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HomeMy WebLinkAbout07-5127COURT OF COMMON PI.~AS OF CUMBERLAND COUNTY, PENNSYLVANIA / CIVIL ACTION -LAW BLUESTONE IlWESTMENTS, INC. Plaintiff No. 0'1- 51a~ GiYI l TerM vs. TIMOTHY HARRIS and JODI HARRIS CIVIL ACTION Defendant NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS 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 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, 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 AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND ASSOCIATES, P.C. By: ~~. Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 0 7 - ..5'/.z 7 ~'_c~! ~~ vs. TIMOTHY HARRIS and JODI HARRIS Defendants CIVIL ACTION COMPLAINT The above Plaintiff brings this action against the above Defendants to recover the sum of $21,252.30, with interest thereon as hereinafter stated, upon the following causes of action: 1. Plaintiff, BLUESTONE INVESTMENTS, INC., is a Pennsylvania corporation with a registered address of 3100 Old Carriage Drive, Easton, PA 18045. 2. Defendant, TIMOTHY HARRIS, is an adult individual located at 506 Grant Drive, Camp Hill, PA 17011. 3. Defendant, JODI HARRIS, is an adult individual located at 506 Grant Drive, Camp Hill, PA 17011. 4. At the special instance and request of Defendants, Bank One, N.A. issued to Defendants its Visa credit cazd, and from time to time thereafter, Defendants made various purchases, in which transactions Defendants made use of said Visa credit cazd. A true and correct statement of Defendants' account is attached hereto, made a part hereof and marked Exhibit "A." 5. For value received, Bank One, N.A. assigned, transferred and set over to Plaintiff all its rights, title and interest in this claim. 6. By virtue of said assignment, Plaintiff acquired legal title to Defendants' aforementioned credit cazd account and became the legal holder of the claim against the Defendants. 7. Defendants have not adhered to the agreed-upon repayment obligations that govern the aforesaid Visa credit card account, by reason of which Defendants are in default thereof. 8. Defendants received, accepted and made various purchases using the credit cazd described in Exhibit "A," and a total amount which became due as a result thereof, after allowance for all proper credits for payments and/or adjustments, if any, was $14,094.06. 9. Plaintiff is entitled to receive interest on the above amount determined by applying the agreed interest rate of 23.00% per annum to the past due balance. As of August 15, 2007 the total amount of interest due to Plaintiff is $7,158.24. 10. Plaintiff is entitled to have the 23.00% interest chazge continue to accrue, as set forth above, from August 15, 2007 on down to the date of judgment in this matter. 11. Plaintiff has made demand against Defendants for the aforesaid sum, but Defendants has failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against Defendants for $21,252.30 together with the continually accruing interest chazge at the agreed rate of 23.00% per annum from August 15, 2007, costs of suit and all other relief to which Plaintiff may be entitled. COUNT II Alternative to Count I -Unjust Enrichment 12. Plaintiff incorporates the allegations of every pazagraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 13. The goods, wazes, merchandise and/or services, described in the exhibits attached hereto were purchased by Defendants, and Defendants received and accepted the benefit of such goods, wares, merchandise and/or services provided by Plaintiff. 14. At all times material hereto, Defendants were aware that Plaintiff was providing the aforesaid goods, wares, merchandise and/or services to Defendants, and that Plaintiff expected to be paid for such. 15. At all times material hereto, Defendants, with the aforesaid knowledge, permitted Plaintiff to provide and/or deliver said goods, wazes, merchandise and/or services, and to incur damages. 16. At all times material hereto, Defendants were unjustly enriched by retaining the benefit of receiving said goods, wazes, merchandise and/or services without paying Plaintifffair and reasonable compensation. 17. By reason of the aforesaid unjust enrichment of Defendants at Plaintiffs expense, an implied contract exists between Plaintiff and Defendants, and Defendants are obligated to pay Plaintiff the quantum meruit value of the goods, wares, merchandise, and/or services described in the exhibits attached hereto, in the amount of $14,094.06. WHEREFORE, Plaintiff demands judgment against Defendants for $14,094.06 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from August 15, 2007, costs of suit and all other relief to which Plaintiff may be entitled. AMATO AND ASSOCIATES, P.C. By: ~~ C~ -~-- Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM B LUE ST ONE INVESTMENTS INC. 107 North Commerce Way Bethlehem PA 18017 CREDITOR NAME:. ORIGINAL CREDITOR: ORIGINAL ACCOUNT #: DEBTOR NAME: ACCOUNT NUMBER: DATE OPENED: DATE LAST PAID: PRINCIPAL: INTEREST: INTEREST RATE: TOTAL: STATEMENT OF AMOUNT Bluestone Investments, Inc. BANK ONE, N.A. 4366133034384775 TIMOTHY HARRIS and JODi HARRIS 1070583 11-195 3-11-05 $14,094.06 $7,158.24 23.00% $21,252.30 1 VERIFICATION Carrie Tobin, hereby states that she is the Financial Administrator of Bluestone Investments, Inc., Plalntiffin this action, and verifies that the statements made in the attached Complaint are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. CAut%s2~_ Carne Tobin {p, .3 ~-} c~. na ~ o v1 rt}~ ~"" T V '~ ~Q /~~ ~i! ~- ,- ~ -~ ~ , ~-~ !V ~~ r__. „~ C:'! ~t .... "< SHERIFF'S RETURN - REGULAR CASF~+NO: 2007-05127 P !~'"• COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BLUESTONE INVESTMENTS INC VS HARRIS TIMOTHY ET AL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HARRIS TIMOTHY the DEFENDANT at 1928:00 HOURS, on the 28th day of August 2007 at 506 GRANT DRIVE CAMP HILL, PA 17011 mT71R/~mTTV TTT 1'Yn T ['~ 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 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 00 q ~ l'~+0? ~-• 4 Sworn and Subscibed to before me this day So Answers: ~~ ~aE:~.."...P R. Thomas Kline 09/04/2007 ~MIlTCI f~ ~G~CIC'TATF.R By: of A.D. SHERIFF'S RETURN - REGULAR CASL-N0: 2007-05127 P L''" COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BLUESTONE INVESTMENTS INC VS HARRIS TIMOTHY ET AL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HARRIS JODI was served upon the DEFENDANT at 1935:00 HOURS, on the 31st day of August 2007 at 4415 CARLISLE ROAD GARDNERS, PA 17324 JODI HARRIS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 8.64 Affidavit .00 Surcharge 10.00 .00 a, 1y ~b~ ~v-' / 24.64 Sworn and Subscibed to before me this R. Thomas Kline So Answers: 09/04/2007 AMATO & ASSOCIATES day By: of A.D. ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 07-5127 Civil vs. TIMOTHY HARRIS and JODI HARRIS CIVIL ACTION Defendant PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enterjudgment by default for want of an answer in favor of Plaintiff and against the above-named defendant(s) only and assess damages as follows: Debt 521,252.30 Interest (from 8/15107 to 10/1 /07 at 23% per annum) 608.86 Payments 0.00 Total $21,861.16 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. Pursuant to RCP 237.1, I certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on September 21, 2007. Dated: 2007 AMATO AND AS CI~C. By: ~ Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 1070583 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff vs. TIMOTHY HARRIS and JODI HARRIS Defendant No. 07-5127 Civil CIVIL ACTION CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: C/O Amato and Associates, PC 107 North Commerce Way Bethlehem PA 18017 I do certify that the precise last known address of the within named defendant is: 506 GRANT DRIVE CAMP HILL PA 1701 1 AMATO AND ASSOCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 1610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 07-5127 Civil vs. TIMOTHY HARRIS and JODI HARRIS Defendant(s) T0: Timothy Harris 506 GRANT DRIVE CAMP HILL PA 1701 1 Date of Notice: September 21, 2007 IMPORTANT NOTICE YOU ARE IN DEFAl1LT 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 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 A LAWYER, 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 AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND ASSOCIATES, P.C. By: ~- Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File# 1070583 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 07-5127 Civil vs. TIMOTHY HARRIS and JODI HARRIS Defendant(s) T0: Jodi Harris 4415 Carlisle Road Gardners PA 17324 Date of Notice: September 21, 2007 IMPORTANT NOTICE 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 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 Y.OU DO NOT HAVE A LAWYER, 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 AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND ASSOCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File# 1070583 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff . vs. TIMOTHY HARRIS and JODI HARRIS Defendantls) . No. 07-5127 Civil CIVIL ACTION AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that the above Defendantls) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act of 2003; That Timothy Harris is over 18 years of age, resides at 506 GRANT DRIVE, CAMP HILL PA 1701 1 and is employed; That Jodi Harris is over 18 years of age, resides at 506 GRANT DRIVE, CAMP HILL PA 1701 1 and is employed; Sworn to and subscribed before me this '~'^ day of Cwj 2007 A. D NOTAR PUBL N07ARIAL SEAL GEOFFREY G SCHOENECK p,r.r ~=~„~t fie `!-tAMPTON CNTY HANOVER TO~'v E ° , ~y~ar 29, 2008 r -- f: : Y ~ o ~ }`C` ~ ~ . ~ 7 •.~ T ~., ~ 0 ~~, l ~ r e r I r~ ' _-0 O ` D r - S D V ~ ~ -'.. ` .~ + ~=i ~ ~~.: - .,,_ .-~'' `, •{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 07-5127 Civil vs. TIMOTHY HARRIS and JODI HARRIS CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF 521,861.16 ON GLI~ ~ , 2007. ( - A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY -CUMBERLAND COUNTY Is~ n ~lc.$ ~• ~ Alc.[i If you have any questions concerning the above, please contact the undersigned. AMATO AND AS CIAT S, P.C. By: __ Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 1610) 866-0400 A DEBT COLLECTION LAW FIRM ~ . _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff vs. TIMOTHY HARRIS and JODI HARRIS 504 6 rant Drtve 44~It P A t'7 t o / No. 07-5127 Civil PRAECIPE FOR WRIT EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary -Cumberland County: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendants} Afl cash on hand or in the possession of the defendant(s). accounts receivables, furniture, furnishings, eauipment. inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to the above- named defendants. SPECIFIALLY, THE 2003 JEEP LIBERTY. 12) against TIMOTHY HARRIS and JODI HARRIS, Defendant(s) 13) and against ........................................Garnishee(s) (4) and index this writ (a) against ..................................Defendant(s) and (b) against .......................................Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishees} as follows:(Specifically describe the property) (5) Amount Due S 21,861.16 Statutory Interest From October 4, 2007 S 586.42 Less Payment S 0.00 Costs S Poundage S Total 5 22,447.58 AMATO AND ASSOCIATES, P.C. By: Date:March 14, 2008 Ronald Amato Attorney I.D. No. 32323 Attorney File#: 1070583 Attorneys for Plaintiff ! ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff vs. TIMOTHY HARRIS and JODI HARRIS Defendant(s) No. 07-5127 Civil CIVIL ACTION CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE I do certify that the precise last known address of the within named defendant(s) is the address provided below, and request that the Sheriff serve the above named defendant(s) at: 506 GRANT DRIVE CAMP HILL PA 17011 AMATO AND ASSOCIATES, P.C. By: Dated:March 14, 2008 Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File #:1070583 ~ 9.s .~ o~o~~.9u ;~ C"- ~ ~3 . pO O o p~ to O (n S O ~, 1 S s r g~ r~, n D ~ ~ - -^-S C= s , C1 a - ? ~ ~ _ ~ : -c _-~ ~.. -= ~i "'~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-5127 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BLUESTONE INVESTMENTS, INC., Plaintiff (s) From TIMOTHY HARRIS and JODI HARRIS, 506 Grant Drive, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the possession of the defendants, accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, and and all other personal property belonging to the above named defendants, SPECIFICALLY, THE 2003 JEEP LIBERTY. . (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 $21,861.16 Interest from 10/04/07 -- $586.42 Atty's Comm Atty Paid $186.04 Plaintiff Paid Date: 3/24/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs Curt's R. Long, o ota By: Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATU AND ASSOCIATES, P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 R. THOMAS KLINE Sheriff EDWARD L,SCHORPP Solicitor ~°~`'~t~ of ~un~~Prt~ '~d OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 05/29/08 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant Bluestone Investment, Inc. vs Timothy Harris & Jodi Harris Writ No. 2007-5127 Civil Term Property Claim Determination Dear Sir, ~ ~.~, ~7i ~~ ~ ~ ~~ Reference is made to Property Claim dated May 19, 2008, entered ~ ' ~" z by Jeffrey A. Johnson, pertaining to Writ of Execution No. 2007-5127 "' ~ .~- Civil Term, Bluestone Investments, Inc. -vs- Timoth Harris & Jodi Harris. ~'_ Y _ t~~ ~~= t!v ~ vim'' R. Thomas Kline, Sheriff, has determined that the claimant, Jeffrey A. Jol~on, -• -+ in the above mentioned property claim, is the owner of the property set forth ther ~ ~ So Answers: ~~~"~~rl~/llC .~ Thomas R. Kline, Sheriff cc Ronald Amato, Atty for Pltff Timothy Hams, Deft Jody Harris, Deft. Jeffrey A. Johnson,Claimant PfiOPERT~' C~,AIM In the Court of Common Pleas of Lp Cumberland County, Pennsylvania bLUFSTaNE ~ruVE-S'f MC--~~IINC. Writ No. ~ ~ ^ S I a~ VS ~ tI L.~ ~~ n~ o ~ }i `1 ~' V Q ~ I ! 1 fi'ft-~ S TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANTA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE New ~'1~~-~PrNa ~'2~~ Moor 708 ~ yL300961 $ `t,oOU,00 L.U ~ `fl-~C'f ~D I ~r IiOUN"IYLY ~j X, I /q'"TV ~ 5~ QQQ~ d 0 L.~ylnrCr t2acM - Ck~,~ ; ~ 5a.ao - E,..u 1~r~ ~ a5 . a U (`1~Se, TV2NiT7l2~ ~ 300, QO - ~~~-r,~u.ES ~` So. QG - rELE ~IS~a~ _ ~ aoa. ~b - ,pyD / VCS. ~ ioa.o© .Q, N ~ ~, o.. ~Q ~, - ~~ ~ ~ -5 0. Qd I "lz N I ~r$t.6 < CN m-rt~S '~ (S U. OU ~ ~ ~ IC/1'L1Jw~tV6 ~ ~S. Od THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: Date ~ - ~ q - Q g Claimant State. of Pennsylvania: Courtly of Cumberland U L~ V c1 ~,Ey ~~~a>t.NSo'*~ being duly s o c ing to la deposes and says that the above list in the property claim are correct and true. ~~ Sworn and subscribe to before ~~e~ ~~,,.,, ~'----day of Q ~Oo C ~ t Notary Pub is NOTARIA~_ SEAL ~ CtAlJDiA A. BREWBAKER, NOTARY PUBl1C y'~ ~ C~-`Il-I-ISLE. ' Carlisle 8oro. Cumberland County coos Gr~N~.s, ~~ I'73 ~~f Q ~c-~rr~~ y .. ~T . _ ~~~ ...gym?--~. ` ' °%' ~~// t' ~a751 ~~S~Bow~s #dQ0.0U - ~c-~~~~.~ ~ goo, op - S,~„E '~ 3 d a, o 0 - ~~Sr+wA~Sri~ $ 15a, 00 - CODE ~ar ~ 1 U. ~~ - TP~s~-E2 $ a.5, 00 ~~Q.aoM # I - ~~ ~' 1, 000, OU - L,rrMPS ~ ioo, 00 - N~c~-tr~,i-,~D $ X00, 0 0 ' 1 EzC-Pr>-~ F ~ 15, 00 - Co r, Qum ~ ~~.~ +~&~ ~ ~UQ~ GQ llE~J lLaar~ ~' 3 _ BCC $ 3QO, 00 -.Qrr~-~sc-rL $ aoo . av I~~e.o~~, ~~ - 6~ ~ roo, 00 -- .~ ~ss~ ~ ~ 5 0, od - LTM P ~ as . o 0 -- (~„~ ~ 15.40 - Qu-R-E~v ~ S, OU -- 2,~,, o ,$ ao, o v r so, o0 -- S p~,~Tr Nc- E~u~ A, ~ r, ao o , o a -Taco-s ~ 54o.ao '~2aPEYLTy V R-Lr~E ~ . '~' yVoo,p S1~vES ~~~ _ M Q~NTfi N ~- K-~ M-SC.~..~hNc-pus - .~~r- ~a F~,~ _ N~~- - v 5 66Q G2~w ~ $oo.oo ~ 3oa.oa ~ 6aa~ 00 ~ aoo. 00 ~ 3, aoo, 00 ~ laa, acI ~~ 1 !~~- (\Y~1/{\~/' 1l~/~`n/~~ _. V~j/, Y~ ~h t ~~: ~,A` 4 R. THOMAS KLINE Sheriff EDWARD L:SCHORPP Solicitor of ~untbPrt~ ~d ~°~`~t~ OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 06/12/08 Bluestone Investments, Inc. vs Timothy Harris & Jodi Hari' Writ No. 2007-5127 Civil T Property Claim Determinati Dear Sir, Reference is made to Property Claim dated June 2, 2008, entered by Cher D. Conley, pertaining to Writ of Execution No. 2007-5127 Civil Term Bluestone Investments, Inc. -vs- Timothy Harris and Jodi Hams. RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant n ~= ~a m O -ri ` ~ ~' r-~ `-- ~ ~ ~ r~- - a -~ n ~~ , c ~ ~ :~; ~t ~' ~- v? cn cn ~~ R. Thomas Kline, Sheriff, has determined that the claimant, Cher D. Conley, in the above mentioned property claim, is the owner of the property set forth therein. So Answers: ~i~~s/~'~wrC~~.l Thomas R. Kline, Sheriff By cc Ronald Amato, Atty for Pltff Timothy Hams, Deft Jodi Harris, Deft. Cher D. Conley, Claimant PROPERTY CLAIM ~[ra~~-I-o~ ~n ~ps-Frn.~.l~-s vas ~ , c r~S TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, P+-e7nnsylvania Writ No. ~ d ~ ! "" 502.7 The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof aze: LIST OF PROPERTY VALUE -~~- _(R- fF FF~ FFl ~~ , ~ ~ - ~ ~ ~ Kack ~ - r~a~ k tuood -lay I ti~rcnri Gamin 2.50 . as ~ j ~ ' ,~ol~.W~~ C'~t~-r~a,rk u r~ -lav 1 i ~~rla I~o-I~n 3 sa N+ Date Claimant State. of Pennsyly ' . County of Cumberland • I being duly sworn rding to law, deposes and says that the above list in the property claim aze correct and Sworn an subscn to before e / da of 8 ~ Claimant JD.T~II11.~ii~ - - ~d ~p ~V~ dJ ° DIA A. BREWBAKER, NOTARY PUBUC Carlisle Boro. Cumberland County ~ /~ /, ly Commission Expires April 4, 2009 ~~~~ "7' ~ l ~ ~ ~ 7d /3 K.f ~ - 11761 ~ I Y1~O ,YYI - .I P7,1 /101-i1 ~ e nnrt ln.. r ~w than UUU THE CLAIlVIANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: '~"aihR,y, a,,~ h1 win; - aid/c~~-e~v zoo ~ kl~ - ~CtT - ~zQap-~terly -VR~u,+~an.6yw IO~~aa 0 Krr - YKi.~c... ~~-~ -ao.o-o st TV - ~5~ B~ - ~J'tc~c.~t. ~ lucre-~ ~ uili~tx, ~ $~ `°~' ~~- ~ed-0:,~~.r1~/P~~~~-,~ 400.E ~~ $ED- r~ ~ndv4aA- Y~~~ aat~ ~ ~ ~~o?o l-dlu,adu/miM~U z~ ems- - ~~bi~1- A~-~ ~ ~-~ ~ccl 13E1J - ~r `w:w ~ ` {70.. AA a"~ 6~i~Q.t.. ~ U~~ ~p0 .aD 2~ BED- s~Pl~ CJ~9XY1 , Dk~n.a~ ~~ oa DJD, C~ ~ ppeaJc~n.~ au~i~E - SrnaD~. ~o.~Q.-~-~p so ~ DuTs~f~- ~RAe- ~ ~ ~jOp.oa ~ s =o~ d z - Nn~ $aaz ~.~ yv R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. 6""'"`~~~~. ~R,..( Jam., ~:• ~7~ L=.:.`~ Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Milage Surcharge Levy Certified Mail Post Pone Sale Garnishee Bad Check Postage Total 18.00 1.69 .50 2.00 23.00 30.00 40.00 115./` / ~;~ 9/0 9 ~„ Advance Costs: 150.00 Sheriff's Costs: 115. i9 0~ ,~y C~,.~.., 34.g~ Refunded to Atty on 1 /20/09 So Answers; ~~~~~ ~ R. Thomas Kline, Sheriff '~, ~~~~ y Claudia A. Brewbaker c: ~ ; c= ~ ;ti -;- ._ c_ a ' ~ rc7 r - c~3 ~i' .. ~ -_N~~. ... ~. + L 7 ~~J.. .__ ~' ,~T~ -~-' ~tl G3 fi ~~ d S Z ~~J6J 8001 ~` ~:. , ~~:_, . ~~ ~ ~ ~.J 0 v t.s .s ~k. ~ ~ ~~ 3 a2~,~. ~ ~ o a ~Y' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-5127 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BLUESTONE INVESTMENTS, INC., Plaintiff (s) From TIMOTHY HARRIS and JODI HARRIS, 506 Grant Drive, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the possession of the defendants, accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, and and all other personal property belonging to the above named defendants, SPECIFICALLY, THE 2003 JEEP LIBERTY. . (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 othentivise 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 $21,861.16 Interest from 10/04/07 -- $586.42 Atty's Comm Atty Paid $186.04 Plaintiff Paid Date: 3/24/08 L.L. $.50 Due Prothy $2.00 Other Costs Curtis .Long, Pro of (Seal) By: Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOCIATES, P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323