HomeMy WebLinkAbout01-5338ENGLEHART TRUCKING, INC.,
Plaintifl;
1-81 CARLISLE FUEL STOP, INC.,
Defendant.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: MECHANIC'S LIEN
ENGLEHART TRUCKING, INC.'S
MECHANIC'S LIEN CLAIM AGAINST 1-81 CARLISLE FUEL STOP, INC.
1. The claimant is Englehart Trucking, Inc., ("Englehart") with an address of 515
Iron Mine Road, Middletown, PA, 17057.
2. Pursuant to 49 P.S. § 1201(4), Englehart files its mechanic's lien claim as a
contractor in this case.
3. The owner of the property subject to this mechanic's lien claim is I-81 Carlisle
Fuel Stop, Inc., ("Carlisle Fuel").
4. I-81 Carlisle Fuel Stop, Inc., is a Pennsylvania corporation with its principal place
of business located at 1550 Harrisburg Pike, Carlisle, PA, 17013.
5. Carlisle Fuel entered into an agreement with Englehart wherein Carlisle Fuel
agreed to pay for hauling services provided by Englehart. Englehart provided invoices for
services rendered to Carlisle Fuel which invoices were signed as accepted by Carlisle Fuel.
6. The property subject to this lien ("building site") is described as follows:
ALL THAT CERTAIN parcel of real estate in the Township of Middlesex,
County of Cumberland and State of ?ennsylvania, to-wit:
BEGINNING at an iron pin on the southern right of way line of the Carlisle
Pike (U.S. Route #11) (L.R. #34), said point being located and referenced 70
feet in a southerly direction at right angles to Pennsylvania Department of
Transportation center line Highway Station 234+45.54; thence South 4 degrees
54 minutes 27 seconds West, a distance of 422.40 feet to an iron pin; thence
North 85 degrees 05 minutes 33 seconds West, a distance of 118.79 feet to an
iron pin in line of lands now or late of C. F. Bucher; thence North 9 degrees 55
minutes West, a distance of 437.10 feet to a point on the southern right of way
line of the Carlisle Pike (U.S. Route #I 1) (L.R. #34); thence along the southerly
right of way line of the Carlisle Pike (U.S. Route #1 l) (L.R. #34), by a curve to
the left having a radius of 11,529.19 feet, an arc distance of 60.03 feet to a
point; thence continuing along the southerly right of way line of the Carlisle
Pike (U.S. Route #I I) (L.R. #34), South 85 degrees 05 minutes 33 seconds
East, a distance of 170.54 feet to the place of BEGINNING. BEING the same,
more or less, but subject to all legal highways.
BEING the same premises which Dennis D. Willey, by Deed dated 1/8/99 and
recorded in Cumberland County Deed Book 192, page 620, granted and
conveyed unto 1-81 CarlisIe Fuel Stop, Inc.
7. Englehart provided services to Carlisle Fuel on the following dates: May 25, 2001;
May 31, 2001; June 7, 2001; June 8, 2001; June 9, 2001; and, June 10, 2001. The value of these
services provided is $4,378.50.
provided.
To date, Carlisle Fuel has failed and refused to pay Englehart for the services
9. Representatives of Carlisle Fuel directed Englehart to perform hauling services for
Carlisle Fuel.
Date:
Respectfully submitted,
'BRIEN, BARIC i SCH
David A. Baric, Esquire
ID # 44853
17 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiffs
VERIFICATION
I verify that the statements made in the foregoing Englehart Trucking, Inc.'s Mechanics
Lien Claim Against 1-81 Carlisle Fuel Stop, Inc. are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
ENGLEHART TRUCKING, INC.
dave/litigation/Englehar[ truck ing/mechanics, corn
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-05338 p
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ENGLEHART TRUCKING INC
VS
1-81 CARLISLE FUEL STOP INC
JASON VIORAL , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within MECHANICS LIEN CLAIM was served upon
1-81 CARLISLE FUEL STOP INC
the
OWNER
, at 1550:00 HOURS,
at 1550 HARRISBURG PIKE
CARLISLE, PA 17013
on the 14th day of .September, 2001
by handing to
ARSH GREWAL MANAGER
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 18.00
Service 3.25
Affidavit .00
Surcharge 10.00
.00
31.25
Sworn and Subscribed to before
me this _ /~ ~ day of
~ ~2~;! A.D.
' /Prothonotary" /--!
So Answers:
R. Thomas Kline
09/17/2001
OBRIEN BARIC & SCHERER
eput~/ s~rif~
ENGLEHART TRUCKING, INC.,
Plaintiff
1-81 CARLISLE FUEL STOP, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01 - 5338
MECHANICS LIEN
PRELIMINARY OBJECTIONS
Defendant, 1-81 Carlisle Fuel Stop, Inc., by its attorneys, Broujos & Giiroy, P.C., sets forth
the following preliminary objections:
1
Pursuant to 49 P.S. §1505, Defendant 1-81 Carlisle Fuel Stop, Inc. files herein preliminary
objections to the entry of a mechanics lien in the above captioned matter.
2
Plaintiff has failed to conform with the Mechanics Lien Law of 1963, 49 P.S. §1101, et seq.
for the following reasons:
A. The type of work performed by Plaintiff was not incidental to the "erection,
construction, alteration or repair" as those terms are defined at 49 P.S. §1201
and, therefore, Plaintiff cannot impose a mechanics lien against the
mentioned real estate for the work Plaintiff performed.
B. Plaintiff did not have any contractual arrangement with the Defendant.
Plaintiff was a sub-contractor with respect to all work done at Defendant's
property. In its status as a sub-contractor and assuming for purposes of this
sub-paragraph that the work Plaintiff performed is appropriately the subject
of the entry of a mechanics lien, Plaintiff is in violation of 49 P.S. §1501(A)
and 49 P.S. §1501(B) based upon Plaintiffs' failure to provide preliminary
notice on or before the date of completion of its work or the thirty day notice
prior to filing this lien. Plaintiff never provided invoices for services
rendered to Defendant. Plaintiff did provide what appeared to be
acknowledgments of the time Plaintiff started work at Defendant's property
and the time Plaintiff ended work at the Defendant's property and a
representative of Defendant did merely sign those documents to acknowledge
Plaintiff was at the property for the stated time. Said documents did not
contain any stated price or any terms of a contractual relationship.
WHEREFORE, Defendant requests your Honorable Court to dismiss the mechanics lien
entered in the above referenced matter and to mark said lien as strickened.
Respectfully submitted,
(717) 243-4574
Supreme Court ID No. 29943
STATE OF PENNSYLVANIA, I
COUNTY OF CUMBERLANDt ss.
Robert P Ziegler
I, .............................................................................. Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ................
Veterans Affairs Secretary
.................................................................................... is the grantee
6th
the same having been sold to said grantee on the ............................................... day of
March
A D ~1~ 2002 , under and by virtue of a writ ..............
execution i -- the 12th
................................................ S~U~ on .....................................
day ot .... _D_e_c__e?_b_e_r_ ............ A.D., ~_x_2_0__0~ out ot the Court o~ Comman Pleas of said County as o~
civil
.................................................................................. Ter~,
Number _ __ _5_3_5_8_ ...... , at the suit of __F_ _i_r_s_t_ _ _U_n_i_o_ _n__N_a_t_ !__~_k_,__7_~__f_9_r__P___a__H_o_u_9).n_~_fAn___A_ae_n_~y__
Susan M Hoetger
................................... against .................................................... is
250 4725
duly recordedlnSherifCsDeedBookNo ............. , Page .............
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this _~_2_-.-~____ day
First Union National Bank, Trustee for
Pennsylvania Housing Finance Agency
VS
Susan M. Hoetger
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states
that on December 18, 2001 at 8:49 o'clock pm, EST, he served a tree copy of the within
Real Estate Writ, Notice and Description, in the above entitled action, upon the within
named defendant, to wit: Susan M. Hoetger, by making known unto Susan Hoetger
personally, at 414 North Pitt Street, Carlisle, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said tree and correct copy of
the same.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on January 07, 2002 at 4:22 o'clock P.M., E.S.T., he posted a true copy of the within
Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Susan M. Hoetger located at 414 North Pitt Street, Carlisle, Pennsylvania,
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Susan M. Hoetger, by regular mail to her last known address of 414
North Pitt Street, Carlisle, PA 17013. This letter was mailed under the date of January
23, 2002 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the
sum of $1.00 to Attorney Leon P. Haller for The Secretary of Veterans Affairs of
Washington, D.C., his successors and/or assigns. It being highest bid and best price
received for the same The Secretary of Veterans Affairs of Washington, D.C., his
successors and/or assigns of Wissahickon Avenue and Manheim Street, P.O. Box 8079,
Philadelphia, PA 19101, being the buyer in this execution paid Sheriff R. Thomas Kline
the sum of $712.40, it being costs.
Sheriff's Costs:
Docketing 30.00
Poundage 13.97
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 6.50
FIRST UNION NATIONAL BANK,
TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
SUSAN M. HOETGER,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
: NO. 2001 53~8
: IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug &Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 414 NORTH PITT STREET, CARLISLE,
PENNSYVLANIA 17013:
1. Name and address of the Owner(s) or Reputed Owner(s) :
Susan M. Hoetger
414 North Pitt Street
Carlisle, PA 17013
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every jud~LLent creditor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW):
5. Name and address of every other person who has any record
lien on the property:
UNKNOWN
~. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
UNKNOWN
7. Name and address of every other person of whom the
FIRST UNION NATIONAL B/LNK,
TRUSTEE FOR PENNSYLVANIA
HOUSING FINANCE AGENCY,
PLAINTIFF
VS.
SUSAN M. HOETGER,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERL~uND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
: NO. 2001 5358
:
: IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE:
TIME:
LOCATION:
WEDNESDAY, MARCH 6, 2002
10:00 O'clock A.M.
Commissioner's Hearing Room
2nd Ploor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
414 NORTH PITT STREET
CARLISLE
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 2001 5358
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
SUSAN M. HOETGER
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
~heriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE ~LD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
autached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL THAT CERTAIN tract of land, together With the improvements thereon erected, situate
in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded
and described as follows:
ON the North by lands formerly of Ida E. Gelsinger and now or formerly of George Link;
on the East by 60-feet wide North Pitt Street; on the South by lands formerly of Guy Boyd
and later Velva S. Lamason and now or formerly of Norman Chronister; and on the West
by an alley.
THE ABOVE described tract of land contains 24 feet in front along the western line of 60-
feet wide North Pitt Street and extends westwardly therefrom at an even width a distance
of 160 feet, more or less, to the alley aforesaid, and has thereon erected a 2 112 story
frame dwelling house and other improvements. BEING known as 414 North Pitt Street,
CaHisle, Pennsylvania, 17013.
BEING THE SAME PREMISES WHICH Dennis L. Husler and Consolacion
Husler by deed dated 10/27/97 and recorded in Cumberland County
Deed book 166 Page 931 granted and conveyed unto Susan M. Hoetger.
TO BE SOLD AS THE PROPERTY OF SUSAig M. HOETGER ON JUDGMENT
NO. 2001 5358.
PARCEL: 06-02-1798-267
WRIT OF EXECU'I:ION and/or ATrACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF ~.-Land
To satisfy the debt, interest and costs due
Housinq Finance Agency
from
NO, ~ ClVIL~ Term
CIVIL ACTION - LAW
COUNTY:
First Union National Bank trustee for Pennsylvania
PLAINTIFF(S)
Susan M. Hoetger: 414 North Pitt Street, Carlisle, PA 17013
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
** See attached legal description
(2) You are also directed to attach the property of the defendant(s) not levied upon in lhe possession of __
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any properly 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 lhe 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 $73,524.26
at $12.70 per diem to 3-6-02
Interest $].q~,R_ 5{'1
Atty's Comm %
Atty Paid $103.25
Plaintiff Paid
L.L. ¢.50
Due Pmthy $1.00
f~herCosts Late cbmrqes at $17.88 per month
t~ $~ d~t~ $71.52
Escrow Deficit $2,000.00
Date: December 12, 2001
REQUESTING PARTY:
Name Leon P. Haller, Esquire
Address: 1719 North Front Street
Harrisburg, PA 17102
A~orney for: Plaintiff
Telephone: (717) 234-4178
Supreme Court ID No. 15700
Curtis R. Long,
by:
,~Prothonetary, Civil Division
REAL ESTATE SALE No. ~o
On December 13, 2001, the sheriff levied upon the
defendant's interest in the real property situated in
Carlisle Borough, Cumberland County, PA,
known and numbered as 414 North Pitt Street, Carlisle
and more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: December 13, 2001 By:
eal E§tate Deputy
THE PATRIOT NEWS
THESUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County cf Dauphin} ss
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
P ri - newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and
12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION .................................................................................
COPY Sworn to and su d d~/of F/~uary 2002 A.D.
,6o I
' Tiny L. Ru~tdl, Notary Pul~c
I ~m,,burg, Oau~n ~ / N(~q-ARY PUBLIC
I :~,y commission expires June 6, 2002
Member, Pennaytvania Assoctati~n
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND ~NTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
Total
$ 211.20
$ 1.50
$ 212.70
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The ~pnday Patriot-News. newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
:
COUNTY OF CUMBERLAND :
SS.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JANUARY 25, FEBRUARY 1, 8, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are tree.
~ ESTATE 83,w.~ NO. 60
Writ No. 2001-5358 Civil
First Union National Bank,
Trustee for Pennsylvania Housing
Finance Agency
VS.
Susan M. Hoetger
Atty.: Leon P. Hailer
ALL THAT CERTAIN tract of land,
together with the improvements
thereon erected, situate in the Fifth
Ward of the Borough of Carlisle.
Cumberland County. Pennsylvania,
bounded and described as follows:
ON the North by lands formerly
of Ida E. Gelsinger and now or for-
merly of George Link; on the East
by 60-feet wide North Pitt Street;
on the South by lands formerly of
Guy Boyd and later Velva S.
Lamason and now or formerly of
lUarman Chmuiater: and on the West
SWORN TO AND SUBSCRIBED before me this
8 day of FEBRUARY, 2002
ENGLEHART TRUCKING, INC.,
Plaintiff,
1-81 CARLISLE FUEL STOP, INC.,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 01-5338
:
: MECHANIC'S LIEN
PRAECIPE TO SATISFY
TO THE PROTHONOTARY:
Kindly mark the judgmem entered in the above-captioned action on September 12, 2001,
as having been satisfied..
Date: August //~ ,2002
Respectfully submitted,
David A. Badc, Esquire
ENGLEHART TRUCKING, INC.,
Plaintiff,
1-81 CARLISLE FUEL STOP, INC.,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 01-5338
:
: MECHANIC'S LIEN
:
CERTIFICATE OF SERVICE
I hereby certify that on August ]~' ,2002, I, David A. Baric, Esquire of O'Brien,
Baric & Scherer, did serve a copy of the PRAECIPE TO SATISFY by first class U.S. mail,
postage prepaid, to the party listed below, as follows:
Hubert X. Gilroy, Esquire
Broujos & Gilroy
Four North Hanover Street
Carlisle, Pennsylvania 17013
David A. Baric, Esquire
dave/litigation/Englehart.tmcking/satisfacti°n'pra