
before me this
of
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-05291 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BEST ROOFING TECHNOLOGY INC
VS
TROLINGER TERRY M ET AL
WILLIAM CLINE
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
VILLAGECRAFT FACTORY DIRECT INC
the
OWNER
, at 1924:00 HOURS, on the 25th day of September, 2006
at 170 YORK ROAD
CARLISLE, PA 17013
by handing to
JERRY TROLINGER,
ADULT IN CHARGE
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16 . 0 O~
/J/o~lo'
r~~'
R. Thomas Kline
c+
09/27/2005
OBRIEN BARIC SCHERER
Sworn and Subscibed to
By:
~v/'
/ Deputy Sheriff
before me this day
of
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-05291 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BEST ROOFING TECHNOLOGY INC
VS
TROLINGER TERRY M ET AL
WILLIAM CLINE
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM
was served upon
VILLAGECRAFT CONTRACT FURNISHINGS L P
the
OWNER
, at 1924:00 HOURS, on the 25th day of September, 2006
at 170 YORK ROAD
CARLISLE, PA 17013
by handing to
JERRY TROLINGER,
ADULT IN CHARGE
a true and attested copy of MECHANICS LIEN CLAIM
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.007
II/OG,{O&
So Answers:
.r'~~
R. Thomas Kline
~
09/27/2006
OBRIEN BARIC SCHERER
Sworn and Subscibed to
By:
4y~'
r eputy Sheriff
before me this
day
of
A.D.
.
II
BEST ROOFING TECHNOLOGY, INC.,
Plaintiff
v.
JERRY M. TROLINGER, UI UNG LEE,
PYONG SUN LEE, VILLAGECRAFT
CONTRACT FURNISHINGS, L.P,
VILLAGECRAFT FACTORY
DIRECT, INC.,
Defendants.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006- 5291 MLD
CIVIL ACTION-LA W
PRAECIPE TO SATISFY
TO THE PROTHONOTARY:
Kindly mark the claim entered against Jerry M. Trolinger, Defendant and Villagecraft
Factory Direct, Inc., Defendant in the above-captioned action filed on September 11, 2006 as
having been satisfied.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
David A. Baric, Esquire
J.D. # 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Plaintiff, Best Roofing
Technology, Inc.
...
il
-~t
!I
Ii
CERTIFICATE OF SERVICE
I hereby certify that on January 8, 2006, I, David A. Baric, Esquire of O'Brien, Baric &
Scherer, did serve a copy ofthe Praecipe To Satisfy, by first class U.S. mail, postage prepaid, to
the party listed below, as follows:
Faith M. Lucchesi, Esquire
Pallo Lucchesi Law Offices, LLC
1368 South Atherton Street
State College, Pennsylvania l680~ 4
David A. Baric, Esquire
..........
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