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HomeMy WebLinkAbout95-04567 .' " " '" ,'. SADIQ ALIZADA and GITEE ALIZADA, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. JURY TRIAL DEMANDED OLD GUARD MUTUAL INSURANCE COMPANY, plaintiff v, COMPLl\INT 1, plaintiff, Old Guard Mutual Insurance Company, is a Pennsylvania insurance company with a principal place of business at 2929 Lititz pike, P.O. BoX 3010, Lancaster, Lancaster county, PA 17604. 2, Defendants Sadiq Alizada and Gitee Alizada are adult individuals residing at 1879 Douglas Drive, carlisle, cumberland county, Pennsylvania 17013. 3. On or about March 1, 1994, and at all other relevant times, Glenn A. and Jean W. Stambaugh were the owners of a residential rental property located at 816 Forbes Road, carlisle, Cumberland county, Pennsylvania 17013. 4. On or about March 1, 1994, and at all other relevant times, the aforesaid rental property was insured under a comprehensive landlord policy with plaintiff with the stambaughs as named insureds. A copy of the declaration sheet is attached hereto as Exhibit "A" and incorporated herein by reference. 5. On or about september 9, 1993, Defendants entered into a lease with Mr. and Mrs. stambaugh for the aforesaid rental property for the term of nine months, beginning on october 1, 1993, and ", ,', " .' ending on June 30, 1994, A copy of the aforesaid lease is attached hereto as Exhibit "B" and incorporated herein by reference. 6. On or about March 1, 1994, while occupying the aforesaid rental property, Defendants stored some oil-soaked rags on a wooden shelf in the garage of the rental property. 7, At approximately 9:00 p.m. on March 1, 1994, the oil- soaked rags ignited, causing fire to erupt in the garage and spread from the garage into the kitchen and other areas of the rental property. 8, As a result of the fire and associated hp.at and smoke, the rental property and its contents were considerably damaged and required repairs and restoration in the amount of $105,551,53, 9. As a result of the aforesaid fire and associated heat and smoke, Mr. and Mrs, Stambaugh sustained rental loss for eight months at $700 per month for a total of $5,600. 10. As a result of the aforesaid fire and associated heat. and smoke, Mr, and Mrs. Stambaugh sustained incidental damages, including,police security for the premises in the amount of $165, 11. As a result of the aforesaid fire and associated heat and smoke, Plaintiff made payment under the aforesaid insurance policy to the Stambaughs for the aforementioned damages in the amount of $111,116.53 (less a $200 deductible), and is subrogated to the loss sustained, -2- ", . ' " .' (d) Failing to keep the premises free of combustible, volatile, and/or flammable materials which are likely to become ignited; (e) causing or permitting an explosive concentration of combustible, volatile, and/or flammable vapors to accumulate on the premises; (f) Failing to properly control and/or contain combustible, volatile, and/or flammable materials in proper storage containers and/or facilities; (g) Failing to properly store combustible, volatile, and/or flammable materials in violation of 35 P.S, 51181, et seq" and 37 Pa. Code 511.1, et seq.; (h) Failing to properly store and/or dispose of combustible, volatile, and/or flammable materials in violation of local ordinances; (i) Failing to take proper and reasonable measures to extinguish the aforesaid fire; (j) Failing to keep the aforesaid fire from spreading from the garage to other portions of the aforesaid rental property; (k) Failing to warn Mr. and Mrs. stambaugh of the storage and/or use of combustible, volatile, and/or flammable materials in the rental property; (1) Failing to supervise and/or attend to storage of combustible, volatile, and/or flammable materials; and -4- (d) Failing to keep the premises free of combustible, volatile, and/or flammable materials which are likely to become ignited; (e) Causing or permitting an explosive concentration of combustible, volatile, and/or flammable vapors to accumulate on the premises; (f) Failing to properly control and/or contain combustible, VOlatile, and/or flammable materials in proper storage containers and/or facilities; (g) Failing to properly store combustible, VOlatile, and/or flammable materials in violation of 35 P.S, 51181, et ~., and 37 Pa. Code 511.1, et sea.; (h) Failing to properly store and/or dispose of combustible, volatile, and/or flammable materials in violation of local ordinances; (i) Failing to take proper and reasonable measures to extinguish the aforesaid fire; (j) Failing to keep the aforesaid fire from spreading from the garage to other portions of the aforesaid rental property; (k) Failing to warn Mr. and Mrs. stambaugh of the storage and/or use of combustible, volatile, and/or flammable materials in the rental property; (1) Failing to supervise and/or attend to storage of combustible, volatile, and/or flammable materials; and -7- ". . . . ' COUNT III OLD GUARD MUTUAL INSURANCE COMPANY v. SADIQ ALIZADA BREIICH OF LEIISE 24, Paragraphs 1 through 23 above are incorporated herein by reference, 25, Under the terms and conditions of the attached Lease, Defendant covenanted and agreed to use due care in the use of the leased premises. 26. Under the terms and conditions of the attached Lease, the Defendant agreed and covenanted to pay for all repairs to the leased premises which were necessitated by any lack of care on the part of the Defendant, 27. Under the terms and conditions of the attached Lease, the Defendant agreed and covenanted to keep and maintain the leased premises in as good repa~r and condition as was present when he initially leased the premises, and to surrender the leased premises in like repair and condition when he vacated the leased premises, -, 28. The Defendant took possession of the leased premises, as lessee, on or about October 1, 1993, and continued in possession until the building and its contents on the leased premises were damaged by fire, heat, and smoke on or about March 1, 1994. 29. Prior to the fire, and while the Lease was in full force and effect, Defendant carelessly, negligently and recklessly stored -9- ., , ' and/or used combustible, volatile, and/or flammable materials on the leased premises in a manner that would permit the materials to ignite as more specifically set forth above. 30, The carelessness, negligence and recklessness of Defendant as set forth herein was a breach of the attached Lease. 31. The aforesaid breach by Defendant resulted in the fire and resultant heat and smoke that damaged the building on the leased premises. 32, In addition, Defendant breached the lease agreement by failing to pay for all the repairs to the property which were necessitated by his ,lack of care as more specifically set forth above and failed to surrender the leased premises in like repair and condition as when it was initially leased to him, 33. As a direct and proximate result of the Defendant' s breaches of the lease agreement, Mr. and Mrs, stambaugh sustained the damages as more specifically set forth above. 34. As a direct and proximate result of the Defendant' s breaches of the lease agreement, Plaintiff made payment under the aforesaid insurance policy to the Stambaughs for the aforementioned damages in the amount of $111,116.53 (less a $200 deductible), and is subrogated to the loss sustained. WHEREFORE, Plaintiff, Old Guard Mutual Insurance company, demands judgment against Defendant Sadiq Alizada, individually and/or jointly and severally, in the amount of $111,116.53, -10- .', . ' .' 39. The Defendant took possession of the leased premises, as lessee, on or about October 1, 1993, and continued in possession until the building and its contents on the leased premises were damaged by fire, heat, and smoke on or about March 1, 1994. 40, Prior to the fire, and while the Lease was in full force and effect, Defendant carelessly, negligently and recklessly stored and/or used combustible, volatile, and/or flammable materials on the leased premises in a manner that would permit the materials to ignite as more specifically set forth above. 41. The carelessness, negligence and recklessness of Defendant as set forth herein was a breach of the attached Lease, 42, The aforesaid breach by Defendant resulted in the fire and resultant heat and smoke that damaged the building on the leased premises. 43. In addition, Defendant br.eached the lease agreement by failing to pay for all the repairs to the property which were necessitated by her lack of care as more specifically set forth above and failed to surrender the leased premises in like repair and condition as when it was initially leased to her, 44. As a direct and proximate result of the Defendant's breaches of the lease agreement, Mr. and Mrs. Stambaugh sustained the damages as more specifically set forth above. 45, As a direct and proximate result of the Defendant's breaches of the lease agreement, Plaintiff made payment under the aforesaid insurance policy to the Stambaughs for the aforementioned ~12- 11.1 . NAMED INSURED AND ADDRESS LANDLORD 'POLICY DECLARATIOI\IS POLICY NUMBER OLD GUARD MUTUAL INSURANCE COMPANY BP.D1459'3 D/B 2929 L1TITZ PIKE, P.O, BOX 3010 ***DUPLICATE*** LANCASTER. PA 17604 COMPREHENSIVE POLICY 0668 0000 GLENN A & JEAN W STAMBAUGH AGENCY Acordia of Central pa Inc 1171 CLAREMONT ROAD CARLISLE, PA 17013 401 E Louther St P.O. Box 116 Carlisle, PA 17013 PHONE I 717-249-2727 POLICY PERIOO: FROM 9/30/93 TO 9/30/94 BEGINNING ANO ENOING AT 12:01 AM, STANDARD TIME lOCATION OF DESIGNATED PREMISES - .. NAMED INSURED IS: I ND I V I DUAL BUSINESS OF NAMED INSURED: LESSOR IN CONSIDERATION OF THE PREMIUM. INSURANCE IS PROVIDED ON THE DESCRIBED PREMISES FOR THOSE BASIC COVERAGES FOR WHICH SPECIFIC LIMITS OF LlABltlTY ARE SHOWN. OR ARE OTHERWISE STATED AS INCLUDED: Att, SUBJECT TO THE PROVISIONS OF THIS POLICY INCtUDING ITS FORMS AND ENDORSEMENTS, lOC.l 816 FORBES ROAD CARLISLE, CUMBE~LAND CO PA LANDLORD OCCUPANCY ONE FAMILY lOC.2 lOC.3 I LOCATION 1 $ 112,000 $ NO COVERAGE $ 100,000 $ 10,000 $ 2,000 LIMITS OF LlABIUTY tOCATlON 2 LOCATION 3 . ';~'~~~f1,$1'i~~({6~':';~6~~~,~B~~~~ri~s';:~rf~~:;iU';it';fl;!5!~~ iHf.1/..!'BUI[OING! 04% ANNUAL'INFtAT.I.ON'Ft\CTOf\/t'i'nny,: tt;r~g:;~g~~.~~~J~;~~~~:~iJ'c~~~~;J0.';;;t"i\~1;i'f;?;:i!1;;lWJ;;;~,/' 'i:~t,D!MONEYAtiosECURmEsoN.PREMISESI,;"t:,f;,<'>'i:,.:'::, .' . i1;;Rl!M\~~\~'~?i,ffli~;~~~~...~t[';s~~~I~;I~;;{i,~,,:,j::;.::;.'...')W~!!!:{i Alt LOCATIONS AtL LOCATIONS WITH COVERAGE B ALL tOCATIONS WITH COVERAGE B LIMITS OF LlABIUTY 300,000 LIMIT PER OCCURRENCE 5 ,000 LIMIT PER PERSON 25 , 000 LIMIT PER ACCIDENT LOCATION 1 REPLACEMEKT COST NO COVERAGE $ NO COVERAGE NO COVERAGE SINCl IN COV D SINCl IN COV D lIMITED COVERAGE LOCATION 2 .. . . tOCAllON 3 . ;'i:8]l6'~sttD,m~TJ~N;''?8~~~ ~:~uIi.Di;;d",;;}1;;:'.:;~:;;r:k;;:{,i'.; iX(lOSS ~tiDJUSTMENT; COVi B: OUSINESS. PERSONAL.' PROPERTYi') ,;:",ACCOUNTS'RECEIVABLE',;::.,:",'./::i,,;.:.'i,.'.Ji'::' , '.':' , ,,"" ..', ' ,;'ii BURGlARY.'AND,' ROBBERY-COVERAGEi',O"", .'. .'.:.. -Ii, ....x;.E'x'; :')MONEYjtI/OSECIJRITIES ON PREMISES J.e: ,:'i " "/,,,:,j ,'<: MOI/EYMo SECIJRITlES OFF PREMISES,"',' :. ::'.:: ,'. '" ,,- ,ii;') OUTDOOR-IEXTERIORI'BUILDIND GLASS;,::':<;\j ~: .:;";~{~X\;; 7.1 FORMS AND ENDORSEMENTS OF THIS INSURANCE CONTRACT AT ISSUE DATE U0403-DEC SUPP CM810-PA MANDATORY BU0401-BP POLICY BUOS05-PREM LIMT MSO tOLf1:[BU0260-BUILD CDE/LA IB.I MORTGAGEE 19,1 PREMIUM (HINIHUM PREMIUH . NOHREFUHDAOLE . $50.) TOTAL ANNUAL PREMIUM - $259 ISSUE DATE 3/07/94 AIITlIORI7FD ~1r.NATlJRF. ~ -:Jr:"~ I , '~..,.j...~.'.~~ t.' . I ~~t~o'~.n...'"" . ; -"l~~~\i."/~ :,.'~~.,~ i 'I . ~..". ',"' ", . f,., ..,. ' .', , Bslween ' . I. . AndSndill ALizndn nnd Gine~ Aliz,!dn ~____"..____'_ _..__..,__- , 'herelnollel" whelher one or more; relerred 10 os "Ienonl", Jolnlly and seve.r!llly: ';',' I ..... '" ' ,', . I .' . "," '.' " WITNESSETH: Thol Londlord h~roby I~oseo 10 Tenonl and Ihe loller Ie to hom ~he.l~rmo'.lho propor,Iy loco led '0 . '. . ..,.. 816 Forbes Road, Carlisle, PA 17013 , I he prY~entlal~ :..t~1~f!:-,/':'.\:;:."" : Stewart Rf!81 Estate 111~ ~ 4 r- ~ 3 q.3 ' , LEAse, -----; " , s\\( S~t~.t Sepnember __.__, " ".' .... ," , .. :::, '" ,,' ." " , ' ' " ,""." ' , ' , ", :,: ,,' :' '.' , "'~,', ,,: , , . '..:"'-. 93 19_.., This leaso mode Ihls' 9 nIl doy 01_ Glenn A, & Jenn W. snnmbnugh Ihe Londlortl. --- , al lor Iho lerm 01 9 monbhs beginning ol1lho I an doy'of October 93 ,19 ___,. day 01 and ending on Ihe '30nh June ~,19!~.." Dollars ($ 6,300.00 _..I eltherenlol six thousnnd nhree hundred no cents per year payable In monlhly Inslollmenl~ 01 Seven hundred no cenbs Dollars 'S 700.00 I eoch on Iho' he doyo! each monlh In advance. Tenonl agrees 10 pay 0 lale paymenl , ~hargo 015% percenl psr month 01 Ihe a~ounl of renlln deloullllvo days oller due dole. This lelllng Is upon Ihe . !ollowlnQ conditions, covenonls and agresmenls: ~A ' , , (,Ij',/i onl v I. Use 01 Premises: Tononl agrees 10 use Ihe properly only 09 r"s i don".....:- ff p"npl e IInd nollo assign Ihlli leaso or sublol Ihe properly, or carryon ony unlowlul business. . . Tenonl ogrees nol 10 alter"or make addlllons 10 tho proporty wllhoul Owner or A'genl's permission. Tenonl agrees 10 use due coro In use 01 Ihe properly, Ihe appliances Ihereln, and olt olhsr parts 01 Owner'o properly, 10 give nollce to Owner or Agenl II Ihe neod lor repair Ihereol end 10 pay lor all repairs ". 10 Ihe propcrly which ero neccssltsled by any lock 01 core on ths pari 01 Ihe Tenanl. Owner or Agenl will makc neccssory repolrs 10 Ihs properly and oppllonccs thcreln In a rcosonoble lime allerTenant nollllos Owncr or Agenl ollhe need 01 repairs. The said properly Is 10 be kept and molntnlned In os gnorl rel'Rlr ond condlllon os 01 presenl and lit cxplrallon 01 this leose, Ihey ere 10 be surienilered In like repaIr Bnd condition, naturol wear and dameges happening by IIro, slorm or olhor casual lies 9nly excepled. 2. Ownsr's or Agenl's L1eblllty: Tenenl agrees ihol Owner or Agenl shell nol be liable lor properly domage or personal Inlury occurring ,on the properly unloes the domage or Injury resulls directly hom Owner's or Agenl's negligence. Electric ond Plumbing: (a) Overloading eleclrlcal syslem shall nol bs permllled, Any damoge 10 eleclrlcal syslem caused by overloodlng shall bo repaired allenonl's expense.\b) Plumbing leaks"and adluslmenls will be laken care of and paid lor,by lhe Owner excepllng clogged plumbing which shall be corrected at Ihe lenonl's expsnse. (c) Owner will correcl ond poy lor allhelr expense any 'allurs or dslect Inherent In appllences IIselllncludlng parle. Tenonls sholl be responsible lor ony repairs, 01 any oppllonce lallure caused by overloading or abuse. (d) In Ihe evenl of power loss, low voltage or lallure 01 eny mechonlcal, or oppllance or plumbing overllow which moy rssultln loss ollood In sloroge or ony other Iypo of porsonol ' losses as 0 result 01 such lallure, Owner or Agent shall be held hormless, legally or olhorwlse lor such oc. ' CUllonces, during the enUre term 01 this leoso ond lis renew!!' porlods II any. ' , , 3. Owner's RighI 01 Enlry: Owner or Agenl, or any person outhorlzed by him, wllh the prior speclllo consent 01 , Tenonl, which consenl shall not be unrensonably wllhhold, sholl have tho rlghllo enler,lhe properly 01 , , ,:rooBcnoblc IImcslo Inspecl, moke repairs or ollerollons os noeded,to enforce lhls loaso, ond alter nollco .. ,,01 lermlnollon Is glvon, to show Iho properly 10 prospectlvo 10no~Is: provldod, however,lhot Tononls ccn. ,,' I~ ' ... ,,' sonl eholl not bo necessory In cose of emorgency. ' ',';, ~h;" .1 'I:,,: ".\"N !;';i.ll,)W:\{;';il.'i~Ul~:~~~ " .. ,j ,....'.~ . ... .... ;:-. .~ .,. ' , . . ..-..... .",' .. " "I , .. .. ,.,.,. UlIlltloa: Garbage romovol, waler and aewer, electrlo, neo, 011, or any clher sarvlco lor Ihe use ollhe lenont 0 I Ihe properly furnlshod by any Public Sorvlce Company durlno Iho sold ,",erm shall bo paid for by Iho lenonl unloss olherwlso provided horoln.ln ooso dllollur"o 10 pay utllltloolho Ownsr or Agonl may collocl as ronl duo and In arrears clou~lo Iho cool. . , . F~rolioaranco . lole Paymants: Accoptanoo by Iho Owner or Agonl 01 any ollho ssld renl 01 any time oller Iho somo shall become due, oller delaull has been made In the paymenllhereol. or any lallure 10 enlorce eny ollhe rlghls herein reservod 10 the Owner or Agenl, or any of Iho pimallles, lorlellur!! or condlllons hereIn oontalned, shall nolln any wIse be consIdered a waiver ollho rig hI 10 enlorce Iho same at any IIms " wllhoul any nollce whatSoever and aoy ollemptlo colleollhe renl ~y:one proceeding sholl nol be con. . . sldere~ os a waIver 01 Ihe rlghllo collectlhe earn!! by anI' olher p~oc~ ~dl:1li, bul all 01 ;;id rlghls ollne Owner or Agenl, and all lorlellureo, penallles and conditions may be enlorced logelher or successIvely 01 . Ihe opllon 'ollhe Ownar or Agonl, Ills lurlher agread Ihatlllhe lenanl shall become Insolvenl, make an llsslgnmenl lor Ihe bene III at credltore, commit any acl 01 bankruptcy, IIle a volunlary pellllon In bankruptcy, or II any ludgemenl shall be enlered or an Invclunlary pollllon In bankruptcy lIIed agalnsllhe , lenant, all renl reservod lor Ihe lulllarm 01 Ihls lanse ehall become duo and colleclable Imm.edlalely by dlslress or olhorwlse. ConIes sian 01 Judgomenl: Upon broach 01 any 01 Iho covenonts or agreemenls ollhls leaso or upon Its ler. mlnallon by lorlellure, delaull or explrallon, Iho prothonolary or any Allor~oy os aloresald Is hereby aulhorlzed Ic appear lor and 10 c6nfess ludgmonlln an amicable acllon 01 oJeclmenl against Ihe sold Te. nanl and In lavor of the Own or or Agenllor Iho promises herein described and 10 dlreclthe Immedlole Is. suing or a wrll of havero loclns possssslonom wllh clouse of lIerl loci os lor cosIo, waIving all Ir., regularllles, wllhoul nollce and wlthoul askIng leavo 01 courl. Nol1C8 10 Cull: Waiver: Ten:ml here~y wolves the Notice to Cult requlremonts ollho Ponnsylvonla Lsndlord and Tenanl Act 011951 as amended 68 P.S. 250.101 el. seq. whIch provides lor 1I1100n (15), Ihlrly (301. or nlnely (90) dsy nollce 10 ,quit In certain clrcumslances. In lien Ihereol, In tho event lenanl lolls 10 pay Ihe renl when due, or breaches any olhor lorms or conditions ollhlslease, Owner or Agonl shall be required III glva lenanl only live 15) days wllhln nollce prior to commonclng logol action agalnslthe lenon\. The Inollce shall bo sorved by any ollhe lollowlng means: By nolllylng Iho resldenlln porson, by delivering a copy ollho nollce by cerllllod or reglslered moll, or by posllng sold ne,lIce on Ihe proporly. 10. . Pictures or olher ob/ecls !'lilY be hung pr(l'!!d,d henG!ng Is o-;ccmilllsj,l.J,by m~&i'lf. iiI ~nlli" lYllu ,:.iciure '. hangers. ' Owner or Agenl does nol represenllhe basemsnllo be habitable nor do thoy accepl any responslblllly lor waler or mildew damllga In Ihs basemsnt. . It Is the lanonls responsibility to keep Iho sidewalks clear 01 011 dobrls Including snow o'nd the lenont will provide lor grass 10 bo cuI on Ihe premises, ' , ,:.. ' . Should landlord permll an:l11als 10 be kepI by lononlll shall be underslood Ihsllandlord reserves Ihe right to require tenanl's 10 havo onlmols removsd from properly or lenonls 10 vocato promises II noise, dlslur. bance, or uncleanliness rasulls from keeping sold pelo, or II odjolnlng lonanl's complain 01 such condl. lions. NO PETS ALL'JIlED. The Torm "Tonanl": Tho lerm lenanl used heroIn shall reler collecllvely \0 all porsons namsd above, and sIgning Ihls lease os lenanl, omlthc lIoblllly 01 eoch such pm son sholl be Jolnl and Geveral. Nollce glvan by Owner or Agnnllo any person named os lenant or ony such person to Ownor or Agenl shall bind all per. sons Signing Ihls loass as 0 lononl. , ., . ' , " . , . ..i':' . '.. ,;'.., , ~'.. ,;-.'.~., ,'" .. .. ,,_ . ~- .~,: ,\. ';-. .':. :', ' ,.:',:; t,':..~:-.:.. 15. . NO "ATERUEUS IJElUIITTED. :';;~, ...'.k .' tl . ""'~';.;':-"~":"\" "~ . .... /-'1. ~..:,;. '" ....:.:.a. .'> j'~; ....,.~. ~t::~ .,,~ n';.; ...:..t.:~~.. . ',:,.. ." .,t;;.: '._; ~.','. ,.;':I"'f .I......lJ:; ;'i: ~~-~'i::.':'.\. ;~'~.~ .~.~ :~;"~i:;-~"'~~'_ .' . \.... '", -'.:!> ".", !..' t.?':,', '.. . >'::.~,j .t. . ~'.:. -..... " :.....i;.~.L..~:,. ,J 6 :,~.;.;: NO r~'~KIHG '.; 1.0" "11' ~'D"":l'IH~"!1'III'~J~t.:;~~!~::_(h~;I,.~~~:i'r~::~~I2-/;....,..:Q!'.~~.:rf..-:1,{~~.,~~. ',-:\.'. '~'/' . ":'}.-;-' ',;h(,~~~~~. ";,;"', :.~ ,,~., .:. , ".~"", ..-u...... I ~"" .........'..'1r...~'I~..~'~. '.. ".~j-" ',...'. (~..t ...'",,~ . '.' "'.-"; ~,~,:.~;~~t1JtJi:~~j.\jt;!i~t~~',:; ..i~t\;o?,iI\X~'t(,'\.lar.':.w,;fi"~:~ ~n~, ~~'I~/r.'~'I~~V~'llc.I" ,~.If ,'1,":-." i, ,.\\ ,1 ~ I . ... " I ',' 'cr,I". ;" .' ''\ ,~c! / SHERIFF'S RETURN - REGULAR CASE NO; 1995-04567 P COMMONWEALTH OF PENNSYLVANIA; COUNTY OF CUMBERLAND OLD GAURD MUTUAL INS CO VS, ALIZADA SADIQ ET AL MICHAEL BARRICK CUMBERLAND Ccunty, Pennsylvania, who to law, says, the within COMPLAINT & upon ALIZADA SADIQ defendant, at 956;00 HOURS, on the 31st day of Aucust 1995 at 1879 DOUGLAS DRIVE CARLISLE, PA 17013 , Sheriff or Deputy Sheriff of being duly sworn acccrding NOTICE was served the County, Pennsylvania, by SADIQ ALIZADA a true and attested copy of the COMPLAINT & NOTICE and at the same time directing Her attention to the contents thereof. ,CUMBERLAND handing to GITEE ALIZADA WIFE OF Sheriff's Costs; Docketing Service Affidavit Surcharge 18.00 2.80 .00 2.00 $22.80 I, lit) ~) D .1'0 So answers; . ~ _.'(1I"";"/..P'- , .,. -t:,rt"../."-:_".,." .- ., ~."....-"'" ......... R. lhomas K11ne, Sheriff CLARK DEVERE u:t? 08/31/1995 ~ by -:;1f%.A? .. epu y er1ff Sworn snd subscribed hO before me this J.1..-l day of ~r::;., I... . 19 Q~ A.D. q~ ~.o~~(a'rY~ .