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HomeMy WebLinkAbout03-4878WADDEN SYSTEM24 INC. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. ®3 -- 7? 0iui??£rtr>?? ELMER J. SLASEMAN Individually and Trading As CIVIL DIVISION - LAW REFRIGERATION, SERVICES, INSTALLATION and : R.S.I. Defendants NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 NOTICA LE HAN DEMANDADO A LISTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VEINTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDA ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 WADDEN SYSTEM24 INC. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 03 - 1/p 9? l21;'o, L-.,,, ELMER J. SLASEMAN Individually and Trading As CIVIL DIVISION - LAW REFRIGERATION, SERVICES, INSTALLATION and R. S.I. Defendants COMPLAINT The Plaintiff, WADDEN SYSTEM 24 INC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendants to recover the sum of FOUR THOUSAND, SIX HUNDRED SIXTY-SIX DOLLARS AND FORTY-FOUR CENTS ($4,666.44), along with interest thereon from November 1, 2001 upon a cause of action of which the following is a statement: 1. The Plaintiff, WADDEN SYSTEM24 INC., is a corporation organized and existing under the laws of Canada, having its principal office and place of business at 5674 Sherbrooke W., Montreal, Quebec, Canada. 2. The Defendant, ELMER J. SLASEMAN, is an adult individual trading and doing business as REFRIGERATION, SERVICES, INSTALLATION and R.S.I. with an office and place of business at 120 Fourth Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff, at the special instance and oral request of the Defendants, sold and delivered goods, wares and merchandise to Defendant. F:\USER\STACY\CCP COMPLAWTS\FORMS\MASTERCOMP.FRW.wpd:I8.Iu103 4. The prices charged for said goods, wares and merchandise were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay to Plaintiff. 5. The balance due and owing by Defendants to Plaintiff is the sum of Four Thousand, Six Hundred Sixty-Six Dollars and Forty-Four Cents ($4,666.44), as appears by Plaintiff's Statement of Account hereto attached, marked as Exhibit "A" and made a part hereof. 6. Plaintiff frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of FOUR THOUSAND, SIX HUNDRED SIXTY-SIX DOLLARS AND FORTY-FOUR CENTS ($4,666.44), together with interest thereon from November 1, 2001. Respectfully submitted, KNUPP, & IMBLUM, P.C. Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff F:\USEMSTAMCCP COMPLAINTS\FORMS\MASTERCOMP.FRW.wpd: I M103 WADDEN SystemU Inc. 5674 Sherbrooke W. Monmeal, Quebec, Canada H4A 1 W7 2(800)392-3336 /Yr 2S NOV 1 3 2001 11616V6 De compt®I R•livi De Cotnpte STATEMENT I STATEMENT DATE: 2001/11101 DATE: 2001111101 "'" l~b. s ?W t? tl", "ober SA007S3 Refrigeration Specialist Elmer J. Slassman 120 Fourth Street New Cumberland, Pennsylvania, USA 17070 Page 1 SVP NE PAS TENIR COMPTE POUR UN PAIEMENT EFFECTUf IL Y A MOWS DE 30 JOURS. I PLEASE REIVIRM THIS PORTKRI WAN YOM( PAYMENT 4 M PAYKIO BY eIVOICr. CKECK INDNIDUAL INVOICES PAID AMO rtant Yaveyb UNT...TTED 5 I SADOM RNAa/rWon epaChallat 19-JUN-98 13608 Invoice 7,392.00 I 10-JUL-98 13608 Payment 3,868.43 01-APR-01 Adj. Payment -934.17 2,588.40 13808 28-SEP-01 Int. 01-10-01 Invoice 1,975.54 ' Int. 01-10-01 1 2,599.40 1,975.54 0-30 30.60 66-00 11,1111411 " 6owa no BALANCE DUE $0.00 $1,975.54 $0.00 $2,599.40 , Q ? , N.A. Lea raieaanea an retard seat sujots A dae [raja de etnanaeaamt de 0.06670 par jour(]ei P Late payments will Incur a dally financing Charye of 0.0667% (24%annwlly ) JUL 18 '03 02:10PM KNUPP & KODAK PC VERIFICATION P.5 VE7-Q4A 157ECrp,FTA*Y -TA CA S V PEK (name) (doe) of WADDEN SYSTFM24 INC., verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are trade subject to the penalties of 18 Pa. C. S. §4904, relating to unworn falsification to authorities. WA,DDEN SYSTEM24 INC. BY: Title: VECALTARy-iREASJQER Dated: /s t .200-3 29275 F:IUSEMSTACYICCP COMPLAINTSIFORMSIMASTERCOMP.FRW.wpd' 187u103 70 ? ? ? F? ? c SHERIFF'S RETURN - REGULAR CASE NO: 2003-04878 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WADDEN SYSTEM24 INC VS SLASEMAN ELMER J ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SLASEMAN ELMER J the DEFENDANT , at 1625:00 HOURS, on the 25th day of September, 2003 at 120 FOURTH STREET NEW CUMBERLAND, PA 17070 by handing to ELMER SLASEMAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.73 Affidavit .00 Surcharge 10.00 .00 39.73 Sworn and Subscribed to before me this o7.?k day of DLC.d a 6V-3 A. D. rothonotary So Answers: R. Thomas Kline 09/26/2003 KNUPP KODAK IMBLUM By: ?,? Deputy Siff SHERIFF'S RETURN - REGULAR CASE NO: 2003-04878 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WADDEN SYSTEM24 INC VS SLASEMAN ELMER J ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SLASEMAN ELMER T/A REFRIGERATI SERVICES INSTALLATION & RSI the DEFENDANT , at 1625:00 HOURS, on the 25th day of September, 2003 at 120 FOURTH STREET NEW CUMBERLAND, PA 17070 ELMER SLASEMAN by handing to a true and attested copy of COMPLAINT & NOTICE 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 v .00 1 10.00 R. Thomas Kline .00 16.00 09/26/2003 KNUPP KODAK IMBLUM Sworn and Subscribed to before By: me this i s „2.-w1_ day of U???VV3 A. D. ?rt honotary Deputy Sheriff WADDEN SYSTEMS24, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2003-04878 ELMER J. SLASEMAN, Individually and CIVIL DIVISION - LAW Trading As REFRIGERATION, SERVICES, INSTALLATION and R.S.I. Defendants PRAECIPE TO AMEND CAPTION TO THE PROTHONOTARY: Pursuant to the signed Stipulation to Amend Caption attached hereto, please amend the DEFENDANT in the above-captioned matter to be: REFRIGERATION SPECIALIST, INC. TO Cumberland County Prothonotary Dated: February 4. 2004 Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041 WADDEN SYSTEM24, INC. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2003-04878 ELMER J. SLASEMAN, Individually and Trading As CIVIL DIVISION - LAW REFRIGERATION, SERVICES, INSTALLATION and R.S.I. ST "PLATION TO AMEND CAPTION AND NOW, this day of , 2004, comes Plaintiff, WADDEN SYSTEM24, INC., by and through its attorney, ROB 4T D. KODAK, ESQUIRE, KNUPP, KODAK & IMBLUM, P.C., and Defendants, ELMER J. SLASEMAN, Individually and Trading As REFRIGERATION, SERVICES, INSTALLATION and R.S.I., pro se, and files the following Stipulation to Amend Caption, as follows: 1. The above captioned case originated in the Court of Common Pleas of Cumberland County, Pennsylvania, on September 16, 2003. 2. Defendant was properly served by the Sheriff of Cumberland County on September 25, 2003. 3. The parties then entered into discussions regarding who the appropriate defendant should be and the parties agreed that the caption should be amended to make the sole defendant in this case to be Refrigeration Specialist, Inc. 4. The parties further agree that Elmer J. Slaseman and Refrigeration, Services, Installation and R.S.I. should be deleted from the caption in its entirety. 5. The parties agree that the above entities, enumerated in paragraph 4, are not proper party Defendants in this action and should be deleted, WHEREFORE, the parties move to amend the caption of the action filed to the above term and number and to remove Elmer J. Slaseman, Individually and Trading As Refrigeration, Services, Installation and R.S.I., and that the sole Defendant be named as Refrigeration Specialist, Inc. Respectfully submitted, Pro se Defendant KNUPP, KODAJS & IMBLUM, P.C. i Robert D. Kodak 407 North Front Street Post Office Box 11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorney Id. No. 18041 Attorney for Plaintiff New Cumberland. PA 17070 ? - - ? ?? _ ' ?E., ; ;? a ? ?? {?? l?.?J ? T? ?? N .am o w WADDEN SYSTEM24 INC. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2003-04878 CIVIL REFRIGERATION SPECIALIST, INC. Defendant CIVIL DIVISION - LAW TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) REFRIGERATION SPECIALIST, INC., named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint $4,666.44 Interest from November 1, 2001 at the legal rate of 6% per annum 670.80 Total $5,337.24 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant(s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached. KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak, Attorney for Plaintiff DATED: Judgment entered and damages assessed as above. Prothonotary 3//?? LAW OFFICES OF Robert L. Knupp KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak CAMERON MANSION Gary J. Imblum 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 7171238-7159 Facsimile: 717/238-7158 email: kki.law@verizon.net March 1. 2004 REFRIGERATION SPECIALIST INC 120 FOURTH STREET NEW CUMBERLAND PA 17070 RE: Wadden System24 Init. VS: Refrigeration Specialist, Inc. (Amended Caption) No. 2003-04878 Civil, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 29275 Greetings: J a -Ito-derttKQp " (1909-1976) Robert H. Maurer (1923-1998) In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Amended Caption and Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak, Esq. RDK/kgb enclosure cc: LEONARD WALLIS DIXON COMMERCIAL INVEST G POST OFFICE BOX 550 LEWISTON NY 14092-0550 #M8669-480311 bur f WADDEN SYSTEM24 INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. REFRIGERATION SPECIALIST, INC. Defendant NO. 2003-04878 CIVIL CIVIL DIVISION - LAW IMPORTANT NOTICE TO: REFRIGERATION SPECIALIST, INC., Defendant(s) DATE OF NOTICE: MARCH 1, 2004 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 WADDEN SYSTEM24, INC. P]aintiff VS REFRhFRATION SPECIALIST, INC 120 FOURTH STREET NEW CUMBERLAND, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 9P7? No. 03-444& CIVIL Term 2003 Amount due 8 5.337.24 InterestFRON DATE OF JUDG. (03125104) Atty's Comn. 8 266.86 and Costs TO BE OETERMINEO 8 TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against REFRIGERATION SPECIALIST, INC. Defendant (s) (3) and against Garnishee (s), (4) and index this writ (a) against REFRIGERATION SPECIALIST, INC. Defendant(s) and (b) against Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT, REFRIGE N SPECIALIST, INC., AT 120 FOURTH STREET, NEW CUMBERLAND, CUMBERLAND COUNTY, PENNSYLV (5) Exemption has (not) been waived. Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Dated 06/04/04 Attorney For Plaintiff(s) rnti aas 'Pas TsaP ST siapaad sTT e se F,v -11 TI r .p i,P__e sz e ,.;11 aa? c i t .o c: ,a?dwoo ac Pinogs (q b yfl2sE?xc? ' (:i15ua arov .,as %,?=5"'.:oq;oxd ay: Rq F,soca,e,;z ni aonnoo 3o se Pa. -. ,arar E c<aouT Rao _..,r-. sanssT :??M ay: ua4M °I60 6 am f. n- y 9 P, T, P IC, T ,a Pas aai, - 'a,,z, 55 is no- a _ u? _r 1::a a45 c ?p'? ;' ?T'Ic PaloTiWoo aq PTFo4s b udy?asTsd (z'. v+, Au- >. Pwpn-o', oa c; - aaa .veb P811 Per 11 T" PanaT ?u. v ..r O'J dn,.-. r.. 4^4y axP3 oansr. ;?p;n aT. F1 m0 . ?',sa42 aye O, ?•?'. •.c]?aIT as i(ew i]Jw,, I --;I '1] e VO "IlvSI ,_, c..._ aTlB saP's? 'Paso, :pnI - d i oTno4s F]'?:.oo a4a 91E0r_ aToy_ 6q p.z,I,jzne se .i.rn zauzone 10 JI-I na. a'TC s*_ lu N aya ll&T,y LTI tisa n ,, xapcp 33.CN to 0 0l N O ? .z N ? 6 ? O m u v El F F ~ ti U J [t] Q N V Lu W w ? W 'u U1 a R' '? a v O X > ? p 'CY m U W W x d H q U o a a ? W Q w o ti KC z o W a N c a? ? A O O z ¢ ° 40 -?` 43 ? o o 0 Lo r 3 J, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 034878 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WADDEN SYSTEM24, INC., Plaintiff (s) From REFRIGERATION SPECIALIST, INC., 120 FOURTH STREET, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT, REFRIGERATION SPECIALIST, INC., AT 120 FOURTH STREET, NEW CUMBERLAND, PA (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 subject to 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 $5,337.24 Interest FROM DATE OF JUDG 3/25/04 Arty's Comm % $266.86 Arty Paid $137.73 Plaintiff Paid Date: JUNE 8, 2004 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothono ?J Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF '?C Jr ` F--? Telephone: 717-238-7159 Supreme Court ID No. 18041 ? m ?` L N s -<,:' CII CJ ?, ? ( ? s t .r `n WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-4878 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WADDEN SYSTEM24, INC., Plaintiff (s) From REFRIGERATION SPECIALIST, INC., 120 FOURTH STREET, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT, REFRIGERATION SPECIALIST, INC., AT 120 FOURTH STREET, NEW CUMBERLAND, PA (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 subject to 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 $5,337.24 Interest FROM DATE OF JUDG 3/25/04 Atty's Comm % $266.86 Atty Paid $137.73 Plaintiff Paid Date: JUNE 8, 2004 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonoo Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee TOTAL $ Advance Costs: 150.00 Sheriff's Costs: 67.47 18.00 $ 82.53 1.33 50? 1.00 Refunded to Arty on 09/24/04 26.64 20.00 67.47 Sworn and Subscn to before me This _ _ dgy of /(° c ? 2004 4 Prothonot `tea v Inr CE D NO( .l1Hi?,;.? n;lU So Answers; R. Thomas Kline, SMriff 0 q. 4K L) ? By Claudia A. Brewbaker 0 4? pRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P. R. C. P. 3101 to 3149 WADDEN SYSTEM24. INC. Plaintiff VS REFRIGERATION SPECIALIST INC. 120 FOURTH STREET NEW CUMBERLAND PA 17070 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 NO. 2003-04878 CIVIL Term 2003 Amount due $ 5.337.24 InterestFROM DATE OF JUDG. (03125104) Atty's Comm. $ 266.86 Defendant (s) and Costs TO BE DETERMINED$ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against REFRIGERATION SPECIALIST INC. Defendant (s) (3) and against FULTON BANK Garnishee (s) (4) and index this writ (a) against REFRIGERATION SPECIALIST INC. Defendant(s) and (b) against FULTON BANK Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT (S) AT ABOVE-LISTED ADDRESS AND GARNISH FULTON BANK, 6520 CARLISLE PIKE, #600, MECHANICSBURG PA 17050, ANY OTHER ACCOUNTS UNDER DEFENDANT'S HANSE(S) AND/OR HIM # 25-1628655. (5) Exemption has (not) been waived. Dated 03/30/05 Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Attorney For Plaintiff(s) '(o)6OTE aTny aag •pazTSap sr suapuad siT a se 6urxapuT pue pagoelle sT a9gsTUZe6 aql 10 amen agl UT A;jedoid Teaz ;T 6Tuo pa39Tdmoo aq pTnogs (q)(6) gdezbezed I(q)"Ic aTny aa5 'I,ze;ouogloid eql (.q A( unoo leg; uT esznoo ;o se pazrnbaz sT 6urx8puT .ClunoO zagloue of sanssT 3rzn aql uegM '(e)60TE aTny .(q pazTzoglne se pazTSap sr 'aoueznssT ;o Alunoo aql uT sUOTlnoaxe agl ;o 6urxapuT ;r ATuo pa3aTdmoo aq pTnogs (e) W gdez6ezed '(ITJm agl uT papnTOuT all of cT 88gsTuze6 pameu a uT ATuo palaTdmoo aq pTnogs anoge) (E) gdezbezed •panssT gorgn uT A3unoo aql ;o ;;rzags agl 03 ATUO palOazTP aq .Cem luam6pnC pazza;sues; a uo panssT ;TJm a MULE aTny zapuN 'paleoTpuT aq pTnogs dlunoo aq3 '(q)COTE aTny Aq pazTzoglne se .SluaoD zagloue ;o 3;Tzags aql o; paloazTP sr lrzn aql uaAm (T) gde36ezed sapu0 31ON o f O O N N H " H U Z H a' N H H ? w ul r z c o W M z ° N S N U z H z 0 E H [!1 H H u a U W H X U W 0 O W H a E-+ H U W H a W W a N w w J X " ro ° 'd m 0 x a. 4 0 q w 4 a o 0 w xa w n ? zo O V hV) 1 ? .o v V J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-4878 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WADDEN SYSTEM24, INC., Plaintiff (s) From REFREIGERATION SPECIALIST, INC., 120 FOURTH STREET, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISH FULTON BANK, 6520 CARLISLE PIKE, #600, MECHANICSBURG, PA 17050, ANY OTHER ACCOUNTS UNDER DEFENDANT'S NAME(S) AND/OR EIN #25-1628655 GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 subject to 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 $5,337.24 L.L. Interest FROM DATE OF JUDG. (3125104) Atty's Comm $266.86 % Due Prothy $1.00 Arty Paid $218.20 Other Costs Plaintiff Paid Date: APRIL 1, 2005 CURTIS R. LONG Prothonoott ry (Seal) 0 o Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 WADDEN SYSTEM 24 INC Plaintiff v REFRIGERATION SPECIALIST INC Defendant v FULTON BANK TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-04878 CIVIL CIVIL DIVISION - LAW PRAECIPE Please dissolve the Garnishment against FULTON BANK issued in the above- captioned matter. TO Cumberland County Prothonotary Dated: Garnishee Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041 C LJ C - vm T _ 014 b kA _ C"1 SHERIFF'S RETURN - GARNISHEE CASE NO: 2003-04878 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND WADDEN SYSTEM24 INC VS SLASEMAN ELMER J ET AL And now ROBERT BITNER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:20 Hours, on the 7th day of April , 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT REFRIGERATION SPECIALIST INC hands, possession, or control of the within named Garnishee FULTON BANK 6520 CARLISLE PIKE MECHANICSBURG. PA 17055 Cumberland County, Pennsylvania, by handing to MARY ANN MANION (TELLER) , personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 , in the true and made So answers: ?/? ?i?w?YCJooe R. Thomas KlinY Sheriff of Cumberland County 04/07/2005 Sworn a subscribed to before me Deputy r`i f LBy this day of Q A.D. _ I- I OTAR L Al TI) h KER. NOTARY PUBLIC ro my My Commission Expires April 4, 2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL So thi 20 Advance Costs: 150.00 Sheriff's Costs 79.56 18.00 70.44 1.56 1.00 Refunded to Atty on 5/16/06 30.00 20.00 9.00 79.56 (? 01051VI Sworn and Subscribed to before me s R: Thomas Kl me, ? "ff XD. ' ill 0By 8€ b d S tdV 5001 J j 12)yH5 C'j1 0 W c J oQ ?? c:k. s?iSv ?.? 17fZ7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 034878 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WADDEN SYSTEM24, INC., Plaintiff (s) From REFREIGERATION SPECIALIST, INC., 120 FOURTH STREET, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISH FULTON BANK, 6520 CARLISLE PIKE, #600, MECHANICSBURG, PA 17050, ANY OTHER ACCOUNTS UNDER DEFENDANT'S NAME(S) AND/OR KIN #25-1628655 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 subject to 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 $5,337.24 L.L. Interest FROM DATE OF JUDG. (3/25/04) Arty's Comm $266.86 % Due Prothy $1.00 Arty Paid $218.20 Other Costs Plaintiff Paid Date: APRIL 1, 2005 CURTIS R. LONG Prothonot4ly (Seal) BY Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041