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HomeMy WebLinkAbout08-2574ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7152 Attorney for Plaintiff CIT GROUP/COMMERCIAL IN THE COURT OF COMMON PLEAS SERVICES, INC. CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA v NO. ?g -0257 v' SARAGO ENTERPRISES, LLC also known as SARAGO'S BIG UGLY CIVIL ACTION - LAW WAREHOUSE Defendant(s) 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 AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Listed puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 CIT GROUP/COMMERCIAL SERVICES, INC. v Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. d P-?7 Cum /- SARAGO ENTERPRISES, LLC also known as SARAGO'S BIG UGLY WAREHOUSE Defendant(s) CIVIL ACTION - LAW COMPLAINT The Plaintiff, CIT GROUP/COMMERCIAL SERVICES, INC. by its attorneys, KODAK & IMBLUM, P.C., brings this action ofAssumpsit against the Defendant to recover the sum of THREE THOUSAND TWO HUNDRED THIRTY-FIVE DOLLARS AND THIRTY- SEVEN CENTS ($3,235.37), along with interest thereon at the statutory rate from March 14, 2008, upon a cause of action of which the following is a statement: 1. The Plaintiff, CIT GROUP/COMMERCIAL SERVICES, INC., factor for Ace Global Trading and Coaster of America, is a corporation organized and existing under the laws of the State of Virginia, having its principal office and place of business at 134 Wooding Avenue, Danville, VA 24541. 2. The Defendant, SARAGO ENTERPRISES, LLC also known as SARAGO'S BIG UGLY WAREHOUSE, is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 5267 Simpson Ferry Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\CIT 34319,wpd 2 3. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiff's Statement of Account hereto attached, marked Exhibit "A" and made a part hereof, Plaintiff, at the special instance and request of the Defendant, sold and delivered goods, wares and merchandise of the kind and description set forth on said Exhibit to the total amount of Three Thousand Eleven Dollars and Fourteen Cents ($3,011.14). 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 promised and agreed to pay to Plaintiff. 5. Due to Defendant's default in payment of said amount due and owing as aforesaid, interest through March 13, 2008 has been added to said account in the total amount of Two Hundred Twenty-Four Dollars and Twenty-Three Cents ($224.23). 6. The balance due and owing by Defendant to Plaintiff is the sum of Three Thousand Two Hundred Thirty-Five Dollars and Thirty-Seven Cents ($3,235.37). 7. Plaintiffs Invoices are not attached to this pleading due to the voluminous nature of same and have previously been provided to Defendant. 8. Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\CIT 34319.wpd 3 neglects to pay said amount or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of THREE THOUSAND TWO HUNDRED THIRTY-FIVE DOLLARS AND THIRTY-SEVEN CENTS ($3,235.37), along with interest thereon at the statutory rate as set forth herein. Respectfully submitted, Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney ID No. 18041 Attorney for Plaintiff F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\CIT 34319.wpd 03/1.312008 14:42 2015859244 TERRACE INT PAGE 04/04 ar The CIT Group/Commerciei Services, Inc. 134 WOODING AVENUE, DANVILLE, VA 24541 REGION 04 REQUEST TO PLACE ACCOUNT FOR COLLECTION CLIENT 7008 C I T COLLECTION ACCOUNT DO NOT MAIL CHARLOTTE, NC 20231 ACCOUNT EXEC 09 S J MACRILLO. CREDIT UNIT 16 A/REC UNIT 001 1 434/791:-6200 PAGE 1 NOTICE DATE 01/31/08 CUSTOMER 0199407 SARAGO ENTERPRISES LLC SARAGO'S BIG UGLY WAREHOUSE 5267 SIMPSON FERRY RD MECHANICSBURG , PA 17050 CREATED BY SE1 DAN S J EANES -------------- ---- ACAR0390 TRANSACTION --- ---- ------- REFERENCE ------------- ITEM --------------- RISK DISCOUNT ----- TERM ----_ DUE ----------- BATCH DESCRIPTION DATE NUMBER AMOUNT CODE AMOUNT CODE DATE DATE NSR INVOICE 09/14/07 23855 1.154.52 A-gaaT 110 1D1407 092707 052 INVOICE 09/04/07 4450321 988.02 I 0 8 Ak' 110 100407 090507 801 INVOICE 10/25/07 4514133 868.62 A/ S A 1 110 112407 102607 801 TOTAL AMOUNT 3,0 11.14 cV QJ-' ea?'? ?m c? VERIFICATION I, ROBERT D. KODAK, state that I am not a party to the action but that, at the request of the Plaintiff, CIT GROUP/COMMERCIAL SERVICES, INC., and based upon knowledge, information, records and documents supplied to me by the Plaintiff, the averments set forth in Plaintiffs Complaint are true. A Verification executed by the Plaintiff can be supplied at time of trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authoritie Robert D. Kodak, Esquire Dated: ??? a W 4 P?- 1: - 'P h) c -) _-4 r -_ Y,I _S 1 OV) SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02574 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CIT GROUP/COMMERCIAL SERVICES VS SARAGO ENTERPRISES LLC AKA SAR R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SARAGO ENTERPRISES LLC A/K/A SAPAGO'S BIG UGLY WAREHOUSE but was unable to locate Them in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT , SARAGO ENTERPRISES LLC A/K/A SARAGO'S BIG UGLY WAREHOUSE , 5267 SIMPSON FERRY ROAD MECHANICSBURG, PA 17050 DEFENDANT IS NOT LOCATED AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge So answers 18.00 10.00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 4 KODAK & IMBLUM 04/29/2008 Sworn and Subscribed to before me this day of J A. D. w ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. PO BOX 11848 HARRISBURG, PA 17108-1848 717) 238-7152 CIT GROUP/COMMERCIAL SERVICES, INC. Plaintiff v SARAGO ENTERPRISES, LLC a/k/a Sarago's Big Ugly Warehouse Defendant(s) ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA NO. 08-2574 CIVIL ACTION -LAW PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-referenced matter for service u on p Defendant(s) as follows: SARAGO ENTERPRISES, LLC a/k/a Sarago's Big Ugly Warehouse 1418 Red Hill Road Dauphin, PA 17018 TO: Cumberland County Prothonotary Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041 Email: robert.kodak@verizon.net Dated: Tune 3 2008 W 1*0 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-02574 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CIT GROUP/COMMERCIAL SERVICES VS SARAGO ENTERPRISES LLC AKA SAR R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: SARAGO ENTERPRISES LLC A/K/A SARAGO'S BIG UGLY WAREHOUSE but was unable to locate Them deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On July 8th , 2008 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County 49.25 Postage .76 87.01 07/08/2008 KODAK & IMBLUM So answer ?_. R. Thomas Kline Sheriff of Cumberland County '7?5/o t q, Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania CIT Group Carmerc al Services Inc V5. Sarago Enterprises LLC a/k/a Sarago's Big Ugly Warehouse No. 08-2574 civil Now, June 5, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, )20 , at within upon at by handing to a and made known to Sheriff of 1 . Sworn and subscribed before me this day of , 20 copy of the original So answers, COSTS SERVICE MILEAGE AFFIDAVIT o'clock M. served the the contents thereof. County, PA (Pt#it.t of the ?'*Iteriff Mary Jane nyder Real Estate DSepu William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy CIT GROUP/COMMERCIAL SERVICES INC. VS County of Dauphin SARAGO ENTERPRISES LLCA/K/A SARAGO'S BIG UGLY WAREHOUSE Sheriff s Return No. 2008-T-1214 OTHER COUNTY NO. 08-2574 And now: JUNE-30,2008 at 10:12:00 AM served the within NOTICE & COMPLAINT upon SARAGO ENTERPRISES LLC A/K/A SARAGO'S BIG UGLY WAREHOUSE by personally handing to CHRIS SARAGO 1 true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at C/O CHRIS SARAGO OR NICK SARAGO 1418 RED HILL ROAD DAUPHIN PA 17018 PRESIDENT Sworn and subscribed to before me this 3RD day of July, 2008 Aol? NOTARIAL SEAL ARY JANE SNYDER, Notary Publi Highspire, Dauphin County S MY Expires Sept 1 2010 So Answers, ? %oft Sheriff o Imm By Deputy S ff Deputy: G MILLER Sheriffs Costs: $49.25 6/9/2008 CIT GROUP/COMMERCIAL SERVICES, INC. Plaintiff v. IN TIME COURT OF COMMON PLEAS CUMBERLANDCOUNTY, PENNSYLVANIA NO. 2008-2574 CIVIL SARAGO ENTERPRISES, LLC also known as : CIVIL ACTION -LAW SARAGO'S BIG UGLY WAREHOUSE Defendant TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ERAEC,'I Fog DEFAULT NDGME _T Please enter judgment in favor of Plaintiff and against Defendant(s) SARAGO ENTERPRISES, LLC also known as SARAGO'S BIG UGLY WAREHOUSE, named for failure to file within the required time an Answer t0 the Complaint in the above-captioned case and assess the Plaintiff's damages as follows: Amount claimed in Plaintiff's Complaint $3,235.37 Interest at the statutory rate of 6% per annum from March 14, 2008 Total = $3,324.30 I hereby certify that a written Important Notice of the intent to file this Praecipe was mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice is attached. KODAK & M, P.C. By Robert D. Kodak, Attorney for Plaintiff DATED: OO6 Judgment entered and damages assessed as above. thonotary I ' LAW OFFICES OF KODAK & IMBLUM, P.C. CAMERON MANSION Telephone Robert D. Kodak 407 NORTH FRONT STREET 717.238.7152 Gary J. Imblum POST OFFICE BOX 11848 Facsimile HARRISBURG, PA 17108-1848 717.238.7158 www.kodak-imblum.com July 31, 2008 SARAGO ENTERPRISES LLC SARAGOS BIG UGLY WAREHOUSE FIL E % CHRIS SARAGO OR NICK SARAGO PRES 1418 RED HILL ROAD DAUPHIN PA 17018 RE: CIT Group/ Commercial Services, Inc. VS: Sarago Enterprises, LLC a/k/a Sarago's Big Ugly Warehouse Our File No. 34319 No. 08-2574 Civil, Court of Common Pleas Cumberland County, Pennsylvania Gentlemen: In accordance with Pennsylvania Rules of Civil Procedure 237.1, 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, Pennsylvania, to enter judgment against you in the amount as set forth in said Complaint. Very truly yours, RDK/bjh enclosure cc JOHN ELLSWORTH JR TERRACE INT'L PO BOX 1186 FORT LEE NJ 07024 KODAK & IMBLUM, P.C. Robert D. Kodak robert.kodak@kodak-imblum.com 20080051 CIT GROUP/COMMERCIAL SERVICES, INC. Plaintiff V. SARAGO ENTERPRISES, LLC also known as SARAGO'S BIG UGLY WAREHOUSE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-2574 CIVIL CIVIL ACTION - LAW ?4R?, FILE E"ORTANT NOTICE TO: SARAGO ENTERPRISES LLC. a/k/a SARAGO'S BIG UGLY WAREHOUSE Defendant(s) DATE OF NOTICE: July 31, 2008 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 MAYBE 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 TWO LIBERTY AVENUE CARLISLE PA_ 17013 (717) 249-3166 r Ire, r n CIT GROUP/COMMERCIAL SERVICES, INC. Plaintiff PENNSYLVANIA V. SARAGO ENTERPRISES, LLC also known as SARAGO'S BIG UGLY WAREHOUSE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. 20o8-2574 CIVIL CIVIL ACTION - LAW TO: SARAGO ENTERPRISES LLC ALSO KNOWN AS SARAGO'S BIG UGLY WAREHOUSE Defendant(s) You are hereby notified that on 3 , 206 the following (Judgment) has been entered against y4in above-captioned case. bAg ment enfieied in the amount of $3024.30 DATE: !?/*m , - Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: SARAGO ENTERPRISES LLC SARAGOS BIG UGLY WAREHOUSE % CHRIS SARAGO OR NICK SARAGO PRES 1418 RED HILL ROAD DAUPHIN PA 17018 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 CIT Group/Commercial Services, Inc. IN THE COURT OF COMMON PLEAS OF 134 Wooding Ave, Danville, VA 24541 Cumberland COUNTY, PENNSYLVANIA Plaintiff Writ No. Term 20 Vs No. 08-2574 Term 20 08 SARAGO ENTERPRISES LLC a/k/a SARAGO'S BIG UGLY WAREHOUSE 1418 Red Hill Road Dauphin, PA 17018 DEFENDANT(S) Amount Due 9/ 3/ 08 jdmt $ 3,324.30 Interest from 9/3/08-10/9/08 (0.55 per diem) $ 19.94 Atty's Commission $ 166.22 Costs (to be determined) Cumberland = $256.51 to date $ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff ofCounty, Pennsylvania (2) against Sarago Enterprises, LLC a/k/a Sarago's Big Ugly Warehouse e en ant s (3) and against anus ee s ; (4) and index this writ (a) against Sarago Enterprises, LLC a/k/a Sarago's Big Ugly Warehouse Defendant(s) and (b) against arinsneeks), 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 THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY INCLUDING BUT NOT LIMITED TO, FURNITURE, OFFICE EQUIPMENT, JEWELRY, SUPPLIES, ELECTRONICS, LAWN AND GARDEN EQUIPMENT, ETC. (5) Exemption has (not) been waived. Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Dated 10/9/08 Attorney For Plaintiff(s) (o)toI£ alwa aaS pansop s! suapuad s!t u su Su!xapm pus pogosiu s! aags!we8 aql jo auuu aql ui ,ClWwd luai3! Cluo palalduoo oq plnogs (q)(b) gdulSejud (q)1701 £ almd aaS ,4elouo4losd agl Xq flunoo legl u! asmoo p se pannbaj si 8mxapu! f4unoo is poue of sonss! Rue aql uagM '(e)to l £ aln2l Xq pazuoglnu su pai!sap s! `oousmss! jo filunoo aqi u! suo!inoaxa aql jo Eu!xapu! 3i Aluo palalduoo aq plnogs (s)(b) gdu8s"ud (i!N+ oql u! papnlou! aq of s! 2a4s!un8 pausu u u! Kluo palalduoo aq p(nogs mogs) (£) 4duj8saud •panss! go!gm u! dlunoo agl;o,guags aqi of 6luo paloanp aq ,Ceu luaugpnf papapuun u uo panss! t!im u (o)£Ol £ almd japul) paisa!pu! oq plnogs f4-oo a p `(q)£OI E aing 6q pazuoglnu se 4unoo jagioue 3o,juags aql of poloanp s! ilim agl uagm (t) gd=hmd iapun KON O O N V G M N r~ °' x O 0 C'4 cc cz w $ 1-4 a~ C7 ? ? ? A z _H 3 0 U ' c? r ? • r ? tr r y VM ` I: ' ' OD 6 tit, cY WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-2574 Civil CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due CIT GROUP/COMMERCIAL SERVICES, INC., Plaintiff (s) From SARAGO ENTERPRISES LLC A/K/A SARAGO'S BIG UGLY WAREHOUSE, 1418 RED HILL ROAD, DAUPHIN, PA 17018 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS INCLUDING BUT NOT LIMITED TO, FURNITURE, OFFICE EQUIPMENT, JEWELRY, SUPPLIES, ELECTRONICS, LAWN AND GARDEN EQUIPMENT, ETC.. (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 $3,324.30 L.L. $.50 Interest FROM 9/3/08 -10/9/08 (0.55 PER DIEM) - $19.94 Atty's Comm % $166.22 Due Prothy $2.00 Atty Paid $129.00 Plaintiff Paid Other Costs Date: OCTOBER 14, 2008 (Seal) 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 C s . Low By: Deputy