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Home My WebLink About08-5052A.H. Reif Landscape Supply IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. Q$ - 50601 C iv i t lern^ Chronister Landscapes, Inc. CIVIL ACTION Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado gue si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 A.H. Reif Landscape Supply IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. d ?' Jra Chronister Landscapes, Inc. CIVIL ACTION Defendant COMPLAINT 1. Plaintiff is A.H. Reiff (A.H. Reiff) Landscape Supply located at 7365 Wertzville Road, Carlisle, PA 17013. 2. Defendant is Chronister Landscapes, Inc. (Chronister Landscapes) located at 564 South P Street, Lemoyne, PA 17043.. 3. On or around March 26, 2007, pursuant to Chronister Landscapes' request, Chronister Landscape took possession of those items appearing in Exhibit "A" attached to this complaint either by way of receiving delivery from A.H. Reiff or picking the items up from A.H. Reiff's place of business. 4. Prior to taking possession Chronister Landscapes agreed to the prices set forth in Exhibit "A" attached hereto. 5. The total of the two invoices attached as Exhibit "A" is $13,156.37. 6. Payments made by Chronister Landscapes were $1,020.00 made on January 28, 2008, $1,000.00 made on February 22, 2008, $1,000.00 made on March 21, 2008 and $1,000.00 made on April 15, 2008 for a total of $4,020.00. 7. After payments of the aforesaid $4,020.00, a principal balance of $9,136.37 ($13,156.37 less $9,136.37) remained. 8. As of August 1, 2008, fmance charges are $2,825.43. 9. On the first day of each month beginning with September 1, 2008 an additional $137.04 in finance charges will accrue. 10. A.H. Reiff has requested that Chronister Landscapes pay the aforesaid amount, however, Chronister Landscapes refuses to do the same. WHEREFORE, A.H. Reiff Landscape Supply requests judgment against Chronister Landscapes, Inc. in the amount of $11,961.80 ($9,136.37 + $2,825.43) plus an additional $137.04 per month as of the first day of each month beginning with September 1, 2008 and continuing monthly as aforesaid up until the date of entry of judgment. YOFFE & YOFFE, P.C. VF ,?, REY YOFF , ES UIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 A.H. Reif Landscape Supply Plaintiff VS. Chronister Landscapes, Inc. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Complaint are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. A.H. Reiff Landscape Supply Dated: B 1 Y AAmon H. Reiff, Presid Jul 24 08 02,36p A.H. REIFF LANDSCAPE SUPPLY A H Reiff Landscape Supply 7365 WertzvM9 Road Carlisle, PA 17013 PH 717-766-2050 Fax 717-786-1466 Bill To Chronister Landscapes 564 S. Third St Lemoyne, PA 17043 Phone: 717-540-8834 Fax: 717-774-6772 P.1 Invoice Date Invoice # 3!2612007 7210 Ship To P.O. Number Terms Due Date Ship Via COD 3/2612007 3/26/2007 Iklivered Quantity Item Code Description Price Each Amount 18 Boulders 3/27 165.00 2,970.OOT 1 Delivery Fee 100.00 100.00T 18 Boulders 3/28 165.00 2,970.OOT 1 Delivery Fee 100.00 100.00T Delivered to 816 Rudytown Rd.Newcumberland Finance Charge of 1.5% per month will apply to overdue invoices. Sales Tax (6.0%) $368.40 Total 56,508.40 EXHIBIT "A" Jul 24 08 12:20p A.H. REIFF LANDSCAPE SUPPLY A H Reiff Landscape Supply 7385 Wertaville Road Carlisle, PA 17013 PH 717-786-2050 Fax 717-766-1466 Bill To Chronister Landscapes 564 S. Third St. Lemoyne, PA 17043 Phone: 717.540-8834 Fax: 717-774-6772 p.3 Invoice Daft Invoice # 3126/2007 NBS-0207 Ship To P.O. Number Terms Due Date Ship Via HomeBuilderS... COD 3/26/2007 3126x2007 Pik-Up & Del Quantity Item Code Description Price Each Amount 1 Boulders 7086 Returned 0.00 O.OOT 70 Tread 4220 Lilac 12.50 875.OOT 460.05 Lumber 7093. Boards for Pergola 0.70 322.04T 10 Tanbark 7093 0.00 O.OOT 2 Pallets 7093 0.00 O.OOT 154 Lumber 4218 gaming lumber 3.97 611.38T 120 Lumber 4218 Framing Lumber 1.50 180.OOT 60 Radial Block 4218 returned 0.00 O.OOT 87 Caps 4218 returned 0.00 O.OOT 2 Natural Wall S:.. 7084 Laurel Hill 165.00 330.OOT 3 Rock 7084 Returned 0.00 O.OOT 5 Tread 7084 7.50 37.50T 111 Blue Stone 7062 Tumbled 12x12 6.50 721.50T 188.35 Tread 7062 7.50 1,412.63T 31 Tread 7074 Mills 7.50 232.50T 82.5 Tread 7074 7.50 618.75T 806.55 Pavers 7089 Returned Most 0.00 O.OOT 300 Flag Stone 7089 4.50 1,350.OOT -93.25 Flag Stone 7089 Returned 4.50 419.63T 9 Pallets 7089 0.00 O.OOT 1 Delivery Fee 7089 0.00 O.OOT Finance Charge of 1.S% per month will apply to overdue invoices. Sales Tax (6.096) $376.30 Total $6,647.97 EXHIBIT "A" -n coo v+ m!•F.., t S7 C7 - n - 3T7 Ld J J C .w ran SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-05052 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND A H REIF LANDSCAPE SUPPLY VS CHRONISTER LANDSCAPES INC 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 CHRONISTER LANDSCAPES INC but was unable to locate Them in his bailiwick. He therefore returns the lT/' Aff- T YTTT r TT/%M-rt?T? NOT FOUND , as to the within named DEFENDANT CHRONISTER LANDSCAPES INC 564 SOUTH 3RD STREET LEMOYNE, PA 17043 DEFENDANT IS NOT KNOWN AT GIVEN ADDRESS OR AT THE LEMOYNE POST OFFICE. Sheriff's Costs: So ans Docketing 18.00 Service 15.00 ------- Not Found 5.00 Thomas Kline Surcharge 10.00 GSher"'- f of Cumberland County 00 4 FE & YOFFE /08/2008 Sworn and Subscribed to before me this day of , A. D. A.H. Reif Landscape Supply IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 08-5052 Chronister Landscapes, Inc. CIVIL ACTION Defendant PRAECIPE TO REINSTATE Please reinstate the Complaint filed in the above captioned action. YOFFE & YOFFE, P.C. By J91 4 - Y FRENY F E, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 r 7 `. E X cr. S 3 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05052 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND T TT T1TTT? T TTTr%0t Ann" OTTnnT V VS CHRONISTER LANDSCAPES INC NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CHRONISTER LANDSCAPES INC the DEFENDANT , at 1655:00 HOURS, on the 1st day of October , 2008 at 1000 W FOXCROFT DRIVE CAMP HILL, PA 17011 JANE CHRONISTER by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge J0104/0 Y ?- So Answers: 18.00 15.00 .59 10.00 R. Thomas Kline .00 43.59 10/02/2008 YOFFE & YOFFE Sworn and Subscibed to before me this of By: day Deputy Sheriff A. D. E A.H. Reif Landscape Supply Plaintiff VS. Chronister Landscapes, Inc. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5052 CIVIL ACTION PRAECIPE To the Prothonotary of Cumberland County: Please enter judgment, by default, in favor of Plaintiff, A.H. Reif Landscape Supply, and against Defendant Chronister Landscapes, Inc., in the amount of $12,235.88 for its failure to file an Answer or otherwise plead to the Complaint in this case within the time allowed by law. A copy of the notice required by Pa. R.C.P. 237 is attached hereto and it is hereby certified that said notice was mailed to Chronister Landscapes, Inc. on November 4, 2008. YOFFE & YOFFE, P.C. Dated: 1111511au? B , N. YOF , ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 A.H. Reif Landscape Supply Plaintiff vs. Chronister Landscapes, Inc. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5052 CIVIL ACTION NOTICE TO: Chronister Landscapes, Inc., 1000 W. Foxcroft Drive, Camp Hill, PA 17011 DATE: November 4, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 NOTICIA IMPORTANTE A: Chronister Landscapes, Inc., 1000 W. Foxcroft Drive, Camp Hill, PA 17011 FECHA DEL AVISO: November 4, 2008 USTED ESTA EN REBELDIA HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA LISTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA A.H. Reif Landscape Supply Plaintiff VS. Chronister Landscapes, Inc. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5052 CIVIL ACTION CERTIFICATION OF ADDRESSES The undersigned certifies that to the best of Plaintiff's knowledge the names and addresses of the proper individuals who are to receive notice of entry of judgment in the above captioned action are as follows: Chronister Landscapes, Inc. 1000 W. Foxcroft Drive Camp Hill, PA 17011 YOFFE & YOFFE, P.C. By 41 FFRE . YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 A.H. Reif Landscape Supply Plaintiff VS. Chronister Landscapes, Inc. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5052 CIVIL ACTION AFFIDAVIT OF NONMILITARY SERVICE To the best of the plaintiffs and the undersigned's knowledge information and belief, defendant is not in the military service as defined and covered by 50 U.S.C.A. Section 501 et seq. YOFFE & YOFFE, P.C. Date: I ?Sll ZUU? By A 4 FRE . YOF , ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 ZZ N O Film L-+ j I l A.H. Reif Landscape Supply Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. Chronister Landscapes, Inc. Defendant To: Chronister Landscapes, Inc. NO. 08-5052 CIVIL ACTION You are hereby notified that on November 1-1+1, 2008, a Judgment has been entered against you in the above captioned case in the amount of $12,235.88. DATE: / ( ?'. " 112. " s Prbthonotary n rA I hereby certify that the name and address of the proper person(s) to receive this notice under Pa. R. Civ. P. 236 is: Chronister Landscapes, Inc. 1000 W. Foxcroft Drive Camp Hill, PA 17011 YOFFE & YOFFE, P.C. Date: By A 4 FFRE N. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 A: Chronister Landscapes, Inc. Defendido/a Defendidos/as Por este medio se le esta notificando que el de del 2008, el/la siguiente (Orden), (Decreto), (Fallo) ha sido anotado en contra suya en el caso mencionao en el epigrafe. FECHA: Protonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: YOFFE & YOFFE, P.C. Date: BY. FREYN. YOFFE; ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: A . ,<ei Lajorisc,?e, &4W5 -6 . Plai n-h FF Gtn?,s.r (,tclS?As, Inc. 1-,e ?eiui (w4- ? Confessed Judgment ? Other File No. Amount Due wI a3-5. kg Interest 6t!1 )01109 -)l L yue Atty's Comm Costs (tc ihP /zdded) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on 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. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest 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 efendant(s) described in the attached exhibit. Date I nq Signature: Print Name: Address Attorney for: Telephone: pendens against real estate o the ?ofFc? afk,Rt ly Senctik A*.. SU i? ??{ C&Pko thPA 17111 ?Ia1rYl;?F Supreme Court ID No: i Issue writ of execution in the above matter to the Sheriff of bi-b-'01rl &Pd County, for debt, interest and costs, upon the following described property of the defendant (s) -W -?¢ Wo) 00 ,? Q tIti 0 00 0 0 Q°oo 0Q r _ - _ D 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5052 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due A. H. REIF LANDSCAPE SUPPLY, Plaintiff (s) From CHRONISTER LANDSCAPES, INC., 1000 W. Foxcroft Drive, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property of Defendant. (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 $12,235.88 Interest from 11/17/08 to date of sale Atty's Comm % Atty Paid $220.59 Plaintiff Paid Date: 11/17/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs to be added CQR"Lio"n-g-, Prothonota By: Deputy REQUESTING PARTY: Name JEFFREY N. YOFFE, ESQUIRE Address: YOFFE & YOFFE, P.C. 214 SENATE AVE, SUITE 404 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-975-1838 Supreme Court ID No. 52933 ov r" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AM,CN ?, E-t, PRAECIPE FOR wRrr OF EXECUTION Caption: A N . ket F l.cLiir aiv, ?la1n+?FF .6'. ?:b?rl;n+Si? I.iw+clS«1?"'S, Inc. lie F?nc l w4- : ? Confessed Judgment ? Other File No. N- 5nrj Amount Due 1 ?? 3rJ ?1 K Interest in 111111Qg , Q4e o yje. Atty's Comm Costs (.N be / Add) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on 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. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of t' Ui 11 CIOLA' A. County, for debt, interest 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 copics of lengthy personalty list) a 1'. V 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 pendens against real estate of the defendant(s) described in the attached exhibit. ?t; c ycCk, Date 1 -1 f) u Signature: Print Name: P 40 Address: 1U-SFl1Gt ? Av` - Su i-le 404 UuA0611, ?-'k 170 Attorney for: ?? n i?'?h F? Telephone: ("1 I `)? ??15' 1 3 0 Supreme Court ID No: s Issue writ of execution in the above matter to the Sheriff of t•,I1AI4e( 16U'A County, for debt, interest and costs, upon the following described property of the defendant (s) ?? `? G r ? ? ? ? ? a C') t^-.a -- `=^' _l c.u '?"F ? ?t ?_._ ?? -._ , _ ?? _... ? ,._ _ _ , , _; `__ ?'? v /ame,udeol WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5052 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due A. H. REIF LANDSCAPE SUPPLY, Plaintiff (s) From CHRONISTER LANDSCAPES, INC., 1000 W. Foxcroft Drive, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property of Defendant. (2) You are also directed to attach the property of the defendant(s) not levied upon in the?ossession of T 1v f-- 9,e; &I'v/C , 3,3 3,5 M,4,eX? t S7>peer i C,a GARNISHEE(S) as follows: A J I nCr-au,vr-s o 6e PC"i.4tit Ae/d. A 't- .1-ti fe-1le; 5' 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 $12,235.88 Interest from 11/17/08 to date of sale Atty's Comm % Atty Paid $220.59 Plaintiff Paid Date: 11/17/08 (Seal) REQUESTING PARTY: Name JEFFREY N. YOFFE, ESQUIRE Address: YOFFE & YOFFE, P.C. 214 SENATE AVE, SUITE 404 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-975-1838 Supreme Court ID No. 52933 L.L. $.50 Due Prothy $2.00 Other Costs to be added mlr" .m COPY FROM Teal "whlrrof, I here unto "t my h" r?d tin IM of Ud C At Cat ele. P a 7-747" (7- TIM' Prv*he v Az SHERIFF'S RETURN - GARNISHEE CASE NO: 2008-05052 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND A H REIF LANDSCAPE SUPPLY VS CHRONISTER LANDSCAPES INC And now SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, at 0010:48 Hours, on the 6th day of December , 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT CHRONISTER LANDSCAPES INC hands, possession, or control of the within named Garnishee INTEGRITY BANK 3335 MARKET ST CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to , in the JOHN ROZMANN (CUSTOMER SERVICE) , 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 Service .00 Affidavit .00 Surcharge .00 R. Thomas Kline .00 Sheriff mb rland County .00 12/08/2008 G By Sworn and Subscribed to before me De uty Sheriff this Day of , A. D. A.H. Reif Landscape Supply Plaintiff vs. Chronister Landscapes, Inc. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5052 CIVIL ACTION PLAINTIFF'S INTERROGATORIES TO GARNISHEE TO: Integrity Bank, Garnishee: 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 Chronister Landscapes, Inc. any money or were you liable to them on any negotiable or other written instrument, or did they claim that you owed them any money or were liable to them for any reason? 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 part by Chronister Landscapes, Inc.? 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 Chronister Landscapes, Inc. or in which Chronister Landscapes, Inc. 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 Chronister Landscapes, Inc. had an interest. 5. At any time before or after you were served did Chronister Landscapes, Inc. 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? 6. At any time after you were served did you pay, transfer or deliver any money or property to Chronister Landscapes, Inc. or to any person or place pursuant to their direction or otherwise discharge any claim of Chronister Landscapes, Inc. against you? YOFFE & YOFFE, P.C. Date: December 9, 2008 By FA?IA , J - - RE N. YO , ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe@ verizon. net m J 7:-T` I NI) O A.H. REIF LANDSCAPE SUPPLY : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : Amount due $12,235.88 :Interest $ from 11/17/08 to date of sale Atty's Comm $ and Costs to be added $ CHRONISTER LANDSCAPES, INC. Defendant : Case No. 08-5052 PRAECIPE TO VOLUNTARILY WITHDRAW AND VOLUNTARILY DISCONTINUEINTERROGATORIES To: The Cumberland County Prothonotary Please mark as voluntarily withdrawn and voluntarily discontinued the interrogatories which were filed in this case by Plaintiff. YOFFE & YOFFE, P.C. Date: December 22, 2008 By r? FFFREY N. YOFFE; ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 t??ry ?r 3'? ?; ?3 Ca= :i ?`1 3 ? J ??},r ? ID /a m e x) deal WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5052 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due A. H. REIF LANDSCAPE SUPPLY, Plaintiff (s) From CHRONISTER LANDSCAPES, INC., 1000 W. Foxcroft Drive, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property of Defendant . (2) You are also directed to attach the property of the defendant(s) not levied upon in the ossession of I t y 'e i f y /J,4 ,v C 3 3 3,S /V7 ,q R k'e.f STRee? , ?? 4'P 44 / / 7a l/ GARNISHEE(S) as follows: n?1 A / ! A CC;; ?i 7'S p ? Oe tC Nail R 'vt h e Id. q 1- 1"n. t2? /F? 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 $12,235.88 Interest from 11/17/08 to date of sale Atty's Comm % Arty Paid $220.59 Plaintiff Paid Date: 11/17/08 L.L. $.50 Due Prothy $2.00 Other Costs to be added (Seal) REQUESTING PARTY: Name JEFFREY N. YOFFE, ESQUIRE Address: YOFFE & YOFFE, P.C. 214 SENATE AVE, SUITE 404 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-975-1838 Supreme Court ID No. 52933 r a u 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: Advance Costs: 275.00 Sheriff's Costs: 178.11 Docketing 36.00 96.89 Poundage 3.49 Law Library .50 Refunded on 06/16/09 Prothonotary 2.00 Mileage 55.40 Surcharge 30.00 Levy 40.00 Postage 1.72 Garnishee 9.00 So Answers, $ 178.11 ??Jiq/aq `?. ??' 14-100, R. omas Kline, Sheriff B Sharon R. Lantz AQ? 5 Z 01 b 8 I AON 8000 S: Vd 'A { ,L ri