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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. ---:,~ -- Ii 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 -.-.-- 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: q / I ~ 6? I ( \ . " , I. -..... "\ " ".,::} ,j ,." l ~~~ ", --, 0<:\ ~. ~ ~~ ~~ ...--"\""- ., \., ~. 1 v-,. --....' \ ~, ~ , '\"> ....'( f C) ~" ~ ,::J .-1 -, l'il I .11 -~\, ::.~ . 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 n r--.:> c::::::l . _."'~.\. ~~~ (.: ~;-, .:oj"l c'" ,1 ,', 0 :::! r-T'-; C) -I t-' t a~ -0 Cl ,", c:....; :<. 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 (") ~;. o ( ) .--l 0" ~)l ::;1 r~l -- c.;) (.>.; 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 *' / -... 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 r--.) = c::::> er- a c-, --4 N o o -n --\ :C" m- r-- -am :.00 ~') , ~i(:' .,- -T; :.'),i ,.0 On'! _--i J> .J.::J -< -,:J 3: N .. N CD II . I -'~ 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 o c,-= ;~~; ~~~C, --:;J> I, <. ,....,., = = 0"" o C") -, N 0" o -r. -t :L..,., ril, ...,0"1 ~fJQ '=~.;}~~: >-~~ -(( ~;:~() Om ::r;! ~:J -< -0 ~ r;? N (.;1 ,,' 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. 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