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HomeMy WebLinkAbout07-6249Robert D. Kodak, Esquire Supreme Court I.D. 18041 KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, PA 17108-1848 717-238-7152 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Pennsylvania State Bank PENNSYLVANIA STATE BANK, IN THE COURT OF COMMON PLEAS Division of BLC BANK, N.A. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. WILLIAM J. KALDES Defendant : CIVIL DIVISION -LAW : NO. 6'7- `zZq 9 21?A"_? 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, 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 TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 PENNSYLVANIA STATE BANK, IN THE COURT OF COMMON PLEAS Division of BLC BANK, N.A. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL DIVISION -LAW WILLIAM J. KALDES :NO. d7- 6 Z y 9 ?'+-"`'P Ali'"' Defendant COMPLAINT The Plaintiff, Pennsylvania State Bank, Division of BLC Bank, N.A., by its attorneys, Robert D. Kodak, Esquire, Kodak & Imblum, P.C., brings this action of Assumpsit against the Defendant to recover the sum of Six Thousand, One Hundred Forty-Seven Dollars and Sixty Cents ($6,147.60), along with interest thereon at the rate of 9.900% from October 1, 2007, upon a cause of action of which the following is a statement: 1. The Plaintiff, Pennsylvania State Bank, is a financial corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 2148 Market Street, Camp Hill, Cumberland County, Pennsylvania, and is a Division of BLC Bank, N.A.. bj :comp:kaldes.wpd:29Nov06 2. The Defendant, William J. Kaldes, is an adult individual residing at 5908 Stephens Crossing, Mechanicsburg, Cumberland County, Pennsylvania 17050. On or about April 11, 2007, Defendant did enter into a Promissory Note with Plaintiff for the purpose of obtaining a loan. A true and correct copy of said Promissory Note is attached hereto, marked as Exhibit "A" and made a part hereof. 4. The Defendant is indebted to Plaintiff in the principal amount of Four Thousand, Eight Hundred Sixty-Nine Dollars and Twenty-Nine Cents ($4,869.29) as of October 1, 2007. 5. Due to Defendant's default in payment of said amount due and owing as aforesaid, and in accordance with the terms and conditions of the Promissory Note attached hereto as Exhibit "A" and made a part hereof, interest has been added to said account in the total amount of Sixty Dollars and Seventy-Five Cents ($60.75), as shown on Exhibit "B" attached hereto and made a part hereof. 6. Due to Defendant's default in payment of said amount due and owing as aforesaid and in accordance with the terms and conditions of the Promissory Note attached hereto as Exhibit "A" and made a part hereof, late charges have been added to said account in the total amount of One bj:comp:kaldes.wpd:29Nov06 2 Hundred Ninety-Two Dollars and Ninety-six Cents ($192.96), as shown on Exhibit "B" attached hereto and made part hereof 7. In further accordance with the terms and conditions of the Promissory Note attached hereto as Exhibit "A" and made a part hereof, Defendant is liable for attorney/collection costs and fees which have been added to said account in the amount of One Thousand, Twenty-four Dollars and Sixty Cents ($1,024.60).. 8. The balance due and owing by Defendant to Plaintiff is the sum of Six Thousand, One Hundred Forty-Seven Dollars and Sixty Cents ($6,147.60). 9. All payments made by Defendant have been credited to the account which is the subject of this pleading. 10. Plaintiff has demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof bj:comp:ka1des.wpd:29Nov06 3 WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of Six Thousand, One Hundred Forty-Seven Dollars and Sixty Cents ($6,147.60), along with interest thereon at the rate of 9.900% from October 1, 2007 Respectfully submitted, Harrisburg, PA 17108-1848 (717) 238-7152 Fax: (717) 238-7158 email: robert.kodak@verizon.net Attorney ID No. 18041 Attorney for Plaintiff bj:comp:kaldes.wpd:29Nov06 4 Post Office Box #11848 OCT-12-2007 09:57 B.L.C.EKING ST.BRANCH 717 396 7510- P.03/04 PROMISSORY NOTE Rrlaelyal Loan Oats oan into Zip I Ccii Ammnt 101"C a 57 300.00 0&11.2007 10-11-2007 7130001 aZS An 2741 Relarenees in the shaded area are for Landers use only and do not limit the 4p icabdsy of rm document to any particular loan or Item Any item above contairim ""' has Liam omitted due to text length fimmilms Borrower: wnuam J Kaldse Lender: Pennsylvania State Bank SON staphens Crossing Camp Hill Offlos IMeciwnicebutp. PA 17050 2148 Market8veet PO Box 487 Camp Hill, PA 17011 Principal Amount: $7,500.00 Interest Rate: 9.900% We of Note: April 11, 2007 PROUSE TO PAY, I ('Borrower") promise to pay to Pennsylvania State Bank ('Lander"), or order, In lawful money of the United States of America, the principal amount of Seven Thousand Flea Hundred 6WOO Dollars ($7,500.00), togetheawith alder stte terms andof SA poi annum on the unpaid principal balance from April 11, 2007, until paid In frill the Interest rote may n9 the 'INTEREST AFTER DEFAULT" section PAYMENT. I will pay this loan in 5 payments of :1,286,42 each payment and an rreguk r Inst payment estimated at III j21116.31. My first pay+nnt>< is due I1Aay 11, 2007, and all subsequent payments are due on the same day at each month sftm that. My finial payment will be due art Octaber 11, 2007, and will be for all principal and an accrued interest not yet paid. Payments Include principal and Interest. Unless otherwise agreed or required by applicable law, payments will be appNed to accrued unpeld Interest; then to any unpaid voluntary credit Insurance prentlums; then to principal; these to any unpaid collection comb; and then to any late charges. Interest on this Make Is carnputsd on a 386 366 simple Interest basis; that It, by applying the raft of the annual Interest rats over the number of days in a year (366 during loop years), multiplied by the outstanding principal balance. multiplied by the aebtsl number of days the principal bWanee is outstanding. I will pay Lender at Lender's address shown above or at such other plan as Lender may designate In writing. PREPAYMENT. I may pay without penally all or a portion of the amount owed oadmr than it is due Early payments Will not, unless agreed 10 by Lender in wrding, relieve we of my obligation to conbmm to make payments under the payment schedule Rather. early payments will reduce the principal balance due and may result in rry malcrng lower payments. I agree not to send Lander payments marked 'peed in full'. 'without recourse', or similar language It I send such a payment Lender may accept n without losing any of I~* rights under this Note, and I will remam obkgated to pay any further amount owed to lender All written n full o? amount o owed disputed or thaAm tendered ts, uwin other check or conker other I ay gent instrume full that indicates that the payment constitutes 'payment satisfaauon of a disputed amount must be marled or delivered to Pennsylvania State Bank, 2148 Market Street Camp Hill. PA 17011 LATE CHARGE If a payment w 16 days or more late, 1 will be charged 5 0W1. of the unpaid portion of the regularly scheduled payment or $10.0. whichever is greater. INTEREST AFTER DEFAULT. Upon default, including failure to pay upon Mal maturity, the total sum due under this Note wig continue to accrue interest at the interest role under this Note K Judgment is entered in connection with throe Note, interest wit corMnue to accrue after the data of judgment at the rate in effect at the time )udgmant is entered DEFAULT. i will be in default under this Note d any of the following happen Payment Default. I fart to make any payment when due under Iho Note Break Others Promises. I break any promise made to Lender or fart to pwlwm promptly al the time and strictly in the manner provided in the Note or in any agreement related to this Note, or in any other agreement or ban I have with Lander False Statements. Any representation or statement made or furnished lo Lender by me or on my behalf under this Note of the rotated documents is ate or moloading in any material respect, ehWe? now or at the tuts roads or fumished Death or Insolvency. Any Borrower dies or becomes insolvent, a receiver is appointed for any pan of my property, I matte an assignment for the benefit of creditors, or any proceeding is commenced eN1nr by me or against ma under any bankruptcy or insolvency laws Taking of the Property. Any creditor or govurimenW agency lines to wino any of the property or any other of my property in which Lander has a lien This includes taking of, garnishing of or levying on my accounts wdh Lander However, ri i dispute in good fair[ whether the clam an which the taking of the property is based is valid or reMcnifible, and d 1 give Lender wnuon notes of the claim and furnish Lender with monies or a Surety bond sabstectory to Lender to satisfy tha claim, than this default "ision will, not apply Events Affacting Guarantor. Any of the precedshg oventa occurs with respect to any guarantor, endorser, surety, or acdxmmodaoon parly of any of the indebtedness or any guarantor, andomer, surety, or acaortvnodauon parry dies or becomes incompetent. or revokes or dapufss the validity of, or Irabrlry under, any guaranty of the indobtedneaa evidenced by this Note LENDER'S RIGKTS. Upon default, tender may. after giving such nat ess d required by "cable law, declare ft entire unpaid principal balance under this Note and all accrued unpaid interest immediately due, and then I will pay that amount ATTORNEYS' FEES; EXPENSES. Larder may hue or pay someons sibs to help collect this Note d 1 do not pay I will pay Lender that amount This includes, subject to any limits under spplicade law, Lender's attomeys' leas and Lender's legal expenses, whelhar or not there is a lewsud, including attorneys' fees, expenses for bankruptcy proceodnga (tncludng efforta to modify or vacate any automata; -stay or injunction), and appeals It not prohibited by applicable law, I also will pay any court costs, in addition to all other mums provided by law GOVERNING LAW. This Note will be governed by federal low oppillable to Lender and, to the wdent not preempted by federal law, rttle on of the Commonwealth of Pennsylvania without regard to Its conflicts of low pmAslona. ThIa Note has beefs accepted by L CommonwealMt of Pannaylvanla. CHOICE OF VENUE. R there is a lawsuit, t agree upon Lenders request to submit to the lunsdWtion or the courts of Cumberland County, CornrranweaMh of Pennsylvarra DISHONORED ITEM FEE. I will pay a too to Lander or 51 ri 00 d I make a payment on my loan and the check or peauthorrted charge with which I pay is later dishonored RIGHT OF SETOFF. To the extent permitted by spplrceble law, Lander reserves a right of setoff in all my accounts with Lander (wrwtnsr choolong, savings, or some other account) The includes ail erzounts I hold lofty wdh someone also and all accounts I may open in Rte future. However. MIS does not include any IAA or Keogh accounts, or any true be prohibrlad by law 1 Authorize Lender, o the extent pormated by applicable taw, to charge or setoff at sums Id ov such accounts. OCT-12-2007 09:5e B.L.C.EKING ST.BRANCH 717 395 7515 P.04/04 PROMISSORY NOTE (Continued) Page 2 COLLATERAL This ben Is unsecured. SHARING INFORMATION WITH AFFILIATES AND OTNEAS. Under die Fair Credit Reporting. Ad, we have the right to shire IntrinHI rt about our experiences or Ireroectwns won you. Lima" you vmb' cl othemee, we also have the right to share any attwr iriforrriatxxi about you with any of our aft wdrj (persons related by corriyrion ownership or ai iilmted by corporate control, now or in fire future) smear dlrecdy of for example, through a central database This other mforrnetion may include but is not limited to application iMorrnahon, credit repot from consumer reporting agencies, and any otter inivmmoon we have afoul you If you do not went us to share VMS other rdomtatron with 04 affiliates. you can direct us rid to by w" to us at ice addross shown at the begsnkig al this Agreement USE OF INSURANCE RELATING TO YOUR LOAN. THE BORROWER HERBY CONSENTS TO THE USE OR SMARING OF ANY INSURANCE COVERAGE INFORMATION OBTAINED AS PART OF THE LOAN PROCESS IN THE MARKETING OF INSURANCE OR ANNUITIES SUCCESSOR INTUREM The terms of this Now ahall be boding upon me, and upon my heirs, personal representatives, successors and assigrs, and Shall inure to the benefit of Lender and da successors and asslgrrs GENERAL PROVISIONS, N any part of M Note cannot le enforced, airs fact will not affect tits rest of the Note Lender may, delay or forgo anforong any of its nghts or wriedies undar the Note without lasing them. 1 and any other person who signs, guarantee or endorses fns Note. to the extent allowed by law, waive presentrnenl, demand for payment, and noece of dishonor Upon any change in the temm of this Note, and urilmr. olhermse expressly stated n wnung, no party who signs this Nate, whielher nor maker, guarantor, accionvnodation rttsker or endorser. shall be released trom Oabilr y Alt such patois agree that Lender may renew or extend (repeatedly and Kor any length of mite) this loan or release any OM or guarantor or cdtateml, or impair, fad to realize upon or perfect Lender's security inWitmat in fife collatmal. All such parties also agree that Lender may modify this loan without tree owmernt of or notice to anyone at tier man 9* poly with whorn the rnodr("bon is made. The obligations under this Now are prit and several The means Viet die words 111, 'me", end 'my' mean each" all of the persons sigrung below. PRIOR TO SIGNING THIS NOTE, I READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE. I AGREE TO THE TERMS OF THE NOTE I ACKNOWLEDGE AECE7PT OF A COMPLETED COPY OF TKS PROMIISSORY NOTE THIS NOTE M GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS NOTE iS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW. BORROWER- x SU9 Wdlrarh J Kaldea IJ/OI AO IAa V. 1 t-om aw Z? N eM, %? • M Nd11Y?lm 1E 'AHm oft- TOTAL P.04 OCT-12-2007 09:57 B.L.C.EKING ST.BRANCH A9^6h Pennsylvania State Bank October 2, 2007 Kodak & Imblum, P.C. Cameron Mansion 407 North Front Street P.0. Box 11843 Harrisburg, PA 17108-1848 RE: Willian? J. Kaldes(Pennsylvania State Ban)r) Dear Kodak & Imblum, 717 396 7518 P..02i04 Please start legal litigation- Customers loan has matured. Thank you. Mailing Address Collateral Address 5908 Stephens Crossing Same Mechanicsburg, PA 17050 ACCOUNT INFORMATION ...7150001426 Account # ...........•.... .......... .... April 11, 2007 Date of Loan ....................... ....... ....October 11, 2007 maturity Date ...................... ... •.....$4,869.29 Principal Balance .............••••• . ......$5,123.00 Net Payoff ......................... ........••• d Daily E . •••-••'$1'32 ... arne Interest .$60.75 Delinquent Interest .............. . ...... 869.29 $4 Delinquent principal ............... , ....... ...$0.00 Delinquent Escrow .................. .... $192.96 Late charges owing ................. ....... ..... 55,123.00 Total Delinquent ................ ... . .. .......July 11, 2007 Past Due Date . . . . . . . . . . . . . . . . . . . . . ... . October 11, 2007 Next Due Date ...................... ... .Unsecured Security ..... .................... .... .. Please call me at 711-735-5712 it you have any questions- Thank you for your cooperation in this matter. re imberly Martin Loan Adjustor DCT-22-2007 15:48 B.L.C.EKING ST.BRANCH 717 395 7518 P.02i04 'V IFICATI N 1, DAVID W. PREVOST, Vice-President/Special Assets . STATE BANK. Division of BLC BANK, N.A.. verify that the stat document are true and correct. I understand that false statements penalties of 18 Pa. C. S. §4904, relating to unswom falsification toy Of PliNNSYLVANIA made in the aforegoing are made subject to the PENNSYLVANIA SATE BANK, Division of BLC A MlK, N.A. V David W. Prevost Vice-President/Speci i Assets Officer bated: 14 4 tJ.comp:kaldcs.%vpd:29Nov06 TOT1lL P . 07 t\ r N - l C7 r?} Cn q- 5-1 t rn PENNSYLVANIA STATE BANK, : IN THE COURT OF COMMON PLEAS Division of BLC BANK, N.A. : CUMBERLAND CTY., PENNSYLVANIA Plaintiff vs. : CIVIL DIVISION -LAW WILLIAM J. KALDES NO. 07-6249 CIVIL TERM Defendant TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) WILLIAM J. KALDES, 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 Plaintiff's Complaint $6,147.60 Interest at the rate of 9.90% per annum from October 1, 2007 126.80 Total = $6,274.40 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. KODAK & , P.C. By Robert D. Kodak, Attorney for Plaintiff DATED:") EC. 19, ;Z607 Judgment entered and damages assessed as above. r/ 0 01-4 Pr onota LAW OFFICES OF KODAK & IMBLUM, P.C. Robert D. Kodak CAMERON MANSION Gary J Imblum 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 kkLL w®verizonnet December b, 2007 WILLL4?M J KALDES 5908 STEPHENS CROSSING MECHANICSBURG PA 17050 L E F I . one 7159 C a 717.238.7158 RE: Pennsylvania State Bank, Division of BLC Bank, N.A. VS: William J. Kaldes No. 07-6249 Civil Term, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 3-07-0209 Dear Mr. Kaldes: 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 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, KODAK & IMBLUM, P.C. Robert D. Kodak THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/kqb enclosure cc: KIMBERLY MARTIN LOAN ADJ STERLING FINANCIAL SERVICES 949 EAST KING STREET LANCASTER PA 17602 o u rr+r t , f..?, 47, 01] a PENNSYLVANIA STATE BANK, : IN THE COURT OF COMMON PLEAS Division of BLC BANK, N.A. : CUMBERLAND CTY., PENNSYLVANIA Plaintiff vs. : CIVIL DIVISION - LAW WILLIAM J. KALDES NO. 07-6249 CIVIL TERM Defendant TO: WILLIAM T. KALDES, Defendant(s) You are hereby notified that on -i)c r , 206 the following (Judgment) has been entered against you in the above-captioned case. Tudgment entered in the amount of $6,274.40. DATE: I a1 4 O ? ZIA "Ivw ',kYr ZVO-C'"" Pr . onotary I hereby certify that the name and address of the proper person(s) to receive this notice is: WILLIAM J KALDES 5908 STEPHENS CROSSING MECHANICSBURG PA 17050 C C Q rri .. C-) rn 4 YJ r--X 4=.. ?? _ ILI C- t r n y c-n CZ) y 1 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06249 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNSYLVANIS STATE BANK VS KALDES WILLIAM J WILLIAM CLINE Sheriff or teputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KALDES WILLIAM J the DEFENDANT , at 2053:00 HOURS, on the at 5908 STEPHENS CROSSING MECHANICSBURG, PA 17050 WILLIAM KALDES a true and attested copy of COMPLAINT & N Ct 8th day of November , 2007 by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.56 Postage .58 Surcharq? 10.00 `b1 .00 ,3 tat ?? 39.14 Sworn and Subscibed to before me this day of , So Answersl,: >11 R. Thomas Kl 11/13/2007 KODAK & IMBLUM By: A. D. PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 PENNSYLVANIA STATE BANK, IN THE COURT OF COMMON PLEAS OF division of BLC Bank, N.A. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs $ 1N11S ? WILLIAM J. KALDES Vg p 1 0 efendant V PENNSYLVANIA LIQUOR CONTROL BOARD ROOM 401, WEST NORTH BLDG HARRISBURG, PA Writ No. Term 20 No. 2007-6249 CIVIL Term 2007 Amount due $ 6,274.40 Interest @ 9.9% FROM IDMT 12/19/07 -7/30/08 $ 365.92+ Interest rate = $1.73 PER DIEM Atty's Comm. $ 313.72 Costs to be determined $ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of DAUPHIN County, Pennsylvania (2) against WILLIAM J. KALDES een ans; (3) and against PENNSYLVANIA LIQUOR CONTROL BOARD arrus ee s ; (4) and index this writ (a) against WILLIAM J. KALDES een ans;a (b) against PENNSYLVANIA LIQUOR CONTROL BOARD arms ee 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 ONLY ON THE ABOVE-LISTED DEFENDANT(S) PENNSYLVANIA LIQUOR CONTROL BOARD LICENSE NO. E986, LID NO. 5410, ISSUED TO WILLIAM J. KALDES T/A THE SPOT, WHICH IS BEING HELD FOR SAFEKEEPING AT THE ADDRESS OF THE PA LIQUOR CONTROL BOARD, ROOM 401, WEST NORTH BUILDING, HARRISBURG, PA. (5) Exemption has (not) been waived. Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Dated 7/30/08 Attorney For Plaintiff(s) '(o)fiOTE aTng aag •paz T.Sap sT suapuad STT B SV buTxapuT PUP pago27171P ST eagsTuzLb aqa ;o awau ag71 uT A71iadoid T29z 3T ATuo pagaTdwoo aq pTnogs (q)({,) gdazb2zad (q)bOiE aing aag •Aavjouogjosd a- Aq A71unoo 71aq; uT asanoo ;o se paaTnbaz ST buTxapuT Aaunoo zag71oua o71 sanssT 71T-Im aqa uagM (v)ioEE aTng Aq pazT.zog71np SP pazTSap ST 'aouaanssT ;o A71unoo ag71 uT suoT71noaxa ag71 ;o buTxapuT ;T ATuo pagaTdwoo aq pTnogs (P) (V) gd2sbazed (71TzM 91471 UT papnTouT 9q 071 ST aagsruavb paweu a uT ATuo pagaTdwoo aq pTnogs anoga) (E) gdPa6vavd 'panssT goTgM uT A71unoo ag71 3o ;;Taags aqa o71 ATuo pa;oaaTp aq Aew 71uawbpnC paaaa;suval a uo panssT 71T-IM 2 (o)£OT£ aTng zapun •pa712oTpuT aq pTnogs A71unoo ag71 I(q)£OT£ 9Tnu Aq pazT.zog71ne se A71uno0 i9g71oua 90 ;;TZags a1471 071 pa7109.zTp ST ITam aqa uagM (T) gdva5vard aapun 211014 I NJ 0 0 N N H v H u 14 0 0 N 1M O W Q a a O F-+ W ? va o w ;wq v v u o 0 W 4-4 z 'C z 4 U) co U o od p p g 0 0 in .c l 3 a A-t b C... F"i i. ,l., WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6249 Civil CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due PENNSYLVANIA STATE BANK, division of BLC BANK, N.A., Plaintiff (s) From WILLIAM J. KALDES, 5908 Stephens Crossing, Mechanicsburg, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PENNSYLVANIA LIQUOR CONTROL BOARD, Rm 401, West North Bldg, Harrisburg, PA levy on above-listed defendant Pennsylvania Liquor Control Board License No. E986, LID NO. 5410, issued to William J. Kaldes t/a THE SPOT, which is being held for safekeeping at the address of the PA Liquor Control Board. 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 $6,274.40 L.L. $.50 Interest @9.9% from JDMT 12/19/07 - 7/30/08 - $365.92 Interest rate = $1.73 per diem Atty's Comm % Due Prothy $2.00 Atty Paid $158.64 Plaintiff Paid Other Costs Date: 7/31/08 (Seal) S " R. " a twkis R. Long, Prothonotary By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: KODAK & IMBLUM, PC CAMERON MANSION 407 NORTH FRONT STREET PO BOX 11848 HARRISBURG, PA 17108-1848 Attorney for: PLAINTIFF Telephone: 717-238-7152 ?" Supreme Court ID No. s Robert D. Kodak, Esquire Supreme Court I.D. 18041 KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, PA 17108-1848 717-238-7159 Fax: 717-238-7158 email: robert.kodak@kodak-imblum.com Attorney for Plaintiff PENNSYLVANIA STATE BANK, Division of BLC Bank, N.A. Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6249 CIVIL WILLIAM J. KALDES Defendant V. PENNSYLVANIA LIQUOR CONTROL BOARD Garnishee PRAECIPE TO THE PROTHONOTARY: Please file the attached Return of Service from the Dauphin County (PA) Sheriff to the above term and number. TO Cumberland County Prothonotary Dated: August 18, 2009 Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041 Personal Property FACE SHEET File # Case Number Document Type Bankruptcy Case Number 2008-CV-09795 WRIT OF EXECUTION Received From: County Date Received: 8/6/2008 Date Expires: 11/6/2008 No Defendant(s)' Name: WILLIAM J KALDES Current Physical Address: 5098 STEPHENS CROSSING MECHANICSBURG, PA 17050 Primary Plaintiff(s) Name: PENNSYLVANIA STATE BANK DIVISION OF BLC BANK NA Attorney: ROBERT Firm: KODAK & IMBLUM Attorney Phone: 238-7152 Attorney Address: 407 N. FRONT ST, PO BOX 11848 HBG, PA 17108 PERSONAL PROPERTY INFORMATION Monies Levied: Date of Sale: Date of Levy: District Justice: COMMENTS LIQUOR LICENSE NO. E986, LID NO. 5410 LEVIED AT THE PLCB BY DEPUTY R. HOPKINS ON 08-07-2008 @ 12:17HRS, WRIT IS IN THE LEVY FILE AAR AND NOW: WRIT REISSUED ON 01-20-2009 AAR AND NOW: LEVY MADE AT THE PLCB OF LIQUOR LICENSE NO. E986, LIC. NO. 5410 BY DEPUTY R. HOPKINS ON 01-21-2009 @ 11:1OHRS. SENT NOTICE TO THE ATTORNEY AND WRIT IS IN THE LEVY FILE AAR AND NOW 7/21/2009 RETURNED WRIT EXPIRED AND NOW 8/2/2009 SENT REFUND TO ATTORNEY RETURNED WRIT TO PROTHY f ach Aveanntina J Amount Date Added Category lD $200.00 8/6/2008 Deposit Agency 286489 ($10.00) 8/2/2009 State Fee 330965 ($70.00) 8/2/2009 Sheriff Costs 330966 ($1.40) 8/2/2009 Poundage 330967 ($118.60) 8/2/2009 Refund to Atty/Pltf 330968 Total Number of Rows: 5 Balance Due: $0.00 OF THE „, '??QE?Y 2009 AUG 19 PH 2= L 4 PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A. Plaintiff v WILLIAM J. KALDES, Defendant(s) TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6249 CIVIL ACTION - LAW PRAECIPE Satisfy Judgment and Discontinue Case TO: Cumberland County Prothonotary Dated: September 15, 2009 za4t2?? Robert D. Kodak, Esquire Attorney for Plaintiff Attorney I.D. No. 18041 RLE1Y-O'f' = : 2099 SEP 16 P l 2: 2 5 CU 4T)"