HomeMy WebLinkAbout08-3782DELL & HOMSHER
Adam E. Kosowsky, Esquire
Attorney I.D. No. 95001
600-A Eden Road
Lancaster, PA 17601
717-581-0620
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
EARL and NANCY KOSOWSKY, Husband
and Wife,
Plaintiffs,
V.
No. 08- 3,78x1 Civil TerM
DOORWAYS UNLIMITED, INC,
Defendant,
PRAECIPE TO ENTER JUDGMENT NOTE
To the Prothonotary:
Please enter a Judgment against Defendant, DOORWAYS UNLIMITED, INC.
and in favor of Plaintiffs, EARL and NANCY KOSOWSKY, Husband and Wife, in the amount
of $100,725.00 for failure to make payments on the two attached Demand Notes. as follows:
Judgement on Note 1: Outstanding balance $45,000.00
Outstanding interest $15,750.00
Total for Note 1 $60,750.00
Judgement on Note 2: Outstanding balance $30,000.00
Outstanding interest $9,975.00
Total for Note 2 $39,975.00
Grand Total for Both Notes: $100,725.00
Pursuant to Rule 2951(a)(1) and (2) of the Pennsylvania Rules of Civil Procedure, I
hereby certify that this Judgment is not being entered against an natural person in connection
with a consumer credit transaction notice; that the Plaintiff has an address of 507 Beford Place,
Lititz PA 17543; and that Defendant has a registered address of P.O. Box 3097, Shiremanstown
PA, 17011.
t?.
dam E. Kosowsky, Esquire
Attorney I.D. No. 95001
•: ?etJC. )l?diaeClee. pea
a8- civic Term
DEMAND N O T E
$ 'Sj vod. Shiremanst A
Dated: l d 200`f
FOR VALUE RECEIVED,
C)ac?s Ku'jAr'T&.) having an
address of .-0
P () , (S p 3 Of 7 (hereinafter
"Maker") promises to pay ko e o e o ' At )( A'P-JD 65? 1eOsOwsk'I
jointly and severally, having an address of
P t1 q Geq o A-
L_rq-1'TZJ (hereinafter collectively ayee"), the
principal sum 6V3o ooo;po in lawful money of the United States
of America, together ?Avith interest on the unpaid principal
balance as provided in this Note, as follows:
(a) The principal balance shall accrue interest at a
rate of 79; per annum. Interest shall accrue from the date of
this Note until all amounts due hereunder have been paid in f-u__.
(b) Maker shall make quarterly interest payments in
the amount of $Sr2S-,ttDeach, commencing on the first. of the mcn7n
from the date of this Note and continuing every ninety days
thereafter until the principal has been repaid upon demand or
voluntarily repaid by the Maker.
(c) All amounts due pursuant to this note stall be
payable at ?,rr7.,Z ?? 1,75
pe as Payee 7 13g0FrW jpl, or at such c er
may trcm time>to rime d?es_gnat n writinc.
(d) The rate of interest provided for in this Note
shall continue to apply to the debt evidenced by this Ncte
notwithstanding the entry of judgment on this Note.
(e) The Payee may demand
in full at any time by giv.i- Maker
(T) Maker shall have the
indebtedness evidenced by this Note
time and from time to time without
unearned interest.
pa?nnent of th_s ind??.ed-_??
30 days prior writ-n rot_ =
pr ivi loge of pa,;i Z,1'
in full or in part at anv
the payment cf pena_tv or
Maker shall pay to Payee a late charge equal to five pert_nt
(5%) of any payment not received by Payee within fifteen (i5;
days after the payment is due.
All amounts payable pursuant to this Note shall be pair
without deduction or set-off, -
The liability of each Maker, if more than one, pursuant
this Note shall be joint and several.
r
. Maker and all endorsers, sureties and guarantors of this
Note jointly and severally (a) waive presentment for payment,
demand, notice of demand, notice of nonpayment or dishonor,
protest and notice of protest of this Note, and all other notices
in connection with the delivery, acceptance, performance, default
or enforcement of the"payment of this Note and (b) agree that the
liability of each of them (i) shall be unconditional, without
regard to the liability of Maker or of any other of them and (ii)
shall not be affected in any manner by any indulgence, extension
of time, renewal. waiver or modification granted or consented to
by Payee. Maker and all endorsers, sureties and guarantors
consent (c) to all extensions of time, renewals, waivers, or
modifications that may be granted by Payee with respect to the
provisions of this Note and (d) to the release of any collateral
held by Payee as security for payment of the indebtedness
evidenced by this Note. Maker and all endorsers, sureties and
guarantors of this Note each agree that additional makers,
endorsers, guarantors or sureties may become parties to or
guarantee, endorse or become surety for payment of amounts due
pursuant to this Note without notice and without affecting the
liability of Maker or any endorser, surety or guarantor of this
Note.
Payee shall not be deemed, by any act or omission or by env
failure to exercise any right or remedy, to have waived or -
released any of Payee's rights or remedies pursuant to this Ncta
unless such waiver or release is in writing and signed by oavee:
and any such waiver or release shall be effective only to the
extent specifically set forth in such writing. A waiver cr
release as to any event shall not be construed as continuing cr
as a waiver or release of any right or remedy to a subsecuent
event. -
Payee may pledge or sell participations in or transfer t_s
Note or any interest in this Note (anal any renewals. eXLens_cns
and modifications of this Note) and any such pledgee or
transferee shall have all the rights cf Payee with resoec-. ?c
this Note (and any renewals, extensions and modifications c_ ;?ls
Note) as if such pledgee or transferee were named as ray;==
this Note. -n
Any notice given hereunder shall be given by mailing suc
notice by certified or registered mail, return receipt recues:=- ,
to the address set forth on the first page of this Note, cr a:
such other address as may have been designated by notice tC
either party. Any notice shall be effective upon receipt.
This Note shall be governed by and construed according
the laws of the Commonwealth of Pennsylvania. "
Whenever used in this Note, the singular number shall
include the plural, the plural the singular, the use of env
gender shall be applicable to all genders and the words
and "Maker" shall be deemed to include the respective successors
and assigns of Payee and Maker.
The occurrence of the following event shall constitute a
default:
The nonpayment of any amount payable under this
Note (as hereinafter defined) within fifteen (15) days after t;.e
date such payment is due,
Upon the occurrence of the default as set forth in this
Note, the entire unpaid balance of principal, together with
accrued interest thereon, shall become immediately due and
payable without presentment, demand, protest or notice of any
kind,
UPON THE OCCURRENCE OF AN EVENT OF DEFAULT MAKER IRREVOCABLY
AUTHORIZES AND EMPOWERS THE PROTHONOTARY OR ANY ATTORNEY TO
APPEAR AT ANY TIME FOR MAKER IN ANY ACTION BROUGHT AGAINST MA=-
ON THIS NOTE, WITH OR WITHOUT DECLARATION FILED, AS OF ANY TEP„M,
AND THEREIN TO CONFESS AND ENTER JUDGMENT AGAINST MAKER FOR 7HE
ENTIRE UNPAID PRINCIPAL OF THIS NOTE AND ALL OTHER SUMS PAYABLE
PURSUANT TO THE TERMS OF THIS NOTE AND ALL ARREARAGES OF INTED.?=ST
DUE PURSUANT TO THIS NOTE, TCGEirsER WITH COSTS OF SUIT. FOR
PURPOSES OF ENTERING AND CONFESSING JUDGMENT AGAINST MAKER, IS
NOTE OR A COPY OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL BE A
SUFFICIENT WARRANT. THE AUTHORITY GRANTED TO CONFESS AND EN`-1=--1'
JUDGMENT SHALL NOT BE EM-:RUSTED BY ANY EXERCISE BUT SH ,L
CONTINUE AND REMAIN IN EF_`CT UNTIL PAYMENT IN FULL OF ALL
AMOUNTS DUE PURSUANT. TO :I S NC Iz.
In the event Payee takes any legal action (i) to collect a-v
amounts due pursuant to this Note or (ii) to protect Pavee's
rights pursuant to this Note, Maker shall pay, in addition to a_1
other amounts due pursuant to this Note, all costs and ex-ens-=s
incurred by Payee, including attorney's fees.
The remedies of Payee at law or at equity or as Drovidec
this Note or in any instrument given in connection with this tio:e
(a) shall be cumulative and concurrent and (b) may be pursued
singly, successively or together at the sole discretion of Payee
and (c) may be exercised as often as occasion therefor shall
occur.
Maker waives and releases (a) all errors, defects and
imperfections in any proceedings instituted by Payee under t1nterms of this Note and (b) all benefit that might accrue to Maker
by virtue of any present cr future laws (i) exempting any
property, real or personal, or any part of the proceeds arisinc
from any sale of any such property, from attachment, levy, or
sale under execution or (ii) providing for any stay of executicn,
exemption from civil process or extension of time for payment:
and Maker agrees that any real estate that may be levied upon
pursuant to a judgment obtained pursuant to this Note, on any
writ of execution issued thereon, may be sold upon any such sn=it
in whole or in part and in any order desired by Payee.
IN WITNESS WHEREOF, Maker, intending this to be a sealed
instrument and to be legally bound, has caused this Note to be
duly executed and delivered to Payee the day and year first above
written.
Attest:
By : ? -?
President
1 . ,
The undersigned clearly and specifically understands that by
signing the note above referred to above containing a Confession
of Judgment clause:
1. Solely upon the occurrence of a default (as defined in thq
note). I authorize the Prothonotary of any Court of record or any
attorney to enter a judgment against the undersigned and in favor
of the holder without. notice and without declaration of default,
for non-payment.
2. I waive all right to notice and to have an opportunity tc be
heard prior to the entry of the judgment on the Court
records, understanding that the only method to challenge this
judgment would be by proceedings in Court to open or strike i-
which proceedings would result in substantial attorneys fees wV_ch
the undersigned would have to pay. (Without such clause
containing a Confession of Judgment the holder would have to _-le
suit against the undersigned which would give the undersigned an
opportunity for a hearing which the undersigned does not have by
reason of the Confession,) `
The undersigned acknowledges receipt of a copy of this af_1CI
and certifies that after reading and fully understandinc i,
theundersigned has signed this affidavit intentionally,
understandingly and voluntarily waiving all the above rightZ,
being willing to sign such note despite the consequences s=t
--
;-
above.
Affirmed to and subscribed
before me is day of
20Ct .
of y Public
My Commission Expires:
Borg?Ct,
•: \neh. 991doaed,er. ate
A
DEMAND N0TE
$45,000.00
Shiremansto n PA
Dated: 2002
FOR VALUE RECEIVED, Doorways Unlimited Inc., having an
address of P.O. Box 3097,Shiremanstown, PA 17011, (hereinafter
"Maker") promises to pay to the order of Nancy and Earl Kosowsky,
jointly and severally, having an address of 462 Dolly Drive,
Lancaster, PA 17061 (hereinafter collectively "Payee"), the
principal sum of$45,000.00 , in lawful money of the United States
of America, together with interest on the unpaid principal
balance as provided in this Note, as follows:
(a) The principal balance shall accrue interest at a
rate of 7% per annum. Interest shall accrue from the date of
this Note until all amounts due hereunder have been paid in full,
(b) Maker shall make quarterly interest payments in
the amount of $787,50 each, commencing on the first of the month
from the date of this Note and continuing every ninety days
thereafter until the principal has been repaid upon demand or
voluntarily repaid by the Maker.
(c) All amounts due pursuant to this Note shall be
payable at 462 Dolly Drive, Lancaster, PA 17061, or at such other
place as Payee may from time to time designate in writing.
/ (d) The rate of interest provided for in this Note
shall continue to apply to the debt evidenced by this Note
notwithstanding the entry of judgment on this Note.
(e) The Payee may demand payment of this indebtedness
in full at any time by giving Maker 30 days prior written notice.
(f) Maker shall have the privilege of paying the
indebtedness evidenced by this Note in full or in part at any
time and from time to time without the payment of penalty or
unearned interest.
Maker shall pay to Payee a late charge equal to five percent
(5%) of any payment not received by Payee within fifteen (15)
days after the payment is due.
All amounts payable pursuant to this Note shall be paid
without deduction or set-off.
The liability of each Maker, if more than one, pursuant to
this Note shall be joint and several.
w
Maker and all endorsers, sureties and guarantors of this
Note jointly and severally (a) waive presentment for payment,
demand, notice of demand, notice of nonpayment or dishonor,
protest and notice of protest of this Note, and all other notices
in connection with the delivery, acceptance, performance, default
or enforcement of the payment of this Note and (b) agree that the
liability of each of them (i) shall be unconditional, without
regard to the liability of Maker or of any other of them and (ii)
shall not be affected in any manner by any indulgence, extension
of time, renewal, waiver or modification granted or consented to
by Payee. Maker and all endorsers, sureties and guarantors
consent (c) to all extensions of time, renewals, waivers, or
modifications that may be granted by Payee with respect to the
provisions of this Note and (d) to the release of any collateral
held by Payee as security for payment of the indebtedness
evidenced by this Note. Maker and all endorsers, sureties and
guarantors of this Note each agree that additional makers,
endorsers, guarantors or sureties may become parties to or
guarantee, endorse or become surety for payment of amounts due
pursuant to this Note without notice and without affecting the
liability of Maker or any endorser, surety or guarantor of this
Note.
Payee shall not be deemed, by any act or omission or by any
failure to exercise any right or remedy, to have waived or
released any of Payee's rights or remedies pursuant to this Note
unless such waiver or release is in writing and signed by payee:
and any such waiver or release shall be effective only to the
extent specifically set forth in such writing. A waiver or
release as to any event shall not be construed as continuing or
as a waiver or release of any right or remedy to a subsequent
event.
Payee may pledge or sell participations in or transfer this
Note or any interest in this Note (and any renewals, extensions
and modifications of this Note) and any such pledgee or
transferee shall have all the rights of Payee with respect to
this Note (and any renewals, extensions and modifications of this
Note) as if such pledgee or transferee were named as Payee in
this Note.
Any notice given hereunder shall be given by mailing such
notice by certified or registered mail, return receipt requested,
to the address set forth on the first page of this Note, or at
such other address as may have been designated by notice to
either party. Any notice shall be effective upon receipt.
This Note shall be governed by and construed according to
the laws of the Commonwealth of Pennsylvania.
Whenever used in this Note, the singular number shall
include the plural, the plural the singular, the use of any
gender shall be applicable to all genders and the words "Payee"
and "Maker" shall be deemed to include the respective successors
and assigns of Payee and Maker.
,.
The occurrence of the following event shall constitute a
default;
The nonpayment of any amount payable under this
Note (as hereinafter defined) within fifteen (15) days after the
date such payment is due,
Upon the occurrence of the default as set forth in this
Note, the entire unpaid balance of principal, together with
accrued interest thereon, shall become immediately due and
payable without presentment, demand, protest or notice of any
kind.
UPON THE OCCURRENCE OF AN EVENT OF DEFAULT MAKER IRREVOCABLY
AUTHORIZES AND EMPOWERS THE PROTHONOTARY OR ANY ATTORNEY TO
APPEAR AT ANY TIME FOR MAKER IN ANY ACTION BROUGHT AGAINST MAKER
ON THIS NOTE, WITH OR WITHOUT DECLARATION FILED, AS OF ANY TERM,
AND THEREIN TO CONFESS AND ENTER JUDGMENT AGAINST MAKER FOR THE
ENTIRE UNPAID PRINCIPAL OF THIS NOTE AND ALL OTHER SUMS PAYABLE
PURSUANT TO THE TERMS OF THIS NOTE AND ALL ARREARAGES OF INTEREST
DUE PURSUANT TO THIS NOTE, TOGETHER WITH COSTS OF SUIT. FOR
PURPOSES OF ENTERING AND CONFESSING JUDGMENT AGAINST MAKER, THIS
NOTE OR A COPY OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL BE A
SUFFICIENT WARRANT. THE AUTHORITY GRAN'T'ED TO CONFESS AND ENTER
JUDGMENT SHALL NOT BE EXHAUSTED BY ANY EXERCISE BUT SHALL
CONTINUE AND REMAIN IN EFFECT UNTIL PAYMENT IN FULL OF ALL
AMOUNTS DUE PURSUANT TO THIS NOTE.
In the event Payee takes any legal action (i) to collect any
amounts due pursuant to this Note or (ii) to protect Payee's
rights pursuant to this Note, Maker shall pay, in addition to all
other amounts due pursuant to this Note, all costs and expenses
incurred by Payee, including attorney's fees.
The remedies of Payee at law or at equity or as provided in
this Note or in any instrument given in connection with this Note
(a) shall be cumulative and concurrent and (b) may be pursued
singly, successively or together at the sole discretion of Payee
and (c) may be exercised as often as occasion therefor shall
occur.
Maker waives and releases (a) all errors, defects and
imperfections in any proceedings instituted by Payee under the
terms of this Note and (b) all benefit that might accrue to Maker
by virtue of any present or future laws (i) exempting any
property, real or personal, or any part of the proceeds arising
from any sale of any such property, from attachment, levy, or
sale under execution or (ii) providing for any stay of execution,
exemption from civil process or extension of time for payment;
and Maker agrees that any real estate that may be levied upon
pursuant to a judgment obtained pursuant to this Note, on any
writ of execution issued thereon, may be sold upon any such writ
in whole or in part and in any order desired by Payee.
A
IN WITNESS WHEREOF, Maker, intending this to be a sealed
instrument and to be legally bound, has caused this Note to be
duly executed and delivered to Payee the day and year first above
written,
Attest:
Doorway jnim' e U
By:
Warren ne, III,
President
?Vd%?V6%4'
.. . . •
The undersigned clearly and specifically understands that by
signing the note above referred to above containing a Confession
of Judgment clause:
1. Solely upon the occurrence of a default (as defined in the
note), I authorize the Prothonotary of any Court of record or any
attorney to enter a judgment against the undersigned and in favor
of the holder without notice and without declaration of default
for non-payment.
2. I waive all right to notice and to have an opportunity to be
heard prior to the entry of the judgment on the Court
records, understanding that the only method to challenge this
judgment would be by proceedings in Court to open or strike it,
which proceedings would result in substantial attorneys fees which
the undersigned would have to pay. (Without such clause
containing a Confession of Judgment the holder would have to file
suit against the undersigned which would give the undersigned an
opportunity for a hearing which the undersigned does not have by
reason of the Confession.)
The undersigned acknowledges receipt of a copy of this affidavit
and certifies that after reading and fully understanding it,
theundersigned has signed this affidavit intentionally,
understandingly and voluntarily waiving all the above rights,
being willing to sign such note despite the consequences set forth
above. / If
Affirmed to and subscribed
before me this _day of
.7_
2002,
W
rcf- X/
Doorway Unlimited, Inc.
F?? f
ary °li'c `.
My Commissik/ Expires:
DELL & HOMSHER
Adam E. Kosowsky, Esquire
Attorney I.D. No. 95001
600-A Eden Road
Lancaster, PA 17601
717-581-0620
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
EARL and NANCY KOSOWSKY, Husband
and Wife,
Plaintiffs,
V.
No.
DOORWAYS UNLIMITED, INC,
Defendant,
AFFIDAVIT
I, Adam E. Kosowsky, Esquire, Attorney for Plaintiffs in the above referenced matter
hereby state that the judgment entered in the above matter is not being entered by confession
against a natural person in connection with a consumer credit transaction.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4909 relating to sworn
falsification by authorities.
Adam E. Kosowsky, Esquire
Attorney I.D. No. 95001
COMMONWEALTH OF PENNSYLVANIA:
SS:
COUNTY OF LANCASTER:
On this, the INay of , before me, the subscriber, a
Notary Public in and for the aforesai Commonwealth and County, personally appeared ADAM
E. KOSOWSKY. ESQ, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within instrument and acknowledged that she executed the same for the purpose
therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
NOWW feel
f am X fbltsl^ NOWY Pubic
MW*MM .. umsew 0"*
DELL & HOMSHER
Adam E. Kosowsky, Esquire
Attorney I.D. No. 95001
600-A Eden Road
Lancaster, PA 17601
717-581-0620
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
EARL and NANCY KOSOWSKY, Husband
and Wife,
Plaintiffs,
V. No.
DOORWAYS UNLIMITED, INC,
Defendant,
CERTIFICATE OF RESIDENCE
that:
I, Adam E. Kosowsky, Esquire, Counsel for Plaintiffs in the above action hereby certify
Plaintiffs are adult individuals with an address of 507 Beford Place, Lititz PA 17543;
AND
Defendant is a Domestic Pennsylvania Corporation with a mailing address of P.O. Box
3097, Shiremanstown PA, 17011, with its princi 1 place of business at 444 Railroad
Avenue, Shiremanstown PA, 17011.
4I _
am E. Kosowsky, Esquire
Attorney I.D. No. 95001
COMMONWEALTH OF PENNSYLVANIA:
SS:
COUNTY OF LANCASTER:
On this, the 0?lay of before me, the subscriber, a
Notary Public in and for the afores ' Commonwealth and County, personally appeared ADAM
E. KOSOWSKY. ESO, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within instrument and acknowledged that she executed the same for the purpose
therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
Ar MM L OF FEW$
Nolaft Seal
&mn Y.
MN11F16U111Yrp., at OuCr
MY E Jan. 12, 2640
DELL & HOMSHER
Adam E. Kosowsky, Esquire
Attorney I.D. No. 95001
600 A Eden Road
Lancaster, PA 17601
717-581-0620
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
EARL and NANCY KOSOWSKY, Husband
and Wife,
Plaintiffs,
V. No.
DOORWAYS UNLIMITED, INC,
Defendant.
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a true and correct copy of the foregoing
document upon the following person(s) and in the following manner, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure.
Service Via First Class Mail to:
Doorways Unlimited, Inc.
4441 RailRoad Avenue
Shiremanstown, PA 17011
Date: u C -? ax
Doorways Unlimited, Inc.
P.O. Box 3097
Shiremanstown, PA 17011
DE & HOMSHER
Adad-E. Kosowsky, Esquire
Attorney I.D. No. 95001
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
CV60C ® Confessed Judgment
Other
File No.?.?,?`? `-
?la?•+1•''? AmouatDue
V. ''
9av??? ?,??lM?"J ZNC
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not wise out of a retail installment sale,
contract, or account based an a confession of judgment, but if it does, it is based on the appropriate original
proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as
amended
law writ of execution in the above matter to the Sheriff of ti n++?y??a
County, for debt, Werest and coats, upon the following described property of the defendant (s)
Issue writ of attachment to the Sheriff of County, for debt, itnereat
and costs, as above, directing attachment against the above-named garnishee(s) for the following property
(if real estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
? (Indicate) Index this writ against the garnishee (s) as a lis
r de s described in the attached exhibit.
Date $/ 1 Z / O Signature:
Print Name:
Address:
. Interest
: Atty's Comm
: Costs
against real estate of the
/// l & DL
Attorney for. A, tj?
Telephone: l ?5-81 - Obi 2-c-?
Supreme Court ID No:
t
r -v-/ 04 SL 1,e m -t-s 22, . ;4 1'a 110t t
PRAECIPE FOR ATTACHMENT EXECUTION
W 9>
co
W co
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-3782 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EARL and NANCY KOSOWSKY, Plaintiff (s)
From DOORWAYS UNLIMITED, INC., 4441 Railroad Avenue, Shiremanstown, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell all inventory in warehouse,
all vehicles, tools, equipment, office furniture, computers, andy and all prperty of defendant
located at 4441 Railroad Avenue, Shiremanstown, PA 17011 .
(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 $100,725.00
Interest
Atty's Comm %
Atty Paid $53.75
Plaintiff Paid
Date: 8/14/08
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
fl;ftrtis; R. LoWIRF onota
By:
Deputy
REQUESTING PARTY:
Name ADAM E. KOSOWSKY, ESQUIRE
Address: 600-A EDEN ROAD
LANCASTER PA 17601
Attorney for: PLAINTIFF
Telephone: 717-581-0620
Supreme Court ID No. 95001
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2008-03782 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
KOSOWSKY EARL ET AL
VS
DOORWAYS UNLIMITED INC
And now CPL. TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according
to law, at 0009:14 Hours, on the 26th day of September, 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
DOORWAYS UNLIMITED INC
hands, possession, or control of the within named Garnishee
GEORGE MESSINGER 444 RAILROAD AVE
SHIREMANSTOWN, PA 17011
Cumberland County, Pennsylvania, by handing to
in the
GEORGE L. MESSINGER
personally 3 true and attested copies of the within
WRIT OF EXECUTION and made the contents thereof known to His .
Sheriff's Costs: So answers:
Docketing .00 ?00 Service .00 ?Affidavit .00
Surcharge .00 R. Thomas Kline
.00 Sheriff of Cumberland County
09/29/2008
By 4Z- 040???z X,,/?
Sworn and Subscribed to before me De uty Sheri f
this Day of ,
A. D.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
his writ is returned STAYED, WRIT IS EXPIRED.
Sheriff's Costs: Advance Costs:
-W i Sheriff's Costs:
Docketing 18.00
Poundage 1.88
Law Library 'i .50
Prothonotary 2.00
Mileage 13.00
Surcharge 30.00
Garnishee 9.00
Ley- C 20.00
Passage 1.72
TOTAL; 96.10 ?
?- I
150.00
96.10
53.90
Refunded to attorney 05-20-09
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So Answers-
R. bomas Kline, Sheriff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-3782 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EARL and NANCY KOSOWSKY, Plaintiff (s)
From DOORWAYS UNLIMITED, INC., 444/Railroad Avenue, Shiremanstown, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell all inventory in warehouse,
all vehicles, tools, equipment, office furniture, computers, andy and all prperty of defendant
located at 4441 Railroad Avenue, Shiremanstown, PA 17011.
(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 $100,725.00
Interest
Atty's Comm %
Atty Paid $53.75
Plaintiff Paid
Date: 8/14/08
L.L. $.50
Due Prothy $2.00
Other Costs
C . Long, Pr ary
(Seal)
By:
Deputy
REQUESTING PARTY:
Dame ADAM E. KOSOWSKY, ESQUIRE
Address: 600-A EDEN ROAD
LANCASTER PA 17601
Attorney for: PLAINTIFF
Telephone: 717-581-0620
Supreme Court ID No. 95001