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Home My WebLink About00-05119 -~ ~ ~._~ "" IN THE COURT OF COMMON OF COMMON PLEAS OF CUMBERLMAN COUNTY, PA, CIVIL DIVISION COPELCO CAPITAL, INC. Plaintiff v, NOTICE OF JUDGMENT COOPER & HOLLAND INC d/b/a SGT. YORK'S &SGT, YORK' Defendants NO.00-SI19 , ~ ~-;~~ GOl [~ Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $8,380,06 on ,,1..(- 1 y ::lOt ;1000 A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed, Ie; cZ"'1~~~.~ I Prothonotary/Clef.!:: () () ~~~ P J r ryCWJ<"Clr:-4<u If you have any questions regarding this matter, please contact the filing party: Name: Joann Needleman, Esquire Address: Suite 935, One Penn Center at Suburban Station 1617 J,F,K. Boulevard Philadelphia, PA 19103 Telephone No,: 215-665-1133 (This Notice is given in accordance with Pa,R.C,P, ~236) , , - NEEDLEMAN & NEEDLEMAN, P,C, BY: Joann Needleman, Esquire Attorney for Plaintiff Identification No, 74276 Suite 935 One Penn Center at Suburban Station Building 1617 John F, Kennedy Boulevard Philadelphia PA 19103 (215) 665-1133 COPELCO CAPITAL, INC, Plaintiff v, CUMBERLAND COUNTY COURT OF COMMON PEAS COOPER & HOLLAND INC d/b/a SGT, YORK'S & SGT, YORK' Defendants NO, PRAECIPE TO THE PROTHONOTARY: Enter judgment against the Defendants in the amount of $8.380,06. in accordance with the attached Certified Exemplified Judgment of Docket No, DC 6753-99 of the Superior Court ofthe State of New Jersey and index said judgment against the Defendants, NEEDLEMAN & NEEDLEMAN, P.C. BY: DLEMAN. ESQUIRE or Plaintiff -"'~ ---~. ~~ -.....- NEEDLEMAN & NEEDLEMAN, P.C, BY: Joann Needleman, Esquire Attorney for Plaintiff Identification No. 74276 Suite 935 One Penn Center at Suburban Station Building 1617 John F, Kennedy Boulevard Philadelphia PA 19103 (215) 665-1133 COPELCO CAPITAL, INC, Plaintiff v. CUMBERLAND COUNTY COURT OF COMMON PEAS COOPER & HOLLAND INC d/b/a SGT, YORK'S & SGT, YORK' Defendants NO, AFFIDA VIT COMMONWEALTH OF PENNSYLVANIA SS, COUNTY OF PHILADELPHIA JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she is the attorney for the Plaintiff, Copelco Capital, Inc,; that she is authorized to make this Affidavit on its behalf; the address of Plaintiff is One International Blvd, Mahwah, NJ 07340; and to the best of her knowledge. the last known address of Defendant is 402 Market Street. Lemoyne. PA 17043 and that the iudl!ment reflected by Docket No, DC 6753- 99, Superior Court of New Jersey, is valid, enforceable and unsatisfied, These statements are made subject to the penalties of 18 Pa,C,S.A, Section 4904 relating to unsworn falsification to authorities, SWORN TO AND SUBSCRIBED before me this /8' day of Apri I '7 NOi{~1i.t , ,.,. ,?u::iic , Qlty ,/ PI1iIad~llla". ,::a GOUll~L-l ~IllftU\llreaM8tCh~" DLEMAN, ESQUIRE Plaintiff " ~~~'iR_ ~#;_~'''~~~...' "-'r _..J - "~ -~"-- ~( ~. ~~ "~~~@,i NEEDLEMAN & NEEDLEMAN. P,C, BY: Joann Needleman, Esquire Attorney for Plaintiff Identification No, 74276 Suite 935 One Penn Center at Suburban Station Building 1617 John F, Kennedy Boulevard Philadelphia PA 19103 (215) 665-1133 COPELCO CAPITAL, INC, Plaintiff v, CUMBERLAN COUNTY COURT OF COMMON PEAS COOPER & HOLLAND INC d/b/a SGT, YORK'S & SGT, YORK' Defendants NO, CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: The address of the Plaintiff, judgment creditor, is One International Blvd, Mahwah, NJ 073401, and the last known address of the Defendants is 402 Market Street, Lemoyne, PA, NEEDLEMAN & NEEDLEMAN, P.C. BY EEDLEMAN ...... ~~ "'M~' , ' .,.. - 0\. ,~ SUPERIOR COURT OF NEW JERSEY BERGEN COUNTY LAW DIVISION sPECIAL CIVIL PART CIVIL ACTION EXEMPLIFIED JUDGMENT Copelco Capital, Inc. Plaintiff(s) vs, Cooper & Holland. Inc. d/b/a Sgt York's and Sgt York's Defendant(s) DOCKET NUMBER: DC 6753-99 I, Angelo J. Cataldo, Clerk ofthe Superior Court, do hereby certify that on the 1st day of October in the year of 1999, judgment was rendered in the said Court in favor of Copelco Capital. Inc. and against Cooper & Holland, Inc. d/b/a Sgt York's and Sgt York's for the sum of Eight Thousand One Hundred Fifty Four DOLLARS and Ninety Six and Ten cents debt, and Two Hundred Twenty Five DOLLARS cents cost of suit, and No executions has been issued thereon and returned to court at a cost of $ None The name ofthe plaintiffs attorney is: Uscher Quiat Uscher and Russo 401 Hackensack Ave.. Hackensack. NJ 07601 ,~e;~'J~-!?~Jj,", ~V.,$!f '>,""'<'." J.. AX,(,f~~:f0~}'~~~'I'~' (~,~.. t: 'i -~.'/y UtH'~ ""~:J, l~j64, fi' --" ',' ":':-:\0 e.J\'.::.:~ Uij."lU )[''j~,:) t'~~.~",\\ OQU CfJ \""')\, ,4'J,,'" ",,-,,':} ~',~;Ef{~;'Y:\;:")~~ ~"'"' "'-"~U;;';(",'~"--'~ ",'-l I../JiL eN\'." In Witness Whereof, I have hereto affixed my hand as the Clerk of said Court and the Seal of said Court, as provided by Law, this 17th day of March A,D,,2000, ~ ~ovUo-v< ANGELO 1. AT 0, CLERK OF THE CdlURT ~""""'". "',,,, , ' ." ,.. 4^ ,~. . SUPERIOR COURT OF NEW JERSEY LA W DIVISION - SPECIAL CIVIL PART BERGEN COUNTY I, Donald W, DeCordova , Supervising Judge of the Superior Court of New Jersey, Special Civil Part, Law Division, Bergen County, certify that said Superior Court, Special Civil Part is a Court of Record, having a Clerk and a seal; that the seal hereto affixed is the proper seal ofthe said court; that Angelo J. Cataldo, who signed the attestation was at the time of signing Clerk of the Superior Court, Special Civil Part; that the signature is the handwriting of Angelo 1. Cataldo and that all official acts of the Clerk of the Court are entitled to full faith and credit. I further certify that said attestation is executed according to law. sealed this ro:.' "',,, ',~j/ll, ~v,,,,.],,:rll'f.,')' , >' "/~ ".,<(; "~''>'';'" J- v <to "/:< '/'.( ~ c,., '.~ (::'/<;":~:./"~f~ ,,,.:.:"#' {, PI,." 6,''"1' "') .,:t. ....rf':'..'!!'.~'.' '.,'.'tJ e"re,-:,. lU:jf)1 ':"'..;':~ ql;Cj Ui:!Q ,,;.," ~.,;:. gQt] '1'Q c~.:(lflfvJ9l~"k1 (;:(',',..r,.~,."y,{:'jl." ~ '<~"~'i7fl'<'1...N;:{)t/,,,,~ :.o~ {!o:lailIlJ;>\;l'" <(." CI,IIL eN\\. S 'E OF NEW JERSEY: :SS. COUNTY OF BERGEN : 17 day of March Supervising Judge, Bergen County Special Civil Part OONALD W. deCORDOVA. J.S.C. I, Angelo 1. Cataldo, Clerk of the Superior Court of New Jersey, Special Civil Part, Law Division, Bergen County, certify that the Honorable Donald W, DeCordova whose name is subscribed to the preceding certificate, is one of the Judges of this court, duly commissioned and sworn, that the signature of the Judge is genuine, Signed and sealed this 17th day of March ,2000, ~ &J,~ Angelo J, atald Clerk, Special Civil Part ,~ L~IL!l -a I JOII'i .J - "II illmtiti U".IIIli .L- t:lJ'.&l ".&LW":..,.~"" DANKA'F~NDING COMPAN (PLAINTIFF(~n ) - VS .-, COOPER & HOLLAND INC (DEFENDANT(S)) o BER SUPEIHOIl COUIlT O~EW ,JEIlSEY LAW DIVISION-SPECIAL CIVIL PAIlT ON (CONTf(;;CTJ DOCKET NO, ..JUDGi1ENT rW, DC-~00675~i-~99 VJ-'00992:3-9il' ),)}), STATEMENT FOil DOCKETING .,.c" CIlEDITORS ATTOIlNEY: MICHeiEL QUIAT USCHER QUIAT USCHER & IlUSSO CONTINENTAL PLAZA II 401 HACKENSACK AVE HACKENSACK NJ 07601 .._----------_._--~._-------------_._------------------------- JUDGMENT IN THE ABOVE ENTID_ED CAUSE WAS IN FAVOR OF: DANKA FUNDING COMPANY LLC ENTERED IN THE BERGEN COUNTY SPECIAL CIVIL PART : r,GAINST: COOPER & HOLLAND INC DB fiGT YORKfi SGT YOj~I<S AN EXECUTION WAS ISSUED ON AND WAfi RETURNED ON MONIES RECEIVED BY fiCP OFFICER TOTAL Cf,EDITS I I ,JUDGMENT DATE I I JUDGMENT AMOUNT(*) $,00 COfiTS & ATTORNEY FEES $,00 ADDITIONAL COfiTfi TOTAL CREDITS; IF {.~NY TOT,',L lO/Ol/if.?9't ~~B 11~S4, 9i..~ '~;22~5. 10 $,00 ~;B ,380,06 t,OO '~~8 ,3HO . 06 (*)INCLUDEfi PilE-JUDGMENT INTI~REfiT (IF ANY) I HEREBY CERTIFY THAT THE FOREGOING REFLECTS l~E AS OF l~IS TIME, D~,TE :.~~~__~ 8__~Q9!_ SEAL PF RECORD IN "fHIS COURl I .__.n____~~..__._...~...... CLERK OF THE SPECIAL CIVIL PART ~lL CII,.JIL F'(~RT .------------------------------------------------------..---------------------------------- ----------.--------------------------------------------------------.-..---------------------- ....- ._.._.....~. ....._........._..~. I, THE UNDERSIGNED, AM (ATTORNEY FOR) THE ABOVE NAMED PLAINTIFF, CERTIFY THAT AT THE PRESENT TIME THERE IS DUE UPON T~~ ABOVE MENTIONED ,JUDGMENT, WHICH IS ABOUT TO BE DOCKETED IN THE SUPEIlIOR COURT OF NEW JERfiEY, AS HEREIN SET FORl~, THE TOTAL JUDGMENT DUE INCLUDES THE $5.00 DOCKETING FEE, TOT A L JU IJ GMEN T DUE $ ___,_______,__,_______,__. TOT,~L CREDITS fiU 8TOT AL ,. __,_____,,________, INTEREST $______,_,__", TOH1L DUE THIS Di\TE $_________ (BEING A fiUM NOT LESS TI~AN TEN DOLLARS) I CERTIFY TI~AT THE FOREGOING fiTATEMENTS MADE BY ME ARE TRUE, I AM AWARE THAT IF ANY OF THE FOI~EG(jINI:.:i STATEMENTS MADE BY piE ARE WILL.FULL Y F(~LSE 1 I AM SUBJECT TO PUNISHl1ENT, Dr, TE : _,___,___,,___,__,________,,_ ..,~" """......,~. iIIIIIIii' "'~"";,: BER UAN[<(\ '.F~JNUING COI-'iPi~iN (PL':-IINTIFF(~;) ) SUPERIOR COURT L, NEW JERSEY LAW DIVISION--SPECIAL CIVIL PART _M. l.-iS -- COOPER & HOLl_ANI) INC ( DEFEr-! Dtih!T (~~) ) DO. (CClr~TRtICT) DOCKET i\!C) , .JUDCihEi-'.JT NU, [)C"--OOc.:,?~;:-}-99 i.) "J-. 00 9()23"- '7'9 )))))) STATEMENT FOR DOCKETING (((((( CREDITORS ATTORNEY: riICHt~EL \~UIf:\T USCHER QUIAY USCHER & IZUSSO CONTINENTAL PLAZA II 401 ~iACKEN~:~-~K AVE ~"IACKENSACK NJ 07601 --------------------------------------- ----------------- -------- JUDGMENT IN THE ABOVE ENTI"fLED CAUSE WAS ENTEi~ED IN THE GERGEN COUN"fV SPECIAL CI~iIL PART IN Fr~i.)OP GF ~ ; /.jr..JI:::-IIj---!:3T; OANKA FUNOING COMPANY LLC COOPE~ ~ HOLLAND !NC DB :;(J-r YOF{I{f) ": sur "(UF:<~3 A~~ E/ECUTION WAS ISSUED ON AND WAS RETURNED ON MONIES RECEIVED BY SCP OFFICER T"]"T;IL C::;E01T:3 I JUDGME~T DATE JUDGMENT AMOU~T(*) $.00 COSTS ~ A'fTORNEY FEES $,00 ADDITIONAL cosTs TfJT~IL 10/01/199'7' $8)1::;4,96 $225,10 $,00 ':~a ",380 , Cl6 CREDIT::::, IF ?'INY- $,00 TDTi~1L ':~8 ) 380 , 06 (*)INCLUDES PRE-JUDGMENT INTERES"r (IF ANY) ~3Er;1 ANGELO J, ~ATALor. CLERK OF THE SPECIAL CIUIL PART BERGEN C()JNTY SPFC~AL CIVIL PART """," f~ "''''',,' .;::, f:OURT) I HEi~EBY CERTIFY THAT THE FOREGOING REFLECTS THE AS OF THIS TIME, Ue,TI:.: ~UN 0 8 _2000 "______________._"_______________"_________M________________."_____"__________________________"__________ ._--------_._---------.----------"---"------------------------------------------_._--------------"------ I, TH~ ;JNDERSIGt!ED. AM (ATTORNEY FOR) TiiE ABOVE NAMED Pl.AINfIFF": CERTIFY THAT AT THE PRESENT TIME fHERE I':; DUE: IJ1'1lNfi11:. ,;81l')E riUnlUi!ED JIJDGMDrI, IJHICH ['3 ABOUT TO BE IlOCi<ETI:1J IN THE SIJI'EllIiJR GOlJR1- OF NEW JERSEY, AS HEREIN SET FOR-f"li, THE fOTAL "JUDi3MENT DlJE INCLUDES THE $5,00 DOCKETING FEE, l'OTAL JUDGMENT DUE $ fOTAL CREDITS $ SIJBTIlTAL S [N-rl~::{EST $ rOTAL DUE THIS DATE $ (BElt~G A SUM NOT LESS THAN TEc! UiJLL,;r,S) [ CERTIFY -f~i~T "fHE F-(l~EGOING STATEMEN"rS MADE 8Y ME I~OREGnING Sl"A"fEMENTS MADE 8Y ME ARE WILI_FIJLLY FALSi~! ARE (RUE, I AM AWARE "fHAT IF [ AM SUBJEC-r TO PUNISHMEN"r, {,flY UF' THE DtlTE: ," , .,,< ~1'"~"-""'1l1 ""~'~~",",- .' - ".'''~l~''IiIIi~iIiiI~lll~- ~ ~ j (lJ - ff - ;;v (0 li::~ ~N I~ ~ ~'".() =.J'lEi -{q, ~ o o (;tJ ,........ 1- -~---.-' ",,' " ..,"""", ,~""" ' (') ,-- ~ -,..-,_.C< rl~r,,'-:, ~~:~. ~;:_:~ <::-........ ~,.::.: ~E; c --:;:-;> ==i -<. ,,, ~~; (\.) i:::J S'? r:- C:,l .. l"(, , . Ii I' , , i', H \" ~ i t' ;'1 I H [, I I: I I I " Ii ~ I I I' ~ [I I i: I I [! -, --.--' --' -:=-'"J -< '~,,>, ", !1.l~ I . . " NEEDLEMAN & NEEDLEMAN, P,C. BY: Joann Needleman. Esquire Attorney for Plaintiff Identification No, 74276 Suite 935 One Penn Center at Suburban Station Building 1617 John F, Kennedy Boulevard Philadelphia PA 19103 (215) 665-1133 COPELCO CAPITAL, INC, Plaintiff v. CUMBERLAND COUNTY COURT OF COMMON PLEAS COOPER & HOLLAND, INC, d/b/a SGT. YORK'S & SGT, YORK'S Defendants & DAUPHIN COUNTY BANK & TRUST ~ow KNOWN AS Allfirst Ba~rnishee NO. 00-5119 mJSW~RS INTERROGATORIES IN ATTACHMENT TO: Dauphin County Bank & Trust Now Known As Allfirst Bank You are required to file answers to the following interrogatories within twenty (20) days after service upon you, Failure to do so may result in a default judgment against you, 1, At the time you were served or at any subsequent time, did you owe the defendant any money or were you liable to defendant on any negotiation or other written instrument, or did the defendant claim that you owe him/her any money or were liable to him/her for any reason? As of September l2, 2000, the defendant Cooper Holland Inc. d/b/a Sgt. York's maintains no bank accounts with Allfirst Bank formerly Daup.hin County Bank and Ttust. 2, At the time you were serveo or at any subsequent tIme, was there in your possession, custody or control or in the joint possession. custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? NO 3. At the time you were served or at any subsequent time, did you hold legal title to -" . " ~ i"'~ '~ ~~ I , . -' ...... any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? NO 4, At the time you were served or any subsequent time, did you hold as fiduciary any property in which defendant had an interest? NO 5. At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent. and if so what was the consideration therefor? NO 6, At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? NO 7, At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings. tax or other accounts or deposits in which defendant has an interest? NO /L-/ 10 N NEEDLEMAN, ESQUIRE Attorney for Plaintiff ~_~,u;~~9~"-;t.'-""'~'M~~'I,,I"'Yol4<ffl',,";;~n,j"0iY'--i'M";~{;ib_"Yt~';,(f>!'-'ii-".,,,,,';,."~,1$-~,c""~it1,I;J"c&.."'h~r_-~~_~.*,~;8i;,,i~'iI!~i!UIl!;.iWtJl!II~$l!I;OII@[\llt..lWlojil.\!\I~~ o ~ ... ritJD 2:~ tJ5.~ ~6 ~o ~ ~ , "" -, ~ ,~ " '0 <:;) t') M -0 o -.,.., - ...~ ".,-.' vi~.:71 :~~r= :]'1 (...." ~i',_) -'--"-n ';:0-:;-:0 ,-.'h aI"n g -< U1 ~ .... r:9 ,-.> U1 .;r .\ [:;,1 Ii i) I ~'1 "" H. __c ~ -'4'-' J . ... YERIFICATION I, Joan E. German, verify that I am a Legal Assistant for Allfirst Bank a Maryland state-chartered commercial bank organized and doing business under the laws of the State of Maryland; that I make this verification on its behalf, being authorized to do so; that the statements made in the foregoing Answers to Plaintiff s Interrogatories to Garnishee are true and correct to my personal knowledge or information and belief. I understand that false statements made herein are made subject to penalties of 18 Pa.C.S. s4904 relating to unsworn falsification to authorities. DATE cr IIJjoo I . ~JL1M11~ Legal Assistant Allfirst Bank (410) 244-3803 ." ~~ j W:/iQ;,!,,i;[-MlliIfiI/jol!!Wll;~;~~~;l!!I;'!HW!!h"~~IW~~-"'~~~Y!ti ~"..~~-~,.._"~,,--,-~-~," UIiil IlIIMl ~, -.. \. ",""0,. <:;) 0 c: 0 -n 2i tn ::J rTt ,t_.-,l -0 n1~ , ZS; -l"'lfn "9 ~6 t.Y! ,:~ -0 :;1q, I~ "'.-H :;l!: ~'c"5 ~ orn' sJ .!A) ~ U1 "l,~ ~.~ ~_. 1- ~~ _"~'1~~ -~IIR" -,~,~ ~"",,"," 'jl'~~~' ~, ",_~":,,,'~"'1, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: vs. ( ) Confessed Judgment (X) Other File No. 00-5119 Amount Due: $ 8,380.06 Interest Atty's Comm Costs COPELCO CAPIT AL INC COOPER & HOLLAND INC d/b/a SGT YORK'S & SGT. YORK'S TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding flledpursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s): ANY AND ALL TANGIBLE ITEMS OF THE DEFENDANT AT THE LOCATION: 402 MARKET STREET.LEMOYNE. PA 17043 PRAEOIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachmentagainst the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list): Dauphin Deposit Bank & Trust Fulton Bank Harris Savings Bank 1200 Market Street 599 N. 12th Street 1200 Market Street Lemoyne, PA 17043 Lemoyne, PA 17043 Lemoyne, PA 17043 o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit Date: 8/21/00 Signature: Print Nam : Address:93 ne Penn Center, Phila, Pa 19103 Attorney for: Plaintiff, Copelco Captiallnc Telephone: 215-665-1133 Supreme Court 10 No.: 74276 ~~.^. - /!Wl!n:b!&.i!iMHIlJ.~\ ' ""' _~a~'!i' -, ; _!;Bl'~ I "J ,;; -~ ~", - JiIIIIlr'I' .' ~"' 'lIIlm ';.-;.>3iI~ ~" -^ '. ,"",' J Lv '- L., ~ , <b ~ B , Q; \:) ~ ~ \ , \0 ~ ' , ~ \' ~ r ~ \', f "- Cl (';:) ~ C 0 .-,..,~~ ~ ~ I ve-, U) . ~~ Qr-;": ;"'1 Z"" ._":J zf I ~f C; ,<'" ;?r.... Z..,j 5>L: C ~-'? 2"::: .' , =< :J .i:'" l~ ss. ~ ~~ ~ . ~ ~,-.. 1i1I-v, .\ , NEEDLEMAN & NEEDLEMAN, P.c. BY: Joann Needleman, Esquire Attorney for Plaintiff Identification No. 74276 Suite 935 One Penn Center at Suburban Station Building 1617 John F. Kennedy Boulevard Philadelphia PA 19103 (215) 665-1133 COPELCO CAPITAL, INC. Plaintiff , v. CUMBERLAND COUNTY COURT OF COMMON PLEAS COOPER & HOLLAND, INC. d/b/a SGT. YORK'S & SGT. YORK'S Defendants & HARRIS SAVINGS BANK Garnishee NO. 00-5119 A~~WM'j +0 : INTERROGATORIES IN ATTACHMENT TO: HARRIS SAVINGS BANK You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment against you. !jJY1. At the time you were served or at any subsequent time, did you owe the defendant any money or were you liable to defendant on any negotiation or other written instrument, or did the defendant claim that you owe him/her any money or were liable to him/her for any reason? p-2. At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? jJY3. At the time you were served or at any subsequent time, did you hold legal title to >\ , any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? ~ 4. At the time you were served or any subsequent time, did you hold as fiduciary any property in which defendant had an interest? ~> At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent, and if so what ... was the consideration therefor? ~6. At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? ~7> At the time you were served or at any subsequent time, did you have any safe deposit boxes. pledges, documents of title; securities, notes, coupons, receivables. collateral, checking. savings. tax or other accounts or deppsits in whjch defendant has an interest? - J.I,j15 (f~~U"-~70 ~~~)'luftP7- /11'~ . ~ ~' . ATTACHMENT TO INTERROGATORIES Question 7 : YES. Defendants Checking account # 1000026251 was closed on 9/08/2000 by Harris Savings Bank due to negative balances from 08/2/2000 to 09/08/2000, caused by NSF Checks and Overdraft fees and charges. r11.Wr' ~.=.--~ " "au " . WRIT OF EXECUTION a.nd/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-5119 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Copeleo Capital Inc. PLAINTIFF(S) f~m Cooper & Holland Inc. d/b/a SGT York's & SGT. York's DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) ana to sell Any and all tanaible items of the Defendant at the location: 402 Market Street. Lemovne. PA 17043 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Dauphin Deposit BAnk & Trust 1200 Market STreet Fulton Bank Harris Savings Bank 599 N. 12th Street 1200 Market Street Lp-ffioyner PA 17041 T.emnyne. PA 17043 Lemovne. PA 17043 GARNISHEE(S) as follows: and to notffy 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 property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subjectto attachment is found in the 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 $8,380.06 Interest AllY's Comm Ally Paid Plaintiff Paid % LL $.50 Due Prothy $1. 00 Other Costs $33.00 Date: September 5, 2000 Curtis R. Long Prothonotary, Civil D',vision by: 7A?d. ?X}/k W Deputy REQUESTING PARTY: Name Address: Joann Needleman, Esq~ Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: 215-665-1133 Supreme Court 10 No. 74276 '"fp i ~~' 1""'~""'I.ff~i~'f "'""'" +..- \ " ~ '\ "J',-;.., '''''''J~', &~~,h~ ~"i'4 ;;-,r;,rn-"r'll l,~ 100;,:')'; ,".1, '0, f, 1\l>,,'~'..:';;\il..N dl . ~,...llmo;:y Wi"ir.!"t-r){' j , t "J:'rj C,,!-,. ",1"[' ":'~-'<," ',i~LO ::x~.:' my hand :).J, ! ie ,,8f.1l dl SZJid Court ;:r1' {>I~):,~lp n'l , - ~, ,. ~ ,";'. "I ((,. This 5 I -~ <;;/fi1~ qq~, 'i~Y 0L~.., ~ ~..- ?: ld,./ 9:f' 'L",,,,,,_,,,~ . qq , . . 'q '''r'' . t.~, 'R '_ I I oWo~ iotary , 935 One Penn Center 00, ~"""'_-_I_l!titlJ)t::ml8l1''''''~''''''''''''''11J ."Ill1~~~~ ~.~ ~"~~ ....... . - o c: <" -rJ C;'_, ~!;:;' 2:C en ~':.::: ~t:~, "'" J.:c 5;2 ~ a c:~ ,-=:) c:> -4 I .D C) ., ""1 <~~8 ~-,i} ~~~ ".;::~ -;-: ...~:'" -"'''~ .",;C) ~:~rf1 S:> -< o o , ."'1 i' II II II I' , , ~ r "oil t I w ,~, ,J '" ~~-.lk-i' .' ~- NEEDLEMAN & NEEDLEMAN, P.C. BY: Joann Needleman, Esquire Attorney for Plaintiff Identification No. 74276 Suite 935 One Penn Center at Suburban Station Building 1617 John F. Kennedy Boulevard Philadelphia PA 19103 (215) 665-1133 COPELCO CAPITAL, INC. Plaintiff v. CUMBERLAND COUNTY COURT OF COMMON PEAS """",",,,<< COOPER & HOLLAND INC d/b/a SGT. YORK'S & SGT. YORK' Defendants & DAUPHIN COUNTY BANK & TRUST nlk/a ALLFIRST BANK OF MARYLAND Garnishee NO.00-5119 PRAECIPE TO DISSOL VE/WITHDRA W AL GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve and withdrawal the garnishment execution against DAUPHIN COUNTY BANK & TRUST nlk/ a ALL FIRST BANK OF MARYLAND, forthwith. Date: October 2, 2000 NEEDLEMAN, P.C. ,......,,"'''''''..~ ~~- r '^,', -"-,'., '^ ..", , ,I ,:~... CERTIFICATE OF SERVICE I, JOANN NEEDLEMAN, ESQUIRE, hereby certify that on this date I have caused a true and correct copy of the foregoing Withdraw/Dissolve Garnishment on behalf of Plaintiff, Cope1co Capital Inc to be served by regular, first class mail, postage pre-paid upon: Joan E. German, Legal Assistant Allfirst Bank P.O. Box 1596 Legal Division 101-850 Baltimore, MD 21203 BY: NEEDLEMAN rney for Plaintiff DATED: October 3, 2000 ~1~.>JiTh!iliJ!m"/i!;,t#iii~rifljl~;U .,' c~ r~"";.I~i'mlli~~i~i!l\r~~l1A'''"' ~".lwlBi- -.....~* ~r~I'llE!l!l@!ltililllli~iI~___~:-' ~\~ ~ ,~I ~ r-V L'-\ ~ ~~ " ~ C ~ ~, o c: ;;:. -or):; rrttll Z:Ti &\1- "'" ~7 (25 ?Eg .~c: ~ C> C> ::r; C> ~ I (S> -0 :;;: N .' ~-i ,,~..-J \ Ul o () ." '-\ ih~ -n!l. :~JO 0," -,..,,~ -r" -H 0- -70 .;;,,~ 111 9; .". :J:1 :< ., 1~ -~~~ ~_______ .Ili.iJ.'~ 1- .t.~..~ 'j.:;;O..1I_ ..~--~~~~~IOO ~ -~ ~~". -~1II1 ,'"- --;~'''''''t'''..~"~:. .... NEEDLEMAN & NEEDLEMAN, P.C. BY: Joann Needleman, Esquire Attorney for Plaintiff Identification No. 74276 Suite 935 One Penn Center at Suburban Station Building 1617 John F. Kennedy Boulevard Philadelphia PA 19103 (215) 665-1133 COPELCO CAPITAL, INC. Plaintiff v. CUMBERLAND COUNTY COURT OF COMMON PEAS COOPER & HOLLAND INC d/b/a SGT. YORK'S & SGT. YORK' Defendants & HARRIS SAVINGS BANK Garnishee NO.00-5119 PRAECIPE TO DISSOLVE/WITHDRAWAL GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve and withdrawal the garnishment execution against HARRIS SAVINGS BANK, forthwith. ( \ LEMAN, P.C. 1 , ESQUIRE Date: October 2, 2000 . " -~ ~...-, .". ""~'"i1''''''' ~" ,'. ~ , '\~;,/ '\ CERTIFICATE OF SERVICE I, JOANN NEEDLEMAN, ESQUIRE, hereby certify that on this date I have caused a tme and correct copy of the foregoing Withdraw/Dissolve Garnishment on behalf of Plaintiff, Cope1co Capital Inc to be served by regular, first class mail, postage pre-paid upon: Margret R. Siemers Sr. Database Development Services Rep. Harris Savings Bank 2nd & Pine Street P.O. Box 1711 Harrisburg, PA 17105 BY: NEEDL DATED: October 3, 2000 ,hl~liilIll;Il:oI!lIlii~iJ!!:~';~W_"~_H'~J",~"i!;-~~~j~_~.ill~Hi,;t,~,.~~l!r..~~' ,," -- ,_,'0_";"'-- 'bd.J' '1 ~- .:~_ -~j = ,,,,,,( , @~ iZJ ~ ~- ~ -... ~~\ ~ ~ I -, " ~ """""'Ii. 1 n:iJ!.>-liHif~' ~- (} C ~ -05:. ref'" Z::o :Z:C ,^p ~Z ~U ~O ~2 z :< C> o :% g '- " \ C5' -0 :> ~ at (:) o -n --I :~~ -n ';1;:;:':" _,_.il" ~j2~) :::"-':::" "'"~ ::D ~--4C) ~:;-)rn ':::-; ~ ,~ J / / ~> I; : ' ~-"-,~,"'," WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-5119 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Copeleo Capital Inc. PLAINTIFF(S) from Cooper & Holland Inc. d/b/a SGT York's & SGT. York's DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Any and all tanoible items of the Defendant at the location: 402 Market Street. Lemovne. PA 17043 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Dauphin Deposit BAnk & Trust 1200 Market STreet Fulton Bank Harris Savings Bank 599 N. 12th Street 1200 Market Street Lemoyne FA 17043 Lernoynp PA 17043 Lemovne. PA 17043 GARNISHEE(S) as follows: and to notny the garnishee(s) thaI: (a) an allachment has been issued; (b) the garnishee(s) isiare enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property oflhe defendant(s) not levied upon an subjecllo attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above stated, Amount Due Interest Ally's Comm Ally Paid Plaintiff Paid $8,380.06 LL $.50 % Due Prothy $1. 00 Other Costs $33.00 Date: September 5, 2000 Curtis R. Long Prothonotary, Civil Division by: 1Y;..M K'. X;~ W Deputy REQUESTING PARTY: Name Address: Joann Needleman, Esq. 935 One Penn Center Philadelphia, PA 19103 Attorney for.: Plaintiff Telephone: 215-665-1133 Supreme Court ID No. 74276 ~ w.ni , ' i..''''._'''''-,.;....''''...liiiiii:>l--'.- - -'~.~~,'IIIldilIiIiilI" , -~" 'iii!>. ~ '--, ,........... ',.' :\i R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Atty Joann Needleman's office. Defendant moved and left no forwarding address. sheriff's Costs: Docketing Poundage Law Library Prothonotary Service Garnishee Surcharge Levy $18.00 3.79 .50 1. 00 32.86 27.00 50.00 60.00 $193.15 Advance Costs: Sheriff's Costs: $300.00 193.15 $106.85 ;'-:J2:j~~< ~ R. Thomas Kli~heri'ff Sworn and subscribed to before me BY ~~ .svuLtL D puty Sheriff This ~/iI.#- day of 1&.. ". #... , 2000, A.D. (/",.. (], I1AdJR,-o./ ~ Prothonotary' .. _, H,"~" ' ~ ~ - -.t> ':'":'-'- , ~ I'.' '. ) SO j . Ck- 3073~ ~