HomeMy WebLinkAbout08-1729
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff
No. 08- 17a9
0 ivi ( --I& m
vs.
KENNETH BYERS and
SHAWN M BYERS
Defendant
CIVIL ACTION
PRAECIPE FOR ENTRY OF JUDGMENT
AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY, CUMBERLAND COUNTY:
Pursuant to the Pennsylvania Rule of Civil Procedure 3002, kindly file and index the attached
certified docket entries and judgment previously entered in the Court of Common Pleas of Franklin
County, in an action captioned BLUESTONE INVESTMENTS INC. vs. KENNETH BYERS and SHAWN
M BYERS, at docket no. 2007-1021, and assess damages in favor of the Plaintiff, BLUESTONE
INVESTMENTS INC., and against the Defendant, KENNETH BYERS and SHAWN M BYERS, as
follows:
Amount of Foreign Judgment $3,264.60
Payments 350.00
Interest (from March 29, 2007 to February 27,
2008 at statutory
of 6% per annum) 161.32
TOTAL
Dated: February 27, 2008
Attorney File # 1062034
Damages assessed and judgment
entered as above:
$3,075.92
AMATO AND ASSOCI S, P. C.
By:
Ro ald Amato,-Cs-q, 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
PROTHONOTARY
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff
VS.
KENNETH BYERS and
SHAWN M BYERS
Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF NORTHAMPTON
. SS:
Ronald Amato, Esquire, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff, BLUESTONE INVESTMENTS INC. , is authorized to make this affidavit on its
behalf; and that, to the best of his knowledge, information and belief:
1. The name of the judgment debtor is KENNETH BYERS and SHAWN M BYERS.
2. The last known post office address of the judgment debtor is 445 E. KING ST,
SHIPPENSBURG PA 17257.
3. The name of the judgment creditor is BLUESTONE INVESTMENTS INC.
4. The last known post office address of the judgment creditor is c/o Amato and
Associates, P.C., 107 North Commerce Way, Bethlehem PA 18017.
5. The judgment in favor of Plaintiff, BLUESTONE INVESTMENTS INC., and against
Defendants, KENNETH BYERS and SHAWN M BYERS, entered in the total sum of $3,264.60 in the
Court of Common Pleas of Franklin County, is valid, enforceable, and unsatisfied as of this date;
February 27, 2008.
SWORN TO AND SUBSCRIBED
BEFORE ME THIS &', DAY
OF eAc?? , 2008.
N?tary Public
NOTARIAL SEAL
GEOFF-" Y c , 7-,ECK
Notary Puoiic
HANOVER TOWNSHIP, NORTHAMPTON CNTY
My Commission Expires Mar 29, 2008
No.
: CIVIL ACTION
AFFIDAVIT
Ronald Amato
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff
No.
VS.
KENNETH BYERS and
SHAWN M BYERS
Defendant(s)
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 he is
unable to determine whether or not the above Defendant(s) 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;
That Kenneth Byers is over 18 years of age, resides at 445 E. KING ST,
SHIPPENSBURG PA 17257 and is employed;
That Shawn M. Byers is over 18 years of age, resides at 445 E. KING ST,
SHIPPENSBURG PA 17257 and is employed;
Sworn to and subscribed
before me this (e day
of f ` -? 2008 A
NOTA PUBLIC
NOTARIAL SEAL
GEOFFREY G SCHOENECK
Notary Public
1H; ER TOWNSHIP, NORTHAMPTON CNTY
Commission Expires Mar 29, 2008
IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff
vs.
KENNETH BYERS and
SHAWN M BYERS
Defendant
No. Awl -I OQ_l
CIVIL ACTION
PRAECIPE FOR TRANSFER OF JUDGMENT
TO THE PROTHONOTARY, FRANKLIN COUNTY:
- J
X7 -`?
-< = ti
0
Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s),
pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal a judgement entered February 1, 2007 against the above-named defendan?t(s)tbefore Todd
R. Williams, as set forth in the transcript of judgment, which is attached hereto. Assess
damages as follows:
Judgment Amount
Post Judgment Interest
(from 2/01/07 to 03/19/07
at 6% per annum)
Payments
Total
Dated: 2007
t-C .-to
wtutfirb
on this "Ima i .la.QJ l aL,
4
3,488.10
26.50
250.00
$3,264.60
AMATO AND ASSOCIATES, P.C.
By:
Ronald Amato, Esq., Atty ID #32323
Michael J. Kennedy, Esq., Atty ID #72412
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
?___ (610) 866-0400
A DEBT COLLECTION LAW FIRM
?n??Vrothonotary, of Franklin County, PA
i
,COMMONWEALTH OF PENNSYLVANIA
JUN I Y OF 'ZAJLNA6".LM
Mag. Dist. No.
39-3-04
MDJ Name: Hon.
TODD R. WILLIAMS
Address: 1157 GARVER LIff
PO BOX 460
SCOTLAND, PA
Telephone: (717 ) 263-7949 17254-0460
Ct(wI -IU41„1
NOTICE OF JUDGMENT/TFc 1" IP
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rBLDESTONE INVESTMENTS INC
?
107 NORTH C0MMZR`4:-'ptY `.
BETHLEHEM[, PA 18 017
L J
VS.
DEFENDANT: NAME and ADDRESS
'BYERS, KENNETH, ET AL. 7
445 N KING STREET
SHIPPENSBUR6,, PA 17257
C/O AM[ATO AND ASSOCIATES INC L J
107 NORTH COMMERCE NAY Docket No.: CV-0000359-06
BETHLEHEM[, PA 18017 Date Filed: 12/08/06
t
i
THIS IS TO NOTIFY YOU THAT:
D$FAULT - JUD( PLTI!- - - ?? 1
Judgment: (Dafe of Judgmerit)'
® Judgment was entered for: (Name) BLUESTONE IBMSTMENTS INC
® Judgment was entered against. (Name) BYERS, SEIS=TH
in the mminunt of -It 3,488.10
Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
F This case dismissed without prejudice.
F Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127`
F] Portion of Judgment for physical damages arising out of
residential lease $
Amount of Judgment $ 3,391.10
Judgment Costs $-97
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 3,488.10
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN-THE-COURT OF COMMON PILIEAS FURT- HER`PROCESS MUST _ ,. .
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS M SS THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLE RESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL D RI JUD E 1 JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
_n
A2 Date RA?n
- ) '••w„y .{.vqr YJIJIIV CUGVIJ.c .
I certify that this is a true and correct copy of the record of the proceedings contaiNin the.judgmdg t-,.
.3- /Z - 6 7 Date 7-ovm Af-, A: r.0 .
M;igisterial District Judge
My commission expires first Monday of January, 2008 SEAL
AOPC 315-06
DATE PRINTED: 3/12/07 1:38:00 PM[
_ COMMONWEALTH OF PENNSYLVANIA
GOUNTY OF: FRANKLIN
y... Mag. Dist. NO.
39-3-04
MDJ Name: Hon.
TODD R. WILLIAM
Address: 1157 GARNER LN
PO BOX 460
SCOTLAND, PA
Telephone: (717 263-7949 17254-0460
NOTICE OF JUDGM N lll&IPT
CIVIL CASE i ?J
PLAINTIFF: P?c3y
NAME a TSrldINCss
fHLUESTONE INVESTIEW
107 NORTH COIKEjtCE NAY
BETHLEHEM, PA 18017
L J
vs. NAME anc ADDRESS
fHYERB, >E31KETH, ET AL.
445 W KING STREET
SHIPPENSBURG, PA 17257
C/O MATO AND ASSOCIATES INC L J
107 NORTH COIO`ERCE WAY
BETHLEHEM, PA 18017 Docket No.: CV-0000359-06
Date Filed: 12/08/06
THIS IS TO NOTIFY YOU THAT:
Judgment: DEFAULT J'O XMZNT PLTY
(Date of Judgment)_ . ---?/HY/-99- ?_ - . _ _-_--=- --- -
® Judgment was entered for: (Name) BLUESTONE IWmBTm[=TB INC
® Judgment was entered against: (Name) BYERS, SHAWN
in the amount of $ 3,488.10
Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
This case dismissed without prejudice.
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
Portion of Judgment for physical damages arising out of
residential lease
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits
Post Judgment Costs
$ 3,391.10
-00
$ 3,488.10
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT-OF-COMMON PLEAS=ALI F`URTHER PROCESS MUST--
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE JSSUED by THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS-, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
.J
A' J
Date
Magiste ial District Judge
I certify that this is a true and correct copy of the record of the proceedings containing the judgment.
-7-12--07 Date
Magisterial District Judge
My commission expires first Monday of January, 2008 SEAL
AOPC 315-06
DATE PRINTED: 3/12/07 1:38:00 PI[
12142202262008 Franklin County Prothonotary's Office
PYS510 Civil Case Print
2007-01021 BLUESTONE INVESTMENTS INC (vs) KENNETH BYERS ET AL
Reference No..:
Case Type.....: JUDGMENT (GENERAL)
Judgment...... .00
Judge Assigned:
Disposed Desc.:
------------ Case Comments -------------
Page 1
Filed......... 3/29/2007
Time.......... 2:20
Execution Date 0/00/0000
Jury Trial....
Disposed Date. 0/00/0000
Higher Crt 1.:
Higher Crt 2.:
********************************************************************************
General Index Attorney Info
BLUESTONE INVESTMENTS INC
% AMATO & ASSOCIATES
107 N COMMERCE WAY
BETHLEHEM PA 18017
BYERS KENNETH
445 WEST KING STREET
SHIPPENSBURG PA 17257
BYERS SHAWN M
445 W KING STREET
SHIPPENSBURG PA 17257
PLAINTIFF AMATO RONALD
DEFENDANT
DEFENDANT
Judgment Index Amount Date Desc
BYERS KENNETH 3,264.60 3/29/2007 JUDGMENT
BYERS SHAWN M 3,264.60 3/29/2007 JUDGMENT
BYERS KENNETH 3,215.55 10/01/2007 WRIT OF EXECUTION
BYERS SHAWN M 3,215.55 10/01/2007 WRIT OF EXECUTION
********************************************************************************
* Date Entries
********************************************************************************
3/29/2007 PRAECIPE FOR TRANSFER OF JUDGMENTEAGAINST THE DEFENDANTS IN THE
AMOUNT OF $3,264.60 FILED.
-------------------------- ______________
---------------------
3 29/2007 NOTICE OF DISTRICT JUSTICE JUDGMENT TRANSCRIPT FILED.
------------------------------------------ _
3/29/2007 NOTICE OF ENTRY OF JUDGMENT SENT VIA REGULAR MAIL TO DEFENDANT(S).
------------------------ _________________
3/29/2007 CERTIFICATION OF ADDRESSES FILED. ----
------------------------
-------------------------------------------
3 29/2007 AFFIDAVIT OF NON-MILITARY SERVICE FILED.
------------------------------- _ __
10/01/2007 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) AGAINST DEFENDANTS
IN AMOUNT OF $3215.55 FILED.
WRIT OF EXECUTION PREPARED AND SENT TO SHERIFF FOR SERVICE AND COPY
TO ATTY.
------------
-------------------------------------------------------
10/01/2007 CERTIFICATION OF ADDRESSES FILED.
----------------------
---------------------------------------------
10 01/2007 WAIVER OF WATCHMAN FILED.
------------------ _ _ _ __
----------------------- ___
10/25/2007 SHERIFF'S RETURN: WRIT OF EXECUTION NOT SERVED ON KENNETH AND SHAWN
M BYERS DEFENDANTS NOT FOUND.
------002-Image-page(s)-exist(s)-for-this entry
----------------- _
1/28/2008 PRAECIPE TO REISSUE WRIT OF EXECUTION FILED AND COPY RETURNED TO
ATTY. WRIT OF EXECUTION REISSUED AND SENT TO SHERIFF FOR SERVICE.
- - - - - - - - - -002-Immaage ENQR(Ys)_exist(s) for this-entry
-
********************************************************************************
* Escrow Information
* Fees & Debits Beg Bal Pymts/Ad' End Bal
JUDGT/GENERAL 17.00 17.00 .00
JUDG DISC 5.00 5.00 .00
JUDG TAX .50 .50 .00
12142202262008 Franklin County Prc
PYS510 Civil Case F
20b7-0;021 BLUESTONE INVESTMENTS INC (v:
Reference No..:
Case Type.....: JUDGMENT (GENERAL)
Judgment. ... .00
Judge Assigned:
Disposed Desc.:
------------ Case Comments
JUDGEM-AUTO FEE 5
00
PRAE REIN/REIS .
8.00
WRIT OF EXEC 21
00
CERT COPY .
1n nn
honotary' s Office Page 2
int
KENNETH BYERS ET AL
Filed......... 3/29/2007
Time.......... 2:20
Execution Date 0/00/0000
Jury Trial....
Disposed Date.
Hi
her C
t 1 0/00/0000
g
r
.:
Higher Crt 2.:
5.00 .00
8.00 .00
21.00
in n n .00
--
------- ------------
66.50 66.50 .00
********************************************************************************
* End of Case Information
********************************************************************************
fk Prt ifi0
on this 4 ]n Qu aall Qjn
Arothonotary of Franklin County, PA
Y?
v
w
W
W
S
--Q.
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff : No.
vs.
KENNETH BYERS and
SHAWN M BYERS
Defendant
CIVIL ACTION
NOTICE OF JUDGMENT
Please be advised that the above-named Plaintiff, BLUESTONE INVESTMENTS INC. , has
transferred to the Court of Common Pleas of CUMBERLAND County, Pennsylvania, a judgment
entered against you in the Court of Common Pleas of Franklin County. Said judgment being
entered in the Court of Common Pleas of CUMBERLAND County, Pennsylvania, to the above
civil action number against the above named defendant(s) in the amount of $3,075.92, this
day of 17 AA o re_h , 2008.
PR x Y - C BERLAND COUNTY
Per:
If you have any questions concerning the above, please contact the undersigned.
AMATO AND ASSOC 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
(610) 866-0400
A DEBT COLLECTION LAW FIRM
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
RECEIVED
BLUESTONE INVESTMENTS INC.
Plaintiff
VS.
KENNETH BYERS and
SHAWN M RVFRS
No. 08-1729 Civil
CIVIL ACTION
Defendant(s)
MEMBERS 1ST FEDERAL CREDIT UNION
Garnishee W,6 '16,
INTERROGATORIES TO GARNISHEE
To: MEMBERS 1 ST FEDERAL CREDIT UNION, Garnishee
401 E. KING STREET, SHIPPENSBURG PA 17257
APR 0 2 2008
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 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 the defendant on any negotiable or other written instrument, or
did the defendant claim that you owed the defendant any money or were liable to the
defendant for any reason? Nb
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 art by the defendant?
?DI 3(03V K?? neth or Beers
iV in G-S Shy ? M. &-jers
3. 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 at any subsequent time did you hold as fiduciary any
property in which the defendant had an interest?
N0
5. At any time before or after you were served did the defendant transfer or deliver any
property to you or to any person or place pursuant to your direction or consent and if so what
was the consideration therefor?
(b
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 the defendant's direction or otherwise
discharge any claim of the defendant against you?
IV
7. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which funds are
deposited electronically on a recurring basis and which are identified as being funds that upon
deposit are exempt from execution, levy or attachment under Pennsylvania or federal law?
If so, identify each account and state the reason for the exemption, the amount being
withheld under each exemption and the entity electronically depositing those funds on a
recurring basis. _
Hb
8. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which the funds
on deposit, not including any otherwise exempt funds, did not exceed the amount of the
general monetary exemption under 42 Pa.C.S.A. § 8123? If so, identify each account.
NC t"d.e/b 3,r- NO j .oo
9. At any time before or after you were served, did the defendant, either solely or in part,
have any account (savings, checking, certificate of deposit, money market, deposits or any
other debt and/or property) [including but not limited to 21827958941 with your office?
X-] q 5? q - C-Lese(±
'31(?DT3?-Snv c-7-3
10. If your answer to interrogatory #9 is in the affirmative, state:
A) the account number of each account;
B) the amount of money in each account.
31 U-? 3 L 10 ' ICS .31 AMATO AND ASSOCIA S, P.C.
J By:
R ald 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
Attorney File#: 1062034
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff No. 08-1729 Civil
VS.
KENNETH BYERS and
SHAWN M BYERS
CIVIL ACTION
Defendant(s)
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:
445 E. KING ST
SHIPPENSBURG PA 17257
Dated: March 20, 2008
AMATO AND ASSOCIA 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
Attorney File #: 1062034
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff No. 08-1729 Civil
VS. .
KENNETH BYERS and
SHAWN M BYERS
CIVIL ACTION
Defendant(s)
WAIVER OF WATCHMAN
To the Sheriff:
Any deputy sheriff levying upon or attaching any property under the within writ may
leave same without a watchman, in custody of whomever is found in possession, after
notifying person of levy or attachment without liability on the part of such deputy or the
sheriff to any plaintiff herein for any loss, destruction or removal of any such property before
the sheriff's sale thereof.
Dated: March 20, 2008
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
(610) 866-0400
A DEBT COLLECTION LAW FIRM
Attorney File#: 1062034
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is
(Name)
awr6ob- a"Abf M"W1A ( L%M111
(title) (Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
(SIGNATU
AA"f -
?. rv
cm
r
crli
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
"' CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff
VS.
KENNETH BYERS and 4*5 L--- Ki"9 St
SHAWN M BYERS 5hjRXe.&bvt5, PA JUST
Defendant(s)
: CIVIL ACTION NO. 08-1729 Civil
Amount Due $ 3,075.92
Interest $ 1.37
Payments $ 0.00
Costs $
Poundage $
MEMBERS 1ST FEDERAL CREDIT UNION
Garnishee
Kor E. Ibnq St
%ippess6oq, PA
17A57
: Total $ 3,077.29
To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION AND
ATTACHMENT IN THE ABOVE MATTER.
PRAECIPE WRIT OF EXECUTION
Issue a 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) All cash
on hand or in the possession of the defendant(s) accounts receivables furniture furnishings
equipment, inventory, tools, electronic equipment vehicles anv and all other personal
property belonging to the above-named defendant(s).
PRAECIPE FOR WRIT OF ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs,
as above, directing attachment against the above named garnishee(s) for the following
property: All property of the above-named defendant(s) including without limitation all
savings and checking accounts certificates of deposit money market accounts deposits and
all debts and other property and/or obligations owing from the above-named garnishee to the
above named defendant(s), including but not limited to account #2182795894 and any
account owned solely or in part by the above-named defendant(s) which are in the
possession, custody and/or control of said garnishee(s).
AMATO AND ASSOCIATES P.C.
By:
R Wald 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
Attorney File#: 1062034
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff
No. 08-1729 Civil
VS.
Defendant(s)
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
KENNETH BYERS and
SHAWN M BYERS
the address provided below, and request that the Sheriff serve the above named defendant(s)
at:
445 E. KING ST
SHIPPENSBURG PA 17257
Dated: March 20, 2008
AMATO AND ASSOCIA C.
By:
Ile, 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
Attorney File #: 1062034
.--•
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1729 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BLUESTONE INVESTMENTS INC., Plaintiff (s)
From KENNETH BYERS and SHAWN M. BYERS, 445 E. King Street, Shippensburg, PA 17257
(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, electronic equipment, vehicles, and and all other personal property belonging to the
above-named defendants.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
MEMBERS 1sT FEDERAL CREDIT UNION, 401 E. King Street, Shippensburg, PA 17257
All property of the above-named defendants, including, without limitation, all savings and checking
accounts, certificates of deposit, money market accounts, deposits and all debts and other property
and/or obligations owing from the above-named garnishee to the above named defendants, including
but not limited to account #2182795894, and any account owned solely or in part by the above-named
defendants, which are in the possession, custody and/or control of said garnishee.
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 $3,075.92
Interest -- $1.37
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: 3/28/08
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
Curti R. Long, P oar
By:
Deputy
REQUESTING PARTY:
Name RONALD AMATO, ESQUIRE
Address: AMATO AND ASSOCIATES, PC
107 NORTH COMMERCE WAY
4WE CORD FROM RECORD
in Tewnwy whereof, i here unto set My hid
tt >W of said Cowt at CUM, Pa.
c8
OIL* ??aAgh -
BETHLEHEM, PA 18017
Attorney for: PLAINTIFF
Telephone: 610-866-0400
Supreme Court ID No. 32323
C(SUP,T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BLUESTONE INVESTMENTS INC.
Plaintiff
No. 08-1729 Civil
VS.
KENNETH BYERS and
SHAWN M BYERS
Defendant(s)
MEMBERS IST FEDERAL CREDIT UNION
Garnishee
CIVIL ACTION
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please discontinue the above-captioned matter against MEMBERS 1 ST FEDERAL CREDIT
UNION, Garnishee, ONLY, without prejudice.
AMATO AND S 0 IA"f S, P.C.
By:
Ronald Ama , 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
t? Q°
L
ae W n "
z
J
6`
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
Milage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
18.00
2.49
.50
2.00
25.00
50.00
20.00
9.00
126.99
Advance Costs: 150.00
126.99
23.01
Refunded on 10/30/08
So Answers,
R. Thomas Kline, Shenff
B
y
'Q'0-0 'D
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1729 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BLUESTONE INVESTMENTS INC., Plaintiff (s)
From KENNETH BYERS and SHAWN M. BYERS, 445 E. King Street, Shippensburg, PA 17257
(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, electronic equipment, vehicles, and and all other personal property belonging to the
above-named defendants.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
MEMBERS 1sT FEDERAL CREDIT UNION, 401 E. King Street, Shippensburg, PA 17257
All property of the above-named defendants, including, without limitation, all savings and checking
accounts, certificates of deposit, money market accounts, deposits and all debts and other property
and/or obligations owing from the above-named garnishee to the above named defendants, including
but not limited to account #2182795894, and any account owned solely or in part by the above-named
defendants, which are in the possession, custody and/or control of said garnishee.
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 $3,075.92
Interest -- $1.37
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: 3/28/08
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
_Curti L. Long, Pro ry .
By:
Deputy
REQUESTING PARTY:
Name RONALD AMATO, ESQUIRE
Address: AMATO AND ASSOCIATES, PC
107 NORTH COMMERCE WAY